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Jaiprakash Associates Ltd.

BSE: 532532 Sector: Infrastructure
NSE: JPASSOCIAT ISIN Code: INE455F01025
BSE 00:00 | 21 Oct 9.25 0.30
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8.94

NSE 00:00 | 21 Oct 9.25 0.30
(3.35%)
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OPEN 9.09
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VOLUME 703008
52-Week high 15.90
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Mkt Cap.(Rs cr) 2,271
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Sell Price 0.00
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OPEN 9.09
CLOSE 8.95
VOLUME 703008
52-Week high 15.90
52-Week low 3.29
P/E
Mkt Cap.(Rs cr) 2,271
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

Jaiprakash Associates Ltd. (JPASSOCIAT) - Auditors Report

Company auditors report

TO THE MEMBERS OF JAIPRAKASH ASSOCIATES LIMITED

Report on the Audit of the Standalone Financial Statements Qualifiedopinion

We have audited the Standalone Financial Statements of JaiprakashAssociates Limited ("the Company") which comprise the Standalone Balance Sheetas at 31 March 2020 and the Standalone Statement of Profit and Loss (including othercomprehensive income) Standalone Statement of Changes in Equity and Standalone Statementof Cash Flows for the year then ended and Notes to the Standalone Financial

Statements including a summary of significant accounting policies andother explanatory information.

In our opinion and to the best of our information and according to theexplanations given to us except for the possible effects of the matter described in theBasis for Qualified Opinion paragraph the aforesaid Standalone Financial Statements givethe information required by the Companies Act 2013 ("the Act") as amended inthe manner so required and give a true and fair view in conformity with the accountingprinciples generally accepted in India of the state of affairs of the Company as at March31 2020 the loss (including other comprehensive income) change in equity and its cashflows for the year ended on that date.

Basis of Qualified opinion Attention is drawn to:

Refer Note No. 44 of audited Standalone Financial Statements theinsolvency petition filed by the IDBI with the National

Company Law Tribunal (‘NCLT') Allahabad against the JaypeeInfratech Limited (‘JIL') (Subsidiary of the Company) was admitted and InterimResolution Professional (‘IRP') was appointed by the NCLT. The Hon'bleSupreme Court of India also admitted the Petition/Intervention filed by certain homebuyers of JIL and gave various interim directions from time to time including continuationof Corporate Insolvency Resolution Process (‘CIRP').

The NCLT New Delhi Principal Bench approved the Resolution

Plan (with modification) of NBCC (India) Limited on 03.03.2020 wherebyas per the scheme approved by NCLT the company's investment in equity of JIL bereduced to Nil and also decided that deposit of Rs. 750 crores made by JaiprakashAssociates Limited shall be utilized with interest for the cause of the creditors ofCorporate Debtor meaning thereby not to be refunded to the Company. The Company has filedthe appeal on 12.03.2020 before the NCLAT against the inclusion of the deposit withinterest as part of the resolution plan. In view of the order of the NCLT the companyshould have made the provision of Rs. 849.26 Crores as diminution in value of theinvestment in equity of JIL and deposit of Rs. 750 Crores.

However the company has not made provisions in the books for theamount of said investment and amount of deposit total aggregating to Rs. 1599.26 crores.Had these provisions been made the Loss would have been increased to that extent.

Matters stated above have also been qualified in our report inpreceding years.

We conducted our audit in accordance with the Standard on Auditing(SAs) specified under section 143(10) of the

Act. Our responsibilities under those Standards are further describedin the Auditor's Responsibilities for the Audit of the Standalone FinancialStatements section of our report. We are independent of the Company in accordance with theCode of Ethics issued by Institute of Chartered Accountants of India (‘ICAI')together with the ethical requirements that are relevant to our audit of the financialstatements under the provisions of the Act and Rules thereunder and we have fulfilled ourother ethical responsibilities in accordance with these requirements and the Code ofEthics. We believe that the evidence we have obtained is sufficient and appropriate toprovide a basis for our qualified opinion.

Emphasis of matter:

We draw attention to the following matters:

1. Refer Note No. 31 [d] [i] & [ii] of audited Standalone FinancialStatements a. The Competition Commission of India (‘CCI') vide its Order dated31st August 2016 held various cement manufacturers liable for alleged contravention ofcertain provisions of the Competition Act 2002 during F.Y. 2009-10 & 2010-11 andinteralia imposed a penalty of Rs. 1323.60 Crores on the Company. The

Company had filed an Appeal against the said Order which was heard onvarious dates by Hon'ble National Company Law Appellate Tribunal (NCLAT). NCLAT videits Order dated 25th July 2018 has rejected the appeals of all the cement manufacturersincluding that of the Company without interfering in the penalty though if calculated onthe basis of profits earned by the Cement business the same would have been Rs. 237.70Crores only as against the penalty of

Rs. 1323.60 Crores calculated on the profits for all business segmentsof the Company. The Company and other affected cement manufacturers have filed appeal withthe Hon'ble Supreme Court and the case has since been admitted with the directionsthat the interim Order passed earlier by NCLAT in the matter will continue in themeantime. The Company's request for rectification of Demand Notice was declined byCCI and the Company has filed a review application before Hon'ble NCLAT against thesaid rejection by CCI which matter is still pending.

b. The Competition Commission of India vide its other order dated 19thJanuary 2017 held various cement manufacturers liable for alleged contravention ofcertain provisions of the Competition Act 2002 in the State of Haryana during F.Y.2012-13 to F.Y. 2014-15 and interalia imposed a penalty of Rs. 38.02 Crores on the Companybased on criteria of average turnover of the Company as a whole as against the‘relevant turnover' of ‘Cement Division'. The Company had filed anappeal against the said Order before NCLAT which has stayed the operation of impugnedorder and further proceedings are progressing in the matter. Based on the advice of theCompany's counsels the Company believes that it has reasons to succeed in appeal inthe above cases. Hence no provision is considered necessary in the financialsof thecompany.

