You are here » Home » Companies » Company Overview » Gravita India Ltd

Gravita India Ltd.

BSE: 533282 Sector: Metals & Mining
NSE: GRAVITA ISIN Code: INE024L01027
BSE 00:00 | 17 Jan 335.45 20.90
(6.64%)
OPEN

312.10

HIGH

343.95

LOW

309.85

NSE 00:00 | 17 Jan 334.60 20.65
(6.58%)
OPEN

314.85

HIGH

344.00

LOW

310.10

OPEN 312.10
PREVIOUS CLOSE 314.55
VOLUME 103013
52-Week high 343.95
52-Week low 73.00
P/E 55.08
Mkt Cap.(Rs cr) 2,316
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00
OPEN 312.10
CLOSE 314.55
VOLUME 103013
52-Week high 343.95
52-Week low 73.00
P/E 55.08
Mkt Cap.(Rs cr) 2,316
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

Gravita India Ltd. (GRAVITA) - Auditors Report

Company auditors report

To the Members of Gravita India Limited

Report on the Audit of the Standalone Financial Statements Opinion

1. We have audited the accompanying standalone financial statements of Gravita IndiaLimited (‘the Company') which comprise the Balance Sheet as at 31 March 2020 theStatement of Profit and Loss (including Other Comprehensive Income) the Cash FlowStatement and the Statement of Changes in Equity for the year then ended and a summary ofthe significant accounting policies and other explanatory information.

2. In our opinion and to the best of our information and according to the explanationsgiven to us and based on the consideration of the reports of the other auditors asreferred to in paragraph 15 below the aforesaid standalone financial statements give theinformation required by the Companies Act 2013 (‘Act') in the manner so required andgive a true and fair view in conformity with the accounting principles generally acceptedin India including Indian Accounting Standards (‘Ind AS') specified under section 133of the Act of the state of affairsof the Company as at 31 March 2020 and its profit(including other comprehensive income) its cash flows and the changes in equity for theyear ended on that date.

Basis for Opinion

3. We conducted our audit in accordance with the Standards on Auditing specified undersection 143(10) of the Act. Our responsibilities under those standards are furtherdescribed in the Auditor's Responsibilities for the Audit of the Financial Statementssection of our report. We are independent of the Company in accordance with the Code ofEthics issued by the Institute of Chartered Accountants of India (‘ICAI') togetherwith the ethical requirements that are relevant to our audit of the financial statementsunder the provisions of the Act and the rules thereunder and we have fulfilled our otherethical responsibilities in accordance with these requirements and the Code of Ethics. Webelieve that the audit evidence we have obtained and that obtained by the other auditorsin terms of their reports referred to in paragraph 15 of the Other Matter section below issufficient and appropriate to provide a basis for our opinion.

Key Audit Matters

4. Key audit matters are those matters that in our professional judgment were of mostsignificance in our audit of the standalone financial statements of the current period.These matters were addressed in the context of our audit of the financial statements as awhole and in forming our opinion thereon and we do not provide a separate opinion onthese matters.

