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Ansal Housing Ltd.

BSE: 507828 Sector: Infrastructure
NSE: ANSALHSG ISIN Code: INE880B01015
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VOLUME 18927
52-Week high 17.55
52-Week low 3.52
P/E
Mkt Cap.(Rs cr) 40
Buy Price 6.68
Buy Qty 1000.00
Sell Price 6.66
Sell Qty 8268.00
OPEN 6.66
CLOSE 7.40
VOLUME 18927
52-Week high 17.55
52-Week low 3.52
P/E
Mkt Cap.(Rs cr) 40
Buy Price 6.68
Buy Qty 1000.00
Sell Price 6.66
Sell Qty 8268.00

Ansal Housing Ltd. (ANSALHSG) - Auditors Report

Company auditors report

To

The Members of Ansal Housing Limited

(Formerly known as Ansal Housing and Construction Limited)

Report on the Audit of the Standalone Financial Statements

Opinion

We have audited the accompanying standalone financial statements of Ansal HousingLimited (formerly known as Ansal Housing and Construction Limited) ("theCompany") which comprise the Balance Sheet as at 31st March 2019 and the Statementof Profit and Loss(including Other Comprehensive Income) Statement of Changes in Equityand the Statement of Cash Flows for the year then ended and notes to the financialstatements including a summary of significant accounting policies and other explanatoryinformation (hereinafter referred as ‘'Standalone Financial Statements").

In our opinion and to the best of our information and according to the explanationsgiven to us the aforesaid standalone financial statements give the information requiredby the Companies Act 2013 (‘'the Act'') in the manner so required and give a trueand fair view in conformity with the accounting principles generally accepted in India ofthe state of affairs (financial position) of the Company as at March 31 2019 and itsloss (financial performance including other comprehensive income) changes in equity andits cash flows for the year ended on that date.

Basis for Opinion

We conducted our audit in accordance with the Standards on Auditing (SAs) specifiedunder section 143(10) of the Companies Act 2013. Our responsibilities under thoseStandards are further described in the Auditor's Responsibilities for the Audit of theFinancial 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 together with the ethical requirements that are relevant to our audit of thestandalone financial statements under the provisions of the Companies Act 2013 and theRules thereunder and we have fulfilled our other ethical responsibilities in accordancewith these requirements and the Code of Ethics. We believe that the audit evidence we haveobtained is sufficient and appropriate to provide a basis for our opinion.

Emphasis of Matter

a. Attention is invited to Note 42 to the standalone financial statements regardingcompany's investment of Rs. 491.67 lakh in a wholly owned subsidiary company in Sri Lankaby way of equity shares. The subsidiary company had filed an arbitration claim against theBoard of Investment of Sri Lanka (BOI) which has been withdrawn during the year andcompany gone for settlement. The BOI has terminated the agreements for development ofintegrated township in Sri Lanka between the subsidiary and the BOI. During the year themanagement of the subsidiary company has written off all assets. Now the subsidiarycompany does not have enough assets to redeem the said investment but management of thecompany is of the opinion that they will be able to redeem the said investment through thesettlement and write down of Investment is not required at this stage.

b. We draw attention to Note 1.19 & 33 to the standalone financial statements whichdescribe the uncertainty relating to the outcome of certain matters pending in litigationwith Courts/Appellate Authorities pending the final outcome of the aforesaid matterswhich is presently unascertainable no adjustments have been made in these standalonefinancial statements.

Our opinion is not modified in respect of these matters.

Key Audit Matters

Key audit matters are those matters that in our professional judgment were of mostsignificance in our audit of the standalone financial statements of the current period.These matters were addressed in the context of our audit of the standalone financialstatements as a whole and in forming our opinion thereon and we do not provide aseparate opinion on these matters.

We have determined the matters described below to be the key audit matters to becommunicated in our report.

