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Kilburn Chemicals Ltd.

BSE: 524699 Sector: Industrials
NSE: N.A. ISIN Code: INE655C01027
BSE 00:00 | 11 May Kilburn Chemicals Ltd
NSE 05:30 | 01 Jan Kilburn Chemicals Ltd
OPEN 8.67
PREVIOUS CLOSE 8.67
VOLUME 361
52-Week high 9.12
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P/E
Mkt Cap.(Rs cr) 12
Buy Price 9.12
Buy Qty 20.00
Sell Price 8.67
Sell Qty 161.00
OPEN 8.67
CLOSE 8.67
VOLUME 361
52-Week high 9.12
52-Week low 0.00
P/E
Mkt Cap.(Rs cr) 12
Buy Price 9.12
Buy Qty 20.00
Sell Price 8.67
Sell Qty 161.00

Kilburn Chemicals Ltd. (KILBURNCHEMICAL) - Auditors Report

Company auditors report

To the Members of Kilburn Chemicals Limited

Report on the Audit of the Financial Statements

Qualified Opinion

We have audited the accompanying Financial Statements of Kilbum Chemicals Limited("the Company") which comprise the Balance Sheet as at 31st March2021 the Statement of Profit and Loss (including Other Comprehensive Income)theStatement of Changes in Equity andthe Statement of Cash Flows for the year ended onthat date and notes to the financial statements including a summary of the significantaccounting policies and other explanatory information (hereinafter referred to as"Financial Statements").

In our opinion and to the best of our information and according to the explanationsgiven to us except for the effect of matters discussed in the Basis for Qualified Opinionsection of our report the aforesaid Financial Statements give the information required bythe Companies Act 2013 ("the Act") in the manner so required and give a trueand fair view in conformity with the Indian Accounting Standards prescribed under Section133 of the Act read with the Companies (Indian Accounting Standards) Rules 2015 asamended; (‘IND AS) and other accounting principles generally accepted in India ofthe state of affairs of the Company as at 31stMarch 2021 its losses(including Other Comprehensive Income) changes in equity and its cash flows for the yearended on that date.

Basis for Qualified Opinion

a) Non-Recognition of interest expense

We draw attention to Note 44d(iii)of the Financial Statements relating tonon-recognition of interest expense amounting to Rs. 676.73 Lakhs (Rs. 1881.96 Lakhs forthe year ended 31stMarch 2020)on its bank borrowings and Rs. 73.32 Lakhs (Rs.194.16 Lakhs for the quarter ended 31stMarch 2020) on its other borrowingsfrom 1stApril 2020 till the date of commencement of CIRP i.e. 9thAugust2020.As a result finance costs liabilities on account of interest and totalcomprehensive loss are understated to that extent. This constitutes a material departurefrom the requirement of Ind AS 1 "Presentation of Financial Statements".

We conducted our audit in accordance with the Standards on Auditing (SAs) specifiedunder section 143(10) of the Companies Act 2013 ("the Act"). Ourresponsibilities under those Standards are further described in the Auditor'sResponsibilities for the Audit of the Financial Statements section of our report. We areindependent of the Company in accordance with the Code of Ethics issued by the Instituteof Chartered Accountants of India ("ICAI") together with the ethicalrequirements that are relevant to our audit of the Financial Statements under theprovisions of the Act and the Rules made thereunder and we have fulfilled our otherethical responsibilities in accordance with these requirements and the Code of Ethics. Webelieve that the audit evidence we have obtained is sufficient and appropriate to providea basis for our qualified opinion.

Material Uncertainty Related To Going Concern

The Company could not continue its production from October 2018 due to acute liquidityissues. The Company has also defaulted in repayment of loans amounting to Rs.16913.66Lakhs to the lender banks against the credit facilities availed under consortiumarrangement besides interest. As a result the lender banks had classified loan accountsof the Company as Non-Performing Assets by December 2018. As described in Note 44d(ii) tothe Financial Statements during the quarter ended 30th June 2020 the lenderbanks have filed an application under Section 7 of the Insolvency and Bankruptcy Code2016 ("the IBC") before the National Company Law Tribunal ("the NCLT")to initiate the Corporate Insolvency Resolution Process ("the CIRP") against theCompany. The Hon'ble NCLT Kolkata Bench has admitted the application filed by the lendersand ordered the commencement of the CIRP vide its order dated 10th August2020. Consequently Mr. ParthaPratim Ghosh Insolvency Professional having RegistrationNo.IBBI/IPA-001/IP-P00554/2017-2018/10984 was appointed as the Resolution Professional forthe Company by the Hon'ble NCLT Kolkata Bench on 10thAugust 2020.

