The Members of
Madhav Marbles and Granites Limited
Report on the Audit of the Standalone Financial Statements
We have audited the accompanying standalone Ind AS financial statements of MadhavMarbles & Granites Limited ("the Company") which comprise the BalanceSheet as at March 312019 the Statement of Profit and Loss (including Other ComprehensiveIncome) the Statement of Cash Flows & the Statement of Changes in Equity for theyear and notes to financial statements including summary of the significant accountingpolicies and other explanatory information (hereinafter referred to as "thestandalone financial statements").
In our opinion and to the best of our information and according to the explanationsgiven to us the aforesaid standalone financial statements give the information requiredby the Companies Act 2013 ("the Act") in the mannerso required and give atrueand 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 Indiaof the state of affairs of the Company as at March 312019 its profit including totalcomprehensive income its cash flows and the changes in equity for the year ended on thatdate.
Basis for Opinion
We conducted our audit of the standalone financial statements in accordance with theStandards on Auditing (SA's) specified under section 143(10) of the Act(SAs). Ourresponsibilities under those Standards are further described in the Auditor'sResponsibilities for the Audit of the Standalone Financial Statements section of ourreport. We are independent of the Company in accordance with the Code of Ethics issued bythe Institute of Chartered Accountants of India (ICAI) together with the independencerequirements that are relevant to our audit of the standalone financial statements underthe provisions of the Act and the Rules made there under and we have fulfilled our otherethical responsibilities in accordance with these requirements and the ICAI's Code ofEthics. We believe that the audit evidences we have obtained are sufficient andappropriate to provide a basis for our audit opinion on the standalone financialstatements.
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 matterstobe communicated in our report.
Description of Key Audit Matters
|Key Audit Matters ||How the matter was addressed in our audit |
|REVENUE RECOGNITION || |
|Recognition of the company's revenue is complex due to several types of Export sales contracts including generation and captive consumption of power. || We tested the relevant internal controls used to ensure the completeness accuracy and timing of revenue recognised including controls over the generation and captive consumption of power at year-end. |
| We focused on this area as recognition of revenue involves significant judgement and estimates made by Management including whether contracts contain multiple performance obligations which should be accounted for separately and the most appropriate method for recognition of revenue for identified performance obligations. This comprises allocation of consideration to the individual performance obligations assessing whether performance obligations under export sales contracts are satisfied at a point in time or over time. Further it comprises the point in time when transfer of control has occurred regarding generation and sale of electricity which are accounted for over time. || We read some sample of Export Sale contracts also the contract between Madhav Marbles & Granites Limited and Tamil Nadu Electricty Board to assess whether the method for recognition of revenue was relevant and consistent with Ind AS- 11 5 and had been applied consistently. Where a contract contained multiple elements we considered Management's judgements as to whetherthey comprised performance obligations that should be accounted for separately and in such cases challenged the judgements made in the allocation of the consideration to each performance obligation. |
| The Company has followed Ind AS-115 for recognizing revenue in the financial statements for the financial year2018-19. || We evaluated the significant judgements and estimates made by Management in applying company's accounting policy to a sample of specific contracts and separable performance obligations of contracts and we obtained evidence to support them including details of contractual agreements shipping bills purchase orders etc. For the contracts selected we inspected original signed contracts and reconciled the revenue recognised to the underlying accounting records. We obtained a sample of Management's calculations for the recognition of revenue related to generation and captive consumption of power during the year as well as at the year-end. |
| We reviewed the Company's implementation of Ind AS 115 including changes to procedures accounting guidelines disclosures and systems to support correct revenue recognition. We reviewed and discussed the group accounting policy & disclosures with Management including the key accounting estimates and judgements made by Management. || |
|DUES OF INCOME TAX AND INDIRECT TAX || |
|The Company has material uncertain tax positions including matters under dispute which involves significant judgment to determine the possible outcome of these disputes. ||Our audit procedures include the following substantive procedures: |
|Refer to Note. no. (vii) of the ANNEXURE B of the Audit report on the Standalone Financial Statements. || We had obtained understanding of key uncertain tax positions by obtaining details of completed tax assessments and demands for the year ended March 312019 from the management. |
