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Gujarat State Petronet Ltd.

BSE: 532702 Sector: Others
NSE: GSPL ISIN Code: INE246F01010
BSE 00:00 | 26 Nov 302.50 -9.95
(-3.18%)
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306.85

HIGH

310.20

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301.50

NSE 00:00 | 26 Nov 302.30 -10.25
(-3.28%)
OPEN

309.00

HIGH

310.00

LOW

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OPEN 306.85
PREVIOUS CLOSE 312.45
VOLUME 21702
52-Week high 383.00
52-Week low 191.00
P/E 16.84
Mkt Cap.(Rs cr) 17,067
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00
OPEN 306.85
CLOSE 312.45
VOLUME 21702
52-Week high 383.00
52-Week low 191.00
P/E 16.84
Mkt Cap.(Rs cr) 17,067
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

Gujarat State Petronet Ltd. (GSPL) - Auditors Report

Company auditors report

To

The Members of

Gujarat State Petronet Limited

Report on the Audit of Standalone Ind ASFinancial Statements

Opinion

We have audited the accompanying standalone IND AS financial statementsof PETRONET LIMITED

('The Company) which comprise the Balance Sheet as at 31st March2020 the Statement of Profit and Loss (including Other Comprehensive Income) theStatement of Changes in Equity and Statement of Cash Flows for the year then ended and asummary of significant accounting policies and other explanatory information (hereinafterreferred to as “the standalone Ind AS financial statements”) which we havesigned under reference to this report.

In our opinion and to the best of our information and according to theexplanations given to us the aforesaid standalone financial statements give theinformation required by the Companies Act 2013 (“the Act”) in the manner sorequired and give a true and fair view in conformity with the Indian Accounting Standardsprescribed under section 133 of the Act read with the Companies (Indian AccountingStandards) Rules 2015 as amended (“Ind AS”) and other accounting principlesgenerally accepted in India of the state of affairs of the Company as at 31stMarch 2020 the profit and total comprehensive income changes in equity and its cashflows for the year ended on that date.

Basis for Opinion

We conducted our audit of the standalone financial statements inaccordance with the Standards on Auditing specified under section 143(10) of the Act(SAs). Our responsibilities under those Standards are further described in theAuditor's Responsibilities for the Audit of the Standalone 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) together with theethical requirements that are relevant to our audit of the standalone financial statementsunder the provisions of the Act and the Rules made thereunder and we have fulfilled ourother ethical responsibilities in accordance with these requirements and the ICAI'sCode of Ethics. We believe that the audit evidence we have obtained is sufficient andappropriate to provide a basis for our audit opinion on the standalone financialstatements.

Key Audit Matters

Key audit matters are those matters that in our professional judgmentwere of most significance in our audit of the financial statements for the financial yearended 31st March 2020. These matters were addressed in the context of ouraudit of the financial statements as a whole and in forming our opinion thereon and wedo not provide a separate opinion on these matters.

We have determined that there are no key audit matters to communicatein our report.

Information Other than the Standalone Financial Statements andAuditor's Report Thereon

The Company's Board of Directors is responsible for thepreparation of the other information. The other information comprises the informationincluded in the Management Discussion and Analysis Board's Report includingAnnexures to Board's Report Business Responsibility Report Corporate Governance andShareholder's Information but does not include the standalone financial statementsand our auditor's report thereon.

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

In connection with our audit of the standalone financial statementsour responsibility is to read the other information and in doing so consider whether theother information is materially inconsistent with the standalone financial statements orour knowledge obtained during the course of our audit or otherwise appears to bematerially misstated.

If based on the work we have performed we conclude that there is amaterial misstatement of this other information; we are required to report that fact. Wehave nothing to report in this regard.