Subsequent to the reporting period i.e. 30th September 2020 on anapplication filed by Mr. ParthaPratim Ghosh under Section 27 of the IBC for replacement ofthe Resolution Professional the Hon'ble NCLT Kolkata Bench appointed Mr. Sanjai KumarGupta having Registration No. IBBI/IPA-001/IP-P00592/2017-18/11045 as the ResolutionProfessional.

These events and conditions indicate a material uncertainty which may cast asignificant doubt on the Company's ability to continue as a going concern and the same issolely dependent on the IBC proceedings. Based on the Resolution Professional's assessmentof the successful IBC proceedings this Financial Statement has been prepared on goingconcern basis.

Emphasis of Matter

We draw attention to Note 44(e) of the Financial Statements which state that certainLoans and Advances Trade Payables and Trade Receivables being subject to confirmationfrom respective parties and consequential reconciliation and adjustments arisingtherefrom if any. The Company however does not expect any material variation. TheCompany is also hopeful for recovery of loans and advances and other receivables in thenormal course of business.

Our Opinion is not modified in respect of the above matter.

Key Audit Matters

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

Key Audit Matters Response to Key Audit Matters
Property Plant and Equipment
There are areas where management judgement impacts the carrying value of property plant and equipment intangible assets and their respective depreciation rates. These include the decision to capitalise or expense costs; the annual asset life review; the timeliness of the capitalisation of assets and the measurement and recognition criteria for assets retired from active use. We do not consider this management judgement to be of high risk of significant misstatement or to be subject to significant level of judgment. However due to their materiality in the context of the Balance Sheet of the Company this is considered to be an area which had the significant effect on the overall audit strategy and allocation of resources in planning and completing our audit. • We assessed the controls in place over the fixed assets evaluated the appropriateness of capitalisation process performed tests of details on costs capitalised the timeliness of the capitalisation of the assets and the de-recognition criteria for asset retired from active use.
• In performing these procedures we reviewed the judgements made by management including the nature of underlying costs capitalised; determination of realizable value of the assets retired from active use; the appropriateness of assets lives applied in the calculation of depreciation; the useful lives of assets prescribed in Schedule II to the Actand the useful lives of certain assets as per the technical assessment. We observed that the management has regularly reviewed the aforesaid judgments and there are no material changes.

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

The Company's management is responsible for the preparation of the other information.The other information comprises the information included in the Management Discussion andanalysis; Management's Report including Annexure to Management's Report CorporateGovernance and Shareholders Information but does not include the Financial Statements andour Auditor's Report thereon.

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

In connection with our audit of the Financial Statements our responsibility is to readthe other information and in doing so consider whether the other information ismaterially inconsistent with the Financial Statements or our knowledge obtained during thecourse of our audit or otherwise appears to be materially misstated. After going throughthe other information identified as such if we conclude that there is a materialmisstatement we are required to communicate the matter to those charged with governance.

Responsibilities of Management and those charged with governance for the FinancialStatements

In view of ongoing Corporate Insolvency Resolution Process (‘CIRP') theResolution Professional (‘RP') is responsible for the preparation and presentation ofthe Financial Results that give a true and fair view of the net profit / (loss) and Othercomprehensive Income and other financial information in accordance with the recognitionand measurement principles laid down in Indian Accounting Standards prescribed underSection 133 of the Act. This responsibility also includes maintenance of adequateaccounting records in accordance with the provisions of the Act for safeguarding theassets of the Company and for preventing and detecting frauds and other irregularities;selection and application of appropriate accounting policies; making judgments andestimates that are reasonable and prudent; and design implementation and maintenance ofadequate internal financial controls that were operating effectively for ensuring theaccuracy and completeness of the accounting records relevant to the preparation andpresentation of the Financial Statements that give a true and fair view and are free frommaterial misstatement whether due to fraud or error.

In preparing the Financial Statements the Board of Directors and Management areresponsible for assessing the Company's ability to continue as a going concerndisclosing as applicable matters related to going concern and using the going concernbasis of accounting unless the management either intends to liquidate the Company or tocease operations or has no realistic alternative but to do so.

The Board of directors and respective management under the Resolution Professional arealso responsible for overseeing the Company's financial reporting process.

Auditor's Responsibilities for the Audit of the Financial Statements

Our objectives are to obtain reasonable assurance about whether the FinancialStatements as a whole are free from material misstatement whether due to fraud or errorand to issue an Auditor's Report that includes our Opinion. Reasonable assurance is a highlevel of assurance but is not a guarantee that an audit conducted in accordance with SAswill always detect a material misstatement when it exists. Misstatements can arise fromfraud or error and are considered material if individually or in the aggregate theycould reasonably be expected to influence the economic decisions of users taken on thebasis of these Financial Statements.

