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Electrotherm (India) Ltd.

BSE: 526608 Sector: Metals & Mining
NSE: ELECTHERM ISIN Code: INE822G01016
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VOLUME 260
52-Week high 154.00
52-Week low 76.20
P/E
Mkt Cap.(Rs cr) 141
Buy Price 0.00
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Electrotherm (India) Ltd. (ELECTHERM) - Auditors Report

Company auditors report

TO

THE MEMBERS OF

ELECTROTHERM (INDIA) LIMITED.

Report on the audit of Standalone Ind AS Financial Statements Opinion

We have audited the accompanying Standalone Ind AS Financial Statements of ELECTROTHERM(INDIA) LIMITED ("the Company") which comprise the Balance Sheet as atMarch 31 2020 the Statement of Profit and Loss (including other comprehensive income)Statement of Changes in Equity Statement of Cash Flows for the year then ended and notesto the standalone financial statements including a summary of significant accountingpolicies and other explanatory information (hereinafter referred to as "theStandalone Ind AS Financial

Statements").

In our opinionandtothebestofourinformationandaccordingtotheexplanationsgiven to us readwith the notes to accounts except for the effects of the matter 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 accounting principlesgenerally accepted in India of the state of affairs of the Company as at March 31 2020and its Profit(including other comprehensive income) changes in equity and itscash flows for the year ended on that date.

Basis for Qualified Opinion

We draw attention to Note No. 34(b) of non- provision of interest on NPA accounts ofbanks of Rs.160.67 Crore (Net of Reversal of Rs.17.31 crore on its settlement) for theyear under consideration and the total amount of such unprovided interest till date is Rs1037.01 Crore. The exact amounts of the said non provisions of interest are not determinedand accounted for by the Company and accordingly

(a) Bankers/ ARCs Loan liabilities and the retained earnings (Loss) as on 31stMarch 2020 are understated by Rs.1037.01 Crore and

(b) the profit for the year is overstated by Rs.160.67 Crore.

We conducted our audit of the Standalone Ind AS Financial Statements in accordance withthe Standards on Auditing (SAs) as specified under section 143(10) of the Companies Act2013 ("the Act"). Our responsibilities under those SAs are further described inthe Auditor's Responsibilities for the Audit of the Standalone Ind AS 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 together with the ethicalrequirements that are relevant to our audit of the financial statements under theprovisions of the Act and the Rules there under and we have fulfilled our other ethicalresponsibilities in accordance with these requirements and the Code of Ethics. We believethat the audit evidence we have obtained opinion. is

Emphasis of Matter

We draw attention to following Notes of Standalone Ind AS Financial Statements of theCompany:-

(a) Note No 15(e) in respect of non-payment of Installments due to lender of theloan for the period from 31st December 2019 to 31st March 2020 and requested all lendersto allow this moratorium period for the payments and the lenders are yet to confirm therevised repayment schedule.

(b) Note No 33(a) in respect of treatment in the books of accounts of theassignment / settlements of debts of various banks and the financial institution and itswaiver of principal and interest amount.

(c) Note No 33(a)(i)(e) in respect of Petition filed by Central Bank of India afinancial creditor under Section 7 of the Insolvency and Bankruptcy Code 2016 before theNational Company Law Tribunal (NCLT) Ahmedabad.

(d) Note No 35(d) in respect of confirmation / reconciliation of few accounts of"Trade Receivables" "Trade Customers" Advances Recoverable in Cashor Kind" and "Advance to suppliers and other parties".

(e) Note No 37 in respect of pending litigations and recovery proceedingsagainst the company and the Directors of the Company. In Our opinion in respect of theabove Emphasis of Matter we do not provide any modified opinion as these are notmaterial.

Key Audit Matters

Key audit matters are those matters that in our professional judgment were of mostsignificance in our audit of the Standalone Ind AS Financial Statements for the financialyear ended March 31 2020. These matters were addressed in the context of our audit of the

Standalone Ind AS Financial Statements as a whole and in forming our opinion thereonand we do not provide a separate opinion on these matters. In addition to the matterdescribed in the Basis for Qualified Opinion section we have determined the mattersdescribed below to be the key audit matters to be communicated in our report.

