TO THE MEMBERS OF INDUSTRIAL INVESTMENT TRUST LIMITED
Report on the Audit of the Standalone Financial Statements
We have audited the accompanying Standalone Financial Statements of IndustrialInvestment Trust Limited ("the Company") which comprise the Balance Sheet as atMarch 31 2020 the Statement of Profit and Loss( including the Other ComprehensiveIncome) the Statement of Changes in Equity and the Statement of Cash Flow for the yearthen ended and notes to the Standalone Financial Statements including the summary ofsignificant accounting policies and other explanatory information (hereinafter referred toas "Standalone Financial Statements").
In our opinion and to the best of our information and according to the explanationsgiven to us the aforesaid Standalone Financial Statements give the information requiredby the Companies Act 2013 as amended (the "Act") in the manner so required andgive a true and fair view in conformity with the accounting principles generally acceptedin India of the state of affairs of the Company as at March 31 2020 its loss includingother comprehensive income/(loss) the Changes in Equity and its Cash Flows for the yearended on that date.
Basis for Opinion
We conducted our audit of the Standalone Financial Statements in accordance with theStandards on Auditing (SAs) as specified under section 143(10) of the Act. Ourresponsibilities under those Standards are further described in the Auditor'sResponsibilities for the Audit of the Standalone Financial Statements section of ourreport. We are independent of the Company in accordance with the Code of Ethics issued bythe Institute of Chartered Accountants of India ("the ICAI") together with theethical requirements that are relevant to our audit of the Standalone Financial Statementsunder the provisions of the Act and the Rules thereunder and we have fulfilled our otherethical responsibilities in accordance with these requirements and the Code of Ethics. Webelieve that the audit evidence we have obtained is sufficient and appropriate to providea basis for our opinion on the Standalone Financial Statements.
Emphasis of Matter
a) We draw attention to note 41 of the Standalone Financial Statements regardinginvestment in joint venture Future Generali India Life Insurance Company Limited("FGILICL"). The Management of the Company is of the view for the reasonsstated in the note that impairment of Rs. 1330.00 lakhs towards equity investment as atMarch 312020 is considered adequate and no further adjustment is required in its carryingamount of investment as at balance sheet date.
b) We draw attention to note 45(a) of the Standalone Financial Statements regardinginvestment in its subsidiary IITL Projects Limited. The financials statements of thesubsidiary have been prepared on a going concern basis although the subsidiary company isincurring continuous losses and the net worth of the subsidiary company is negative as onMarch 312020. In view of current status of the Real estate industry and in particularadverse cash flows of the Joint Ventures of the subsidiary their ability to continue asgoing concern is doubtful. Further considering that the subsidiary has also net Loss forthe year ended March 31 2020 and the current liabilities exceeded its total assetsindicate that a material uncertainty exists that may cast significant doubt its ability tocontinue as a Going Concern. The Management of the Company is of the view for the reasonsstated in the note that additional impairment provision of Rs. 273.00 lakhs towardsequity investment as at March 312020 is considered adequate and has fully provided forloss of Rs. 4002.27 lakhs on account of change in fair value of preference shares.
c) We draw attention to note 45(b) of the Standalone Financial Statements regardinginvestment in its subsidiary IIT Insurance Broking and Risk Management Private Limitedthe management of the Company is of the view for the reasons stated in the note thatimpairment of Rs. 112.00 lakhs towards equity investment as at March 312020 is consideredadequate based on audited net worth as at March 31 2020.
d) We draw attention to note 45(d) of the Standalone Financial Statements regardinginvestment in associate company World Resorts Limited ("WRL"). The associate hasincurred loss in the current year and the net worth of the associate has eroded. TheManagement of the Company is of the view for the reasons stated in the note has providedfor loss Rs. 1551.81 lakhs towards entire equity investment and Rs. 2412.57 lakhs towardpreference share investment on account of change in fair value as at March 31 2020.
e) We draw attention to note 46 of Standalone Financial Statements the Company hadreceived letter from the Reserve Bank of India (RBI) dated June 25 2018 vide saidletter the RBI has prohibited the Company not to expand its credit/ investment portfolioother than investment in Government Securities till net Non-Performing Assets("NPAs") are brought down to below 5%. The Board of the Company in its meetingheld on August 13 2018 discussed and deliberated on the issues raised by RBI and formedan action plan for the same.
f) We draw attention to note 54 to the Standalone Financial Statements which describesthe impact of Covid-19 pandemic on the Company's operations and results as assessed by themanagement.
