TO THE MEMBERS OF ATLANTA LIMITED
Report on the Audit of the Standalone Financial Statements
We have audited the accompanying standalone financial statements of Atlanta Limited("the Company") which comprises the Balance Sheet as at March 31 2021 theStatement of Pro t and Loss (including Other Comprehensive Income) the Statement ofChanges in Equity and the Statement of Cash Flows for the year ended on that date and asummary of the significant accounting policies and other explanatory information(hereinafter referred to as "the 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 Indian Accounting Standards prescribed under section133 of the Act read with the Companies (Indian Accounting Standards) Rules 2015 asamended ("Ind AS") and other accounting principles generally accepted in Indiaof the state of a airs of the Company as at March 31 2021 the profit and totalcomprehensive income changes in equity and its cash flows for the year ended on thatdate.
Basis for Opinion
We conducted our audit of the standalone financial statements in accordance with theStandards on Auditing specified under section 143 (10) of the Act (SAs). Ourresponsibilities under those Standards are further described in the AuditorsResponsibilities for the Audit of the Standalone Financial Statements section of ourreport. We are independent of the Company in accordance with the Code of Ethics issued bythe Institute of Chartered Accountants of India (ICAI) together with the independencerequirements that are relevant to our audit of the standalone financial statements underthe provisions of the Act and the Rules made thereunder and we have fulfilled our otherethical responsibilities in accordance with these requirements and the ICAIs Code ofEthics. We believe that the audit evidence we have obtained is sufficient and appropriateto provide a basis for our audit opinion on the standalone financial statements.
We draw attention to the following notes in the standalone Ind AS financial statementsannexed to the auditors report
Emphasis of matters
a) Material Uncertainty Related to Going Concern:
We draw attention to the Statement of Pro t and Loss which indicate that the Companyhas incurred a net loss of ` 93718999/- during the year ended March 31 2021 and hasbeen incurring losses regularly over the previous financial years. As of that datebankers of the company have classified all the loan accounts of the company as"Non-performing Assets" (NPA). There have also been cash flow constraints due toinsu cient order book position and cancellation of certain on-going projects. These eventsand conditions indicate existence of a material uncertainty that may cast significantdoubt on the companys ability to continue as a going concern.
ii. The management of the company however is of the opinion that due to the variousbusiness revival steps being taken by them they would be in a position to overcome theaforesaid adverse situation
iii. The standalone financial statements of the Company has accordingly been preparedon the basis of continued going concern assumption.
Our opinion is not modified in respect of this matter.
b) Other Matters
Attention is drawn to Note no. 3.23(a) regarding classification of loan accounts asother current financial liabilities in the financial statement of the Company as theCompany has entered in to a compromised and negotiated settlement with the lenders of theCompany pursuant to which the lenders and Company have agreed to withdraw theclaims/counter claims led against each other.
ii) Note no 3.4(a) to the financial statements regarding Investments in Equity Sharesof MORA Tollways Limited ("the subsidiary")
On the basis of veri cation and explanations given to us the Concession agreementdated 10th September 2011 between the subsidiary and Bihar State Road DevelopmentCorporation Limited ("the authority") was terminated by the subsidiary on20.02.2015 for the default committed by the authority. The subsidiary had claimedtermination payment from the authority due to the dispute. The Arbitral Tribunal vide itsAward dated 25.05.2019 rejected the companys claim for the termination payment.These conditions indicate a significant decline in the fair value of investments in theequity instruments of the subsidiary held by the company. The management of the companyis however of the opinion that no diminution in the value of the investment in thesubsidiary is required to be provided in view of the reasons stated in the in thefinancial statements as at March 31 2021. (Refer Note no 3.4(a))
iii) Note no 3.4(b) to financial statements regarding Investments in equity shares ofAtlanta Ropar Tollways Private Limited ("the subsidiary").
The subsidiarys independent standalone Auditors report for the financialyear ended March 31 2021 have reported that the company has incurred a net loss of `619354279/- during the year ended March 31 2021 and has been incurring lossesregularly over the previous financial years resulting in a negative net worth of `746248731 as on March 31 2021. Further the lenders of the subsidiary have classifiedall the loan accounts of the subsidiary as Non-Performing Assets (NPAs). These conditionsindicate a significant decline in the fair value of investments in the equity instrumentsof the subsidiary. The management of the company is however of the opinion that nodiminution in the value of the investment in the subsidiary is required to be provided inview of the reasons stated in the in the financial statements as at March 31 2021.(Refernote no3.4(b))
Our opinion is not modified in respect of the above 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 a separateopinion on these matters. We have determined the matters described below to be the keyaudit matters to be communicated in our report.
