You are here » Home » Companies » Company Overview » Jai Balaji Industries Ltd

Jai Balaji Industries Ltd.

BSE: 532976 Sector: Metals & Mining
NSE: JAIBALAJI ISIN Code: INE091G01018
BSE 00:00 | 20 Sep 51.75 -0.45
(-0.86%)
OPEN

54.70

HIGH

54.70

LOW

49.80

NSE 00:00 | 20 Sep 51.40 -0.65
(-1.25%)
OPEN

51.50

HIGH

52.80

LOW

50.20

OPEN 54.70
PREVIOUS CLOSE 52.20
VOLUME 8019
52-Week high 70.35
52-Week low 14.51
P/E 17.08
Mkt Cap.(Rs cr) 572
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00
OPEN 54.70
CLOSE 52.20
VOLUME 8019
52-Week high 70.35
52-Week low 14.51
P/E 17.08
Mkt Cap.(Rs cr) 572
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

Jai Balaji Industries Ltd. (JAIBALAJI) - Auditors Report

Company auditors report

To The Members of

JAI BALAJI INDUSTRIES LIMITED

Report on the Audit of the Standalone Financial Statements

Opinion

We have audited the accompanying standalone financial statements of TRIES LIMITED("the

Company") which comprise the balance sheet as at 31st March 2020 and thestatement of Profit and Loss (including other comprehensive income) statement of cashflows and statement of changes in equity for the year then ended and a summary ofsignificant accounting policies and other explanatory information.

In our opinion and to the best of our information and according to the explanationsgiven to us "except for the effects of the matter described in the Basis forQualified Opinion section" of our reportthe aforesaid standalone financialstatements give the information required by the Companies Act 2013 ("the Act")in the manner so required and give a true and fair view in conformity with the IndianAccounting Standards prescribed under section 133 of the Act read with the Companies(Indian Accounting Standards) Rules 2015 as amended ("Ind AS") and otheraccounting principles generally accepted in India of the state of affairs of the Companyas at March 31 2020 and its loss total comprehensive income its cash flows and thechanges in equity for the year ended on that date.

Basis for Qualified Opinion

We conducted our audit of the standalone financial statements in accordance with theStandards on Auditing specified under section 143(10) of the Act (SAs). Ourresponsibilities under those Standards are further described in the Auditor'sResponsibility for the Audit of the Standalone Financial

Statements section of our report. We are independent of the Company in accordance withthe Code of Ethics issued by the Institute of Chartered Accountants of India (ICAI)together with the ethical requirements that are relevant to our audit of the standalonefinancial statements under the provisions of the Act and the Rules made thereunder and wehave fulfilled our other ethical responsibilities in accordance with these requirementsand the ICAI's Code of Ethics. We believe that the audit evidence obtained by us issufficient and appropriate to provide a basis for our opinion on the standalone financialstatements.

The Company has not provided for interest amounting to Rs.103019.80 Lacs of whichRs.27383.99 Lacs pertains to the current financial year on various loans and creditfacilities availed from banks and financial institution on the ground that same is beingtreated as Non-Performing Assets by the lenders. Due to this reason loss for the currentfinancial year has been understated by Rs.27383.99 Lacs and accordingly loss for the yearended 31st March 2020 would have been Rs. 38817.58 Lacs instead of Rs.11433.59 Lacs.

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 of the current period.These matters were addressed in the context of our audit of the standalone financialstatements as a whole and in forming our opinion thereon and we do not provide aseparate opinion on these matters. We have determined the matters described below to bethe key audit matters to be communicated in our report.

