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National Steel & Agro Industries Ltd.

BSE: 513179 Sector: Metals & Mining
NSE: NATNLSTEEL ISIN Code: INE088B01015
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OPEN 3.89
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VOLUME 3108
52-Week high 7.17
52-Week low 2.85
P/E
Mkt Cap.(Rs cr) 17
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

National Steel & Agro Industries Ltd. (NATNLSTEEL) - Auditors Report

Company auditors report

TO

THE MEMBERS OF

NATIONAL STEEL AND AGRO INDUSTRIES LIMITED

REPORT ON THE AUDIT OF THE STANDALONE IND AS FINANCIAL STATEMENTS

OPINION

We have audited the standalone financial statements of National Steel and AgroIndustries Limited ("the company") which comprise the balance sheet as at 31stMarch 2021 the statement of profit and loss including statement of other comprehensiveincome statement of changes in equity and statement of cash flows for the year thenended and notes to the financial statements including a summary of significantaccounting policies and other explanatory information.

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 in the manner so required and give a true and fair view inconformity with the accounting principles generally accepted in India of the state ofaffairs of the Company as at March 31 2021 its loss changes in equity and in cash flowsfor the year ended on that date.

Basis for Opinion

We conducted our audit of the standalone Ind AS financial statements in accordance withthe Standards on Auditing (SAs) as specified under Section 143(10) of the Companies Act2013. Our responsibilities under those Standards are further described in the 'Auditor'sResponsibilities for the Audit of the Standalone Ind AS Financial Statements' section ofour report. We are independent of the Company in accordance with the 'Code of Ethics'issued by the Institute of Chartered Accountants of India together with the ethicalrequirements that are relevant to our audit of the financial statements under theprovisions of the Companies Act 2013 and the Rules thereunder and we have fulfilled ourother ethical responsibilities in accordance with these requirements and the Code ofEthics. We believe that the audit evidence we have obtained is sufficient and appropriateto provide a basis for our audit opinion on the Standalone Ind AS financial statements.

Emphasis Of Matter

1. We draw attention to Note 29 to the Ind AS financial statements. The Company hasaccumulated secured debts (inclusive of interest & net of payment) amounting to1456.43 crores which was classified as Non-Performing Assets (NPA) by the banks.

2. One of the lenders has declared Company and it's Directors as Willful Defaulter. Twolender banks have issued notices to the Company and it's Directors with intent to classifythem as "Willful Defaulter". The Company and it's Directors have respectivelyreplied to the said notices.

3. One of the financial creditors had filed petition before National Company Law Board(NCLT) under Insolvency and Bankruptcy Code (IBC) for which Company has adopted legalrecourse. Some of the Operational Creditors has filed petition before National Company LawBoard (NCLT)/Supreme Court under Insolvency and Bankruptcy Code (IBC) for which Companyhas adopted legal recourse.

4. IDBI Bank Limited State Bank of India Union Bank of India (Earlier Andhra Bank)Central Bank of India and Bank of Maharashtra (collectively hereinafter referred as"Banks") through joint assignment agreement assigned it's debts extended to theCompany to JM Financial Asset Reconstruction Company Limited ("JMFARC") alongwith all underlying securities rights title and interest thereof on 31st March 2021.

Our opinion is not qualified on these matters.

Material Uncertainty Related to Going Concern

We draw attention to Note 30 of the financial statement regarding preparation offinancial statements on going concern basis which states that the Company has incurredlosses during the year its liabilities exceeded total assets and its net worth has beenfully eroded as on 31st March 2021. As stated these events and conditions along withother matters indicate that a material uncertainty exists that may cast significant doubton the Company's ability to continue as a going concern.

Our opinion is not modified in this regard.

Key Audit Matters

Key audit matters are those matters that in our professional judgment were of mostsignificance in our audit of the Standalone Ind AS financial statements for the financialyear ended March 31 2021. These matters were addressed in the context of our audit of theStandalone Ind AS financial statements as a whole and in forming our opinion thereon andwe do not provide a separate opinion on these matters. For each matter below ourdescription of how our audit addressed the matter is provided in that context.

We have determined the matters described below to be the key audit matters to becommunicated in our report. We have fulfilled the responsibilities described in theAuditor's responsibilities for the audit of the Standalone Ind AS financial statementssection of our report including in relation to these matters. Accordingly our auditincluded the performance of procedures designed to respond to our assessment of the risksof material misstatement of the Standalone Ind AS financial statements. The results of ouraudit procedures including the procedures performed to address the matters below providethe basis for our audit opinion on the accompanying Standalone Ind AS financialstatements.