| || We along with our internal tax experts and appropriate senior management |
| ||> Discussed 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 formed an opinion that we do not require any legal opinion from the expert in that field. |
|INVESTMENT || |
|Investment in Mutual Funds: The Company has invested in various Quoted Mutual funds which is a financial asset for the company. Also the company has followed Ind As- 109 and the investment in mutual funds has been recognized at market value as on March 31 2019 and remeasurement gain/loss has been recognizes in profit & loss account. ||Our procedures included but were not limited to the following: |
| || Scrutiny of documents related to investment in mutual funds |
| || Obtained an understanding of management's process of recording of investments profit/loss on sale of such investments expenses etc. and evaluated it on the basis statements received from the intermediary |
| || Assessed the reasonableness & correct recording of the transactions based on statements available with the Company. |
|Investment in Subsidiary: ||Our procedures included but were not limited to the following: |
|During the financial year2018-19 the Company has subscribed 305100 shares of MADHAV NATURAL STONE SURFACES PRIVATE LIMITED viz 66.33% of the total shares issued by the said company and thus Madhav Natural Stone Surfaces Private Limited is a subsidiary of MADHAV MARBLES & GRANITES LIMITED. The company has followed Ind AS-109 and the said investment has been recognized at Amortizing cost as on March 31 2019 as the shares of the subsidiary company are unquoted. The company does not have any other subsidiary other then MADHAV NATURAL STONE SURFACES PRIVATELIMITED. || Obtained an understanding of management's process & methodology of investment in shares. We also tested whether any Loss allowance is required to be made and formed an opinion that there is no such requirement. |
| || Assessed the appropriateness of the methodology and valuation model used by the management. |
| || Assessed the reasonableness of the assumptions made by the management regarding the value of underlying shares. |
Information Other than the Standalone Financial Statements and Auditor's Report Thereon
The Company's Board of Directors is responsible for the preparation of the otherinformation. The other information comprises the information included in the ManagementDiscussion and Analysis Board's Report including Annexures to Board's Report CorporateGovernance and Shareholder's Information but does not include the standalone financialstatements and our auditor's report thereon.
Our opinion on the standalone financial statements does not cover the other informationand we do not express any form of assurance conclusion thereon.
In connection with our audit of the standalone financial statements our responsibilityis to read the other information and in doing so consider whether the other informationis materially inconsistent with the standalone financial statements or our knowledgeobtained during 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's Responsibility for the Standalone 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 standalone financial statements that give a true and fair view of the financialposition financial performance total comprehensive income changes in equity and cashflows of the Company in accordance with the Ind AS and other accounting principlesgenerally accepted in India.
This responsibility also includes maintenance of adequate accounting records inaccordance with the provisions of the Act for safeguarding the assets of the Company andfor preventing and detecting frauds and other irregularities; selection and application ofappropriate accounting policies; making judgments and estimates that are reasonable andprudent; and design implementation and maintenance of adequate internal financialcontrols that were operating effectively for ensuring the accuracy and completeness ofthe accounting records relevant to the preparation and presentation of the standalonefinancial statements that give a true and fair view and are free from materialmisstatement whether due to fraud or error.
In preparing the standalone financial statements management is responsible forassessing the Company's ability to continue as a going concern disclosing as applicablematters related to going concern and using the going concern basis of accounting unlessmanagement either intends to liquidate the Company orto cease operations or has norealistic alternative butto do so.
The Board of Directors of the company are also responsible for overseeing the Company'sfinancial reporting process.
Auditor's Responsibilities for the Audit of the Standalone Financial Statements
Our objectives are to obtain reasonable assurance about whether the standalonefinancial statements as a whole are free from material misstatement whether due to fraudor error and to issue an auditor's report that includes our opinion. Reasonable assuranceis a high level of assurance but is not a guarantee that an audit conducted in accordancewith SAs will always detect a material misstatement when it exists. Misstatements canarise from fraud or error and are considered material if individually or in theaggregate they could reasonably be expected to influence the economic decisions of userstaken on the basis of these standalone financial statements.
