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HSIL Ltd.

BSE: 500187 Sector: Industrials
NSE: HSIL ISIN Code: INE415A01038
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VOLUME 21026
52-Week high 287.35
52-Week low 95.00
P/E 12.51
Mkt Cap.(Rs cr) 1,384
Buy Price 0.00
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Sell Price 0.00
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OPEN 225.00
CLOSE 226.50
VOLUME 21026
52-Week high 287.35
52-Week low 95.00
P/E 12.51
Mkt Cap.(Rs cr) 1,384
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

HSIL Ltd. (HSIL) - Auditors Report

Company auditors report

To the Members of HSIL Limited

REPORT ON THE AUDIT OF THE STANDALONE FINANCIAL STATEMENTS

OPINION

We have audited the standalone financial statements of HSIL Limited ("theCompany") which comprise the Balance sheet as at 31st March 2020 and the Statementof Profit and Loss (including Other Comprehensive Income) the Statement of Changes inEquity and the Cash Flow Statement for the year then ended and notes to the financialstatements including a summary of significant accounting policies and other explanatoryinformation.

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 accounting principlesgenerally accepted in India of the state of affairs of the Company as at 31st March2020 and its Profit (including other comprehensive income) changes in equity and itscash flows for the year ended on that date.

BASIS FOR OPINION

We conducted our audit in accordance with the Standards on Auditing(SAs) specified under section 143(10) of the Companies Act 2013. Our responsibilitiesunder those Standards are further described in the Auditor's Responsibilities for theAudit of the Standalone Financial Statements section of our report. We are independent ofthe Company in accordance with the Code of Ethics issued by the Institute of CharteredAccountants of India (ICAI) together with the ethical requirements that are relevant toour audit of the standalone financial statements under the provisions of the CompaniesAct 2013 and the Rules made thereunder and we have fulfilled our other ethicalresponsibilities in accordance with these requirements and the Code of Ethics. We believethat the audit evidence we have obtained is sufficient and appropriate to provide a basisfor our opinion.

EMPHASIS OF MATTER

Attention is drawn to:

(i) Note no. 53 regarding the utilisation of the BusinessReconstruction Reserve ('BRR') to the extent of Rs 1400.02 lakhs which was created inaccordance with a scheme of arrangement (the scheme) approved by Hon'ble High Court ofCalcutta. During the year the Company has impaired goodwill related to a Businessundertaking amounting to Rs 1400.02 lakhs and charged the same as exceptional item tostatement of statement of Profit and Loss of that year and withdrawn equivalent amountfrom BRR.

(ii) Note no. 58 regarding COVID-19 related lock-down/ restrictionswhere management could perform year end physical verification of inventories at certainlocations subsequent and near to year end. However we could not been able to physicallyobserve the verification of inventories that was carried out by the Management.Consequently we have performed alternate procedures to audit the existence of Inventoryas per the guidance provided by in SA 501 "Audit Evidence - Specific Considerationsfor Selected Items" and have obtained sufficient audit evidence to issue ourunmodified opinion on these Financial Statements.

Further opinion of the management on the carrying value of assets andliabilities and COVID-19 impact on the operation as stated in the said note.

Our opinion is not modified in respect of the above matters.

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 March 31 2020. These matters were addressed in the context of our audit of thefinancial statements as a whole and in forming our opinion thereon and we do not providea separate opinion on these matters. We have determined the matters described below to bethe key audit matters to be communicated in our report.