Responsibility of Management and those charged with governance for theInd AS financial statements

The Company's Board of Directors is responsible for the mattersstated in section 134(5) of the Act with respect to the preparation of these standalonefinancial statements that give a true and fair view of the financial position financialperformance total comprehensive income changes in equity and cash flows of the Companyin accordance with the Ind AS and other accounting principles generally accepted in India.This responsibility also includes maintenance of adequate accounting records in accordancewith the provisions of the Act for safeguarding the assets of the Company and forpreventing and detecting frauds and other irregularities; selection and application ofappropriate accounting policies; making judgments and estimates that are reasonable andprudent; and design implementation and maintenance of adequate internal financialcontrols that were operating effectively for ensuring the accuracy and completeness ofthe accounting records relevant to the preparation and presentation of the standalonefinancial statements that give a true and fair view and are free from materialmisstatement whether due to fraud or error.

In preparing the standalone financial statements management isresponsible 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 management either intends to liquidate the Company or to ceaseoperations or has no realistic alternative but to do so.

The Board of Directors is responsible for overseeing the Company'sfinancial reporting process.

Auditors Responsibilities for the Audit of the Ind AS FinancialStatements

Our objectives are to obtain reasonable assurance about whether thefinancial 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. Reasonableassurance is a high level of assurance but it is not a guarantee that an audit conductedin accordance with SAs will always detect a material misstatement when it exists.Misstatements can arise from fraud or error and considered material if individually or inthe aggregate they could reasonably be expected to influence the economic decisions ofusers taken on the basis of these financial statements.

As part of an audit in accordance with SAs we exercise professionaljudgment and maintain professional skepticism throughout the audit. We also:

• Identify and assess the risks of material misstatement of thefinancial statements whether due to fraud or error design and perform audit proceduresresponsive to those risks and obtain audit evidence that is sufficient and appropriate toprovide a basis for our opinion. The risk of not detecting a material misstatementresulting from fraud is higher than for one resulting from error as fraud may involvecollusion forgery intentional omissions misrepresentations or the override of internalcontrol.

• Obtain an understanding of internal financial controls relevantto the audit in order to design audit procedures that are appropriate in thecircumstances. Under section 143(3)(i) of the Act we are also responsible for expressingour opinion on whether the Company has adequate internal financial controls system inplace and the operating effectiveness of such controls.

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

• Conclude on the appropriateness of management's use of thegoing concern basis of accounting and based on the audit evidence obtained whether amaterial uncertainty exists related to events or conditions that may cast significantdoubt on the Company's ability to continue as a going concern. If we conclude that amaterial uncertainty exists we are required to draw attention in our auditor'sreport to the related disclosures in the standalone financial statements or if suchdisclosures are inadequate to modify our opinion. Our conclusions are based on the auditevidence obtained up to the date of our auditor's report. However future events orconditions may cause the Company to cease to continue as a going concern.

• Evaluate the overall presentation structure and content of thefinancial statements including the disclosures and whether the financial statementsrepresent the underlying transactions and events in a manner that achieves fairpresentation.

Materiality is the magnitude of misstatements in the standalonefinancial statements that individually or in aggregate makes it probable that theeconomic decisions of a reasonably knowledgeable user of the financial statements may beinfluenced. We consider quantitative materiality and qualitative factors in

(i) planning the scope of our audit work and in evaluating the resultsof our work; and (ii) to evaluate the effect of any identified misstatements in thefinancial statements.

We communicate with those charged with governance regarding amongother matters the planned scope and timing of the audit and significant audit findingsincluding any significant deficiencies in internal control that we identify during ouraudit.

We also provide those charged with governance with a statement that wehave complied with relevant ethical requirements regarding independence and tocommunicate with them all relationships and other matters that may reasonably be thoughtto bear on our independence and where applicable related safeguards.

Report on other legal and Regulatory Requirements

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

a) We have sought and obtained all the information and

explanations which to the best of our knowledge and belief werenecessary for the purposes of our audit.

b) In our opinion proper books of account as required by law have beenkept by the Company so far as it appears from our examination of those books.

c) The Balance Sheet the Statement of Profit and Loss including OtherComprehensive Income Statement of Changes in Equity and the Statement of Cash Flow dealtwith by this Report are in agreement with the books of account.

d) In our opinion the aforesaid standalone IND AS financial statementscomply with the Indian Accounting Standards specified under Section 133 of the Act readwith the Companies (Indian Accounting Standards) Rules 2015 as amended.