2. Refer Note No. 38 of audited Standalone Financial Statements YesBank Limited (‘YBL') / Assets Care and Reconstruction Enterprise Limited (ACRE)invoked entire pledged equity share 280966000 of Rs. 10/- each of Bhilai Jaypee CementLimited (‘BJCL') (a subsidiary of the company) and also recalled outstandingloan and invoked corporate guarantee and shortfall undertaking given by the companyagainst the loan facility of Rs. 465 Crores and Rs. 45 Crores to JCCL a wholly ownedsubsidiary of the company. YBL assigned the same in favour of Assets Care andReconstruction Enterprise Limited (‘ACRE') The ACRE informed about the transferof the entire pledged/NDU share of BJCL in its name. However the company is contesting theassignment on the basis of the fact that these facilitates has been covered under theComprehensive Reorganization & Re-structuring Plan (CRRP) of Company & JaypeeCement Corporation Limited (‘JCCL') duly approved by the consortium of lendersincluding YBL at its meeting held on 22nd June 2017 and subsequently YBL signed MasterRe-structuring Agreement (‘MRA') through deed of accession. Hence the carryingvalue of above said equity share of BJCL and 752 Equity Shares held in the name of nomineeshareholders continue to be included as part of Non-Current investment of the company inthe Standalone Balance Sheet.

BJCL has incurred cash losses in the current year as well as in thepast years and its Net worth has been fully eroded. However based on valuation reportfrom independent Valuer on the assets of BJCL the management believes that the realizableamount is higher than the carrying value of the Non-Current Investment aggregating to Rs.407.72 Crores and receivable Rs. 507.30 Crores and as such these are considered good andrecoverable.

3. Refer Note No. 39 of audited Standalone Financial Statements YesBank Limited /Suraksha Assets Reconstruction Private Limited (‘ARC') has invokedpledged of 50000 Equity shares of Rs 10/- each of Yamuna Expressway Tolling Limited(subsidiary Company) held by the Company. The company is contesting the invocation by thelenders. Pending settlement with the Lender/ARC the company continues to show the aboveinvestments as non-current at cost.

4. Refer Note No. 40 of audited Standalone Financial Statements lenderof MP Jaypee Coal Limited (‘MPJPCL') has invoked the corporate guarantee givenby the

Company for financial assistance granted to MPJPCL and served a noticeto the company to make payment of Rs. 25.75 Crores outstanding as on 31st August 2018Rs. 22.89 Crores outstanding as on 31.03.2020 (previous years Rs. 22.24 crores). Howeverthe liability has not been considered in the books of accounts as the Coal Block forwhich Mining Rights are held by MPJPCL is yet to be re-allotted by the NominatedAuthority.

5. Refer Note No. 41 of audited Standalone Financial Statements lenderof Jaypee Cement Corporation Limited (‘JCCL') (subsidiary company) has invokedthe corporate guarantee given by the company for financial assistance being granted toJCCL and asked to make payment for Rs. 438.36 Crores and Rs. 20.79 Crores being amountoutstanding as on 09.09.2018. However the liability has not been considered in the booksof accounts as the loan in question is part of approved Comprehensive Reorganization& Restructuring plan of JCCL and the Company. The company has made Non-CurrentInvestment in equity of JCCL of Rs.1454.71 Crores.

The Subsidiary has incurred cash loss during the last few years and itsNet worth has been fully eroded. However based on report from independent professional inview of the management the fair market value of the assets of the JCCL is higher thantheir carrying value as such no provision for impairment in the carrying value of theinvestment is required.

6. Refer Note No. 42 of audited Standalone Financial StatementsNon-Current Trade receivables includes Rs. 2579.95 Crores outstanding as at March 312020 (Rs. 2661.34 Crores outstanding as at 31st March 2019) which represents variousclaims raised on the Clients based on the terms and conditions implicit in the Engineering& Construction Contracts in respect of closed/suspended/ under construction projects.These claims are mainly in respect of cost over run arising due to suspension of worksclient caused delays changes in the scope of work deviation in design and other factorsfor which company is at various stages of negotiation/ discussion with the clients orunder Arbitration/ litigation. On the basis of the contractual tenability progress ofnegotiations/ discussions/ arbitration/ litigations the management considers thesereceivables are recoverable.

7. Refer Note No. 50 of audited Standalone Financial

Statements the Confirmations/ Reconciliation of balances of secured& unsecured loans certain balances with banks including certain fixed deposits tradereceivables trade and other payables and loans and advances are pending.

The management is confident that on confirmation/ reconciliation therewill not be any material impact on the Standalone Financial Statements.

8. Refer Note No. 43 of audited Standalone Financial Statements thecompany has made a Non-Current Investment of Rs. 340 Crores (34 crores Equity Shares ofRs. 10/- each fully paid up) in Prayagraj Power Generation Company limited(‘PPGCL') (earlier an associate company). Lenders of PPGCL has invoked theentire pledged share of PPGCL held by Jaiprakash Power Ventures Limited (‘JPVL')(then Holding Company of PPGCL) on 18th December 2017 due to default in payment toBanks/Financial Institutions. After obtaining various approvals / documentation etc. theLenders have affected change in Management in favour of Renascent Power Ventures PrivateLimited. Post change of Management and various restructuring effects fair value of sharesheld the company in PPGCL is not available therefore currently the carrying value hasbeen reduced to book value of

PPGCL as per financials of PPGCL as on 30th September

2019 available to the company.

9. Refer Note No. 46 of audited Standalone Financial Statements; thecompany has made investment in equity shares (Quoted) of Rs. 1742.62 Crores in JaiprakashPower Ventures Limited (‘JPVL') an associate company (earlier subsidiary) of thecompany. JPVL has signed a ‘Framework Agreement' on 18th April 2019 with theBanks andFinancialInstitutionsforrestructuringoftheoutstanding Loans and Interest.Accordingly JPVL has issued fully paid 0.01% Cumulative Compulsory Convertible PreferenceShares amounting to Rs 3805.53 crores on 23.12.2019 and fully paid 9.50% CumulativeRedeemable Preference Shares for Rs. 34.52 crores to their Lenders in December 2019.Further JPVL has issued 492678462 equity shares of Rs. 10/- each to FCCB Holders atRs. 12/- per equity share and 351769546 equity shares of Rs. 10/- each to JSW EnergyLimited at par against their outstanding liabilities as per agreed terms.

