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Comfort Fincap Ltd.

BSE: 535267 Sector: Financials
NSE: N.A. ISIN Code: INE274M01018
BSE 00:00 | 27 Sep 52.20 2.45
(4.92%)
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51.90

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52.20

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49.10

NSE 05:30 | 01 Jan Comfort Fincap Ltd
OPEN 51.90
PREVIOUS CLOSE 49.75
VOLUME 8603
52-Week high 55.50
52-Week low 3.92
P/E 14.03
Mkt Cap.(Rs cr) 57
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00
OPEN 51.90
CLOSE 49.75
VOLUME 8603
52-Week high 55.50
52-Week low 3.92
P/E 14.03
Mkt Cap.(Rs cr) 57
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

Comfort Fincap Ltd. (COMFORTFINCAP) - Director Report

Company director report

To the Members of the Company

Your Directors have pleasure in presenting the Thirty Ninth Annual Report of ComfortFincap Limited ('the Company') on the business and operations of your Company along withthe Audited Financial Statements (Consolidated and Standalone) for the Financial yearended March 312021.

1) FINANCIAL HIGHLIGHTS:

The summary of Audited Consolidated and Standalone Financial performance of theCompany for the Financial year ended March 312021 is summarized as under:

(Rs in Lacs)
particulars

STANDALONE

CONSOLIDATED

2020-2021 2019-2020 2020-2021 2019-2020
Revenue from Operations 1112.77 578.87 1112.77 578.87
Other operating Income 1.01 1.98 1.01 1.98
Total Revenue 1113.78 580.85 1113.78 580.85
Total Expenditure 555.79 392.05 555.79 392.05
Profit before Tax 558.00 188.80 558.00 188.80
Current Tax Expenses 179.96 127.71 179.96 127.71
Deferred Tax (35.36) (62.68) (35.36) (62.68)
Tax of earlier years (4.61) (0.08) (4.61) (0.08)
Profit for the Year 418.00 123.86 418.01 123.86
Earnings Per Share (EPS in Rs.) 3.85 1.14 3.85 1.14

2) FINANCIAL PERFORMANCE

The Consolidated and Standalone Financial Statements of the Company for the year endedMarch 312021 have been prepared in accordance with Indian Accounting Standards (IND-AS)the relevant provisions of section 129 and 133 of Companies Act 2013 Regulation 33 ofSEBI (Listing Obligations and Disclosure Requirements) Regulations 2015 (hereinafterreferred to as "the SEBI Listing Regulations") which have been reviewed by theStatutory Auditors. The Company is submitting the quarterly/half yearly/annual financialresults on both Standalone and Consolidated basis.

On a Standalone and Consolidated basis the Company registered revenue from operationsof Rs. 1112.77 lakhs for the year ended March 312021 as compared to Rs. 578.87 lakhs inthe previous financial year ended March 312020. The Net profit stood at Rs. 418.00 lakhsfor the year ended March 312021 as compared to the profit of Rs. 123.86 lakhs in theprevious financial year ended March 31 2020.

In accordance with the provisions contained in section 136 of the Companies Act 2013the Annual Report of the Company containing Notice of the Annual General MeetingConsolidated and Standalone Financial Statements Report of the Auditor's and Board ofDirectors thereon are available on the website of the Company at www.comfortfincap.com.Further a detailed analysis of Company's performance is included in the ManagementDiscussion and Analysis Report ("MDAR") which forms part of this Annual report.

3) DIVIDEND

Based on the Company's financial performance for the year 2020-21 and in order toconserve cash resources to face the challenges and the contingencies created by COVID19pandemic the Board of Directors have not recommended any dividend on equity shares forthe year ended on March 312021.