The key audit matter How our audit addressed the key audit matter
Adoption of Ind AS 115 – Revenue from Contracts with Customers
As described in Note 1.4 to the standalone financial statements the Company has adopted Ind AS 115 Revenue from Contracts with Customers (‘Ind AS 115') which is the new revenue accounting standard. The application and transition to this accounting standard is complex and is an area of focus in the audit. Our audit procedures on adoption of Ind AS 115 Revenue from contracts with Customers (‘Ind AS 115') which is the new revenue accounting standard include –
• Evaluated the design and implementation of the processes and internal controls relating to implementation of the new revenue accounting standard;
The revenue standard establishes a comprehensive framework for determining whether how much and when revenue is recognized. This involves certain key judgments relating to identification of distinct performance obligations determination of transaction price of identified performance obligation the appropriateness of the basis used to measure revenue recognized over a period. Additionally the standard mandates robust disclosures in respect of revenue and periods over which the remaining performance obligations will be satisfied subsequent to the balance sheet date. • Evaluated the detailed analysis performed by management on revenue streams by selecting samples for the existing contracts with customers and considered revenue recognition policy in the current period in respect of those revenue streams;
• Evaluated the cumulative effect adjustments as at 1 April 2018 for compliance with the new revenue standard; and
• Evaluated the appropriateness of the disclosures provided under the new revenue standard and assessed the completeness and mathematical accuracy of the relevant disclosures.
Assessing the carrying value of Inventory
The Company's inventory comprise of ongoing and completed real estate projects Land fiats Farm Land Building materials • etc. As at 31 March 2019 the carrying values of inventories amounts to Rs. 193652.86 lakh. Our audit procedures/ testing included among others:
We read and evaluated the accounting policies and disclosures made in the financial statements with respect to inventories;
The inventories are carried at the lower of the cost and net realizable value (‘NRV'). The determination of the NRV involves estimates based on prevailing market conditions current prices and expected date of commencement and completion of the project the estimated future selling price cost to complete projects and selling costs. • We understood and reviewed the management's process and methodology of using key assumptions for determination of NRV of the inventories;
• We have tested the NRV of the inventories to its carrying value in books on sample basis.
Considering significance of the amount of carrying value of inventories in the financial statements and the involvement of significant estimation and judgement in such assessment of NRV the same has been considered as key audit matter.
Evaluation of uncertain tax positions
The company has material uncertain tax positions including matters under dispute which involves significant judgment determine the possible outcome of these disputes. Our audit procedures include the following substantive to procedures:
Refer Note no. 33 of the standalone financial statements. • Obtained understanding of key uncer tain tax positions
• Analysed the all correspondence for uncertain key tax positions; and
• Discussed with appropr iate senior management and evaluate the management key assumptions in estimates of tax provisions where required.

Other Information

The Company's Board of Directors is responsible for the preparation of the otherinformation. The other information comprises the information included in the ManagementDiscussion & Analysis Board's Report including Annexures to Board's Report BusinessResponsibility Report Corporate Governance and Shareholder's Information but does notinclude the standalone financial statements and our auditor's report thereon.

Our opinion on the standalone financial statements does not cover the other informationand we do not express any form of assurance conclusion thereon. In connection with ouraudit of the standalone financial statements our responsibility is to read the otherinformation and in doing so consider whether the other information is materiallyinconsistent with the standalone financial statements or our knowledge obtained in theaudit or otherwise appears to be materially misstated. If based on the work we haveperformed we conclude that there is a material misstatement of this other information weare required to report that fact. We have nothing to report in this regard.

Responsibility of Management for Standalone 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 ofthese standalone financial statements that give a true and fair view of the financialposition financial performance changes in equity and cash flows of the Company inaccordance with the accounting principles generally accepted in India including theAccounting Standards specified under section 133 of the Act. This responsibility alsoincludes maintenance of adequate accounting records in accordance with the provisions ofthe Act for safeguarding of the assets of the Company and for preventing and detectingfrauds and other irregularities; selection and application of appropriate implementationand maintenance of accounting policies; making judgments and estimates that are reasonableand prudent; and design implementation and maintenance of adequate internal financialcontrols that were operating effectively for ensuring the accuracy and completeness ofthe accounting records relevant to the preparation and presentation of the standalonefinancial statements that give a true and fair view and are free from materialmisstatement whether due to fraud or error.

