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Bharat Agri Fert & Realty Ltd.

BSE: 531862 Sector: Agri and agri inputs
NSE: N.A. ISIN Code: INE842D01011
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OPEN 605.00
CLOSE 598.75
VOLUME 9782
52-Week high 614.90
52-Week low 163.00
P/E
Mkt Cap.(Rs cr) 317
Buy Price 600.00
Buy Qty 13.00
Sell Price 601.00
Sell Qty 70.00

Bharat Agri Fert & Realty Ltd. (BHARATAGRIFERT) - Auditors Report

Company auditors report

TO THE MEMBERS OF

Bharat Agri Fert and Realty Limited

Report on the Audit of the Standalone Financial Statements

Qualified Opinion

We have audited the accompanying standalone financial statements of BharatAgri Fert and Realty Limited (the "Company") which comprise the BalanceSheet as at March 31 2021 the Statement of Profit and Loss (including OtherComprehensive Income) the Statement of Changes in Equity and the Statement of Cash Flowsfor the year ended on that date and a summary of significant accounting policies and otherexplanatory information (hereinafter referred to as the "standalone financialstatements"). In our opinion and to the best of our information and according to theexplanations given to us except for the possible effect of matters described in the Basisfor Qualified Opinion section of our report the aforesaid standalone financial statementsgive the information required by the Companies Act 2013 (the "Act") in themanner so required and give a true and fair view in conformity with the Indian AccountingStandards prescribed under section 133 of the Act read with the Companies (IndianAccounting Standards) Rules 2015 as amended ("Ind AS") and other accountingprinciples generally accepted in India of the state of affairs of the Company as at March31 2021 and its loss total comprehensive income changes in equity and its cash flowsfor the year ended on that date.

Basis for Qualified Opinion

a) Loan given to an Associate Company - Mol Chem Ltd

As per the agreement dated 28th May 2015 the Company had given loan toM/s Mol Chem Ltd aggregating to Rs.8.25 Crore. The loan was repayable over a period offive years. Delays/defaults were observed in payment of interest and in view of this theCompany had amended agreement. However same was not complied by M/s Mol Chem Ltd. In viewof this the said loan was recalled on 31/08/2019.The Loan amount is Rs.8.99 Crores as at31st March 2021.The management of Company has informed that all necessarysteps are taken by the Company. However there is no recovery of the said loan in spite ofsignificant time is lapsed. Company has not made any provision in respect of the saidoutstanding loan.

b) Investment in an Associate Company - Mol Chem Ltd:

Carrying value of the equity shares investment in an associate Company-Mol Chem Ltd is Rs.35.06 lacs as at 31st March 2021.The fair valuation reportas required by Ind AS 109 is not on record. In spite of the significant time has lapsedMol Chem did not able to service the loan availed from the Company. In spite of this theCompany has not made any provision regarding the said equity investment in Mol Chem Ltd.

c) Carrying value of old overdue trade receivables is Rs.9.74Crores as at 31st March 2021.The Company has not made any provision regardingthe said old overdue trade receivables.

We conducted our audit of the standalone financial statements inaccordance with the Standards on Auditing ("SA"s) specified under section143(10) of the Act. Our responsibilities under those Standards are further described inthe Auditor's Responsibilities for the Audit of the Standalone Financial Statementssection of our report. We are independent of the Company in accordance with the Code ofEthics issued by the Institute of Chartered Accountants of India ("ICAI")together with the ethical requirements that are relevant to our audit of the standalonefinancial statements under the provisions of the Act and the Rules made thereunder and wehave fulfilled our other ethical responsibilities in accordance with these requirementsand the ICAI's Code of Ethics. We believe that the audit evidence obtained by us issufficient and appropriate to provide a basis for our audit opinion on the standalonefinancial statements.