|Sr. Key Audit Matter ||Auditors Response |
|1 Evaluation of uncertain tax positions ||Principal Audit Procedures |
|The Company has material uncertain tax positions including matters under dispute which involves signi cant judgment to determine the possible outcome of these disputes. ||Obtained details of completed tax assessments and demands for the year ended March 31 2018 from management. We involved our internal experts to challenge the managements underlying assumptions in estimating the tax provision and the possible outcome of the disputes. Our internal experts also considered legal precedence and other rulings in evaluating managements position on these uncertain tax positions. Additionally we considered the effect of additional information in respect of uncertain tax positions as at April 1 2021 to evaluate whether any change was required to managements position on these uncertainties. |
|Refer Notes 4(e) (f) and (g) to the Standalone Financial Statements || |
The Companys Board of Directors is responsible for the preparation of the otherinformation.
The other information comprises the information included in the Management Discussionand Analysis Boards Report including Annexures to Boards Report BusinessResponsibility Report Corporate Governance and Shareholders Information but doesnot include the standalone financial statements and our auditors 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 our audit of the standalone financial statements our responsibilityis to read the other information and in doing so consider whether the other informationis materially inconsistent with the standalone financial statements or our knowledgeobtained during the course 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.
Managements Responsibility for the Standalone Financial Statements
The Companys Board of Directors is responsible for the matters stated in section134 (5) of the Act with respect to the preparation of these standalone financialstatements that give a true and fair view of the financial position financialperformance total comprehensive income changes in equity and cash flows of the Companyin accordance with the Ind AS and other accounting principles generally accepted in India.This responsibility also includes maintenance of adequate accounting records in accordancewith the provisions of the Act for safeguarding the assets of the Company and forpreventing and detecting frauds and other irregularities; selection and application ofappropriate accounting policies; making judgments and estimates that are reasonable andprudent; 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 Companys ability to continue as a going concern disclosing asapplicable matters related to going concern and using the going concern basis ofaccounting unless management either intends to liquidate the Company or to ceaseoperations or has no realistic alternative but to do so.
The Board of Directors are responsible for overseeing the Companys financialreporting process.
Auditors Responsibilities for the Audit of the Standalone 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 auditors report that includes our opinion. Reasonableassurance is a high level of assurance but is not a guarantee that an audit conducted inaccordance with SAs will always detect a material misstatement when it exists.Misstatements can arise from fraud or error and are considered material if individuallyor in the aggregate they could reasonably be expected to influence the economic decisionsof users taken on the basis of these standalone financial statements.
As part of an audit in accordance with SAs we exercise professional judgment andmaintain professional scepticism throughout the audit. We also:
Identify and assess the risks of material misstatement of the standalone 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 financial controls relevant to the audit in orderto design audit procedures that are appropriate in the circumstances. Under section143(3)(I) of the Act we are also responsible for expressing our opinion on whether theCompany has adequate internal financial controls system in place and the operatingeffectiveness of such controls.
Evaluate the appropriateness of accounting policies used and the reasonableness ofaccounting estimates and related disclosures made by management.
Conclude on the appropriateness of managements use of the going concern basis ofaccounting and based on the audit evidence obtained whether a material uncertaintyexists related to events or conditions that may cast significant doubt on theCompanys ability to continue as a going concern. If we conclude that a materialuncertainty exists we are required to draw attention in our auditors report to therelated disclosures in the standalone financial statements or if such disclosures areinadequate to modify our opinion. Our conclusions are based on the audit evidenceobtained up to the date of our auditors report. However future events or conditionsmay cause the Company to cease to continue as a going concern.
Evaluate the overall presentation structure and content of the standalone financialstatements including the disclosures and whether the standalone financial statementsrepresent the underlying transactions and events in a manner that achieves fairpresentation.
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 in uenced. We considerquantitative materiality and qualitative factors in
(i) planning the scope of our audit work and in evaluating the results of our work; and
(ii) to evaluate the effect of any identified misstatements in the financialstatements.
We communicate with those charged with governance regarding among other matters theplanned scope and timing of the audit and significant audit ndings including anysignificant deficiencies in internal control that we identify during our audit.
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 standalone financial statementsof the current period and are therefore the key audit matters. We describe these mattersin our auditors report unless law or regulation precludes public disclosure aboutthe matter or when in extremely rare circumstances we determine that a matter should notbe communicated in our report because the adverse consequences of doing so wouldreasonably be expected to outweigh the public interest benefits of such communication.