In preparing the standalone financial statements management is responsible forassessing the Company's ability to continue as a going concern disclosing as applicablematters related to going concern and using the going concern basis of accounting unlessmanagement either intends to liquidate the Company or to cease operations or has norealistic alternative but to do so. The Board of Directors are also responsible foroverseeing the company's financial reporting process.

Auditor's Responsibilities for the Audit of the Financial Statements

Our objectives are to obtain reasonable assurance about whether the standalonefinancial statements as a whole are free from material misstatement whether due to fraudor error and to issue an auditor's report that includes our opinion. Reasonable assuranceis a high level of assurance but is not a guarantee that an audit conducted in accordancewith SAs will always detect a material misstatement when it exists. Misstatements canarise from fraud or error and are considered material if individually or in theaggregate they could reasonably be expected to influence the economic decisions of userstaken on the basis of these standalone 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 material misstatement of the financialstatements 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 control relevant to the audit in order todesign audit procedures that are appropriate in the circumstances. Under section 143(3)(i)of the Companies Act 2013 we are also responsible for expressing our opinion on whetherthe company has adequate internal financial controls system in place and the operatingeffectiveness of such controls.

• Evaluate the appropriateness of accounting policies used and the reasonablenessof accounting estimates and related disclosures made by 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 standalonefinancial statements including the disclosures and whether the standalone financialstatements represent the underlying transactions and events in a manner that achieves fairpresentation. We communicate with those charged with governance regarding among othermatters the planned scope and timing of the audit and significant audit findingsincluding any significant defficiencies in internal control that we identify during ouraudit. We also provide those charged with governance with a statement that we havecomplied with relevant ethical requirements regarding independence and to communicatewith them all relationships and other matters that may reasonably be thought to bear onour independence 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 standalone financial statementsof the current period and are therefore the key audit matters. We describe these mattersin our auditor's report unless law or regulation precludes public disclosure about thematter or when 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.

Other Matter

Attention is invited to Note 1.19 (a) & (b) of standalone Financial Statements thestatus of various ongoing projects recognition of expense and income and the realizablevalue of the costs incurred are as per the judgment of Management of the Company andcertified by their technical personnel and being of technical nature have been reliedupon by us. Our opinion is not modified in respect of these matters.

Report on Other Legal and Regulatory Requirements

1. As required by the Companies (Auditor's Report) Order 2016 ("the Order")issued by the Central Government of India in terms of sub-section (11) of section 143 ofthe Companies Act 2013 we give in the "Annexure A" statement on the mattersspecified in paragraphs 3 and 4 of the Order to the extent applicable.

2. As required by Section 143(3) of the Act we report that:

(a) We have sought and obtained all the information and explanations which to the bestof our knowledge and belief were necessary for the purposes of our audit.

(b) In our opinion proper books of account as required by law have been kept by theCompany so far as it appears from our examination of those books.

(c) The Balance Sheet the Statement of Profit and Loss and the Cash Flow Statementand Statement of Changes in Equity dealt with by this Report are in agreement with thebooks of account.

(d) In our opinion the aforesaid standalone financial statements comply with theIndian Accounting Standards specified under Section 133 of the Act read with Rule 7 ofthe Companies (Accounts) Rules 2014.

(e) On the basis of the written representations received from the directors as on 31stMarch 2019 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 of Section164 (2) of the Act.

(f) 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".

(g) 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 its financialposition in its standalone financial statements – Refer Note 33 to the standalonefinancial statements;

ii. The Company has made provision as required under the applicable law or accountingstandards for material foreseeable losses if any on long-term contracts. Further thecompany did not have any derivative contract.

iii. There has been no delay in transferring amounts required to be transferred tothe Investor Education and Protection Fund by the Company.

ANNEXURE-A TO THE INDEPENDENT AUDITORS' REPORT

(Referred to in paragraph - 1 under the heading of "Report on Other Legal andRegulatory Requirements" of our Report of even date)

Based on the audit procedures performed for the purpose of reporting a true and fairview on the standalone financial statements of the Company and taking into considerationthe information and explanations given by the management and the books of account andother records examined by us in the normal course of audit and to the best of ourknowledge and belief we report that:-

(i) (a) The company has maintained proper records showing full particulars includingquantitative details and situation of Property Plant and Equipment.