5. We have determined the matters described below to be the key audit matters to becommunicated in our report.

Key audit matter How our audit addressed the key audit matter
Initial Audit engagement – Opening Balances Our audit work included but was not limited to the following procedures:
We have been appointed as the statutory auditors of Company for year ended 31 March 2020. a) Prepared a detailed transition plan including ensuring compliance with independence requirements prior to the start of the audit;
Standard on Auditing 510 Initial Audit Engagements
– Opening Balances in conducting an initial audit engagement several considerations are involved which are generally not associated with recurring audits. The audit transition including the audit of the opening balances requires additional planning activities and considerations necessary to establish an appropriate audit plan and strategy. This includes: b) Inspected management's process and control documentation to assist us in obtaining and understanding of the Company's financial reporting and business processes including control environment;
a) Gaining an initial understanding of the Company and its business including its control environment and information systems sufficient to make an audit assessment and develop the audit strategy and plan; c) Obtained and read management reports policies instructions as well as planning and governing documents minutes of the board of directors audit committee and other committees of the board internal audit reports;
Key audit matter How our audit addressed the key audit matter
b) Obtaining sufficient appropriate audit evidence regarding the opening balances including the selection and application of accounting policies; and d) Held discussions with the management at various levels of the Company and heads of the Business Risk and Finance functions to understand their roles in the business and company's financial reporting process;
c) Communicating with the predecessor auditors as required and permitted under applicable professional regulations. e) Obtained an understanding of and evaluated appropriateness and consistency of the accounting policies used in the preparation of the financial statements of the Company for the financial year ended 31 March 2019;
The aforesaid activities required involvement of considerable audit efforts and accordingly audit of the opening balances was identified as a key audit matter for the current year audit.
f ) Read previous year financial statements to identify material opening balances. Obtained underlying accounting schedules prepared by the management and scanned for unusual items;
g) Traced the account balances from the trial balance for the previous financial year to the audited financial statements and traced the balance sheet account balances to the opening trial balance of the current year; and
h) On a sample basis tested the opening balances for financial line items including property plant and equipment bank balances borrowings share capital and other current assets and liabilities as considered necessary.
Estimation and taxability in respect of SGST incentives Our audit work included but was not limited to the following procedures:
The Company's manufacturing facility at Chittoor is eligible for incentives available under "Industrial Development Policy 2015-2020" notified by the Andhra Pradesh government. The Company has been granted "Small Industry" status and is eligible for incentives like power cost reimbursement interest reimbursement refund of sales tax/ state goods and services tax paid in cash etc. Based on such policy the Company has continued to recognize the incentives which are computed on the basis of the State Goods and Services Tax (SGST) paid to the Government of Andhra Pradesh. The SGST incentives amounting to ` 1569.28 Lacs have been accrued in the financial statements for the year ended 31 March 2020. Refer note 23 to the standalone financial statements. a) Discussed the underlying SGST incentive matter with the management and obtained an understanding of the basis for management's judgement;
b) Evaluated the design and tested the operating effectiveness of key controls around the taxability of SGST incentives;
c) Obtained the tax views sought by the Company's management from an external legal counsel on the matter and evaluated the independence objectivity and competency of the specialists involved;
d) Involved auditor's expert to perform an evaluation of the relevant judgements passed by the authorities and assess the taxability of these incentives including the appropriateness of the tax rates used;
The key judgement is involved in the taxability of the SGST incentive on accrual or receipt basis relying on case laws and judgements and the resultant impact on the financial position results of operations and cash flows. In March 2019 the incentive income was offered to tax on accrual basis while as per the tax opinion obtained in quarter ended 31 December 2019 such income was to be offered to tax on receipt basis. Considering the materiality of amounts involved and significant Judgements involved the same has been considered as a Key audit matter for the current year's audit. e) Tested the arithmetical accuracy of the computation performed by the management; and
f ) Evaluated the appropriateness of the accounting policy used and related disclosures made in the accompanying standalone financial statements with regard to this matter.
Revenue recognition Our audit work included but was not limited to the following procedures:
Refer note 23 to the standalone financial statements. The Revenues of the Company consists primarily of sale of products and is recognized when control of products being sold is transferred to the customer and there is no unfulfilled obligation. a) Assessed the appropriateness of the Company's revenue recognition accounting policies in accordance with Ind AS 115 – Revenue from contracts with customers (Ind AS 115);
Revenue is measured at fair value of the consideration received or receivable and is accounted for net of rebates and trade discounts. b) Tested the design and operating effectiveness of the general IT control environment and the manual controls for recognition of revenue;
Revenue recognition process also involves certain key judgements relating to identification of distinct performance obligations determination of transaction price of the identified performance obligations and the appropriateness of revenue recognized. c) Performed substantive analytical procedures on revenue which included ratio analysis product mix analysis customer analysis etc.;
The Company also focuses on revenue as a key performance measure which could create an incentive for overstating revenue. d) Tested on a sample basis sales transactions to the underlying supporting documentation which includes goods dispatch notes and shipping documents;
Considering the materiality of amounts involved and significant judgements involved the same has been considered as a key audit matter for the current year's audit. e) Reviewed on a sample basis sales agreements and the underlying contractual terms related to delivery of goods and rebates to assess the Company's revenue recognition policies with reference to the requirements of the applicable accounting standards;
f ) Obtained supporting documentation for a sample of credit notes issued after the year end to determine whether the transaction was recognized in the correct accounting period;
g) Performed other substantive audit procedures including obtaining debtor confirmations on a sample basis and reconciling revenue recorded during the year with statutory returns;
h) Assessed if there is any modification to or other impact on the contracts with customers due to COVID 19 outbreak;
i) Tested manual journal entries impacting revenue including credit notes claims etc. which were material or irregular in nature with supporting documents and evaluated business rationale thereof; and
j) Ensured the adequacy and appropriateness of disclosures made in the financial statements in accordance with the requirements of Ind AS 115.

