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Impex Ferro Tech Ltd.

BSE: 532614 Sector: Metals & Mining
NSE: IMPEXFERRO ISIN Code: INE691G01015
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Impex Ferro Tech Ltd. (IMPEXFERRO) - Auditors Report

Company auditors report

To

THE MEMBERS OF IMPEX FERRO TECH LIMITED

Report on the Financial Statements Qualified Opinion

We have audited the accompanying Financial Statements of IMPEX FERRO TECH LIMITED("the Company") which comprise the Balance Sheet as at March 31 2019 theStatement of Profit and Loss (including Other Comprehensive Income) the Statement ofChanges in Equity and the Statement of Cash Flows for the year ended on that date and asummary of the significant accounting policies and other explanatory information(hereinafter referred to as "the Financial Statements").

In our opinion and to the best of our information and according to the explanationsgiven to us except for the possible effect of the matter described in the basis forqualified opinion section of our report the aforesaid 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 principlesaccepted in India of the state of affairs of the Company as at 31st March 2019 the lossand total comprehensive loss changes in equity and its cash flows for the year ended onthat date. Basis for Qualified Opinion

We draw your attention to Note No. 12(iii) of the accompanying Financial Statementsregarding non provision of interest expense on the borrowings of the Company amounting toRs 3685.53 lakhs for the year ended 31st March 2019 (Cumulative Non Provisioning of Rs10125.11 lakhs till 31.03.2019) and penal interest and charges thereof (amount remainingunascertained) which is not in accordance with the requirements of Ind AS 23: BorrowingCosts read with Ind AS 109: Financial Instruments. Had the aforesaid interest expense beenrecognized the finance cost for the year ended 31st March 2019 would have been Rs3804.23 lakhs instead of reported amount of Rs 118.70 lakhs. The total expenses for theyear ended 31st March 2019 would have been Rs 15370.01 lakhs instead of Rs 11684.48lakhs. The Net Loss after tax for the year ended 31st March 2019 would have been Rs5360.16 lakhs instead of reported amount of Rs 1674.63 lakhs. Total comprehensive Lossfor the year ended 31st March 2019 would have been Rs 5318.13 lakhs instead of reportedamount of Rs 1632.60 lakhs. Other equity as on 31st March 2019 would have been Rs38301.19 Lakhs instead of reported amount of Rs 28176.08 Lakhs and Other CurrentFinancial Liability as on 31st March 2019 would have been Rs 18466.15 Lakhs instead ofreported amount of Rs 8341.04 Lakhs.

We conducted our audit of the Financial Statements in accordance with the Standards onAuditing (SAs) specified under section 143(10) of the Companies Act 2013. Ourresponsibilities under those Standards are further described in the Auditor'sResponsibilities for the Audit of the Financial Statements section of our report. We areindependent of the Company in accordance with the Code of Ethics issued by the Instituteof Chartered Accountants of India together with the ethical requirements that are relevantto our audit of the financial statements under the provisions of the Companies Act 2013and the Rules there under and we have fulfilled our other ethical responsibilities inaccordance with these requirements. We believe that the audit evidence we have obtained issufficient and appropriate to provide a basis for our qualified opinion.

Material Uncertainty Relating To Going Concern

We draw your attention to Note No. 34 of the financial statements regarding preparationof the financial statements on going concern basis for the reason mentioned therein. Thecompany has accumulated losses during year ended 31.03.2019. As on date the company'scurrent liabilities are substantially higher than its current assets and net worth hasalso been fully eroded. These conditions indicate the existence of a material uncertaintythat may cast significant doubt on the company's ability to continue as going concern. Theappropriateness of assumption of going concern is critically dependent upon the debtresolution of the company which is under process the company's ability to raise requisitefinance generation of cash flows in future to meet its obligation and to earn profit infuture.

Key audit matters

Key audit matters are those matters that in our professional judgment were of mostsignificance in our audit of the financial statements of the current period. These matterswere addressed in the context of our audit of the financial statements as a whole and informing our opinion thereon and we do not provide a separate opinion on these matters. Wehave determined the matters described below to be the key audit matters to be communicatedin our report.

