You are here » Home » Companies » Company Overview » Fine Organic Industries Ltd

Fine Organic Industries Ltd.

BSE: 541557 Sector: Industrials
NSE: FINEORG ISIN Code: INE686Y01026
BSE 00:00 | 18 Jun 2825.60 -40.00
(-1.40%)
OPEN

2842.00

HIGH

2875.15

LOW

2793.10

NSE 00:00 | 18 Jun 2826.10 -33.50
(-1.17%)
OPEN

2887.00

HIGH

2887.70

LOW

2790.00

OPEN 2842.00
PREVIOUS CLOSE 2865.60
VOLUME 6848
52-Week high 3565.25
52-Week low 1852.10
P/E 75.37
Mkt Cap.(Rs cr) 8,663
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00
OPEN 2842.00
CLOSE 2865.60
VOLUME 6848
52-Week high 3565.25
52-Week low 1852.10
P/E 75.37
Mkt Cap.(Rs cr) 8,663
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

Fine Organic Industries Ltd. (FINEORG) - Auditors Report

Company auditors report

To

The Members of

Fine Organic Industries Limited

(Formerly known as ‘Fine Organic Industries Private Limited')

REPORT ON THE AUDIT OF THE IND AS FINANCIAL STATEMENTS

Opinion

We have audited the accompanying Ind AS Financial Statements of Fine Organic IndustriesLimited (herein referred to as the "Company") which comprise the Balance Sheetas at March 31 2020 the Statement of Profit and Loss (including other comprehensiveincome) the Statement of Changes in Equity the Statement of Cash Flows for the year thenended and notes to the Financial Statements including a summary of the significantaccounting policies and other explanatory information.

In our opinion and to the best of our information and according to the explanationsgiven to us the aforesaid Ind AS Financial Statements give the information required bythe Companies Act 2013 ("the Act") in the manner so required and give a trueand fair view in conformity with the Indian Accounting Standards prescribed under section133 of the Act read with the Companies (Indian Accounting Standards) Rules 2015 asamended ("Ind AS") and other accounting principles generally accepted in Indiaof the state of affairs of the Company as at March 31 2020 and its profit (includingother comprehensive income) statement of changes in equity and its cash flows for theyear ended on that date.

Basis for Opinion

We conducted our audit in accordance with the Standards on Auditing (SAs) specifiedunder section 143(10) of the Act (SAs). Our responsibilities under those Standards arefurther described in the Auditor's Responsibilities for the Audit of 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 Ind AS Financial Statements under theprovisions of the Companies Act 2013 and the Rules made there under and we havefulfilled our other ethical responsibilities in accordance with these requirements and theICAI's Code of Ethics. We believe that the audit evidence obtained by us is sufficient andappropriate to provide a basis for our opinion on Ind AS Financial Statements.

Emphasis of Matters

We draw attention to Note no. 44 of the Ind AS Financial Statements as regards themanagement's evaluation of COVID-19 impact on the future performance of the Company. Ouropinion is not modified in respect of this matter.

Key Audit Matters

Key Audit Matters are those matters that in our professional judgment were of mostsignificance in our audit of the Ind AS Financial Statements of the current period. Thesematters were addressed in the context of our audit of the Ind AS Financial Statements as awhole and in forming our opinion thereon and we do not provide a separate opinion onthese matters.

We have determined the matters described below to be the key audit matters to becommunicated in our report. We have fulfilled the responsibilities described in theAuditor's responsibilities for the audit of the Ind AS Financial Statements section of ourreport including in relation to these matters. Accordingly our audit included theperformance of procedures designed to respond to our assessment of the risks of materialmisstatement of the Ind AS Financial Statements. The results of our audit proceduresincluding the procedures performed to address the matters below provide the basis for ouraudit opinion on the accompanying Ind AS Financial Statements.

1 Revenue Recognition

For the year ended March 31 2020 the Company has recognised revenue from contractswith customers amounting to Rs 102621.08 Lakhs.