Considering the implementation of Debt Resolution Process valuation ofassets of JPVL conversion of outstanding dues of FCCB holders and JSW Energy Limited andfurther better prospects no diminution is envisaged by the management in the carryingvalue in the Standalone Financial Statements on the basis of quoted share price of JPVLbeing less than the carrying value. 10. Refer Note No. 48 of audited Standalone FinancialStatements in the opinion of the management in the case of loss making segments of thecompany no impairment in the assets of the segment is required in view of temporary natureof the losses Valuation report circle rates of the immovable property and future cashflows which are higher than the carrying value of the assets.

11. Refer Note No. 49 of audited Standalone Financial Statements theCompany has received Termination Notice for the Mandla North Coal Mine allotted byNominated Authority Ministry of Coal on account of not meeting eligibility criteriamentioned in the Coal Mines Development and Production Agreement along with instructionsfor invocation of the Bank Guarantee submitted by the company in the form of PerformanceSecurity. The Hon'ble High Court has granted stay against the Termination Notice andinvocation of Performance Guarantee. Since the matter is now being sub-judice in the HighCourt the recoverability of the amount invested aggregating to Rs. 295.80 Crores as on31.03.2020 in the development of the Coal Block and impact of the invocation of thePerformance Guarantee is uncertain as such no provision has been considered necessary tobe made in the Standalone Financial Statements by the management.

12. Refer Note No. 52 of audited Standalone Financial StatementsDuring the year the Company has made payment to its Managerial Personnel in terms oftheir respective appointments and within the limits prescribed under the Companies Act2013 ("the Act"). In view of default in repayment of principal and/or interestto Banks and Financial Institutions during the current year the remuneration paid to ShriPankaj Gaur Joint Managing Director (Construction) for the period from 1st April 2019 to30th June 2019 and Shri Sunny Gaur Managing Director (Cement) for the period from 1stApril 2019 to 30th December 2019 based on the approval of NRC & Board the approvalof lenders has been sought whereafter the shareholders' approval shall be obtained.

As reported earlier the appointment and remuneration of Shri RahulKumar the then Whole time director and CFO (for the period from 31.10.2015 to 30.10.2018)was rejected by MCA vide letter dated 27.12.2017 on account of non-recovery ofremuneration paid to 8 managerial personnel (for the year 2014-15 and 2015-16 (upto31.10.2015).

The Company sought clarifications from Ministry of Corporate Affairs(MCA). In view of Clarification from MCA the recovery of remuneration from the said 8KMPs is not required who were appointed at a time when the Company was in profits andthere were no defaults. Accordingly no further action is required in respect of theremuneration paid to the said 8 KMPs during the year 2014-15 and 2015-16 (upto31.10.2015).

As regards waiver of recovery of remuneration paid to Shri Rahul Kumarthe then Whole-time Director & CFO in view of the clarification/ confirmation givenby the

MCA the reason for rejection of application for approval ofappointment and remuneration of Shri Rahul Kumar as given by MCA does not survive. Inview of amended provisions the power to approve remuneration/ waiver of recovery ofremuneration stands transferred and vested in the shareholders with prior approval of thelenders. Accordingly the Company has approached the lenders through their lead lender toaccord approval/no-objection for the said waiver of recovery of remuneration which isawaited post which the Company shall seek approval of the shareholders.

13. Refer Note No. 55 of audited Standalone Financial Statements thereare certain Entry tax matters under Appeals aggregating to Rs. 297.82 Crores (excludinginterest currently unascertainable) pertaining to the State of Madhya Pradesh andHimachal Pradesh. The Company has challenged these on account of various grounds inHon'ble High Courts. No provision has been considered of the above in the StandaloneFinancial Statements as management is of the opinion that the Company will succeed in theappeal. The Company has already deposited Rs.166.79 Crores and also furnished BankGuarantees of Rs. 125.43 Crores against the above.

14. Refer Note No. 53 of audited Standalone Financial Statements theLenders of the company in their Joint Lenders Forum (‘JLF') meeting held on 22ndJune 2017 have approved restructuring / realignment/ reorganization of debt of theCompany & its wholly owned subsidiary Jaypee Cement Corporation Limited(‘JCCL') being Restructuring Scheme.

The company has provided interest expenses on the debt portion thatwill remain with the company in accordance with the Restructuring Scheme approved andMaster Restructuring Agreement (‘MRA') signed with the Lenders. Interest for theyear ended March 31 2020 aggregating to Rs. 1072.64 crores and Rs. 2968.15 crores tillMarch 31 2020 on debt portion which will be transferred to Real Estate SPV namely‘Jaypee Infrastructure Development Limited' (‘JIDL') on sanction ofthe scheme of Arrangement by Hon'ble National Company Law Tribunal(‘NCLT') Allahabad with appointed date of 1st July 2017 has been added to thecarrying cost of the Inventory/ Projects under development in respect of SDZ Real EstateUndertaking (‘SDZ-RE') since the same has to be serviced from theassets/development of Assets of SDZ-RE.

However before the order on the above restructuring scheme by theHon'ble NCLT ICICI Bank Limited on the direction of RBI had filed an applicationwith Hon'ble

NCLT Allahabad bench U/s 7 of Insolvency & Bankruptcy Code 2016against the company which is pending. On restructured loan the company has also defaultedin the payment of interest and principal for the financial year 2018-2019 and 2019-2020.

As such till the decision of the Hon'ble NCLT on restructuringand/or application u/s 7of Insolvency & Bankruptcy Code 2016 and furtheraction/restructuring by the lenders on this account there remains uncertainty and as suchits impact on the financials of the company is not ascertainable.

15. Refer Note No. 54 of audited Standalone Financial Statements whichdescribe the uncertainties and the impact of Covid-19 pandemic on the Company'soperations and results as assessed by the management. Further due to Covid-19 related lockdown restrictions management was able to perform year end physical verification ofinventory at certain locations subsequent to the year end. Also we are not able tophysically observe the verification of inventory that was carried out by the management.Consequently we have performed alternative procedures to audit the existence of Inventoryas per the guidance provided in SA-501 "Audit Evidence-

Specific Consideration for Selected Items" and have obtainedsufficient audit evidence.

Our opinion is not modified in respect of above stated matters in para(1) to (15).

Key Audit Matters

Key audit matters are those matters that in our professional judgmentwere of most significance in our audit of the standalone financial statements of thefinancial year ended

March 31 2020. These matters were addressed in the context of ouraudit of the financial statements as a whole and in forming our opinion thereon and wedo not provide a separate opinion on these matters.