Information other than the Financial Statements and Auditor's Report thereon

6. The Company's Board of Directors is responsible for the other information. The otherinformation comprises the information included in the Annual Report but does not includethe standalone financial statements and our auditor's report thereon. The Annual Report isexpected to be made available to us after the date of this auditor's report.

Our opinion on the standalone financial statements does not cover the other informationand we will not express any form of assurance conclusion thereon.

In connection with our audit of the standalone financial statements our responsibilityis to read the other information identified above when it becomes available and in doingso consider whether the other information is materially inconsistent with the standalonefinancial statements or our knowledge obtained in the audit or otherwise appears to bematerially misstated.

When we read the Annual Report if we conclude that there is a material misstatementtherein we are required to communicate the matter to those charged with governance.

Responsibilities of Management and Those Charged with Governance for the StandaloneFinancial Statements

7. The accompanying standalone financial statements have been approved by the Company'sBoard of Directors. The Company's Board of Directors is responsible for the matters statedin section 134(5) of the Act with respect to the preparation of these standalone financialstatements that give a true and fair view of the financial position financial performanceincluding other comprehensive income changes in equity and cash flows of the Company inaccordance with the accounting principles generally accepted in India including the IndAS specified under section 133 of the Act. This responsibility also includes maintenanceof adequate accounting records in accordance with the provisions of the Act forsafeguarding of the assets of the Company and for preventing and detecting frauds andother irregularities; selection and application of appropriate accounting policies; makingjudgments and estimates that are reasonable and prudent; and design implementation andmaintenance of adequate internal financial controls that were operating effectively forensuring the accuracy and completeness of the accounting records relevant to thepreparation and presentation of the financial statements that give a true and fair viewand are free from material misstatement whether due to fraud or error.

8. In preparing the financial statements management is responsible for assessing theCompany's ability to continue as a going concern disclosing as applicable mattersrelated to going concern and using the going concern basis of accounting unless managementeither intends to liquidate the Company or to cease operations or has no realisticalternative but to do so.

9. Those Board of Directors is also responsible for overseeing the Company's financialreporting process.

Auditor's Responsibilities for the Audit of the Financial Statements

10. 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 auditor's report that includes our opinion. Reasonable assurance is a highlevel of assurance but is not a guarantee that an audit conducted in accordance withStandards on Auditing will always detect a material misstatement when it exists.Misstatements can arise from fraud or error and are considered material if individuallyor in the aggregate they could reasonably be expected to influence the economic decisionsof users taken on the basis of these financial statements.