e) As the Company is a Government Company in terms of notificationnumber: G.S.R. 463(E) dated 05th June 2015 issued by Ministry of CorporateAffairs the sub section (2) of section 164 of the Act is not applicable.

f) With respect to the adequacy of the internal financial controls overfinancial reporting of the Company and the operating effectiveness of such controls referto our separate report in “Annexure A”. Our report expresses an unmodifiedopinion on the adequacy and operating effectiveness of the Company's internalfinancial controls over financial reporting.

g) With respect to the other matters to be included in theAuditor's Report in accordance with Rule 11 of the Companies (Audit and Auditors)Rules 2014 in our opinion and to the best of our information and according to theexplanations given to us:

i) The Company has disclosed the impact of pending litigations on itsfinancial position in its financial statements. Refer Note-32 to the financial statements.

ii) The Company has made provision as required under the applicablelaw or Indian accounting standards for material foreseeable losses if any on long-termcontracts including derivative contracts.

iii) There has been no delay in transferring amounts required to betransferred to the Investor Education and Protection Fund by the Company.

2. As required by section 143(5) of the Act we give in “AnnexureB” a statement on matters specified by the Comptroller and Auditor- General of Indiafor the Company.

3. As required by the Companies (Auditor's Report) Order 2016(“the Order”) issued by the Central Government of India in terms of sub-section(11) of section 143 of the Act we give in the Annexure C a statement on the mattersspecified in the paragraph 3 and 4 of the Order to the extent applicable.

For Anoop Agarwal & Co.
Place: Ahmedabad Chartered Accountants
Date : 8 th June 2020 Firm Registration No. 001739C
(CA Chirag J Patel)
Partner
Membership No. 115637
UDIN : 20115637AAAABG8520

ANNEXURE - A TO THE INDEPENDENT AUDITOR'S REPORT

Report on the Internal Financial Controls under Clause (i) ofSub-section 3 of Section 143 of the Companies Act 2013 (“the Act”)

We have audited the internal financial controls over financialreporting of GUJARAT STATE PETRONET LIMITED (“the Company”) as of 31stMarch 2020 in conjunction with our audit of the standalone IND AS financial statements ofthe Company for the year ended on that date.

Management's Responsibility for Internal Financial Controls

The Company's management is responsible for establishing andmaintaining internal financial controls based on the internal control over financialreporting criteria established by the Company considering the essential components ofinternal control stated in the Guidance Note on Audit of Internal Financial Controls overFinancial Reporting issued by the Institute of Chartered Accountants of India(‘ICAI'). These responsibilities include the design implementation andmaintenance of adequate internal financial controls that were operating effectively forensuring the orderly and efficient conduct of its business including adherence tocompany's policies the safeguarding of its assets the prevention and detection offrauds and errors the accuracy and completeness of the accounting records and the timelypreparation of reliable financial information as required under the Companies Act 2013.

Auditor's Responsibility

Our responsibility is to express an opinion on the Company'sinternal financial controls over financial reporting based on our audit. We conducted ouraudit in accordance with the Guidance Note on Audit of Internal Financial Controls overFinancial Reporting (the ‘Guidance Note') and the Standards on Auditing issuedby ICAI and deemed to be prescribed under Section 143(10) of the Companies Act 2013 tothe extent applicable to an audit of internal financial controls both applicable to anaudit of Internal Financial Controls and both issued by the Institute of CharteredAccountants 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 were established andmaintained and if such controls operated effectively in all material respects.

Our audit involves performing procedures to obtain audit evidence aboutthe adequacy of the internal financial controls system over financial reporting and theiroperating effectiveness. Our audit of internal financial controls over financial reportingincluded obtaining an understanding of internal financial controls over financialreporting 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 auditors' judgment including the assessment of therisks of material misstatement of the financial statements whether due to fraud or error.

We believe that the audit evidence we have obtained is sufficient andappropriate to provide a basis for our audit opinion on the Company's internalfinancial controls system over financial reporting.