Emphasis of Matter

a) Transfer Developments Rights:

The Company has made payment for the purpose of purchase of TransferDevelopments Rights (TDR) from M/s Hubtown Limited (erstwhile Acruti City Limited) on19/09/2014 for a sum aggregating to Rs.9.66 Crores. The Company has informed that TDR istransferred in it's name and it has received short TDR for area 332.180 sq. mtrs.aggregating to Rs.1.36 Crores. The Company has not filled any claim for the said shortreceipt of TDR. The Company has purchased corporate office from M/s Hubtown Limited(erstwhile Acruti City Limited) and has contended ultimately to adjust the short receiptof TDR by way of maintenance of its corporate office at Andheri payable to M/s HubtownLimited (erstwhile Acruti City Limited). The Company is intending to use the said TDR andother TDRs purchased in the proposed development of the real estate business. Carryingvalue of the said TDR aggregating to Rs.9.66 Crores as at 31st March 2021 andother TDR purchased depends on the Company's ability to further fund the proposeddevelopment of reality business & other business segments.

b) Society Maintenance Charges (SMC):

Society maintenance charges aggregating to Rs.0.26 Crores (app.) arevery old and the Company has not made provision in this regard. The matter is notsub-judice. The management of Company has informed that all necessary steps are taken bythe Company and is hopeful about recovery of the SMC.

c) Confirmations of the certain trade receivables trade payables &other receivables:

Balances of the certain trade receivables trade payables & otherreceivables are subject to confirmations and reconciliations. Management has stated thatall known liabilities are duly provided by the Company.

d) Old overdue advances:

The Company has given advances to certain parties aggregating toRs.1.30 Crores (app) Certain material amount of advances are old and overdue.Company's management is of the opinion that the intended material/services arereceived from certain parties for which expenses will be booked after receipt of bills andin respect of certain parties material/services will be received in future and accordinglyno provision is necessary in this regard. It is also informed that in case of fewadvances some parties may refund the advances to the Company.

e) Subjudice matters:

The Company has informed that certain matters are subjudice as at 31stMarch 2021.The summary in brief is as under:

Sn. Particulars Amt. Rs.(in Crores)
1 Amount deposited in protest with MSEDCL 0.53
2 Society common area maintenance charges receivables 1.15
3 Maintenance Charges payable* 0.33

* The case is yet to be admitted

The management has stated that being the matters are subjudice noimpact of these is envisaged on the financial statements.

f) The above stated illustrative matters coupled by COVID situationhas significantly affected the company's cash flows and ability to raise furtherfunds. This has an impact on Company's business which further depends upon outcomeof the above matters and ability of the Company to raise the funds.

Our opinion is not modified in respect of this matter.

Key Audit Matters

Key audit matters (‘KAM') are those matters that in ourprofessional judgment were of most significance in our audit of the financial statementsof the current period. These matters were addressed in the context of our audit of thefinancial statements as a whole and in forming our opinion thereon and we do not providea separate opinion on these matters.

Sn. The Key Audit Matters How our audit addressed the key audit matter
1. Trade Receivables Our audit procedures included among others the following:
1. Evaluation of sales procedure.
2. Evaluated the design of the internal controls relating to sale booking.
3. Evaluated sales invoices on test check basis.
4. Evaluated ageing analysis and ledger accounts of the trade receivables.
2. Inventories Our audit procedures included among others the following:
1. Evaluation of accounting of inventory related procedure.
2. Correlation of inventory as per books and as per physical stock verification reports.
3. Evaluated requirements of IND AS-2.
3. Loans & Advances Our audit procedures included among others the following:
1. Evaluation of underlying contracts.
2. Evaluation of management perspective of overdue interest amount.

Information Other than the Financial Statements and Auditor'sReport Thereon

The Company's Board of Directors is responsible for the otherinformation. The other information comprises the information included in the ManagementDiscussion and Analysis Board's Report including Annexures to Board's ReportBusiness Responsibility Report Corporate Governance and Shareholder's Informationbut does not include the standalone financial statements and our auditor's reportthereon.

Our opinion on the standalone financial statements does not cover theother information and we do not express any form of assurance conclusion thereon.

In connection with our audit of the standalone financial statementsour responsibility is to read the other information and in doing so consider whether theother information is materially inconsistent with the standalone financial statements orour knowledge obtained during the course of our audit or otherwise appears to bematerially misstated.

If based on the work we have performed we conclude that there is amaterial misstatement of this other information we are required to report that fact. Wehave nothing to report in this regard.

Management's Responsibilities for the Standalone FinancialStatements

The Company's Board of Directors is responsible for the mattersstated in section 134(5) of the Act with respect to the preparation of these standalonefinancial statements that give a true and fair view of the financial position financialperformance including other comprehensive income changes in equity and cash flows of theCompany in accordance with the Ind AS and other accounting principles generally acceptedin India. This responsibility also includes maintenance of adequate accounting records inaccordance with the provisions of the Act for safeguarding the assets of the Company andfor preventing 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 isresponsible for assessing the Company's ability to continue as a going concerndisclosing as applicable matters related to going concern and using the going concernbasis of accounting unless management either intends to liquidate the Company or to ceaseoperations or has no realistic alternative but to do so.