11. As part of an audit in accordance with Standards on Auditing we exerciseprofessional judgment and maintain professional skepticism throughout the audit. We also:

Identify and assess the risks of material misstatement of the financial statementswhether due to fraud or error design and perform audit procedures responsive to thoserisks and obtain audit evidence that is sufficient and appropriate to provide a basis forour opinion. The risk of not detecting a material misstatement resulting from fraud ishigher than for one resulting from error as fraud may involve collusion forgeryintentional 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 with reference to financial statements in place andthe operating effectiveness of such controls;

Evaluate the appropriateness of accounting policies used and the reasonableness ofaccounting estimates and related disclosures 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 material uncertaintyexists related to events or conditions that may cast significant doubt on the Company'sability to continue as a going concern. If we conclude that a material uncertainty existswe are required to draw attention in our auditor's report to the related disclosures inthe financial statements or if such disclosures are inadequate to modify our opinion.Our conclusions are based on the audit evidence obtained up to the date of our auditor'sreport. However future events or conditions may cause the Company to cease to continue asa going concern; and

Evaluate the overall presentation structure and content of the financial statementsincluding the disclosures and whether the financial statements represent the underlyingtransactions and events in a manner that achieves fair presentation.

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

13. We also provide those charged with governance with a statement that we havecomplied with relevant ethical requirements regarding independence and to communicatewith them all relationships and other matters that may reasonably be thought to bear onour independence and where applicable related safeguards.

14. From the matters communicated with those charged with governance we determinethose matters that were of most significance in the audit of the financial statements ofthe current period and are therefore the key audit matters. We describe these matters inour auditor's 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.

Other Matter

15. We did not audit the financial statements of four partnership firms included in thestandalone financial statements whose financial information reflects total net profitafter tax of ` 13.19 lacs for the year ended 31 March 2020 as considered in thestandalone financial statements. These financial statements have been audited by otherauditors whose audit reports have been furnished to us by the management and our opinionin so far as it relates to the amounts and disclosures included in respect of thesepartnership firms is based solely on the audit reports of such other auditors. Our opinionon the standalone financial statements and our report on other legal and regulatoryrequirements below are not modified in respect of the above matters with respect to ourreliance on the work done by and the reports of the other auditors.

16. The standalone financial statements of the Company for the year ended 31 March 2019were audited by the predecessor auditor Deloitte Haskin and Sells who have expressed anunmodified opinion on those standalone financial statements vide their audit report dated28 May 2019.

Report on Other Legal and Regulatory Requirements

17. As required by section 197(16) of the Act based on our audit we report that theCompany has paid remuneration to its directors during the year in accordance with theprovisions of and limits laid down under section 197 read with Schedule V to the Act.

18. As required by the Companies (Auditor's Report) Order 2016 (‘the Order')issued by the Central Government of India in terms of section 143(11) of the Act we givein the Annexure A statement on the matters specified in paragraphs 3 and 4 of the Order.

19. Further to our comments in Annexure A as required by section 143(3) of the Actbased on our audit we report to the extent applicable that: a) we have sought andobtained all the information and explanations which to the best of our knowledge andbelief were necessary for the purpose of our audit of the accompanying standalonefinancial statements; b) in our opinion proper books of account as required by law havebeen kept by the Company so far as it appears from our examination of those books; c) thestandalone financial statements dealt with by this report are in agreement with the booksof account; d) in our opinion the aforesaid standalone financial statements comply withInd AS specified under section 133 of the Act; e) on the basis of the writtenrepresentations received from the directors and taken on record by the Board of Directorsnone of the directors is disqualified as on 31 March 2020 from being appointed as adirector in terms of section 164(2) of the Act; f ) we have also audited the internalfinancial controlswithreferencetofinancialstatements of the Company as on 31 March 2020 inconjunction with our audit of the standalone financial statements of the Company for theyear ended on that date and our report dated

