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J K Cements Ltd.

BSE: 532644 Sector: Industrials
NSE: JKCEMENT ISIN Code: INE823G01014
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OPEN 2670.00
PREVIOUS CLOSE 2674.25
VOLUME 3975
52-Week high 3445.50
52-Week low 2005.00
P/E 32.62
Mkt Cap.(Rs cr) 20,709
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00
OPEN 2670.00
CLOSE 2674.25
VOLUME 3975
52-Week high 3445.50
52-Week low 2005.00
P/E 32.62
Mkt Cap.(Rs cr) 20,709
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

J K Cements Ltd. (JKCEMENT) - Auditors Report

Company auditors report

To the Members of J. K. Cement Limited

Report on the Audit of the Standalone Ind AS Financial Statements

Opinion

We have audited the accompanying standalone Ind AS financial statements of J. K. CementLimited ("the Company") which comprise the Balance sheet as at March 31 2022the Statement of Profit and Loss including the statement of Other Comprehensive

Income the Cash Flow Statement and the Statement of

Changes in Equity for the year then ended and notes to the standalone Ind AS financialstatements including a summary of significant accounting policies and other explanatoryinformation.

In our opinion and to the best of our information and according to the explanationsgiven to us the aforesaid standalone Ind AS financial statements give the informationrequired by the Companies Act 2013 as amended ("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 March 31 2022its profit including other comprehensive income its cash flows and the changes in equityfor the year ended on that date.

Basis for Opinion

We conducted our audit of the standalone Ind AS financial statements in accordance withthe Standards 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 Ind AS Financial Statements' section ofour report. We are independent of the Company in accordance with the ‘Code of Ethics'issued by the Institute of Chartered Accountants of

India together with the ethical requirements that are relevant to our audit of thefinancial statements under the provisions of the Act and the Rules thereunder and we havefulfilled our other ethical responsibilities in accordance with these requirements and theCode of Ethics. We believe that the audit evidence we have obtained is sufficient andappropriate to provide a basis for our audit opinion on the standalone Ind AS financialstatements.

Emphasis of Matter on CCI Case

We draw attention to Note 36A to the standalone Ind AS financial statements wherein ithas been stated that the Competition Commission of India (RsCCI') has imposed penalty ofRs 12854 lacs (‘first matter') and Rs 928 lacs (‘second matter') in twoseparate orders dated August 31 2016 and January 19 2017 respectively for allegedcontravention of provisions of Competition Act 2002 by the Company. The Company has filedappeals against the above orders.

The National Company Law Appellate Tribunal (‘NCLAT') on hearing the appeal inthe first matter upheld the decision of CCI for levying the penalty vide its order datedJuly 25 2018. Post order of the NCLAT CCI issued a revised demand notice dated August 72018 of Rs15492 lacs consisting of penalty of Rs12854 lacs and interest of Rs 2638lacs. The Company has filed appeal with Hon'ble Supreme Court against the above order.Hon'ble Supreme Court has stayed the NCLAT order. While the appeal of the Company ispending for hearing the Company backed by a legal opinion believes that it has a goodcase and accordingly no provision has been considered in the books of accounts. In thesecond matter demand had been stayed and the matter is pending for the hearing beforeNCLAT. While the appeal of the Company is pending for hearing the Company backed by alegal opinion believes that it has a good case and accordingly no provision has beenconsidered in the books of accounts.

Our opinion is not modified in respect of this matter.

Key Audit Matters

Key audit matters are those matters that in our professional judgment were of mostsignificance in our audit of the standalone Ind AS financial statements for the financialyear ended March 31 2022. These matters were addressed in the context of our audit of thestandalone Ind AS financial statements as a whole and in forming our opinion thereon andwe do not provide a separate opinion on these matters. For each matter below ourdescription of how our audit addressed the matter is provided in that context. We havedetermined the matters described below to be the key audit matters to be communicated inour report. We have fulfilled the responsibilities described in the Auditor'sresponsibilities for the audit of the standalone Ind AS 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

Ind AS financial statements. The results of our audit procedures including theprocedures performed to address the matters below provide the basis for our audit opinionon the accompanying standalone Ind AS financial statements.

