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NLC India Ltd.

BSE: 513683 Sector: Infrastructure
NSE: NLCINDIA ISIN Code: INE589A01014
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VOLUME 1020901
52-Week high 92.40
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P/E 7.59
Mkt Cap.(Rs cr) 12,098
Buy Price 0.00
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Sell Price 0.00
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OPEN 87.65
CLOSE 87.60
VOLUME 1020901
52-Week high 92.40
52-Week low 54.70
P/E 7.59
Mkt Cap.(Rs cr) 12,098
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

NLC India Ltd. (NLCINDIA) - Auditors Report

Company auditors report

INDEPENDENT AUDITORS' REPORT

R Subramanian and Company LLP Manohar Chowdhry & Associates
Chartered Accountants Chartered Accountants
New No.6 Old No. 36 #27 Subramaniam Street
Krishna Swamy Avenue Luz Mylapore Abiramapuram
Chennai 600004 Chennai 600018

TO:

The Members of NLC India Limited

REPORT ON THE AUDIT OF THE STANDALONE FINANCIAL STATEMENTS

Opinion:

We have audited the accompanying Standalone Financial Statements of NLC IndiaLimited ("the Company") ("NLCIL") which comprise the StandaloneBalance Sheet as at March 31 2022 the Standalone Statement of Profit and Loss (includingother Comprehensive income) the Standalone Statement of Changes in Equity and theStandalone Statement of Cash Flows for the year then ended including a summary of thesignificant accounting policies and other explanatory information in which are includedthe Returns for the year ended on that date audited by the branch auditors of theCompany's branches located at

Talabira and Barsingsar (hereinafter referred to as "Standalone FinancialStatements").

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 required by the Companies Act 2013("Act") in the manner so required and give a true and fair view in conformitywith the Indian Accounting Standards prescribed under Section 133 of the Act read with theCompanies (Indian Accounting Standards) Rules 2015 as amended ("Ind AS") andother accounting principles generally accepted in India of the state of affairs of theCompany as at March 31 2022 the profit (including other comprehensive income) thechanges in equity and its cash 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 Act. Our responsibilities under those Standards are furtherdescribed in the "Auditors' Responsibilities for the Audit of the StandaloneFinancial 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 ("ICAI") together with the ethical requirements that are relevant to ouraudit of the financial statements under the provisions of the Act and the Rulesthereunder and we have fulfilled our other ethical responsibilities in accordance withthese requirements and the ICAI's Code of Ethics. We believe that the audit evidenceobtained by us and the audit evidence obtained by the branch auditors in terms of theirreports referred to in "other matters" section below is sufficient andappropriate to provide a basis for our opinion.

Material Uncertainty Related to Going Concern:

We draw attention to Note 61(c) of the Standalone Financial Statements which indicatesthe challenges faced by the

Company with reference to acquisition of further lands due to legislative changes andthe resistance of land owners for higher compensation / employment opportunities etc. Inthe eventuality of the Company unable to acquire requisite lands there would be amaterial uncertainty on the operations of the Company which may cast significant doubt onthe Company's ability to continue as a going concern in future. However in order toovercome the challenges the Company has revised its compensation and Rehabilitation andResettlement (R&R) policy and various other welfare measures to continue on furtherland acquisitions which would sustain mining operations and power generation without anydisruptions.

Our Opinion is not modified in respect of this matter.

Emphasis of Matter

We draw attention to the following matters in the Notes to the Standalone FinancialStatements:

1. Note 2(j) with regards to capitalization of Talabira II & III Coal mines.

2. Note 10(A)(c) regarding the provision towards loss allowance on outstanding tradereceivables for the year ended

March 31 2022 pending receipt of confirmation of balances and completion of exerciseof the reconciliation of balances and resolving various issues in respect of whichactions have been initiated.

3. Note 11 and 31(a) relating to recognition of income tax expense for the year endedMarch 31 2022 which has been paid under the Direct Tax Vivad Se Vishwas Act 2020 (VSVS)towards settlement of income tax disputes and consequent recovery action being initiatedfrom the beneficiaries as per CERC tariff regulations.

4. Note 13(b)/ 22(c) where the Company had filed truing up petition for the Tariffperiod 2014- 19 for its Neyveli Mines.

Central Electricity Regulatory Commission (CERC) has issued True up order during March2022 and corrigendum for the same during April 2022 for tariff period 2014-19. TheCompany is seeking clarification from Ministry of Coal and also filed a review petitionbefore the commission. Pending disposal of the review petition the impact of the orderhas been deferred.

5. Note 13(c)/ 22(d) where the Company has filed truing up petition for the tariffperiod 2014 - 19 for its Thermal stations in December 2019. Any adjustment arising out ofthe same shall be considered in the books of accounts on receipt of order from CERC.

6. Note 13(e)/ 30(b) wherein an amount of 165.78 Crore being 50% of the mine closuredeposit including interest for the five-year period from FY 2016-17 to FY 2020-21 wasconsidered on a provisional basis under the head Regulatory income during the FY 2020-21pending filing of claim with coal controller. Further an amount of 22.22 Crore has beenprovisionally considered as regulatory income for the FY 2021-22.

7. Note 13(f) regarding the Deferred Tax Liability materialized from FY 2019-20 onwardsis yet to be considered in the Financials pending finalization of the claim amount frombeneficiaries.

8. Note 23(d) with respect to determination of lignite transfer price whereinadjustments which may arise out of revision of lignite price if any will be recognizedupon filing of petition with CERC and/or disposal of petition by CERC as the case may be.

9. Note 62 regarding the management's assessment of impact on financial position of theCompany due to COVID 19 pandemic.

Our Opinion on the Standalone Financial Statements is not modified in respect of theabove matters.

As per branch auditor's report of Talabira branch submitted to us:

10. Note 30(d) with respect to income of 48.59 Crore booked on account of"Regulatory Deferral Account Balance Income" on the basis of managementapproval but the petition is yet to be filed with CERC for further orders. Opinion of theauditor of the branch with respect to the branch financial statements is not modified inrespect of the above matter.