Key Audit Matters How our audit addressed the Key Audit Matters
Expected Credit Loss (As described in Point No. VI e of note 1 of the standalone Ind AS financial statements)
The Company determines expected credit losses based on historical loss experience adjusted to reflect current and estimated future economic conditions. Our audit procedures related to verification of expected credit losses for trade receivables included the following among others:
The Company considered current and anticipated future economic conditions and effect from the pandemic relating to COVID-19. We identified expected credit losses as a key audit matter because the Company exercises significant judgment in calculating the same. We tested the effectiveness of controls over the (1) development of the methodology for the allowance for credit losses including consideration of the current and estimated future economic conditions
(2) completeness and accuracy of information used in the estimation of probability of default and
(3) Computation of the allowance for credit losses based on the age wise details of trade receivables provided to us.
(4) We tested the mathematical accuracy and computation of the allowances by using the same input data used by the Company.
Provisions and contingent liabilities relating to taxation litigations and claims
Our audit procedures included:
The provisions and contingent liabilities relate to ongoing litigations and claims with various authorities and third parties. These relate to direct tax indirect tax claims general legal proceedings and other eventualities arising in the regular course of business. (1) Understanding the process followed by the Company for assessment and determination of the amount of provisions and contingent liabilities relating to taxation litigations and claims.
As at the year ended 31 March 2021 the amounts involved are significant. The computation of a provision or contingent liability requires significant judgment by the Company becau se of the inherent complexity in estimating future costs. The amount recognised as a provision is the best estimate of the expenditure. (2) Eva luating the desi gn a nd implementation and testing operating effectiveness of key internal controls around the recognition and measurement of provisions a nd reassessm ent of contingent liabilities.
The provisions and contingent liabilities are subject to changes in the outcomes of litigations and claims and the positions taken by the Company. It involves significant judgment and estimation to determine the likelihood and timing of the cash outflows and interpretations of the legal aspects tax legislations and judgments previously made by authorities. (3) Involving our tax professionals with specialised skills and knowledge to assist in the assessment of the value of significant provisions and contingent liabilities relating to taxation matter on sample basis in light of the nature of the exposures applicable regulations and related correspon dence wi th the authorities.
(4) Inquiring the status in respect of significant provisions and contingent liabilities with the Company's internal tax and legal team including challenging the assumptions and critical judgments made by the Company which impacted the com pu ta ti on of th e provi si on s an d inspecting the computation.
(5) Assessing the assumptions used and estimates of outcome and financial effect including considering judgment of the Company supplemented by experience of similar decisions previously made by the authorities and in some cases relevant opinions given by the Company's advisors.
(6) Testing data used to develop the estimate for completeness and accuracy.
(7) Evaluating judgments made by the Company by comparing the estimates of prior year to the actual outcome.
Assessing the Company's disclosures in the standalone financial statements in respect of provisions and contingent liabilities.

We have determined that there are no other key audit matters to communicate in ourreport.

INFORMATION OTHER THAN THE FINANCIAL STATEMENTS AND AUDITOR'S REPORT THEREUPON

The Company's Board of Directors is responsible for the other information. The otherinformation comprises the information included in the Annual Report 2020-21 but does notinclude the Standalone Ind AS financial statements and our auditor's report thereon.

Our opinion on the Standalone Ind AS financial statements does not cover the otherinformation and we do not express any form of assurance conclusion thereon.

In connection with our audit of standalone Ind AS financial statements ourresponsibility is to read the other information and in doing so consider whether suchother information is materially inconsistent with the standalone Ind AS 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 STANDALONE IND AS 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 Ind AS financial statements that give a true and fair view of thefinancial position financial performance including other comprehensive income cash flowsand changes in equity of the Company in accordance with the accounting principlesgenerally accepted in India including the Indian Accounting Standards (Ind AS) specifiedunder section 133 of the Act read with the Companies (Indian Accounting Standards) Rules2015 as amended. This responsibility also includes maintenance of adequate accountingrecords in accordance with the provisions of the Act for safeguarding of the assets of theCompany and for preventing and detecting frauds and other irregularities; selection andapplication of appropriate accounting policies; making judgments and estimates that arereasonable and prudent; and design implementation and maintenance of adequate internalfinancial controls that were operating effectively for ensuring the accuracy andcompleteness of the accounting records relevant to the preparation and presentation ofthe standalone Ind AS financial statements that give a true and fair view and are freefrom material misstatement whether due to fraud or error.

