THE MEMBERS OF
ANKIT METAL & POWER LIMITED
Report on the Audit of Financial Statements
We have audited the accompanying Financial Statements of ANKIT METAL & POWERLIMITED ("the Company") which comprise the Balance Sheet as at 31st March2019 the Statement of Profit and Loss (including Other Comprehensive Income) theStatement of Changes in Equity and the Statement of Cash Flows for the year then ended anda summary of significant accounting policies and other explanatory information(hereinafter referred to as "the Financial Statements").
In our opinion and to the best of our information and according to the explanationsgiven to us except for the possible effect of matter described in the basis forqualified opinion section of our report the aforesaid Financial Statements give theinformation required by the Companies Act 2013 (the Act") in the manner sorequired and give a true and fair view in conformity with the Indian Accounting Standardsprescribed under Section 133 of the Act read with the Companies (Indian AccountingStandards) Rules 2015 as amended ("Ind AS") and other accounting principlesaccepted in India of the state of affairs of the Company as at 31st March 2019 and theloss including Other Comprehensive Income the Statement of Changes in Equity and its CashFlow Statement for the year ended on that date.
Basis for Qualified Opinion
We draw your attention to note no. 28 of the accompanying Financial Statementsregarding non provision of interest expense on the borrowings of the Company amounting toर 12297.85 Lacs for the year ended 31st March 2019 (cumulative non provision of र39937.90 Lacs and penal interest and charges thereof (amount remaining unascertained)which is not in accordance with the requirements of Ind AS 23: Borrowing Costs read withInd AS 109: Financial Instruments. During the period the Company has also reversedinterest amounting to र 2229.95 Lacs relating to earlier period.
Had the aforesaid interest expense been recognized the finance cost for the year ended31st March 2019 would have been र 14793.40 Lacs instead of reported amount of र 265.60Lacs. The total expenses for the year ended 31st March 2019 would have been र 64673.50Lacs instead of र 50145.70 Lacs. The Net Loss after tax for the year ended 31st March2019 would have been र 23754.30 Lacs instead of reported amount of र 9226.50 Lacs. TotalComprehensive Loss for the year ended 31st March 2019 would have been र 23761.29 Lacsinstead of reported amount of र 9233.49 Lacs. Other equity as on 31st March 2019 wouldhave been र (112341.08) Lacs instead of reported amount of र (72403.18) Lacs and OtherCurrent Financial Liability as on 31st March 2019 would have been र 85451.95 Lacsinstead of reported amount of र 45514.05 Lacs.
We conducted our audit of the Financial Statements in accordance with the Standards onAuditing (SAs) specified under section 143(10) of the Act. Our responsibilities underthose Standards are further described in the Auditor's Responsibilities for the Audit ofthe Financial Statements section of our report. We are independent of the Company inaccordance with the Code of Ethics issued by the Institute of Chartered Accountants ofIndia (ICAI) together with the independence requirements that are relevant to our audit ofthe Financial Statements under the provisions of the Act and the Rules made thereunderand we have fulfilled our other ethical responsibilities in accordance with theserequirements and the ICAI's Code of Ethics. We believe that the audit evidence we haveobtained is sufficient and appropriate to provide a basis for our qualified opinion on thefinancial statements.
Material uncertainty relating to Going Concern
We draw your attention to note no. 29 of the Financial Statements regarding preparationof the Financial Statements on going concern basis for the reason mentioned therein. TheCompany has accumulated losses during year ended 31st March 2019. As on date theCompany's current liabilities are substantially higher than its current assets and networth has also been fully eroded. These conditions indicate the existence of a materialuncertainty that may cast significant doubt on the Company's ability to continue as goingconcern. The appropriateness of assumption of going concern is critically dependent uponthe debt resolution of the Company which is under process the Company's ability to raiserequisite finance generation of cash flows in future to meet its obligation and to earnprofit in future.
Key Audit Matters
Key Audit Matters are those matters that in our professional judgment were of mostsignificance in our audit of the financial statements of the current period. These matterswere addressed in the context of our audit of the financial statements as a whole and informing our opinion thereon and we do not provide a separate opinion on these matters.