Key audit matters How our audit addressed the key audit matter
Impairment assessment of Investments in J. K. Cement (Fujairah) FZC a wholly owned subsidiary
(a) (as described in note 4A 4B & 5 of the standalone Ind AS financial statements)
As at March 31 2022 the Company has an investment in J. K. Cement (Fujairah) FZC a wholly owned subsidiary of Rs99288.30 lacs (including share application money of Rs2471.55 lacs paid in current year against 3% non-cumulative redeemable preference shares in J. K. Cement (Fujairah) FZC the allotment which is expected to be made by end of June 2022). Our audit procedures included the following:
Gained an understanding of the impairment assessment process and evaluated the design and tested the operating effectiveness of controls.
J. K. Cement Works (Fujairah) FZC (step down subsidiary) is incurring losses and its entire net worth is eroded. As a result an impairment assessment was required to be performed by the Company by comparing the carrying value of these investments to their recoverable amount to determine whether an impairment was required to be recognised. Assessed the Company's valuation methodology applied in determining the recoverable amount. Assessed the assumptions of the cash flow forecasts including weighted average cost of capital expected growth rates and terminal growth rates used.
Accordingly during the current year based on business valuation of J. K. Cement Works (Fujairah) FZC" by an independent external valuer the Company has recognized provision towards diminution of carrying amount of investment J. K. Cement (Fujairah) FZC of 16686.50 lacs). The Total amount of Rs 13000 lacs (Previous year Rs Rs 13000 lacs (Previous year Rs16686.50 lacs) has been disclosed as exceptional item. Discussed potential changes inputs as compared to previous year / actual performance with management in order to evaluate whether the inputs and assumptions used in the cash flow forecasts were appropriate.
Involved specialists to assist us in evaluating the valuation methodologies and sensitivity testing of key assumptions used by management in determining the recoverable value headroom.
For the purposes of the above impairment testing value in use has been determined by forecasting and discounting future cash flows. Furthermore the value in use is highly sensitive to changes in some of the inputs used for forecasting the future cash flows. Further the determination of the recoverable amount of the investments in J. K. Cement (Fujairah) FZC involved judgments due to inherent uncertainty in the assumptions supporting the recoverable amount of these investments. Accordingly the impairment assessment of investments in J. K. Cement (Fujairah) FZC was determined to be a key audit matter in our audit of the standalone Ind AS financial statements. Tested the arithmetical accuracy of the valuation model. Assessed the relevant disclosures made within the standalone Ind AS financial statements.
Claims litigations and contingent liabilities
(as described in note 36A of the standalone Ind AS financial statements) As of March 31 2022 the Company has disclosed contingent liabilities of Rs31401.56 lacs relating to tax and legal claims. Our audit procedures included the following:
There are several pending legal and regulatory cases against the Company across various jurisdictions. Accordingly management exercises its judgement in estimation of provision required in respect of such cases. The evaluation of management's judgements including those that involve estimations in assessing the likelihood that a pending claim will succeed or a liability will arise and the quantification of the ranges of potential financial settlement have been a matter of most significance during the current year audit. Gained an understanding of the process of identification of claims litigations and contingent liabilities and evaluated the design and tested the operating effectiveness of key controls.
Obtained the summary of Company's legal and tax cases and assessed management's position through discussions with the legal head tax head and Company's management on both the probability of success in significant cases and the magnitude of any potential loss.
Furthermore the Company has operations across many jurisdictions and is subject to taxation related litigations as per local tax regulations. Evaluation of the outcome of the taxation related matters and whether the risk of loss is remote possible or probable requires judgement by management given the complexities involved. Obtained responses from third-party legal counsel against independent confirmation rolled out by us and conducted discussion with them regarding material cases. Inspected external legal opinions and other evidence to corroborate management's assessment of the risk profile in respect of legal claims.
Accordingly due to large number of claims and complexity/ judgement involved in outcome of these litigations. Claims litigations and contingent liabilities was determined to be a key audit matter in our audit of the standalone Ind AS financial statements Engaged tax specialists to assess management's application and interpretation of tax legislation affecting the Company and to consider the quantification of exposures and settlements arising from disputes with tax authorities in the various tax jurisdictions.
Assessed the relevant disclosures made within the standalone Ind AS financial statements.
Revenue Recognition – Discounts incentives rebates etc.
(as described in note 27 of the standaloneIndASfinancialstatements) For the year ended March 31 2022 the Company has recognized revenue from operations of Rs752905.28 lacs. Our audit procedures included the following:
Revenue is measured net of discounts incentives rebates etc. earned by customers on the Company's sales. Due to the Company's presence across different marketing regions within the country and the competitive business environment the estimation of the various types of discounts incentives and rebate schemes to be recognised based on sales made during the year is material and considered to be complex and judgmental and dependent on various performance obligations and market conditions. Considered Company's revenue recognition policy and its compliance in terms of Ind AS 115 ‘Revenue from contracts with customers'. Assessed the design and tested the operating effectiveness of internal controls with regards to approvals calculation provision and disbursement of discounts incentives and rebates.
Therefore there is a risk of revenue being misstated as a result of faulty estimations over discounts incentives and rebates. Performed sample test of supporting documentation for computation of discounts incentives and rebates recorded and/ or disbursed during the year including credit notes issued after the year end date.
Accordingly given the complexity and judgement involved in the assessment of provisions required for discounts incentives and rebates Revenue recognition Discounts incentives rebates etc. was determined to be a key audit matter in our audit of the Performed analytical review and compared the management's assessment of discounts incentives and rebates recorded for the current year with historical trends of discount given and reversal of such discounts incentives and rebates to assess the adequacy of provisions made during the current year.
Standalone Ind AS financial statements. Performed sample test of manual journals posted to discounts incentives and rebates to identify unusual or irregular items.
Assessed the relevant disclosures made within the standalone Ind AS financial statements.

