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Modi Rubber Ltd.

BSE: 500890 Sector: Others
NSE: MODIRUBBER ISIN Code: INE832A01018
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OPEN 67.05
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VOLUME 5
52-Week high 89.25
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P/E 19.43
Mkt Cap.(Rs cr) 168
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OPEN 67.05
CLOSE 67.05
VOLUME 5
52-Week high 89.25
52-Week low 51.55
P/E 19.43
Mkt Cap.(Rs cr) 168
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

Modi Rubber Ltd. (MODIRUBBER) - Auditors Report

Company auditors report

To THE MEMBERS OF MODI RUBBER LIMITED

Report on the Audit of the Standalone Financial Statements

Opinion

We have audited the accompanying standalone financial statements of ModiRubber Limited ("the Company") which comprise the Balance sheet as atMarch 31 2022 the Statement of Profit and Loss (including Other Comprehensive Income)the Statement of Changes in Equity and the Statement of Cash Flows for the year ended onthat date and a summary of significant accounting policies and other explanatoryinformation (hereinafter referred to as the "standalone financial statements").

In our opinion and to the best of our information and according to theexplanations given to us the aforesaid standalone financial statements give theinformation required by the Companies Act 2013 ("the Act") in the manner sorequired and give a true and fair view in conformity with the accounting principlesgenerally accepted in India of the state of affairs of the Company as at 31 March 2022and profit (including other comprehensive income) changes in equity and its cash flowsfor the year ended on that date.

Basis for Opinion

We conducted our audit of the standalone financial statements inaccordance with the Standards on Auditing ("SA"s) specified under section143(10) of the Act. Our responsibilities under those Standards are further described inthe Auditor's Responsibilities for the Audit of the standalone financial statementssection of our report. We are independent of the Company in accordance with the Code ofEthics issued by the Institute of Chartered Accountants of India ("ICAI")together with the ethical requirements that are relevant to our audit of the standalonefinancial statements under the provisions of the Act and the Rules made thereunder and wehave fulfilled our other ethical responsibilities in accordance with these requirementsand the ICAI's Code of Ethics. We believe that the audit evidence obtained by us issufficient and appropriate to provide a basis for our audit opinion on the standalonefinancial statements.

Key Audit Matters

Key audit matters ('KAM') are those matters that in our professionaljudgment were of most significance in our audit of the standalone financial statements ofthe current period. These matters were addressed in the context of our audit of thestandalone financial statements as a whole and in forming our opinion thereon and we donot provide a separate opinion on these matters.

Sr. No. The key audit matter Auditor?s Response
1 Evaluation of contingencies & uncertain tax positions Principal Audit Procedures Performed
Prior to closure of operations by illegal strikes of the workers in August 2001 and thereafter sanction of Rehabilitation Scheme under the provisions of SICA by BIFR on 21.04.2008 (refer note 41 & 42 of financial statements) the Company operated in multiple jurisdictions and subjected to periodic challenges by local tax authorities income tax authorities labour law authorities & other statutory authorities on a range of various tax & other matters during the normal course of business. These involve significant management judgment to determine the possible outcome of the uncertain tax positions & other contingencies consequently having an impact on related accounting and disclosures in the standalone financial statements. Our audit procedures include the following substantive procedures:
Refer Note 2(m) Note 24(a) & Note 40 to the standalone financial statements. • Obtained understanding of key contingencies & uncertain tax positions and;
• We along with our internal legal experts:
Read and analysed select key correspondences external legal opinions / consultations by management for key contingencies & uncertain tax positions;
Discussed with appropriate senior management and evaluated management?s underlying key assumptions in estimating the tax provisions; and
Assessed managements estimate of the possible outcome of the disputed cases.
2 Revaluation of Freehold Land Principal Audit Procedures Performed
The Company revalued their freehold land during the year and recognised a revaluation gain of Rs. 18938.52 lacs as "increase in fair value of freehold land" under other comprehensive income in the statement of profit and loss as per the requirement of Ind AS 16. Our procedures in relation to the valuation of freehold land held by the Company included:
Management has engaged independent valuers to estimate the fair value of the freehold land who have inter-alia used ‘reference to circle rates? approach accessibility to freehold land and other valuation technique as appropriate to arrive at fair valuation of freehold land. • Evaluating the independent valuers? competence capabilities and objectivity.
The valuation of freehold land depends on certain key assumptions that require significant judgements as stated in note no. 3 to the standalone financial statements which led us to consider this a key audit matter. • Obtaining the valuation reports.
• Checking the accuracy of the input data on a sample basis used by the independent valuers supporting documentation including:
Title deeds of freehold lands
Circle rates used by independent valuers.
We found the key assumptions used in management?s valuation of freehold land were supported by the available evidence.