4) TRANSFER OF UNCLAIMED DIVIDEND AMOUNTS AND CONCERNED SHARES TO INVESTOR EDUCATIONAND PROTECTION FUND (IEPF) AUTHORITY

Pursuant to the applicable provisions of the Act read with Investor Education andProtection Fund Authority (Accounting Audit Transfer and Refund) Rules 2016 (includingany statutory modification(s) and/or reenactment(s) thereof for the time being in force)the Company will be transferring the dividend and the shares to the IEPF Authority for itsun-paid /unclaimed dividend Account of the financial year 2013-14. The Company will besending individual correspondence to the shareholders and newspaper advertisement forclaiming the un-paid/unclaimed dividend in respect of which dividend has not been en-cashed or claimed by the members for 7 consecutive years or more. The shareholders areonce again requested to claim their un-paid/unclaimed to avoid the transfer to IEPFAuthority.

Members who have not yet en-cashed their Dividends from financial year 2013-14 and2014-15 and thereafter are requested to make their claims to the Company/RTA. Members arerequested to quote folio numbers/DP ID - Client ID in all their correspondence

5) share CAPITAL

During the year under review there has been no change in share capital of the Company.The paid-up Equity Share Capital of the Company as on March 31 2021 was Rs 108513000(Rupees Ten Crores Eighty Five Lakhs Thirteen Thousand Only) divided into 10851300Equity Shares of Rs. 10 each. Further there was no public issue rights issue bonusissue or preferential issue etc. during the year. The Company has not issued shares withdifferential voting rights or sweat equity shares nor has it granted any stock optionsduring the F.Y.

6) TRANSFER TO RESERVES

There was no amount which was transferred to General Reserves during the year underreview. The closing balance of the retained earnings of the Company for F.Y. 2020-2021after all appropriation and adjustments was Rs. 2989.37 lakhs.

7) LISTING WITH THE STOCK EXCHANGE(S)

Your Company's equity shares are listed on the BSE Limited. Annual listing fees for theFinancial Year 2020-21 and 2021-22 have been paid to BSE Limited. The Status of Listing ofthe Company displays it as suspended on the website of Calcutta Stock Exchange Limited.The Company has been sending emails to Calcutta Stock Exchange Limited and continuallyfollowing up for the same awaiting for their reply in this regards.

8) SUBSIDIARIES JOINT VENTURES AND ASSOCIATES COMPANIES

The Company has one Associate Company namely Lemonade Shares & Securities PrivateLimited as on March 31 2021. There are no Subsidiaries or joint venture companies withinthe meaning of Section 2(87) and 2(6) of the Companies Act 2013 ("Act").

Further the report on the performance financial position and overall contribution tocompany's profitability of the Associate Company and salient features of the financialstatements in the prescribed Form AOC-1 is marked and annexed as "Annexure 1"to this report.

9) DEPOSITS

The Company has not accepted any deposits and as such no amount on account of principalor interest on public deposit under section 73 and 74 of the Companies Act 2013 readtogether with the Companies (Acceptance of Deposits) Rules 2014 was outstanding as on thedate of the Balance Sheet.

10) MATERIAL CHANGES AFFECTING THE COMPANY

No material changes and commitments occurred after the close of the financial year2020-21 till the date of this Report which affects the financial position of the Company.It is hereby confirmed that there has been no other change in the nature of business ofthe Company.

Further the COVID-19 pandemic has emerged as a global challenge creating disruptionacross the world. Inspite of the unprecedented situation your Company has been successfulin averting potential adverse impact on the business and on the contrary has grown andcontinues to outperform most of the industry peers. Based on the facts and circumstancesthe company has been operating in normal course and there have been no adverse impacts onthe liquidity revenues or operational parameters during the F.Y. Most of your Company'scosts are flexible and have been managed prudently. In stark contrast to the generalperception this unprecedented crisis has hastened the adoption of digital processes andsystems across the entire country and the industry.

11) CORPORATE Governance

Pursuant to Regulation 34(3) read with Schedule V of the SEBI Listing Regulations2015 a separate section on Corporate Governance practices followed by Company togetherwith a Certificate from Practicing Company Secretary confirming compliance forms anintegral part of this Report.

