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Comfort Intech Ltd.

BSE: 531216 Sector: Consumer
NSE: N.A. ISIN Code: INE819A01031
BSE 15:05 | 07 Dec 29.85 -0.10
(-0.33%)
OPEN

29.50

HIGH

30.00

LOW

29.40

NSE 05:30 | 01 Jan Comfort Intech Ltd
OPEN 29.50
PREVIOUS CLOSE 29.95
VOLUME 33086
52-Week high 33.75
52-Week low 19.80
P/E 18.43
Mkt Cap.(Rs cr) 95
Buy Price 29.85
Buy Qty 67.00
Sell Price 29.95
Sell Qty 279.00
OPEN 29.50
CLOSE 29.95
VOLUME 33086
52-Week high 33.75
52-Week low 19.80
P/E 18.43
Mkt Cap.(Rs cr) 95
Buy Price 29.85
Buy Qty 67.00
Sell Price 29.95
Sell Qty 279.00

Comfort Intech Ltd. (COMFORTINTECH) - Director Report

Company director report

To the Members of the Company

Your Directors have pleasure in presenting the Twenty Seventh AnnualReport of Comfort Intech Limited ('the Company') on the business and operations of yourCompany along with the Audited Financial Statement (Consolidated and Standalone) for theFinancial year ended March 312021.

1) financial highlights:

The summary of Audited Consolidated and Standalone Financialperformance of the Company for the financial year ended March 312021 is summarized asunder:

(Rs. In Lakhs)

PARTICULARS STANDALONE CONSOLIDATED
2020-2021 2019-2020 2020-2021 2019-2020
Revenue from Operations 12241.85 8343.33 12241.85 8343.33
Other operating Income 16.10 3.18 16.10 3.18
Total Revenue 12257.96 8346.51 12257.96 8346.51
Total Expenditure 11678.59 8356.78 11678.59 8356.78
Profit before Tax 579.37 (10.28) 579.37 (10.28)
Current Tax Expenses 133.47 51.43 133.47 51.43
Deferred Tax (32.84) 0 (32.84) 0
Tax of earlier years (3.82) 1.30 (3.82) 1.30
Profit for the Year 482.57 (63) 1020.99 (221.72)
Earnings Per Share (EPS in Rs.) 1.51 (0.20) 3.19 (0.69)

2) financial performance

The Consolidated and Standalone Financial Statements of the Company forthe year ended March 312021 have been prepared in accordance with Indian AccountingStandards (IND-AS) the relevant provisions of section 129 and 133 of Companies Act 2013Regulation 33 of SEBI (Listing Obligations and Disclosure Requirements) Regulations 2015(hereinafter referred to as "the SEBI Listing Regulations") which have beenreviewed by the Statutory Auditors. The Company is submitting the quarterly / half yearly/ annual financial results on both Standalone and Consolidated basis.

At Standalone Level the revenue from operations has increased to Rs.12241.85 Lakhs for the F.Y. as compared to Rs. 8343.33 Lakhs in the Previous Year. The NetProfit for the F.Y. increased to Rs. 482.57lakhs against loss of Rs. 63 lakhs reported inthe Previous Year.

The Consolidated revenue from operations increased to Rs. 12241.85Lakhs for the F.Y. as compared to Rs. 8343.33Lakhs in the Previous Year. The Net Profitfor the F.Y. increased to Rs. 1020.99 lakhs against loss of Rs. 221.72 lakhs reported inthe Previous Year.

In accordance with the provisions contained in section 136 of theCompanies Act 2013 the Annual Report of the Company containing Notice of the AnnualGeneral Meeting Consolidated and Standalone Financial Statements Report of the Auditor'sand Board of Directors thereon are available on the website of the Company atwww.comfortintech.com. Further a detailed analysis of Company's performance is includedin the Management Discussion and Analysis Report ("MDAR") which forms part ofthis Annual report

3) DIVIDEND

Based on the Company's financial performance for the year 2020-21 andin order to conserve cash resources to face the challenges and the contingencies createdby COVID19 pandemic the Board of Directors have not recommended any dividend on equityshares for the year ended on March 312021.