Our opinion is not modified in this regard.
Key Audit Matters
Key audit matters are those matters that in our professional judgment were of mostsignificance in our audit of the Standalone Financial Statements for the financial yearended March 31 2020. These matters were addressed in the context of our audit of theStandalone Financial Statements as a whole and in forming our opinion thereon and we donot provide a separate opinion on these matters. For each matter below our description ofhow our audit addressed the matter is provided in that context.
We have determined the matters described below to be the key audit matters to becommunicated in our report. We have fulfilled the responsibilities described in theAuditors' responsibilities for the audit of the Standalone Financial Statements section ofour report including in relation to these matters. Accordingly our audit included theperformance of procedures designed to respond to our assessment of the risks of materialmisstatement of the Standalone Financial Statements. The results of our audit proceduresincluding the procedures performed to address the matters below provide the basis for ouraudit opinion on the accompanying Standalone Financial Statements.
|Key Audit Matter ||How Key Audit Matter was addressed in our Audit |
|Carrying Value of Investment ||Our audit procedures included and were not limited to the following: |
|(Refer Note 2.11 "Financial Instrument" and Note 7 and Note 47 of the Standalone Financial Statements) ||i. Reviewed the Accounting Policies used by the Company for accounting and disclosing Investments for compliance with the accounting framework. |
| ||ii. Evaluated the valuation methodology recommended by the valuation expert. |
|The investments portfolio is valued at Rs. 3843073.80 (in thousands) which represents almost 91.26% of the total assets of the Company as at March 31 2020. The Impairment review of unquoted investment is considered to be risk area due to the size of the balances as well as the judgmental nature of key assumptions which may be subject to management override. ||iii. Assessed the adequacy of internal controls evaluated the design and tested the operating effectiveness of such controls for initial recognition subsequent measurement and disclosure of investments as on the reporting date as per applicable regulations. |
| ||iv. Held discussions with management regarding appropriate implementation of policy on impairment. |
|Impairment assessment commences with management's evaluation on whether there is an indication of impairment loss. As part of such evaluation management considers financial information liquidity and solvency position of subsidiaries associates and joint venture. ||v. Obtained and read latest audited financial statements of subsidiaries and associates. Noted key financial attributes. |
|Management also considers other factors such as assessment of company's operations business performance and modifications if any by the auditors of such subsidiaries associates and joint venture. Based on such evaluation the Company has made impairment provisions against the above investments. ||vi. We evaluated the impairment assessment performed by management. |
|We focused on this area due to magnitude of the carrying value of investments in subsidiaries associates and joint venture which comprise 91.26 % of the total assets as at March 312020 and are subject to annual impairment assessment. || |
|Impact of new tax ordinance on income tax ||Our audit procedures included and were not limited to the following: |
|(Refer Note 2.18 "Taxation" and Note 9 and 10 of the Standalone Financial Statements) ||i. Assessed the evaluation and assumptions used by the management for the assessment of option under Section 115BAA of the Act. |
| || |
| ||ii. Evaluated opinion of tax expert. |
| ||iii. Evaluated the estimates / assumptions used by the management in determination of future taxable profit in respect of the unused tax credits recognized in the books. |
|The Taxation Laws (Amendment) Ordinance 2019 introduced Section 115BAA with effect from April 12020 which provided that a domestic company shall at its option pay tax at a lower rate of 22 percent subject to certain conditions including that the total income should be computed without claiming any deduction or exemption; ||iv. Evaluated whether the measurement and recognition of deferred tax assets and liabilities is in line with the applicable Indian Accounting Standards. |
|Further a clarification from the Central Board of Direct Taxes clarified that the tax credit of Minimum Alternate Tax paid by the Company exercising option under section 115BAA shall not be available consequent to exercising of such option. ||v. Reviewed the disclosure made by the Company in the financial statements in this regard. |
|As at March 31 2020 the Company has not exercised the option under Section 115BAA. || |
|The Company has unused tax credits (MAT credit) of Rs. 45.62 lakhs. || |
|Significant judgment and estimates are involved in assessing the recognition / recoverability of the unused tax credits as well as the tax rates to be applied for recognition of deferred tax assets and liabilities as at the balance sheet date. || |
|Accordingly the same is considered as a key audit matter. || |
Information Other than the Standalone Financial Statements and Auditor's Report thereon
The Company's Board of Director is responsible for the preparation of the otherinformation. The other information comprises of the information included in the AnnualReport but does not include the Standalone Financial Statements and our Auditors' Reportthereon.