A declaration with respect to the compliance with the Code of Conduct duly signed bythe Chief Executive Officer and Chief Financial Officer of the Company also forms part ofthis Report

12) BOARD OF DIRECTORS AND Key Managerial PERSONNEL

I. Board of Directors

Following were the Directors as on March 31 2021:

Sr. No. Name of the Person DIN Category
1 Mr. Ankur Agrawal 06408167 Executive Director
2 Mr. Devendra Lal Thakur 00392511 Non-executive Independent Director
3 Mr. Milin Ramani 07697636 Non-executive Independent Director
4 Mrs. Apeksha Kadam 08878724 Additional Director (Non-Executive-Non-Independent women Director)

During Financial year following changes took place in Board of Directors of theCompany;

a. Change in Directors:

(1) Cessation/ Resignation: Ms. Divya Padhiyar (DIN: 08598655) Independent Director ofthe Company has resigned with effect from closing hours of February 112021. Furtherpursuant to Regulation 30 of SEBI Listing Regulations she stated that there was nomaterial reason other than personal and unavoidable circumstances mentioned in herresignation letter.

(2) Appointment/Re-appointment: Pursuant to Regulation 17 of the SEBI ListingRegulations read with section 161 of the Companies Act 2013 and based on recommendationof Nomination and Remuneration Committee the Board of Directors has appointed Mrs.Apeksha Santosh Kadam (DIN: 08878724) as Additional Woman Director with effect fromFebruary 12 2021 to hold office up to the date of forthcoming Annual General Meeting.Further on the Recommendation of Nomination and Remuneration Committee and the Board ofDirectors the Board and subject to approval of Shareholders at ensuing Annual GeneralMeeting it is proposed to appoint Mrs. Apeksha Kadam as Non-Executive Non-IndependentWoman Director of the Company w.e.f. February 12 2021. The Company has received requisitedeclarations from her.

During the year under review the Non-Executive Directors of the Company had nopecuniary relationship or transactions with the Company other than sitting feescommission perquisites and reimbursement of expenses incurred by them for the purpose ofattending meetings of the Board/Committees of the Company.

(3) Director liable to retire by rotation: Pursuant to provisions of Section 152(6) ofthe Act Mr. Ankur Anil Agrawal Executive Director retires by rotation at theforthcoming Annual General Meeting and being eligible offers himself for re-appointment.Brief profile of Mr. Ankur Agrawal as required under Regulation 36 (3) of the SEBI ListingRegulations read with SS-2 on General Meetings is provided in the Notice of the ensuingAGM.

None of the Directors are disqualified for being appointed as the Director of theCompany in terms of Section 164 of the Companies Act 2013.Further the Company after dueassessment took on record the necessary declarations received from the IndependentDirectors under Section 149(7) of the Companies Act 2013 that they meets the criteria ofIndependence laid down in section 149(6) of the Companies Act 2013 and Regulation16(1)(b) of the SEBI Listing Regulations Further All the independent directors areregistered with the Indian Institute of Corporate Affairs ("IICA"). TheIndependent Directors have confirmed that they are not aware of any circumstances orsituation which exists or reasonably anticipated that could impair or impact his abilityto discharge his/her duties with an objective independent judgment and without anyexternal influence.

II. Key Managerial Personnel's (KMP's)

Following were the Key Managerial Personnel's as on March 312021:

Sr. No. Name of the Person Designation
1 Mr. Bharat Shiroya Chief Executive Officer
2 Mrs. Nirmala Kanjar Chief Financial Officer
3 Ms. Sneha Mandelia Company Secretary & Compliance Officer

> Change in Key Managerial Personnel's: The Board of Directors of the Company on recommendationof Nomination and Remuneration Committee had considered and approved the appointment ofMs. Sneha Mandelia as Company Secretary & Compliance Officer of the Company witheffect from July 1 2020.

III. Director's Evaluation

In terms of the requirement of the Companies Act 2013 and Regulation 4 (2)(f) of theSEBI Listing Regulations and annual performance evaluation of the Board is undertakenwhere the Board formally assesses its own performance with the aim to improve theeffectiveness of the Board and the Committees.

The Board and the Nomination and Remuneration Committee reviewed the performance ofindividual directors on the basis of criteria such as the contribution of the individualdirector to the board and committee meetings like preparedness on the issues to bediscussed meaningful and constructive contribution and inputs in meetings etc. Theperformance evaluation of the Independent Directors was carried out by the entire Boardexcluding the Independent Director being evaluated.