Revenue from contracts with customers is recognised when control of the goods orservices are transferred to the customer at an amount that reflects the consideration towhich the Company expects to be entitled in exchange for those goods or services.

The Company has generally concluded that as principal it typically controls the goodsor services before transferring them to the customer.

The variety of terms that define when controls are transferred to the customer as wellas the high value of the transactions give rise to the risk that revenue is notrecognised in the correct period.

Revenue is measured net of returns and allowances cash discounts trade discounts andvolume rebates (collectively ‘discount and rebates'). There is a risk that thesediscount and rebates may be incorrectly recorded as it also requires a certain degree ofestimation resulting in understatement of the associated expenses and accrual.

Revenue is also an important element of how the Company measures its performance. TheCompany focuses on revenue as a key performance measure which could create an incentivefor revenue to be recognised before the risk and rewards have been transferred.

Accordingly due to the significant risk associated with revenue recognition inaccordance with terms of Ind AS 115 ‘Revenue from contracts with customers' it wasdetermined to be a key audit matter in our audit of the Ind AS Financial Statements.

Auditors' Response

Our audit procedures included the following:

• Assessed the Company's revenue recognition procedure as per Ind AS 115‘Revenue from contracts with customers'.

• Assessed the design and tested the operating effectiveness of internal controlsrelated to revenue recognition discounts and rebates.

• Performed sample tests of individual sales transaction and traced to salesinvoices sales orders and other related documents. Further in respect of the sampleschecked that the revenue has been recognised as per the terms.

• To test cut off selected sample of sales transactions made pre and post-yearend agreeing the period of revenue recognition to third party support such astransporter invoice and customer confirmation of receipt of goods.

• Tested the provision calculations related to discounts and rebates by agreeing asample of amounts recognised to underlying arrangements with customers and othersupporting documents.

• Performed analytical procedures of revenue by streams to identify any unusualtrends.

• The Company has provided confirmations from customers on sample basis to supportexistence assertion of trade receivables and assessed the relevant disclosures made in thefinancial statements; to ensure revenue from contracts with customers are in accordancewith the requirements of relevant accounting standards.

2 Evaluation of uncertain tax imposition

The Company has material uncertain tax position including matters under dispute whichinvolves significant judgment to determine the possible outcome of these disputes.

{Refer to note no. 40 of the Ind AS Financial Statements}

Auditors' Response

We have obtained details of all pending assessments and demands for the year endedMarch 31 2020 from the management. We have evaluated the possible outcome of pendingassessments and disputed matters under litigations.

3 Capitalisation of property plant and equipment

During the year ended March 31 2020 the Company has incurred significant capitalexpenditure. Further out of the total additions of Rs 17260.02 Lakhs to property plantand equipment amount of Rs 16625.87 Lakhs in the current year significant part of thecapitalisation pertains to the new plant namely N-42 located at Ambernath to expandcompany's production capacity. Entire plant has been successfully commissioned andcapitalised during the year in phased manner.

Significant level of judgement is involved to ensure that the aforesaid capitalexpenditure / additions meet the recognition criteria of Ind AS 16 - Property Plant andEquipment specifically in relation to determination of trial run period and costsassociated with trial runs for it to be ready for intended use. As a result the aforesaidmatter was determined to be a key audit matter

{Refer to note no. 4 of the Ind AS Financial Statements}

Auditors' Response

Performed walk-through of the capitalisation process and tested the design andoperating effectiveness of the controls in the process.

Assessed the nature of the additions made to property plant and equipment and capitalwork- in-progress on a test check basis to test that they meet the recognition criteria asset out in para 16 to 22 of Ind AS 16 including any such costs incurred specifically fortrial run.

Assessed that the borrowing cost capitalised (including foreign exchange loss to theextent it is considered as an adjustment to interest cost) is in accordance with theaccounting policy of the Company.