4) SHARE CAPITAL

During the year under review there has been no change in share capitalof the Company. The paid-up Equity Share Capital of the Company as on March 312021 wasRs. 319938080.. Further there was no public issue rights issue bonus issue orpreferential 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.

5) TRANSFER TO RESERVES

There was no amount which was transferred to General Reserves duringthe year under review. The closing balance of the retained earnings of the Company forF.Y. 2020-2021 after all appropriation and adjustments was Rs. 7167.95 lakhs.

6) LISTING WITH THE STOCK EXCHANGE(S)

Your Company's equity shares are listed on the BSE Limited. Annuallisting fees for the Financial Year 2020-21 and 2021-22 have been paid to BSE Limited(Scrip Code: 531216) where the shares of the company are listed.

7) subsidiaries joint ventures and associates companies

The Company has three Associate Companies namely Lemonade Shares &Securities Private Limited Comfort Securities Limited and Liquors India Limited as onMarch 312021. There are no Subsidiaries or joint venture Companies within the meaning ofSection 2(87) and 2(6) of the Companies Act 2013 ("Act").

Further the report on the performance financial position and overallcontribution to company's profitability of the Associate Company and salient features ofthe financial statements in the prescribed Form AOC-1 is marked and annexed as "Annexure1" to this report.

8) transfer of unclaimed dividend amounts and concerned shares toinvestor education and protection fund (IEPF) authority

Your Company did not have any funds lying in unpaid or unclaimeddividend accounts for a consecutive period of seven years. Therefore there were no fundswhich were required to be transferred to the Investor Education and Protection Fund(IEPF). Further members who have not yet en-cashed their Final Dividends of financialyears 2014-15 2015-16 and 2016-17 are requested to make their claims to the Company /RTA. Members are requested to quote folio numbers / DP ID - Client ID in all theircorrespondence.

9) DEPOSITS

The Company has not accepted any deposits and as such no amount onaccount of principal or interest on public deposit under section 73 and 74 of theCompanies Act 2013 read together with the Companies (Acceptance of Deposits) Rules 2014was outstanding as on the date of the Balance Sheet.

10) MATERIAL CHANGES AFFECTING THE COMPANY

During the year under review the company has received following ordersfrom Securities and Exchange board of India:

1. Adjudication order no. Order/AP/SK/2020-21/10006 dated December 282020 under Section 15-I of Securities and Exchange Board of India Act 1992 read with rule5 of SEBI (Procedure For Holding Inquiry And Imposing Penalties By Adjudicating Officer)Rules 1995 and accordingly the company had paid penalty of ' 100000/- (Rupees One LakhOnly).

2. Order passed by Whole time member vide SEBI Order no.WTM/SM/IVD/ID5/10430/2020-21 dated February 15 2021 Under Sections 11 11(4) and 11B (1)of the Securities and Exchange Board of India Act 1992 directing that the company hasbeen restrain from accessing the securities market and further prohibit them from buyingselling or otherwise dealing in securities directly or indirectly or being associatedwith the securities market in any manner for a period of six (06) months from the date ofthe Order. Further Appeal was filed before SEBI SAT and vide order dated May 112021SEBI SAT had given stay order till pendency of the Appeal.

Further It is hereby confirmed that there has been no other change inthe nature of business of the Company.

Further the COVID-19 pandemic has emerged as a global challengecreating disruption across the world. Inspite of the unprecedented situation your Companyhas been successful in averting potential adverse impact on the business and on thecontrary has grown and continues to outperform most of the industry peers. Based on thefacts and circumstances the company has been operating in normal course and there havebeen no adverse impacts on the liquidity revenues or operational parameters during theF.Y. Most of your Company's costs are flexible and have been managed prudently. In starkcontrast to the general perception this unprecedented crisis has hastened the adoption ofdigital processes and systems across the entire country and the industry.

