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Milton Industries Ltd.

BSE: 535025 Sector: Others
NSE: MILTON ISIN Code: INE376Y01016
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Milton Industries Ltd. (MILTON) - Auditors Report

Company auditors report

To

The Members of

Milton Industries Limited (CIN: L20299GJ1985PLC008047)

Report on the Audit of the Financial Statements

Opinion

We have audited the financial statements of Milton Industries Limited ("theCompany") which comprise the balance sheet as at 31st March 2022 the statement ofProfit and Loss and statement of cash flows for the year then ended and notes to thefinancial statements including a summary of significant accounting policies and otherexplanatory information In our opinion and to the best of our information and according tothe explanations given to us the aforesaid financial statements give the informationrequired by the Companies Act 2013 ("The Act") in the manner so required andgive a true and fair view in conformity with the accounting principles generally acceptedin India of the state of affairs of the Company as at March 31 2022 and profit and itscash flows for the year ended on that date.

Basis for Opinion

We conducted our audit in accordance with the Standards on Auditing (SAs) specifiedunder section 143(10) of the Companies Act 2013. Our responsibilities under thoseStandards are further described in the Auditor's Responsibilities for the Audit of theFinancial Statements section of our report. We are independent of the Company inaccordance with the Code of Ethics issued by the Institute of Chartered Accountants ofIndia together with the ethical requirements that are relevant to our audit of thefinancial statements under the provisions of the Act and the Rules thereunder and we havefulfilled our other ethical responsibilities in accordance with these requirements and theCode of Ethics. We believe that the audit evidence we have obtained is sufficient andappropriate to provide a basis for our opinion.

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.

We have determined the other Key matters described below to be the key audit matters tobe communicated in our report.

Key Audit matter How our audit addressed key Audit matter
Assessment of litigations and related disclosure of contingent liabilities Our audit procedures included the following;
(Refer to Annexure I of significant accounting policies and practices to the financial statements) - We understood assessed and tested the design and operating effectiveness of key controls surrounding assessment of litigations relating to the relevant laws and regulations;
"Use of estimates and critical accounting judgements
- Provisions and contingent liabilities" Note 35 to the Financial Statements - "Contingent Liability and Commitments" - We discussed with management and those charged with the governance the recent developments and the status of the material litigations which were reviewed and noted;
Significant management judgement is required to assess the contingent liabilities to determine the probability of occurrence of material outflow of economic resources and whether a provision should be recognized or a disclosure should be made. The management judgement is also supported with legal advice in certain cases as considered appropriate. Therefore it is considered to be a Key Audit Matter. - We performed our assessment on a test basis on the underlying calculations supporting the contingent liabilities/ other significant litigations disclosed in the Financial Statements;
- We considered external legal opinions where relevant obtained by management;
- We evaluated management's assessment around those matters that are not disclosed or not considered as contingent liability as tlie probability of material outflow is considered to be remote by the management; and
- We assessed the adequacy of the Company's disclosures.
Based on the above work performed the assessment in respect of litigations and; related disclosures relating to contingentliabilities/other significant litigations in the Financial Statements is considered to be reasonable.

Emphasis of Matter

We draw the attention that financial results which indicate that the company has shownreceivable as short term loans & advances with a company in which there is adisagreement regarding the tenure. The Company has taken legal action/recourse and isexamining other options for recovery. Interest thereon as matter of prudence has notbeen provided in accounts. During the year company received principal payment for the saidloan & advances.

Our opinion is not modified in respect of this matter.

Information other than the financial statements and auditors' 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 Annexure to Board's Report Business Responsibility Report CorporateGovernance and Shareholder's Information but does not include the financial statementsand our auditor's report thereon. Our opinion on the financial statements does not coverthe other information and we do not express any form of assurance conclusion thereon. Inconnection with our audit of the financial statements our responsibility is to read theother information and in doing so consider whether the other information is materiallyinconsistent with the financial statements or our knowledge obtained during the course ofour 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 Financial Statements

The Company's Board of Directors is responsible for the matters stated in section134(5) of the Act with respect to the preparation of these financial statements that givea true and fair view of the financial position financial performance and cash flows ofthe Company in accordance with the accounting principles generally accepted in Indiaincluding the accounting Standards specified under section 133 of the Act. Thisresponsibility also includes maintenance of adequate accounting records in accordance withthe provisions of the Act for safeguarding of the assets of the Company and for preventingand detecting frauds and other irregularities; selection and application of appropriateaccounting policies; making judgments and estimates that are reasonable and prudent; anddesign implementation and maintenance of adequate internal financial controls that wereoperating effectively for ensuring the accuracy and completeness of the accountingrecords relevant to the preparation and presentation of the financial statement that givea true and fair view and are free from material misstatement whether due to fraud orerror.