Our opinion on the Standalone Financial Statements does not cover the other informationand we do not express any form of assurance conclusion thereon.
In connection with our audit of the Standalone Financial Statements our responsibilityis to read the other information and in doing so consider whether the other informationis materially inconsistent with the Standalone Financial Statements or our knowledgeobtained in the 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.
Responsibilities of Management for the Standalone Financial Statements
The Company's Board of Directors is responsible for the matters stated in Section134(5) of the Act with respect to the preparation of these Standalone Financial Statementsthat give a true and fair view of the financial position financial performance includingother comprehensive income/(loss) changes in equity and cash flows of the Company inaccordance with the accounting principles generally accepted in India including theIndian Accounting Standards (Ind AS) specified under section 133 of the Act read with theCompanies (Indian Accounting Standards) Rules 2015 as amended.
This responsibility also includes maintenance of adequate accounting records inaccordance with the provision of the Act for safeguarding the assets of the Company andfor preventing and detecting frauds and other irregularities; selection and application ofthe appropriate accounting policies; making judgements and estimates that are reasonableand prudent; 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 is responsible forassessing the Company's ability to continue as a going concern disclosing as applicablematters related to going concern and using the going concern basis of accounting unlessmanagement either intends to liquidate the Company or to cease operations or has norealistic alternative but to do so.
Those Board of Directors are also responsible for overseeing the Company's financialreporting process.
Auditor's Responsibilities for the Audit of the Standalone Financial Statements
Our objectives are to obtain reasonable assurance about whether the StandaloneFinancial 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 Standalone 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 material misstatement of the StandaloneFinancial 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 the audit in order todesign audit procedures that are appropriate in the circumstances. Under section 143(3)(i)of the Act we are also responsible for expressing our opinion on whether the company hasadequate internal financial controls system in place and the operating effectiveness ofsuch controls.
Evaluate the appropriateness of accounting policies used and the reasonablenessof accounting estimates and related disclosures made by 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 Standalone Financial Statements or if such disclosures are inadequate to modify ouropinion. Our conclusions are based on the audit evidence obtained up to the date of ourauditor's report. However future events or conditions may cause the Company to cease tocontinue as a going concern.
Evaluate the overall presentation structure and content of the StandaloneFinancial Statements including the disclosures and whether the Standalone FinancialStatements represent the underlying transactions and events in a manner that achieves fairpresentation.
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 Standalone Financial Statements may be influenced. Weconsider quantitative materiality and qualitative factors in (i) planning the scope of ouraudit work and in evaluating the results of our work; and (ii) to evaluate the effect ofany identified misstatements in the Standalone 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 also provide those charged with governance with a statement that we have compliedwith relevant ethical requirements regarding independence and to communicate with themall relationships and other matters that may reasonably be thought to bear on ourindependence and where applicable related safeguards.