11) CORPORATE GOVERNANCE

Pursuant to Regulation 34(3) read with Schedule V of the SEBI ListingRegulations a separate section on Corporate Governance practices followed by Companytogether with a Certificate from Practicing Company Secretary confirming compliance formsan integral part of this Report.

A declaration with respect to the compliance with the Code of Conductduly signed by the Chief Executive Officer and Chief Financial Officer of the Company alsoforms part of this Report.

12) BOARD OF DIRECTORS AND KEY MANAGERIAL PERSONNEL

I. Board of directors

Following were the Directors as on March 31 2021:

Name of the Person din Category
1 Mr. Ankur Agrawal 06408167 Non-Executive Non Independent 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 ( Executive Women Director)

During Financial year following changes took place in Board ofDirectors of the Company;

a. Change in Directors:

1) Cessation/ Resignation: Ms. Divya Padhiyar (DIN: 08598655)Independent Director of the Company has resigned with effect from closing hours ofFebruary 112021. Further pursuant to Regulation 30 of SEBI Listing Regulations shestated that there was no material reason other than personal and unavoidable circumstancesmentioned in her resignation letter.

2) Appointment/Re-appointment:

> Pursuant to Regulation 17 of the SEBI Listing Regulations readwith section 161 of the Companies Act 2013 and based on recommendation of Nomination andRemuneration Committee the Board of Directors has appointed Mrs. Apeksha Kadam (DIN:08878724) as Additional Woman Director with effect from February 11 2021 to hold officeup to the date of forthcoming Annual General Meeting. Further on the Recommendation ofNomination and Remuneration Committee and the Board of Directors the Board and subject toapproval of Shareholders at ensuing Annual General Meeting it is proposed to appoint Mrs.Apeksha Kadam as Executive Woman Director of the Company. The Company has receivedrequisite declarations from her.

> Pursuant to section 149 of the Companies Act 2013 and based onthe recommendation of Nomination and Remuneration Committee the board of Directors it ispropose to re-appoint Mr. Devendra Lal Thakur (DIN: 00392511) as Non- ExecutiveIndependent director of the Company w.e.f. November 24 2020 for the second term. Furtherthe Company has received all the requisite declaration to re-appoint him as an Independentdirector of the Company.

> During the year under review the Executive Director of theCompany had no pecuniary relationship or transactions with the Company other than sittingfees commission perquisites and reimbursement of expenses incurred by them for thepurpose of attending meetings of the Board / Committees of the Company.

3) Director liable to retire by rotation: Pursuant to provisions ofSection 152(6) of the Act Mr. Ankur Anil Agrawal Non-Executive Director retires byrotation at the forthcoming Annual General Meeting and being eligible offers himself forre-appointment. Brief profile of Mr. Ankur Agrawal as required under Regulation 36 (3) ofthe SEBI Listing Regulations read with SS-2 on General Meetings is provided in the Noticeof the ensuing AGM.

None of the Directors are disqualified for being appointed as theDirector of the Company in terms of Section 164 of the Companies Act 2013.Further theCompany after due assessment took on record the necessary declarations received from theIndependent Directors under Section 149(7) of the Companies Act 2013 that they meets thecriteria of Independence laid down in section 149(6) of the Companies Act 2013 andRegulation 16(1)(b) of the SEBI Listing Regulations Further All the independentdirectors are registered with the Indian Institute of Corporate Affairs("IICA"). The Independent Directors have confirmed that they are not aware ofany circumstances or situation which exists or reasonably anticipated that could impairor impact his ability to discharge his/her duties with an objective independent judgmentand without any external influence.

ii) Key Managerial Personnel's (KMP's)

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

Name of the Person Designation
1 Mr. Anil Agrawal Chief Executive Officer
2 Mr. Kailash Purohit Chief Financial Officer
3 Mr. Hiren Gediya Company Secretary & Compliance Officer

> Change in Key Managerial Personnel's: The Board of Directors ofthe Company on recommendation of Nomination and Remuneration Committee had consideredand approved the appointment of Mr. Kailash Purohit as Chief Financial Officer (CFO)w.e.f. September 10 2020.