We have determined that there are no other key audit matters to communicate in ourreport.

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

The Company's Board of Directors is responsible for the other information. The otherinformation comprises the information included in the Annual report but does not includethe standalone Ind AS financial statements and our auditor's report thereon. Our opinionon the standalone Ind As financial statements does not cover the other information and wedo not express any form of assurance conclusion thereon. In connection with our audit ofthe standalone Ind AS financial statements our responsibility is to read the otherinformation and in doing so consider whether such other information is materiallyinconsistent with the financial statements or our knowledge obtained in the audit orotherwise appears to be materially misstated. If based on the work we have performed weconclude that there is a material misstatement of this other information we are requiredto report that fact. We have nothing to report in this regard.

Responsibilities of Management for the Standalone Ind AS 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

Ind AS financial statements that give a true and fair view of the financial positionfinancial performance including other comprehensive income cash flows and changes inequity of the Company in accordance with the accounting principles generally accepted inIndia including the Indian Accounting Standards (Ind AS) specified under section 133 ofthe Act read with [the Companies (Indian Accounting Standards) Rules 2015 as amended.This responsibility also includes maintenance of adequate accounting records in accordancewith the provisions of the Act for safeguarding of the assets of the Company and forpreventing and detecting frauds and other irregularities; selection and application ofappropriate accounting policies; making judgments and estimates that are reasonable andprudent; and the 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 standalone IndAS financial statements that give a true and fair view and are free from materialmisstatement whether due to fraud or error.

In preparing the standalone Ind AS 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 Ind AS Financial Statements

Our objectives are to obtain reasonable assurance about whether the standalone Ind ASfinancial 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 Ind AS 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 standalone Ind ASfinancial 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 with reference to financial statements in place andthe operating effectiveness of such 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 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 standalone IndAS financial statements including the disclosures and whether the standalone

Ind AS financial statements represent the underlying transactions and events in amanner that achieves fair presentation.