Key Audit Matter How our audit addressed the key Audit Matter
1 Accuracy of recognition measurement presentation and disclosures of revenues and other related balances in view of adoption of Ind AS 115 "Revenue from Contracts with Customers" (new revenue accounting (standard) w.e.f 01.04..2018 Our audit procedures included the following:
The application of the new revenue accounting standard involves certain key judgements relating to identification of distinct performance obligations determination of transaction price of the identified performance obligations the appropriateness of the basis used to measure revenue recognized over a period. We have assessed the Company's process to identify the impact of adoption of the new revenue accounting standard. Our audit approach consisted testing of the design and operating effectiveness of the internal controls and substantive testing as follows :
Additionally new revenue accounting standard contains disclosures which involves collation of information in • Evaluated the design of internal controls relating to recording of efforts incurred and estimation of efforts required to complete the performance obligations.
respect of disaggregated revenue and periods over which the remaining performance obligations will be satisfied subsequent to the balance sheet date. • Selected a sample of contracts and through inspection of evidence of performance of these controls tested the operating effectiveness of the internal controls relating to efforts incurred and estimated.
Claim and exposure relating to taxation and litigation Our audit procedures included the following:
The Company has material uncertain tax positions including matters in respect of disputed claims /levies under various taxes and legal matters. Our audit procedures include the following substantive procedures:
• Obtained understanding of key uncertain tax positions;
The taxes and litigation exposures have been identified as key audit matter due to: • We have reviewed and analysed key correspondences relating to dispute;
i. Litigation cases require significant judgement due to complexity of the case and involvement of various authorities. • We have discussed the matter for key uncertain tax positions with appropriate senior management;
ii. These involve significant management judgment to determine the possible outcome of the uncertain tax positions. • We have evaluated management's underlying key assumptions in estimating the tax provisions; and Assessed management's estimate of the possible outcome of the disputed cases;

Emphasis of Matter

(i) As referred to Note No. 28 of the Financial Statements no provision has been madein the books in respect of the fire occurred in the Captive Power Plant. The reportedfinancials might have consequential impact which remains unascertained and unprovided for.

(ii) As referred in Note No. 29 of the Financial Statements the balance of SundryDebtors Advances Creditors etc. includes balances remaining outstanding for asubstantial period. The balances are subject to confirmations and reconciliation. Thereported Financials might have consequential impact which remains unascertained.

Our report is not modified in these matters.

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

The Company's Board of Directors is responsible for other information. The otherinformation comprises the information included in the Company's Annual Return but does notinclude the Financial Statements and our Auditor's report thereon.

Our opinion on the Financial Statements does not cover the other information and we donot express any form of assurance conclusion thereon.

In connection with our audit of the Financial Statements our responsibility is to readthe other information and in doing so consider whether the other information ismaterially inconsistent with the Financial Statements or our knowledge obtained during thecourse of our audit or otherwise appears to be materially misstated.

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

Responsibility of the Management for the Financial Statements

The Company's Board of Directors is responsible for the matters stated in section134(5) of the Companies Act 2013 with respect to the preparation of these financialstatements that give a true and fair view of the financial position and financialperformance and cash flow of the Company in accordance with the accounting principlesgenerally accepted in India including the accounting Standards specified under section133 of the Act. This responsibility also includes maintenance of adequate accountingrecords in accordance with the provisions of the Act for safeguarding of the assets of theCompany and for preventing and detecting frauds and other irregularities; selection andapplication of appropriate implementation and maintenance of 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 statement that give a true and fair view andare free from material misstatement whether due to fraud or error.

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.

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

Auditor's Responsibilities for the Audit of the Financial Statements

Our objectives are to obtain reasonable assurance about whether the financialstatements as a whole are free from material misstatement whether due to fraud or errorand to issue an 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 with SAswill always detect a material misstatement when it exists. Misstatements can arise fromfraud or error and are considered material if individually or in the aggregate theycould reasonably be expected to influence the economic decisions of users taken on thebasis of these financial statements.

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

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

• Obtain an understanding of internal financial controls relevant to the audit inorder to design audit procedures that are appropriate in the circumstances. Under section143(3)(i) of the Companies Act 2013 we are also responsible for expressing our opinionon whether the company has adequate internal financial controls system in place and theoperating effectiveness of such controls.

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

• Conclude on the appropriateness of management's use of the going concern basisof accounting 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.

• Evaluate the overall presentation structure and content of the FinancialStatements including the disclosures and whether the financial statements represent theunderlying transactions and events in a manner that achieves fair presentation.

Materiality is the magnitude of misstatements in the standalone financial statementsthat individually or in aggregate makes it probable that the economic decisions of areasonably knowledgeable user of the financial statements may be influenced. We considerquantitative materiality and qualitative factors in (i) planning the scope of our auditwork and in evaluating the results of our work; and (ii) to evaluate the effect of anyidentified misstatements in the financial statements.