S. NO. THE KEY AUDIT MATTERS HOW THE MATTER WAS ADRESSED IN OUR AUDIT
1. LOAN CLASSIFIED AS Non Performing Assets (NPA) TRANSFERRED TO ASSET RECONSTRUCTION COMPANIES (ARC) OUR AUDIT PROCEDURES INCLUDE THE FOLLOWING:
(Refer Note 20 to the Standalone Financial Statements) 1. We obtained the understanding of these asset reconstruction schemes through meetings with management and review of the minutes of the Board of Directors.
a) Rupee Loan from Banks and financial institutions had been classified as NPA and the lenders have served a call up notice for their exposure. Entire exposure of the lenders has fallen due on immediate demand basis.
b) Axis Bank UCO Bank Allahabad Bank Union Bank of IndiaBank of IndiaUnited Bank of IndiaState Bank of India have already assigned their entire exposure to the Assets Reconstruction Companies in previous years. During the current financial year the following banks have also assigned their entire exposure in favour of Assets Reconstruction Companies: 2. We reviewed the correspondence of the company with the relevant Asset reconstruction companies and we have examined the agreement made with them.
i. The WBIDFCL IDBI Bank Indian Overseas Bank and Vijaya Bank also assigned there debts due by the Company in favour of Assets Reconstruction Companies.
ii. One time settlement offer with Oriental Bank of Commerce against their entire exposure is under process.
iii. The Company is in active negotiation with Canara Bank Corporation Bank Punjab National Bank and The Federal Bank Limited to restructure its debts.The finalisation of any corrective plan is still pending.
iv. The Company had made payments to the above ARC's which has not been adjusted against the liability and is shown as advances to the ARC.
2. THE COMPANY'S EXPOSURE TO LITIGATION RISK OUR AUDIT PROCEDURES INCLUDE THE FOLLOWING:
(Refer Note 35A to the Standalone Financial Statements)
The Company is exposed to different laws regulations and interpretations thereof and hence there is a litigation risk. Consequently the Company has significant litigation 1. We obtained details of completed tax assessments and demands for the year ended March 31 2020 from management. 2. We examined the assumptions used in estimating the tax provision and the possible outcome of the disputes.
cases pending with Custom Authorities Excise Authorities Service tax Authorities and Income tax Authorities. 3. We considered legal precedence and other rulings in evaluating management's position on these tax positions.
Given the nature and amounts involved in such cases and the appellate forums at which these are pending the ultimate outcome and the resultant accounting in the financial statements is subject to significant judgement which can change over time as new facts emerge and each legal case progresses and therefore we have identified this as key audit matter.
3. Adoption of Ind AS 116 "Leases " OUR AUDIT PROCEDURES INCLUDE THE FOLLOWING:
(Refer to Note 37 to the Standalone Financial Statements) Effective 1st April 2019 Ind AS 116 replaces the existing standard Ind AS 17 and specifies how an entity will recognise measure present and disclose leases. The 1. Assessing the accounting regarding leases with reference to consistency with the definitions of Ind AS 116. This includes factors such as lease term discount rate and measurement principles;
standard provides a single lease accounting model requiring lessees to recognise a right of use asset ("ROU asset") and a corresponding liability on the lease commencement date. It provides exemption for leases with lease term of 12 months or less or the underlying asset has a low value. The Company has applied Ind AS 116. We considered the first-time application of the standard as a key audit matter due to the judgements needed in establishing the underlying key assumptions. 2. Testing completeness of the lease data as at 31st March 2019 by reconciling the Company's operating lease commitments to the underlying data used in computing the ROU asset and Lease liability;

Emphasis of Matter

1. We draw attention to Note - 36 of the financial statements the Company has beenincurring losses and its net worth has completely eroded also its current liabilityexceeds current assets by Rs.273161.96 Lacs. However the financial statements of theCompany have been prepared on a going concern basis because the management is confidentthat the improvement in market scenario will help in improving the financial health of thecompany and accordingly Deferred Tax Assets amounting to Rs.29085.14 Lacs created up to31st March 2015 have been carried forward.

2. We also draw attention to Note No.20 of the accompanying Standalone FinancialStatements in respect of treatment in the books of accounts of the assignment / settlementof Debts of various Banks and the Financial Institutions.

3. We draw attention to Note No.59 to the financial statements in relation tooutstanding balances of trade receivables trade payables and loans and advances which aresubject to confirmation and subsequent adjustments if any.

4. We draw attention to Note.61 to the financial statement which describes theuncertainties and potential impact of the Covid -19 pandemic on the Company's operationsand results as assessed by the management for which a definitive assessment of the impactin the subsequent period is highly dependent upon circumstances as they evolve.

5. We draw attention to Note No. 49 to the Financial statement regarding impairmentloss. The Company has impaired its assets subject to management decision which led to animpairment loss of Rs. 576.79 lacs.

Our report is not modified in respect of above matters.