Reviewed the project completion/handover certificate provided by the management todetermine whether the asset is in the location and condition necessary for it to becapable of operating in the manner intended by the management

INFORMATION OTHER THAN THE IND AS FINANCIAL STATEMENTS AND AUDITORS' REPORT THEREON

The Company's Management & Board of Directors are responsible for the otherinformation. The other information comprises the information included in the Company'sannual report. For example Corporate Overview Key Highlights Board's Report Report onCorporate Governance Management Discussion & Analysis Report Business ResponsibilityReport etc. but does not include the Ind AS Financial Statements and our auditors'report thereon.

Our opinion on the Ind AS Financial Statements does not cover the other information andwe do not express any form of assurance conclusion thereon.

In connection with our audit of the Ind AS Financial Statements our responsibility isto read the other information and in doing so consider whether the other information ismaterially inconsistent with the Ind AS Financial Statements or our knowledge obtainedduring the course of audit or otherwise appears to be materially misstated.

If based on the work we have performed we conclude that there is a materialmisstatement of this other information we are required to report that fact. We havenothing to report in this regard.

MANAGEMENT'S RESPONSIBILITY FOR THE IND AS FINANCIAL STATEMENTS

The Company's Management and Board of Directors are responsible for the mattersspecified in section 134(5) of the Act with respect to the preparation of these Ind ASFinancial Statements that give a true and fair view of the financial position financialperformance including other comprehensive income changes in equity and cash flows of theCompany in accordance with the Ind AS and other accounting principles generally acceptedin India. This responsibility also includes the maintenance of adequate accounting recordsin accordance with the provisions of the Act for safeguarding of the assets of the Companyand for preventing and detecting the frauds and other irregularities selection andapplication of appropriate accounting policies making judgments and estimates that arereasonable and prudent and design implementation and maintenance of internal financialcontrols that were operating effectively for ensuring the accuracy and completeness ofthe accounting records relevant to the preparation and presentation of the financialstatements that give a true and fair view and are free from material misstatement whetherdue to fraud or error.

In preparing the financial statements management and Board of Directors areresponsible for assessing the Company's ability to continue as a going concerndisclosing as applicable matters related to going concern and using the going concernbasis of accounting unless the management either intends to liquidate the Company or tocease operations or has no realistic alternative but to do so.

The Board of Directors are also responsible for overseeing the Company's financialreporting process.

AUDITOR'S RESPONSIBILITY FOR THE AUDIT OF THE IND AS FINANCIAL STATEMENTS

Our objectives are to obtain reasonable assurance about whether the financialstatements as a whole are free from material misstatement whether due to fraud or errorand to issue an Auditors' report that includes our opinion. Reasonable Assurance is a highlevel of assurance but is not a guarantee that an audit conducted in accordance with SAswill always detect a material misstatement when it exists. Misstatements can arise fromfraud or error and are considered material if individually or in the aggregate theycould reasonably be expected to influence the economic decisions of users taken on thebasis of these Ind AS Financial Statements.

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

• Identify and assess the risk of material misstatement of the 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 financial control relevant to the audit inorder to design audit procedures that are appropriate in the circumstances. Under section143(3)(i) of the Act we are also responsible for expressing our opinion on whether theCompany has adequate internal financial controls system in place and the operatingeffectiveness of such controls.

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

• Conclude on the appropriateness of the management's use of the going concernbasis of accounting and based on the audit evidence obtained whether a materialuncertainty exists related to events or conditions that 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 Auditors' report to therelated disclosures in the Ind AS Financial Statements or if such disclosures areinadequate to modify our opinion. Our conclusions are based on the audit evidenceobtained up to the date of our Auditors' report. However future events or conditions maycause the Company to cease to continue as a going concern.

• Evaluate the overall presentation structure and content of the Ind AS FinancialStatements including the disclosures and whether the Ind AS Financial Statementsrepresent the underlying transactions and events in a manner that achieves fairpresentation.

We communicate with those charged with governance regarding among other matters theplanned scope and timing of the audit and significant audit findings including anysignificant deficiencies in internal control that we identify during our audit.