In a separate meeting of Independent Directors held on February 11 2021 theperformance evaluation of the Board as whole Chairman of the Company and the NonIndependent Directors was evaluated. The Board of Directors expressed their satisfactionwith the evaluation process based on the recommendation of the Nomination &Remuneration Committee.

IV. Familiarization program for Independent Director(s)

The familiarization program aims to provide the Independent Directors their rolesresponsibilities in the Company nature of the industry business model processes andpolicies and the technology and the risk management systems of the Company theoperational and financial performance of the Company significant development so as toenable them to take well informed decisions in timely manner. Further the Directors areencouraged to attend the training programmers' being organized by variousregulators/bodies/institutions on above matters. The policy on Company's familiarizationprogram for Independent Directors is hosted on the Company's website.

V. Meeting of the Board and its Committees:

The Board has established following three Committees:

a. Audit Committee

b. Nomination and Remuneration Committee and

c. Stakeholders' Relationship Committee.

Details of the Board and its Committees along with their amended charters compositionmeetings held during the year are given under Corporate Governance Report appearingelsewhere as a separate section in this Annual Report.

13) AuDITORS

a. STATuTORY AuDITOR

The Company's Statutory Auditors M/s. A. R. Sodha & Co. Chartered Accountants(FRN 110324W) were appointed for a period of 5 consecutive years till the conclusion ofthe 40th AGM subject to ratification by members every year. Further pursuantto the the Companies (Amendment) Act 2018 effective from 7 May 2018 the requirement ofseeking ratification from the members for the continuation of re-appointment of theStatutory Auditors has been withdrawn from the Statute. The statutory auditors haveconfirmed that they satisfy the independence criteria as required under the Companies Act2013. M/s. A. R. Sodha & Co. Chartered Accountants (FRN 110324W) has confirmed theireligibility and consent under Sections 139 and 141 of the Companies Act 2013 and theCompanies (Audit and Auditors) Rules 2014 for their continuance as the Auditors of theCompany for the financial year 202122. In terms of the SEBI Listing Regulations theAuditors have also confirmed that they hold a valid certificate issued by the Peer ReviewBoard of the ICAI. Further the report of the Statutory Auditors along with the notes isenclosed with the Financial Statements.

The Auditors have issued modified opinion on the Financial Statements for the financialyear ended March 312021 as mentioned below:

The Company has not provided for defined benefit obligation in the nature of gratuitybased on the requirement of Ind AS 19 i.e. "Employee Benefit" which requiresdefined benefit obligation to be recognized based on actuarial valuation basis. In absenceof valuation we are unable to quantify the impact of above on the net profit for the yearand liabilities as on reporting date.

Management's Explanation:

For-payment of gratuity it is accounted-for on payment basis.

Further the Auditors of the Company have not reported any fraud as specified underSection 143(12) of the Companies Act 2013.

b. SECRETARIAL AUDITOR

Pursuant to the provisions of Section 204 of the Companies Act 2013 read with theCompanies (Appointment and Remuneration of Managerial Personnel) Rules 2014 the Companyhas appointed M/s. Mitesh J. Shah & Associates Practicing Company Secretaries(Membership No.: F10070; Certificate of Practice No.: 12891) as Secretarial Auditor ofthe Company for the financial year 2020-21 to conduct the Secretarial Audit and issue theSecretarial Audit Report in Form MR-3.The report of the Secretarial Auditor for thefinancial year 2020-21 is annexed as Annexure 2 to this report. The report isself-explanatory and contains some qualification reservation and adverse remarks asmentioned below:

I. The Company has not complied with provision of section 203 and Regulation 6 (1) ofSEBI (LODR) w.r.t to appointment of Company Secretary as Company Secretary was notappointed within stipulated period of time. However Company Secretary was appointed on 01July 2020 (i.e. after 6 (six) form the resulting vacancy);

II. The Company is suspended on Calcutta Stock Exchange

Management's Explanation:

I. Ms. Sneha Mandelia (ACS 49137) appointed as Company Secretary and Compliance Officerof the Company w.e.f July 01 2020.