We communicate with those charged with governance regarding among other matters theplanned scope and timing of the audit and significant audit findings including anysignificant deficiencies in internal control that we identify during our audit. We alsoprovide those charged with governance with a statement that we have complied with relevantethical requirements regarding independence and to communicate with them allrelationships and other matters that may reasonably be thought to bear on ourindependence and where applicable related safeguards.

From the matters communicated with those charged with governance we determine thosematters that were of most significance in the audit of the financial statements of thecurrent period and are therefore the key audit matters. We describe these matters in ourauditor's report unless law or regulation precludes public disclosure about the matter orwhen in extremely rare circumstances we determine that a matter should not becommunicated in our report because the adverse consequences of doing so would reasonablybe expected to outweigh the public interest benefits of such communication.

Report on Other Legal and Regulatory Requirements

I. As required by the Companies (Auditor's Report) Order 2016 ("the Order")issued by the Central Government Of India in terms of sub-section(ll) of Section 143 ofthe Companies Act 2013 we give in the Annexure A a Statement on the matters specifiedin paragraphs 3 and 4 of the Order to the extent applicable.

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

a) Except for the possible effect of the matter described in the basis for qualifiedopinion section of our report we have sought and obtained all the information andexplanations which to the best of our knowledge and belief were necessary for the purposesof our audit.

b) Except for the possible effect of the matter described in the basis for qualifiedopinion section of our report in our opinion proper books of account as required by lawhave been 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 other comprehensiveincome the cash flow statement and the statement of changes in equity dealt with by thisReport are in agreement with the books of accounts.

d) Except for the possible effect of the matter described in the basis for qualifiedopinion section of our report in our opinion the aforesaid financial statements complywith the Accounting Standards specified under Section 133 of the Act read with Rule 7 ofthe Companies (Accounts) Rules 2014.

e) The matter described in the basis for qualified opinion section of our report mayhave adverse effect on the functioning of the company.

f) On the basis of the written representations received from the directors as on 31stMarch 2019 taken on record by the Board of Directors none of the directors isdisqualified as on 31st March 2019 from being appointed as a director in terms of Section164 (2) of the Act.

g) With respect to the adequacy of the internal financial controls over financialreporting of the Company and the operating effectiveness of such controls refer to ourseparate Report in "Annexure B".

h) With respect to the other matters to be included in the Auditor's Report inaccordance with the requirements of section 197(16) of the Act as amended :

In our opinion and to the best of our information and according to the explanationsgiven to us the remuneration paid by the

Company to its directors during the year is in accordance with the provisions ofsection 197 of the Act.

i) With respect to the other matters to be included in the Auditor's Report inaccordance with Rule 11 of the Companies

(Audit and Auditors) Rules 2014 in our opinion and to the best of our information andaccording to the explanations given to us:

a) The Company has disclosed the impact of pending litigations on the financialposition in the Financial Statements. Refer Note 27 to its financial statements.

b) The Company did not have any long term contracts including derivative contracts forwhich there were any material foreseeable losses;

c) There were no amounts which were required to be transferred by the company to theInvestor Education and Protection Fund.

For R. Kothari & Company
Chartered Accountants
Firm Reg. No.:-307069E
CA. Manoj Kumar Sethia
Place: Kolkata Partner
Date: 27th May 2019 Membership No.:- 064308

"Annexure A" to Independent Auditors' Report

The Annexure A referred to in paragraph I under the heading 'Report on Other Legal& Regulatory Requirements' of our report of even date to the financial statements ofthe Company for the year ended 31st March 2019 we report that:

(i) (a) The Company is maintaining proper records showing full particulars includingquantitative details and situation of property plant and equipment.

(b) The Property plant and equipment of the Company have been physically verified bythe management during the year and no material discrepancies were noticed on suchverification. In our opinion the periodicity of physical verification is reasonablehaving regard to the size of the company and nature of its assets.

(c) According to the information and explanations given to us and on the basis of ourexamination of the records of the Company the title deeds of immovable properties areheld in the name of the Company.

(ii) The inventory has been physically verified by the management during the year atreasonable intervals. In our opinion the frequency of such verification is reasonable. Thediscrepancies noticed on verification between the physical stocks and the book recordswere not material having regard to the size of the operation of the Company and the samehave been properly dealt with in the books of account.

(iii) The company has not granted any loans secured or unsecured to companies firmsor other parties covered in the register maintained under section 189 of the Companies Act2013. Therefore the reporting under Paragraph 3(iii) is not applicable to the company.

(iv) In our opinion and according to the information and explanation given to us theCompany has complied with the provisions of section 185 and 186 of the Companies Act 2013in respect of grant of loans making investments and providing guarantees and securitiesas applicable.