Key Audit Matters (Other than those given in Basis for Qualified Opinion) How the matter was addressed in our
Revenue Recognition In view of the significance of the matter we applied the following audit procedures in this area among others to obtain sufficient appropriate audit evidence:
The principal products of the Company comprise Induction Furnaces Steel and Electric Vehicles that are mainly sold through distributors and direct sale channels amongst others. Revenue is recognized when the customer obtains control of the goods. We assessed the appropriateness of the revenue recognition accounting policies by comparing with applicable accounting standards.
We identified revenue recognition as a key audit matter because the Company and its external stakeholders focus on revenue as a key performance indicator. This could create an incentive for revenue to be overstated or recognized before control has been transferred. We performed substantive testing by selecting samples of revenue recorded during the year by testing the underlying transactionsdocuments using statistical sampling.
We carried out analytical the year to identify unusual variances.
We performed confirmation procedures on selected customer balances at the balance sheet date.
We tested on a sample basis specific revenue transactions recorded before and after the financial year end date to determine whether the revenue had been recognised in the appropriate financial period.
We tested manual journal entries posted to revenue to identify unusual items.

Other Information

The Company's management and Board of Directors are responsible for the preparation ofthe other information. The other information comprises the information included in theCompany's annual report but does not include the Standalone Ind AS Financial Statementsand our Auditors' Report thereon.

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

In connection with our audit of the standalone Ind AS financial statements ourresponsibility is to read the other information and in so consider whether the otherinformation is materially inconsistent with the financial statements or our knowledgeobtained in the or otherwise appears to be materially misstated.

When we read the Board's Report including Annexure to Board's Report if we concludethat there is a material misstatement therein we are required to communicate the matterto those charged with governance. We have nothing to report in this regard.

Responsibilities of Management and Those Charged with Governance for the Standalone IndAS Financial Statements

The statement has been prepared on the basis of the Standalone Ind AS FinancialStatements. The Company Management and Board of

Directors are responsible for matter stated in section 134(5) of the Act with respectto the preparation and presentation of the Standalone Financial Statement that gives atrue and fair view of the Net Profit for the year ended on March 31 2020 and othercomprehensive income of the Company and other financial information in accordance with theapplicable accounting standards prescribed under Section 133 of the Act read with relevantrules issued thereunder and other accounting principles generally accepted in India Thisresponsibility also includes maintenance of adequate accounting records in accordance withthe provisions of the Act for safeguarding of the assets of the Company and for preventingand detecting frauds and other irregularities; selection and application of appropriateaccounting policies; making judgments and estimates that are reasonable and prudent; andthe design implementation and maintenance of adequate internal financial controls thatwere operating effectively for ensuring the accuracy and completeness of the accountingrecords relevant to the preparation and presentation of the statement that give a trueand fair view and are free from material misstatement whether due to fraud or error.

In preparing the statement management and Board of Directors are responsible forassessing the Company's ability to continue as a going concern disclosing as applicablematters related to going concern and using the going concern basis of accounting unlessmanagement either intends to liquidate the Company or to cease operations or has norealistic alternative but to do so.

Board of Directors is also responsible for overseeing the Company's financial reportingprocess.

Auditor's Responsibilitiesfor the Audit of the Standalone Ind AS Financial Statements

Our objectives are to obtain reasonable assurance about whether the Standalone Ind-ASfinancial statements as a whole are free from material misstatement whether due to fraudor error and to issue an auditor's report that includes our opinion. Reasonable assuranceis a high level of assurance but is not a guarantee that an audit conducted in accordancewith SAs will always detect a material misstatement when it exists. Misstatements canarise from fraud or error and are considered material if individually or in theaggregate they could reasonably be expected to influence the economic decisions of userstaken on the basis of these statements.

As part of an audit in accordance with SAs we exercise professional judgment andmaintain professional skepticism We also:

??Identify and assess the risks of material misstatement of Standalone Ind-AS financialstatements whether due to fraud or error design and perform audit procedures responsiveto those risks and obtain audit evidence that is sufficient and appropriate to provide abasis for our opinion. The risk of not detecting a material misstatement resulting fromfraud is higher than for one resulting from error as fraud may involve collusionforgery intentional omissions misrepresentations or the override of internal control.