Description of Key Audit Matter How our audit addressed the key audit matter
Goodwill impairment assessment (as described in note no.5 of the financial statements)
The Company had recognised goodwill on merger of Garden Polymers (P) Ltd (GPPL) in earlier year. Subsequent to adoption of Ind AS it was subject to impairment testing. Our response to the audit risk
In line with requirements of Ind AS-36 an impairment assessment being performed on yearly basis and the company has recognised impairment loss of Rs 1400.02 lakhs in financial year 2019-20 charged to BRR. (Refer note no. 5 to the financial statements) We evaluated the process by which management prepared its cash flow forecast and compared them against the latest Board approved plans and management approved forecasts. We evaluated the historical accuracy of the plans and forecasts. These procedures enabled us to determine the accuracy of the forecasting process and apply appropriate sensitivities to the cash flows.
We assessed the appropriateness of independent valuer's / management adopted discount rates future cash flows and longterm growth rates specifically focusing on the CGUs identified opposite. We benchmarked assumptions against industry.
Based upon our assessments described above we challenged management on the appropriateness of its sensitivity calculations by applying our own sensitivity analysis to the forecast cash flows long-term growth rates and discount rates to ascertain the extent to which reasonable adverse changes would either individually or in aggregate require an impairment of either the goodwill or indefinite life assets.
Reviewing the appropriateness of discount rate through the use of our valuations specialists; We determined whether impairment charge were required based on the results of our work has been made. Management has described the key sensitivities applied in the 'Goodwill and other intangible assets' note to the Financial Statements in note no. 5
Based on independent valuation report impairment loss of Rs 1400.02 lakhs has been provided during the current year.
Our audit procedures includes:
Valuation of Financial instruments
Valuation of financial instruments-Investments (held at fair value) Control testing:
The company has investment in unlisted equity shares Rs 1165.48 lakhs (PY '1999.49 lakhs) of APGPCL. The investment was made for specific purpose to meet certain criteria for power purchase. The said investment is measured at Fair Value through Other Comprehensive Income. • We tested the design and operating effectiveness of key Controls.
• Controls over the validation completeness implementation and usage of valuation models.
Independent reperformance:
We have considered the valuation of financial instruments as key audit matter considering complexities and financial impact involved over financial statements.
• Our own valuation specialists independently challenged management on the valuations where they were found outside our expected range.
Methodology choice:
• We evaluated the company management's sensitivity analysis around the key assumptions to ascertain the extent of change in those assumptions that would be required for the investment to be impaired. In the context of observed industry practice our own valuation specialists assisted us in challenging the appropriateness of significant models and methodologies used by an independent valuer in calculating fair values risk exposures completeness of risk factors and in calculating FVAs.

INFORMATION OTHER THAN THE FINANCIAL STATEMENTS AND AUDITOR'S REPORTTHEREON

The Company's Board of Directors is responsible for the preparation ofthe other information. The other information comprises the information included in theManagement Discussion and Analysis Board's Report including Annexures to Board's ReportCorporate

Governance and Shareholder's Information but does not include thefinancial statements and our auditor's report thereon.

Our opinion on the financial statements does not cover the otherinformation and we do not express any form of assurance conclusion thereon. In connectionwith our audit of the financial statements our responsibility is to read the otherinformation and in doing so consider whether the other information is materiallyinconsistent with the financial statements or our knowledge obtained during the course ofour audit or otherwise appears to be materially 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.

We have nothing to report in this regard.

RESPONSIBILITIES OF MANAGEMENT FOR THE STANDALONE FINANCIAL STATEMENTS

The Company's Board of Directors is responsible for the matters statedin Section 134(5) of the Companies Act 2013 with respect to the preparation of thesefinancial statements that give a true and fair view of the financial position financialperformance changes in equity and cash flows of the Company in accordance with theaccounting principles generally accepted in India including the Indian AccountingStandards (Ind AS) specified under Section 133 of the Act. This responsibility alsoincludes maintenance of adequate accounting records in accordance with the provisions ofthe Act for safeguarding of the assets of the Company and for preventing and detectingfrauds and other irregularities; selection and application of appropriate accountingpolicies; making judgements and estimates that are reasonable and prudent; and designimplementation and maintenance of adequate internal financial controls that wereoperating effectively for ensuring the accuracy and completeness of the accountingrecords relevant to the preparation and presentation of the financial statements thatgive a true and fair view and are free from material misstatement whether due to fraud orerror.

In preparing the financial statements the Board of Directors 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 the Board of Directors either intends to liquidate the Companyor to cease operations or has no realistic alternative but to do so. Those Board ofDirectors are also responsible for overseeing the Company's financial reporting process.

AUDITOR'S RESPONSIBILITIES FOR THE AUDIT OF THE STANDALONE 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. Reasonable assuranceis a high level of assurance but is not a guarantee that an audit conducted in accordancewith SAs will always detect a material misstatement when it exists. Misstatements canarise from fraud or error and are considered material if individually or in theaggregate they could reasonably be expected to influence the economic decisions of userstaken on the basis of these financial statements.

As part of an audit in accordance with SAs we exercise professionaljudgement 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 control relevant to theaudit in order to design audit procedures that are appropriate in the circumstances. UnderSection 143(3)(i) of the Companies Act 2013 we are also responsible for expressing ouropinion on whether the Company has adequate internal financial controls system in placeand the operating effectiveness of such controls.

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

• Conclude on the appropriateness of management's use of the goingconcern basis of accounting and based on the audit evidence obtained whether a materialuncertainty exists related to events or conditions that may cast significant doubt on theability of the Company to continue as a going concern. If we conclude that a materialuncertainty exists we are required to draw attention in our auditor's report to therelated disclosures in the financial statements or if such disclosures are inadequate tomodify our opinion. Our conclusions are based on the audit evidence obtained up to thedate of our auditor's report. However future events or conditions may cause the Companyto 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.