In preparing the standalone Ind AS financial statements the Board of Directors isresponsible for assessing the Company's ability to continue as a going concerndisclosing as applicable matters related to going concern and using the going concernbasis of accounting unless the Board of Directors either intends to liquidate the Companyor to cease operations or has no realistic alternative but to do so.

The Board of Directors is also responsible for overseeing the Company's financialreporting process.

AUDITOR'S RESPONSIBILITY FOR THE AUDIT OF STANDALONE IND AS FINANCIAL STATEMENTS

Our objectives are to obtain reasonable assurance about whether the Standalone Ind ASfinancial 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 Standards on Auditing (SAs) will always detect a material misstatement when itexists. Misstatements can arise from fraud or error and are considered material ifindividually or in the aggregate they could reasonably be expected to influence theeconomic decisions of users taken on the basis of these Standalone Ind AS financialstatements.

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 Standalone Ind ASfinancial 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 or the override of internalcontrol.

- Obtain an understanding of internal control relevant to the audit in order to designaudit procedures that are appropriate in the circumstances. Under section 143(3)(i) of theCompanies Act 2013 we are also responsible for expressing our opinion on whether thecompany has adequate internal financial controls with reference to Standalone Ind ASfinancial statements of the Company in place and the operating effectiveness of suchcontrols.

- Evaluate the appropriateness of accounting policies used and the reasonableness ofaccounting estimates and related disclosures made by management.

- Conclude on the appropriateness of management's use of the going concern basis ofaccounting 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 Ind AS financial statements or if such disclosures are inadequate tomodify our opinion. Our conclusions are based on the audit evidence obtained up to thedate of our auditor's report. However future events or conditions may cause the Companyto cease to continue as a going concern.

- Evaluate the overall presentation structure and content of the Standalone Ind ASfinancial statements including the disclosures and whether the Standalone Ind ASfinancial statements represent the underlying transactions and events in a manner thatachieves fair presentation. We communicate with those charged with governance regardingamong other matters the planned scope and timing of the audit and significant auditfindings including any significant deficiencies in internal control that we identifyduring our audit.

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

From the matters communicated with those charged with governance we determine thosematters that were of most significance in the audit of the Standalone Ind AS financialstatements of the current period and are therefore the key audit matters. We describethese matters in our auditor's report unless law or regulation precludes public disclosureabout the matter or when in extremely rare circumstances we determine that a mattershould not be communicated in our report because the adverse consequences of doing sowould 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 2016 ("the Order")issued by the Central Government of India in terms of sub-section (11) of section 143 ofthe Act we give in the "Annexure-A" a statement on the matters specified inparagraphs 3 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 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 the Statement of OtherComprehensive Income the Cash Flow Statement and Statement of Changes in Equity dealtwith by this Report are in agreement with the books of account.

d. In our opinion the aforesaid standalone financial statements comply with the IndianAccounting Standards specified under Section 133 of the Act read with Companies (IndianAccounting Standards) Rules 2015 as amended.

e. On the basis of the written representation received from the directors as on March31 2021 taken on record by the Board of Directors none of the directors is disqualifiedas on March 31 2021 from being appointed as a director in terms of Section 164(2) of theCompanies Act 2013.

f. With respect to the adequacy of the internal financial controls with reference toStandalone Ind AS financial statements of the Company and the operating effectiveness ofsuch controls refer to our separate Report in "Annexure-B" to this report.

g. In our opinion no managerial remuneration for the year ended March 31 2021 hasbeen paid/provided by the Company to its directors. Therefore the provisions of Section197 read with Schedule V to the Act are not applicable.

g. 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 Company has disclosed the impact of pending litigations on its financialposition in its financial statements - Refer Note 31 to the financial statements.

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

iii. There has been no amount that is required to be transferred to the InvestorEducation and Protection Fund by the Company.

For Fadnis & Gupte
Chartered Accountants
FRN-006600C
Place : Indore CA Vikram Gupte
Dated : 30th June 2021 (Partner)
Membership No. 074814
UDIN: 21074814AAAAEG4591

ANNEXURE A TO THE AUDITORS' REPORT

As referred to in our Independent Auditor's Report of even date to the members ofNational Steel and Agro Industries Limited for the year ended March 31 2021

(i) (a) The Company has maintained proper records showing full particulars includingquantitative details and situation of property plant and equipment.

(b) As informed and explained to us the management during the year has physicallyverified the items of the property plant and equipment of the company at reasonableinterval and no significant discrepancies were noticed on such physical verification.