> Further the Company has appointed Mr. Hiren Gediya as CompanySecretary and Compliance Officer of the Company w.e.f. from July 15 2020 and has resignedw.e.f July 15 2021.

However post financial year following changes took place in KeyManagerial Personnel's of the Company.

> The Board of Directors of the Company on recommendation ofNomination and remuneration Committee appointed Ms. Nidhi Basu as Company Secretary andCompliance Officer of the Company w.e.f. from August 112021.

iii) Director's Evaluation

In terms of the requirement of the Companies Act 2013 and Regulation 4(2) (f) of the SEBI Listing Regulations and annual performance evaluation of the Board isundertaken where the Board formally assesses its own performance with the aim to improvethe effectiveness of the Board and the Committees.

The Board and the Nomination and Remuneration Committee reviewed theperformance of individual directors on the basis of criteria such as the contribution ofthe individual director to the board and committee meetings like preparedness on theissues to be discussed meaningful and constructive contribution and inputs in meetingsetc. The performance evaluation of the Independent Directors was carried out by the entireBoard excluding the Independent Director being evaluated.

In a separate meeting of Independent Directors held on February 112021 the performance evaluation of the Board as whole Chairman of the Company and theNon Independent Directors was evaluated. The Board of Directors expressed theirsatisfaction with 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 Directorstheir roles responsibilities in the Company nature of the industry business modelprocesses and policies and the technology and the risk management systems of the Companythe operational 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 various regulators /bodies / institutions on above matters. The policy on Company's familiarization programfor Independent Directors is hosted on the Company's website.

V) Meeting of the Board and its committees:

The Board has established following Four Committees:

a. Audit Committee ;

b. Nomination and Remuneration Committee ;

c. Stakeholders' Relationship Committee and

d. Corporate Social Responsibility Committee

Details of the Board and its Committees along with their amendedcharters composition meetings held during the year are given under Corporate GovernanceReport appearing elsewhere as a separate section in this Annual Report.

13) AUDITORS

(a) STATUTORY AUDITOR

The Company's Statutory Auditors M/s. A. R. Sodha & Co. CharteredAccountants (FRN 110324W) were appointed for a period of 5 consecutive years till theconclusion of the 28th AGM subject to ratification by members every year. Furtherpursuant to the Companies (Amendment) Act 2018 effective from 7 May 2018 therequirement of seeking ratification from the members for the continuation ofre-appointment of the Statutory Auditors has been withdrawn from the Statute. Thestatutory auditors have confirmed that they satisfy the independence criteria as requiredunder the Companies Act 2013. M/s. A. R. Sodha & Co. Chartered Accountants (FRN110324W) has confirmed their eligibility and consent under Sections 139 and 141 of theCompanies Act 2013 and the Companies (Audit and Auditors) Rules 2014 for theircontinuance as the Auditors of the Company for the financial year 2021-22. In terms of theSEBI Listing Regulations the Auditors have also confirmed that they hold a validcertificate issued by the Peer Review Board of the ICAI. Further the report of theStatutory Auditors along with the notes is enclosed with the Financial Statements.

The Auditors have issued modified opinion on the Financial Statementsfor the financial year ended March 312021 as mentioned below:

The Company has not provided for defined benefit obligation in thenature of gratuity based on the requirement of Ind AS 19 i.e. "EmployeeBenefit" which requires defined benefit obligation to be recognized based onactuarial valuation basis. In absence of valuation we are unable to quantify the impact ofabove on the net profit for the year and 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 asspecified under Section 143(12) of the Companies Act 2013.