(b) As explained to us the Property Plant and Equipment have been physically verifiedby the management in accordance with a regular programme of verification which in ouropinion is reasonable having regard to the size of the Company and nature of its assets.According to the information and explanations given to us no material discrepancies werenoticed on such physical verification.

(c) The title deeds of immovable properties including in Property Plant and Equipmentof the company are held in the name of the Company except as stated in Note- 2 of thefinancial statement.

(ii) The inventory of building materials stores and spares restaurant's provisionsbeverages etc. land and fiats/ shops/houses etc. at major locations has been physicallyverified during the year by the management. In our opinion the frequency of verificationis reasonable. According to the information and explanations given to us keeping in viewthe nature of the operations of the company inventory of work-in-progress cannot bephysically verified. As explained to us there was no material discrepancies noticed onphysical verification of inventory.

(iii) The company has not granted loans secured or unsecured to companies firmslimited liability partnerships or other parties covered in the register maintained undersection 189 of the Companies Act 2013. Therefore the provisions of Clause 3(iii)(a)(b)and (c) of the said Order are not applicable to the company.

(iv) In our opinion in respect of loans investments guarantees and securityprovisions of section 185 and 186 of the Companies Act 2013 have been complied with.

(v) During the previous year the company approached the National Company Law Tribunal(NCLT) New Delhi under section 74(2) of the companies act 2013 seeking approval forextension of time to repay the deposits which was received vide NCLT's order dated 3rdOctober 2016. The total outstanding deposits at the time of Company's application to theNCLT amounting to Rs. 8457.47 Lakh are generally being repaid by the company as per theterms of NCLT Orders though there are some overdue amounts. However the NCLT vide itsorder dated 1st December2017 has permitted to pay Rs. 125.00 Lakh per month includinghardship cases and same scheme has been extended by NCLT till May 2019 vide its latestorder dated 25.04.2019. The Company is in the process of complying with the above NCLTorders (Refer Note No 16.6 of the standalone financial statements). Further in our opinionand according to the information and explanations given to us the provision of sections73 to 76 or any other relevant provisions of Companies Act 2013 and the rules framedthereunder wherever applicable have been complied with by the Company.

(vi) We have broadly reviewed the books of account maintained by the company pursuantto the Rules made by the Central Government for the maintenance of cost records undersection 148 of the Act and are of the opinion that prima facie the prescribed accountsand records have been made and maintained. However we have not nor we are requiredcarried out details examination of such accounts and records

(vii) (a) On the basis of our examination of the records of the company amountsdeducted/accrued in the books of account in respect of undisputed statutory dues includingprovident fund employees' state insurance income-tax Goods and Services tax sales-taxservice tax duty of customs duty of excise value added tax cess and any otherstatutory dues have not been regularly deposited during the year by the company with theappropriate authorities and there have been delay in a large number of cases. We areinformed that the Company's operations during the year did not give rise to any liabilityfor custom duty and excise duty.

In our opinion no undisputed amounts were in arrears as at 31 March 2019 for a periodof more than six months from the date they became payable except the following dues:-

Name of the Statute Nature of dues Amount Period to which (Rs. In Lakh) the amount relates Due Dates Date of Payments Remarks
Haryana VAT Act. Value Added Tax (including interest) 960.51 Apr 14 – June 17 Monthly Unpaid -
Building and Other Construction Workers Act Labour Cess 583.45 Upto March 19 Yearly Unpaid -
Income Tax Tax deducted at source 57.16 March 18 & August 18 Monthly Unpaid -

(b) On the basis of our examination of the books of accounts and records the detailsof the dues of income tax or sales tax or service tax or duty of customs or duty of exciseor value added tax or cess which have not been deposited on account of any dispute are asunder:-