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.

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

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) planningthe scope of our audit work and in evaluating the results of our work; and (ii) toevaluate the effect of any identified misstatements in the standalone financialstatements.

OTHER MATTER

I) As stated in Note no. 55 of financial statements figures for theyear ended 31st March 2019 are restated audited figures after giving impact of the schemeapproved by the Hon'ble NCLT Kolkata Bench on 26th June 2019 and effective from 1st April2018 which has been approved by Board of Directors. The restated financial statements forthe year ended 31st March 2019 are to be adopted by the shareholders.

Our opinion on above matters are not modified.

REPORT ON OTHER LEGAL AND REGULATORY REQUIREMENTS

1. 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 Companies Act 2013 we give in the "Annexure A" astatement on the matters specified in paragraphs 3 and 4 of the Order.

2. As required by Section 143(3) of the Act we report that:

(a) We have sought and obtained all the information and explanationswhich to the best of our knowledge and belief were necessary for the purposes of ouraudit;

(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) The Balance Sheet the Statement of Profit and Loss (including theStatement of Other Comprehensive Income) Statement of Changes in Equity and the Cash FlowStatement dealt with by this Report are in agreement with the books of account;

(d) In our opinion the aforesaid standalone financial statementscomply with the Accounting Standards specified under Section 133 of the Act read withCompanies (Indian Accounting Standards) Rules 2015 as amended;

(e) On the basis of the written representations received from thedirectors as on March 31 2020 taken on record by the Board of Directors none of thedirectors is disqualified as on March 31 2020 from being appointed as a director in termsof Section 164 (2) of the Act;

(f) With respect to the adequacy of the internal financial controlsover financial reporting of the Company and the operating effectiveness of such controlsrefer to our separate Report in "Annexure B". Our report expresses an unmodifiedopinion on the adequacy and operating effectiveness of the Company's internal financialcontrols over financial reporting.

(g) With respect to the other matter to be included in the Auditors'report under Section 197(16) as amended:

In our opinion and according to the information and explanation givento us the managerial remuneration paid/provided during the current year by the Company isin accordance with the provisions of Section 197 of the Act.

<p >(h) With respect to the other matters to be included in the Auditor'sReport in accordance with Rule 11 of the Companies (Audit and Auditors) Rules 2014 asamended 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 no. 47 to the financialstatements;

ii) The Company has made provision as required under the applicablelaw or 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.

For LODHA & CO.
Chartered Accountants
Firm's Registration Number: 301051E
N.K.Lodha
Partner
Place: New Delhi Membership No. 85155
Date: 10th June 2020 UDIN: 20085155AAAACD9627

Annexure - A to the Auditors' Report

The Annexure referred to in Independent Auditors' Report to the membersof the HSIL Limited on the standalone financial statements for the year ended 31st March2020 we report that:

(i) (a) The Company has maintained proper records showing fullparticulars including quantitative details and situation of fixed assets.

(b) The Company has a regular programme of physical verification of itsfixed assets by which all fixed assets are verified in a phased manner over a period ofthree years. In our opinion this periodicity of physical verification is reasonablehaving regard to the size of the Company and the nature of its assets. As per theprogramme certain fixed assets were physically verified during the year and no materialdiscrepancies were noticed on such verification.

(c) According to the information and explanations given to us and onthe basis of our examination of the records of the Company the title deeds of immovableproperties are held in the name of the Company as at Balance Sheet date. (read with NoteNo. 4(6) of financial statements).

(ii) As per the information and explanation given to us theinventories of the Company (except stock lying with the third parties and goods intransit) have been physically verified by the management at reasonable intervals duringthe year. The discrepancies noticed on such physical verification of inventory as comparedto book records were not material.

(iii) According to the records and information and explanation madeavailable to us the Company has not granted any loans secured or unsecured to companiesfirms limited liability partnerships or other parties covered in the register maintainedunder section 189 of the Companies Act 2013 ('the Act') hence other parts of this clauseare not applicable.

(iv) 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 theAct with respect to the loans investments guarantees and security.

(v) The Company has not accepted any deposits from the public withinthe meaning of Section 73 to 76 of the Act and relevant rules hence we do not offer anycomment on the same. Further we have been informed that no order has been passed by theCompany Law Board or National Company Law Tribunal or Reserve Bank of India or any courtor any other tribunal in this regard.