(b) secretarial auditor

Pursuant to the provisions of Section 204 of the Companies Act 2013read with the Companies (Appointment and Remuneration of Managerial Personnel) Rules2014 the Company has appointed M/s. Mitesh J. Shah & Associates Practicing CompanySecretaries (Membership No.: F10070; Certificate of Practice No.: 12891) as SecretarialAuditor of the Company for the financial year 2020-21 to conduct the Secretarial Audit andissue the Secretarial Audit Report in Form MR-3.The report of the Secretarial Auditor forthe financial year 2020-21 is annexed as Annexure 2 to this report. The report isself-explanatory and contains some qualification reservation and adverse as follows.

I. The Company has not complied with provision of section 179 (3)of theCompanies Act 2013 w.r.t. removal of CFO and passing of necessary resolution under thesaid provision ;

II. The Adjudication Order has been passed by the Adjudicatingofficer vide. SEBI No. Order/ AP/SK/20202- 21/10006 dated December 28 2020 and theCompany has been charged under section 15A(b) of SEBI Act for Rupees One lakh Only.

Managements Explanation:-

i) The Company has complied with the provision of section 179 (3)of theCompanies Act 2013. The word resigned was used instead of Removal.

ii) As per the Adjudication order the Company has made the payment ofRupees One Lakh.

Pursuant to circular No. CIR/CFD/CMD1/27/2019 dated 8th February 2019issued by the SEBI the company has obtained Annual Secretarial Compliance Report for theyear ended March 31 2021 from Practicing Company Secretaries on compliance of allapplicable SEBI Regulations/circulars/ guidelines issued there under and the copy of thesame has been submitted with the Stock Exchange(s)within the prescribed time.

(c) INTERNAL AUDITOR

M/s. Siddhant Shah & Co. Practicing Chartered Accountants Mumbaiperformed the duties of internal auditors of the company for the F.Y. 2020-21 and theirreport is reviewed by the Audit committee from time to time. Further Board of Directorsof the Company were informed that M/s. Siddhant Shah & Co. has integrated it'sOrganization with M/s. AHSP & Co. LLP hence the Company has appointed M/s. AHSP &Co. LLP as an 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 theCompany is not required pursuant to Section 148(1) of the Companies Act 2013 read withRule 3 of the Companies (Cost records and Audit) Rules 2014 and accordingly it is notrequired to appoint Cost Auditor.

14) NOMINATION AND REMUNERATION POLICY

The Company has a Nomination and Remuneration Policy for Directors andSenior Managerial Personnel approved by the Nomination and Remuneration Committee and theBoard. The policy is available at the website of the Company at web linkhttp://www.comfortintech.com/Investorrelation. The purpose of the Remuneration Policy isto establish and govern the procedure applicable:

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

• To ensure remuneration payable to Directors KMP's & otherSenior Management strike appropriate balance and Commensurate among others with thefunctioning of the Company and its long term objectives.

• To retain motivate and promote talent within the Company and toensure long term sustainability of the managerial persons and create competitiveadvantage.

The policy inter-alia covers the Directors' appointment andremuneration Key Managerial Personnel and other senior management appointment andremuneration.

15) CODE OF CONDUCT

The Company has adopted a Code of Conduct for Prevention of InsiderTrading and Code for Fair Disclosure with a view to regulate trading in securities by theDirectors and designated person of the Company in compliance with SEBI (Prohibition ofInsider Trading) Regulations 2015. The code is available on website of the Company at weblink link http://www.comfortintech.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 providesfor identification 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.comfortintech.com/Investorrelation.

During the year under review all related party transactions are at anarm's length basis in the ordinary course of business. All related party transactions areplaced before the Audit Committee for review and approval of the Committee and to theBoard for approval.

The Company has not entered into any material transactions with relatedparties referred to in Section 188(1) of the Companies Act 2013 and in compliance withthe SEBI Listing Regulations. Accordingly the details are not required to be given underAOC-2.