II. The Company has been sending emails to Calcutta Stock Exchange and continuallyfollowing up for the same awaiting for their reply in this regards.

Pursuant to circular No. CIR/CFD/CMD1/27/2019 dated 8th February 2019 issued by theSEBI the company has obtained Annual Secretarial Compliance Report for the year endedMarch 31 2021 from Practicing Company Secretaries on compliance of all applicable SEBIRegulations/circulars/ guidelines issued thereunder and the copy of the same has beensubmitted with the Stock Exchange(s)within the prescribed time.

c. INTERNAL AuDITOR

M/s. Siddhant Shah & Co. Practicing Chartered Accountants Mumbai performed theduties of internal auditors of the company for the F.Y. 2020-21 and their report isreviewed by the Audit committee from time to time. Further Board of Directors of theCompany were informed that M/s. Siddhant Shah & Co. has integrated it's Organizationwith M/s. AHSP & Co. LLP hence the Company has appointed M/s. AHSP & Co. LLP asan Internal Auditors of the company for the F.Y. 2021-22.

d. COST AUDITOR

The Maintenance of the cost records for the services rendered by the Company is notrequired pursuant to Section 148(1) of the Companies Act 2013 read with Rule 3 of theCompanies (Cost records and Audit) Rules 2014 and accordingly it is not required toappoint Cost Auditor

14) NOMINATION AND REMUNERATION POLICY

The Company has a Nomination and Remuneration Policy for Directors and SeniorManagerial Personnel approved by the Nomination and Remuneration Committee and the Board.The policy is available at the website of the Company at web link http://www.comfortfincap.com/Investorrelation.The purpose of the Remuneration Policy is to establish and govern the procedureapplicable:

• To evaluate the performance of the members of the Board.

• To ensure remuneration payable to Directors KMP's & other Senior Managementstrike appropriate balance and Commensurate among others with the functioning of theCompany and its long term objectives.

• To retain motivate and promote talent within the Company and to ensure long termsustainability of the managerial persons and create competitive advantage.

The policy inter-alia covers the Directors' appointment and remuneration KeyManagerial Personnel and other senior management appointment and remuneration.

15) CODE OF CONDUCT

The Company has adopted a Code of Conduct for Prevention of Insider Trading and Codefor Fair Disclosure with a view to regulate trading in securities by the Directors anddesignated person of the Company in compliance with SEBI (Prohibition of Insider Trading)Regulations 2015. The code is available on website of the Company at web link link http://www.comfortfincap.com/Investorrelation

16) RELATED Party TRANSACTIONS

The Company has put in place a policy for related party transactions ('RPT policy')which has been approved by the Board of Directors. The RPT policy provides foridentification of related party transactions necessary approvals by the AuditCommittee/Board of Directors/ Shareholders reporting and disclosure requirements incompliance with the Act and the SEBI Listing Regulations. The said RPT policy has beenuploaded on the website of the Company and can be accessed at the following link: http://www.comfortfincap.com/Investorrelation.

During the year under review all related party transactions are at an arm's lengthbasis in the ordinary course of business. All related party transactions are placedbefore the Audit Committee for review and approval of the Committee and to the Board forapproval.

Further details of the material related party transactions under Section 188 (1) ofthe Companies Act 2013 required to be disclosed under Form AOC-2 pursuant to Section 134(3) of the Act is not applicable as the Company has not entered into any suchtransactions.

Pursuant to Regulation 23(9) of the SEBI Listing Regulations your Company has filedthe half yearly reports on related party transactions with the Stock Exchanges.

17) WHISTLE BLOWER POLICY/VIGIL MECHANISM

In Compliance with Section 177(9) of the Companies Act 2013 and Regulation 22 of SEBIListing Regulations the Company has adopted a Whistle Blower Policy. The Company's vigilmechanism/ Whistle blower Policy aims to provide the appropriate platform and protectionfor Whistle Blowers to report instances of fraud and mismanagement if any to promotereporting of any unethical or improper practice or violation of the Company's Code ofConduct or complaints regarding accounting auditing internal controls or suspectedincidents of violation of applicable laws and regulations including the Company's code ofconduct or ethics policy or Code of Conduct for Prevention of Insider Trading in theCompany Code of Fair practices and Disclosure.