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 the standalone Ind AS financialstatements for the financial year ended March 31 2022 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.

Report on Other Legal and Regulatory Requirements

1. As required by the Companies (Auditor's Report) Order 2020 ("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 1" 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 andobtained all the information and explanations which to the best of our knowledge andbelief 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 it appears from our examination of those books; financial (c) TheBalance Sheet the Statement of and Loss including the Statement of Other ComprehensiveIncome the Cash Flow Statement and Statement of Changes in Equity dealt with by thisReport are in agreement with the books of account; (d) In our opinion the aforesaidstandalone IndAS the Accounting Standards Section 133 of the Act read with Companies(Indian Accounting Standards) Rules 2015 as amended;

(e) The matter described in Emphasis of Matter on CCI Case' paragraph above in ouropinion may have an adverse effect on the functioning of the Company; (f) On the basis ofthe written representations received from the directors as on March 31

2022 taken on record by the Board of Directors none of the directors is 31 2022 frombeing appointed as a director in terms of Section 164 (2) of the Act; (g) With respect tothe adequacy of the internal financial standaloneIndAS the operating effectiveness of suchcontrols refer to our separate Report in "Annexure 2" to this report; h) In ouropinion the managerial remuneration for the year ended March 31 2022 has been paid /provided by the Company to its directors in accordance with the provisions of section 197read with Schedule V to the Act; (i) With respect to the other matters to be included inthe Auditor's Report in accordance with Rule 11 of the Companies (Audit and Auditors)Rules 2014 as amended in our opinion and to the best of our information and according tothe explanations given to us: i. The Company has disclosed the impactofpendinglitigationsonits position in its standalone Ind AS financial statements ReferNote 36A to the standalone Ind AS financial statements; ii. The Company did not have anylong-term contracts including derivative contracts for which there were any materialforeseeable losses; iii. There has been no delay in transferring amounts required to betransferred to the Investor Education and Protection Fund by the Company. iv. a) Themanagement has represented that to the best of its knowledge and belief no funds havebeen advanced or loaned or invested (either from borrowed funds or share premium or anyother sources or kind of funds) by the company to or in any other person(s) orentity(ies) including foreign entities ("Intermediaries") with theunderstanding whether recorded in writing or otherwise that the

Intermediary shall whether directly or indirectly lend or invest in othercontrolswithreferencetothese persons or entities identified in any manner whatsoever by oron behalf of the company ("Ultimate Beneficiaries") or provide any guaranteesecurity or the like on behalf of the Ultimate Beneficiaries; b) The management hasrepresented that to the best of its knowledge and belief no funds have been received bythe company from any person(s) or entity(ies) including foreign entities ("FundingParties") with the understanding whether recorded in writing or otherwise that thecompany shall whether directly or indirectly lend or invest in other persons orentities identified in any manner whatsoever by or on behalf of the Funding Party("Ultimate Beneficiaries") or provide any guarantee security or the like onbehalf of the Ultimate Beneficiaries; and c) Based on such audit procedures that wereconsidered reasonable and appropriate in the circumstances nothing has come to our noticethat has caused us to believe that the representations under sub-clause (a) and (b)contain any material misstatement.

v. The dividend paid during the year by the Company is in compliance with section 123of the Act.

For S.R. Batliboi & Co. LLP
Chartered Accountants
ICAI Firm Registration Number: 301003E/E300005
per Atul Seksaria
Partner
Place of Signature: New Delhi Membership Number: 086370
Date: 21 May 2022 UDIN: 22086370AJJBBC5999

Annexure 1 referred to in paragraph under the heading "Report on other legal andregulatory requirements" of our report of even date

Re: J. K. Cement Limited (‘the Company')

In terms of the information and explanations sought by us and given by the company andthe books of account and records examined by us in the normal course of audit and to thebest of our knowledge and belief we state that: (i) (a) (A) The Company has maintainedproper records showing full particulars including quantitative details and situation of

Property Plant and Equipment. (B) The Company has maintained proper records showingfull particulars of intangibles assets.