Pursuant to Regulation 23(9) of the SEBI Listing Regulations yourCompany has filed the half yearly reports on related party transactions with the StockExchanges.

17) WHISTLE BLOWER POLICY / VIGIL MECHANISM

In Compliance with Section 177(9) of the Companies Act 2013 andRegulation 22 of SEBI Listing Regulations the Company has adopted a Whistle BlowerPolicy. The Company's vigil mechanism/ Whistle blower Policy aims to provide theappropriate platform and protection for Whistle Blowers to report instances of fraud andmismanagement if any to promote reporting of any unethical or improper practice orviolation of the Company's Code of Conduct or complaints regarding accounting auditinginternal controls or suspected incidents of violation of applicable laws and regulationsincluding the Company's code of conduct or ethics policy or Code of Conduct for Preventionof Insider Trading in the Company Code of Fair practices and Disclosure.

The Vigil Mechanism provides a mechanism for employees of the Companyto approach the Chairman of the Audit Committee of the Company for redressal. Details ofthe Vigil Mechanism and Whistleblower policy are made available on the Company's websiteat http://www.comfortintech.com/Investorrelation

During the Financial Year 2020-21 no cases under this mechanism werereported to the Company.

18) prevention of sexual harassment of women at workplace

The Company is committed to upheld and maintain the dignity of womanemployees and to provide a safe and conducive work environment to all its employees andassociates working in the Company. In Compliance with the Sexual Harassment of Women atWorkplace (Prevention Prohibition and Redressal) Act 2013 your company has put in placePolicy on Prevention of Sexual Harassment at Workplace. All employees (permanentcontractual temporary trainees) are covered under this policy.

Your Directors further state that during the financial year 2020-21there were no complaints received pursuant to Sexual Harassment of Women at Workplace(Prevention Prohibition and Redressal) Act 2013.

19) annual return

Pursuant to Section 92(3) of the Act and Rule 12 of the Companies(Management and Administration) Rules 2014 the Annual Return for F.Y. 2020-21 isavailable on Company's weblink http://www.comfortintech.com/Admin/File/Form MGT 7-1 .pdf.

20) directors' responsibility statement

Pursuant to Section 134 of the Companies Act 2013 and to the best ofBoard's knowledge and belief and according to the information and explanations obtained bythem your Directors confirm the following statements:

i. In the preparation of the annual accounts for the year ended March312021 the applicable accounting standards have been followed and there are no materialdepartures.

ii. The Directors have selected such accounting policies and appliedthem consistently and made judgments and estimates that were reasonable and prudent so asto give a true and fair view of the state of affairs of the Company at the end of thefinancial year and of the profit of the Company for the year under review.

iii. The Directors have taken proper and sufficient care for themaintenance of adequate accounting records in accordance with the provisions of this Actfor safeguarding the assets of the Company and for preventing and detecting fraud andother irregularities.

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

v. The Directors had laid down internal financial controls to befollowed by the company and that such internal financial controls are adequate and wereoperating effectively.

vi. The Directors had devised proper system to ensure compliance withthe provisions of all applicable laws and that such system were adequate and operatingeffectively.

21) MANAGEMENT DISCUSSION AND ANALYSIS REPORT

Management Discussion and Analysis Report as stipulated under the SEBIListing Regulations is presented in a separate section forming part of this AnnualReport. It provides details about the overall industry structure global and domesticeconomic scenarios developments in business operations/ performance of the Company'svarious businesses internal controls and their adequacy risk management systems humanresources and other material developments during the financial year 2020-21.

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

Your Company had 7 employees as on March 312021. The statementcontaining particulars of employees as required under Section 197(12) of the CompaniesAct 2013 read along with Rule 5(2) and 5(3) of the Companies (Appointment andRemuneration of Managerial Personnel) Rules 2014 is not applicable to the Company as noemployees were in receipt of remuneration above the limits specified in Rule 5(2) of theCompanies (Appointment and Remuneration of Managerial Personnel) Rules 2014.