(vi) The Central Government has not specified maintenance of costrecords under sub-section (1) of Section 148 of the Act in respect of Company's productsand services. Accordingly the provisions of clause 3(vi) of the Order are not applicable.

(vii) (a) According to the records of the company the company isgenerally regular in depositing undisputed statutory dues including provident fundemployees' state insurance income tax Goods and Service Tax custom duty cess andother material statutory dues with the appropriate authorities.

There were no undisputed statutory dues payable as at March 31 2020which were outstanding for a period of more than six months from the date they becomepayable.

b) According to the records and information &explanations given to us there are no dues in respect of income tax or sales tax orservice tax or entry tax or duty of custom or goods and services tax or duty of excise orCentral Sales Tax or value added tax that have not been deposited with the appropriateauthorities on account of any dispute except as given below:

Name of Statute Nature of Due Period Amount involved (' in Lakhs) Forum where matter is pending
The Central Excise Act 1944 Excise Duty 1987-89 27.81 Commissioner of Central Excise Rohtak
The Central Excise Act 1944 Cenvat Credit 2007-08 11.09 Customs Excise and Service Tax Appellate Tribunal Bangalore
The Central Excise Act 1944 Service Tax Input Credit 2006-07 3.08 Commissioner (Appeals)
The Central Excise Act 1944 Excise Duty 1999-2000 24.26 Customs Excise and Service Tax Appellate Tribunal Bangalore
The Central Excise Act 1944 Excise Duty 2010-11 9.71 Customs Excise and Service Tax Appellate Tribunal Bangalore
The Central Excise Act 1944 Excise Duty 2004-05 to 2005-06 14.98 Customs Excise and Service Tax Appellate Tribunal Bangalore
Finance Act 1994 Service Tax MAR 06 - SEP 06 1.60 Customs Excise and Service Tax Appellate Tribunal Bangalore
Finance Act 1994 Service Tax JUL 05 - MAR 06 0.01 Customs Excise and Service Tax Appellate Tribunal Bangalore
Finance Act 1994 Service Tax 2012-13 to 2014-15 130.39 Commissioner (Appeals) Jaipur
The Central Sales Tax Act Sales Tax 2016-17 21.48 Deputy Commissioner (State Tax) LTU Panjagutta Hyderabad
Telangana Tax on Entry of Goods into Local areas Act 2001 Entry Tax 2011-12 to 2016-17 1926.66 Telangana High Court Hyderabad
Telangana Tax on Entry of Goods into Local areas Act 2001 Entry Tax 2012-13 to 2016-17 1043.35 Telangana High Court Hyderabad
Telangana Tax on Entry of Goods into Local areas Act 2001 Entry Tax 2017-18 95.52 Telangana High Court Hyderabad
Entry Tax Act 2001 Entry Tax 2011-12 to 2016-17 52.59 The Appellate Dy. Comm. Rural Division Hyderabad
GST Act 2017 Good and Service Tax July-17 to Nov-17 107.66 Telangana High Court Hyderabad
Income Tax Act 1961 Income - Tax Assessment Year 2012-13 3.84 Commissioner Income Tax (Appeals) Hubli
AP VAT Act Value Added Tax 2011-12 & 12-13 3.75 Asst. Commissioner (CT) LTU Nalgonda Division Nalgonda.

(viii) The Company has not defaulted in repayment of loans orborrowings to any bank or financial institution or government during the year. The Companydid not have any outstanding debentures during the year.

(ix) The Company did not raise any money by way of initial public offeror further public offer (including debt instruments). On the basis of information andexplanation given to us term loans have been applied for the purposes for which they wereobtained.

(x) Based on the audit procedures performed and on the basis ofinformation and explanations given to us no fraud by the Company or on the Company by itsofficers or employees has been noticed or reported during the period covered by our audit.

(xi) On the basis of records and information and explanations madeavailable and based on our examinations of the records of the company the company haspaid / provided managerial remuneration in accordance with the requisite approvalsmandated under Section 197 read with Schedule V of the Act.

(xii) On the basis of information and explanation given to us theCompany is not a Nidhi Company. Accordingly reporting under clause 3 (xii) of the saidorder is not applicable.

(xiii) As per the information and explanations and records madeavailable by the management of the company and audit procedures performed for the relatedparty transactions entered during the year the company has complied with the provisionsof section 177 and 188 of the Act where applicable. As explained and as per the records /details the related party transactions have been disclosed in the standalone financialstatements as required by the applicable accounting standards. (Refer Note no.50)

(xiv) During the year the Company has not made any preferentialallotment or private placement of shares or fully or partly paid convertible debenturesand hence reporting under clause 3 (xiv) of the Order is not applicable to the Company.