??Obtain an understanding of internal control relevant to the audit in order to designaudit procedures that are appropriate in the circumstances. Under section 143(3)(i) of theAct we are also responsible for expressing our opinion on whether the company hasadequate internal financial controls system in place and the operating effectiveness ofsuch control.

??Evaluate the appropriateness of accounting estimates and related disclosurespoliciesusedandthereasonablenessofaccounting made by management.

??Conclude on the appropriateness of management's use of the going concern basis ofaccounting and based on the audit evidence obtained whether a materialuncertaintyexistsrelatedtoeventsorconditionsthat may cast significant doubt on theCompany's ability to continue as a going concern. If we conclude that a materialuncertainty exists we are required to draw attention in our auditor's report to therelated disclosures in the Standalone Ind-AS Financial Statement or if such disclosuresare inadequate to modify our opinion. Our conclusions are based on the audit evidenceobtained up to the date of adoption of the accounts of the Company by Board of Directorsin their meeting on 30 may cause the Company th June2020. Howeverfuture events orconditions to ceasetocontinue as a

??Evaluate the overall presentation structure and content of the Financial Statementincluding the disclosures and whether the Statement represents theunderlyingtransactionsevents in a manner that achieves fair presentation. and We communicate with those chargedwith governance regarding among other matters the planned scope and timing of the auditand anysignificantdeficiencies internal control that we identify during our audit.

We also provide those charged with governance with a statement that we have compliedwith relevant ethical requirements regarding independence and to communicate with themall relationships and other matters that may reasonably be thought to bear on ourindependence and where applicable related safeguards.

From the matters communicated with those charged with governance we determine thosematters that were of most significance in audit of the Standalone Ind AS FinancialStatements for the financial year ended March 31 2020 and are therefore the key auditmatters. We describe these matters in our auditor's report unless law or regulationprecludes public disclosure about the matter or when in extremely rare circumstances wedetermine that a matter should not be communicated in our report because the adverseconsequences of doing so would reasonably be expected to outweigh the public interestbenefits of such communication

Report on Other Legal and Regulatory Requirements

(A) As required by the Companies (Auditors' Report) Order 2016 ("the Order")issued by the Central Governmentof India in terms of Section "Annexure A"a statement on the mattersspecifiedin paragraphs 3 and 4 of the Order to the extentapplicable for the year ended on 31st March 2020.

(B) As required by Section 143(3) of the Act we broadly report that :-

(a) We have sought and obtainedalltheinformationand explanations which to the best ofour knowledge and belief were necessary for the purposes of our audit;

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

(c) The Balance Sheet the Statement of Profit and Loss (including other comprehensiveincome) the Statement of Changes in Equity and the Cash Flow Statement dealt with by thisreport are in agreement with the books of account;

(d) In our opinion the aforesaid Ind AS financialstatementscomplywiththeAccountingStandardsspecifiedundersection133 of the Act read withCompanies(IndianAccountingStandards) Rules 2015 as amended;

(e) On the basis of the written representations received from the directors as on March31 2020 and taken on record by the Board of Directors none of the Directors isdisqualified as on March 31 2020 from being appointed as a director in terms of Section164(2) of the Act;

(f) With respect to the adequacy of the internal financial controls with reference tofinancial statements of the Company and the operating effectiveness of such controlsrefer to our separate Report in‘ Annexure B': and

(g) In our opinion the managerial remuneration for the year ended March 31 2020 hasbeen paid / provided by the Company to its directors in accordance with the provisions ofsection 197 read with Schedule V to the Act.

(C) With respect to the other matters to be included in the Auditors' Report inaccordance with Rule 11 of the Companies (Audit and Auditors) Rules 2014 as amended inour opinion and to the best of our information and according to the explanations given tous:

(i) The Company has disclosed the impact of pending litigations on its financialposition Refer Note No.31(a) 33 and 37 to the Standalone Financial Statement;

(ii) There are no long-term contracts including derivative contracts and accordingly noprovision is required to be made for any loss from the same; and

(iii) There is no fund which is pending to be transferred to the Investor Education andProtection Fundby the Company.