The Vigil Mechanism provides a mechanism for employees of the Company to approach theChairman of the Audit Committee of the Company for redressal. Details of the VigilMechanism and Whistleblower policy are made available on the Company's website at http://www.comfortfincap.com/Investorrelation

During the Financial Year 2020-21 no cases under this mechanism were reported to theCompany

18) PREVENTION OF SEXuAL Harassment OF WOMEN AT WORKPLACE

The Company is committed to upheld and maintain the dignity of woman employees and toprovide a safe and conducive work environment to all its employees and associates workingin the Company. In Compliance with the Sexual Harassment of Women at Workplace(Prevention Prohibition and Redressal) Act 2013 your company has put in place Policy onPrevention of Sexual Harassment at Workplace. All employees (permanent contractualtemporary trainees) are covered under this policy.

Your Directors further state that during the financial year 2020-21 there were nocomplaints received pursuant to Sexual Harassment of Women at Workplace (PreventionProhibition and Redressal) Act 2013.

19) annual return

Pursuant to Section 92(3) of the Act and Rule 12 of the Companies (Management andAdministration) Rules 2014 the Annual Return for F.Y. 2020-21 is available on Company'swebsite at www.comfortfincap.com.

20) DIRECTORS' Responsibility STATEMENT

Pursuant to Section 134 of the Companies Act 2013 and to the best of Board'sknowledge and belief and according to the information and explanations obtained by themyour Directors confirm the following statements:

i. In the preparation of the annual accounts for the year ended March 312021 theapplicable accounting standards have been followed and there are no material departures.

ii. The Directors have selected such accounting policies and applied them consistentlyand made judgments and estimates that were reasonable and prudent so as to give a true andfair view of the state of affairs of the Company at the end of the financial year and ofthe profit of the Company for the year under review.

iii. The Directors have taken proper and sufficient care for the maintenance ofadequate accounting records in accordance with the provisions of this Act for safeguardingthe assets of the Company and for preventing and detecting fraud and other irregularities.

iv. The Directors have prepared the annual accounts on a going concern basis.

v. The Directors had laid down internal financial controls to be followed by thecompany and that such internal financial controls are adequate and were operatingeffectively.

vi. The Directors had devised proper system to ensure compliance with the provisions ofall applicable laws and that such system were adequate and operating effectively.

21) MANAGEMENT DISCUSSION AND ANALYSIS REPORT

Management Discussion and Analysis Report as stipulated under the SEBI ListingRegulations is presented in a separate section forming part of this Annual Report. Itprovides details about the overall industry structure global and domestic economicscenarios developments in business operations/ performance of the Company's variousbusinesses internal controls and their adequacy risk management systems human resourcesand other material developments during the financial year 2020-21.

22) REMUNERATION TO DIRECTORS PARTICULARS OF EMPLOYEES AND HUMAN RESOURCES (HR):

Your Company had 9 employees as on March 312021. The statement containing particularsof employees as required under Section 197(12) of the Companies Act 2013 read along withRule 5(2) and 5(3) of the Companies (Appointment and Remuneration of Managerial Personnel)Rules 2014 is not applicable to the Company as no employees were in receipt ofremuneration above the limits specified in Rule 5(2) of the Companies (Appointment andRemuneration of Managerial Personnel) Rules 2014.

Further the ratio of the remuneration of each Director to the median employee'sremuneration and other details in terms of Section 197(12) of the Companies Act 2013 readalong with Rule 5(1) of the Companies (Appointment and Remuneration of ManagerialPersonnel) Rules 2014 is annexed herewith as Annexure 3 and forms part of thisReport.

Your Directors would like to record their appreciation of the efficient and loyalservice rendered by the employees.

23) INTERNAL CONTROL SYSTEMS AND THEIR ADEQUACY

The Company has adequate system of internal control to safeguard and protect from lossunauthorized use or disposition of its assets. All the transactions are properlyauthorized recorded and reported to the Management. The Company is following all theapplicable Accounting Standards for properly maintaining the books of accounts andreporting financial statements. The internal auditor of the company checks and verifiesthe internal control and monitors them in accordance with policy adopted by the company.The Company continues to ensure proper and adequate systems and procedures commensuratewith its size and nature of its business.