Key Audit Matters:

Key audit matters are those matters that in our professional judgment were of mostsignificance in our audit of the standalone financial statements of the current period.These matters were addressed in the context of our audit of the standalone financialstatements as a whole and in forming our opinion thereon and we do not provide aseparate opinion on these matters. In addition to the matter described in the MaterialUncertainty Related to Going Concern section we have determined the matters describedbelow to be the key audit matters to be communicated in our report.

The following have been considered as Key Audit Matters:

Sl no. Key Audit Matter Auditors' Response
1 Assessment of provisions and contingent liabilities in respect of certain litigations including direct and indirect taxes various claims filed by other parties not acknowledged as debt. In view of the significance of the matter we performed the following key audit procedures:
A high level of judgment is required in estimating the amount of provisioning. The Company's assessment is supported by the facts of matter their own judgment experience and independent legal advice wherever considered necessary. Accordingly unexpected adverse outcomes which may significantly impact the reported profit and net assets are disclosed. • Testing the design and operating effectiveness of controls relating to taxation and contingencies;
• We evaluated management's judgements in respect of estimates of provisions exposures and contingencies;
• In understanding and evaluating management's judgements we have utilized our internal tax experts.
A sum of 8406.74 Crore have been considered by the Company towards contingent liability and commitments representing claims of third parties. Refer Note 53 of the Standalone Financial Statements. • We have also examined the status of recent and current tax assessments and enquiries the outcome of previous claims judgmental positions taken in tax returns and developments in the tax environment; and
Included in the above is a sum of 4864.05 Crore that has been considered by the Company towards contingent liability which includes claims of third party's compensation for land acquisition. • Additionally we also evaluated the adequacy of disclosures on provisions and contingencies made in the Standalone Financial Statements in accordance with Ind AS 37 Provisions Contingent Liabilities and Contingent Assets.
The Company has not accepted the said claims which are contested in legal proceedings and are pending for disposal by the appellate authorities. Further there are several items of disputes pending in various appellate forums in respect of determination and quantification of liability towards direct and indirect taxes by the departments. Liabilities in respect of disputed demands are considered only as contingent liabilities pending the outcome of the decision of the appellate authorities. The total unpaid amount of disputed liabilities on account of Direct and Indirect taxes (including land tax) is 630.60 Crore.
2 Project activities of Bithnok and BTPSE project: Our audit procedures performed included the following:
Accuracy of impairment provisions in respect of exploration and evaluation assets and projects under "Capital work in progress" which involves critical judgment of the management in respect of feasibility of ongoing projects. • We obtained the details of project activities of Bithnok and BTPSE project from the management;
The Standalone Financial Statements include relevant disclosures that identify and explain the amounts arising from such feasibility study. Refer Note 5 to the Standalone Financial Statements. • Reviewed the correspondence with EPC contractor and the details of claims made against the Company and counter claims made by the Company;
Further an aggregate amount of 388.98 Crore towards land capital advance and CWIP relate to Bithnok and BTPSE which are currently on hold on account of cancellation of contract by the end customer and the eventual litigation with the EPC contractor appointed by the Company. • Took note of the counter points of the Company against claim made by EPC contractor; and
• Reviewed the basis for provision of 29.98 Crore

and 114.79 Crore made for the year ended

March 31 2022.

The EPC contractor has made certain claim against for which the Company has made some counter claims. However in the meantime the Company has admitted a sum of 29.98 Crore as payable and accordingly provided the same for the year ended March 31 2022.
During the year the Company has made encashment of BG amounting to 36.99 Crore. The Company made further claim towards encashment of BG amounting to 126.27 crore for which the Company could not encash due to the direction of Hon'ble Supreme Court to extend the validity of BG. Pending disposal of the case a provision of 114.79 Crore has been made against the said advance for which the said BG issued has been provided for the year ended March 31 2022.
3 Expected Credit Loss on Trade Receivables: Our audit procedures performed included the following:
Ind AS 109 - Financial instruments (Ind AS 109) requires the Company to provide for impairment of its financial instruments (designated as amortized cost or fair value through other comprehensive income) using the expected credit loss (ECL) approach. Such ECL allowance is required to be measured considering the guiding principles mentioned in the Standard. • We understood the process of ECL estimation and tested the design and operating effectiveness of key controls around data extraction and validation;
• The computation is based on ageing reports derived from SAP;
In the process of applying such principles and other requirements of the Standard a significant degree of judgment has been applied by the management. The ECL in respect of trade receivables represents management's best estimate of the loss allowance. The ECL allowance is computed based on a simplified model considering ageing of trade receivables and also trend of collection of dues. • We having regard to profile and the background of the customers collection of dues and the measures of the Govt(s) in regard to settlement of dues by such customers understood the methodology used by the management to arrive at their ECL provision and examined certain assumptions used by the Company;
The calculation of ECL allowance is a complex area considering the profile and background of customers and requires management to make significant assumptions on customer payment behaviour and other relevant risk characteristics when assessing the historical information and estimating the level and timing of expected future cash flows. • We also tested the arithmetical accuracy and assessed the judgments used in the management's model used to calculate provision for credit losses; and
• We assessed the disclosures included in the Ind AS Financial Statements with respect to such allowance/ estimate are in accordance with the requirements of Ind AS 109 and Ind AS 107 -
The provision for ECL on trade receivables amounts to 501.51 Crore as at March 31 2022. Financial Instruments: Disclosures.
4 Direct Tax Vivad Se Vishwas Act 2020 (VSVS) (A) Our audit procedures performed included the following: (A) On VSVS
The Company has opted the VSVS for settlement of income tax disputes and has filed the relevant details before the income tax department. In consequence of the same the Company has remitted a sum of 730.91 Crore during the years 2019-20 and 2021-22. • Verified all the assessment orders passed which are subject to VSVS;
• Verified the appeals pending against various forums and the status of the same;
Upon due scrutiny the income tax department has accepted the application and issued Form-5 as per the provisions of VSVS thereby concluding the disputes. • Analysed the various issues for which Company has opted for VSVS;
• Verified the Forms (Form 1 2 3 and 4) filed by the Company under VSVS;
• Verified the payments made under VSVS;
• Verified Form-5 issued by the income tax department; and
• Understood the reasons for pending tax litigations which are not subjected to VSVS.
(B) (B) On recovery of VSVS tax from beneficiaries
Exceptional item includes 389.97 Crore on account of income tax recoverable from the beneficiaries as per the CERC tariff Regulations for different Tariff periods due to payments/adjustments relating to earlier periods pursuant to opting of VSVS. Pending billing to beneficiaries the said amount has been considered as unbilled revenue as on March 31 2022 and is grouped under other current assets. • We have obtained an understanding of the CERC tariff Regulations orders circulars guidelines procedures and power purchase agreements entered in respect of recoverability of income tax paid from beneficiaries;
• Evaluated and tested the effectiveness of the Company's design of internal controls relating to recognition and measurement of revenue;
• We involved our internal tax experts to understand and evaluate the recoverability of income tax paid from beneficiaries review legal precedence in this regard;
• We have gone through the expert opinion obtained by the management in this regard; and
• Verified the accounting of revenue for amount recoverable from beneficiaries.
5 Amortisation of Freehold Land Our audit procedures performed included the following:
The accounting policy followed by the Company until FY 2020-21 provides that no depreciation to be charged on freehold land. • Read the Company's accounting policy with respect to depreciation in accordance with Ind AS 16 - Property Plant and Equipment;
With effect from April 01 2021 the Company has changed its accounting policy to amortise freehold land on the basis of minerals extracted during the year to the total estimated minable reserves of the said quantum of land used for mining in the year under review as certified by Technical experts. • Analysed the data from the certificates issued by technical experts including the total estimated lignite reserves vis-a-vis lignite actually extracted during each year;
This change in the accounting policy has significant impact on the financial statements and considering this as material prior period item the Company has restated previous year financials as well the opening reserves as on 01.04.2020. • Analysed the industry norms on similar matter and the appropriate treatment recognized;
• Evaluated the key assumptions made including land available for mining and minable reserves available;
• Review of the workings done in this regard including mathematical accuracy; and
• Checked the compliance and disclosure requirements as per Ind AS 8 Accounting Policies Changes in Accounting Estimates and Errors.