In addition to the matter described in the Basis for Qualified

Opinion section we have determined the matters described below to bethe key audit matters to be communicated in our report. For each matter below ourdescription of how our audit addressed the matter is provided in that context:

1. Revenue recognition from Construction Contracts
Key audit matter description The Company recognises revenue on the basis of stage of completion based on the proportion of contract costs incurred relating to the total costs of the contract at completion. Thus the recognition of revenue is based on estimates in relation to total estimated costs of each contract and cost incurred.
There are significant accounting judgments which includes estimates of cost of completion of the Contract the stages of completion and timing of revenue recognition. Estimates also takes into account various contingencies in the contracts & uncertain risks disputed claims against the company relating to different contract which are reviewed by the management on a regular basis over the contract life and adjusted appropriately.
The revenue on contracts may also include variable consideration (variations and claims). Variable consideration is recognised when the recovery of such consideration is probable.
Refer to Note Number 1 Significant Accounting Policies of the Standalone Financial Statements- ‘Revenue from contracts with customers- Revenue from construction and other contracts'
Principal Audit Procedures Our procedures included :
• Assessing the appropriateness of the Company's revenue recognition accounting policies in line with Ind AS 115 and testing thereof.
• Assessed the appropriateness of the estimates used as well as their operating effectiveness;
• Selection of sample of contracts for appropriate identification of performance obligations;
• For the sample selected reviewing for change orders and the impact on the estimated costs to complete;
• Discussion with the qualified & experienced project personnel regarding estimates of costs to complete for sample contracts determination of milestones various inherent contingencies in the contracts & reasonableness of revenue disclosures
2. Evaluation of Uncertain Direct Tax positions Key audit matter description The Company has material direct tax matters under dispute which involves significant judgment to determine to Note Number 31[c] of the Standalone Financial Statements
Principal Audit Procedures Our procedures included the following:
• Obtained details of key uncertain tax matters;
• Obtained details of completed tax assessments and demands till March 31 2020 and details of assessments in Appeal;
• Discussed with appropriate senior management and evaluated the Management's underlying key assumptions in estimating the tax provision;
• Assessed management's estimate of the possible outcome of the disputed cases and considered legal precedence and other rulings in evaluating management's position on these uncertain tax positions.

Information Other than the Standalone Financial Statements andAuditor's Report Thereon

The Company's Board of Directors is responsible for thepreparation of the other information. The other information comprises the informationincluded in Management Discussion and Analysis Board's Reports including Annexure toBoard Report Business Responsibility Report Corporate Governance and ShareholderInformation but does not includes the standalone financial statements and auditor'sreport thereon.

Our opinion on the standalone financial statement does not cover theother information and we do not express any form assurance conclusion thereon.

In connection with our audit of the standalone financial statement ourresponsibility is to read the other information and in doing so consider whether theother information is materially inconsistent with the standalone financial statements orour knowledge obtained during the course of our audit or otherwise appears to bematerially misstated.

If based on our work we have performed we conclude that there is amaterial misstatement of this other information we are required to report that fact. Wehave nothing to report in this regard.

Management's Responsibility for the Standalone FinancialStatements

The Company's Board of Directors is responsible for the mattersstated in Section 134(5) of the Act with respect to the preparation of these standalonefinancial statements that give a true and fair view of the financial position financialperformance (including other comprehensive income)

changes in equity and cash flows of the Company in accordance withthe accounting principles generally accepted in India including the Indian AccountingStandards (Ind AS) specified under Section 133 of the Act. This responsibility alsoincludes maintenance of adequate accounting records in accordance with the provisions ofthe Act for safeguarding of the assets of the Company and for preventing and detectingfrauds and other irregularities; selection and application of appropriate accountingpolicies; making judgments and estimates that are reasonable and prudent; and designimplementation and maintenance of adequate internal financial controls that were operatingeffectively for ensuring the accuracy and completeness of the accounting records relevantto the preparation and presentation of the standalone financial statements that give atrue and fair view and are free from material misstatement whether due to fraud or error.

In preparing the standalone financial statements management and Boardof Directors are responsible for assessing the Company's ability to continue as agoing concern disclosing as applicable matters related to going concern and using thegoing concern basis of accounting unless management either intends to liquidate theCompany or to cease operations or has no realistic alternative but to do so.

Those Board of Directors are also responsible for overseeing theCompany's financial reporting process.

Auditor's Responsibility for the Standalone Financial Statements

Our objectives are to obtain reasonable assurance about whether thestandalone financial statements as a whole are free from material misstatement whetherdue to fraud or error and to issue an auditor's report that includes our opinion.Reasonable assurance is a high level of assurance but is not a guarantee that an auditconducted in accordance with SAs will always detect a material misstatement when itexists. Misstatements can arise from fraud or error and are considered material ifindividually or in the aggregate they could reasonably be expected to influence theeconomic decisions of users taken on the basis of these standalone financial statements.

As part of an audit in accordance with SAs we exercise professionaljudgment and maintain professional skepticism throughout the audit. We also:

• Identify and assess the risks of material misstatement of thestandalone financial statements whether due to fraud or error design and perform auditprocedures responsive to those risks and obtain audit evidence that is sufficient andappropriate to provide a basis for our opinion. The risk of not detecting a materialmisstatement resulting from fraud is higher than for one resulting from error as fraudmay involve collusion forgery intentional omissions misrepresentations or the overrideof internal control.

• Obtain an understanding of internal control relevant to theaudit in order to design audit procedures that are appropriate in the circumstances. UnderSection 143(3) (i) of the Act we are also responsible for expressing our opinion onwhether the company has adequate internal financial controls with reference to standalonefinancial statements 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 thegoing concern basis of accounting and based on the audit evidence obtained whether amaterial uncertainty exists related to events or conditions that may cast significantdoubt on the Company's ability to continue a going concern. If we conclude that amaterial uncertainty exists we are required to draw attention in our auditor'sreport to the related disclosures in the standalone 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 auditors' 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 thestandalone financial statements including the disclosures and whether the standalonefinancial statements represent the underlying transactions and events in a manner thatachieves fair presentation.

We communicate with those charged with governance regarding amongother matters the planned scope and timing of the audit and significant audit findingsincluding any significant deficiencies in internal control that we identify during ouraudit.