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

From the matters communicated with those charged with governance we determine thosematters that were of most significance in the audit of the Ind AS Financial Statements ofthe current period and are therefore the key audit matters. We describe these matters inour Auditors' report unless law or regulation precludes public disclosure about the matteror when in extremely rare circumstances we determine that a matter should not becommunicated in our report because the adverse consequences of doing so would reasonablybe expected to outweigh the public interest benefits of such communication.

REPORT ON OTHER LEGAL AND REGULATORY REQUIREMENTS

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

a) We have sought and obtained all the information and explanations which to the bestof our knowledge and belief were necessary for the purposes of our audit of the aforesaidfinancial statements.

b) In our opinion proper books of account as required by law relating to preparationof the aforesaid financial statements have been kept so far as it appears from ourexamination of those books.

c) The Balance Sheet the Statement of Profit and Loss (including other comprehensiveincome) Statement of Changes in Equity and the Statement of Cash Flows dealt with by thisReport are in agreement with the relevant books of account.

d) In our opinion the aforesaid Ind AS Financial Statements comply with the IndianAccounting Standards prescribed under Section 133 of the Act.

e) On the basis of the written representations received from the Directors of theCompany as on March 31 2020 taken on record by the Board of Directors of the Companynone of the directors of the Company incorporated in India is disqualified as on March 312020 from being appointed as a director in terms of Section 164(2) of the Act.

f) With respect to the adequacy of the internal financial controls over financialreporting of the Company and the operating effectiveness of such controls; refer to ourseparate report in ‘Annexure -A'. Our report expresses an unmodified opinion on theadequacy and operating effectiveness of the Company's internal financial controls overfinancial reporting.

g) With respect to the other matters to be included in the Auditors' Report inaccordance with the requirements of section 197(16) of the Act as amended in our opinionand to the best of our information and according to the explanation given to us theremuneration paid/provided by the Company to its director during the year is in accordancewith the provision of section 197 of the Act.

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

(i) The Company has disclosed the impact of pending litigations on its financialposition in its Ind AS Financial Statements.

(ii) The Company has made Provision as required under the applicable law or accountingstandards for material foreseeable losses if any on long-term contracts includingderivative contracts.

(iii) There were no amounts which were required to be transferred to the InvestorEducation and Protection Fund by the Company.

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

For B Y & Associates

Chartered Accountants

Firm's registration number: 123423W

CA Bhavesh Vora

Partner

Membership Number: 043908

Date : June 27 2020

Place : Mumbai ICAI

UDIN: 20043908AAAABY7248

‘ANNEXURE - A' TO THE INDEPENDENT AUDITORS' REPORT

(Referred to in paragraph 1(f) under ‘Report on Other Legal and RegulatoryRequirements' section of our report to the members of ‘Fine Organic IndustriesLimited' of even date)

Report on the Internal Financial Controls Over Financial Reporting under Clause (i) ofsub-section 3 of Section 143 of the Companies Act 2013 (‘the Act').

We have audited the internal financial controls over financial reporting of FineOrganic Industries Limited (‘the Company') as of March 31 2020 in conjunction withour audit of the Ind AS Financial Statements of the Company for the year ended on thatdate.

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 businessthe safeguarding of its assets the prevention and detection of frauds and errors theaccuracy and completeness of the accounting records and the timely preparation of reliablefinancial information as required under the Companies Act 2013.

AUDITOR'S RESPONSIBILITY

Our responsibility is to express an opinion on the internal financial controls overfinancial reporting of the Company based on our audit. We conducted our audit inaccordance with the Guidance Note on Audit of Internal Financial Controls Over FinancialReporting (the ‘Guidance Note') issued by the Institute of Chartered Accountants ofIndia and the Standards on Auditing prescribed under Section 143(10) of the Companies Act2013 to the extent applicable to an audit of internal financial controls. Those Standardsand the Guidance Note require that we comply with ethical requirements and plan andperform the audit to obtain reasonable assurance about whether adequate internal financialcontrols over financial reporting was established and maintained and if such controlsoperated effectively in all material respects.