Information other than the Standalone Financial Statements andAuditors' 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 Directors'Report including Annexures to Directors' Report and Responsibility Report but does notinclude the Standalone Financial Statements and our Auditors' report thereon. The otherinformation is expected to be made available to us after the date of this Auditors'report.

Our opinion on the Standalone Financial Statements does not cover the other informationand we do not express anyform of assurance conclusion thereon.

In connection with our audit of the Standalone Financial Statements our responsibilityis to read the other information identified above when it becomes available and in doingso consider whether the other information is materially inconsistent with the

Standalone Financial Statements or our knowledge obtained in the audit or otherwiseappears to be materially misstated. On receipt of other information if we conclude thatthere is a material misstatement therein we are required to communicate the matter tothose charged with governance and we shall:

(a) If the material misstatement is corrected perform necessary procedure toensure the correction; or

(b) If the material misstatement is not corrected after communicating the matter tothose charged with governance take appropriate action considering our legal rights andobligations to seek to have the uncorrected material misstatement appropriately broughtto the attention of users for whom this Auditors' report is prepared.

Responsibilities of Management and those charged with Governance for the StandaloneFinancial 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 Standalone Financial Statementsthat give a true and fair view of the financial position financial performance (includingOther Comprehensive Income) changes in equity and cash flows of the Company in accordancewith the accounting principles generally accepted in India including the Ind AS. 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 statements thatgive a true and fair view and are free from material misstatement whether due to fraud orerror.

In preparing the Financial Statements the Board of Directors is responsible forassessing the Company's ability to continue as a going concern disclosing as applicablematters related to going concern and using the going concern basis of accounting unlessBoard of Directors either intends to liquidate the Company or to cease operations or hasno realistic alternative but to do so.

These Board of Directors are also responsible for overseeing the Company's financialreporting process.

Auditors' Responsibility for the Audit of the Standalone Financial Statements

Our objectives are to obtain reasonable assurance about whether the StandaloneFinancial Statements as a whole are free from material misstatement whether due to fraudor error and to issue an auditors' report that includes our opinion.

Reasonable assurance is a high level of assurance but is not a guarantee that an auditconducted in accordance with 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 Financial Statements.

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

• Identify and assess the risks of material misstatement of the StandaloneFinancial Statements whether due to fraud or error design and perform audit proceduresresponsive to those risks and obtain audit evidence that is sufficient and appropriate toprovide a basis for our opinion. The risk of not detecting a material misstatementresulting from fraud is higher than for one resulting from error as fraud may involvecollusion forgery intentional omissions misrepresentations or the override of internalcontrol.

• Obtain an understanding of internal financial control relevant to the audit inorder to design audit procedures that are appropriate in the circumstances. Under section143(3)(i) of the Act we are also responsible for expressing our opinion on whether theCompany has adequate internal financial controls system in place and the operatingeffectiveness of such controls.

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

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

• Evaluate the overall presentation structure and content of the StandaloneFinancial Statements including the disclosures and whether the Standalone FinancialStatements represent the underlying transactions and events in a manner that achieves fairpresentation.

• Obtain sufficient appropriate audit evidence regarding the financial informationof the Company and its branches to express an opinion on the standalone financialstatements. We are responsible for the direction supervision and performance of the auditof the financial statements of such entities included in the standalone financialstatements of which we are the independent auditors. For the branches included in thestandalone financial statements which have been audited by the branch auditors suchbranch auditors remain responsible for the direction supervision and performance of theaudits carried out by them. We remain solely responsible for our audit opinion. Ourresponsibilities in this regard are further described in the section titled ‘OtherMatter' in this audit report.