We have determined the matters described below to be the key audit matters to becommunicated in our report.
|Sl. No. Key Audit Maer How our audit addressed the Key Audit Maer || |
| || |
|1 Accuracy of recognion measurement presentaon and disclosures of revenues and other related balances in view of adopon of Ind AS 115 "Revenue from Contracts with Customers" (new revenue accounng (standard) w.e.f. 1st April 2018 ||Our audit procedures included the following: |
|The applicaon of the new revenue accounng standard involves certain key judgements relang to idenficaon of disnct performance obligaons determinaon of transacon price of the idenfied performance obligaons the appropriateness of the basis used to measure revenue recognized over a period. ||We have assessed the Company's process to idenfy the impact of adopon of the new revenue accounng standard. Our audit approach consisted tesng of the design and operang effecveness of the internal controls and substanve tesng as follows : |
| || Evaluated the design of internal controls relang to recording of efforts incurred and esmaon of efforts required to complete the performance obligaons. |
|Addionally new revenue accounng standard || |
|contains disclosures which involves collation of information in respect of disaggregated revenue and periods over which the remaining performance obligations will be sasfied subsequent to the balance sheet date. || Selected a sample of contracts and through inspection of evidence of performance of these controls tested the operating effectiveness of the internal controls relating to efforts incurred and estimated. |
|2 Claim and exposure relang to taxaon and ligation The Company has material uncertain tax posions including maers in respect of disputed claims/ levies under various taxes and legal maers. The taxes and ligaon exposures have been idenfied as key audit maer due to: ||Our audit procedures included the following: |
| ||Our audit procedures include the following substanve procedures: |
| || Obtained understanding of key uncertain tax posions; |
| || We have reviewed and analysed key correspondences relang to dispute; |
|i. Ligaon cases require significant judgement due to complexity of the case and involvement of various authories. || We have discussed the maer for key uncertain tax posions with appropriate senior management; |
|ii. These involve significant management judgment to determine the possible outcome of the uncertain tax posions. || We have evaluated management's underlying key assumpons in esmang the tax provisions; and assessed management's esmate of the possible outcome of the disputed cases. |
Emphasis of Matter
i. As referred in note no. 32 of the Financial Statements the balance of TradeReceivables Advances Trade Payables etc. includes balances remaining outstanding for asubstantial period. The balances are subject to confirmations and reconciliation. Thereported Financials might have consequential impact which remains unascertained
ii. As referred in note no. 27 of the Financial Statements various credit facilitiesavailed from UBI IOB SBI IDBI and Allahabad Bank have been assigned by the respectivebanks in favour of Asset Reconstruction Companies under various assignment agreementsbetween the respective banks and Asset Reconstruction Companies. In absence of informationabout the terms of assignments the company is carrying the various credit facilities asappearing in the books and as per the previous terms with the respective banks. This mayhave consequential impact on the reported financials.
Our report is not modified in these matters.
Information other than the Financial Statements and Auditor's Report thereon
The Company's Board of Directors is responsible for the preparation of the otherinformation. The other information comprises the information included in the Company'sAnnual Return but does not include the Financial Statements and our Auditor's reportthereon.
Our opinion on the Financial Statements does not cover the other information and we donot express any form of assurance conclusion thereon.
In connection with our audit of the Financial Statements our responsibility is to readthe other information and in doing so consider whether the other information ismaterially inconsistent with the Financial Statements or our knowledge obtained during thecourse of our audit or otherwise appears to be materially misstated.
If based on the work we have performed we conclude that there is a materialmisstatement of this other information we are required to report that fact. We havenothing to report in this regard.
Responsibility of the Management for the Financial Statements
The Company's Board of Directors is responsible for the matters stated in section134(5) of the Companies Act 2013 ("the Act") with respect to the preparation ofthe Financial Statements that give a true and fair view of the financial positionfinancial performance including Other Comprehensive Income the Statement of Changes inEquity and Cash Flow Statement in accordance with the Ind AS and other accountingprinciples generally accepted in India. This responsibility also includes maintenance ofadequate accounting records in accordance with the provisions of the Act for safeguardingof the assets of the Company and for preventing and detecting frauds and otherirregularities; selection and application of appropriate implementation and maintenance ofaccounting policies; making judgments and estimates that are reasonable and prudent; anddesign implementation and maintenance of adequate Internal Financial Controls that wereoperating effectively for ensuring the accuracy and completeness of the accountingrecords relevant to the preparation and presentation of the Financial Statements thatgive a true and fair view and are free from material misstatement whether due to fraud orerror.
In preparing the financial statements management is responsible for assessing theCompany's ability to continue as a going concern disclosing as applicable mattersrelated to going concern and using the going concern basis of accounting unless managementeither intends to liquidate the Company or to cease operations or has no realisticalternative but to do so.