(b) All Property Plant and Equipment were physically verified by the management in theprevious year in accordance with a planned programme of verifying them once in three yearswhich is reasonable having regard to the size of the Company and the nature of its assets.

(c) The title deeds of all the immovable properties (other than properties where theCompany is the lessee and the lease agreements are duly executed in favour of the lessee)are held in the name of the Company. (d) The Company has not revalued its Property Plantand Equipment (including Right of use assets) or intangible assets during the year endedMarch 31 2022.

(e) There are no proceedings initiated or are pending against the Company for holdingany benami property under the Prohibition of Benami Property Transactions Act 1988 andrules made thereunder.

(ii) (a) The inventory has been physically verified by the management during the yearexcept for inventories lying with third parties. In our opinion the frequency ofverification by the management is reasonable and the coverage and procedure for suchverification is appropriate. Discrepancies of 10% or more in aggregate for each class ofinventory were not noticed in respect of such verification. Inventories lying with thirdparties amounting to Rs14554 lacs have been confirmed by them as at March 31 2022 anddiscrepancies were not noticed in respect of such confirmations. (b) According to theinformation and explanations given to us and on the basis of our examination of therecords of the Company the Company has been sanctioned working capital limits in excessof Rs. five crores in aggregate from banks and financial institutions during the year onthe basis of security of current assets of the Company. In our opinion the quarterlystatements filed by the Company with such banks and financial institutions are inagreement with the books of account of the Company.

(iii) (a) During the year the Company has provided loans advances in the nature ofloans stood guarantee and provided security to companies or any other parties as follows:

Investment (Rs in lacs) Guarantees (Rs in lacs)
Aggregate amount granted/ provided during the year
- Subsidiaries 98701 Nil
- Associates 417 Nil
- Others 284 Nil
Balance outstanding as at balance sheet date in respect of above cases
- Subsidiaries 155359 9595
- Associates 417 Nil
- Others 702 Nil

(b) During the year the Company has not provided security granted loan and advances inthe nature of loan to companies firms Limited Liabilities Partnership or any otherparties. Further during the year the investments made and guarantees provided tocompanies are not prejudicial to the Company's interest. (c) The Company has not grantedloans and advances in the nature of loans to companies firms Limited LiabilityPartnerships or any other parties. Accordingly the requirement to report on clause3(iii)(c) (d) (e) and (f) of the Order are not applicable to the Company. (iv) There areno loans and security in respect of which provisions of sections 185 and 186 of theCompanies Act 2013 are applicable. Further investments made and guarantees provided inrespect of which provisions of sections 185 and 186 of the Companies Act 2013 areapplicable have been complied with by the Company.

(v) The Company has neither accepted any deposits from the public nor accepted anyamounts which are deemed to be deposits within the meaning of sections 73 to 76 of theCompanies Act and the rules made thereunder to the extent applicable.

Accordingly the requirement to report on clause 3(v) of the Order is not applicable tothe Company.

(vi) We have broadly reviewed the books of account maintained by the Company pursuantto the rules made by the Central Government for the maintenance of cost records undersection

148(1) of the Companies Act 2013 related to the manufacture of goods and are of theopinion that prima facie the specified have been made and maintained. We have nothowever made a detailed examination of the same.

(vii) (a) Undisputed statutory dues including goods and services tax provident fundemployees' state insurance income-tax sales-tax duty of custom value added tax cessand other statutory dues have generally been regularly deposited with the appropriateauthorities. According to the information and explanations given to us and based on auditprocedures performed by us no undisputed dues in respect of goods and services taxprovident fund employees' state insurance income-tax service tax sales-tax duty ofcustom duty of excise value added tax cess and other statutory dues which wereoutstanding at the year end for a period of more than six months from the date theybecame payable.