We also provide those charged with governance with a statement that wehave complied with relevant ethical requirements regarding independence and tocommunicate with them all relationships and other matters that may reasonably be thoughtto bear on our independence and where applicable related safeguards.

From the matters communicated with those charged with governance wedetermine those matters that were of most significance in the audit of the standalonefinancial statements of the current period and are therefore the key audit matters. Wedescribe these matters in our auditors' report unless law or regulation precludespublic disclosure about the matter or when in extremely rare circumstances we determinethat a matter should not be communicated in our report because the adverse consequences ofdoing so would reasonably be expected to outweigh the public interest benefits of suchcommunication.

Other Matter

Due to the COVID-19 pandemic and the lockdown and other restrictionsimposed by the Government and local administration the audit process were carried outbased on the remote access to the extent available/feasible and necessary records madeavailable by the management.

Report on Other Legal and Regulatory Requirements

1. As required by the Companies (Auditor's Report) Order 2016(‘the order') issued by the Central Government of India in terms of Sub Section(11) of Section 143 of the Act we give in the Annexure a statement on the mattersspecified in paragraph 3 & 4 of the Order to the extent applicable.

2. As required by Section 143(3) of the Act we report that: a) We havesought and except for the possible effects of the matter described in the Basis ofQualified

Opinion given above obtained all the information and explanationswhich to the best of our knowledge and belief were necessary for the purposes of ouraudit. b) Except for the possible effects of the matter described in the Basis ofQualified Opinion given above in our opinion proper books of account as required by lawhave been kept by the Company so far as it appears from our examination of those books. c)The Balance Sheet the Statement of Profit and Loss

(including other comprehensive income) the Cash Flow Statement and theStatement of Changes in Equity dealt with by this Report are in agreement with the booksof account. d) Except for the possible effects of the matter described in the Basis ofQualified Opinion given above in our opinion the aforesaid standalone financialstatements comply with the Ind AS specified under Section 133 of the Act read with Rule 7of the Companies (Accounts) Rules 2014. e) The matter described in the ‘Basis ofQualified Opinion' and ‘Emphasis of Matter' given above in our opinion mayhave an adverse effect on the functioning of the Company. f) On the basis of writtenrepresentations received from the directors as on 31st March 2020 taken on record by theBoard of Directors none of the directors is disqualified as on 31st March 2020 frombeing appointed as a director in terms of Section 164(2) of the Act. g) With respect tothe adequacy of the internal financial controls over financial reporting of the companyand the operating effectiveness of such controls refer to our separate Report in Annexure"A". Our report expresses a qualified opinion on the adequacy and operatingeffectiveness of the Company's internal financial controls over financial reporting.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 wereport that: i. The Company has disclosed the impact of pending litigations as at 31 March2020 on its financial position in its standalone financial statements - Refer Note 31 tothe standalone financial statements. ii. The Company did not have any long-term contractsincluding derivative contracts for which there were any material foreseeable losses. iii.There has been no delay in transferring amounts required to be transferred to theInvestor Education and Protection Fund by the Company during the year ended March 312020.

3. With respect to the matter to be included in the Auditors'Report under section 197(16) of the Act: Refer Note No. 52 of audited Standalone FinancialStatements During the year the Company has made payment to its Managerial Personnel interms of their respective appointments and within the limits prescribed under theCompanies Act 2013 ("the Act"). In view of default in repayment of principaland/or interest to Banks and Financial Institutions during the current year theremuneration paid to Shri Pankaj Gaur Joint Managing Director (Construction) for theperiod from 1st April 2019 to 30th June 2019 and Shri Sunny Gaur Managing Director(Cement) for the period from 1st April 2019 to 30th December 2019 based on the approvalof NRC & Board the approval of lenders has been sought whereafter theshareholders' approval shall be obtained.

As reported earlier the appointment and remuneration of Shri RahulKumar the then Whole time director and CFO (for the period from 31.10.2015 to 30.10.2018)was rejected by MCA vide letter dated 27.12.2017 on account of non-recovery ofremuneration paid to 8 managerial personnel (for the year 2014-15 and 2015-16 (upto31.10.2015).

The Company sought clarifications from Ministry of Corporate Affairs(MCA). In view of Clarification from MCA the recovery of remuneration from the said 8KMPs is not required who were appointed at a time when the Company was in profits andthere were no defaults. Accordingly no further action is required in respect of theremuneration paid to the said 8 KMPs during the year 2014-15 and 2015-16 (upto31.10.2015).

As regards waiver of recovery of remuneration paid to Shri Rahul Kumarthe then Whole-time Director & CFO in view of the clarification/ confirmation givenby the

MCA the reason for rejection of application for approval ofappointment and remuneration of Shri Rahul Kumar as given by MCA does not survive. Inview of amended provisions the power to approve remuneration/ waiver of recovery ofremuneration stands transferred and vested in the shareholders with prior approval of thelenders. Accordingly the Company has approached the lenders through their lead lender toaccord approval/no-objection for the said waiver of recovery of remuneration which isawaited post which the Company shall seek approval of the shareholders.

For Rajendra K. Goel & Co.
Chartered Accountants
F. R. N.: 001457N
R K Goel
Partner
M. No.: 006154
Place: New Delhi
Date: 27.05.2020
UDIN: 20006154AAAABS3396

ANNEXURE TO THE INDEPENDENT AUDITORS' REPORT

(Referred to in paragraph 1 under ‘Report on Other Legal andRegulatory Requirements' section of our report of even date) i. a) The Companyhas maintained proper records showing full particulars including quantitative details andsituation of fixed assets. The situation of the moveable assets used in the constructionactivity keeps on changing from works sites depending upon requirements for a particularcontract.

b) The Company has a regular programme of physical verification of itsfixed assets by which substantial assets are verified in a phased manner. In our opinionthis periodicity of physical verification is reasonable having regard to the size of theCompany and the nature of its assets. Pursuant to the programme fixed assets werephysically verified by the Management during the year. According to the information andexplanations given to us no material discrepancies were noticed on such verification.

c) According to the information and explanations given to us and therecords examined by us we report that other than the immovable properties acquired onamalgamations with the Company as per schemes approved by the Hon'ble High Courts inearlier years the title deeds are held in the name of the Company as at the balance sheetdate.