24) CONSERVATION OF Energy AND Technology ABSORPTION & Foreign Exchange EarningsAND OUTGO

The Company is taking all possible measures to conserve energy. Several environmentfriendly measures are adopted by the Company. The Company continued to give major emphasisfor conservation of Energy and the measures taken during the previous years werecontinued. The Company regularly reviews power consumption patterns across its units andimplement requisite improvements/changes in the process in order to optimize powerconsumptions.

The Company's operations do not require significant import of technology

Foreign Exchange Earnings and Outgo

Details of foreign exchange earnings and outgo required under Section 134 (3) (m) ofthe Act read with Rule 8 (3) of the Companies (Accounts) Rules 2014 are as under:

Total Foreign Exchange used and earned by the Company is as follows:

Particulars Year Ended March 312021 Year Ended March 312020
Foreign Exchange Used - -
Foreign Exchange Earned - -

25) CORPORATE SOCIAL RESPONSIBILITY (CSR)

Your Company's profits net worth and turnover are far below the criteria as mentionedin Section 135 of the Companies Act 2013 read with Companies (Corporate SocialResponsibility Policy) Rules 2014. Hence the CSR provisions are not applicable to theCompany during the F.Y. 2020-21

26) BUSINESS RISK MANAGEMENT

Pursuant to section 134 (3) (n) of the Companies Act 2013 the company has adequaterisk management mechanism and is periodically reviewed by the Board. The major risksidentified by the business are systematically addressed through mitigating actions on acontinuing basis and cost-effectively risks are controlled to ensure that any residualrisks are at an acceptable level. The company has been addressing various risks impactingthe company and brief view of the company on risk management is provided in ManagementDiscussion and Analysis Report.

27) PARTICuLARS OF LOANS GuARANTEES AND INVESTMENTS

Loans Guarantee and Investments covered under Section 186 of the Companies Act 2013form part of the notes to the financial statements provided in this Annual Report.

28) CHIEF EXECuTIVE OFFICER & CHIEF FINANCIAL OFFICER CERTIFICATION

Chief Executive Officer & Chief Financial Officer Certification as required underRegulation 17 (8) read with Part B of Schedule II of the SEBI Listing Regulationscertifying that the financial statements do not contain any untrue statement and thesestatements represent a true and fair view of the Company's affairs has been obtained.

29) Significant AND MATERIAL ORDERS PASSED By The REGuLATORS OR COuRTS

During the Financial Year 2020-21 there were no significant or material orders passedby the Regulators or Courts or Tribunals impacting the going concern status and operationsof the Company in the future.

30) SECRETARIAL STANDARDS

Your Company has complied with the applicable Secretarial Standard SS-1 and SS-2 withrespect to Board Meetings and General Meetings respectively specified by the Institute ofCompany Secretaries of India.

31) ACKNOWLEDGEMENTS

Your Board takes this opportunity to place on record our deep appreciation to ourShareholders Customers Business Partners Vendors Bankers Financial InstitutionsRegulatory and Government Authorities and other Stakeholders at large for all supportrendered during the year under review. We strive to build rewarding relationships with ourstakeholders - clients employees shareholders business partners communities andregulators - for achieving our long-term vision aligned with our stakeholders' interests.

The Directors also thank the Government of India Governments of various states inIndia and concerned Government departments and agencies for their co-operation. TheDirectors hereby acknowledge the dedication loyalty hard work cooperation solidarityand commitment rendered by the employees of the Company and their families during the year

The Directors deeply regret the losses suffered due to the Covid-19 pandemic and placeon record their sincere appreciation to all the front-line workers and those who have gonebeyond their duties in battling against the pandemic.

BY ORDER OF THE BOARD OF DIRECTORS OF COMFORT FINCAP LIMITED
Sd/-
ANKUR AGRAWAL
Chairman & DIRECTOR
DATE : JULY 29 2021 DIN: 06408167
PLACE : MUMBAI

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