In preparing the financial statements management is responsible for assessing theCompany's ability to continue as a going concern disclosing as applicable mattersrelated to going concern and using the going concern basis of accounting unless managementeither intends to liquidate the Company or to cease operations or has no realisticalternative but to do so. The Board of Directors is also responsible for overseeing theCompany'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 scepticism 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 Companies Act 2013 we are also responsible for expressing our opinion on whetherthe company 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 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.

Materiality is the magnitude of misstatements in the financial statements thatindividually or in aggregate makes it probable that the economic decisions of areasonably knowledgeable user of the financial statements may be influenced. We considerquantitative materiality and qualitative factors in (i) Planning the scope of our auditwork and in evaluating the results of our work; and (ii) to evaluate the effect of anyidentified misstatements in the financial statements.

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

We also provide those charged with governance withal 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 withthose charged with governance we determine those matters that were of most significancein the audit of the financial statements of the current period and are therefore the keyaudit matters. We describe these matters in our auditor's report unless law or regulationprecludes public disclosure about the matter or when in extremely rare circumstances wedetermine that a matter should not be communicated in our report because the adverseconsequences of doing so would reasonably be expected to outweigh the public interestbenefits of such communication.

Our report is not modified in respect of these matters.

Report on Other Legal and Regulatory Requirements

As required by the Companies (Auditor's Report) Order 2020 ("the Order")issued by the Central Government of India in terms of sub-section (11) of section 143 ofthe Companies Act 2013 we give in the Annexure "A" statement on the mattersspecified in paragraphs 3 and 4 of the Order to the extent applicable.

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) 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 and the Cash Flow Statementdealt with by this Report are in agreement with the books of account;

(d) In our opinion the aforesaid financial statements comply with the AccountingStandards specified 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 31stMarch 2022 taken on record by the Board of Directors none of the directors isdisqualified as on 31st March 2022 from being appointed as a director in terms of Section164 (2) of the Act;

(f) With respect to the adequacy of the internal financial controls over financialreporting of the Company and the operating effectiveness of such controls refer to ourseparate Report in "Annexure B";

(g) With respect to the other matters to be included in the Auditor's Report inaccordance with the requirements of section 197(16) of the Act as amended in our opinionand to the best of our information and according to the explanations given to us theremuneration paid by the Company to its directors during the year is in accordance withthe provisions of section 197 of the Act; and

(h) With respect to the other matters to be included in the Auditor's Report inaccordance with Rule 11 of the Companies (Audit and Auditors) Rules 2014 in our opinionand to the best of our information and according to the explanations given to us:

i. Except disputed tax liabilities mentioned in Annexure A point (vii) (c) the Companydoes not have any pending litigations which would impact its financial position.

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

iii. There were no amounts which were required to be transferred to the InvestorEducation and Protection Fund by the Company.

iv. a) The management has represented that to the best of its knowledge and beliefthat no funds have been advanced or loaned or invested (either from borrowed funds orshare premium or any other sources or kind of funds) by the company to or in any otherperson(s) or entity(ies) including foreign entities ("Intermediaries") withthe understanding whether recorded in writing or otherwise that the Intermediary shallwhether directly or indirectly lend or invest in other persons or entities identified inany manner whatsoever by or on behalf of the company ("Ultimate Beneficiaries")or provide any guarantee security or the like on behalf of the Ultimate Beneficiaries;

b) The management has represented that to the best of its knowledge and belief thatno funds have been received by the company from any person(s) or entity(ies) includingforeign entities ("Funding Parties") with the understanding whether recordedin writing or otherwise that the company shall whether directly or indirectly lend orinvest in other persons or entities identified in any manner whatsoever by or on behalf ofthe Funding Party ("Ultimate Beneficiaries") or provide any guarantee securityor the like on behalf of the Ultimate Beneficiaries; and

c) Based on such audit procedures that have been considered reasonable and appropriatein the circumstances nothing has come to their notice that has caused us to believe thatthe representations under sub-clause (i) and (ii) of Rule 11 (e) as provided under (a)and (b) above contain any material mis-statement.

d) The dividend declared or paid during the year is in compliance with section 123 ofthe Companies Act 2013.