Information Other than the Financial Statements and

Auditor's Report thereon

The Company's Board of Directors is responsible for the other

information.The other information comprises Board's Report

Report on Corporate Governance and Business Responsibility Report but does not includethe consolidated financial statement standalone financial statements and our auditor'sreport 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 standalone financial statements or our knowledge obtainedduring the course 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.

Management' Responsibility for the Standalone Ind AS Financial Statements

The Company's Board of Directors is responsible for the matters stated in section134(5) of the Companies Act 2013 ("the Act") with respect to the preparation ofthese Ind AS financial statements that give a true and fair view of the financialposition financial performance including other comprehensive income cash flows andchanges in equity of the Company in accordance with the accounting principles generallyaccepted in India. This responsibility also includes maintenance of adequate accountingrecords in accordance with the provisions of the Act for safeguarding the assets of theCompany and for preventing and detecting frauds and other irregularities; selection andapplication of appropriate accounting policies; making judgments and estimates that arereasonable and prudent; and design implementation and maintenance of adequate internalfinancial controls that were operating effectively for ensuring the accuracy andcompleteness of the accounting records relevant to the preparation and presentation ofthe financial statement that give a true and fair view and are free from materialmisstatement 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 are also responsible for overseeing the Company's financialreporting process.

Auditor's Responsibility for the Audit of the Standalone Ind AS Financial Statements

Our objectives are to obtain reasonable assurance about whether the Ind AS 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 judgement andmaintain professional scepticism throughout the audit. We also:

• Identify and assess the risks of material misstatement of the Ind AS financialstatementswhether 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

the operating effectiveness of such controls.

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

Conclude on the appropriateness of management's use

of the going concern basis of accounting and based on the audit evidence obtainedwhether a material uncertainty exists related to events or conditions that may castsignificant doubt on the Company's ability to continue as a going concern. If we concludethat a material uncertainty exists we are required to draw attention in our auditor'sreport to the related disclosures in the Ind AS financial statements or if suchdisclosures are inadequate to modify our opinion. Our conclusions are based on the auditevidence obtained up to the date of our auditor's report.However future events orconditions may cause the Company to cease to continue as a going concern.

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

Materiality is the magnitude of misstatements in the Ind AS financial statements thatindividually 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 I 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 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 financial statementsof the current period and are therefore the key audit matters. We describe these mattersin our auditor' report unless law or regulation precludes public disclosure about thematter or when 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

1. As required by Section 143(3) of the Act based on our audit 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 it appears from our examination of those book.

(c) The Balance Sheet the Statement of Profit and Loss including 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 aforesaid Ind AS financial statements comply with the IndianAccounting Standards specified under Section 133 of the Act read with relevant rulesissued thereunder.

(e) On the basis of the written representations received from the directors as on 31stMarch 2020 taken on record by the Board of Directors none of the directors isdisqualified as on 31st March 2020 from being appointed as a director in terms of Section164 (2) of the Act.

(f) 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 A". Our report expresses an unmodified opinion onthe adequacy and operating effectiveness of the Company's internal financial controls overfinancial reporting.

(g) 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 opinionand to the best of our information and according to the explanations given to us theremuneration paid by the Company to its directors during the year is in accordance withthe provisions of section 197 of the Act.

(h) 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 opinionand to the best of our information and according to the explanations given to us:

i. The Company has disclosed the impact of pending litigations on its financialposition in its financial statements - Refer Note 35A

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 such sum which needs to be transferred to the Investor Educationand Protection Fund by the Company.

2. 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 Companies Act 2013 we give in the Annexure "B" a statement on the mattersspecified in paragraphs 3 and 4 of the Order to the extent applicable.

For S. K. AGRAWAL & CO.
Chartered Accountants
Firm's Registration No-306033E
(J. K. CHOUDHURY)
Partner
Place: Kolkata Membership No: 009367
Dated : July 312020 UDIN:20009367AAAADB7735

ANNEXURE "A" TO THE INDEPENDENT AUDITOR'S REPORT

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

We have audited the internal financial controls over financial reporting of JAI BALAJIINDUSTRIES LIMITED ("the Company") as of March 31 2020 to the extent of recordsavailable with us in conjunction with our audit of the Ind AS financial statements of theCompany for the year ended on that date.