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

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

• Obtain an understanding of internal control relevant to the audit in order todesign audit procedures that are appropriate in the circumstances. Under section 143(3)(i)of the Act we are also responsible for expressing our opinion on whether the Company hasadequate internal financial controls with reference to financial statements in place andthe operating effectiveness of such controls.

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

• Conclude on the appropriateness of management's use of the going concern basisof accounting and based on the audit evidence obtained whether a material uncertaintyexists related to events or conditions that may cast significant doubt on the Company'sability to continue as a going concern. If we conclude that a material uncertainty existswe are required to draw attention in our Auditor's Report to the related disclosures inthe Financial Statements or if such disclosures are inadequate to modify our opinion.Our conclusions are based on the audit evidence obtained up to the date of our Auditor'sReport. However future events or conditions may cause the Company to cease to continue asa going concern.

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

We communicate with those charged with governance regarding among other matters theplanned scope and timing of the audit and significant audit findings including anysignificant deficiencies in internal control that we identify during our audit.

We also provide those charged with governance with a statement that we have compliedwith relevant ethical requirements regarding independence and to communicate with themall relationships and other matters that may reasonably be thought to bear on ourindependence and where applicable related safeguards.

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

Report on Other Legal and Regulatory Requirements

1. As required by the Companies (Auditor's Report) Order 2016 ("the Order")issued by the Central Government of India in terms of sub-section (11) of section 143 ofthe Act we give in the Annexure A a statement on the matters specified in paragraphs 3and 4 of the Order to the extent applicable.

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

a. we have sought and obtained all the information and explanations which to the bestof our knowledge and belief were necessary for the purposes of our audit;

b. except for the possible effects of the matters described in the Basis for QualifiedOpinion section above in our opinion proper books of account as required by law havebeen kept by the Company so far as it appears from our examination of those books;

c. the Balance Sheet the Statement of Profit and Loss (including Other ComprehensiveIncome) the Statement of Changes in Equity and the Statement of Cash Flows dealt with bythis Report are in agreement with the books of account;

d. except for the significance of the matters discussed in the Basis for QualifiedOpinion section above in our opinion the aforesaid Financial Statements comply with theIND AS specified under Section 133 of the Act;

e. the matters described in the Basis for Qualified Opinion section above in ouropinion may have an adverse effect on the functioning of the Company.

f. In terms of Section 17(1)(b) of the Insolvency and Bankruptcy Code 2016 the powersof Board of Directors have been suspended and exercised by Resolution Professional.However on the basis of the written representations received from the directors as on 31stMarch2021and taken on record by the Board of Directors none of the directors isdisqualified as on 31stMarch 2021from being appointed as a director in termsof Section 164(2) of the Act.

g. with respect to the adequacy of the internal financial controls with reference tofinancial statements of the Company and the operating effectiveness of such controlsrefer to our separate report in "Annexure B"; and

h. with respect to the other matters to be included in the Auditor's Report inaccordance with the requirements of section 197(16) of the Act the Company has compliedwith the provisions of Section 197 read with Schedule V to the Actrelating to managerialremuneration.

i. with respect to the other matters to be included in the Auditor's Report inaccordance with Rule 11 of the Companies (Audit and Auditors) Rules 2014in 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 33(A)(i) to the Financial Statements

ii. the Company did not have any long-term contracts including derivative contracts forwhich there were any material foreseeable losses; and

iii. there is no amount which is required to be transferred to the Investor Educationand Protection Fund by the Company in accordance with the relevant provisions of the Actand the Rules made thereunder.

ForV. SINGHI & ASSOCIATES
Chartered Accountants
Firm Registration No. :311017E
(AniruddhaSengupta)
Place: Kolkata Partner
Date: 30thJuly 2021 Membership No. 051371

Annexure - A to the Independent Auditor's Report

Referred to in paragraph-1 on other Legal and Regulatory Requirements of our Report ofeven date to the members of Kilbum Chemicals Limited on the Financial Statements for theyear ended 31st March 2021

i. a) The Company has maintained proper records showing full particulars includingquantitative details and situation of its Fixed Assets.

b) As explained to us Fixed Assets have been physically verified by the management atregular intervals which in our opinion is reasonable having regard to the size of theCompany and the nature of the assets. As informed to us no material discrepancies werenoticed on such verification.