For KPSJ&ASSOCIATES LLP

(Chartered Accountants)

FRN: 124845W/W100209

Sd/-

PRAKASH PARAKH

Partner

M.NO: 039946

UDIN: 22039946AQMCKP4509

Place: Ahmedabad

Date: 29/07/2022

Annexure "A" to the Independent Auditor's Report (Contd.)

(Referred to paragraph under ‘Report on other legal and regulatory requirements'section of the Independent Auditors' Report of even date to the members of MILTONINDUSTRIES LIMITED on the financial statements for the year ended March 312022)

Based on the audit procedures performed for the purpose of reporting a true and fairview on the financial statements of the Company and taking into consideration theinformation and explanations given to us and the books of account and other recordsexamined by us in the normal course of audit and to the best of our knowledge and beliefwe report that:

i. In respect of the Company's Property Plant & Equipment and Intangible assets:

(a)(A) The company has maintained proper records showing full particulars includingquantitative details and situation of Property Plant and Equipment and relevant detailsof right-of-use.

(B) The company has no intangible assets present for the period under review;

(b) The company has a regular programme for physical verification in a phased periodicmanner which in our opinion is reasonable having regards to the size of the company andthe nature of its assets. No material discrepancies were noticed on such verifications.

(c) According to information and explanations given by the management the titledeeds/lease deeds of immovable Properties included in Property Plant and equipment areheld in the name of company.

(d) According to the information and explanations given to us and on the basis of ourexamination of the records of the Company the Company has not revalued its Propertyplant and equipment (including Right-of-use assets).

(e) According to the information and explanations given to us and on the basis of ourexamination of the records of the Company there are no proceedings initiated or pendingagainst the Company for holding any benami property under the Prohibition of benamiProperty Transactions Act 1988 and rules made thereunder.

ii. (a) Physical verification of inventory has been conducted at reasonable intervalsduring the year by the management and no material discrepancies were noticed on suchphysical verification.

(b) During any point of time of the year the company has not been sanctioned workingcapital limits in excess of Five Crore rupees in aggregate from banks or financialinstitutions;

iii. According to the information and explanations given to us and on the basis of ourexamination of the records of the Company the Company has not made investments providedany guarantee or security to companies firms limited liability partnerships or any otherparties during the year. The Company has granted loans to companies firms limitedliability partnerships or any other parties during the year details of the loan is statedin sub-clause (a) below.

(a) A. Based on the audit procedures carried on by us and as per the information andexplanations given to us the Company does not have any subsidiaries for the period underreview.

B. Based on the audit procedures carried on by us and as per the information andexplanations given to us the Company has granted loans to parties other than subsidiariesmore specifically mentioned in the financial statements of the company. The company hasoutstanding balance of Rs. 0.41 crores receivable as short term loan and advances.

(b) According to the information and explanations given to us and based on the auditprocedures conducted by us we are of the opinion that the terms and conditions of theloans given are prima facie not prejudicial to the interest of the Company.

(c) According to the information and explanations given to us and on the basis of ourexamination of the records of the Company in the case of loans given the repayment ofprincipal and payment of interest has been stipulated and the repayments or receipts havebeen regular.

(d) According to the information and explanations given to us and on the basis of ourexamination of the records of the Company there is no overdue amount for more than ninetydays in respect of loans given.

(e) According to the information and explanations given to us and on the basis of ourexamination of the records of the Company there is no loan given falling due during theyear which has been renewed or extended or fresh loans given to settle the over dues ofexisting loans given to the same party.

(f) According to the information and explanations given to us and on the basis of ourexamination of the records of the Company the Company has not given any loans eitherrepayable on demand or without specifying any terms or period of repayment.

iv. In our opinion and according to information and explanation given to us in respectof loans investments guarantees and security the Company has complied with theprovisions of sections 185 and section 186 of the Companies Act 2013.

v. In our opinion and according to the information and explanations given to us thecompany has not accepted any deposits and accordingly paragraph 3 (v) of the order is notapplicable.

vi. In our opinion and according to information and explanation given to us theprovisions of section 148 of the companies act 2013 is not applicable to the company forthe period under review accordingly paragraph 3 (vi) of the order is not applicable.

vii. In respect of statutory dues:

(a) According to the information and explanations given to us and on the basis of ourexamination of the records of the Company amounts deducted/ accrued in the books ofaccount in respect of undisputed statutory dues including provident fund employees' stateinsurance income-tax sales- tax service tax goods and service tax duty of customsduty of excise value added tax cess and other material statutory dues have beengenerally regularly deposited during the year by the company with the appropriateauthorities.