From the matters communicated with those charged with governance we determine thosematters that were of most significance in the audit of Standalone Financial Statements forthe financial year ended March 31 2020 and are therefore the key audit matter. Wedescribe these matters in our auditor's report unless law or regulation precludes publicdisclosure about the matter or when in extremely rare circumstances we determine that amatter should not be communicated in our report because the adverse consequences of doingso would reasonably be expected to outweigh the public interest benefits of suchcommunication.
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 ofthe Act we give in the "Annexure A" a statement on the matters specified inparagraphs 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 explanations which to the bestof our knowledge and belief were necessary for the purposes of our audit;
b) In our opinion proper books of account as required by law have been kept by theCompany so far as appears from our examination of those books;
c) The Balance Sheet Statement of Profit and Loss including Other ComprehensiveIncome Statement of Changes in Equity and the Cash Flow Statement dealt with by thisreport are in agreement with the books of account;
d) In our opinion the aforesaid Standalone Financial Statements comply with the IndianAccounting Standards specified under section 133 of the Act read with Companies (IndianAccounting Standards) Rules 2015 as amended;
e) On the basis of written representations received from the directors as on March 312020 taken on record by the Board of Directors none of the directors is disqualified ason March 31 2020 from being appointed as a director in terms of section 164(2) of theAct;
f) With respect to the adequacy of the internal financial controls over financialreporting with reference to these Standalone Financial Statements of the Company and theoperating effectiveness of such controls refer to our separate Report in "AnnexureB" to this report;
g) In our opinion the managerial remuneration for the year ended March 31 2020 hasbeen paid/provided by the Company to its directors in accordance with the provisions ofsection 197 read with Schedule V to the Act;
h) With respect to the other matters to be included in the Auditor's Report inaccordance with Rules 11 of the Companies (Audit and Auditors) Rules 2014 as amended inour opinion and to the best of our information and according to the explanations given tous:
i) The Company has disclosed the impact of pending litigations on its financialposition in its Standalone Financial Statements as referred to in Note 31 to theStandalone Financial Statements;
ii) The Company did not have any long-term contracts including derivative contracts forwhich there were any material foreseeable losses.
iii) There has been no delay in transferring amounts required to be transferred tothe Investor Education and Protection Fund by the Company.
For Chaturvedi & Shah LLP
Firm Registration no. 101720W/W100355
Vitesh D. Gandhi
Membership No.: 110248
Place: Mumbai Date: July 24 2020
"Annexure A" to the Independent Auditors' Report of even date on theStandalone Financial Statements of Industrial Investment Trust Limited (Referred to inParagraph 1 under the heading of "Report on Other Legal and RegulatoryRequirements" of our report of even date)
i) a) The Company has maintained proper records showing full Particulars includingquantitative details and situation of fixed assets.
b) The Company has a regular programme for physical verification in a phased periodicmanner which in our opinion is reasonable having regards to the size of the Company andthe nature of its assets. No material discrepancies were noticed on such verification.
c) In our opinion and according to the information and explanations given to us titledeeds of immovable properties are held in the name of the company.
ii) As the Company had no Inventories during the year therefore provision of clause(ii) of paragraph of 3 of the order are not applicable to the Company and hence notcommented upon.
iii) The Company has granted loans secured or unsecured to companies firm or otherparties covered in the register maintained under Section 189 of the Act in respect ofwhich:
a) The terms and conditions of the grant of such loans are in our opinion primafacie not prejudicial to the Company's interest.
b) The schedule of repayment of principal and payment of interest has been stipulatedbut in some cases repayments of principal amounts and receipt of interest are not regular.
c) In respect of amount of ' 211294964 of principal amount of loan given to threeparties which is overdue for more than 90 days as explained to us the Management hastaken reasonable steps for recovery of the principal amount and interest.
iv) In our opinion and according to the information and explanations given to us thereare no loans investments guarantees and securities granted in respect of whichprovisions of section 185 and 186 of the Act are applicable and hence not commented upon.