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

ii. According to the information and explanations given to us the Inventories havebeen physically verified during the year at reasonable intervals by the management. Thediscrepancies noticed on verification between the physical inventories and book recordswere not material in relation to the operations of the company and the same have beenproperly dealt with in the books of account.

iii. According to the information and explanations given to us the Company has notgranted any loan secured or unsecured during the year(excluding unsecured loan of Rs.276.57 Lakhs given to a Company in earlier years) to companies Firms Limited LiabilityPartnerships or other parties covered in the register maintained under Section 189 of theAct.

a) No interest is being charged on the above loan as per terms of the agreement betweenthe parties.

b) There is no specified schedule as regards repayment of principal amount andtherefore we are not in a position to make any comments as to whether or not the Companywas regular in receipt of principal amount.

c) In view of our comments in Para (b) above we are not in a position to make anycomments as to whether or not there were any overdue amounts of more than ninety days andwhether any reasonable steps have been taken by the Company for recovery of the principalamount.

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 Act with respectto the loans given investments made and guarantees given.

v. According to the information and explanations given to us the Company has notaccepted any deposits from the public within the meaning of sections 73 to 76 of the Actand the rules framed thereunder to the extent notified. Accordingly clause3(v) of theOrder is not applicable.

vi. According to the information and explanations given to us by the management theCentral Government has prescribed the maintenance of cost records under Sub section 1 ofSection 148 of the Act but since the criteria for minimum turnover is not compliedwithclauses3(vi) of the Order is not applicable.

vii. (a) According to the information and explanations given to us and on the basis ofour examination of the records the Company has defaulted in depositing undisputedapplicable statutory dues including Provident Fund Income Tax Goods and Services Tax andany other statutory dues with the appropriate authorities and the details of arrears inrespect thereof as on 31st March 2021for a period of more than six months areas follows:

Name of Statute Nature of Dues Amount (Rs. in Lakhs) Period to which it relate Due Date Date of Payment Remarks if any
Income Tax Act 1961 TDS on Contractor 1.25 A.Y. 2019-20 Unpaid till date
1.09 A.Y. 2020-21 -
0.22 A.Y. 2021-22 -
TDS on Professional Charges 3.85 A.Y. 2019-20 -
1.63 A.Y. 2020-21 For the months of April - February - 7th of next month. For March - 30 th April of next month -
0.20 A.Y. 2021-22 -
TDS on Rent 0.51 A.Y. 2019-20 -
0.30 A.Y. 2020-21 -
TDS on Interest of Loan 8.77 A.Y. 2019-20
TDS on Salary 1.15 A.Y. 2021-22 -
The Gujarat Professions Tax Act 1976 Professional Tax 0.03 A.Y. 2020-21 30.09.2020

(b) According to the information and explanations given to us the Company has notdeposited the following dues on account of disputes with the appropriate authorities:

Name of the Statue Nature of the dues Amount (Rs. in Lakhs) Period to which the amount pertains Forum where dispute is pending
Income Tax Act 1961 Income Tax 1705.20/- A.Y. 2012-13 Commissioner of Income Tax (Appeals) Kolkata
Income Tax Act 1961 Income Tax 53.43/- A.Y. 2013-14 Commissioner of Income Tax (Appeals) Kolkata
Income Tax Act 1961 Income Tax 8.52/- A.Y. 2014-15 Commissioner of Income Tax (Appeals) Kolkata

viii. According to the information and explanations given to us the Company hasdefaulted in repayment of loans and interest to two banks. The details of such defaultsare as under:

Particulars Amount of Default (Rs. in Lakhs) Period
Principal Interest
Bank of Baroda
a) Term Loan 8300.00 580.54 From October 2018 to March 2021
b) Cash Credit 18.86 From October 2018 to March 2021
State Bank of India
a) Term Loan 8300.00 500.16 From October 2018 to March 2021
b) Cash Credit - 16.59 From October 2018 to March 2021

In addition to this the Company has not recognised interest expense on its borrowingsduring the financial year ended 31stMarch 2021. Amount of interest notrecognised in the books of account during the financial year ended 31stMarch2021 on bank borrowings is Rs. 676.73 Lakhs.

ix. According to the information and explanations given to us and based on ourexamination of the books and records we report that the Company has not raised any moneyby way of initial public offer or further public offer (including debt instruments) orterm loan during the year. Accordingly clause 3(ix) of the Order is not applicable.

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 explanations given to us and based on ourexamination of the books and records we report that the Company has paid /provided formanagerial remuneration in accordance with the requisite approvals mandated by theprovisions of section 197 read with Schedule V to the Act.

xii. According to the information and explanations given to us the Company is not aNidhi Company. Accordingly clause 3 (xii) of the Order is not applicable.

xiii. According to the information and explanations given to us and based on ourexamination of the books and records 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. According to the information and explanations given to us and based on ourexamination of the books and records we report that the Company has not made anypreferential allotment or private placement of shares or fully or partly convertibledebentures during the year and accordingly clause 3(xiv) of the Order is not applicable.

xv. According to the information and explanations given to us and based on ourexamination of the books and records the Company has not entered into any non-cashtransactions with directors or persons connected with him during the year. AccordinglyClause 3 (xv) of the Order is not applicable.

