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Orient Paper & Industries Ltd.

BSE: 502420 Sector: Industrials
NSE: ORIENTPPR ISIN Code: INE592A01026
BSE 00:00 | 28 Jan 31.40 0.15
(0.48%)
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31.10

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32.10

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30.95

NSE 00:00 | 28 Jan 31.35 0.15
(0.48%)
OPEN

31.40

HIGH

32.15

LOW

31.20

OPEN 31.10
PREVIOUS CLOSE 31.25
VOLUME 119079
52-Week high 39.40
52-Week low 19.80
P/E
Mkt Cap.(Rs cr) 666
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00
OPEN 31.10
CLOSE 31.25
VOLUME 119079
52-Week high 39.40
52-Week low 19.80
P/E
Mkt Cap.(Rs cr) 666
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

Orient Paper & Industries Ltd. (ORIENTPPR) - Auditors Report

Company auditors report

To

The Members of

Orient Paper & Industries Limited

Report on the audit of the Financial Statements Opinion

1. W ehaveauditedtheaccompanyingfinancialstatements of Orient Paper & IndustriesLimited ("the Company") which comprise the Balance Sheet as at March 312021the Statement of Profit and Loss(including Other Comprehensive Income) the Statementof Changes in Equity and the Statement of Cash Flows for the year then ended and notes tothe financial statements including a summary of significant accounting policies and otherexplanatory information (hereinafter referred to as "the Financial Statements").

2. In our opinion and to the best of our information and according to the explanationsgiven to us the aforesaid financial statements give the information required by theCompanies Act 2013 ("the Act") in the manner so required and give a true andfair view in conformity with the accounting principles generally accepted in India of thestate of affairs of the Company as at March 31 2021 its total comprehensive income(comprising loss and other comprehensive income) its changes in equityand its cash flowsfor the year then ended.

Basis for opinion

3. W e conducted our audit in accordance with Standards on Auditing (SAs) specifiedunder section 143(10) of the Act. Our responsibilities under those Standards are furtherdescribed in the Auditor's responsibilities for the audit of the financial statementssection of our report. We are independent of the Company in accordance with the Code ofEthics issued by the Institute of Chartered Accountants of India together with the ethicalrequirements that are relevant to our audit of the financial statements under theprovisions of the Act and the Rules thereunder and we have fulfilled our other ethicalresponsibilities in accordance with these requirements and the Code of Ethics. We believethat the audit evidence we have obtained is sufficient and appropriate to provide a basisfor our opinion.

Emphasis of Matter

4. W e draw your attention to Note 52 to the financial statements which explains theuncertainties and management's assessment of the financial impact due to the lockdown/restrictions related to the COVID-19 pandemic imposed by the Governments for which adefinitive assessment of the impact is dependent upon future economic conditions. Ouropinion is not modified in respect of this matter.

Key audit matters

5 K ey audit matters are those matters that in our professional judgment were of mostsignificance in our audit of the financial statements of the current the year. Thesematters were addressed in the context of our audit of the financial statements as a wholeand in forming our opinion thereon and we do not provide a separate opinion on thesematters.

Key audit matter How our audit addressed the key audit matter
Assessment in relation to impairment of Property plant and equipment Right- of- use assets Intangible assets and Capital work- in- progress Our procedures in relation to management's impairment assessment of Property plant and equipment Right- of- use assets Intangible assets and Capital work- in- progress included:
(Refer to Note 49 to the financial statements) • Understanding and evaluating the controls and testing the operating e_ectiveness of the controls related to estimating the fair value of the assets.
Property plant and equipment Right- of- use assets Intangible assets and Capital work- in-progress represents 69% of total assets on the Balance Sheet. • Understanding the methodologies used by the management to estimate values in use.
Management has identified paper unit as single Cash Generating Unit (CGU) and has calculated the recoverable amount of the CGU as the higher of value in use and fair value less costs of disposal. • Assessing the growth rate used by management by comparing to current industry trends.
Value in use is based on discounted future cash flow • Verified the discount rates used by Management by comparing the same as being used in comparable industry.
forecasts requiring management to make judgements on certain key inputs including for example discount rates and long-term growth rates. • Along with auditor's specialist performed sensitivity analysis of possible changes to the key assumptions including assessment of impact of Covid-19 on cash flow projections discount and growth rates etc.
The impairment assessment performed by Management based on value in use method involved significant estimates towards future results of the business in particular the key assumptions on growth rate and discount rates used in the future cash flow forecasts. • Assessing the appropriateness of the presentation and disclosures in the financial statements.
Impairment assessment was considered to be a key audit matter in view of high uncertainty associated with Covid-19 which resulted into temporary interruption in the operations of the Company. Based on the above procedures Management's assessment in relation to impairment of Property plant and equipment Right- of- use assets Intangible assets and Capital work- in- progress is considered to be reasonable.
Management's assessment relating to litigation in respect of levy of tax on excess usage of water and impact on the financial statements We performed the following procedures in this regard:
(Refer Note 51(c) to the financial statements in respect of Water Tax) • Understood and evaluated the design and tested the operating e_ectiveness of controls around the assessment of the matter.
Amount of Rs. 126603 lacs (including interest and penalty of Rs 125190lacs) has been disclosed as ‘contingent liability' in the financial statements which represents excess water consumption charges levied by regulatory authorities (period up to April 2009) against the Company. The Company is contesting the said demand and had filed writ petition in the High Court of Madhya Pradesh and obtained interim stay. • Discussed the status and likelihood of the outcome of the litigation with the external legal counsel engaged by the management.
The Company has obtained external legal opinion to support their assessment around the outcome of the above litigation which have led to the management's conclusion that no provision is required to be made against the demand. • We also evaluated the independence and competency of the management's legal expert.
We considered above to be a key audit matter as the final outcomes of these litigations in case decided against the Company are likely to have significant financial impact. • Obtainedandtestedevidence tosupportthemanagement assessment with regard to non-provisioning against the demand.
• Assessed the appropriateness of disclosures made under the head ‘contingent liabilities' in the financial statements.
Based on the above procedures management's assessment with regard to litigation in respect of levy of tax on excess usage of water under contingent liabilities is considered reasonable.