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

(ii) As informed and explained to us the inventory has been physically verified duringthe year by the management. In our opinion the frequency of verification needs to bestrengthened in view of the nature & size of the business. No material discrepancieswere noticed on such physical verification.

(iii) As explained to us the Company has not granted any loans secured or unsecuredto Companies firms Limited Liability Partnerships or other parties covered in theRegister maintained under Section 189 of the Companies Act 2013.

(iv) In our opinion and according to the information and explanations given to us theCompany has complied with the provisions of section 185 and 186 of the Act with respectto the loans and investments made.

(v) According to the information and explanations given to us the company has notaccepted any deposits under sections 73 to 76 or any other relevant provisions of theCompanies Act and the rules framed there under.

(vi) We have broadly reviewed the books of account maintained by the Company pursuantto the Rules made by the Central Government for the maintenance of cost records undersection 148(1) of the Act and are of the opinion that prima facie the prescribed accountsand records have been made and maintained.

(vii) (a) According to the books of accounts and records examined by us as per thegenerally accepted auditing practices in India in our opinion the company has beenregular in depositing undisputed statutory dues. According to the information andexplanations given to us there were no undisputed amounts payable in respect of ProvidentFund Employees State Insurance Income tax Sales Tax Customs Duty Excise Duty ServiceTax Cess and other material statutory dues which have remained outstanding as at 31stMarch 2021 for a period of more than six months from the date they became payable.

(b) According to the information and explanations given to us and the records of theCompany examined by us there are no dues of income-tax service-tax and goods and servicetax which have not been deposited on account of any dispute except as mentioned below:-

Statement of Disputed Dues

Name of Statute Period to which Dispute Relates Amount Disputed (Rs.) Forum where the dispute is pending
Differential Excise Duty 2018-19 46309420/- Customs Excise and Service Tax Appellate Tribunal New Delhi
Central Excise Duty 2020-21 30281875/- Principal Commissioner Ujjain
Export Shipping Bill 2016-17 10250000/- Customs Excise and Service Tax Appellate Tribunal Mumbai
Import Duty 2016-17 19299130/- Customs Excise and Service Tax Appellate Tribunal Ahmedbad
SDA Refund 2013-14 648119/- Customs Excise and Service Tax Appellate Tribunal Mumbai
Import Duty 2012-13 4748458/- Customs Excise and Service Tax Appellate Tribunal Mumbai
SDA Refund 2009-10 13807709/- Customs Excise and Service Tax Appellate Tribunal Mumbai
Commercial Tax 2004-05 519604/- M.P. Commercial Tax Appellate Board Bhopal
Commercial Tax 2005-06 1868541/- M.P. Commercial Tax Appellate Board Bhopal
Entry Tax 2004-05 5047197/- M.P. High Court Jabalpur Indore bench
Income Tax (Ground of Appeal) 2010-11 4232291/- Commissioner of Income Tax Appeal Mum bai
Income Tax (Ground of Appeal) 2011-12 11830313/- Commissioner of Income Tax Appeal Mum bai

(viii) The Company has defaulted in repayment of loans or borrowings to banks/financial institution as at balance sheet date as mentioned below;

Name of the Bank Amount of Default as at Balance Sheet Date (Including Interest) Period of Default
(Rs. in Crores)
Oriental Bank of Commerce 119.39 Since 25.06.2018
Bank of India 158.81 Since 02.07.2018
United Bank of India 48.82 Since 21.05.2018
Punjab National Bank 113.26 Since 13.07.2018
M/s. JM Financial AR Company Limited 1016.14 (Refer Clause 3 of EOM)

(ix) Paragraph 3(ix) of the Order is not applicable to the Company in respect ofinitial public offer or further public offer.

(x) According to the information and explanations given to us no material fraud on orby the Company has been noticed or reported during the year under audit.

(xi) According to the information and explanations give to us and based on ourexamination of the records of the Company owing to continuous losses the Company has notpaid/provided for managerial remuneration in accordance with the provisions of section 197read with Schedule V to the Act.

(xii) In our opinion the company is not a chit fund or a Nidhi mutual benefit fund/society. Therefore the provisions of clause (xii) of Para 3 of the said order are notapplicable to the company.

(xiii) According to the information and explanations given to us and based on ourexamination of the records of the Company transactions with the related parties are incompliance with sections 177 and 188 of the Act where applicable and details of suchtransactions have been disclosed in the financial statements as required by the applicableaccounting standards.