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

ForV. SINGHI & ASSOCIATES
Chartered Accountants
Firm Registration No. :311017E
(AniruddhaSengupta)
Place: Kolkata Partner
Date: 30thJuly 2021. Membership No. 051371

Annexure - B to the Independent Auditor's Report

(Referred to in paragraph-2(g) on Other Legal and Regulatory Requirements of our Reportof even date to the members of Kilbum Chemicals Limited on the Financial Statements forthe year ended 31st March 2021)

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

We have audited the internal financial controls with reference to financial statementsof Kilburn Chemicals Limited ("the Company") as of 31stMarch 2021inconjunction with our audit of the Financial Statements of the Company for the year endedon that date.

Management's Responsibility for Internal Financial Controls

The Company's management is responsible for establishing and maintaining internalfinancial controls based on the internal financial controls with reference to financialstatements criteria established by the Company considering the essential components ofinternal control stated in the Guidance Note on Audit of Internal Financial Controls overFinancial Reporting issued by the Institute of Chartered Accountants of India(‘ICAI'). These responsibilities include the design implementation and maintenanceof adequate internal financial controls that were operating effectively for ensuring theorderly and efficient conduct of its business including adherence to company's policiesthe safeguarding of its assets the prevention and detection of frauds and errors theaccuracy and completeness of the accounting records and the timely preparation ofreliable financial information as required under the Act.

Auditors' Responsibility

Our responsibility is to express an opinion on the Company's internal financialcontrols with reference to financial statements based on our audit. We conducted our auditin 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 Act to the extentapplicable to an audit of internal financial controls with reference to financialstatements both applicable to an audit of Internal Financial Controls and issued by theInstitute of Chartered Accountants of India. Those Standards and the Guidance Note requirethat we comply with ethical requirements and plan and perform the audit to obtainreasonable assurance about whether adequate internal financial controls with reference tofinancial statements were established and maintained and whether such controls operatedeffectively in all material respects.

Our audit involves performing procedures to obtain audit evidence about the adequacy ofthe internal financial controls with reference to financial statements and their operatingeffectiveness. Our audit of internal financial controls with reference to financialstatements included obtaining an understanding of such internal financial controlsassessing the risk that a material weakness exists and testing and evaluating the designand operating effectiveness of internal control based on the assessed risk. The proceduresselected depend on the auditor's judgment including the assessment of the risks ofmaterial misstatement of the Financial Statements whether due to fraud or error.

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

Meaning of Internal Financial Controls with reference to Financial Statements

A company's internal financial control with reference to financial statements is aprocess designed to provide reasonable assurance regarding the reliability of financialreporting and the preparation of financial statements for external purposes in accordancewith generally accepted accounting principles. A company's internal financial controlswith reference to financial statements includes those policies and procedures that (1)pertain to the maintenance of records that in reasonable detail accurately and fairlyreflect the transactions and dispositions of the assets of the company; (2) providereasonable assurance that transactions are recorded as necessary to permit preparation offinancial statements in accordance with generally accepted accounting principles and thatreceipts and expenditures of the company are being made only in accordance withauthorizations of management and directors of the company; and (3) provide reasonableassurance regarding prevention or timely detection of unauthorized acquisition use ordisposition of the company's assets that could have a material effect on the financialstatements.

Inherent Limitations of Internal Financial Controls with reference to FinancialStatements

Because of the inherent limitations of internal financial controls with reference tofinancial statements 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 withreference to financial statements to future periods are subject to the risk that theinternal financial control with reference to financial statements may become inadequatebecause of changes in conditions or that the degree of compliance with the policies orprocedures may deteriorate.

Opinion

In our opinion the Company has in all material respects an adequate internalfinancial controls system with reference to financial statements and such internalfinancial controls were operating effectively as at 31st March 2021 based onthe internal financial controls with reference to financial statements criteriaestablished by the Company considering the essential components of internal controlsstated in the Guidance Note on Audit of Internal Financial Controls Over FinancialReporting issued by the Institute of Chartered Accountants of India.

ForV. SINGHI & ASSOCIATES
Chartered Accountants
Firm Registration No. :311017E
(AniruddhaSengupta)
Place: Kolkata Partner
Date: 30thJuly 2021. Membership No. 051371

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