Information Other than the Financial Statements and Auditor's ReportThereon

The Company's Board of Directors is responsible for the otherinformation. The other information comprises the information included in the Board'sReport but does not include the standalone financial statements and our auditors' reportthereon.

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

In connection with our audit of the standalone financial statementsour responsibility is to read the other information and in doing so consider whethersuch other information is materially inconsistent with the standalone financialstatements or our knowledge obtained in the audit or otherwise appears to be materiallymisstated. 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 Ind AS Financial Statements

The Company's Board of Directors is responsible for the matters statedin Section 134(5) of the Companies Act 2013 ("the Act") with respect to thepreparation of these standalone financial statements that give a true and fair view of thefinancial position financial performance changes in equity and cash flows of the Companyin accordance with the accounting principles generally accepted in India including theIndian Accounting Standards (Ind AS) 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 standalone financialstatements that give a true and fair view and are free from material misstatement whetherdue to fraud or error.

In preparing the financial statements management and Board ofDirectors are responsible for assessing the Company's ability to continue as a goingconcern disclosing as applicable matters related to going concern and using the goingconcern basis of accounting unless management either intends to liquidate the Company orto cease operations or has no realistic alternative but to do so.

Board of Directors is also responsible for overseeing the Company'sfinancial reporting process.

Auditors Responsibility for the Audit of the Standalone FinancialStatements

Our objectives are to obtain reasonable assurance about whether thefinancial 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 professionaljudgment and maintain professional skepticism throughout the audit. We also:

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

• Obtain an understanding of internal control relevant to theaudit in order to design audit procedures that are appropriate in the circumstances. UnderSection 143(3)(i) of the Act if applicable we are also responsible for expressing ouropinion on whether the company has adequate internal financial controls with reference tostandalone financial statements in place and the operating effectiveness of such controls.

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

• Conclude on the appropriateness of management's use of the goingconcern basis of accounting and based on the audit evidence obtained whether a materialuncertainty exists related to events or conditions that may cast significant doubt on theCompany's ability to continue as a going concern. If we conclude that a materialuncertainty exists we are required to draw attention in our auditor's report to therelated disclosures in the standalone financial statements or if such disclosures areinadequate to modify our opinion. Our conclusions are based on the audit evidenceobtained up to the date of our auditors' report. However future events or conditions maycause the Company to cease to continue as a going concern.

• Evaluate the overall presentation structure and content of thestandalone financial statements including the disclosures and whether the standalonefinancial statements represent the underlying transactions and events in a manner thatachieves fair presentation.

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

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

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

Report on Other Legal and Regulatory Requirements

1. As required by the Companies (Auditor's Report) Order 2020 (the"Order") issued by the Central Government in terms of Section 143(11) of theAct we give in "Annexure A" a statement on the matters specified in paragraphs3 and 4 of the Order.

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

a. We have sought and obtained all the information and explanationswhich to the best of our knowledge and belief were necessary for the purposes of ouraudit.

b. In our opinion proper books of account as required by law have beenkept 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 theStatement of Other Comprehensive Income the Statement of Changes in Equity and theStatement of Cash Flows dealt with by this Report are in agreement with the books ofaccount.

d. In our opinion the aforesaid standalone financial statements complywith the Ind AS as specified under Section 133 of the Act.

e. On the basis of the written representations received from thedirectors as on March 31 2022 taken on record by the Board of Directors none of thedirectors is disqualified as on March 31 2022 from being appointed as a director interms of Section 164(2) of the Act.