Further the ratio of the remuneration of each Director to the medianemployee's remuneration and other details in terms of Section 197(12) of the CompaniesAct 2013 read along with Rule 5(1) of the Companies (Appointment and Remuneration ofManagerial Personnel) Rules 2014 is annexed herewith as Annexure 3 and forms partof this Report.

Your Directors would like to record their appreciation of the efficientand loyal service rendered by the employees.

23) CORPORATE SOCIAL RESPONSIBILITY (CSR)

During the year the company has identified the following as the focusarea for its CSR activity(ies) : Promoting Education skill development and vocationaltraining. The CSR Policy is hosted on the Companies website at www.comfortintech. com

The composition of the CSR Committee CSR Policy and other requireddetails are given in the Annual Report on CSR Activities annexed to this Report as Annexure4.

24) INTERNAL CONTROL SYSTEMS AND THEIR ADEQUACY

The Company has adequate system of internal control to safeguard andprotect from loss unauthorized use or disposition of its assets. All the transactions areproperly authorized recorded and reported to the Management. The Company is following allthe applicable 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.

25) CONSERVATION OF ENERGY AND TECHNOLOGY ABSORPTION & FOREIGNEXCHANGE EARNINGS AND OUTGO

The Company is taking all possible measures to conserve energy. Severalenvironment friendly measures are adopted by the Company. The Company continued to givemajor emphasis for conservation of Energy and the measures taken during the previousyears were continued. The Company regularly reviews power consumption patterns across itsunits and implement requisite improvements / changes in the process in order to optimizepower consumptions.

The Company's operations do not require significant import oftechnology

Foreign Exchange Earnings and Outgo

Details of foreign exchange earnings and outgo required under Section134 (3) (m) of the Act read with Rule 8 (3) of the Companies (Accounts) Rules 2014 are asunder:

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 - -

26) BUSINESS RISK MANAGEMENT

Pursuant to section 134 (3) (n) of the Companies Act 2013 the companyhas adequate risk management mechanism and is periodically reviewed by the Board. Themajor risks identified by the business are systematically addressed through mitigatingactions on a continuing basis and cost-effectively risks are controlled to ensure that anyresidual risks are at an acceptable level. The company has been addressing various risksimpacting the company and brief view of the company on risk management is provided inManagement Discussion and Analysis Report.

27) PARTICULARS Of LOANS GUARANTEES And INVESTMENTS

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

28) Chief EXECUTIVE OFFICER & Chief FINANCIAL OFFICER CERTIFICATION

Chief Executive Officer & Chief Financial Officer Certification asrequired under Regulation 17 (8) read with Part B of Schedule II of the SEBI ListingRegulations certifying that the financial statements do not contain any untrue statementand these statements represent a true and fair view of the Company's affairs has beenobtained.

29) SIGNIFICANT AND MATERIAL ORDERS PASSED BY THE REGULATORS OR COURTS

During the Financial Year 2020-21 there were no significant ormaterial orders passed by the Regulators or Courts or Tribunals impacting the goingconcern status and operations of the Company in the future.

30) Secretarial Standards

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

31) Acknowledgements

Your Board takes this opportunity to place on record our deepappreciation to our Shareholders Customers Business Partners Vendors BankersFinancial Institutions Regulatory and Government Authorities and other Stakeholders atlarge for all support rendered during the year under review. We strive to build rewardingrelationships with our stakeholders - clients employees shareholders business partnerscommunities and regulators - for achieving our long-term vision aligned with ourstakeholders' interests.

FOR AND ON BEHALF OF THE BOARD OF DIRECTORS OF COMFORT INTECH LIMITED
SD/-
ANKUR AGRAWAL
PLACE: MUMBAI chairman & director
DATE : AUGUST 112021 DIN: 06408167

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