The Board of Directors is responsible for overseeing the Company'sfinancial reporting process.

Auditor's Responsibilities for the Audit of the StandaloneFinancial Statements

Our objectives are to obtain reasonable assurance about whether thestandalone financial statements as a whole are free from material misstatement whetherdue to fraud or error and to issue an auditor's report that includes our opinion.Reasonable assurance is a high level of assurance but is not a guarantee that an auditconducted in accordance with SAs will always detect a material misstatement when itexists. Misstatements can arise from fraud or error and are considered material ifindividually or in the aggregate they could reasonably be expected to influence theeconomic decisions of users taken on the basis of these standalone financial statements.

As part of an audit in accordance with SAs we exercise professionaljudgment and maintain professional scepticism throughout the audit. We also:

• Identify and assess the risks of material misstatement of thestandalone financial statements whether due to fraud or error design and perform auditprocedures responsive to those risks and obtain audit evidence that is sufficient andappropriate to provide a basis for our opinion. The risk of not detecting a materialmisstatement resulting from fraud is higher than for one resulting from error as fraudmay involve collusion forgery intentional omissions misrepresentations or the overrideof internal control.

• Obtain an understanding of internal financial control relevantto the audit in order to design audit procedures that are appropriate in thecircumstances. Under section 143(3)(i) of the Act we are also responsible for expressingour opinion on whether the Company has adequate internal financial controls system inplace and the operating effectiveness of such controls.

• Evaluate the appropriateness of accounting policies used and thereasonableness of accounting estimates and related disclosures made by the management.

• Conclude on the appropriateness of management's use of thegoing concern basis of accounting and based on the audit evidence obtained whether amaterial uncertainty exists related to events or conditions that may cast significantdoubt on the Company's ability to continue as a going concern. If we conclude that amaterial uncertainty exists we are required to draw attention in our auditor'sreport to the related disclosures in the standalone financial statements or if suchdisclosures are inadequate to modify our opinion. Our conclusions are based on the auditevidence obtained up to the date of our auditor's report. However future events orconditions may cause the Company to cease to continue as a going concern.

• Evaluate the overall presentation structure and content of thestandalone financial statements including the disclosures and whether the standalonefinancial statements represent the underlying transactions and events in a manner thatachieves fair presentation.

Materiality is the magnitude of misstatements in the standalonefinancial statements that individually or in aggregate makes it probable that theeconomic decisions of a reasonably knowledgeable user of the standalone financialstatements may be influenced. We consider quantitative materiality and qualitative factorsin

(i) planning the scope of our audit work and in evaluating the resultsof our work; and

(ii) to evaluate the effect of any identified misstatements in thestandalone financial statements.

We communicate with those charged with governance regarding amongother matters the planned scope and timing of the audit and significant audit findingsincluding any significant deficiencies in internal control that we identify during ouraudit.

We also provide those charged with governance with a statement that wehave complied with relevant ethical requirements regarding independence and tocommunicate with them all relationships and other matters that may reasonably be thoughtto bear on our independence and where applicable related safeguards.

From the matters communicated with those charged with governance wedetermine those matters that were of most significance in the audit of the standalonefinancial statements of the current period and are therefore the key audit matters. Wedescribe these matters in our auditor's report unless law or regulation precludespublic disclosure about the matter or when in extremely rare circumstances we determinethat a matter should not be communicated in our report because the adverse consequences ofdoing so would reasonably be expected to outweigh the public interest benefits of suchcommunication.