f. With respect to the adequacy of the internal financial controls overfinancial reporting of the Company with reference to these standalone financial statementsand the operating effectiveness of such controls refer to our separate report in"Annexure B" to this report. Our report expresses an unmodified opinion on theadequacy and operating effectiveness of the Company's internal financial controls overfinancial reporting.

g. In our opinion and according to the information and explanationsgiven to us the remuneration paid by the Company to its directors during the current yearis in accordance with the provisions of Section 197 of the Act. The remuneration paid toany director is not in excess of the limit laid down under Section 197 of the Act. TheMinistry of Corporate Affairs has not prescribed other details under Section 197(16) whichare required to be commented upon by us.

h. With respect to the other matters to be included in the Auditor'sReport in accordance with Rule 11 of the Companies (Audit and Auditors) Rules 2014 asamended in our opinion and to the best of our information and according to theexplanations given to us:

i. The Company has disclosed the impact of pending litigation on itsfinancial position in its financial statements- Refer note 42 to the financial statements.

ii. The Company did not have any long-term contracts includingderivative contracts for which there were any material foreseeable losses.

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

iv. (a) The Management has represented that to the best of itsknowledge and belief no funds (which are material either individually or in theaggregate) have been advanced or loaned or invested (either from borrowed funds or sharepremium or any other sources or kind of funds) by the company to or in any other person(s)or entity(ies) including foreign entities ("Intermediaries") with theunderstanding 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 knowledgeand belief no funds (which are material either individually or in the aggregate) havebeen received by the Company from any person or entity including foreign entity("Funding Parties") with the understanding whether recorded in writing orotherwise that the Company shall whether directly or indirectly lend or invest inother persons or entities identified in any manner whatsoever by or on behalf of theFunding Party ("Ultimate Beneficiaries") or provide any guarantee security orthe like on behalf of the Ultimate Beneficiaries;

(c) Based on the audit procedures that have been considered reasonableand appropriate in the circumstances nothing has come to our notice that has caused us tobelieve that the representations under sub-clause (i) and (ii) of Rule 11(e) as providedunder (a) and (b) above contain any material misstatement.

v. The company has not declared or paid any dividend during the yearand has not proposed final dividend for the year.

For Suresh Surana & Associates LLP
Chartered Accountants
Firm's Registration No. 121750 W / W-100010
SD
Kapil Kedar Place: New Delhi
Partner Dated: May 28 2022
Membership No. 094902 UDIN: 22094902AJUPSW8180

ANNEXURE A TO INDEPENDENT AUDITORS' REPORT

(Referred to in paragraph 1 under 'Report on Other Legal and RegulatoryRequirements' section of our report to the Members of the Company of even date)

To the best of our information and according to the explanationsprovided to us by the Company and the books of account and records examined by us in thenormal course of audit we state that:

i. In respect of the Company's Property Plant and Equipment andIntangible Assets:

(a) (A) The Company has maintained proper records showing fullparticulars including quantitative details and situation of Property Plant and Equipmentand relevant details of right-of-use assets.

(B) The Company has maintained proper records showing full particularsof intangible assets.

(b) The Company has a program of physical verification of PropertyPlant and Equipment and right-of-use assets (except the assets which the Company has noaccess) so to cover all the assets once every three years. Accordingly physicalverification of Property Plant and Equipment and right-of-use assets (except the assetswhich the Company has no access) was carried out in financial year 2019-20 which in ouropinion is reasonable having regard to the size of the Company and the nature of itsassets. According to the information and explanations given to us no materialdiscrepancies were noticed on such verification.

(c) According to the information and explanations given to us and onthe basis of our examination of the records of the Company the title deeds of immovableproperties are held in the name of the Company as at the balance sheet date except thefollowing cases (Refer Note 3 of standalone financial statements).