Report on Other Legal and Regulatory Requirements
1. As required by Section 143(3) of the Act based on our audit 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 Pro t and Loss including Other ComprehensiveIncome Statement of Changes in Equity and the Statement of Cash Flow dealt with by thisReport are in agreement with the relevant books of account.
d) In our opinion the aforesaid standalone financial statements comply with the Ind ASspecified under Section 133 of the Act read with Rule 7 of the Companies (Accounts)Rules 2014.
e) On the basis of the written representations received from the directors as on March31 2021 taken on record by the Board of Directors none of the directors is disqualifiedas on March 31 2021 from being appointed as a director in terms of Section 164 (2) of theAct.
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 A". Our report expresses an unmodi ed opinion onthe adequacy and operating effectiveness of the Companys internal financial controlsover financial reporting.
g) With respect to the other matters to be included in the Auditors Report inaccordance with the requirements of section 197 (16) of the Act as amended: In ouropinion and to the best of our information and according to the explanations given to usthe remuneration paid by the Company to its directors during the year is in accordancewith the provisions of section 197 of the Act.
h) With respect to the other matters to be included in the Auditors Report inaccordance with Rule 11 of the Companies (Audit and Auditors) Rules 2014 as amended inour opinion and to the best of our information and according to the explanations given tous:
i. The Company has disclosed the impact of pending litigations on its financialposition in its standalone financial 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 includingderivative contracts.
iii. There has been no delay in transferring amounts required to be transferred tothe Investor Education and Protection Fund by the Company.
2. As required by the Companies (Auditors Report) Order 2016 ("theOrder") issued by the Central Government in terms of Section 143(11) of the Act wegive in "Annexure B" a statement on the matters specified in paragraphs 3 and 4of the Order.
For SURESH C MANIAR & CO
Firm Registration Number 110663W
K. V. SHETH
M. NO. 30063
Date: 30th July 2021
ANNEXURE "A" TO THE INDEPENDENT AUDITORS REPORT
(Referred to in paragraph 1(f) under Report on Other Legal and RegulatoryRequirements section of our report to the Members of Atlanta Limited of even date)
Report on the Internal Financial Controls Over Financial Reporting 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 ATLANTALIMITED ("the Company") as of March 31 2021 in conjunction with our audit ofthe standalone financial statements of the Company for the year ended on that date.
Managements Responsibility for Internal Financial Controls
The Board of Directors of the Company is responsible for establishing and maintaininginternal financial controls based on the internal control over financial reportingcriteria established by the Company considering the essential components of internalcontrol stated in the Guidance Note on Audit of Internal Financial Controls Over FinancialReporting issued by the Institute of Chartered Accountants of India. Theseresponsibilities include the design implementation and maintenance of adequate internalfinancial controls that were operating effectively for ensuring the orderly and efficientconduct of its business including adherence to respective companys policies thesafeguarding of its assets the prevention and detection of frauds and errors theaccuracy and completeness of the accounting records and the timely preparation ofreliable financial information as required under the Companies Act 2013.
Our responsibility is to express an opinion on the internal financial controls overfinancial reporting of the Company based on our audit. We conducted our audit inaccordance with the Guidance Note on Audit of Internal Financial Controls Over FinancialReporting (the "Guidance Note") issued by the Institute of Chartered Accountantsof India and the Standards on Auditing prescribed under Section 143(10) of the CompaniesAct 2013 to the extent applicable to an audit of internal financial controls. ThoseStandards and the Guidance Note require that we comply with ethical requirements and planand perform the audit to obtain reasonable assurance about whether adequate internalfinancial controls over financial reporting was established and maintained and if suchcontrols operated effectively in all material respects.
Our audit involves performing procedures to obtain audit evidence about the adequacy ofthe internal financial controls system over financial reporting and their operatingeffectiveness. Our audit of internal financial controls over financial reporting includedobtaining an understanding of internal financial controls over financial reportingassessing the risk that a material weakness exists and testing and evaluating the designand operating effectiveness of internal control based on the assessed risk. The proceduresselected depend on the auditors judgement including the assessment of the risks ofmaterial misstatement 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 internal financial controls system overfinancial reporting of the Company.