25 June 2020 as per Annexure B expressed unmodified opinion; and g) with respect to theother matters to be included in the Auditor's Report in accordance with rule 11 of theCompanies (Audit and Auditors) Rules 2014 (as amended) in our opinion and to the best ofour information and according to the explanations given to us: i. the Company as detailedin note 35 to the standalone financial statements has disclosed the impact of pendinglitigations on its financial position as at 31 March 2020; ii. the Company did not haveany long-term contracts including derivative contracts for which there were any materialforeseeable losses as at 31 March 2020; iii. there has been no delay in transferringamounts required to be transferred to the Investor Education and Protection Fund by theCompany during the year ended 31 March 2020; and iv. the disclosure requirements relatingto holdings as well as dealings in specified bank notes were applicable for the periodfrom 8 November 2016 to 30 December 2016 which are not relevant to these standalonefinancial statements. Hence reporting under this clause is not applicable.

For Walker Chandiok & Co LLP
Chartered Accountants
Firm's Registration No.: 001076N/N500013
Manish Agrawal
Partner
Place: Ghaziabad Membership No.: 507000
Date: 25 June 2020 UDIN: 20507000AAAABN8979

Annexure A to the Independent Auditor's Report

Based on the audit procedures performed for the purpose of reporting a true and fairview on the financial statements of the Company and taking into consideration theinformation and explanations given to us and the books of account and other recordsexamined by us in the normal course of audit and to the best of our knowledge and beliefwe report that: (i) (a) The Company has maintained proper records showing fullparticulars including quantitative details and situation of fixed assets comprising‘property plant and equipment' ‘capital work-in-progress' and ‘otherintangible assets'.

(b) The fixed assets comprising ‘property plant and equipment' and ‘capitalwork-in-progress' have been physically verified by the management during the year and nomaterial discrepancies were noticed on such verification. In our opinion the frequency ofverification of the fixed assets is reasonable having regard to the size of the Companyand the nature of its assets. (c) The title deeds of all the immovable properties (whichare included under the head ‘Property plant and equipment') are held in the name ofthe Company. In respect of immovable properties in the nature of land buildings and"plant and machinery" that have been taken on lease and disclosed under thehead right-of-use assets in the standalone financial statements the lease agreements arein the name of the Company where the Company is the lessee as per the lease agreement.

(ii) In our opinion the management has conducted physical verification of inventory atreasonable intervals during the year except for goods-intransit. Material discrepanciesnoticed on such verification have been properly dealt with in the books of account.

(iii) The Company has not granted any loan secured or unsecured to companies firmsLimited Liability Partnerships (LLPs) or other parties covered in the register maintainedunder Section 189 of the Act. Accordingly the provisions of clauses 3(iii)(a) 3(iii) (b)and 3(iii)(c) of the Order are not applicable. (iv) In our opinion the Company hascomplied with the provisions of Sections 185 and 186 of the Act in respect of loansinvestments and guarantees. Further in our opinion the Company has not entered into anytransaction covered under Section 185 and Section 186 of the Act in respect of security.

(v) In our opinion the Company has not accepted any deposits within the meaning ofSections 73 to 76 of the Act and the Companies (Acceptance of Deposits) Rules 2014 (asamended). Accordingly the provisions of clause 3(v) of the Order are not applicable.

(vi) We have broadly reviewed the books of account maintained by the Company pursuantto the Rules made by the Central Government for the maintenance of cost records undersub-section (1) of Section 148 of the Act in respect of Company's products and are of theopinion that prima facie the prescribed accounts and records have been made andmaintained. However we have not made a detailed examination of the cost records with aview to determine whether they are accurate or complete.