Meaning of Internal Financial Controls over Financial Reporting

A company's internal financial control over financial reporting isa process 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 controlover financial reporting includes those policies and procedures that :

(1) Pertain to the maintenance of records that in reasonable detailaccurately and fairly reflect the transactions and dispositions of the assets of theCompany;

(2) Provide reasonable assurance that transactions are recorded asnecessary to permit preparation of financial statements in accordance with generallyaccepted accounting principles and that receipts and expenditures of the Company arebeing made only in accordance with authorizations of the Management and directors of theCompany; and

(3) Provide reasonable assurance regarding prevention or timelydetection of unauthorized acquisition use or disposition of the Company's assetsthat could have a material effect on the financial statements.

Inherent Limitations of Internal Financial Controls over FinancialReporting

Because of the inherent limitations of internal financial controls overfinancial reporting including the possibility of collusion or improper

management override of controls material misstatements due to error orfraud may occur and not be detected. Also projections of any evaluation of the internalfinancial controls over financial reporting to future periods are subject to the risk thatthe internal financial control over financial reporting 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 an adequateinternal financial controls system over financial reporting and such internal financialcontrols over financial reporting were operating effectively as at 31 March 2020 based onthe internal 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.

Place: Ahmedabad Date : 8th June 2020 For Anoop Agarwal & Co.
Chartered Accountants Firm Registration No. 001739C
(CA Chirag J Patel)
Partner
Membership No. 115637
UDIN : 20115637AAAABG8520

ANNEXURE - B TO THE INDEPENDENT AUDITOR'S REPORT

Report on the Directions/ Sub-directions issued by Comptroller andAuditor General of India

Based on the audit procedures performed and taking into considerationthe information explanations and written representations given to us by the management inthe normal course of audit we to the best of our knowledge and belief that:

General Directions under section 143 (5) of Companies Act 2013

Sr. No. Directions issued by Comptroller and Auditor General of India Response
1. Whether the company has system in place to process all the accounting transactions through IT system? If yes the implications of processing of accounting transactions outside IT system on the integrity of the accounts along with the financial implications if any may be stated. The Company is using SAP for accounting of all transactions through IT system only.
2 Whether there is any restructuring of an existing loan or cases of waiver/write off of debts /loans/interest etc. made by a lender to the company due to the company's inability to repay the loan? If yes the financial impact may be stated. On the basis of our audit and as per information and explanations given to us there is no such case during the financial year 2019-20 therefore no any impact on the financial statements. The Company is repaying its loan in timely.
3 Whether funds received/receivable for specific schemes from central/ state agencies were properly accounted for/ utilized as per its term and conditions? List the cases of deviation. It is conveyed to us that no funds have been received or receivable from central/ state agencies hence not applicable.

Sector Specific Sub-directions under section 143 (5) of Companies Act2013

Sr. No. Sub-directions issued by Comptroller and Auditor General of India Response
1. Whether the Company has taken adequate measures to prevent encroachment of idle land owned by it. Whether any land of the Company is encroached under litigation not put to use or declared surplus? Details may be provided. As per information and explanation given to us the Company has taken adequate measures to prevent encroachment and there is no encroachment to the land owned by the company.
2 Whether the system in vogue for identification of projects to be taken up under Public Private Partnership is in line with the guidelines/ policies of the Government? Comment on deviation if any? In our opinion and according to the information and explanations given to us the Company does not have any project to be taken up under Public Private Partnership.
3 Whether system for monitoring the execution of works vis-a-vis the milestones stipulated in the agreement is in existence and the impact of cost escalation if any revenue / losses from contracts etc. have been properly accounted for in the books. Based on our audit procedures and according to the information and explanations given to us System for monitoring the execution of works vis-a-vis the milestones stipulated in the agreement is in existence and the impact of cost escalation if any revenue/ losses from contracts etc. have been properly accounted for in the books of accounts.
4 Whether funds received / receivable for specific schemes from central/ state agencies were properly accounted for/ utilized? List the cases of deviations. It is conveyed to us that no funds have been received or receivable from central/ state agencies hence not applicable.
5 Whether the Bank guarantees have been revalidated in time. Yes The Bank guarantees have been revalidated in a timely manner.
6 Comment on the confirmation of balances of trade receivables trade payables term deposits bank accounts and cash obtained. Yes balance confirmation has been received in respect of term deposits bank accounts & Cash. A separate disclosure has been given for trade receivables & trade payables. Please refer to Note no- 38 to notes to account.
7 The cost incurred on abandoned projects may be quantified and the amount actually written-off shall be mentioned. As informed to us the Company has not abandoned any project during the financial year 2019-20.