(v) The Company has not accepted any deposits from the public and consequently thedirectives issued by Reserve Bank of India and provisions of Section 73 to Section 76 orany other relevant provisions of the Companies Act 2013 and the Companies (Acceptance ofDeposit) Rules 2015 with regard to the deposits accepted from the public are notapplicable to the company.

(vi) We have broadly reviewed the books of account maintained by the Company in respectof manufacture of Iron & steel product & Power Generation unit pursuant to theRules made by the Central Government for the maintenance of cost records under Section148(1) of the Companies Act 2013 and we are of the opinion that prima facie the recordshave been maintained. We have however not made a detailed examination of the records witha view to determining whether they are accurate and complete.

(vii) (a) According to the information and explanation given to us and on the basis ofour examination of the books of account the Company has generally delayed in depositingundisputed statutory dues including Provident Fund Income tax sales tax Service TaxDuty of customs value added tax GST cess and other statutory dues during the year withappropriate authorities.

According to the information and explanation given to us no undisputed amounts payablein respect of the above were in arrears as at 31st March 2019 for a period of more thansix months from the date on when they become payable except the following :

Sl. No. Nature of Dues Amount (Rs in lakhs)
1 Service Tax 148.39
2 P.F.Payable 4.67
3 IGST Payable 1.71
4 CGST Payable 4.38
5 SGST Payable 38.52
Total 197.67

(b) According to the information and explanations given to us and records of thecompany examined there were no dues in respect of provident fund employees stateinsurance income taxes sales taxes/ value added taxes service taxes duty of customsexcise duties GST cess etc. which have not been deposited with the appropriateauthorities on account of any dispute except the followings:

Name of the Statute

Nature of Dues

Financial Year

Amount (Rs in lakhs)

Forum where dispute is pending
Central Exise Act 1994

Excise Duty

2005-06

12.36

Commissioner of Central Excise (Appeals) (III)
2007-08

15.55

Cestat Kolkata Branch

2013-14

6.05 Excise Asansol Division

2013-14

7.96 Excise Asansol Division
Sub- Total (a) 41.92
Central Sales

2005-06

304.13 Sr.Joint Commissioner of Commercial Taxes
Tax and Local

2006-07

479.91 Sr.Joint Commissioner of Commercial Taxes
Sales Tax

2008-09

748.45 Sr.Joint Commissioner of Commercial Taxes
Vat & Cst

2009-10

211.16 Sr.Joint Commissioner of Commercial Taxes

2014-15

83.64 Sr.Joint Commissioner of Commercial Taxes

2015-16

38.41 Sr.Joint Commissioner of Commercial Taxes
Sub- Total (b) 1865.7
W. B. Entry Tax Act Entry Tax

2012-13 & 2013-14

504.91 Hon'ble high court of Calcutta
Sub- Total (c) 504.91
Income Tax Act

2009-10

4306.41 Commissioner of Income Tax (Appeals)Kolkata
1961 Income Tax

2011-12

1606.46 Commissioner of Income Tax (Appeals)Kolkata

2014-15

3134.64 Commissioner of Income Tax (Appeals)Kolkata
Sub- Total (d) 9047.51
Total(a+b+c+d) 11460.04

(viii) Based upon the audit procedures performed and according to the records of theCompany examined by us and the information and explanation given to us the Company hasdefaulted in payment of interest and repayment of principal on borrowings to banks asfollows:

Amount of default of Principal portion as on the Balance Sheet Date

(Rs Lacs)
Name of Bank Funded Interest Term Loan Restructured Term Loan Working Capital Term Loan Total Period of Default
State Bank of India 626.93 300.39 2251.60 3178.92 February 2016 to March 2019
Bank of Baroda 153.40 48.45 594.10 795.95 February 2016 to March 2019
Punjab National Bank 121.23 100.32 360.43 581.98 January 2016 to March 2019
United Bank of India 180.05 - 799.50 979.55 April 2016 to March 2019
Grand Total 1081.61 449.16 4005.63 5536.40

Amount of default of Interest portion as on the Balance Sheet Date :

Name of Bank Funded Interest Term Loan Restructured Term Loan Working Capital Term Loan Total Period of Default
State Bank of India 643.08 607.89 2565.99 3816.96 February 2016 to March 2019
Bank of Baroda 98.74 106.16 720.32 925.22 February 2016 to March 2019
Punjab National Bank 99.13 226.84 450.94 776.91 January 2016 to March 2019
United Bank of India 220.68 - 866.71 1087.39 April 2016 to March 2019
Grand Total 1061.63 940.89 4603.96 6606.48

Since the SBT has been merged with SBI SBT's Bank interest default has been mergedwith SBI.