Meaning of Internal Financial Controls Over Financial Reporting
A companys internal financial control over financial reporting is a processdesigned to provide reasonable assurance regarding the reliability of financial reportingand the preparation of financial statements for external purposes in accordance withgenerally accepted accounting principles. A companys internal financial control overfinancial reporting includes those policies and procedures that
(1) pertain to the maintenance of records that in reasonable detail accurately andfairly reflect the transactions and dispositions of the assets of the company;
(2) provide reasonable assurance that transactions are recorded as necessary to permitpreparation of financial statements in accordance with generally accepted accountingprinciples and that receipts and expenditures of the company are being made only inaccordance with authorisations of management and directors of the company; and
(3) provide reasonable assurance regarding prevention or timely detection ofunauthorised acquisition use or disposition of the companys assets that could havea material effect on the financial statements.
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.
In our opinion to the best of our information and according to the explanations givento us the Company has in all material respects an adequate internal financial controlssystem over financial reporting and such internal financial controls over financialreporting were operating effectively as at March 31 2021 based on the internal controlover financial reporting criteria established by the Company considering the essentialcomponents of internal control stated in the Guidance Note on Audit of Internal FinancialControls Over Financial Reporting issued by the Institute of Chartered Accountants ofIndia.
For SURESH C MANIAR & CO
Firm Registration Number 110663W
K. V. SHETH
M. NO. 30063
Date: 30th July 2021
ANNEXURE B TO THE INDEPENDENT AUDITORS REPORT
Referred to in paragraph 2 under the heading Report on Other Legal &Regulatory Requirement of our report of even date to the standalone restated Ind ASfinancial statements of the Company for the year ended March 31 2021 we report that:
(i) (a) The Company has maintained proper records showing full particulars includingquantitative details and situation of fixed assets;
(b) The Company has a regular programme of physical verification of its fixed assets bywhich fixed assets are verified in a phased manner over a period of two years. Inaccordance with this programme certain fixed assets were verified during the year and nomaterial discrepancies were noticed on such verification. In our opinion this periodicityof physical verification is reasonable having regard to the size of the Company and thenature of its assets.
(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 immovable properties areheld in the name of the company.
(ii) (a) As explained to us the inventories have been physically veri ed during theyear by the management. In our opinion having regard to the nature and location ofinventories the frequency of the physical veri cation is reasonable.
(b) In our opinionthe discrepancies noticed on physical veri cation of the inventorieswere not material in relation to the operations of the Company and the same have beenproperly dealt with in the books of account.
(iii) The Company has granted interest free unsecured loans of ` 760874/- to threebodies corporate covered in the register maintained under section 189 of the CompaniesAct 2013 (the Act) and balance outstanding and maximum balance as on 31stMarch 2021 were ` 1286752126/- and `1286752126/- respectively.
(a) In our opinion other terms and conditions on which the loans had been granted tothe bodies corporate listed in the register maintained under Section 189 of the Act werenot prima facie prejudicial to the interest of the Company
(b) In the case of the loans granted to the bodies corporate listed in the registermaintained under section 189 of the Act the borrowers have been regular in the repaymentof principal on demand. All loans given are interest free hence question of payment of theinterest does not arise. The terms of arrangements do not stipulate any repayment scheduleand the loans are repayable on demand.
(c) There are no overdue amount for more than 90 days in respects of the loan grantedto body corporate listed in the register maintained under section 189 of the Act.
(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 loans investments guarantees and security.
(v) The Company has during the year not accepted any deposits from the public andhence the directives issued by the Reserve Bank of India and the provisions of Sections 73to 76 or any other relevant provisions of the Act and the Companies (Acceptance ofDeposit) Rules 2015 or any rules framed there under with regard to the deposits acceptedfrom the public are not applicable. No order has been passed by Company Law Board orNational Company Law Tribunal or Reserve Bank of India or any court or any other tribunalon the company.
(vi) We have broadly reviewed the books of accounts maintained by the Company pursuantto the Companies (Cost records and audit) Rules 2014 and as prescribed by the CentralGovernment under section 148(1) of the Act and are of the opinion that prima-facie theprescribed accounts and cost records have been made and maintained by the Company. We havenot however made a detailed examination of the cost records with a view to determiningwhether they are accurate or complete.
(vii) (a) According to the information and explanations given to us and on the basis ofour examination of the records of the Company amounts deducted/ accrued in the books ofaccount in respect of undisputed statutory dues including provident fund income taxsales tax wealth tax duty of excise service tax goods and service tax duty ofcustoms employees state insurance value added tax cess and other materialstatutory dues have been regularly deposited with few delay in some cases during the yearby the Company with the appropriate authorities.