(vii) (b) The dues of goods and services tax provident fund employees' stateinsurance income-tax sales-tax service tax duty of custom duty of excise value addedtax cess and other statutory dues have not been deposited on account of any dispute areas follows:

Name of the statute Nature of the dues Amount (Rs. in lacs)* Period to which Amount relates Forum where the dispute is pending
The Uttar Pradesh Tax on Entry of Goods into Local Areas Act 2007 Entry tax 314.28 2005-2006 to 2009-2010 Supreme Court
The Bihar Tax on Entry of Goods into Local Areas for Consumption Use or Sale Therein Act 1993 Entry Tax 163.56 2008-2009 to 2015-2016 Appellate Authorities
Central Excise Act 1944 Excise Duty 419.02 1989-1990 Supreme Court
Excise Duty 23.97 1999-2000 to 2007- 2008 High court
Excise Duty 1864.90 1999-2000 to 2007- 2008 Appellate Authorities
Excise Duty 137.00 2013-14 Tribunal(s)
Service Tax (Finance Act1994) Service Tax 48.56 2005-2006 to 2007- 2008 Tribunal(s)
Finance Act 2008 (State) Environment & Health Cess 3323.44 2008-2009 to 2015-2016 High court
Sales tax/value added tax (VAT) Sales TaxVAT interest and Penalty 178.03 2009-2010 Supreme Court
Sales TaxVAT interest and Penalty 9827.14 2013-14 to 2017-18 High court
Sales TaxVAT interest and Penalty 122.28 2012-2013 Tribunal(s)
Sales TaxVAT interest and Penalty 309.62 1991-1992 to 2016-2017 Appellate Authorities
Income Tax Act 1961 Income Tax 1087.48 2007-2008 to 2008-2009 High Court
Income Tax 5122.47 2018-2019 to 2020-2021 Appellate Authorities
Rajasthan Finance Act 2006 Land Tax 1394.76 2006-2013 2019-2022 High Court
The Mines and Minerals (Development and Regulation) Act 2011 Special Charges 295.04 2011-12 to 2021-22 High Court
The Mines and Minerals (Development and Regulation) Act 2015 NMET 47.69 2014- 15 to 2016-17 High Court
Rajasthan Electricity (Duty) Act 1962 Electricity Duty 711.91 2015-16 to 2020-2021 High Court
Electricity Rules 2005 Electricity duty water cess and Urban cess 7117.69 2009-2010 to 2021-2022 High court

* Net of amounts paid under protest/ adjusted against refunds

(viii) The Company has not surrendered or disclosed any transaction previouslyunrecorded in the books of account in the tax assessments under the Income Tax Act 1961as income during the year. Accordingly the requirement to report on clause 3(viii) of theOrder is not applicable to the Company. (ix) (a) The Company has not defaulted inrepayment of loans or other borrowings or in the payment of interest thereon to anylender.

(b) The Company has not been declared willful defaulter by any bank or financialinstitution or government or any government authority. (c) Term loans were applied for thepurpose for which the loans were obtained.

(d) On an overall examination of the financial statements of the Company no fundsraised on short-term basis have been used for long-term purposes by the Company.

(e) On an overall examination of the financial statements of the Company the Companyhas not taken any funds from any entity or person on account of or to meet the obligationsof its subsidiaries and associates. (f) The Company has not raised loans during the yearon the pledge of securities held in its subsidiaries and associate companies. Hence therequirement to report on clause (ix)(f) of the Order is not applicable to the Company. (x)(a) The Company has not raised any money during the year by way of initial public offerfurther public offer (including debt instruments) hence the requirement to report onclause 3(x)(a) of the Order is not applicable to the Company. (b) The Company has not madeany preferential allotment or private placement of shares fully or partially or optionallyconvertible debentures during the year under audit and hence the requirement to report onclause 3(x)(b) of the Order is not applicable to the Company.

(xi) (a) No fraud by the Company or no material fraud on the Company has been noticedor reported during the year.