Those Board of Directors are also responsible for overseeing the Company's financialreporting process.
Auditor's Responsibilities for the Audit of the Financial Statements
Our objectives are to obtain reasonable assurance about whether the FinancialStatements as a whole are free from material misstatement whether due to fraud or errorand to issue an Auditor's Report that includes our opinion. Reasonable assurance is a highlevel of assurance but is not a guarantee that an audit conducted in accordance with SAswill always detect a material misstatement when it exists. Misstatements can arise fromfraud or error and are considered material if individually or in the aggregate theycould reasonably be expected to influence the economic decisions of users taken on thebasis of these Financial Statements.
As part of an audit in accordance with SAs we exercise professional judgment andmaintain professional skepticism throughout the audit. We also:
Identify and assess the risks of the material misstatement of the FinancialStatement whether due to fraud or error design and perform audit procedures responsiveto those risks and obtain audit evidence that is sufficient and appropriate to provide abasis for our opinion. The risk of not detecting a material misstatement resulting fromfraud is higher than for one resulting from error as fraud may involve collusionforgery intentional omissions misrepresentations or the override of internal control.
Obtain an understanding of internal financial controls relevant to the audit inorder to design audit procedures that are appropriate in the circumstances. Under section143(3)(i) of the Companies Act 2013 we are also responsible for expressing our opinionon whether the Company has adequate internal financial controls system in place and theoperating effectiveness of such controls.
Evaluate the appropriateness of accounting policies used and the reasonablenessof accounting estimates and related disclosures made by the management.
Conclude on the appropriateness of management's use of the going concern basisof accounting and based on the audit evidence obtained whether a material uncertaintyexists related to events or conditions that may cast significant doubt on the Company'sability to continue as a going concern. If we conclude that a material uncertainty existswe are required to draw attention in our auditor's report to the related disclosures inthe Financial Statements or if such disclosures are inadequate to modify our opinion.Our conclusions are based on the audit evidence obtained up to the date of our Auditor'sreport. However future events or conditions may cause the Company to cease to continue asa going concern.
Evaluate the overall presentation structure and content of the FinancialStatements including the disclosures and whether the Financial Statements represent theunderlying transactions and events in a manner that achieves fair presentation.
Materiality is the magnitude of misstatements in the Standalone Financial Statementsthat individually or in aggregate makes it probable that the economic decisions of areasonably knowledgeable user of the Financial Statements may be influenced. We considerquantitative materiality and qualitative factors in (i) planning the scope of our auditwork and in evaluating the results of our work; and (ii) to evaluate the effect of anyidentified misstatements in the Financial Statements.
We communicate with those charged with governance regarding among other matters theplanned scope and timing of the audit and significant audit findings including anysignificant deficiencies in internal control that we identify during our audit.
Independent Auditors' Report
We also provide those charged with governance with a statement that we have compliedwith relevant ethical requirements regarding independence and to communicate with themall relationships and other matters that may reasonably be thought to bear on ourindependence and where applicable related safeguards.
From the matters communicated with those charged with governance we determine thosematters that were of most significance in the audit of the Financial Statements of thecurrent period and are therefore the key audit matters. We describe these matters in ourauditor's report unless law or regulation precludes public disclosure about the matter orwhen in extremely rare circumstances we determine that a matter should not becommunicated in our report because the adverse consequences of doing so would reasonablybe expected to outweigh the public interest benefits of such communication.
Report on Other Legal and Regulatory Requirements
As required by the Companies (Auditors Report) Order 2016 ('the order') issued by theCentral Government of India in terms of sub-section (11) of section 143 of the Act wegive in the "Annexure A" a statement on the matters specified in the paragraphs3 and 4 of the order to the extent applicable.