(xiv) According to the information and explanations give to us and based on ourexamination of the records of the Company the Company has not made any preferentialallotment or private placement of shares or fully or partly convertible debentures duringthe year.

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

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

For Fadnis & Gupte
Chartered Accountants
FRN-006600C
Place : Indore CA Vikram Gupte
Dated : 30th June 2021 (Partner)
Membership No. 074814
UDIN: 21074814AAAAEG4591

ANNEXURE B TO THE INDEPENDENT AUDITOR'S REPORT

Referred to in paragraph 2(f) of the Independent Auditors' Report of even date to themembers of National Steel & Agro Industries Limited on the Standalone FinancialStatements as of and for the year ended 31st March 2021

Report on the Internal Financial Controls with reference to Standalone FinancialStatements under Clause (i) of Sub-section 3 of Section 143 of the Companies Act 2013("the Act")

We have audited the internal financial controls with reference to Standalone FinancialStatements of National Steel and Agro Industries Limited ("theCompany") as of 31 March 2021 in conjunction with our audit of the standalonefinancial statements of the Company for the year ended on that date.

Management's Responsibility for Internal Financial Controls

The Company's management is responsible for establishing and maintaining internalfinancial controls based on the internal control over financial reporting criteriaestablished by the Company considering the essential components of internal control statedin the Guidance Note on Audit of Internal Financial Controls over Financial Reportingissued by the Institute of Chartered Accountants of India ('ICAI'). These responsibilitiesinclude the design implementation and maintenance of adequate internal financial controlsthat were operating effectively for ensuring the orderly and efficient conduct of itsbusiness including adherence to company's policies the safeguarding of its assets theprevention and detection of frauds and errors the accuracy and completeness of theaccounting records and the timely preparation of reliable financial information asrequired under the Companies Act 2013.

Auditors' Responsibility

Our responsibility is to express an opinion on the Company's internal financialcontrols with reference to standalone financial statements based on our audit. Weconducted our audit in accordance with the Guidance Note on Audit of Internal FinancialControls over Financial Reporting (the "Guidance Note") and the Standards onAuditing issued by ICAI and deemed to be prescribed under section 143(10) of theCompanies Act 2013 to the extent applicable to an audit of internal financial controlsboth applicable to an audit of Internal Financial Controls and both issued by theInstitute of Chartered Accountants of India. Those Standards and the Guidance Note requirethat we comply with ethical requirements and plan and perform the audit to obtainreasonable assurance about whether adequate internal financial controls with reference tostandalone financial statements was established and maintained and if such controlsoperated effectively in all material respects.

Our audit involves performing procedures to obtain audit evidence about the adequacy ofthe internal financial control system with reference to standalone financial statementsand their operating effectiveness. Our audit of internal financial controls with referenceto standalone financial statements included obtaining an understanding of internalfinancial controls with reference to standalone financial statements assessing the riskthat a material weakness exists and testing and evaluating the design and operatingeffectiveness of internal control based on the assessed risk. The procedures selecteddepend on the auditor's judgment including the assessment of the risks of materialmisstatement of the standalone financial statements whether due to fraud or error.

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

Meaning of Internal Financial Controls over Financial Reporting with reference tofinancial statements

A company's internal financial control with reference to financial statements is aprocess designed to provide reasonable assurance regarding the reliability of financialreporting and the preparation of financial statements for external purposes in accordancewith generally accepted accounting principles. A company's internal financial control withreference to standalone financial statements 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 the transactions are recorded as necessary topermit preparation of Ind AS financial statements in accordance with generally acceptedaccounting principles and that receipts and expenditures of the company are being madeonly in accordance 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 with reference to StandaloneFinancial Statements

Because of the inherent limitations of internal financial controls with reference tostandalone financial statements including the possibility of collusion or impropermanagement override of controls material misstatements due to error or fraud may occurand not be detected. Also projections of any evaluation of the internal financialcontrols with reference to standalone financial statements to future periods are subjectto the risk that the internal financial control with reference to standalone financialstatements may become inadequate because of changes in conditions or that the degree ofcompliance with the policies or procedures may deteriorate.

Opinion

In our opinion the Company has in all material respects an adequate internalfinancial controls system with reference to standalone financial statements and suchinternal financial controls with reference to standalone financial statements wereoperating effectively as at 31st March 2021 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 Fadnis & Gupte
Chartered Accountants
FRN-006600C
Place : Indore CA Vikram Gupte
Dated : 30th June 2021 (Partner)
Membership No. 074814
UDIN: 21074814AAAAEG4591

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