As part of an audit in accordance with SAs we exercise professional judgment andmaintain professional skepticism throughout the audit. We also:
Identify and assess the risks of material misstatement of the standalonefinancial statements whether due to fraud or error design and perform audit proceduresresponsive to those risks and obtain audit evidence that is sufficient and appropriate toprovide a basis for our opinion. The risk of not detecting a material misstatementresulting from fraud is higher than for one resulting from error as fraud may involvecollusion forgery intentional omissions misrepresentations orthe override of internalcontrol.
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 Act we are also responsible for expressing our opinion on whether theCompany has adequate internal financial controls system in place and the operatingeffectiveness 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 standalone financial statements or if such disclosures are inadequate to modify ouropinion. Our conclusions are based on the audit evidence obtained up to the date of ourauditor's report. However future events or conditions may cause the Company to cease tocontinue as a going concern.
Evaluate the overall presentation structure and content of the standalonefinancial statements including the disclosures and whether the standalone financialstatements represent the underlying transactions and events in a manner that achieves fairpresentation.
Materiality is the magnitude of misstatements in the standalone financial statementsthat individually or in aggregate makes it probable that the economic decisions of areasonably knowledgeable user of the 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 the effect of anyidentified misstatements in the financial statements.
Communication with those charged with governance
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 bethought 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 matters in our auditor's 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.
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 books.
c) The Balance Sheet the Statement of Profit and Loss including Other ComprehensiveIncome Statement of Changes in Equity and the Statement of Cash Flow dealt with by thisReport are in agreement with the relevant books of account.
d) In our opinion the aforesaid standalone financial statements comply with the Ind ASspecified under Section 133 of the Act read with Rule 7 of the Companies (Accounts)Rules 2014.
e) On the basis of the written representations received from the directors as on March312019 taken on record by the Board of Directors none of the directors is disqualifiedas on March 312019 from being appointed as a director in terms of Section 164 (2) of theAct.
f) With respect to the adequacy of the internal financial controls over financialreporting 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 opinion and to the best of our information and according to the explanationsgiven to us the remuneration paid by the Company to its directors during the year is inaccordance with the 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 as amended inour opinion and to the best of our information and according to the explanations given tous:
i) The Standalone financial statements disclose the impact of pending litigations onthe Standalone financial position of the company;
ii) The Company did not have any long-term contracts including derivative contractshence; the question of any material foreseeable losses does notarise;
iii) There has been no delay in transferring amounts required to be transferred to theInvestor Education and Protection Fund by the company.
2. As required by the Companies (Auditor's Report) Order 2016 ("the Order")issued by the Central Government in terms of Section 143(11) of the Act we give in"Annexure B" a statement on the matters specified in paragraphs 3 and 4 of theOrder.
| ||For L. S. KOTHARI & CO |
| ||Chartered Accountants |
| ||ICAI Firm Registration No.001450C |
| ||Lalit Kothari |
| ||Partner |
|Camp: Udaipur May 28 201 9 ||Membership No.: 081407 |
Annexure "A" to the Independent Auditor's Report
(Referred to in paragraph 1 (f) under 'Report on Other Legal and RegulatoryRequirements' section of our report to the Members of Madhav Marbles & GranitesLimited of even date)
Report on the Internal Financial Controls Over Financial Reporting under Clause (i) ofSub-section 3 of Section 143 of the Companies Act 2013 ("the Act")
We have audited the internal financial controls over financial reporting of MADHAVMARBLES & GRANITES LIMITED ("the Company") as of March 312019 inconjunction with our audit of the standalone financial statements of the Company for theyear 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 internalcontrol stated 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 including adherence to respective company's policies thesafeguarding of its assets the prevention and detection of frauds and errors theaccuracy and completeness of the accounting records and the timely preparation ofreliable financial information as required under the Companies Act 2013.