(b) During the year no report under subsection (12) of section 143 of the CompaniesAct 2013 has been filed by cost auditor/ secretarial auditor or by us in Form ADT 4 asprescribed under Rule 13 of Companies (Audit and Auditors) Rules 2014 with the CentralGovernment.

(c) As represented to us by the management there are no whistle blower complaintsreceived by the Company during the year.

(xii) The Company is not a nidhi Company as per the provisions of the Companies Act2013.Therefore requirement to report on clause 3(xii)(a)(b)(c) of the Order are notapplicable to the Company. (xiii) Transactions with the related parties are in compliancewith sections 177 and 188 of Companies Act 2013 where applicable and the details havebeen disclosed in the notes to the financial statements as required by the applicableaccounting standards.

(xiv) (a) The Company has an internal audit system commensurate with the size andnature of its business.

(xiv) (b) The internal audit reports of the Company issued till the date of the auditreport for the period under audit have been considered by us. (xv) The Company has notentered into any non-cash transactions with its directors or persons connected with itsdirectors and hence requirement to report on clause 3(xv) of the Order is not applicableto the Company.

(xvi) (a) The provisions of section 45-IA of the Reserve Bank of India Act 1934 (2of1934) are not applicable to the Company. Accordingly the requirement to report onclause (xvi)(a) of the Order is not applicable to the Company. (b) The Company is notengaged in any Non-Banking Financial or Housing Finance activities. Accordingly therequirement to report on clause (xvi)(b) of the Order is not applicable to the Company.

(c) The Company is not a Core Investment Companyas by Reserve Bank of India.Accordingly the requirement to report on clause (xvi)(b) of the Order is not applicableto the Company. (d) There are no other Companies part of the Group hence the requirementto report on clause 3(xvi)(d) of the Order is not applicable to the Company.

(xvii) The Company has not incurred cash losses in the current financial year. (xviii)There has been no resignation of the statutory auditors during the year and accordinglyrequirement to report on Clause 3(xviii) of the Order is not applicable to the Company.(xix) On the basis of the financial ratios disclosed in note 43 to the financialstatements ageing and expected dates of realization of financial assets and payment offinancial liabilities other information accompanying the financial statements ourknowledge of the Board of Directors and management plans and based on our examination ofthe evidence supporting the assumptions nothing has come to our attention which causesus to believe that any material uncertainty exists as on the date of the audit report thatCompany is not capable of meeting its liabilities existing at the date of balance sheet asand when they fall due within a period of one year from the balance sheet date. Wehowever state that this is not an assurance as to the future viability of the Company. Wefurther state that our reporting is based on the facts up to the date of the audit reportand we neither give any guarantee nor any assurance that all liabilities falling duewithin a period of one year from the balance sheet date will get discharged by theCompany as and when they fall due.

(xx) (a) In respect of other than ongoing projects there are no unspent amounts thatare required to be transferred to a fund specified in Schedule VII of the Companies Act(the Act) in compliance with second proviso to sub section 5 of section 135 of the Act.This matter has been disclosed in note 44 to the financial statements. (b) There are nounspent amounts in respect of ongoing projects that are required to be transferred to aspecial account in compliance of provision of sub section (6) of section 135 of CompaniesAct. This matter has been disclosed in note to 44 the financial statements. (xxi) Thereare no qualifications or adverse remarks by the respective auditors in the Companies(Auditors Report) Order (CARO) reports of the companies included in the consolidatedfinancial statements. Accordingly the requirement to report on clause 3(xxi) of the Orderis not applicable to the Holding Company.

For S.R. Batliboi & Co. LLP
Chartered Accountants
ICAI Firm Registration Number: 301003E/E300005
per Atul Seksaria
Partner
Place of Signature: New Delhi Membership Number: 086370
Date: 21 May 2022 UDIN: 22086370AJJBBC5999

Annexure 2 to the Independent Auditor's Report of even date on the Standalone Ind ASFinancial Statements of J. K. Cement Limted

Report on the Internal Financial Controls under Clause (i) of Sub-section 3 of Section143 of the Companies Act 2013 ("the Act")

We have audited the internal financial controls over Company") as of 31 March 2022in conjunction with our audit of the standalone Ind AS financial statements of the Companyfor the year ended on that date.