Materiality is the magnitude of misstatements in the standalone financial statementsthat individually or in aggregate makes it probable that the economic decisions of areasonably knowledgeable user of the standalone financial statements may be influenced. Weconsider quantitative materiality and qualitative factors in (i) planning the scope of ouraudit work and in evaluating the results of our work; and (ii) to evaluate the effect ofany identified misstatements in the Standalone 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 anysignificantficiencies in internal control that we identify during our audit. de

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 Financial Statementsof the current period and are therefore the key audit matters.

We describe these matters in our auditors' report unless law or regulation precludespublic disclosure about the matter or when in extremely rare circumstances we determinethat a matter should not be communicated in our report because the adverse consequences ofdoing so would reasonably be expected to outweigh the public interest benefits of suchcommunication.

Other Matter

We did not audit the financial statements of two (2) Branches included in theStandalone Financial Statements of the Company whose financial statements reflect totalassets of 2463.55 Crore as at March 31 2022 and total revenues of 1454.20 Crore for theyear ended March 31 2022 total net profit before tax of 545.58 Crore for the year endedMarch 31 2022 and total comprehensive income of 561.61 Crore for the year ended March 312022 and net cash out flows of 4.35 Crore for the year ended March 31 2022. Thefinancial statements of these Branches have been audited by the branch auditors whosereports have been furnished to us and our opinion in so far as it relates to the amountsand disclosures included in respect of these Branches is based solely on the report ofsuch branch auditors and the procedures performed by us as stated under Auditors'

Responsibilities for the audit of the Standalone Financial Statements section above.

Our opinion is not modified in respect of this matter.

Report on Other Legal and Regulatory Requirements

1. As required by the Companies (Auditors' Report) Order 2020 ("theOrder") issued by the Central Government of India in terms of sub-section (11) ofsection 143 of the Act we give in "Annexure-I" a statement on the mattersspecified in paragraphs 3 and 4 of the said Order to the extent applicable.

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

a. We have sought and obtained all the information and explanations which to thebest of 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 reports on the accounts of the Branch Offices of the Company audited underSec 143(8) of the Act by the

Branch Auditors have been sent to us and have been properly dealt with by us inpreparing this report;

d. The Balance Sheet the Statement of Profit and Loss (including OtherComprehensive Income) the Statement of Changes in Equity and the Statement of Cash Flowsdealt with by this Report are in agreement with the books of account;

e. In our opinion the aforesaid Standalone Financial Statements comply with theInd AS;

f. The matter described in the "Material Uncertainty Related to GoingConcern" paragraph above in our opinion may not have an adverse effect on thefunctioning of the Company;

g. The Company being a Government Company the provisions of Sec 164(2) of the Actrelating to disqualification of directors is not applicable in view of the NotificationNo: G.S.R 463(E) dated June 05 2015 issued by the Ministry of Corporate Affairs;

h. There is no qualification reservation or adverse remark relating to themaintenance of accounts and other matters connected therewith;

i. With respect to adequacy of the internal financial controls over financialreporting of the Company and the operating effectiveness of such controls we give ourreport in "Annexure-II";

j. The Company being a Government Company the provisions of Sec 197 of the Actrelating to managerial remuneration is not applicable in view of the Notification No:G.S.R 463(E) dated June 05 2015 issued by the Ministry of Corporate Affairs.Accordingly reporting in accordance with requirement of provisions of section 197(16) ofthe Act is not applicable to the Company; and

k. With respect to the other matters to be included in the Auditors' Report inaccordance with Rule 11 of the Companies

(Audit and Auditors) Rules 2014 as amended in our opinion and to the best of ourinformation and according to the explanations given to us:

i. The Company has disclosed the impact of pending litigations on its financialposition in its Standalone Financial Statements Refer to Note 53 of Standalone FinancialStatements;

ii. The Company has long term contracts for coal mining power sale projectexecution etc. However as at March 31 2022 there were no material foreseeable losses onthose contracts. The Company did not have any derivative contracts as at March 31 2022;

iii. There has been no delay in transferring amounts required to be transferredto the Investor Education and

Protection Fund by the Company;

iv. (a) The Management has represented that to the best of its knowledge andbelief no funds (which are material either individually or in the aggregate) have beenadvanced or loaned or invested (either from borrowed funds or share premium or any othersources or kind of funds) by the Company to or in any other person or entity includingforeign entity ("Intermediaries") with the understanding whether recorded inwriting or otherwise that the Intermediary shall whether directly or indirectly lend orinvest in other persons or entities identified in any manner whatsoever by or on behalf ofthe Company ("Ultimate Beneficiaries") or provide any guarantee security or thelike on behalf of the Ultimate Beneficiaries;

(b) The Management has represented that to the best of its knowledge and beliefno funds (which are material either individually or in the aggregate) have been receivedby the Company from any person or entity including foreign entity ("FundingParties") with the understanding whether recorded in writing or otherwise that theCompany shall whether directly or indirectly lend or invest in other persons orentities identified in any manner whatsoever by or on behalf of the Funding Party("Ultimate Beneficiaries") or provide any guarantee security or the like onbehalf of the Ultimate Beneficiaries; and

(c) Based on the audit procedures that have been considered reasonable andappropriate 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. (a) The final dividend paid by the Company during the year which pertains toprevious year 2020-21 is in accordance with Section 123 of the Act to the extent itapplies to payment of dividend;

(b) The interim dividend declared and paid by the Company during the year and untilthe date of this audit report is in accordance with Section 123 of the Act; and

(c) As stated in Note 54 (c) to the Standalone Financial Statements the Board ofDirectors of the Company have proposed final dividend for the year 2021-22 which issubject to the approval of the Members at the ensuing Annual General Meeting. The dividenddeclared is in accordance with section 123 of the Act to the extent it applies todeclaration of dividend.

3. As required by Sec 143(5) of the Act our comments in regard to the directionsand sub- directions issued by the Comptroller and Auditor General of India is given in"Annexure III".