ii. The inventory except for goods-in-transit has been physicallyverified by the management at reasonable intervals during the year. In our opinion thefrequency of such verification is reasonable. In respect of goods-intransit subsequentgoods receipts have been verified or confirmations have been obtained from the parties.The discrepancies noticed on verification between the physical stocks and the book recordswere not material.

iii. In our opinion and according to the information and explanationsgiven to us the Company has not granted any amount in the nature of loans secured orunsecured to Companies Firms Limited Liability Partnerships or Other Parties covered inthe register maintained under Section 189 of the Act. Accordingly paragraph 3(iii) of theOrder is not applicable to the Company. iv. In our opinion and according to theinformation and explanations given to us the Company has generally complied with theprovisions of Sections 185 and 186 of the Act with respect to the loans giveninvestments made guarantees given and security provided except interest free unsecuredloan given to Himalayan Expressway Limited (a wholly owned subsidiary) before commencementof Companies Act 2013.

v. In our opinion and according to the information and explanationsgiven to us the Company has not accepted any deposit from the public during the year. TheCompany has generally complied with the provisions of Sections 73 to 76 or any otherrelevant provisions of the Companies Act 2013 read with the Orders issued by theHon'ble National Company Law Tribunal (NCLT) from time to time; however there havebeen delays in repayment of matured public deposits aggregating to Rs 14 Lakhs (includinginterest) which had matured for repayment before the balance sheet date which are pendingrepayment due to directions by the Government authorities/ courts etc. Further there arecertain payments which have not been en-cashed by certain deposit holders however suchamounts are being reflected in earmarked accounts as per requirements of the Act. Companyis yet to file return of deposit i.e. DPT-3 for the financial year 2018-19. howevermanagement assure that the form DPT-3 for the Financial Year 2018-19 will be filed underCOMPANIES FRESH START SCHEME 2020 (CFSS-2020). vi. We have broadly reviewed the books ofaccount maintained by the Company as specified under Section 148(1) of the Act formaintenance of cost records in respect of products manufactured by the Company and are ofthe opinion that prima facie the prescribed accounts and records have been made andmaintained. However we have not made a detailed examination of the cost records with aview to determine whether they are accurate or complete.

vii. a) Undisputed statutory dues including Provident FundEmployees' State Insurance Income-tax Sales tax Service tax Customs Duty ExciseDuty Value Added Tax Cess Goods and Services Tax and other material statutory dues asapplicable have not been regularly deposited with the applicable authorities and therehave been significant delays in a large number of cases. Undisputed amounts payable inrespect thereof which were outstanding at the year end for a period of more than sixmonths from the date they became payable as follows:

Particulars of Dues Rs.(in Lakhs)
Royalty Payable (Including Interest) 1825.28
District & National Mineral Foundation Payable (Including Interest) 911.79
Building Cess 251.76
Electricity Duty Payable (Including Interest) 10371.33
TDS/TCS Payable 923.08
Sales Tax/Entry Tax/ Service Tax/ GST Payable (Including Interest) 9953.91

b) As per records produced before us and explanations given to us andon the basis of our examination of the records of the Company details of dues ofIncome-tax Sales-tax Service tax Duty of Customs Duty of Excise and Value added taxwhich have not been deposited as on 31 March 2020 on account of disputes are given below:

[Rs. in Lakhs]
Forum where dispute is pending
Name of Statute (Nature of dues) Period to which amount relates Commissionarate Appellate authorities Tribunal High Court Supreme Court Total
Central Excise 1987-88 to 1991-92 1994-1995 1997-98 to 2017-18 4555.23 0 0 0 4555.23
1996-97 to 1997-98 2006-07 to 2016-17 0 2478.47 0 0 2478.47
2000-01 to 2001-02 2004-05 to 2008-09 0 0 575.73 0 575.73
Sales Tax/VAT 2001-02 2006-07 to 2016-17 3691.12 0 0 0 3691.12
1999-00 2004-05 to 2014-15 0 926.44 0 0 926.44
2001-02 to 2007-08 2010-11 to 2017-18 0 0 10074.34 0 10074.34
2001-02 to 2007-08 0 0 0 9029.24 9029.24
Entry Tax 2000-01 2014-15 to 2016-17 341.27 0 0 0 341.27
2006-07 to 2007-08 2010-11 to 2012-13 2014-15 0 528.28 0 0 528.28
2001-02 2007-08 to 2017-18 0 0 15824.16 0 15824.16
Service Tax 1997-98 to 1999-00 26.60 0 0 0 26.60
2010-11 to 2014-15 0 567.09 0 0 567.09
1997-98 to 1998-99 0 0 129.46 0 129.46
Custom duty 2007-08 2010-11 700.00 0 0 0 700.00
2005-06 to 2007-08 0 4595.21 0 0 4595.21
TDS AY 2019-20 1.04 0 0 0 1.04
AY 2008-09 to AY 2011-12 and 2014-15 0 0 9053.05 0 9053.05
AY 2012-13 and AY 2013-14 0 0 0 8443.38 8443.38
Income Tax AY 2012-13 38.76 0 0 0 38.76

Note: Net of Amount deposit under protest. However above amounts arewithout reducing Bank Guarantees. viii. Based on our audit procedures and on theinformation and explanations given by the management we are of the opinion that duringthe year the Company has defaulted in repayment of principal and/or interest to banksfinancial institutions & privately placed debenture-holders wherein the period ofdelay ranges from 1 day to 1400 days.

The overdue interest on borrowings amounts to Rs. 73198.90 lacs asreflected in the standalone Ind AS financial statements which were outstanding as at 31stMarch 2020.