(d) The Company has revalued its Freehold Land (other than land underdispute) during the year and the revaluation is based on the valuation by a RegisteredValuer the details of revaluation of Property plant and equipment is as below:

Description of property Gross carrying value (Rs. in Lacs) Held in name of Whether promoter director or their relative or employee Period held - indicate range where appropriate Reason for not being held in name of company
Patel House Mumbai 27.49 Parmanand Tulsidas Patel No May 06 1982 Pending for registration
15 Friends Colony West New Delhi 2.07 Arun Kumar Kapur (HUF) No February 02 1984 Pending for registration
15 Friends Colony West New Delhi 18.96 Arun Kumar Kapur (HUF) No February 02 1984 Pending for registration
Class of assets Carrying value (in lacs) Revalued amount (in lacs) Revaluation amount (in lacs) Change
Freehold land 183.90 19122.42 18938.52 10298.27%

(e) No proceedings have been initiated during the year or are pendingagainst the Company as at March 31 2022 for holding any benami property under the BenamiTransactions (Prohibition) Act 1988 (as amended in 2016) and rules made thereunder.

II. (a) According to the information and explanations given to us themanagement has not conducted physical verification of inventory during the year due to noaccess to such inventory (Refer note 9 and 45 to the financial statements).

(b) The Company has not availed working capital limits in excess offive crore rupees in aggregate from banks or financial institutions on the basis ofsecurity of current assets; and hence reporting under clause 3(ii)(b) of the Order is notapplicable.

III. In our opinion and according to the information and explanationsgiven to us the Company has provided loans or advances in the nature of loans secured orunsecured to companies during the year in respect of which:

(a) The Company has provided loans or provided advances in the natureof loans to it's group companies details of which is given below:

Particulars Loan Amount (Rs. in Lacs)
Aggregate amount granted during the year 19.90
Balance outstanding at the balance sheet date in respect of above 157.99*

* The Company has considered this loan as doubtful of recovery.

(b) No investments made guarantees provided security given during theyear and hence reporting under clause 3(iii)(b) of the Order is not applicable.

(c) In respect of loans granted by the Company to its joint venturecompany repayment of the principal amount is not stipulated and payment of interest isnot regular details are given below:

Name of the Entity Amount (Rs. in Lacs) Due date Extent of delay (days) Remarks
Modi Marco Aldany Pvt. Ltd. 133.90 Not stipulated Not applicable The Company has considered this loan as doubtful of recovery.

(d) According to the information and explanations given to us and basedon our audit procedures and the information and explanation made available to us whereamount is overdue for more than ninety days are given below:

No. of cases Principal Amount overdue (Rs. in Lacs) Interest overdue (Rs. in Lacs) Total overdue (Rs.in Lacs) Remarks
1 133.90 20.58 152.53 The Company has considered this loan as doubtful of recovery.

(e) In our opinion and according to the information and explanationsgiven to us there are no loans which has been renewed or extended or fresh loan grantedto settle the overdues of existing loans given to the same parties and hence no reportingis made in this regard.

(f) In our opinion and according to the information and explanationsgiven to us the company has granted unsecured loan to its joint venture company withoutspecifying any terms or period of repayment details of the same is given below:

Particulars Amount (Rs. in Lacs)
Aggregate amount of loans
- Repayable on demand and agreement does not specify any terms or 157.99
period of repayment (A)
- Total Loans - (B) 157.99
Percentage of loans/advances in nature of loan to the total loans (A/B) 100%

iv. In our opinion and according to the information and explanationsgiven to us the Company has complied with the provisions of sections 185 and 186 of theAct in respect of the loans.

v. The Company has not accepted any deposit or amounts which are deemedto be deposits. Hence reporting under clause 3(v) of the Order is not applicable.

v1. In our opinion and according to the information and explanationsgiven to us the requirement for maintenance of cost records pursuant to the companies(cost records and audit) Rules 2014 specified by the Central Government of India underSection 148 of the Act are not applicable to the Company for the year under audit. v11. Inrespect of statutory dues:

(a) According to the information and explanations given to us theCompany is generally regular in depositing undisputed statutory dues including goods andservices Tax provident fund employee's state insurance income-tax duty of customs andany other statutory dues to the appropriate authorities during the year. According to theinformation and explanations given to us there are no undisputed amounts payable inrespect of such statutory dues which have remained outstanding as at March 31 2022 for aperiod of more than six months from the date they became payable.