4. During the year the Company has not complied with the requirements relating tothe composition of the Board including failure to appoint woman director as requiredunder Regulation 17(1) of the SEBI (Listing Obligations and Disclosure Requirements)Regulations 2015. However the Company has complied with the requirement of Regulation17(1)(a) with respect to appointment of independent woman director as at March 31 2022.

For R Subramanian and Company LLP For Manohar Chowdhry & Associates
Chartered Accountants Chartered Accountants
Firm Regn. No. 004137S/S200041 Firm Regn. No. 001997S
R. Subramanian M.S.N.M.Santosh
Partner Partner
M No. 008460 M No. 221916
UDIN: 22008460AKBFDJ9190 UDIN: 22221916AJXKXU9603
Place: Chennai
Date: May 30 2022

Annexure-I to the Independent Auditors' Report on the Standalone Financial Statements

With reference to Annexure-I referred to in paragraph 1 in ‘Report on Other Legaland Regulatory Requirements' of the Independent Auditors' Report to the members of theCompany on the standalone financial statements for the year ended

March 31 2022 we report that:

(i) (a) (A) The Company is maintaining proper records showing full particularsincluding quantitative details and situation of Property Plant and Equipment (PPE).

(B) The Company is maintaining proper records showing full particulars ofintangible assets.

(b) The Company has conducted physical verification of PPE in the previous yearwhich is in accordance with their planned programme of verifying them once in two yearswhich is reasonable having regard to the size of the

Company and the nature of its assets.

(c) As informed by the management the Company is in possession of Titledeeds/Assignment deeds/GOs in respect of immovable properties. However in view ofsubstantial volume of land documents held by the Company and reconciliation of the samewith the PPE register which is in progress verification of the title deeds was rendereddifficult. It was also observed on test check of available documents that there wereinstances of title deeds still lying in the name of previous owner. We have been informedthat the management is in process of identifying such title deeds which are still in thename of the previous owners and thereafter requisite steps will have to be initiated bythe management including approval of name changes by appropriate authority. In view ofthis the title deeds of the lands cannot be directly linked with the PPE registermaintained by the Company.

As per expert legal opinion furnished to us the ownership of the land acquired betweenthe incorporation of the Company until the year 1977 and between the years 1997 to 2001 issubject to conditions attached by Government of Tamil Nadu in the respective assignmentdeeds.

Immovable properties of land whose title deeds have been deposited with banks assecurity for term loans have been verified by us based on the documents provided to us bythe Company relating to registration of charges with Ministry of Corporate Affairs.

(d) According to the information and explanations provided to us the Company hasnot revalued its Property Plant and Equipment (including Right of Use assets) orintangible assets during the year ended March 31 2022 and accordingly reporting onclause 3(i)(d) of the Order is not applicable to the Company.

(e) According to the information and explanations provided to us there are noproceedings initiated or are pending against the Company for holding any benami propertyunder the Prohibition of Benami Property Transactions

Act 1988 and rules made thereunder and accordingly reporting on clause 3(i)(e) of theOrder is not applicable to the Company.

(ii) (a) According to the information and explanation provided to us the physicalverification of inventory have been conducted at reasonable intervals by the Stockverification team under Perpetual Inventory System on continuous basis. In our opinionthe coverage and the procedure of such verification by the management is appropriate.Discrepancies of 10% or more in aggregate for each class of inventory were not noticed onsuch physical verification.

(b) The Company has been sanctioned working capital limits in excess of five crorerupees in aggregate from bank during the year on the basis of security of current assetsof the Company. There are few instances noticed wherein the quarterly returns/statementsfiled with the bank are not in agreement with the books of account of the Company.However considering the drawing power and the limits utilised by the Company during theyear the differences are not significant warranting detailed comments.

(iii) According to the information and explanations given to us and on the basis ofour examination of the records of the Company the Company has made investments in andgranted loans during the year to subsidiary companies and employees.

(a) According to the information and explanations given to us and on the basis ofour examination of the records of the Company during the year the Company has providedloans to a subsidiary company and employees as follows:

(Rs Crore)

Particulars Loans
Aggregate amount granted/ provided during the year
Subsidiaries 375
Others Employees 28
Balance outstanding as at balance sheet date in respect of above cases
Subsidiaries -
Others Employees 52

(b) According to the information and explanations given to us and on the basis ofour examination of the records of the Company the investments made and the terms of theloans provided during the year are not prejudicial to the interest of the Company.

(c) According to the information and explanations given to us and on the basis ofour examination of the records of the Company in the case of loan to subsidiary theschedule of repayment of principal and payment of interest have been stipulated and therepayments have been regular. In the case of loans to employees the terms of the loansare governed by the Company's policies. The principal and interest have been recovered atperiodical intervals as laid down in such policies.

(d) According to the information and explanations given to us and on the basis ofour examination of the records of the Company there are no material overdue amounts as atthe Balance Sheet date. Accordingly reporting under clause 3(iii)(d) of the Order is notapplicable.

(e) According to the information and explanations given to us and on the basis ofour examination of the records of the Company there were no cases where the loans havebeen renewed or extended or fresh loans granted to settle the overdues of existing loansgiven to the same parties in respect of loans which had fallen due during the year.

(f) According to the information and explanations given to us and on the basis ofour examination of the records of the Company the Company has not granted any loan whichis repayable on demand or without specifying any terms or period of repayment.Accordingly reporting under the other requirements of clause 3(iii)(f) is not applicable.

(iv) According to the information and explanations given to us and on the basis ofour examination of the records of the Company the loans given investments made andguarantee provided by the Company are in compliance with the provisions of Section 185 and186 of the Act read with Ministry of Corporate Affairs notification number G.S.R. 463(E)dated June 5 2015.

(v) According to the information and explanations given to us and on the basis ofour examination of the records of the

Company the Company has not accepted any deposits or amounts which are deemed to bedeposits during the year. Accordingly clause 3(v) of the Order is not applicable.

(vi) We have reviewed the cost records maintained by the Company as specified bythe Central Government under Section 148(1) of the Act and are of the opinion that theprescribed cost records have been maintained. We have also reviewed the most recent costaudit report made available to us for the PY 2020-21 and did not notice any adversecomments on the maintenance of cost records.