I. As required by section 143(3) of the Act we report that:
a. Except for the possible effects of the matters described in the basis of qualifiedopinion section of our report we have sought and obtained all the information andexplanations which to the best of our knowledge and belief were necessary for the purposeof our audit;
b. Except for the possible effects of the matters described in the basis of qualifiedopinion section of our report in our opinion proper books of account as required by lawhave been kept by the Company so far as it appears from our examination of those books;
c. The Balance Sheet Statement of Profit and Loss including Other ComprehensiveIncome the Statement of Changes in Equity and the Cash Flow Statement dealt with by thisReport are in agreement with the books of accounts.
d. Except for the effects of the matters described in the basis of qualified opinionparagraph above in our opinion the aforesaid Financial Statements comply with the IndianAccounting Standards specified under section 133 of the Act read with Rule 7 of theCompanies (Accounts) Rules 2014.
e. The matter described in the basis for qualified opinion section of our report mayhave adverse effect on the functioning of the company.
f. On the basis of written representations received from the directors as on 31stMarch 2019 and taken on record by the Board of Directors none of the directors isdisqualified as on 31st March 2019 from being appointed as a director in terms ofsection 164(2) of the Act.
g. With respect to the adequacy of the Internal Financial Controls over FinancialReporting of the Company and the operating effectiveness of such controls refer to ourseparate Report in "Annexure B".
h. With respect to the other matters to be included in the Auditor's Report inaccordance with the requirements of section 197(16) of the Act as amended :
In our opinion and to the best of our information and according to the explanationsgiven to us the remuneration payable by the Company to its directors during the year isin accordance with the provisions of section 197 of the Act.
i. With respect to the other matters to be included in the Auditor's Report inaccordance with Rule 11 of the Companies (Audit and Auditors) Rules 2014 in our opinionand to the best of our information and according to the explanations given to us:
i) The Company has disclosed the impact of pending litigations on the financialposition in the Ind AS Financial Statements - Refer note no. 30 (a) to (f) to its Ind ASFinancial Statements.
ii) The Company did not have any long term contracts including derivative contracts forwhich there were any material foreseeable losses.
iii) There were no amounts which were required to be transferred to the InvestorEducation and Protection Fund by the Company.
| ||For J.B.S & Company |
| ||Chartered Accountants |
| ||FRN:323734E |
| ||C.A. Gouranga Paul |
|Place: Kolkata ||Partner |
|Date: : 1st day of June 2019 ||Membership No.063711 |
Annexure A to the Independent Auditors' Report
The Annexure A referred to in paragraph 1 under the heading 'Report on Other Legal& Regulatory Requirements' of our report of even date to the Ind AS FinancialStatements of the Company for the year ended 31st March 2019 we report that:
(i) (a) The Company is maintaining proper records showing full Particulars includingquantitative details and situation of property plant and equipment.
(b) The property plant and equipment of the Company have been physically verified bythe management at reasonable intervals and no material discrepancies were noticed on suchverification.
(c) According to the information and explanations given to us and on the basis of ourexamination of the records of the Company the title deeds of freehold immovableproperties are held in the name of the Company. The Leasehold deeds of immovableproperties are in the name of Company.
(ii) The inventory has been physically verified by the management at reasonableintervals. In our opinion the frequency of such verification is reasonable. Thediscrepancies noticed on verification between the physical stocks and the book recordswere not material having regard to the size of the operations of the Company and the samehave been properly dealt with in the books of account.
(iii) The Company has not granted any loans secured or unsecured to Companies Firmsor other parties listed in the register maintained under section 189 of the Companies Act2013. Therefore the reporting under Paragraph 3 (iii) of the said order is not applicableto the Company.
(iv) In our opinion and according to the information and explanations given to us theCompany has complied with the provisions of section 185 and 186 of the Companies Act 2013in respect of grant of loans making investments and providing guarantees and securitiesas applicable.
(v) The Company has not accepted any deposits from the public and consequently thedirectives issued by Reserve Bank of India and provisions of section 73 to section 76 orany other relevant provisions of the Companies Act 2013 and the Companies (Acceptance ofDeposit) Rules 2015 with regard to the deposits accepted from the public are notapplicable to the Company.
(vi) We have broadly reviewed the books of account maintained by the Company in respectof manufacture of Iron & Steel product & Power generation unit pursuant to theRules made by the Central Government for the maintenance of cost records under section148(1) of the Companies Act 2013 and we are of the opinion that prima facie the recordshave been maintained. We have however not made a detailed examination of the records witha view to determining whether they are accurate and complete.
(vii) (a) According to the information and explanations given to us and on the basis ofour examination of the books of account the Company has generally delayed in depositingundisputed statutory dues including Goods & Service Tax Provident Fund Income TaxSales Tax Service Tax Duty of Customs Value Added Tax Cess and other statutory duesduring the year with appropriate authorities.