Trading under Service Sector

Sr. No. Trading under service sector Response (During the current yearthe company has started retail selling of

CNG for Amritsar-GA hence response is given in this context)

1. Whether the company has an As per the information and explanationsgiven to us and based on the examination

effective system for recovery of dues of the policies in respect ofrecovery of dues from customers the Company has in respect of its sales activities andthe a policy and procedure for effective monitoring of credit exposure and recovery duesoutstanding and recoveries there of dues from its customers in respect of its salesactivities. In our opinion and against have been properly recorded according to theinformation and explanation given to us the recoveries against the in the books ofaccounts? dues have been properly recorded in the books of accounts

2. Whether the company has an effective In our opinion and according tothe information and explanations given to us the

system for physical verification procedures and systems in relationto physical verification of inventories valuation valuation of stock treatment of non-of stock treatment of non-moving items and accounting the effect of shortage / movingitems and accounting the excess noticed during physical verification are reasonable andadequate in relation effect of shortage / excess noticed to the size of the Company andthe nature of its business.

during physical verification

3. The effectiveness of the system In our opinion and according to theinformation and explanations given to us the

followed in recovery of dues in respect Company has a policy andprocedure for effective monitoring of credit exposure of sale activities may be examinedand and recovery of dues from its customers in respect of its sales activities. There areno reported. significant instances of its failure observed for the year under audit.

Place: Ahmedabad For Anoop Agarwal & Co.
Date : 8th June 2020 Chartered Accountants
Firm Registration No. 001739C
(CA Chirag J Patel)
Partner
Membership No. 115637
UDIN : 20115637AAAABG8520

ANNEXURE - C TO THE INDEPENDENT AUDITOR'S REPORT

The Annexure referred to in our Independent Auditors' Report tothe members of the Company on the standalone financial statements for the year ended 31stMarch 2020 we report that:

1. (a) The company has maintained proper records showing fullparticulars including quantitative details and situation of its fixed assets.

(b) The Company has a regular programme of physical verification of itsProperty Plant and Equipment in a phased manner over a period of three years. Inaccordance with this programme certain fixed assets were verified during the year and nomaterial discrepancies were noticed on such verification. In our opinion this periodicityof physical verification is reasonable having regard to the size of the Company and natureof its assets.

(c) According to the information and explanation given to us the titledeeds of immovable properties of the Company are held in the name of the Company.

2. As informed to us physical verification of inventory has beenconducted at reasonable intervals by the management. We have been explained that the stockof Gas at the year end of the year has been taken with reference to reading of Turbineflow meter/ Gas Chromatograph/ Gas measurement system installed at Terminals.

As explained to us no material discrepancies were noticed on physicalverification of inventories as compared to the book records.

3. The Company has not granted any loans secured or unsecured tocompanies firms Limited Liability Partnerships or other parties covered in the registermaintained under section 189 of the Companies Act 2013. Therefore the provisions ofclause 3 (a) (b) and (c ) of the said order not applicable to the Company.

4. The Company has granted Corporate Guarantee of Rs. 6500.00 Lakh inrespect of its two jointly controlled companies namely GSPL India Gasnet Limited and GSPLIndia Transco Limited. In our opinion and according to the information and explanationsgiven to us the company has complied with the provisions of section 185 and 186 of theCompanies Act 2013 in respect of loans investment guarantees and security.

5. In our opinion and according to the information and explanationsgiven to us the Company has not accepted any deposits from the Public during the year.Therefore the directives issued by the Reserve Bank of India and the provisions ofsections 73 to 76 or any other relevant provisions of the Act and the Companies(Acceptance of Deposit) Rules 2015 with regard to the deposits accepted from the publicare not applicable.