Name of the Statute Nature of dues Amount(Rs. In Lakh) Period to which the amount relates Forum where dispute is pending
Income Tax Act Income tax 847.99 AY 1989-90 to 1997-98 & 2002-03 to 2006-07 Supreme Court
Income Tax Act Income tax 5.69 AY 2008-09 Income Tax Appellate Tribunal (Delhi)
Income Tax Act Income tax and Penalty 500.56 AY 2004-05 to 2006-07 & 2013-14 to 2016-17 Commissioner of Income Tax (Appeals) New Delhi
UP Sales Tax Act Sales Tax 76.13 Assessment Years 2004-05 to 2006-07 Tribunal Commercial Tax Ghaziabad
UP Value Added Tax Act Sales Tax 304.76 Assessment Years 2007-08 to 2013-14 Tribunal Commercial Tax Ghaziabad
MP Value Added Tax Act Sales Tax 5.00 Assessment Year 2008-09 Tribunal Commercial Tax Bhopal
Employees Provident Fund Act Provident Fund 33.39 June 1994 to March 2006 Delhi High Court

(viii) On the basis of our examination of the books of accounts and records andexplanations given to us we are of the opinion that the Company has defaulted in therepayment of dues including interest to banks and financial institutions covered by theOrder during the year. While there were delays in repayment on different occasions duringthe year the relevant amounts have been paid to the respective banks and financialinstitutions during the year or loans have been restructured during the year. The defaultwhich have remained outstanding at the year-end are given below:

Particulars Amount of default as on Balance Sheet Date (Rs. In Lakh) Period of Default
Principal Interest Principal Interest
Due to Financial Institutions:
- HDFC Ltd. 870.23 388.71 30 to 60 Days 30 to 90 Days
- IFCI Ltd. 176.51 403.38 30 to 136 Days 30 to 136 Days
- India Bulls Commercial Credit Ltd. - 439.97 30 to 98 Days

(ix) In our opinion the Company did not raise any money by way of initial public offeror further public offer (including debt instruments) during the year and term loansobtained for financing real estate projects in our opinion were used for the real estateprojects on an overall basis.

(x) In our opinion no material fraud by the company or on the Company by its officersor employees has been noticed or reported during the course of our audit.

(xi) In our opinion and according to the information & explanations given to us andbased on our examination of the records of the company Managerial remuneration has notbeen paid or provided in accordance with the requisite approvals mandated by theprovisions of section 197 read with schedule V to the Companies Act. The details are asunder:

a) The Chairman and managing director (CMD) was paid a total remuneration of Rs. 19.75Lakh during the year.

b) The amount so paid to him is refundable to the Company within a period of 2 yearsfrom the receipt of such money i.e. by the month of May 2020 as per the requirements ofSection 197(9) of the Companies Act 2013.

c) The remuneration till the time refunded held by him in trust for the Company.

(xii) In our opinion the Company is not a nidhi company. Hence paragraph 3(xii) ofthe Order is not applicable.

(xiii) Based on our examination of the records of the Company and in our opiniontransactions with the related parties are in compliance with sections 177 and 188 of theAct where applicable and details of such transactions have been disclosed in thestandalone financial statements as required by the applicable Indian accounting standards.

(xiv) Based on our examination of the records of the Company the Company has not madeany preferential allotment or private placement of shares or fully or partly convertibledebentures during the year and hence not commented upon.

(xv) Based on our examination of the records of the Company the Company has notentered into non-cash transactions with directors or persons connected with him.

(xvi) Based on our examination of the records of the Company the Company is notrequired to be registered under section 45-IA of the Reserve Bank of India Act 1934.

ANNEXURE – B TO THE INDEPENDENT AUDITOR'S REPORT OF EVEN DATE ON THE STANDALONEFINANCIAL STATEMENTS OF ANSAL HOUSING LIMITED (FORMERLY KNOWN AS ANSAL HOUSING ANDCONSTRUCTION LIMITED) Report on the Internal Financial Controls under Clause (i) ofSub-section 3 of Section 143 of the Companies Act 2013 ("the Act")

We have audited the internal financial controls over financial reporting of AnsalHousing Limited (Formerly known as Ansal Housing and Construction limited) ("theCompany") as of March 31 2019 in conjunction with our audit of the standalonefinancial statements of the Company for the year ended on that date.