(vii) (a) Undisputed statutory dues including provident fund employees' stateinsurance income-tax sales-tax service tax duty of customs duty of excise valueadded tax cess and other material statutory dues as applicable have generally beenregularly deposited to the appropriate authorities though there has been a slight delayin a few cases. Further no undisputed amounts payable in respect thereof were outstandingat the year-end for a period of more than six months from the date they became payable.(b) The dues outstanding in respect of income-tax sales-tax service-tax duty ofcustoms duty of excise and value added tax on account of any dispute are as follows:

Statement of Disputed Dues

Name of the statute Nature of dues Amount (` in lacs) Amount paid under Protest Period to which the amount Forum where dispute is pending
(` in lacs) relates (FY)
Central Excise Act 1944 Excise duty 9.80 - 2013-14 Appellate authority till Commissioner level
Central Excise Act 1944 Service tax 53.09 3.98 2010-11 to 2014- 15 Customs Excise and Service Tax Appellate Tribunal
Central Excise Act 1944 Service tax 49.25 3.69 2015-16 to 2016- 17 Customs Excise and Service Tax Appellate Tribunal
Central Excise Act 1944 Excise duty 114.90 - 2014-15 to 2017- 18 Customs Excise and Service Tax Appellate Tribunal
Central Excise Act 1944 Excise duty 4.02 - 2016-17 Customs Excise and Service Tax Appellate Tribunal
Central Excise Act 1944 Excise duty 24.29 - 2014-15 to 2017- 18 Appellate authority till Commissioner level
Central Excise Act 1944 Excise duty 15.04 - 2014-15 to 2017- 18 Appellate authority till Commissioner level
Central Excise Act 1944 Excise duty 64.81 - 2014-15 to 2017- 18 Appellate authority till Commissioner level
Customs Act 1962 Custom duty 98.45 14.41 2011-12 to 2014- 15 Appellate authority till Commissioner level
Customs Act 1962 Custom duty 2.81 - 2015-16 Customs Excise and Service Tax Appellate Tribunal
Customs Act 1962 Custom duty 4.54 - 2014-15 Customs Excise and Service Tax Appellate Tribunal
The Rajasthan Value Added Tax Act 2003 Value added tax 1.87 - 2012-13 Appellate Tribunal
Goods and Services Tax 2017 Goods and Services Tax 4.77 0.48 2018-19 Commissioner (Appeals)
Income-tax Act 1961 Income tax 3.70 3.70 2011-12 Income Tax Appellate Tribunal

(viii) The Company has not defaulted in repayment of loans or borrowings to any banksand financial institution during the year. The Company did not have any outstandingdebentures or dues to government during the year.

(ix) The Company did not raise moneys by way of initial public offer or further publicoffer (including debt instruments). In our opinion the term loans were applied for thepurposes for which the loans were obtained though idle funds which were not required forimmediate utilisation have been invested in liquid investments payable on demand.

(x) No fraud by the Company or on the Company by its officers or employees has beennoticed or reported during the period covered by our audit.

(xi) Managerial remuneration has been provided by the Company in accordance with therequisite approvals mandated by the provisions of Section 197 of the Act read withSchedule V to the Act.

(xii) In our opinion the Company is not a Nidhi Company. Accordingly provisions ofclause 3(xii) of the Order are not applicable.

(xiii) In our opinion all transactions with the related parties are in compliance withSections 177 and 188 of Act where applicable and the requisite details have beendisclosed in the financial statements etc. as required by the applicable Ind AS. (xiv)During the year the Company has not made any preferential allotment or private placementof shares or fully or partly convertible debentures.

(xv) In our opinion the Company has not entered into any non-cash transactions withthe directors or persons connected with them covered under Section 192 of the Act. (xvi)The Company is not required to be registered under Section 45-IA of the Reserve Bank ofIndia Act 1934.

For Walker Chandiok & Co LLP
Chartered Accountants
Firm's Registration No.: 001076N/N500013
Manish Agrawal
Partner
Place: Ghaziabad Membership No.: 507000
Date: 25 June 2020 UDIN: 20507000AAAABN8979

Annexure B to the Independent Auditor's Report

Independent Auditor's Report on the internal financial controls with reference to thestandalone financial statements under Clause (i) of Sub-section 3 of Section 143 of theCompanies Act 2013 (‘the Act')

1. In conjunction with our audit of the standalone financial statements of GravitaIndia Limited (‘the Company') as at and for the year ended 31 March 2020 we haveaudited the internal financial controls with reference to financial statements of theCompany as at that date.