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 internal financial controls system overfinancial reporting of the Company.
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 authorizations of management and directors of the company; and
(3) Provide reasonable assurance regarding prevention or timely detection ofunauthorized acquisition use or disposition of the company's assets that could have amaterial effect on the financial statements.
Inherent 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.
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 2019 based on the internal controlover financial reporting criteria established by the Company considering the essentialcomponents of internal control stated in the Guidance Note on Audit of Internal FinancialControls Over Financial Reporting issued by the Institute of Chartered Accountants ofIndia.
| ||For L. S. KOTHARI & CO |
| ||Chartered Accountants |
| ||ICAI Firm Registration No.001450C |
| ||Lalit Kothari |
| ||Partner |
|Camp: Udaipur May 28 201 9 ||Membership No.: 081407 |
Annexure 'B' To The Independent Auditor's Report
(Referred to in paragraph 2 under 'Report on Other Legal and Regulatory Requirements'section of our report to the Members of Madhav Marbles & Granites Limited of evendate)
(i) In respect of the Company's fixed assets:
(a) The Company has maintained proper records showing full particulars includingquantitative details and situation of fixed assets.
(b) The Company has a program of verification to cover all the items of fixed assets ina phased manner which in our opinion is reasonable having regard to the size of theCompany and the nature of its assets. Pursuant to the program certain 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 on the basis of ourexamination of records of the Company the title deeds of immovable properties are held inthe name of the Company.
(ii) As explained to us the inventory has been physically verified at reasonableintervals during the year by the management. In our opinion the frequency of verificationis reasonable. The discrepancies between the physical stocks and the book stocks were notmaterial in relation to the operation of the Company and the same have been properly dealtwith in the books of account.
(iii) According the information and explanations given to us the Company has grantedunsecured loan to one body corporate covered in the register maintained under section 189of the Companies Act 2013 in respect of which:
(a) The terms and conditions of the grant of such loans are in our opinion primafacie not prejudicial to the Company's interest.
(b) The schedule of repayment of principal and payment of interest has been stipulatedand repayments or receipts of principal amounts and interest have been regular as perstipulations.
(c) There is no overdue amount remaining outstanding as at the year-end.
(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 in respect ofgrant of loans making investments and providing guarantees and securities as applicable.
(v) The Company has not accepted deposits during the year and does not have anyunclaimed deposits as at March 31 2019 and therefore the provisions of the clause 3 (v)of the Order are not applicable to the Company.
(vi) We have broadly reviewed the books of account maintained by the Company in respectof products where the maintenance of cost records has been specified by the CentralGovernment under sub-section (1) of Section 148 of the Act and the rules framed thereunder and we are of the opinion that prima facie the prescribed accounts and records havebeen made and maintained.
(vii) According to the information and explanations given to us in respect ofstatutory dues:
(a) The Company has generally been regular in depositing undisputed statutory duesincluding Provident Fund Employees' State Insurance Income Tax Goods and Service TaxCustoms Duty Cess and other material statutory dues applicable to it with the appropriateauthorities.
(b) There were no undisputed amounts payable in respect of Provident Fund Employees'State Insurance Income Tax Goods and Service Tax Customs Duty Cess and other materialstatutory dues in arrears as at March 312019 for a period of more than six months fromthe date they became payable.