The Annexure A referred to in Independent Auditor's Report to the members of Electrotherm(India) Limited on the Standalone Ind AS Financial Statements for the yearended on March 31 2020 we broadly report that for the year under consideration:-

(i) (a) The Company has maintained proper records showing full particulars includingquantitative details and situation of fixed assets.

(b) As informed to us the Company has a programme of physical verification of itsfixed assets by which the fixed assets are verified by the Management at periodic manner.In accordance with this programme fixed assets of Engineering & Technologies Divisionwere verified during the year and as informed to us no material discrepancies werenoticed on such verification. In our opinion this periodicity of physical verification isreasonable having regard to the size of the Company and the nature of its assets.

(c) According to the information and explanation given to us the title deeds ofimmovable properties(which are included under the Note 3- ‘Property plant andequipment') are held in the name of the Company.

at reasonable intervals by the Management during the year. As informed

(ii) Thephysicalverification to us the discrepancies noticed on physical verificationof inventory as compared to book records were not material and have been appropriatelydealt with in the books of accounts.

(iii) The Company has granted loans secured or unsecured to Companies Firm or otherparities covered in the register maintained under section 189 of the Act;

(a) In our opinion and according to the information and explanations given to us theterms and conditions of the grant of such loans; except Unsecured Loans considereddoubtful by the Company are not prejudicial to the Company's interest

(b) In respect of the aforesaid loans the term of repayment of principal and Interesthas not been stipulated. However the repayments or receipts are regular.

(c) In respect of the aforesaid loans there is no amount overdue for more than ninetydays.

(iv) In our opinion and according to the information and explanations given to usprovisions of sections 185 and 186 of the Act in respect of loans to Directors includingentities in which they are interested and in respect of loans given and investments madehave been complied with by the Company. The Company has not granted any guarantees &security in terms of sections 185 and 186 of the Act

(v) In our opinion and according to the information and explanations given to usduring the year under consideration the Company has not accepted any deposits within themeaning of sections 73 to 76 of the Act and Companies (Acceptance of Deposits) Rules 2014(as amended). Accordingly the provisions of clause 3(v) of the Order are not applicableto the Company.

(vi) Pursuant to the rules made by the Central Government of India the Company isrequired to maintain cost records as specified under Section 148(1) of the Act in respectof its products. We have broadly reviewed the same and are of the opinion that primafacie the prescribed accounts and records have been made and maintained. We have nothowever made a detailed examination of the records with a view to determine whether theyare accurate or complete.

(vii) (a) According to the information and explanations given to us and the records ofthe Company examined by us in our opinion the Company is generally regular in depositingundisputed statutory dues including Provident Fund Employees' State Insurance IncomeTax Goods and Service Tax Sales Tax Duty of Customs Cess and other material statutorydues as applicable with the appropriate authorities though there has been a slight delayin a few cases.

(b) There are no undisputed amounts payable in respect of above dues which were inarrears as at March 31 2020 for a period of more than six months from the date theybecame payable.

(c) According to the information and explanations given to us and the records of theCompany examined by us details of outstanding dues in respect of Income Tax Goods andService Tax Sales Tax service tax duty of customs duty of excise value added tax orcess etc which have not been deposited/adjusted/reversed on account of any dispute:-

Name of the Statue Nature of Dues Amount Period to which amount relates Forum Where Dispute is Pending
CENTRAL EXCISE Excise duty 0.00 2005-06 Commissioner Central Excise
ACT1944 Excise duty 11.65 December-2005 to December-2008 CESTAT
Excise duty 175.00 April-2005 to March-2010 CESTAT
Excise duty (Advance Licence) 22.41 March-2011 to December-2011 Commissioner Central Excise
Excise duty 68.62 October-2007 to September-2012 Commissioner Central Excise.
Excise duty 0.12 April-2008 to July-2011 CESTAT
Excise duty 57.38 April-2009 to March-2010 Commissioner Central Excise
Excise duty 6.82 February-2014 to March-2015 Commissioner of Central GST Audit
SUB TOTAL 342.00
FINANCE ACT1944 SERVICE TAX 1.84 April 2007 to March-2008 Commissioner Central Excise.
SUB TOTAL 1.84
CUSTOM ACT1962 CVD 7.27 March-2011 to December 2011 CESTAT
Interest 3.59 May-2007 to February-2008 CESTAT
Custom Duty 0.83 March-2012 to January-2013 Additional Commissioner
Custom Duty 0.02 April 2011 Commissioner of Custom (Preventive)
SUB TOTAL 11.71
MAHARASHTRA VAT 6.06 2009-10 Deputy Commissioner of MVAT
VAT ACT 2002 VAT 23.09 2010-11 Deputy Commissioner of MVAT
SUB TOTAL 29.15
GRAND TOTAL 384.70