The overdue principal repayments of borrowings amounts to Rs. 97542.48lacs as reflected in the standalone Ind AS financial statements which were outstanding asat 31st March 2020. Lender wise details for overdue interest & overdue principalrepayments are given below:

Name of Bank/FI/Debenture holders Overdue Principal repayments as at 31.03.2020 (Rs. in lacs) Period of default for overdue principal repayments Overdue Interest as at 31.03.2020 (Rs. in lacs) Period of default for overdue interest
Allahabad Bank 88.44 1 - 548 208.86 1 - 578
Andhra Bank 334.57 1 - 548 822.15 1 - 425
Axis Bank 1189.18 1 - 548 2024.55 1 - 578
Bank of Baroda 300.23 1 - 548 756.71 1 - 425
Bank of India 74.48 1 - 548 270.47 1 - 578
Bank of Maharashtra 449.38 1 - 548 1620.62 1 - 1005
Canara Bank 4033.75 1 - 821 1995.69 1 - 578
Central Bank of India 18.68 1 - 548 41.56 1 - 578
Corporation Bank 33.51 1 - 548 183.41 1 - 578
Dena Bank 3.79 1 - 548 5.63 1 - 336
Export Import Bank of India 869.38 1 - 548 1852.59 1 - 487
ICICI Bank Ltd 4800.10 1 - 548 13075.43 1 - 578
IDBI Bank Limited 1579.66 1 - 548 4646.93 1 - 578
IFCI Limited 1121.17 1 - 548 1959.70 1 - 578
Indian Bank 319.90 1 - 548 790.10 1 - 425
Indusind Bank Limited 666.67 1 - 275 1121.10 1 - 578
Lakshmi Vilas Bank 18.00 1 - 548 198.07 1 - 578
LIC of India 1226.57 1 - 548 3015.30 1 - 578
Oriental Bank of Commerce 1332.43 1 - 548 263.67 1 - 578
Punjab National Bank 445.24 1 - 548 916.24 1 - 487
Punjab And Sind Bank 10729.12 1 - 548 2809.51 1 - 578
SIDBI 5707.36 1 - 548 1637.25 1 - 456
Standard Chartered Bank 5000.00 1 - 532 553.90 1 - 578
State Bank of India 5577.81 1 - 1400 11615.06 1 - 1339
Syndicate Bank 329.96 1 - 548 727.57 1 - 578
The Jammu And Kashmir Bank 319.44 1 - 548 1067.74 1 - 578
Karnataka Bank 421.88 1 - 548 1007.43 1 - 578
The Karur Vysya Bank Ltd 1135.25 1 - 968 892.08 1 - 1005
The South Indian Bank Ltd 0 0 91.68 1 - 578
UCO Bank 603.94 1 - 548 1475.01 1 - 578
United Bank of India 141.18 1 - 548 333.19 1 - 578
Vijaya Bank 193.60 1 - 548 478.32 1 - 425
Yes Bank Limited 1936.24 1 - 548 3849.03 1 - 578
Foreign Currency Loans/Bonds 24821.02 1 - 548 7135.45 1 - 548
Deferred Payment of Land 21720.55 1 - 549 3756.90 1 - 549
Total 97542.48 73198.90

ix. According to the information and explanations given to us theCompany has not received any term loan during the year. The Company did not raise money byway of initial public offer or further public offer (including debt instruments) duringthe year. x. According to the information and explanations given to us no 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 explanations given to us andbased on our examination of the records of the Company the Company has made payment toits Managerial Personnel in terms of their respective appointments and within the limitsprescribed under the Companies Act 2013 ("the Act") during the year. In view ofdefault in repayment of principal and/or interest to Banks and Financial Institutionsduring the current year the remuneration paid to Shri Pankaj Gaur Joint ManagingDirector (Construction) for the period from 1st April 2019 to 30th June 2019 and ShriSunny Gaur Managing Director (Cement) for the period from 1st April 2019 to 30thDecember 2019 based on the approval of NRC & Board the approval of lenders has beensought whereafter the shareholders' approval shall be obtained.

As reported earlier the appointment and remuneration of Shri RahulKumar the then Whole time director and CFO (for the period from 31.10.2015 to 30.10.2018)was rejected by MCA vide letter dated 27.12.2017 on account of non-recovery ofremuneration paid to 8 managerial personnel (for the year 2014-15 and 2015-16 (upto31.10.2015).

The Company sought clarifications from Ministry Corporate Affairs(MCA). In view of Clarification from MCA the recovery of remuneration from the said 8KMPs is not required who were appointed at a time when the Company was in profits andthere were no defaults.

Accordingly no further action is required in respect of theremuneration paid to the said 8 KMPs during the year 2014-15 and 2015-16 (upto31.10.2015).

As regards waiver of recovery of remuneration paid to Shri Rahul Kumarthe then Whole-time Director & CFO in view of the clarification/ confirmation givenby

MCA the reason for rejection of application for approval ofappointment and remuneration of Shri Rahul Kumar as given by MCA does not survive. Inview of amended provisions the power to approve remuneration/ waiver of recovery ofremuneration stands transferred and vested in the shareholders with prior approval of thelenders. Accordingly the Company has approached the lenders through their lead lender toaccord approval/no-objection for the said waiver of recovery of remuneration which isawaited post which the Company shall seek approval of the shareholders.

The above matter shall be read with Note No. 52 of Standalone FinancialStatements of the Company. xii. In our opinion and according to the information andexplanations given to us the Company is not a Nidhi company. Accordingly paragraph3(xii) of the Order is not applicable to the Company.

xiii. According to the information and explanations given to us andbased on our examination of the records of the Company transactions with the relatedparties are in compliance with Sections 177 and 188 of the Act where applicable anddetails of such transactions have been disclosed in the Standalone Ind AS financialstatements as required by the applicable accounting standards. xiv. According to theinformation and explanations given to us and based on our examination of the records ofthe Company the Company has not made any preferential allotment or private placement ofshares or fully or partly convertible debentures during the year. Accordingly paragraph3(xiv) of the Order is not applicable to the Company. xv. According to the information andexplanations given to us and based on our examination of the records of the Company theCompany has not entered into non-cash transactions with directors or persons connectedwith them. Accordingly paragraph 3(xv) of the Order is not applicable to the Company.xvi. According to the information and explanations given to us the Company is notrequired to be registered under section 45 IA of the Reserve Bank of India Act 1934.Accordingly paragraph 3(xvi) of the Order is not applicable to the Company.

For Rajendra K Goel & Co.
Chartered Accountants
F. R. N. 001457N
R. K. Goel
(Partner)
Membership No. 006154
Place: New Delhi
Dated: May 27 2020
UDIN: 20006154AAAABS3396

ANNEXURE "A" TO THE INDEPENDENT AUDITOR'S REPORT

(Referred to paragraph 2(g) under Report on other Legal and RegulatoryRequirements of our report of even date)

Report on the Internal Financial Controls Over Financial Reportingunder Clause (i) of Sub-section 3 of Section 143 of the Companies Act 2013 ("theAct")

We have audited the internal financial reporting of JAIPRAKASHASSOCIATES LTD ("the Company") as of March 31 2020 in conjunction with ouraudit of the IND AS Standalone Financial Statements of the Company for the year ended onthat date.