v) According to the information and explanations given to us the Company has notaccepted any deposits within the meaning of provisions of sections 73 to 76 or any otherrelevant provisions of the Act and the rules framed thereunder. Therefore the provisionsof Clause (v) of paragraph 3 of the Order are not applicable to the Company.
vi) To the best of our knowledge and as explained the Central Government has notprescribed the maintenance of cost records under sub section (1) of Section 148 of theAct.
vii) a) The company is generally regular in depositing with appropriate authoritiesundisputed statutory dues including Provident Fund Employees' State InsuranceIncome-tax Sales-tax Goods and Service Tax Duty of Customs Duty of Excise Value AddedTax Cess and Other Statutory Dues applicable to it.
b) According to the information and explanations provided to us no undisputed amountpayable in respect of Provident Fund Employees' State Insurance Income-tax Sales-taxGoods and Service Tax Duty of Customs Duty of Excise Value Added Tax Cess and OtherStatutory Dues were outstanding at the year end for a period of more than six monthsfrom the date they became payable.
c) According to the information and explanation given to us there are no dues ofIncome-tax Sales-tax Goods and Service Tax Service Tax Duty of Customs Duty of Exciseand Value Added Tax which have not been deposited with the appropriate authority onaccount of a dispute.
viii) The company has not raised loans from Financial Institutions or Banks or by issueof debentures and therefore provisions of Clause
(viii) of paragraph 3 of the Order are not applicable to the Company and hence notcommented upon.
ix) The company has not raised money by way of Initial Public offer or Further Publicoffer or term Loan and therefore provisions of Clause
(ix) of paragraph 3 of the Order are not applicable to the Company and hence notcommented upon.
x) Based upon the audit procedures performed for the purpose of reporting the true andfair view of the Standalone Financial Statements and according to the information andexplanations provided by the management we report that no fraud by the Company or nomaterial fraud on the Company by the officers and employees of the Company has beennoticed or reported during the year.
xi) According to the information and explanations provided by the managementmanagerial remuneration has been paid/provided in accordance with the requisite approvalsmandated by the provisions of section 197 read with Schedule V to the Act.
xii) In our opinion the Company is not a nidhi company. Therefore provisions ofclause (xii) of Paragraph 3 of the Order are not applicable to the Company and hence notcommented upon.
xiii) According to the information and explanations provided by the managementtransactions with the related parties are in compliance with Sections 177 and 188 of theAct where applicable and the details have been disclosed in the Standalone FinancialStatements as required by the applicable accounting standards.
xiv) According to the information and explanations provided to us and on an overallexamination of the balance sheet the Company has not made any preferential allotment orprivate placement of shares or fully or partly convertible debentures during the yearunder review and hence reporting requirements under clause 3(xiv) of the Order are notapplicable to the Company and not commented upon.
xv) According to the information and explanations provided by the management theCompany has not entered into any non-cash transaction with directors or persons connectedwith him as referred to in Section 192 of Act.
xvi) To the best of our knowledge and as explained the company is required to beregistered under section 45-IA of the Reserve Bank of India Act 1934 and it has obtainedthe registration.
| ||For Chaturvedi & Shah LLP |
| ||Chartered Accountants |
| ||Firm Registration no. 101720W/W100355 |
| ||Vitesh D. Gandhi |
| ||Partner |
| ||Membership No.:110248 |
| ||UDIN: 20110248AAAAAY6306 |
|Place: Mumbai || |
|Date: July 24 2020 || |
"Annexure B" to Independent Auditors' Report on the Standalone FinancialStatements of Industrial Investment Trust Limited
(Referred to in paragraph 2(f) under the heading "Report on Other Legal andRegulatory Requirements" of our report of even date.
Report on the Internal Financial Controls under Clause (i) of Subsection 3 of Section143 of the Companies Act 2013 ("the Act")
We have audited the Internal Financial Control over financial reporting of IndustrialInvestment Trust Limited ("the Company") as of March 312020 in conjunction withour audit of the Standalone Financial Statements of the Company for the year then endedMarch 312020.