Other Information

6. The Company's Board of Directors is responsible for the other information. The otherinformation comprises the information included in the Director's Report but does notinclude the financial statements and our auditor's report thereon.

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

In connection with our audit of the financial statements our responsibility is to readthe other information and in doing so consider whether the other information ismaterially inconsistent with the financial statements or our knowledge obtained in theaudit or otherwise appears to be materially misstated. If based on the work we haveperformed we conclude that there is a material misstatement of this other information weare required to report that fact.

We have nothing to report in this regard.

Responsibilities of management and those charged with governance for the financialstatements

7. The Company's Board of Directors is responsible for the matters stated in section134(5) of the Act with respect to the preparation of these financial statements that givea true and fair view of the financial position financial performance changes in equityand cash flows of the Company in accordance with the accounting principles generallyaccepted in India including the Accounting Standards specified under section 133 of theAct.This responsibility also includes maintenance of adequate accounting records inaccordance with the provisions of the Act for safeguarding of the assets of the Companyand 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 financial statements that give a true and fair view and are free from materialmisstatement whether due to fraud or error.

8. In preparing the financial statements management is responsible for assessing theCompany's ability to continue as a going concern disclosing as applicable mattersrelated to going concern and using the going concern basis of accounting unless managementeither intends to liquidate the Company or to cease operations or has no realisticalternative but to do so. Those Board of Directors are also responsible for overseeing theCompany's financial reporting process.

Auditor's responsibilities for the audit of the financial statements

9. Our objectives are to obtain reasonable assurance about whether the financialstatements as a whole are free from material misstatement whether due to fraud or errorand to issue an auditor's report that includes our opinion. Reasonable assurance is a highlevel of assurance but is not a guarantee that an audit conducted in accordance with SAswill always detect a material misstatement when it exists. Misstatements can arise fromfraud or error and are considered material if individually or in the aggregate theycould reasonably be expected to influence the economic decisions of users taken on thebasis of these financial statements.

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

• Identify and assess the risks of material misstatement of the financialstatements whether due to fraud or error design and perform audit procedures responsiveto those risks and obtain audit evidence that is sufficient and appropriate to provide abasis for our opinion. The risk of not detecting a material misstatement resulting fromfraud is higher than for one resulting from error as fraud may involve collusionforgery intentional omissions misrepresentations or the override of internal control.

• Obtain an understanding of internal control relevant to the audit in order todesign audit procedures that are appropriate in the circumstances. Under Section 143(3)(i)of the Act we are also responsible for expressing our opinion on whether the company hasadequate internal financial controls with reference to financial statements in place andthe operating effectiveness of such controls.

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

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

• Evaluate the overall presentation structure and content of the financialstatements including the disclosures and whether the financial statements represent theunderlying transactions and events in a manner that achieves fair presentation.

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

12. We also provide those charged with governance with a statement that we havecomplied with relevant ethical requirements regarding independence and to communicatewith them all relationships and other matters that may reasonably be thought to bear onour independence and where applicable related safeguards.

13. From the matters communicated with those charged with governance we determinethose matters that were of most significance in the audit of the financial statements ofthe current year and are therefore the key audit matters. We describe these matters in ourauditor's report unless law or regulation precludes public disclosure about the matter orwhen in extremely rare circumstances we determine that a matter should not becommunicated in our report because the adverse consequences of doing so would reasonablybe expected to outweigh the public interest benefits of such communication.

Report on other legal and regulatory requirements

14. As r equired by the Companies (Auditor's Report) Order 2016 ("theOrder") issued by the Central Government of India in terms of sub-section (11) ofsection 143 of the Act we give in the "Annexure B"a statement on the mattersspecified in paragraphs 3 and 4 of the Order to the extent applicable.

15. 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 other comprehensiveincome) the Statement of Changes in Equity and the Statement of Cash Flows dealt with bythis Report are in agreement with the books of account.