Management's Responsibility for Internal Financial Controls

The Company's management is responsible for establishing andmaintaining internal financial controls internal control over financial reporting by theCompany considering the essential components of internal control stated in the GuidanceNote on Audit of Internal Financial Controls over Financial Reporting issued by theInstitute of Chartered Accountants of India (‘ICAI'). These responsibilitiesinclude the design implementation and maintenance of adequate internal financial thatwere operating effectively for ensuring the orderly and efficient conduct of its businessincluding adherence to company's policies the safeguarding of its assets theprevention and detection of frauds and errors the accuracy and completeness of theaccounting records and the timely preparation of reliable financial information asrequired under the Companies Act 2013.

Auditors' Responsibility

Our responsibility is to express an opinion on the Company'sinternal financial controls over financial reporting based on our audit. We conducted ouraudit in accordance with the Guidance Note on Audit of Internal Financial Controls OverFinancial Reporting (the "Guidance Note") and the Standards on Auditing issuedby ICAI and deemed to be prescribed under section 143(10) of the Companies Act 2013 tothe extent applicable to an audit of internal financial controls both applicable to anaudit of Internal Financial Controls and both issued by the Institute of CharteredAccountants of India. Those Standards and the Guidance Note require that we comply withethical requirements and plan and perform the audit to obtain reasonable assurance aboutwhether adequate internal financial controls over financial reporting was established andmaintained and if such controls operated effectively in all material respects. Our auditinvolves performing procedures to obtain audit evidence about the adequacy of the internalfinancial controls system over financial reporting and their operating effectiveness. Ouraudit of internal financial controls over financial reporting included obtaining anunderstanding of internal financial controls over financial reporting assessing the riskthat a material weakness exists and testing and evaluating the design and operatingeffectiveness of internal control based on the assessed risk. The procedures selecteddepend on the auditor's judgment including the assessment of the risks of materialmisstatement of the financial statements whether due to fraud or error. Weoverfinancialbelieve that the audit evidence we have obtained is sufficient and appropriate to providea 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 reportingbased is a processon the designed to provide reasonable assurance regardingestablished thereliability of financial reporting and the preparation of financial statements forexternal purposes in accordance with generally accepted accounting principles.

A company's internal financial control over financial reportingincludes those policies and procedures that:

1. Pertain to the maintenance of records that in reasonable detailaccurately and fairly reflect the transactions and controls dispositions of the assets ofthe company;

2. Provide reasonable assurance that transactions are recorded asnecessary to permit preparation of 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 timelydetection of unauthorized acquisition use or disposition of the company's assetsthat could have a material effect on the financial statements.

Inherent Limitations of Internal Financial Controls over FinancialReporting

Because of the inherent limitations of internal financial controls overfinancial reporting including the possibility of collusion or improper managementoverride of controls material misstatements due to error or fraud may occur and not bedetected. Also projections of any evaluation of the internal financial controls overfinancial reporting to future periods are subject to the risk that the internal financialcontrol over financial reporting may become inadequate because of changes in conditionsor that the degree of compliance with the policies or procedures may deteriorate.

Basis for Qualified Opinion

In our opinion according to the information and explanations given tous and based on our audit procedure performed the following material weakness has beenidentified in the operating effectiveness of the Company's internal financialcontrols over financial reporting as at 31 March 2020: The Company's internalfinancial controls in respect of supervisory and review controls over process ofdetermining of carrying value of the Company's non-current investments in itssubsidiary Jaypee Infratech Limited and deposit of Rs. 750 Crores for which The NCLT NewDelhi Principal Bench approved the Resolution Plan (with modification) under the

Insolvency and Bankruptcy Code 2016 of NBCC (India) Limited on03.03.2020 in case of JIL (matter described in

"Basis of Qualified opinion" para in "Report on theAudit of the

Standalone Financial Statements")whereby as per the schemeapproved by NCLT the company's investment in equity of JIL be reduced to NIL andalso decided that deposit of Rs. 750 crores made by Jaiprakash Associates Limited shall beutilized with interest for the cause of the creditors of Corporate Debtor meaning therebynot to be refunded to Jaiprakash Associates Limited.

Absence of aforesaid assessment in accordance with the accountingprinciples generally accepted in India has resulted in a material misstatement in thecarrying value of investments and Other Current Assets and consequently it has alsoresulted in the understatement of loss for the year.

A ‘material weakness' is a deficiency or a combination ofdeficiencies in internal financial controls over financial reporting such that there is areasonable possibility that a material misstatement of the company's annual orinterim financial statements will not be prevented timely basis.

Qualified Opinion

In our opinion except for the possible effects of the materialweakness described in the Basis for Qualified paragraph the Company has in all materialrespects maintained adequate internal financial controls over financial reporting as at31 March 2020 based on internal control over financial reporting criteria established bythe Company considering the essential components of internal control stated in theGuidance Note issued by the ICAI and the

Company's internal financial controls over financial reportingwere operating effectively as at 31 March 2020.

We have considered the material weakness identified and reported abovein determining the nature timing and extent of audit tests applied in our audit of thestandalone financial statements of the Company as at and for the year ended

31 March 2020 and the material weakness has affected our opinion onthe standalone financial statements of the Company and we have issued a qualified opinionon the standalone financial statements

Emphasis of matter: Attention is drawn to:

Internal control system for financial reporting w.r.t. Confirmations/Reconciliation of balances of certain secured & unsecured loans balances with banksincluding fixed deposits trade receivables trade and other payables and loans andadvances are pending (read with note no. 50 of standalone financial statements) andfurther this to be read with other matters stated under heading "Emphasis ofMatters" in our report may potentially have material impact in the financialstatements.

For Rajendra K. Goel & Co.
Chartered Accountants
detectedona F. R. N.: 001457N
R. K. Goel
(Partner)
M. No.: 006154
Place: New Delhi
Date: 27.05.2020 Opinion
UDIN: 20006154AAAABS3396

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