Management Responsibility for the 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 Reporting("Guidance Note") issued by the Institute of Chartered Accountants of India.These responsibilities include the design implementation and maintenance of adequateinternal financial controls that were operating effectively for ensuring the orderly andefficient conduct of its business including adherence to 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 Act.
Our responsibility is to express an opinion on the Company's internal financialcontrols over financial reporting with reference to these Standalone Financial Statementbased on our audit. We conducted our audit in accordance with the Guidance Note and theStandards on Auditing as specified under Section 143(10) of the Act to the extentapplicable to an audit of internal financial control both issued by the Institute ofChartered Accountants of India. Those Standards and the Guidance Note require that wecomply with ethical requirements and plan and perform the audit to obtain reasonableassurance about whether adequate internal financial controls over financial reporting withreference to Standalone Financial Statements was established and maintained and if suchcontrols operated effectively in all material respects.
Our audit involves performing procedures to obtain audit evidence about the adequacy ofthe internal financial controls system over financial reporting with reference to theseStandalone Financial Statements and their operating effectiveness. Our audit of internalfinancial controls over financial reporting included obtaining an understanding ofinternal financial controls over financial reporting with reference to these StandaloneFinancial Statements assessing the risk that a material weakness exists and testing andevaluating the design and operating effectiveness of internal control based on theassessed risk. The procedures selected depend on the auditor's judgement including theassessment of the risks of material misstatement of the Standalone Financial Statementswhether 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 internal financial controls system overfinancial reporting with reference to Standalone Financial statements.
Meaning of Internal Financial Controls over Financial Reporting with reference to theseStandalone Financial Statements
A company's internal financial control over financial reporting with reference to theseStandalone Financial Statements is a process designed to provide reasonable assuranceregarding the reliability of financial reporting and the preparation of StandaloneFinancial Statements for external purposes in accordance with generally acceptedaccounting principles. A company's internal financial control over financial reportingwith reference to these Standalone Financial Statements includes those policies andprocedures 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 as necessary topermit preparation of Standalone Financial Statements in accordance with generallyaccepted accounting principles and that receipts and expenditures of the company arebeing made only in accordance with authorizations of management and directors of theCompany; and (3) provide reasonable assurance regarding prevention or timely detection ofunauthorized acquisition use or disposition of the company's assets that could have amaterial effect on the Standalone Financial Statements.
Inherent Limitations of Internal Financial Controls over Financial Reporting withreference to these Standalone Financial Statements
Because of the inherent limitations of internal financial controls over financialreporting with reference to these Standalone Financial Statements including thepossibility of collusion or improper management override of controls materialmisstatements due to error or fraud may occur and not be detected. Also projections ofany evaluation of the internal financial controls over financial reporting with referenceto these Standalone Financial Statements to future periods are subject to the risk thatthe internal financial control over financial reporting with reference to these StandaloneFinancial Statements may become inadequate because of changes in conditions or that thedegree of compliance with the policies or procedures may deteriorate.
In our opinion the Company has in all material respects an adequate internalfinancial controls system over financial reporting with reference to these StandaloneFinancial Statements and such internal financial controls over financial reporting withreference to these Standalone Financial Statements were operating effectively as at March31 2020 based on the internal control over financial reporting criteria established bythe Company considering the essential components of internal control stated in theGuidance Note on Audit of Internal Financial Controls Over Financial Reporting issued bythe Institute of Chartered Accountants of India.
| ||For Chaturvedi & Shah LLP |
| ||Chartered Accountants |
| ||Firm Registration no. 101720W/W100355 |
| ||Vitesh D. Gandhi |
| ||Partner |
| ||Membership No.:110248 |
| ||UDIN: 20110248AAAAAY6306 |
|Place: Mumbai || |
|Date: July 24 2020 || |