(b) According to the information and explanations given to us thereare no disputed statutory dues including goods and services tax provident fundemployee's state insurance income-tax duty of customs and any other statutory dues tothe appropriate authorities other than the following:

Name of the statute Nature of dues Amount (Rs. Lacs) Period to which the amount relates Forum where dispute is pending
Central Excise Act 1944 Excise Duty 77.40 1977-78 Allahabad High Court
Central Excise Act 1944 Excise Duty 69.11 July 2001 Allahabad High Court
Foreign Trade Development and Regulation Act 1992 Custom Duty 200.00 1995-1996 Additional DGFT Commissioner (A)
Income Tax Act 1961 Income Tax 944.73 2003-2004 Delhi High Court
PGST ACT 1948 Sales Tax 17.53 1992 to 2002 Deputy Excise & Taxation Commissioner Jalandhar
Bihar Sales Tax Act Sales Tax 101.23 2001-2001 Commercial Taxes Tribunal Patna
UP Trade Tax Act Sales Tax 21.90 1977-1978 Allahabad High Court
UP Trade Tax Act Sales Tax 40.42 2000-2001 Allahabad High Court
UP Trade Tax Act Sales Tax 32.24 2001-2002 Allahabad High Court
UP Trade Tax Act Sales Tax 70.05 2001-2002 Allahabad High Court

Viii. According to the information and explanations given to us there were notransactions relating to previously unrecorded income that have been surrendered ordisclosed as income during the year in the tax assessments under the Income Tax Act 1961(43 of 1961).

ix. (a) The Company has not defaulted in repayment of loans or other borrowings or inthe payment of interest thereon to any lender.

(b) The Company has not been declared wilful defaulter by any bank or financialinstitution or government or any government authority.

(c) The Company has not taken any term loan during the year and hence reporting underclause 3(ix)(c) of the Order is not applicable.

(d) On an overall examination of the financial statements of the Company funds raisedon short-term basis have not been used during the year for long-term purposes by theCompany.

(e) On an overall examination of the financial statements of the Company the Companyhas not taken any funds from any entity or person on account of or to meet the obligationsof 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) During the year the Company has not made any preferential allotment or privateplacement of shares or convertible debentures (fully or partly or optionally) and hencereporting under clause 3(x)(b) of the Order is not applicable.

xi. (a) No fraud by the Company and no material fraud on the Company has been noticedor reported during the year.

(b) No report under sub-section (12) of section 143 of the Companies Act has been filedin Form ADT- 4 as prescribed under rule 13 of Companies (Audit and Auditors) Rules 2014with the Central Government during the year and upto the date of this report.

(c) As represented to us by the management there are no whistle blower complaintsreceived by the Company during the year.

xii. The Company is not a Nidhi Company and hence reporting under clause (xii) of theOrder is not applicable.

xiii. In our opinion the Company are in compliance with Section 177 and 188 of theCompanies Act 2013 with respect to applicable transactions with the related parties andthe details of related party transactions have been disclosed in the financial statementsas required by the applicable accounting standards.

XiV. (a) In our opinion the Company has an adequate internal audit system commensuratewith the size and the nature of its business.

(b) We have considered the internal audit reports for the year under audit issued tothe Company during the year and till date in determining the nature timing and extent ofour audit procedures.

xV. In our opinion during the year the Company has not entered into any non-cashtransactions with its directors or persons connected with its directors and henceprovisions of section 192 of the Companies Act 2013 are not applicable to the Company.

XVi. (a) In our opinion the Company is not required to be registered under section45-IA of the Reserve Bank of India Act 1934. Hence reporting under clause 3(xvi)(a) (b)and (c) of the Order is not applicable.

(b) In our opinion there is no core investment company within the Group (as defined inthe Core Investment Companies (Reserve Bank) Directions 2016) and accordingly reportingunder clause 3(xvi)(d) of the Order is not applicable.

xVii. The Company has not incurred any cash losses during the financial year covered byour audit and the immediately preceding financial year.

xViii. There has been no resignation of the statutory auditors of the Company duringthe 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 indicating that Company is not capable of meeting its liabilitiesexisting at the date of balance sheet as and when they fall due within a period of oneyear from the balance sheet date. We however state that this is not an assurance as tothe future viability of the Company. We further state that our reporting is based on thefacts up to the date of the audit report and we neither give any guarantee nor anyassurance that all liabilities falling due within a period of one year from the balancesheet date will get discharged by the Company as and when they fall due.