Amount of Default of Interest portion of Cash Credit Accounts as on Balance Sheet Date:

Particulars Funded Interest Term Loan Period of Default
State Bank of India 2320.76 February 2016 to March 2019
Bank of Baroda 614.78 February 2016 to March 2019
Punjab National Bank 427.89 January 2016 to March 2019
United Bank of India 356.39 April 2016 to March 2019
Total 3719.82

The unprovided interest liability amounting to Rs 10125.11 lakhs as referred in NoteNo. 12(iii) of the Financial Statements continued to be a default. The company does nothave any loans or borrowings from the government and has not issued any Debentures.

(ix) Based upon the audit procedures performed and the information and explanationsgiven by the management the company has not raised moneys by way of initial public issue/follow-on offer (including debt instruments) and term loans.

(x) Based upon the audit procedures performed and the information and explanationsgiven by the management we report that no fraud by the Company or on the company by itsofficers or employees has been noticed or reported during the year.

(xi) Based upon the audit procedures performed and the information and explanationsgiven by the management the managerial remuneration has been paid or provided inaccordance with the requisite approvals mandated by the provisions of section 197 readwith Schedule V to the Companies Act 2013.

(xii) In our opinion and according to the information and explanations given to us theCompany is not a Nidhi Company. Therefore the reporting under Paragraph 3 (xii) of theOrder is not applicable to the Company.

(xiii) In our opinion and according to the information and explanations given to usall transactions with the related parties are in compliance with Section 177 and 188 ofCompanies Act 2013 where applicable and the details have been disclosed in the FinancialStatements as required by the applicable Accounting Standards.

(xiv) According to the information and explanation given to us and based on ourexamination of the records of the company the company has not made any preferentialallotment or private placement of shares of fully or partly convertible debentures andhence reporting under paragraph 3(xiv) of the Order is not applicable to the Company.

(xv) Based upon the audit procedures performed and the information and explanationsgiven by the management the company has not entered into any non-cash transactions withdirectors or persons connected with them. Accordingly the reporting under Paragraph 3(xv) of the Order is not applicable to the Company and hence not commented upon.

(xvi) In our opinion the company is not required to be registered under section 45 IAof the Reserve Bank of India Act 1934.

For R. Kothari & Company
Chartered Accountants
Firm Reg. No.:-307069E
CA. Manoj Kumar Sethia
Place: Kolkata Partner
Date: 27th May 2019 Membership No.:- 064308

"Annexure B" to Independent Auditors' Report

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

We have audited the internal financial controls over financial reporting of IMPEX FERROTECH LIMITED ("the Company") as of 31st March 2019 in conjunction with ouraudit of the financial statements of the Company for the year ended on that date.Management's Responsibility for Internal Financial Controls

The Company's management is responsible for establishing and maintaining internalfinancial controls based on the internal control over financial reporting criteriaestablished by the Company considering the essential components of internal control statedin the Guidance Note on Audit of Internal Financial Controls over Financial Reportingissued by the Institute of Chartered Accountants of India ('ICAI'). These responsibilitiesinclude the design implementation and maintenance of adequate internal financial controlsthat were operating effectively for ensuring the orderly and efficient conduct of itsbusiness including adherence to 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 Companies Act 2013.

Auditors' Responsibility

Our responsibility is to express an opinion on the Company's internal financialcontrols over financial reporting based on our audit. We conducted our audit in accordancewith the Guidance Note on Audit of internal Financial Controls over Financial Reporting(the "Guidance Note") issued by the Institute of Chartered Accountants of Indiaand the Standards on Auditing issued by ICAI and prescribed under section 143(10) of theCompanies Act 2013 to the extent applicable to an audit of internal financial controlsboth applicable to an audit of Internal Financial Controls and both issued by theInstitute of Chartered Accountants of India. Those Standards and the Guidance Note requirethat we comply with ethical requirements and plan and perform the audit to obtainreasonable assurance about whether adequate internal financial controls over financialreporting was established and maintained and if such controls operated effectively in allmaterial respects.

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

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

Meaning of Internal Financial Controls over Financial Reporting

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

Inherent Limitations of Internal Financial Controls Over Financial Reporting

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

Opinion

In our opinion 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 31 March 2019 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 R. Kothari & Company
Chartered Accountants
Firm Reg. No.:-307069E
CA. Manoj Kumar Sethia
Place: Kolkata Partner
Date: 27th May 2019 Membership No.:- 064308