(viii) According to the records of the Company examined by us and the information andexplanation given to us the Company has defaulted in repayment of loans or borrowings tofinancial institution and asat the balance sheet date. Details of which are asbelow :- bank

Name of Lender

Amount of Default as on March 31 2020 (Rs. in Crore)

Default From
Principal Interest Total
Central Bank of India* 428.94 7.19 436.13 March 2012
Rare Asset Reconstruction Limited 189.95 0.01 189.96 August 2011
(assignee of Indian Overseas Bank)*
Invent Assets Securitization and Reconstruction Private Limited 4.20 - 4.20 December 2019
Edelweiss Asset Reconstruction Company Limited - 0.21 0.21 December 2019
Corporation Bank - 0.95 0.95 December 2019

*The above table does not include the interest which bank has not provided after theaccount has been classifiedas Non-Performing Assets (NPA). and the amount which has beenassigned /settled by the lenders.

The Reserve Bank of India (RBI) has notified the COVID-19 Regulatory Packagespermitting lenders to grant a moratorium period for all installments falling due betweenMarch 1 2020 to August 31 2020 and of which complete details is given in note No. 15(e).The Company has not paid installments due for the quarter ended on December 31 2019 of Rs15.45 Crore and for the quarter ended on March 31 2020 of Rs 25.13 Crore. The Company hasrequested all lenders to allow a moratorium period for the payments or reschedule thepayment of the installments amount not paid and moratorium period or revised schedule isyet to be confirmed.

(ix) The Companyhasnotraisedanymoneybyway or further public offer (includingdebt instruments) and term loans initialpublic during the year. Accordingly theprovisions of Clause 3(ix) of the Order are not applicable to the Company.

(x) During the course of our examination of the books and records of the Companycarried out in accordance with the generally accepted auditing practices in India andaccording to the information and explanations given to us we have neither come across anyinstance of material fraud by the Company or on the Company by its officers or employeesnoticed or reported during the year nor have we been informed of any such case by theManagement.

(xi) In our opinion and according to the information and explanations given to us theCompany has paid / provided managerial remuneration in accordance with the requisiteapprovals mandated by the provisions of section 197 read with Schedule V to the CompaniesAct

2013.

(xii) In our opinion and according to the information and explanation given to us theCompany is not a Nidhi Company. Accordingly paragraph 3(xii) of the Order is notapplicable to the Company.

(xiii) According to the information and explanations given to us and based on ourexamination of the records of the Company transactions with the related parties are incompliance with sections 177 and 188 of the Act where applicable and details of suchtransactionshave been disclosed in the Financial Statements as required by the applicableInd AS-24 Related Party Disclosures.

(xiv) According to the information and explanation given to us and on overallexamination of the balance sheet the Company has not made any preferential allotment orprivate placement of shares or fully or partlyconvertibledebentures during the year underreview and hence reporting requirements under clause 3(xiv) are not applicable to theCompany and not commented upon.

(xv) As explained to us the Company has not entered into any non-cash transactionswith its Directors or persons connected with them. Accordingly paragraph 3(xv) of theOrder is not applicable to the Company.

(xvi) According to the information and explanations provided to us the Company is notrequired to be registered under Section 45-IA of the Reserve Bank of India Act 1934.Accordingly the paragraph 3(xvi) of the Order is not applicable to the Company.

Annexure B referred to paragraph B of Report on Other Legal Regulatory Requirements ofIndependent Auditor's report of even date for year ended March 31 2020.