(b) According to the information and explanations given to us no undisputed amountspayable in respect of provident fund employees' state insurance income-tax sales- taxservice tax goods and service tax duty of customs duty of excise value added tax cessand other material statutory dues were in arrears as at March 31 2022 for a period ofmore than six months from the date they became payable

(c) According to the information and explanations given to us and the records of thecompany examined by us there are no dues of income-tax sales- tax service tax goodsand service tax duty of customs duty of excise and value added tax which have not beendeposited on account of any dispute except followings;

Statute Nature of Dues Amount (Rs. in Lacs) Period to which the amount relates
Income tax Act 1961 Income Tax 290321 2007
Income tax Act1961 Income Tax 1340 2015
Income tax Act1961 Income Tax 16230 2010
Income tax Act1961 Income Tax 28760 2014
Income tax Act1961 Income Tax 713410 2018
Income tax Act1961 Income Tax 227670 2019
Income tax Act1961 Income Tax 906671 2003
Income tax Act 1961 Income Tax 44434 2004
Income tax Act 1961 Income Tax 153345 2009
Income tax Act 1961 Income Tax 171298 2008
Income tax Act 1961 Income Tax 1035262 1991
Income tax Act 1961 Income Tax 1556225 1998
Income tax Act 1961 Income Tax 177810 2005
Income tax Act 1961 Income Tax 197178 2001
5519954

viii According to the information and explanations given to us and on the basis of ourexamination

of the records of the Company the Company has not surrendered or disclosed anytransactions previously unrecorded as income in the books of account in the taxassessments under the Income- tax Act 1961 as income during the year.

ix. According to information and explanation given to us (a) The company has notdefaulted in repayment of loans or other borrowings or in the payment of interest thereonto any lender.

(b) The company has not been declared wilful defaulter by any bank or financialinstitution or other lender;

(c) The company has accepted term loans for the period under review and has applied thesame for the purpose for which it was borrowed;

(d) The company has not raised funds on short term basis which have been utilized forlong term purposes.

(e) The company has not taken any funds from any entity or person on account of or tomeet the obligations of its subsidiaries associates or joint ventures.

(f) The company has not raised any loans during the year on the pledge of securitiesheld in its subsidiaries joint ventures or associate companies.

x. (a) The company has not raised moneys by way of initial public offer or furtherpublic offer (including debt instruments) during the year and hence reporting under clause3(x)(a) of the order is not applicable.

(b) The company has not made any preferential allotment or private placement of sharesor convertible debentures (fully partially or optionally convertible) during the year andhence reporting under clause 3(x)(b) of the order is not applicable.

xi. (a) According to the information available with us no fraud by the company and nofraud on the company has been noticed or reported during the year.

(b) According to the information available with us no report under sub-section (12) ofsection 143 of the Companies Act has been filed by the auditors in F orm ADT-4 asprescribed under rule 13 of Companies (Audit and Auditors) Rules 2014 with the CentralGovernment; during the year and up to the date of this report.

(c) As represented to us by the management there were no whistle-blower complaintsreceived during the year and hence reporting under clause 3(xi)(c) of the order is notapplicable.

xii. The Company is not a Nidhi Company has complied and hence reporting under clause(xii) of the order is not applicable.

xiii. In our opinion and according to the information and explanations given to us thetransactions with related parties are in compliance with Sections 177 and 188 of theCompanies Act 2013 where applicable and the details of the related party transactionshave been disclosed in the financial statements as required by the applicable IndianAccounting Standards.

xiv. (a) Based on information and explanations provided to us and our audit proceduresin our opinion the Company has an internal audit system commensurate with the size andnature of its business;

(b) We have considered the internal audit reports of the Company issued till date forthe period under audit.

xv. According to the information given to us the company has not entered into anynon-cash transactions with directors or persons connected with him Hence the provisionsof section 192 of Companies Act are not applicable to the company.

xvi. (a) According to the information given to us the company is not required to beregistered under section 45-IA of the Reserve Bank of India Act 1934 (2 of 1934). Hencereporting under this clause not applicable to the company.

(b) According to the information given to us the company has not conducted anyNon-Banking Financial or Housing Finance activities without a valid Certificate ofRegistration (CoR) from the Reserve Bank of India as per the Reserve Bank of India Act1934. Hence reporting under this clause not applicable to the company.

(c) According to the information given to us the company is not a Core InvestmentCompany (CIC) as defined in the regulations made by the Reserve Bank of India. Hencereporting under this clause not applicable to the company.