(b) According to the information and explanations given to us no undisputed amountspayable in respect of the above were in arrears as at 31stMarch 2019 for aperiod of more than six months from the date on when they become payable except thefollowing:
|Sl. No. Nature of Dues ||Amount Involved (र in Lacs) |
|1. Income Tax Deducted at Source ||121.19 |
|2. Sales Tax Deducted at Source ||0.32 |
|3. Provident Fund ||88.70 |
|4. Service Tax ||370.62 |
|5. Excise Duty ||952.34 |
|6. Withholding Tax ||1.39 |
|7. Professional Tax on Salary ||0.42 |
|Total ||1543.97 |
(c) According to the information and explanations given to us there are no dues ofIncome Tax Goods & Services Tax Sales Tax Value Added Tax Service Tax CustomsDuty Excise Duty and Cess which have not been deposited with the appropriate authoritieson account of any dispute except the following cases:
|Name of the Statute ||Nature of Dues ||Amount (र in Lacs ) ||Period to which the amount relates ||Forum where the dispute is pending |
|Income Tax Act 1961 || |
|354.58 ||A. Y. 2008-09 ||Commissioner of Income Tax-Appeal (Kolkata) |
|41.39 ||A. Y. 2009-10 ||Commissioner of Income Tax-Appeal (Kolkata) |
|9299.55 ||A. Y. 2011-12 ||Commissioner of Income Tax-Appeal (Kolkata) |
|6692.78 ||A. Y. 2012-13 ||Income Tax Appellate Tribunal (ITAT) |
|5007.30 ||A. Y. 2013-14 ||Commissioner of Income Tax-Appeal (Kolkata) |
|7151.07 ||A.Y 2015-16 ||Commissioner of Income Tax-Appeal (Kolkata) |
|W.B. VAT Act 2003 || |
|222.89 ||F.Y. 2005-06 ||Sr. Joint Commissioner of Commercial Taxes Dharmtala Circle. |
|917.91 ||F.Y. 2006-07 ||Sr. Joint Commissioner of Commercial Taxes Dharmtala Circle. |
|92.94 ||F.Y. 2006-07 ||Joint Commissioner of Commercial Taxes Purulia Range |
|358.17 ||F.Y. 2007-08 ||Sr. Joint Commissioner of Commercial Taxes Dharmtala Circle. |
|87.95 ||F.Y. 2007-08 ||Joint Commissioner of Commercial Taxes Durgapur Range |
|1946.82 ||F.Y. 2008-09 ||Deputy Commissioner of Commercial Taxes |
|683.63 ||F.Y. 2014-15 ||Add. Commissioner of Commercial Taxes Dharamtala Circle |
|3068.82 ||F.Y. 2015-16 ||Special Commissioner of Commercial Taxes Dharamtala Circle |
|Entry Tax || |
|403.60 ||F.Y. 2012-13 ||Sr. Joint Commissioner of Commercial Taxes Dharamtala Circle |
|385.05 ||F.Y. 2013-14 ||Sr. Joint Commissioner of Commercial Taxes LTU Govt. of India |
|353.95 ||F.Y. 2014-15 ||Sr. Joint Commissioner of Commercial Taxes LTU Govt. of India |
|210.24 ||F.Y. 2015-16 ||Joint Commissioner of Commercial Taxes LTU Govt. of India |
|The Central Excise Act 1944 || |
|36.66 ||September 2007 and January 2008 ||CESTAT |
(15.00 paid as duty under protest)
|2011-12 ||CESTAT |
(5.00 paid as duty under protest)
|01.08.2011 to 08.08.2011 ||Commissioner of Central Excise- Bolpur |
|30.91 ||01.02.2012 to 27.12.2012 ||Commissioner Appeal Siliguri |
|75.74 ||2008- 2009 |
|132.60 ||2008- 2009 |
|73.42 ||August 2009 to February 2011 ||CESTAT |
|1809.48 ||2010-2014 ||DGCEI New Delhi |
|0.65 ||2010-11 ||Bolpur Commissionerate |
|59.36 ||2010-11 ||CESTAT |
|50.87 ||2015-16 ||CESTAT |
|4.51 ||2011-2012 ||Commissioner of Central Excise Kolkata-IV |
|984.17 ||2014-17 ||CESTAT |
|66.17 ||2013-14 ||Durgapur Commissionerate |
|156.41 ||2013-14 ||Durgapur Commissionerate |
|310.05 ||2012-13 ||CESTAT |
|Service Tax Rules 2012 ||Service |
|4.33 ||2007-08 ||Durgapur Commissionerate |
There were no other dues of duty which have not been deposited as at 31st March 2019on account of dispute.