Report on the Internal Financial Controls under Clause (i) of Sub -section Act") .3 ofSection 143of the CompaniesAct 2013("the

We have audited the internal financial controls over financial reporting of Electrotherm(India) Limited ("the Company") as of March 31 2020 in conjunction with ouraudit of the Standalone IND AS Financial Statements of the company for the year ended onthat date.

Management's Responsibility for Internal Financial Controls

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

Auditors' Responsibility

Our responsibility is to express an opinion on the Company's internal financialcontrols over financial reporting with reference to these Standalone Ind AS FinancialStatements based on our audit. We conducted our audit in accordance with the Guidance Noteon Audit of Internal Financial Controls Over Financial Reporting (the "GuidanceNote") and the Standards on Auditingas specified under section 143(10) of theCompanies Act 2013 to the extent applicable to an audit of internal financial controlsboth issued by the Institute of Chartered

Accountants of India. Those Standards and the Guidance Note require that we comply withethical requirements and plan and perform the audit to obtain reasonable assurance aboutwhether adequate internal financial controls over financial reporting with reference tothese Standalone Ind AS Financial Statements was established and maintained and if suchcontrols operated effectively in all material respects.

Our audit involves performing procedures to obtain audit evidence about the adequacy ofthe internal financial controls over financial reporting with reference to theseStandalone Ind AS Financial Statements and their operating effectiveness.Ourfinancialcontrols over financial reporting included obtaining an understanding of internalfinancialcontrols over financial reportingwith reference to these Standalone Ind AS FinancialStatements assessing the risk that a material weakness exists testingand evaluatingthe design and eness of internal control based on the assessed risk. The proceduresselected depend on the auditor's judgment including effectiv operating the assessment ofthe risks of material misstatement of the financial statements whether due to fraud orerror.

We believe that the audit evidence we have obtained is sufficient and appropriate toprovide a basis for our audit opinion on the internal financial controls over financialreporting with reference to these Standalone Ind AS Financial Statements.

Meaning of Internal Financial Controls Over Financial Reporting With Reference to theseStandalone Ind AS Financial Statements

A company's internal financial control over financial reportingwith reference to theseStandalone Ind AS Financial Statements is a process designed to provide reasonableassurance regarding the reliability of financial reportingand the preparation of financialstatements for external purposes in accordance with generally accepted accountingprinciples. A company's internalfinancial control over financial reporting with referenceto these Standalone Ind AS Financial Statements includes those policies and proceduresthat

(1) Pertain to the maintenance of records that in reasonable detail accurately andfairly reflect the transactions and dispositions of the assets of the company;

(2) Provide reasonable assurance that transactionsare recorded as necessary to permitpreparation offinancial statements in accordance with generally accepted accountingprinciples and that receipts and expenditures of the with authorizations of managementand directors of the company; and

(3) Provide reasonable assurance regarding prevention or timely detection dispositionofthe un-authorizedacquisition useor company's assets that could have a materialeffect on the financial statements.

Inherent Limitations of Internal Financial Controls Over Financial Reporting withReference to these Standalone Ind AS Financial

Statements

Because of the inherent limitations of internalfinancial controls over financialreporting with reference to these Standalone Ind AS Financial

Statements including the possibility of collusion or improper management override ofcontrols material misstatements due to error or fraud may occur and not be detected.Also projections of any evaluation of the internalfinancial controls over financialreporting with reference to these Standalone Ind AS Financial Statements to future periodsare subject to the risk that the internal financial control over financial reporting withreference to these Standalone Ind AS Financial Statements may become inadequate because ofchanges in conditions or that the degree of compliance with the policies or proceduresmay deteriorate.

Opinion

In our opinion the Company has in all material respects except otherwise stated orreported to the management an adequate internal financial controls system over financialreporting and such internal financial controls over financial reporting were operatingeffectively as at March 31 2020 based on the internal control over financial reportingcriteria established by the Company considering the essential components of internalcontrol stated in the Guidance Note on Audit of Internal Financial Controls Over FinancialReporting issued by the Institute of Chartered Accountants of India.

For Hitesh Prakash Shah & Co
(Firm Regd.No: 127614W)
Chartered Accountants
Place: Ahmedabad Hitesh Shah
Date: 30th June 2020 Partner
Membership No. 124095
UDIN: 20124095AAAABL9501

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