Responsibilities of Management and Those Charged with Governance for Internal FinancialControls

2. The Company's Board of Directors is responsible for establishing and maintaininginternal financial controls based on the internal financial controls with reference tofinancial statements criteria established by the Company considering the essentialcomponents of internal control stated in the Guidance Note on Audit of Internal FinancialControls over Financial Reporting (‘the Guidance Note')issued by the Institute ofChartered Accountants of India (‘ICAI'). These responsibilities include the designimplementation and maintenance of adequate internal financial controls that were operatingeffectively for ensuring the orderly and efficient conduct of the Company's businessincluding adherence to the Company's policies the safeguarding of its assets theprevention and detection of frauds and errors the accuracy and completeness of theaccounting records and the timely preparation of reliable financial information asrequired under the Act.

Auditor's Responsibility for the Audit of the Internal Financial Controls withReference to Financial Statements

3. Our responsibility is to express an opinion on the Company's internal financialcontrols with reference to financial statements based on our audit. We conducted our auditin accordance with the Standards on Auditing issued by the ICAI prescribed under Section143(10) of the Act to the extent applicable to an audit of internal financial controlswith reference to financial statements and the Guidance Note issued by the ICAI. ThoseStandards and the Guidance Note require that we comply with ethical requirements and planand perform the audit to obtain reasonable assurance about whether adequate internalfinancial controls with reference to financial statements were established and maintainedand if such controls operated effectively in all material respects.

4. Our audit involves performing procedures to obtain audit evidence about the adequacyof the internal financial controls with reference to financial statements and theiroperating effectiveness. Our audit of internal financial controls with reference tofinancial statements includes obtaining an understanding of such internal financialcontrols assessing the risk that a material weakness exists and testing and evaluatingthe design and operating effectiveness of internal control based on the assessed risk. Theprocedures selected depend on the auditor's judgement including the assessment of therisks of material misstatement of the financial statements whether due to fraud or error.

5. 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 withreference to financial statements.

Meaning of Internal Financial Controls with Reference to Financial Statements

6. A company's internal financial controls with reference to financial statements is aprocess designed to provide reasonable assurance regarding the reliability of financialreporting and the preparation of financial statements for external purposes in accordancewith generally accepted accounting principles. A company's internal financial controlswith reference to financial statements include those policies and procedures that (1)pertain to the maintenance of records that in reasonable detail accurately and fairlyreflect the transactions and dispositions of the assets of the company; (2) providereasonable assurance that transactions are recorded as necessary to permit preparation offinancial statements in accordance with generally accepted accounting principles and thatreceipts and expenditures of the company are being made only in accordance withauthorisations of management and directors of the company; and (3) provide reasonableassurance regarding prevention or timely detection of unauthorised acquisition use ordisposition of the company's assets that could have a material effect on the financialstatements.

Inherent Limitations of Internal Financial Controls with Reference to FinancialStatements

7. Because of the inherent limitations of internal financial controls with reference tofinancial statements including the possibility of collusion or improper managementoverride of controls material misstatements due to error or fraud may occur and not bedetected. Also projections of any evaluation of the internal financial controls withreference to financial statements to future periods are subject to the risk that theinternal financial controls with reference to financial statements may become inadequatebecause of changes in conditions or that the degree of compliance with the policies orprocedures may deteriorate.

Opinion

8. In our opinion the Company has in all material respects adequate internalfinancial controls with reference to financial statements and such controls were operatingeffectively as at 31 March 2020 based on the internal control over financial reportingcriteria established by the Company considering the essential components of internalcontrol stated in the Guidance Note issued by the ICAI.

For Walker Chandiok & Co LLP
Chartered Accountants
Firm's Registration No.: 001076N/N500013
Manish Agrawal
Partner
Place: Ghaziabad Membership No.: 507000
Date: 25 June 2020 UDIN: 20507000AAAABN8979

.