XX. The Company is not required to spent any amount towards Corporate SocialResponsibility (CSR). Accordingly reporting under clause 3(xx)(a) and (b) of the Order isnot applicable.

For Suresh Surana & Associates LLP
Chartered Accountants
Firm's Registration No. 121750 W / W-100010
SD
Kapil Kedar Place: New Delhi
Partner Dated: May 28 2022
Membership No. 094902 UDIN: 22094902AJUPSW8180

ANNEXURE B TO INDEPENDENT AUDITORS' REPORT

(Referred to in paragraph 2 (f) under "Report on Other Legal andRegulatory Requirements" section of our report of even date)

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

We have audited the internal financial controls over financialreporting of Modi Rubber Limited ("the Company") as on March 31 2022in conjunction with our audit of the financial statements of the Company for the yearended on that date.

Management's Responsibility for Internal Financial Controls

The Company's management is responsible for establishing andmaintaining internal financial controls 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 ('ICAI').These responsibilities include the design implementation and maintenance of adequateinternal financial controls that were operating effectively for ensuring the orderly andefficient conduct of its business including adherence to 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.

Auditors' Responsibility

Our responsibility is to express an opinion on the Company's internalfinancial controls over financial reporting based on our audit. We conducted our audit inaccordance with the Guidance Note on Audit of Internal Financial Controls over FinancialReporting (the "Guidance Note") and the Standards on Auditing issued by ICAIand deemed to be prescribed under section 143(10) of the Companies Act 2013 to theextent applicable to an audit of internal financial controls both applicable to an auditof Internal Financial Controls and both issued by the Institute of Chartered Accountantsof India. Those Standards and the Guidance Note require that we comply with ethicalrequirements and plan and perform the audit to obtain reasonable assurance about whetheradequate internal financial controls over financial reporting was established andmaintained and if such controls operated effectively in all material respects.

Our audit involves performing procedures to obtain audit evidence aboutthe adequacy of the internal financial controls system over financial reporting and theiroperating effectiveness. Our audit of internal financial controls over financial reportingincluded obtaining an understanding of internal financial controls over financialreporting assessing the risk that a material weakness exists and testing and evaluatingthe design and operating effectiveness of internal control based on the assessed risk. Theprocedures selected depend on the auditor's judgment including the assessment of therisks of material misstatement of the financial statements whether due to fraud or error.

We believe that the audit evidence we have obtained is sufficient andappropriate to provide a basis for our audit opinion on the Company's internal financialcontrols system over financial reporting.

Meaning of Internal Financial Controls over Financial Reporting

A company's internal financial control over financial reporting 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 control overfinancial reporting includes those policies and procedures that

(1) pertain to the maintenance of records that in reasonable detailaccurately and fairly reflect the transactions and dispositions of the assets of thecompany;

(2) provide reasonable assurance that transactions are recorded asnecessary to permit preparation of financial statements in accordance with generallyaccepted accounting principles and that receipts and expenditures of the company arebeing made only in accordance with authorisations of management and directors of thecompany; and

(3) provide reasonable assurance regarding prevention or timelydetection of unauthorised acquisition use or disposition of the company's assets thatcould have a material effect on the financial statements. Inherent Limitations ofInternal Financial Controls over Financial Reporting

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

Opinion

In our opinion the Company has in all material respects an adequateinternal financial controls system over financial reporting and such internal financialcontrols over financial reporting were operating effectively as at March 31 2022 basedon the internal control over financial reporting criteria established by the Companyconsidering the essential components of internal control stated in the Guidance Note onAudit of Internal Financial Controls Over Financial Reporting issued by the Institute ofChartered Accountants of India.

For Suresh Surana & Associates LLP
Chartered Accountants
Firm's Registration No. 121750 W / W-100010
SD
Kapil Kedar Place: New Delhi
Partner Dated: May 28 2022
Membership No. 094902 UDIN: 22094902AJUPSW8180

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