Our audit involves performing procedures to obtain audit evidence about the adequacy ofthe internal financial controls system over financial reporting and their operatingeffectiveness. Our audit of internal financial controls over financial reporting includedobtaining an understanding of internal financial controls over financial reportingassessing the risk that a material weakness exists and testing and evaluating the designand operating effectiveness of internal control based on the assessed risk. The proceduresselected depend on the auditor's judgment including the assessment of the risks ofmaterial misstatement of the financial statements whether due to fraud or error.

We believe that the audit evidence we have obtained is sufficient and appropriate toprovide a basis for our audit opinion on the Company's internal financial controls systemover financial reporting.

MEANING OF INTERNAL FINANCIAL CONTROLS OVER FINANCIAL REPORTING

A company's internal financial control over financial reporting is a process designedto provide reasonable assurance regarding the reliability of financial reporting and thepreparation of financial statements for external purposes in accordance with generallyaccepted accounting principles. A company's internal financial control over financialreporting includes those policies and procedures that (1) pertain to the maintenance ofrecords that in reasonable detail accurately and fairly reflect the transactions anddispositions of the assets of the Company; (2) provide reasonable assurance thattransactions are recorded as necessary to permit preparation of financial statements inaccordance with generally accepted accounting principles and that receipts andexpenditures of the Company are being made only in accordance with authorisations of themanagement and directors of the Company; and (3) provide reasonable assurance regardingprevention or timely detection of unauthorised acquisition use or disposition of theCompany's assets that could have a material effect on the financial statements.

INHERENT LIMITATIONS OF INTERNAL FINANCIAL CONTROLS OVER FINANCIAL REPORTING

Because of the inherent limitations of internal financial controls over financialreporting including the possibility of collusion or improper management override ofcontrols material misstatements due to error or fraud may occur and not be detected.Also projections of any evaluation of the internal financial controls over financialreporting to future periods are subject to the risk that the internal financial controlover financial reporting may become inadequate because of changes in conditions or thatthe degree of compliance with the policies or procedures may deteriorate.

OPINION

In our opinion to the best of our information and according to the explanations givento us the Company has in all material respects an adequate internal financial controlssystem over financial reporting and such internal financial controls over financialreporting were operating effectively as at March 31 2020 based on the criteria forinternal financial control over financial reporting criteria established by the Companyconsidering the essential components of internal control stated in the Guidance Note onAudit of Internal Financial Controls Over Financial Reporting issued by the Institute ofChartered Accountants of India.

For B Y & Associates

Chartered Accountants

Firm's registration number: 123423W

CA Bhavesh Vora

Partner

Membership Number: 043908

Date : June 27 2020

Place : Mumbai

ICAI UDIN: 20043908AAAABY7248

‘ANNEXURE - B' TO THE INDEPENDENT AUDITORS' REPORT

(Referred to in paragraph 2 under ‘Report on Other Legal and RegulatoryRequirements' section of our report to the members of ‘Fine Organic IndustriesLimited' of even date)

(i) In respect of the Company's Fixed Assets:

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

b) The Company has a program of verification to cover all the items of fixed assets ina phased manner which in our opinion is reasonable having regard to the size of theCompany and the nature of its assets. Pursuant to the program certain fixed assets werephysically verified by the Management during the year. According to the information andexplanations given to us no material discrepancies were noticed on such verification.

c) According to the information and explanations given to us the records examined byus and based on our examination of the records provided to us we report that the titledeeds comprising immovable properties of land and buildings which are freehold are heldin the name of the Company as at the Balance Sheet date.