(c) Details of dues of Income Tax Sales Tax of dispute are Service Tax Excise Dutyand Value Added Tax which have not been deposited as at March 312019 on account givenbelow:
|Name of the statute ||Nature of the disputed dues ||Amount Rs. (Lacs) ||Period to which the amount relates ||Forum where disputes are pending |
|Income Tax Act 1961 ||Disallowance of claim of deduction u/s 80IA ||25.49 ||A.Y. 2015-1 6 ||CIT (A) |
|Central Excise Duty ||Disallowing Exemption/concession towards DTA sale under Notification No.23/2003 dated 31.3.2003 ||89.81 ||1st April 2008-30th November 2015 ||Central Excise & Service Tax Appellate Tribunal Commissioner (Appeals) |
|Departmental Appeal || || || || |
|Income Tax Act 1961 ||Disallowance of claim of deduction u/s 80IA and personal expenses. ||28.37 ||A.Y. 2013-14 ||ITAT |
|Income Tax Act 1961 ||Relief granted by Commissioner of Income Tax (Appeals) for deduction u/s 80IA 36(1)(iii) and contribution towards PF/ESI ||35.67 ||A.Y. 2012-1 3 ||ITAT |
|Income Tax Act 1961 ||Relief granted by Commissioner of Income Tax (Appeals) for deduction u/s 80IA 36(1)(iii) and contribution towards PF/ESI ||52.12 ||A.Y. 2011-12 ||ITAT |
|Income Tax Act 1961 ||Relief granted by Commissioner of Income Tax (Appeals) for deduction u/s 80IA 1 0B and allowance of expenses ||36.14 ||A.Y. 2010-1 1 ||ITAT |
|Income Tax Act 1961 ||Relief granted by ITAT for deduction u/s 36(1)(vii). ||57.75 ||A.Y. 2004-05 ||Rajasthan High Court |
|Income Tax Act 1961 ||Relief granted by ITAT for deduction u/s 36(1)(vii) 10B and 40(a)(ia). ||27.32 ||A.Y. 2005-06 ||Rajasthan High Court |
|Income Tax Act 1961 ||Relief granted by ITAT for deduction u/s 32 and 40(a)(ia). ||07.44 ||A.Y. 2006-07 ||Rajasthan High Court |
|Income Tax Act 1961 ||Relief granted by ITAT for deduction u/s 40(a)(ia) and allowance of expenses. ||03.17 ||A.Y. 2007-08 ||Rajasthan High Court |
|Income Tax Act 1961 ||Relief granted by ITAT for deduction u/s 40(a)(ia). ||92.81 ||A.Y. 2008-09 ||Rajasthan High Court |
|Income Tax Act 1961 ||Relief granted by ITAT for deduction u/s 40(a)(ia). ||03.69 ||A.Y. 2009-10 ||Rajasthan High Court |
(viii) According to the records of the Company examined by us and the information andexplanation given to us the company has not defaulted in repayment of loans or borrowingsto any financial institution or bank or Government or due to debenture holders as atbalance sheet date.
(ix) The Company has not raised moneys by way of initial public offer or further publicoffer (including debt instruments) or term loans and hence reporting under clause 3 (ix)of the Order is not applicable to the Company.
(x) To the best of our knowledge and according to the information and explanationsgiven to us no fraud by the Company or no material fraud on the Company by its officersor employees has been noticed or reported during the year.
(xi) In our opinion and according to the information and explanations given to us theCompany has paid/provided managerial remuneration in accordance with the requisiteapprovals mandated by the provisions of section 1 97 read with Schedule V tothe Act.
(xii) The Company is not a Nidhi Company and hence reporting under clause 3 (xii) ofthe Order is not applicable to the Company.
(xiii) In our opinion and according to the information and explanations given to usthe Company is in compliance with Section 1 77 and 1 88 of the Companies Act 201 3 whereapplicable for all transactions with the related parties and the details of related partytransactions have been disclosed in the standalone financial statements as required by theapplicable accounting standards.
(xiv) During the year the Company has not made any preferential allotment or privateplacement of shares or fully or partly paid convertible debentures and hence reportingunder clause 3 (xiv) of the Order is not applicable to the Company.
(xv) In our opinion and according to the information and explanations given to usduring the year the Company has not entered into any non-cash transactions with itsDirectors or persons connected to its directors and hence provisions of section 192 of theCompanies Act 2013 are not applicable tothe Company.
(xvi) The Company is not required to be registered under section 45-IA of the ReserveBank of India Act 1934.
| ||For L. S. KOTHARI & CO |
| ||Chartered Accountants |
| ||ICAI Firm Registration No.001450C |
| ||Lalit Kothari |
| ||Partner |
|Camp: Udaipur May 28 2019 ||Membership No.: 081407 |