Report on Other Legal and Regulatory Requirements

1. As required by Section 143(3) of the Act based on our audit wereport that:

a) We have sought and obtained all the information and explanationswhich to the best of our knowledge and belief were necessary for the purposes of ouraudit.

b) In our opinion proper books of account as required by law have beenkept by the Company so far as it appears from our examination of those books.

c) The Balance Sheet the Statement of Profit and Loss including OtherComprehensive Income Statement of Changes in Equity and the Statement of Cash Flows dealtwith by this Report are in agreement with the books of account.

d) In our opinion the aforesaid standalone financial statements complywith the Ind AS specified under Section 133 of the Act.

e) On the basis of the written representations received from thedirectors as on March 31 2021 taken on record by the Board of Directors none of thedirectors is disqualified as on March 31 2021 from being appointed as a director in termsof Section 164(2) of the Act.

f) With respect to the adequacy of the internal financial controls overfinancial reporting of the Company and the operating effectiveness of such controls referto our separate Report in "Annexure A". Our report expresses modifiedopinion on the adequacy and operating effectiveness of the Company's internalfinancial controls over financial reporting.

g) With respect to the other matters to be included in theAuditor's Report in accordance with the requirements of section 197(16) of the Actas amended:

In our opinion and to the best of our information and according to theexplanations given to us the remuneration paid by the Company to its directors during theyear is in accordance with the provisions of section 197 of the Act.

h) With respect to the other matters to be included in theAuditor's Report in accordance with Rule 11 of the Companies (Audit and Auditors)Rules 2014 as amended in our opinion and to the best of our information and according tothe explanations given to us:

i. The Company has disclosed the impact of pending litigations on itsfinancial position in its standalone financial statements.

ii. The Company did not have any long-term contracts includingderivative contracts for which there were any material foreseeable losses;

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

2. As required by the Companies (Auditor's Report) Order 2016("the Order") issued by the Central Government in terms of Section 143(11) ofthe Act we give in "Annexure B" a statement on the matters specified inparagraphs 3 and 4 of the Order.

FOR VERMA MEHTA & ASSOCIATES
Chartered Accountants
Firm's Registration No: 112118W
Sandeep Verma
Partner
Membership No.:045711
Place: Mumbai
Date: 30th June 2021
UDIN: 21045711AAAABX7432

ANNEXURE "A" TO THE INDEPENDENT AUDITOR'S REPORT

(Referred to in paragraph 1 (f) under ‘Report on Other Legal andRegulatory Requirements' section of our report to the Members of Bharat Agri Fert andRealty Limited of even date)

Report on the Internal Financial Controls Over Financial Reportingunder Clause (i) of Sub-section 3 of Section 143 of the Companies Act 2013 ("theAct")

We have audited the internal financial controls over financialreporting of Bharat Agri Fert and Realty Limited (the "Company") as ofMarch 31 2021 in conjunction with our audit of the standalone Ind AS financial statementsof the Company for the year ended on that date.

Management's Responsibility for Internal Financial Controls

The Management of the Company is responsible for establishing andmaintaining internal financial controls based on the internal control over financialreporting criteria established by the Company considering the essential components ofinternal control stated in the Guidance Note on Audit of Internal Financial Controls OverFinancial Reporting issued by the Institute of Chartered Accountants of India (the"ICAI"). These responsibilities include the design implementation andmaintenance of adequate internal financial controls that were operating effectively forensuring the orderly and efficient conduct of its business including adherence tocompany's policies the safeguarding of its assets the prevention and detection offrauds and errors the accuracy and completeness of the accounting records and the timelypreparation of reliable financial information as required under the Companies Act 2013.

Auditor's Responsibility

Our responsibility is to express an opinion on the Company's internalfinancial controls over financial reporting of the Company based on our audit. Weconducted our audit in accordance with the Guidance Note on Audit of Internal FinancialControls Over Financial Reporting (the "Guidance Note") issued by the ICAI andthe Standards on Auditing prescribed under Section 143(10) of the Companies Act 2013 tothe extent applicable to an audit of internal financial controls. Those Standards and theGuidance Note require that we comply with ethical requirements and plan and perform theaudit to obtain reasonable assurance about whether adequate internal financial controlsover financial reporting was established and maintained and if such controls operatedeffectively in all material respects. Our audit involves performing procedures to obtainaudit evidence about the adequacy of the internal financial controls system over financialreporting and their operating effectiveness. Our audit of internal financial controls overfinancial reporting included obtaining an understanding of internal financial controlsover financial reporting assessing the risk that a material weakness exists and testingand evaluating the design and operating effectiveness of internal control based on theassessed risk. The procedures selected depend on the auditor's judgement includingthe assessment of the risks of material misstatement of the financial statements whetherdue to fraud or error. We believe that the audit evidence we have obtained is sufficientand appropriate to provide a basis for our audit opinion on the Company's internalfinancial controls system over financial reporting.