(d) According to the information given to us there is no Core Investment Company (CIC)within the Group (as defined in the core investment companies (Reserve Bank of India)Directions 2016) and accordingly reporting under this clause not applicable to thecompany.

xvii. According to the information given to us the Company has not incurred cashlosses during the financial year covered by our audit and the immediately precedingfinancial year.

xviii. There has been no resignation of the statutory auditors during the year.

xix. On the basis of the financial ratios ageing and expected dates of realisation offinancial assets and payment of financial liabilities other information accompanying thefinancial statements and our knowledge of the board of directors and management plans andbased on our examination of the evidence supporting the assumptions nothing has come toour attention which causes us to believe that any material uncertainty exists as on thedate of the audit report that indicating that company is not capable of meeting itsliabilities existing at the date of balance sheet as and when they fall due within aperiod of one year from the balance sheet date. We however state that our reporting isbased on the facts up to the date of audit report and we neither give any guarantee norany assurance that all liabilities falling due within a period of one year from thebalance sheet date will get discharged by the company as and when they fall due.

xx. In our opinion and according to the information and explanations given to us thereis no unspent amount under sub-section (5) of Section 135 of the Companies Act 2013pursuant to any project. Accordingly clauses 3(xx)(a) and 3(xx)(b) of the Order are notapplicable.

For: KPSJ&ASSOCIATES LLP

(Chartered Accountants)

FRN: 124845W/W100209

Sd/-

PRAKASH PARAKH

Partner

M.NO: 039946

UDIN: 22039946AQMCKP4509

Place: Ahmedabad

Date: 29/07/2022

Annexure "B" to the Independent Auditor's Report

(Referred to in paragraph (f) under ‘Report on other legal and regulatoryrequirements 'section of our report to the Members of MILTON INDUSTRIES LIMITED of evendate)

Report on the internal financial controls over financial reporting under clause (I) ofsub - section 3of section 143 of the Companies Act 2013 ("the Act")

We have audited the internal financial controls over financial reporting of MiltonIndustries Limited("the Company")as at March 31 2022 in conjunction with ouraudit of the financial statements ofthe Company for the year ended on that date.

Management's responsibility for internal financial controls

The board of directors of the Company is responsible for establishing and maintaininginternal financial controls based on the internal control over financial reportingcriteria established by the Company considering the essential components of 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 the safeguarding of its assets the prevention and detection offrauds and errors the accuracy and completeness ofthe accounting records and the timelypreparation of reliable financial information as required under the Companies Act 2013.

Auditors' responsibility

Our responsibility is to express an opinion on the internal financial controls overfinancial reporting of the Company based on our audit. We conducted our audit inaccordance with the Guidance Note on Audit of Internal Financial Controls Over FinancialReporting (the "Guidance Note") issued by the Institute of Chartered Accountantsof India and the standards on auditing prescribed under Sectionl43 (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 were established and maintained and if suchcontrols operated effectively in all material respects. Our audit involves performingprocedures to obtain audit evidence about the adequacy of the internal financial controlssystem over financial reporting and their operating effectiveness. Our audit of internalfinancial controls over financial reporting included obtaining an understanding ofinternal financial controls over financial reporting assessing the risk that a materialweakness exists and testing and evaluating the design and operating effectiveness ofinternal control based on the assessed risk. The procedures selected depend on theauditor's judgment including the assessment of the risks of material misstatement in thefinancial 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 control systemover financial reporting.

Meaning of internal financial controls over financial reporting

A company's internal financial control over financial reporting is a process designedto provide reasonable assurance regarding the reliability of financial reporting and thepreparation of financial statements for external purposes in accordance with generallyaccepted accounting principles. A company's internal financial control over financialreporting includes those policies and procedures that

(i) pertain to the maintenance of records that in reasonable detail accurately andfairly reflect the transactions and dispositions of the assets of the company;

(ii) 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

(iii) 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.

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 of override ofcontrols material misstatements due to error or fraud may occur and not be detected.Also projections of any evaluation of the internal financial controls over financialreporting to future periods are subject to the risk that the internal financial controlover financial reporting may become inadequate because of changes in conditions or thatthe degree of compliance with the policies or procedures may deteriorate.

Opinion

In our opinion and according to the information and explanations given to us theCompany has in all material respects an adequate internal financial control system overfinancial reporting and such internal financial controls over financial reporting wereoperating effectively as at March 31 2022 based on the internal control over financialreporting 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.

For: KPSJ&ASSOCIATES LLP

(Chartered Accountants)

FRN: 124845W/W100209

Sd/-

PRAKASH PARAKH

Partner

M.NO: 039946

UDIN: 22039946AQMCKP4509

Place: Ahmedabad

Date: 29/07/2022.

.