(viii) Based upon the audit procedures performed and according to the records of theCompany examined by us and the information and explanation given to us the Company hasdefaulted in payment of interest and repayment of principal on borrowings to banks asfollows:
|(र in Lacs) |
|Parti culars ||Nature ||Principal ||Interest (Net of Reversal) ||Period of default |
|UCO Bank ||FITL ||486.00 ||109.60 ||October 15 to March 19 |
|Syndicate Bank ||126.00 ||90.93 ||October 15 to March 19 |
|Corporation Bank ||750.00 ||522.78 ||January 16 to March 19 |
|Financial Institution-ACRE ||6426.00 ||719.65 ||October 15 to March 19 |
|Financial Institution-RARE ||384.00 ||72.32 ||October 15 to March 19 |
|TOTAL ||8172.00 ||1515.28 || |
|UCO Bank ||WCTL-1 ||482.00 ||174.48 ||February 16 to March 19 |
|Syndicate Bank ||113.00 ||197.98 ||February 16 to March 19 |
|Corporation Bank ||3.00 ||4.46 ||March 16 to March 19 |
|Financial Institution-ACRE ||1764.00 ||748.61 ||December 15 to March 19 |
|Financial Institution-RARE ||35.00 ||12.52 ||November15 to March19 |
|TOTAL ||2397.00 ||1138.05 || |
|UCO Bank ||WCTL-2 ||185.00 ||71.42 ||February 16 to March 19 |
|Corporation Bank ||191.00 ||341.26 ||March 16 to March 19 |
|Financial Institution-ACRE ||2065.00 ||81.27 ||January 16 to March 19 |
|Financial Institution-RARE ||167.00 ||60.47 ||December 15 to March 19 |
|TOTAL ||2608.00 ||554.42 || |
|Corporation Bank ||TERM LOAN ||1238.00 ||- ||March17 to March 19 |
|Financial Institution-ACRE ||7620.00 ||2124.01 ||November 15 to March 19 |
|Financial Institution-RARE ||459.00 ||166.04 ||December 15 to March 19 |
|TOTAL ||9317.00 ||2290.05 || |
|GRAND TOTAL ||22494.00 ||5497.80 |
In absence of the settlement agreement with ARC (RARE & ACRE) the maturity periodis continued to be shown as per earlier terms with respective banks and outstanding amounttill March 2019 is shown as default and the un-provided liability amounting to '39937.90 Lacs as referred in note no. 28 of the Financial Statements also continued tobe a default. The Company does not have any loans and borrowings from Government and hasnot issued any debentures.
(ix) Based upon the audit procedures performed and the information and explanationsgiven by the management the Company has not raised moneys by way of initial publicissue/follow-on offer (including debt instruments) and term loans.
(x) Based upon the audit procedures performed and the information and explanationsgiven by the management we report that no fraud by the Company or on the Company by itsofficers or employees has been noticed or reported during the year.
(xi) Based upon the audit procedures performed and the information and explanationsgiven by the management the managerial remuneration has been paid or provided inaccordance with the requisite approvals mandated by the provisions of section 197 readwith Schedule V to the Companies Act 2013.
(xii) In our opinion and according to the information and explanations given to us theCompany is not a Nidhi Company. Therefore the reporting under Paragraph 3 (xii) of theOrder is not applicable to the Company.
(xiii) In our opinion and according to the information and explanations given to usall transactions with the related parties are in compliance with section 177 and 188 ofCompanies Act 2013 where applicable and the details have been disclosed in the Ind ASFinancial Statements as required by the applicable Accounting Standards.
(xiv) According to the information and explanation given to us and based on ourexamination of the records of the Company the Company has not made any preferentialallotment or private placement of shares of fully or partly convertible debentures andhence reporting under paragraph 3(xiv) of the order is not applicable to the Company.
(xv) Based upon the audit procedures performed and the information and explanationsgiven by the management the Company has not entered into any non-cash transactions withdirectors or persons connected with them. Accordingly the reporting under Paragraph 3(xv) of the order is not applicable to the Company and hence not commented upon.
(xvi) In our opinion the Company is not required to be registered under section 45 IAof the Reserve Bank of India Act 1934.
| ||For J.B.S & Company |
| ||Chartered Accountants |
| ||FRN:323734E |
| ||C.A. Gouranga Paul |
|Place: Kolkata ||Partner |
|Date: : 1st day of June 2019 ||Membership No.063711 |