Meaning of Internal Financial Controls over Financial Reporting

A company's internal financial control over financial reporting is aprocess designed to provide reasonable assurance regarding the reliability of financialreporting and the preparation of financial statements for external purposes in accordancewith generally accepted accounting principles. A company's internal financial control overfinancial reporting includes those policies and procedures that

(1) pertain to the maintenance of records that in reasonable detailaccurately and fairly reflect the transactions and dispositions of the assets of thecompany;

(2) provide reasonable assurance that transactions are recorded asnecessary to permit preparation of financial statements in accordance with generallyaccepted accounting principles and that receipts and expenditures of the company arebeing made only in accordance with authorisations of management and directors of thecompany; and

(3) provide reasonable assurance regarding prevention or timelydetection of unauthorised acquisition use or disposition of the company's assets thatcould have a material effect on the financial statements.

Inherent Limitations of Internal Financial Controls over FinancialReporting

Because of the inherent limitations of internal financial controls overfinancial reporting including the possibility of collusion or improper managementoverride of controls material misstatements due to error or fraud may occur and not bedetected. Also projections of any evaluation of the internal financial controls overfinancial reporting to future periods are subject to the risk that the internal financialcontrol over financial reporting may become inadequate because of changes in conditionsor that the degree of compliance with the policies or procedures may deteriorate.

Basis of Qualified Opinion

According to the information and explanations given to us and based onour audit the following material weaknesses has been identified in the operatingeffectiveness of the Company's internal financial controls over financial statementsas at March 31 2021:

1. Loan given to an Associate Company - Mol Chem Ltd

2. Investment in an Associate Company - Mol Chem Ltd

3. Non provisioning of old overdue trade receivables

A ‘material weakness' is a deficiency or a combination ofdeficiencies in internal financial control over financial statements such that there isa reasonable possibility that a material misstatement of the Company's financialstatements will not be prevented or detected on a timely basis.

Qualified Opinion

In our opinion to the best of our information and according to theexplanations given to us except for the effects / possible effects of the materialweaknesses described above under Basis for Qualified Opinion paragraph on the achievementof the objectives of the control criteria the Company has in all material respects anadequate internal financial controls system over financial reporting and such internalfinancial controls over financial reporting were operating effectively as at March 312021 based on the criteria for internal financial control over financial reportingestablished 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 ICAI.

FOR VERMA MEHTA & ASSOCIATES
Chartered Accountants
Firm's Registration No: 112118W
Sandeep Verma
Partner
Membership No.:045711
Place: Mumbai
Date: 30th June 2021
UDIN: 21045711AAAABX7432

Annexure – B to the Independent Auditors' Report

The Annexure referred to in Independent Auditors' Report to themembers of the Company on the standalone financial statements for the year ended 31stMarch 2021 we report that:

(i) In respect of Company's property plant and equipment:

(a) The Company has maintained proper records showing full particularsincluding quantitative details and situation of property plant and equipment.

(b) The Company has a regular programme of physical verification of itsproperty plant and equipment by which property plant and equipment are verified in aphased manner over a period of three years. In our opinion this periodicity of physicalverification is reasonable having regard to the size of the Company and the nature of itsassets. In accordance with this programme certain property plant and equipment wereverified during the year and no material discrepancies were noticed on such verification.However these discrepancies need to be further analysed in view of clause (i) (a) above.

(c) According to the information and explanations given to us and onthe basis of our examination of the records of the Company the title deeds of immovableproperties are held in the name of the Company.

(ii) in respect Company's inventories:

The inventory has been physically verified by the management atreasonable intervals during the year. In our opinion the frequency of such verificationis reasonable.

The discrepancies noticed on verification between the physical stocksand the book records were not material.

(iii) in respect of loans secured or unsecured granted to companiesfirms Limited Liability Partnerships or other parties covered in register maintainedunder section 189 of the Act:

The Company has granted loan to a company (associate) covered in theregister maintained under section 189 of the Act.

(a) In our opinion the rate of interest and other terms and conditionson which the loans had been granted to a company (associate) listed in the registermaintained under Section 189 of the Act are not prima facie prejudicial to the interestof the Company.