(xv) According to the information and explanations given to us andbased on our examination of the records the Company has not entered into non-cashtransactions with directors or persons connected with them. Accordingly clause 3(xv) ofthe Order is not applicable.

(xvi) According to the information and explanation given to us theCompany is not required to be registered under section 45-IA of the Reserve Bank of IndiaAct 1934.

For LODHA & CO.
Chartered Accountants
Firm's Registration Number: 301051E
N.K.Lodha
Partner
Place: New Delhi Membership No. 85155
Date: 10th June 2020 UDIN: 20085155AAAACD9627

Annexure B to the Independent Auditor's Report

(Referred to in paragraph 2(f) under 'Report on Other Legal andRegulatory Requirements' section of our report of even date)

REPORT ON THE INTERNAL FINANCIAL CONTROLS OVER FINANCIAL REPORTINGUNDER CLAUSE (I) OF SUB-SECTION 3 OF SECTION 143 OF THE COMPANIES ACT 2013 (“THEACT”)

We have audited the internal financial controls over financialreporting of HSIL Limited ("the Company") as of March 31 2020 in conjunctionwith our audit of the financial statements of the Company for the year ended on that date.

MANAGEMENT'S RESPONSIBILITY FOR INTERNAL FINANCIAL CONTROLS

The Board of Directors of the Company is responsible for establishingand maintaining 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. Theseresponsibilities include the design implementation and maintenance of adequate internalfinancial controls that were operating effectively for ensuring the orderly and efficientconduct of its business including adherence to respective company's policies thesafeguarding of its assets the prevention and detection of frauds and errors theaccuracy and completeness of the accounting records and the timely preparation ofreliable financial information as required under the Companies Act 2013.

AUDITOR'S RESPONSIBILITY

Our responsibility is to express an opinion on the internal financialcontrols over financial reporting of the Company based on our audit. We conducted ouraudit in accordance with the Guidance Note on Audit of Internal Financial Controls OverFinancial Reporting (the "Guidance Note") issued by the Institute of CharteredAccountants of India and the Standards on Auditing prescribed under Section 143(10) of theCompanies Act 2013 to the extent applicable to an audit of internal financial controls.Those Standards and the Guidance Note require that we comply with ethical requirements andplan and perform the audit to obtain reasonable assurance about whether adequate internalfinancial controls over financial reporting was established and maintained and if suchcontrols operated effectively in all material respects. Our audit involves performingprocedures to obtain audit evidence about the adequacy of the internal financial controlssystem over financial reporting and their operating effectiveness. Our audit of internalfinancial controls over financial reporting included obtaining an understanding ofinternal financial controls over financial reporting assessing the risk that a materialweakness exists and testing and evaluating the design and operating effectiveness ofinternal control based on the assessed risk. The procedures selected depend on theauditor's judgement including the assessment of the risks of material misstatement of thefinancial 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 internal financial controlssystem over financial reporting of the Company.

MEANING OF INTERNAL FINANCIAL CONTROLS OVER FINANCIAL REPORTING

A company's internal financial control over financial reporting 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 control overfinancial reporting includes those policies and procedures that (1) pertain to themaintenance of records that in reasonable detail accurately and fairly reflect thetransactions and dispositions of the assets of the company; (2) provide reasonableassurance that transactions are recorded as necessary to permit preparation of financialstatements in accordance with generally accepted accounting principles and that receiptsand expenditures of the company are being made only in accordance with authorisations ofmanagement 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 FINANCIALREPORTING

Because of the inherent limitations of internal financial controls overfinancial reporting 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 overfinancial reporting to future periods are subject to the risk that the internal financialcontrol over financial reporting may become inadequate because of changes in conditionsor that the degree of compliance with the policies or procedures may deteriorate.

OPINION

In our opinion to the best of our information and according to theexplanations given to us the Company has in all material respects an adequate internalfinancial controls system over financial reporting and such internal financial controlsover financial reporting were operating effectively as at March 31 2020 based on theinternal control over financial reporting criteria established by the Company consideringthe essential components of internal control stated in the Guidance Note on Audit ofInternal Financial Controls Over Financial Reporting issued by the Institute of CharteredAccountants of India.

For LODHA & CO.
Chartered Accountants
Firm's Registration Number: 301051E
N.K.Lodha
Partner
Place: New Delhi Membership No. 85155
Date: 10th June 2020 UDIN: 20085155AAAACD9627

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