(vii) (a) Based on the information and explanations given to us and on the basis ofour examination of the records of the Company undisputed statutory dues includingProvident Fund Income-tax Goods and Services Tax Customs Duty Royalty Cess and othermaterial statutory dues applicable to it have generally been regularly deposited by theCompany with the appropriate authorities.

According to the information and explanations given to us and on the basis of ourexamination of the records of the Company no undisputed amounts payable in respect ofProvident Fund Income-tax Goods and Services Tax Customs Duty Royalty Cess and othermaterial statutory dues were in arrears as at 31 March 2022 for a period of more than sixmonths from the date they became payable except in the case of Royalty and Income Tax(TDS) dues as mentioned here below:

Statement of Arrears of Statutory Dues Outstanding for More than Six Months

Name of the statute Nature of the dues Amount (Rs Crore) Period to which the amount relates Due date Date of Payment Remarks
Mines and Mineral (Development and Regulation) Act1957 Royalty 8.86 FYs 2009-10 to 2013-14 - - This is on account of truing up order for the tariff period 2009-14
Income Tax Act Income Tax (TDS) 0.40 FY 2007-08 - - These are dues as appearing in the
Income Tax Act Income Tax (TDS) 0.08 FY 2008-09 - - TDS reconciliation analysis and correction enabling
Income Tax Act Income Tax (TDS) 0.04 FY 2009-10 - - system (TRACES) portal and not accounted in books
Income Tax Act Income Tax (TDS) 0.34 FY 2010-11 - -
Income Tax Act Income Tax (TDS) 0.74 FY 2011-12 - -
Income Tax Act Income Tax (TDS) 0.0007 FY 2013-14 - -
Income Tax Act Income Tax (TDS) 0.0002 FY 2015-16 - -
Income Tax Act Income Tax (TDS) 0.0001 FY 2019-20 - -

(b) According to the information and explanations given to us there are no dues ofProvident Fund Income-tax Goods and Services Tax Customs Duty Royalty Sales TaxService tax Duty of Customs Value Added Tax Cess and other Statutory dues which havenot been deposited as on March 31 2022 on account of any dispute except as reportedbelow:

Statement of Disputed Dues

Name of the Statute Nature of Dues Demand Amount* (Rs Crore) Amount Deposited under Protest (Rs Crore) Period to which the amount relates Forum where dispute is pending
0.09 0.09 FY 2003-04 High court
0.93 - FY 2006-07 CIT(A)
1.80 - FY 2009-10 CIT(A)
1.88 - FY 2011-12 CIT(A)
0.01 0.003 FY 2011-12 CIT(A)
Income Tax Act Income Tax 1.86 1.86 FY 2012-13 Assessing Officer
0.03 0.005 FY 2012-13 CIT(A)
0.0002 - FY 2012-13 Assessing Officer
1.92 1.92 FY 2013-14 Assessing Officer
0.03 0.005 FY 2013-14 CIT(A)
0.02 0.004 FY 2014-15 CIT(A)
0.01 0.003 FY 2015-16 CIT(A)
23.14 23.14 FY 2016-17 CIT(A)
Income Tax Act Income Tax
0.02 0.003 FY 2016-17 CIT(A)
29.99 22.01 FY 2017-18 CIT(A)
0.90 0.07 Apr 2009 to Jun 2012 CESTAT
0.51 0.07 Jul 2012 to Mar 2014 CESTAT
8.53 - Jul 2012 to Mar 2015 Supreme Court
3.67 - Jul 2012 to Mar 2014 Supreme Court
0.26 0.03 Apr 2014 to Mar 2015 CESTAT
Finance Act 1994 Service Tax 2.06 - Jun 2008 to Mar 2012 CESTAT
0.73 0.07 Apr 2015 to Jun 2017 CESTAT
14.17 - Apr 2015 to Jun 2017 Supreme Court
0.08 0.01 Apr 2015 to Jun 2017 CESTAT
38.55 - Oct' 2014 to June 2017 Madras High Court
4.49 - FY 2015-16 Madras High Court
Central Excise Act 1944 Clean Environment Cess and Excise Duty 179.00 - As on 30- 06-2017 Madras High Court
Tamilnadu VAT Act 2006 Sales tax 468.38 112.43 FY 2011-12 to FY 2015-16 Madras High court
0.58 0.29 2008-09 Land Tax Assessing Officer
1.74 0.63 2009-10 Land Tax Assessing Officer
Rajasthan Finance Act 2006 Land Tax 1.74 0.87 2010-11 Land Tax Assessing Officer
2.00 1.00 2011-12 Land Tax Assessing Officer
2.00 1.00 2012-13 Land Tax Assessing Officer
Customs Act1969 Custom Duty 14.82 9.83 FY 2006-07 Supreme Court

*As appearing in the demand notice

(viii) According to the information and explanations provided to us the Companyhas not surrendered or disclosed any transaction previously unrecorded in the books ofaccount in the tax assessments under the Income Tax Act 1961 as income during the year.Accordingly the requirement to report on clause 3(viii) of the Order is not applicable tothe Company.

(ix) (a) According to the information and explanations given to us and on the basisof our examination of the records of the Company the Company has not defaulted inrepayment of loans or other borrowings or in the payment of interest thereon to anylender.

(b) According to the information and explanations given to us and on the basis ofour audit procedures we report that the company has not been declared wilful defaulter byany bank or financial institution or other lendor.

(c) According to the information and explanations given to us and on the basis ofthe examination of the records of the Company the Company has not availed any term loansduring the year.

(d) According to the information and explanations given to us and on an overallexamination of the financial statements of the Company we report that no funds raised onshort- term basis have been used for long-term purposes by the Company.

(e) According to the information and explanations given to us and on an overallexamination of the Standalone financial statements of the Company the Company has nottaken any funds from any entity or person on account of or to meet the obligations of itssubsidiaries.

(f) According to the information and explanations given to us and on the basis ofthe examination of the records of the Company the Company has not raised loans during theyear on the pledge of securities held in its subsidiaries.