(b) Schedule of repayment of principal and payment of interest has beenstipulated. Quarterly interest payment with one-year moratorium is stipulated. Principalis repayable within a period of five years from the date of disbursement. Delays/defaultswere observed in payment of interest and in view of this the Company had amendedagreement. However same was not complied by M/s Mol Chem Ltd. In view of this the saidloan was recalled on 31/08/2019. The Loan amount is Rs.8.99 Crores as at 31stMarch 2021.

(c)As the principal is recalled as stated above. Interest aggregatingto Rs.0.78 Crore is overdue till date. The Company has taken reasonable steps forrecovery.

(iv) The Company has not granted any loans or provided any guaranteesor security to the parties covered under Section 185 of the Act. The Company has compliedwith the provisions of Section 186 of the Act in respect of investments made and loansgiven to the associate covered under Section 186.

(v) In our opinion and according to the information and explanationsgiven to us the Company has not accepted any deposits from the public.

Accordingly paragraph 3 (v) of the Order is not applicable to theCompany.

(vi) We have broadly reviewed the books of accounts and recordsmaintained by the Company pursuant to the Rules prescribed by the Central Government undersub section (1) of section 148 of the Act and are of the opinion that prima facie theprescribed accounts and records have been made and maintained. However we have not made adetailed examination of the records.

(vii) in respect of statutory dues:

(a) According to the information and explanations given to us and onthe basis of our examination of the records of the Company amounts deducted/ accrued inthe books of account in respect of undisputed statutory dues including provident fundemployee state insurance income-tax value added tax duty of customs corresponding cessservice tax GST professional tax and other material statutory dues have been generallyregularly deposited during the year by the Company with the appropriate authorities.According to the information and explanations given to us no undisputed amounts payablein respect of provident fund income tax value added tax duty of customs correspondingcess service tax GST professional tax and other material statutory dues were inarrears as at 31 March 2021 for a period of more than six months from the date they becamepayable.

(b) According to the information and explanations given to us thereare no material statutory dues which have not been deposited with the appropriateauthorities on account of any dispute other than the following dues of VAT and Incometax:

Name of the Statute Nature of Dues Period to which it pertains Forum Where Dispute is Pending Amount (Excluding Interest and Penalty) (Rs. In Lakhs)
2013-2014 Asst. Commissioner Thane Mun. Corp. 1.40
2014-15 DO 15.61
The Maharashtra Local Body Tax TOTAL 17.01
Value added tax Act 2002 Income Tax Income Tax FY 2016-17 CIT (A) 10.47
Act1961 Income Tax Act1961 Income Tax FY2017-18 CIT (A) 9.33

(viii) According to the information and explanations given to us theCompany has not defaulted any loans or borrowings from any bank during the year.

(ix) The Company did not raise any moneys by way of initial publicoffer or further public offer (including debt instruments) or by way of Term Loans duringthe year.

(x) According to the information and explanations given to us nomaterial fraud by the Company or on the Company by its officers or employees has beennoticed or reported during the course of our audit.

(xi) According to the information and explanations give to us and basedon our examination of the records of the Company the Company has paid/provided formanagerial remuneration in accordance with the requisite approvals mandated by theprovisions of section 197 read with Schedule V to the Act.

(xii) In our opinion and according to the information and explanationsgiven to us the Company is not a nidhi company. Accordingly paragraph 3(xii) of theOrder is not applicable.

(xiii) According to the information and explanations given to us andbased on our examination of the records of the Company transactions with the relatedparties are in compliance with sections 177 and 188 of the Act where applicable. Thedetails of such related party transactions have been disclosed in the financial statementsas required under Indian Accounting standard (IND AS) 24 Related Party Disclosurespecified under Section 133 of the Act.

(xiv) According to the information and explanations given to us andbased on our examination of the records of the Company the Company has not made anypreferential allotment of shares. The Company has not made private placement of partly orfully convertible debentures during the year under review.

(xv) According to the information and explanations given to us andbased on our examination of the records of the Company the Company has not entered intonon-cash transactions with directors or persons connected with him.

Accordingly paragraph 3(xv) of the Order is not applicable.

(xvi) The Company is not required to be registered under section 45-IAof the Reserve Bank of India Act 1934.Accordingly paragraph 3(xvi) of the Order is notapplicable.

FOR VERMA MEHTA & ASSOCIATES
Chartered Accountants
Firm's Registration No: 112118W
Sandeep Verma
Partner
Membership No.:045711
Place: Mumbai
Date: 30th June 2021
UDIN: 21045711AAAABX7432

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