Management's Responsibility for Internal Financial Controls

The Company's Management is responsible for establishingandmaintaininginternal based onthe internal control over financial reporting criteria established by the Companyconsidering the essential components of internal control stated in the Guidance Note onAudit of Internal Financial Controls Over Financial Reporting issued by the Institute ofChartered Accountants of India. These responsibilities include the design implementationand maintenance of adequate internal financial controls that were operating effectivelyfor ensuring the orderly and efficient conduct of its business including adherence to theCompany's policies the safeguarding of its assets the prevention and detection of fraudsand errors the accuracy and completeness of the accounting records and the timelypreparation of reliable financial information as required under the Companies Act 2013.

Auditor's Responsibility

Our responsibility is to express an opinion on the Company's internal financialcontrols over financial reporting with reference to these standalone IND AS our audit inaccordance with the Guidance Note on Audit of Internal Financial Controls Over FinancialReporting (the "Guidance Note") and the Standards on Auditing as Act 2013 tothe extent 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 with reference to these standalone Ind AS financial statements was establishedand maintained and if such controls operated effectively in all material respects.

Our audit involves performing procedures to obtain audit evidence about the adequacy ofthe internal financial controls over financial reporting with reference to thesestandalone Ind AS financial statements and their operating effectiveness. Our audit ofinternal financial controls over financial reporting included obtaining an understandingof internal financial controls over financial reporting with reference to these standaloneInd AS financial statements assessing the risk that a material weakness exists andtesting and evaluating the design and operating effectiveness of internal control based onthe assessed risk. The procedures selected depend on the auditor's judgement includingthe assessment of the risks of material misstatement of the standalone Ind AS financialstatements whether due to fraud or error. We believe that the audit evidence we haveobtained is sufficient and appropriate to provide a basis for our audit opinion on theinternal financial controls over financial reporting with reference to these standaloneInd AS financial statements.

Meaning of Internal Financial Controls Over Financial Reporting with Reference to theseStandalone Ind AS Financial Statements

A company's internal financial control over financial reporting with reference to thesestandalone Ind AS financial statements is a process designed to provide reasonableassurance regarding the reliability of financial reporting and the preparation offinancial statements for external purposes in accordance with generally acceptedaccounting principles. A company's internal financial control over financial reportingwith reference to these standalone Ind AS 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 financial statements in accordance with generally acceptedaccounting principles and that receipts and expenditures of the company are being madeonly in accordance with authorisations of management and directors of the company; and (3)provide reasonable assurance regarding prevention or timely detection of unauthorisedacquisition use or disposition of the company's assets that could have a material effecton the financial statements.

Inherent Limitations of Internal Financial Controls Over Financial Reporting withReference to these Standalone Ind AS Financial Statements

Because of the inherent limitations of internal financial controls over financialreporting with reference to these standalone Ind AS 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 Ind AS financial statements to future periods are subject to the riskthat the internal financial control over financial reporting with reference to thesestandalone IND AS financial statements may become inadequate because of changes inconditions or that the degree of compliance with the policies or procedures maydeteriorate.

Opinion

In our opinion the Company has in all material respects adequate internal financialcontrols over financial reporting with reference to these standalone Ind

AS financial statements and such internal financial controls over financial reportingwith reference to these standalone Ind AS financial statements were operating effectivelyas at 31 March 2022 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.

For S.R. Batliboi & Co. LLP
Chartered Accountants
ICAI Firm Registration Number: 301003E/E300005
per Atul Seksaria
Partner
Place of Signature: New Delhi Membership Number: 086370
Date: 21 May 2022 UDIN: 22086370AJJBBC5999

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