(b) According to the information and explanations given to us no undisputed amountspayable in respect of provident fund income tax sales tax wealth tax service taxgoods and service tax duty of excise duty of customs value added tax cess and othermaterial statutory dues were in arrears as at 31st March 2021 for a period of more thansix months from the date they became payable except income tax dues for the financialyear ending on 31st March 2017 amounting to` 108184756/- and interest payable thereon.
(c) According to the information and explanations given to us there are no dues ofincome tax sales tax service tax duty of customs duty of excise valued added tax goods andservice tax and other material statutory dues which have not been deposited with theappropriate authorities on account of any dispute except for the following:
|Name of the statute ||Nature of dues ||Amount in ` ||Period to which the amount relates ||Forum where dispute is pending |
|Income Tax Act1961 ||Income Tax ||3008040/- ||AY 2010-11 ||CIT(A)Mumbai |
|Income Tax Act1961 ||Income Tax ||23355104/- ||AY 2013-14 ||CIT(A)Mumbai |
|Income Tax Act1961 ||Income Tax ||97731016/- ||AY 2016-17 ||CIT(A)Mumbai |
|Income Tax Act1961 ||Income Tax ||91375841/- ||AY 2017-18 ||CIT(A)Mumbai |
|Sales Tax & Value Added Tax Laws ||Sales Tax ||49291421/- ||F.Y.2011-12 ||Bombay High Court |
|Sales Tax & Value Added Tax Laws ||Sales Tax ||93009884/- ||F.Y.2012-13 ||Bombay High Court |
|Sales Tax & Value Added Tax Laws ||Sales Tax ||57817426/- ||F.Y.2013-14 ||Bombay High Court |
|Sales Tax & Value Added Tax Laws ||Sales Tax ||93009883/- ||F.Y.2014-15 ||Bombay High Court |
|Finance Act 1994 ||Service Tax ||2760079/- ||F.Y.2009-10 ||The Commissioner (Appeals) Customs Central Excise & Service Tax |
|Finance Act 1994 ||Service Tax ||36300320/- ||F.Y.April 2007 - Sept 2008 ||The Assistant Registrar Customs Excise & Service Tax Appellate Tribunal |
|Finance Act 1994 ||Service Tax ||28325388/- ||July-2004 to November 2006. ||Customs Excise & Service Tax Appellate Tribunal Kolkata |
(viii) Based on our Audit procedures and according to information and explanation givento us the Company has paid dues to banks with certain delay. The Company has overdueoutstanding dues to financial institutions/banks as at 31st March 2021 (the said dueswere disputed by the Company under a suit led against the Lender Banks which have beensubsequently withdrawn under Compromised and Negotiated Scheme with lenders) and thedetails are as under:
|Name of the Bank / nancial Institution ||Amount (`) ||Nature ||Period |
|Bank of Baroda ||379882451/- ||Principal ||January19 to March19 |
|State Bank of India ||514960608/- ||Principal ||Decenber18 March 20 |
|State Bank of India ||10274846/- ||Interest ||September18 to March19 |
|Union Bank of India ||278634245/- ||Principal ||September18 to March 20 |
Note: All the above lenders have declared the companies all loan accounts as NPA andhave discontinued to charge interest on such loan. The company has therefore not providedinterest for the year under consideration. Hence for the year 2020-21 defaults of interestamount is not ascertainable and not quanti ed.
(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 public offeror further public offer including debt instruments. The term loans have been applied forthe purpose for which they were obtained.
(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 its ocers 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 is inaccordance with the requisite approvals mandated by the provisions of section 197 readwith Schedule V to the Companies Act;
(xii) In our opinion the Company is not a Nidhi Company. Therefore the provisions ofclause 4 (xii) of the Order are not applicable to the Company.
(xiii) In our opinion all transactions with the related parties are in compliance withsection 177 and 188 of Companies Act 2013 and the details have been disclosed in theFinancial Statements as required by the applicable accounting standards.
(xiv) Based upon the audit procedures performed and the information and explanationsgiven by the management the company has not made any preferential allotment or privateplacement of shares or fully or partly convertible debentures during the year underreview. Accordingly the provisions of clause 3 (xiv) of the Order are not applicable tothe Company and hence not commented upon.
(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 him. Accordingly the provisions of clause 3 (xv) ofthe Order are 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 and accordingly the provisions of clause 3 (xvi)of the Order are not applicable to the Company and hence not commented upon.
For SURESH C MANIAR & CO
Firm Registration Number 110663W
K. V. SHETH
M. NO. 30063
Date: 30th July 2021