(x) (a) The Company has not raised any money during the year by way of initialpublic offer / further public offer (including debt instruments). Hence the requirementto report on clause 3(x)(a) of the Order is not applicable to the Company.

(b) The Company has not made any preferential allotment or private placement ofshares or convertible debentures

(fully partially or optionally convertible) during the year under audit. Hence therequirement to report on clause 3(x)(b) of the Order is not applicable to the Company.

(xi) (a) According to the information and explanations given to us no fraud by theCompany and no material fraud on the Company has been noticed or reported during the year.

(b) No report under section 143(12) of the Act has been filed by the auditors inForm ADT 4 as prescribed under Rule 13 of Companies (Audit and Auditors) Rules 2014 withthe Central Government during the year.

(c) As represented to us by the management and according to the information givento us there are no whistle-blower complaints received by the Company during the year.

(xii) The Company is not a Nidhi Company and therefore the requirement to reporton clause 3(xii) of the Order is not applicable 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 section 177 and 188 of the Act wherever applicable. The Company being agovernment company transactions with other government companies are exempt fromcompliance of Section 188 of the Act in terms of Notification No: G.S.R. 463(E). dated5th June 2015 issued by Ministry of Corporate Affairs Government of India. Details ofsuch transactions have been disclosed in the Standalone Financial Statements as requiredby the applicable Ind AS.

(xiv) (a) According to the information and explanations provided to us and based onour examination of the records of the Company in our opinion the Company has an internalaudit system commensurate with the size and nature of its business.

(b) The internal audit reports of the Company issued for the period under audithave been considered by us.

(xv) In our opinion and according to the information and explanations given to usduring the year the Company has not entered into any non-cash transactions with itsdirectors or directors of its subsidiary or associate Company as applicable or personsconnected with them and hence provisions of section 192 of the Act are not applicable.

(xvi) (a) According to the information and explanation provided to us and based onour examination of the records of the Company the Company is not required to beregistered under section 45- IA of the Reserve Bank of India Act 1934 (2 of 1934).

(b) According to the information and explanation provided to us and based on ourexamination of the records of the Company the Company has not conducted any Non-BankingFinancial or Housing finance activities. Accordingly clause 3(xvi)(b) of the Order is notapplicable.

(c) According to the information and explanation provided to us and based on ourexamination of the records of the Company the Company is not a Core Investment Company asdefined in the regulations made by the Reserve Bank of India. Accordingly clause3(xvi)(c) of the Order is not applicable.

(d) According to the information and explanation provided to us and based on ourexamination of the records of the Company the Group does not have any Core InvestmentCompany. Accordingly clause 3(xvi)(d) of the Order is not applicable.

(xvii) The Company has not incurred cash losses in the current and the immediatelypreceding financial year.

(xviii) There has been no resignation of the statutory auditors during the year.Accordingly clause 3(xviii) of the Order is not applicable.

(xix) According to the information and explanations given to us and on the basis ofthe financial ratios ageing and expected dates of realisation of financial assets andpayment of financial liabilities our knowledge of the Board of

Directors and management plans though a material uncertainty related to Going Concernof the Company exists as at the Balance Sheet date as far as it relates to availabilityof lands for mining nothing has come to our attention which causes us to believe thatany material uncertainty exists as on the date of the audit report that the Company is notcapable of meeting its liabilities existing at the date of balance sheet as and when theyfall due within a period of one year from the balance sheet date. We however state thatthis is not an assurance as to the future viability of the Company. We further state thatour reporting is based on the facts up to the date of the audit report and we neither giveany guarantee nor any assurance that all liabilities falling due within a period of oneyear from the balance sheet date will get discharged by the Company as and when they falldue. We also draw reference to the section "Material Uncertainty Related to GoingConcern" in our main Audit Report.

(xx) (a) According to the information and explanations given to us and on the basisof the examination of the records of the Company there are no amounts remaining unspentin respect of other than ongoing projects. Accordingly clause 3(xx)(a) of the Order isnot applicable.

(b) According to the information and explanation provided to us and based on ourexamination of the records of the Company there are no amount remaining unspent underSection 135(5) of the Act pursuant to any ongoing project. Accordingly clause 3(xx)(b)of the Order is not applicable.

For R Subramanian and Company LLP For Manohar Chowdhry & Associates
Chartered Accountants Chartered Accountants
Firm Regn. No. 004137S/S200041 Firm Regn. No. 001997S
R. Subramanian M.S.N.M.Santosh
Partner Partner
M No. 008460 M No. 221916
UDIN: 22008460AKBFDJ9190 UDIN: 22221916AJXKXU9603
Place: Chennai
Date: May 30 2022

Annexure-II to Independent Auditors' Report on the Standalone Financial Statements

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

We have audited the internal financial controls over financial reporting of M/s. NLCIndia Limited ("the Company") as of March 31 2022 in conjunction with our auditof the Standalone Financial 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 controlstated in the Guidance Note on Audit of Internal Financial Controls over FinancialReporting issued by the Institute of Chartered Accountants of India (ICAI). Theseresponsibilities include the design implementation and maintenance of adequate internalfinancial controls that were operating effectively for ensuring the orderly and efficientconduct of its business including adherence to Company's policies the safeguarding ofits assets the prevention and detection of frauds and errors the accuracy andcompleteness of the accounting records and the timely preparation of reliable financialinformation as required under the Companies Act 2013.

Auditors' Responsibility

Our responsibility is to express an opinion on the Company's internal financialcontrols over financial reporting based on our audit. We have conducted our audit inaccordance with the Guidance Note on Audit of Internal Financial Controls over FinancialReporting (the "Guidance Note") and the Standards on Auditing to the extentapplicable to an audit of internal financial controls both issued by the ICAI. ThoseStandards and the Guidance Note require that we comply with ethical requirements and planand perform the audit to obtain reasonable assurance about whether adequate internalfinancial controls over financial reporting was established and maintained and if suchcontrols operated effectively in all material respects.