(ii) In respect of the Company's Inventories:

a) The Inventories has been physically verified during the year by the management. Inour opinion the frequency of verification is reasonable.

b) The procedures for physical verification of inventories followed by the managementare reasonable and adequate in relation to the size of the Company and the nature of itsbusiness.

c) On the basis of our examination of the records of inventories we are of the opinionthat Company is maintaining proper records of inventories. No material discrepancies werenoticed on physical verification of stock as compared to book records.

(iii) The Company has not granted any loans secured or unsecured other than advancesfor expenses to companies firms Limited Liability Partnerships or other parties coveredin the register maintained under section 189 of the Companies Act 2013.

(iv) In our opinion and according to the information and explanations given to us theCompany has complied with the provisions of Sections 185 and 186 of the Act in respect ofgrant of loans making investments and providing guarantees and securities as applicable.

(v) The Company has not accepted deposits during the year and does not have anyunclaimed deposits as at March 31 2020 as prescribed under the provision of the section73 to 76 of the Companies Act 2013 and rules framed there under.

(vi) The Central Government has prescribed maintenance of cost records under clause (d)of sub-section (1) of Section 148 of the Companies Act 2013. As observed by us suchaccounts and records have been made and maintained by the Company. However we have notmade a detailed examination of the cost records with a view to determine whether they areaccurate or complete.

(vii) According to the information and explanations given to us in respect ofstatutory dues:

a) The Company has generally been regular in depositing undisputed statutory duesincluding Provident Fund Employees' State Insurance Income Tax Goods and Service TaxCustoms Duty Cess and other material statutory dues applicable to it with the appropriateauthorities.

b) There were no undisputed amounts payable in respect of Provident Fund Employees'State Insurance Income Tax Goods and Service Tax Customs Duty Cess and other materialstatutory dues in arrears as at March 31 2020 for a period of more than six months fromthe date they became payable.

c) Details of dues of Income Tax Sales Tax Goods &Service Tax and Value AddedTax which have not been deposited as at March 31 2020 on account of dispute are givenbelow:

Sr. No. Financial Year / Period Nature of Demand Appellate Authority where dispute is pending Amounts (Rs)
1 2015-2016 Income Tax Commissioner of Income Tax (Appeal) Mumbai 150.30 Lakhs
2 2014-2015 MVAT Department of Sales tax 5.72 Lakhs

(viii) According to records of the Company examined by us and the information andexplanations given to us the Company has not defaulted in repayment of loans orborrowings to any financial institution or bank or Government. The Company has not issuedany debentures during the year.

(ix) During the year; the Company has not raised moneys by way of Initial Public Offeror Further Public Offer (including Debt Instruments). According to the information andexplanations given to us the term loans raised have been applied by the Company duringthe year for the purposes for which they were raised.

(x) To the best of our knowledge and according to the information and explanationsgiven to us no fraud by the Company or no material fraud on the Company by its officersor employees has been noticed or reported during the year.

(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 Act.

(xii) The Company is not a Nidhi Company and hence reporting under Clause 3 (xii) ofthe Order is not applicable to the Company.

(xiii) In our opinion and according to the information and explanations given to usthe Company is in compliance with Section 177 and 188 of the Companies Act 2013 whereapplicable for all transactions with the related parties and the details of related partytransactions have been disclosed in the Ind AS Financial Statements as required by theapplicable accounting standards.

(xiv) During the year the Company has not made any preferential allotment or privateplacement of shares or fully or partly paid convertible debentures and hence reportingunder Clause 3 (xiv) of the Order is not applicable to the Company.

(xv) In our opinion and according to the information and explanations given to usduring the year the Company has not entered into any non-cash transactions with itsdirectors or directors of its subsidiary companies or persons connected with them andhence provisions of Section 192 of the Act are not applicable.

(xvi) The Company is not required to be registered under Section 45-IA of the ReserveBank of India Act 1934.

For B Y & Associates

Chartered Accountants

Firm's registration number: 123423W

CA Bhavesh Vora

Partner

Membership Number: 043908

Date : June 27 2020

Place : Mumbai

ICAI UDIN: 20043908AAAABY7248