6. As per information & explanation given by the managementmaintenance of cost records has been prescribed by the Central Government undersub-section (1) of section 148 of the Act and we are of the opinion that prima facie theprescribed accounts and records have been made and maintained. We have not however made adetailed examination of the records with a view to determine whether they are accurate andcomplete.

7. (a) According to the information and explanations given to us and onthe basis of our examination of the records of the

Company amounts deducted/ accrued in the books of account in respectof undisputed statutory dues including provident fund income tax sales tax wealth taxservice tax duty of customs value added tax GST cess and other material statutory dueshave been regularly deposited during the year by the Company with the appropriateauthorities. As explained to us the Company did not have any dues on account ofemployees' state insurance and duty of excise.

According to the information and explanations given to us noundisputed amounts payable in respect of provident fund income tax sales tax wealthtax service tax duty of customs value added tax cess GST and other material statutorydues were in arrears as at 31st March 2020 for a period of more than six monthsfrom the date they became payable.

b) According to the information and explanations given to us thefollowing dues of Income Tax Duties of Excise and service tax as at 31stMarch 2020 have not been deposited by the Company on account of disputes given below:

Nature of Statute Nature of Dues Amount C in Lacs) Period to which the amount Relates Forum where the dispute is pending
The Income Tax Act 1961 Assessment Disallowance 3.95 2016-17 CIT (Appeals)
Reduction of MAT Credit 235.38 2012-13 CIT (Appeals)
The Finance Act 1994 Denial of Cenvat Credit 735.04 2005-08 2008-09 & 2010-11 Supreme Court.
Denial of Cenvat Credit 14414.99 2005-08 2008-09 & 2010-11 Gujarat High Court
The Finance Act 1994 Denial of Cenvat Credit 9468.15 2009- 10 2010- 11 2011-12 2012-13 CESTAT
Denial of Cenvat Credit 3920.03 2010-11 2012-13 2014- 15 2015- 16 2016- 17 Commissioner/ Asst. Commissioner
Service tax on Liquidated Damages 480.65 2012-17 CESTAT

8. Based on our audit procedures and according to the information andexplanations given to us the Company has not defaulted in repayment of loans or borrowingto financial institution bank Government or dues to debenture holders. There were nodebenture holders at any time during the year.

9. In our opinion and according to the information and explanationsgiven to us the Company has not raised moneys by way of Initial Public offer or furtherpublic offer or new term loans during the year. However the term loans outstanding at thebeginning of the year have been applied for the purpose for which the loans were raised.

10. To the best of our knowledge and belief and according to theinformation and explanations given to us no material fraud on or by the company by itsofficers or employees during the year was noticed or reported nor we have been informedof such case by the management.

11. According to the information and explanations give to us and basedon our examination of the record of the Company the Company has not paid/ provided formanagerial remuneration.

12. The Company is not a Nidhi company. Therefore the provisions ofclause 3 (xii) of the Companies (Auditor's Report) Order 2016 are not applicable tothe Company.

13. In our opinion all transactions with the related parties are incompliance with section 177 and 188 of Companies Act 2013 where applicable and thedetails of such transactions have been disclosed in the notes to the financial statementsas required by Indian Accounting Standard (AS) 24 Related Party Disclosures.

14. According to the information and explanations given to us theCompany has not made any preferential allotment or private placement of shares or fullyor partly convertible debentures during the year under review and therefore theprovisions of clause 3(ix) of the Companies (Auditor's Report) Order 2016 are notapplicable to the Company.

15. In our opinion and according to the information and explanationsgiven to us the company has not entered in to any non-cash transactions with directors orpersons connected with him.

16. The company is not required to be registered under section 45-IA ofthe Reserve Bank of India Act 1934 and accordingly the provisions of clause 3 (xvi) ofthe Order are not applicable to the Company and hence not commented upon.

Place: Ahmedabad For Anoop Agarwal & Co.
Date : 8th June 2020 Chartered Accountants Firm Registration No. 001739C
(CA Chirag J Patel)
Partner
Membership No. 115637
UDIN : 20115637AAAABG8520

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