Management's Responsibility for Internal Financial Controls

The Board of Directors of the Company is responsible for establishing and maintaininginternal financial controls based on the internal control over financial reportingcriteria

established by the Company considering the essential components of internal controlstated in the Guidance Note on Audit of Internal Financial Controls over FinancialReporting issued by the Institute of Chartered Accountants of India. Theseresponsibilities include the design implementation and maintenance of adequate internalfinancial controls that were operating effectively for ensuring the orderly and efficientconduct of its business the safeguarding of its assets the prevention and detection offrauds and errors the accuracy and completeness of the accounting records and the timelypreparation of reliable financial information as required under the Companies Act 2013.

Auditor's Responsibility

Our responsibility is to express an opinion on the internal financial controls overfinancial reporting of the Company based on our audit. We conducted our audit inaccordance with the Guidance Note on Audit of Internal Financial Controls Over FinancialReporting (the "Guidance Note") issued by the Institute of Chartered Accountantsof India and the Standards on Auditing prescribed under Section 143(10) of the CompaniesAct 2013 to the extent applicable to an audit of internal financial controls. ThoseStandards and the Guidance Note require that we comply with ethical requirements and planand perform the audit to obtain reasonable assurance about whether adequate internalfinancial controls over financial reporting was established and maintained and if suchcontrols operated effectively in all material respects.

Our audit involves 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 judgement 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 of records that in reasonable detail accurately andfairly reflect the transactions and dispositions of the assets of the company;

(2) provide reasonable assurance that transactions are recorded as necessary to permitpreparation of financial statements in accordance with generally accepted accountingprinciples and that receipts and expenditures of the company are being made only inaccordance with authorisations of management and directors of the company; and

(3) Provide reasonable assurance regarding prevention or timely detection ofunauthorised acquisition use or disposition of the company's assets that could have amaterial effect on the financial statements.

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 to the best of our information and according to the explanations givento us the Company has in all material respects an adequate internal financial controlssystem over financial reporting and such internal financial controls over financialreporting were operating effectively as at March 31 2020 based on the internal controlover financial reporting criteria established by the Company.

For S. K. AGRAWAL & CO.
Chartered Accountants
Firm's Registration No-306033E
(J. K. CHOUDHURY)
Partner
Place: Kolkata Membership No: 009367
Dated : July 312020 UDIN:20009367AAAADB7735

Annexure -B to the Independent Auditors' Report

The Annexure referred to in our Independent Auditor's Report to the members of JAIBALAJI INDUSTRIES LIMITED ('the Company') on the standalone financial statements for theyear ended on 31st March 2020. We report that:

i. (a) The Company has maintained proper records

showing full particulars including quantitative details and situation of fixed assets

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

(c) According to information and explanation 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 inventories have been physically verified during the year by the management atregular intervals. In our opinion and according to the information and explanations givento us no material discrepancies were noticed on physical verification.

iii. According to information and explanation given to us and on the basis of ourexamination of the records of the Company the Company has granted unsecured loans to onecompany covered in the register maintained under section 189 of the Companies Act 2013('the Act'). Accordingly we report that: -

a) The terms and conditions of such loans are prima facie not prejudicial to thecompany's interest.

b) The above loans are re-payable on demand

iv. In our opinion and according to the information and explanations given to us theCompany has complied with the provisions of sections 185 and 186 of the Companies Act2013 in respect of loans investments guarantees and securities made.

v. The Company has not accepted any deposits from the public. Accordingly paragraph3(v) of the Order is not applicable.

vi. We have broadly reviewed the books of account maintained by the Company pursuant tothe rules prescribed by the Central Government for maintenance of cost records undersection 148 (1) of the Act and are of the opinion that prima facie the prescribedaccounts and records have been made and maintained.

vii. According to the information and explanations given to us in respect of statutorydues:

(a) The Company has not been regular in depositing undisputed statutory dues includingProvident Fund Employees State Insurance Income Tax Goods and Service Tax Value AddedTax duty of Excise Cess and other statutory dues with the appropriate authorities duringthe year.