Our audit involves performing procedures to obtain audit evidence about the adequacy ofthe internal financial controls system over financial reporting and their operatingeffectiveness. Our audit of internal financial controls over financial reporting includedobtaining an understanding of internal financial controls over financial reportingassessing the risk that a material weakness exists and testing and evaluating the designand operating effectiveness of internal control based on the assessed risk. The proceduresselected depend on the auditors' judgement including the assessment of the risks ofmaterial misstatement of the financial statements whether due to fraud or error.

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

1. pertain to the maintenance of records that in reasonable detail accurately andfairly reflect the transactions and dispositions of the assets of the Company;

2. provide reasonable assurance that transactions are recorded as necessary to permitpreparation of financial statements in accordance with generally accepted accountingprinciples and that receipts and expenditures of the Company are being made only inaccordance with authorisations of management and directors of the Company; and

3. provide reasonable assurance regarding prevention or timely detection ofunauthorised acquisition use or disposition of the Company's assets that could have amaterial effect on the financial statements.

Inherent Limitations of Internal Financial Controls over Financial Reporting

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

Opinion

In our opinion to the best of our information and according to the explanations givento us the Company has in all material aspects an adequate internal financial controlssystem over financial reporting and such internal financial controls over financialreporting were operating effectively as at March 31 2022 based on the internal controlover financial reporting criteria established by the Company considering the essentialcomponents of internal control stated in the Guidance Note on

Audit of Internal Financial Controls Over Financial Reporting issued by the ICAI.

Other Matter

We did not audit the Internal Financial Control over Financial Reporting of two (2)branches included in the Standalone Financial Statements of the Company. The adequacy ofinternal financial controls system over financial reporting and the operatingeffectiveness of such internal financial controls over financial reporting in so far as itrelates to the above two branches is solely based on the corresponding auditors' reportsof the respective branch auditors.

Our opinion is not modified in respect of this matter.

For R Subramanian and Company LLP For Manohar Chowdhry & Associates
Chartered Accountants Chartered Accountants
Firm Regn. No. 004137S/S200041 Firm Regn. No. 001997S
R. Subramanian M.S.N.M.Santosh
Partner Partner
M No. 008460 M No. 221916
UDIN: 22008460AKBFDJ9190 UDIN: 22221916AJXKXU9603
Place: Chennai
Date: May 30 2022

Annexure-III to Independent Auditors' Report on the Standalone Financial Statements

Comments in regard to the directions and sub-directions issued by the Comptroller andAuditor General of India

Directions u/s 143(5) of the Companies Act 2013 Auditors' reply on action taken on the directions Impact on financial statement
1. Whether the Company has a system in place to process all the accounting transactions through IT system? If Yes the implications of processing of accounting transactions outside IT system on the integrity of the accounts along with the financial implications if anymay be stated As per the information and explanations given to us the Company has system in place to process all the accounting transactions through IT system. SAP ERP has been implemented for the processes like Financial Accounting (FI) Controlling (CO) Material Management (MM) Sales and Distribution (SD) Production Planning (PP) Project systems (PS) and Plant maintenance (PM).
During the year the Company has continued to use Payroll Accounting software for employee salary (PIPAS). For integration of the entire system the Company is in the process of implementing Human Capital Management (HCM) and Fund Management (FM) modules of SAP. NA
Our examination of records on sample basis did not reveal any transactions not coming within the purview of various IT systems as stated above.
2. Whether there is any restructuring of any existing loan or cases of waiver/ write off of debts/loans/interest etc. made by a lender to the Company due to the Company's inability to repay the loan? If yes the financial impact may be stated. During the year under Audit there were no cases of waiver/write off/restructuring of any debt/loan/interest etc. NA
3. Whether funds received / receivable for specific schemes from Central / State agencies were properly accounted for / utilised as per its terms and conditions? List the cases of deviation. During the year the Company has recognized 10.88 crore as capital grant for Solar Projects at Andaman and the same have been properly accounted for and utilised as per the terms and conditions stipulated thereto.
This does not include 5.23 crore towards teacher's salary grant received from Tamil Nadu State Government. As per practice in various states salaries of the school teachers are being paid by the Govt. of Tamilnadu through its education department. Apart from Salary all retirement benefits of those school teachers as per applicable guidelines issued by Govt. of Tamilnadu and are being paid by Govt of Tamil Nadu. NA
The salary of the teachers is paid by Govt. of Tamilnadu through NLCIL bank account as there are no separate bank accounts operated by those schools. Hence the regular salary payment of school teachers is not considered as a grant.
4. Whether the Company's financial statements had properly accounted for Mine Closure Liability as per Ministry of Coal guidelines dated 16 December 2019 ? Based on the information and explanations provided to us by the Company the ‘Guidelines for preparation of Mining Plan for the coal and lignite blocks' dated Dec 16 2019 read with ‘Standard of Operating Procedure for Mine Closure reimbursement against Mine Closure Activities in line with the new guidelines for preparation of mining plan for Coal and Lignite blocks issued vide No. F.No. 34011/28/2019-CPAM dated Dec 16 2019' the amount to be considered for Mine Closure amounting to 9 Lakhs per hectare shall arise in the case of New Coal & Lignite Mines/Blocks or for any existing Coal and Lignite Mine/Block which require modification of Mining Plan / Mine Closure Plan as per new modified guidelines dated Dec 16 2019. As on balance sheet date the Company has not received any approval from Ministry of Coal for its revised mine closure plan and accordingly the Company has not considered these new modified guidelines while creating the mine closure liability for the year ended Mar 31 2022.

NA

 

For R Subramanian and Company LLP For Manohar Chowdhry & Associates
Chartered Accountants Chartered Accountants
Firm Regn. No. 004137S/S200041 Firm Regn. No. 001997S
R. Subramanian M.S.N.M.Santosh
Partner Partner
M No. 008460 M No. 221916
UDIN: 22008460AKBFDJ9190 UDIN: 22221916AJXKXU9603
Place: Chennai
Date: May 30 2022

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