Management's Responsibility for Internal Financial Controls

The Company's management is responsible for establishing and maintaining internalfinancial controls based on the internal control over financial reporting criteriaestablished by the Company considering the essential components of internal control statedin the Guidance Note on Audit of Internal Financial Controls Over Financial Reportingissued by the Institute of Chartered Accountants of India. These responsibilities includethe design implementation and maintenance of adequate internal financial controls thatwere operating effectively for ensuring the orderly and efficient conduct of its businessincluding adherence to company's policies the safeguarding of its assets the preventionand detection of frauds and errors the accuracy and completeness of the accountingrecords and the timely preparation of reliable financial information as required underthe Companies Act 2013.

Auditors' Responsibility

Our responsibility is to express an opinion on the Company's internal financialcontrols over financial reporting based on our audit. We conducted our audit in accordancewith the Guidance Note on Audit of Internal Financial Controls Over Financial Reporting(the "Guidance Note") and the Standards on Auditing issued by ICAI and deemedto be prescribed under section 143(10) of the Companies Act 2013 to the extentapplicable to an audit of internal financial controls both applicable to an audit ofInternal Financial Controls and both issued by the Institute of Chartered Accountants ofIndia. Those Standards and the Guidance Note require that we comply with ethicalrequirements and plan and perform the audit to obtain reasonable assurance about whetheradequate internal financial controls over financial reporting was established andmaintained and if such controls operated effectively in all material respects. Our auditinvolves performing procedures to obtain audit evidence about the adequacy of the internalfinancial controls system over financial reporting and their operating effectiveness. Ouraudit of internal financial controls over financial reporting included obtaining anunderstanding of internal financial controls over financial reporting assessing the riskthat a material weakness exists and testing and evaluating the design and operatingeffectiveness of internal control based on the assessed risk. The procedures selecteddepend on the auditor's judgement including the assessment of the risks of materialmisstatement of the financial statements whether due to fraud or error.

We believe that the audit evidence we have obtained is sufficient and appropriate toprovide a basis for our audit opinion on the Company's internal financial controls systemover financial reporting.

Meaning of Internal Financial Controls over Financial Reporting

A company's internal financial control over financial reporting is a process designedto provide reasonable assurance regarding the reliability of financial reporting and thepreparation of financial statements for external purposes in accordance with generallyaccepted accounting principles. A company's internal financial control over financialreporting includes those policies and procedures that (1) pertain to the maintenance ofrecords that in reasonable detail accurately and fairly reflect the transactions anddispositions of the assets of the company; (2) provide reasonable assurance thattransactions are recorded as necessary to permit preparation of financial statements inaccordance with generally accepted accounting principles and that receipts andexpenditures of the company are being made only in accordance with authorisations ofmanagement and directors of the company; and (3) provide reasonable assurance regardingprevention or timely detection of unauthorised acquisition use or disposition of thecompany's assets that could have a material effect on the financial statements.

Inherent Limitations of Internal Financial Controls Over Financial Reporting

Because of the inherent limitations of internal financial controls over financialreporting including the possibility of collusion or improper management override ofcontrols material misstatements due to error or fraud may occur and not be detected.Also projections of any evaluation of the internal financial controls over financialreporting to future periods are subject to the risk that the internal financial controlover financial reporting may become inadequate because of changes in conditions or thatthe degree of compliance with the policies or procedures may deteriorate.

Opinion

In our opinion the Company has in all material respects an adequate internalfinancial controls system over financial reporting and such internal financial controlsover financial reporting were operating effectively as at March 31 2019 based on theinternal control over financial reporting criteria established by the Company consideringthe essential components of internal control stated in the Guidance Note on Audit ofInternal Financial Controls Over Financial Reporting issued by the Institute of CharteredAccountants of India.

ForDewan P.N. Chopra & Co.
Chartered Accountants
Firm Regn. No. 000472N
Place : New Delhi (Sandeep Dahiya)
Dated: 29th May 2019 Partner
Membership No. 505371