According to the information and explanations given to us the following undisputedamounts payable in respect of the aforesaid dues were outstanding as at 31st March 2020for a period of more than six months from the date they became payable: -

Name of Statute Nature of Dues Amount Outstanding (Rs in Lacs) Period to which amount relates
Income Tax Act 1961 TDS 295.88 April'18 to September'19
Provident Fund Act 1952 Provident Fund 781.10 May'16 to September'19
Punjab Value Added Tax Act Value Added Tax 53.57 September'13 to February'14

(b) According to information and explanations given to us the following dues of incometax goods and services tax sales tax duty of excise duty of custom service tax andvalue added tax have not been deposited by the Company on account of disputes:

Name of the Statute Nature of Dues Amount under dispute not yet deposited (' in lacs) Financial year to which the amount relates Forum where dispute is pending
The Central Excise Act 1944 Excise Duty 25274.95 2007-08 to 2019-20 CESTAT Commissioner (Appeals)
The Finance Act 1994 Service Tax 1943.34 2010-11 to 2019-20 CESTAT Commissioner (Appeals)
Custom Act 1962 Custom Duty 559.60 2012-13 2016-17 2017-18 & 2019-20 CESTAT Commissioner (Appeals)
The Good and Services Tax Act 2017 Sales Tax 60.71 2007-20 West Bengal Appellate & Revisional Board
The Central Sales Tax Act 1956 Central Sales Tax 1259.90 2004-2020 West Bengal Appellate & Revisional Board
The West Bengal Value Added Tax Act 2003 Value Added Tax 2862.80 2004-2020 West Bengal Appellate & Revisional Board
The Income Tax Act 1961 Income Tax 6.85 2008-09 DCIT/CIT(A)
Entry Tax Act 1976 Entry Tax 4668.52 2012-2020 Appealate

viii. In our opinion and according to information and explanations given by themanagement we are of the opinion that the Company has defaulted in the repayment of duesto banks and financial institution during the year as given below: -

(Rupees in lacs)
Banks Default of Amount (Principal and Interest)
Canara Bank 1339.34
Corporation Bank 2151.51
Federal Bank 402.49
Oriental Bank of Commerce 23307.39
Punjab National Bank 2823.94
Grand Total 30024.67

*above figures don't include interest amounting to Rs.103019.80 Lacs of whichRs.27383.99 Lacs pertains to financial year 2019-20 as interest has not been providedin the books as mentioned in Note - 20 of the financial statements.

**The lenders have initiated the recovery procedures and have already served the callup notice for their exposure. Therefore instead of structured repayment schedule theentire exposure of the banks/ financial institution has fallen due on immediate basis.

ix. To the best of our knowledge and belief and according to the information andexplanations given to us during the year the Company did not avail any term loan facilityfrom bank or financial institution. Also Company did not raise any money by way ofinitial public offer or further public offer (including debt instruments) during the year.

x. According to the information and explanations given to us no material fraud by theCompany or on the Company by its officers or employees has been noticed or reported duringthe course of our audit.

xi. According to the information and explanation given by the management the companyhas not paid remuneration over and above the limits prescribed under section 197 readwith Schedule - V of the act to executive director.

xii. In our opinion and according to the information and explanations given to us theCompany is not a Nidhi company. Accordingly paragraph 3(xii) of the Order is notapplicable.

xiii. According to the information and explanations given to us and based on ourexamination of the records of the Company transactions with the related parties are incompliance with sections 177 and 188 of the Act where applicable and details of suchtransactions have been disclosed in the financial statements as required by the applicableIndian Accounting Standards.

xiv. The Company has made preferential allotment of shares during the year under reviewand the requirement of Section 42 has been complied with. The shares have been issued aspart of arrangement of assignment of debts to an Asset reconstruction company andaccordingly no amount has been raised out of such issue of shares.

xv. According to the information and explanations given to us and based on ourexamination of the records of the Company the Company has not entered into non-cashtransactions with directors or persons connected with them and hence provisions of section192 of companies Act 2013 are not applicable to the company.

xvi. The Company is not required to be registered under section 45-IA of the ReserveBank of India Act 1934.

For S. K. AGRAWAL & CO.
Chartered Accountants
Firm's Registration No-306033E
0. K. CHOUDHURY)
Partner
Place: Kolkata Membership No: 009367
Dated : July 312020 UDIN:20009367AAAADB7735

.