(d) In our opinion the aforesaid financial statements comply with the AccountingStandards specified under Section 133 of the Act.

(e) On the basis of the written representations received from the directors taken onrecord by the Board of Directors none of the directors is disqualified as on March 312021 from being appointed as a director in terms of Section 164 (2) of the Act.

(f) With respect to the adequacy of the internal financial controls with reference tofinancial statements of the Company and the operating effectiveness of such controlsrefer to our separate Report in "Annexure A".

(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 in our opinionand to the best of our information and according to the explanations given to us: i. TheCompany has disclosed the impact if any of pending litigations as at March 31 2021 onits financial position in its financial statements

– Refer Note 51 to the financial statements. ii. The Company has long-termcontracts as at March 31 2021 for which there were no material foreseeable losses. TheCompany did not have any derivative contract as at March 31 2021. iii. There has been nodelay in transferring amounts required to be transferred to the Investor Education andProtection Fund by the Company. iv. The reporting on disclosures relating to SpecifiedBank Notes is not applicable to the Company for the year ended March 31 2021.

16. The Company has paid/ provided for managerial remuneration in accordance with therequisite approvals mandated by the provisions of Section 197 read with Schedule V to theAct. Also refer Note 46(b) (ii) to the financial statements.

For Price Waterhouse & Co Chartered Accountants LLP

Firm Registration Number: 304026E/ E-300009 Chartered Accountants

Annexure A to Independent Auditors' Report

Referred to in paragraph 15(f)of the Independent Auditors' Report of even date to themembers of Orient Paper & Industries Limited on the financial statements for the yearended March 31 2021 Page 1 of 2

Report on the Internal Financial Controls with reference to financial statements underClause (i) of Sub-section 3 ofSection 143 of the Act

1. W e have audited the internal financial controls reference to financial statementsof Orient Paper & Industries Limited ("the Company") as of March 31 2021 inconjunction with our audit of the financial statements of the Company for the year endedon that date.

Management's Responsibility for Internal Financial Controls

2. 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 designimplementation 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 anderrors the accuracy and completeness of theaccounting records and the timely preparation of reliable financial information asrequired under the Act.

Auditors' Responsibility

3. Our r esponsibility is to express an opinion Company's internal financial controlswith reference to financial statements based on our audit. We conducted our audit inaccordance with the Guidance Note on Audit of Internal Financial Controls Over FinancialReporting (the"Guidance Note") and the Standards on Auditing deemed to beprescribed under section 143(10) of the Act to the extent applicable to an audit ofinternal financial controls both applicable to an audit of internal financial controlsand both issued by the ICAI. Those Standards and the Guidance Note require that we complywith ethical requirements and plan and perform the audit to obtain reasonable assuranceabout whether adequate internal financial controls with reference to financial statementswas established and maintained and if such controls operated effectively in all materialrespects.

4. Our audit involves performing procedures to obtain with audit evidence about theadequacy of the internal financial controls system with reference to financial statementsand their operating effectiveness.Our audit of internal financial controls with referenceto financial statements included obtaining an understanding of internal financial controlswith reference to financial statements assessing the risk that a material weaknessexists and testing and evaluating the design and operating effectiveness of internalcontrol based on the assessed risk. The procedures selected depend on the auditor'sjudgement including the assessment of the risks of material misstatement of the financialstatements whether due to fraud or error.

5. 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 financial statements.

Meaning of Internal Financial Controls with reference to financial statements

6. A company's internal financial controls 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. Acompany's internal financial controls withreference to financial on the statements includes those policies and procedures that (1)pertain to the maintenance of records that in reasonable detailaccurately and fairlyreflect the transactions and dispositions of the assets of the company; (2)providereasonable assurance that transactions are recorded as necessary to permit preparation offinancial statements in accordance with generally accepted accounting principles and thatreceipts and expenditures of the company are being made only in accordance withauthorisations of management and directors of the company; and (3) provide reasonableassurance regarding prevention or timely detection of unauthorised acquisition use ordisposition of the company's assets that could have a material effect on the financialstatements.

Inherent Limitations of Internal Financial Controls with reference to financialstatements

7.Because of the inherent limitations of internal financialcontrolswithreferencetofinancialstatementsincluding the possibility of collusion orimproper management override of controls material misstatements due to error or fraud mayoccur and not be detected. Also projections of any evaluation of the internal financialcontrols with reference to financial statements to future periods are subject to the riskthat the internal financial controls with reference to financial statements may becomeinadequate because of changes inconditions or that the degree of compliance with thepolicies or procedures may deteriorate.

Opinion

8. In our opinion the Company has in all respects an adequate internal financialcontrols system with reference to financial statements and such internal financialcontrols with reference to financial statements were operating effectively as at March 312021 based on the internal control over financial reporting criteria established by theCompany considering the essential components of internal control stated in the GuidanceNote on Audit of Internal Financial Controls Over Financial Reporting issued by theInstitute of Chartered Accountants ofIndia. (Also refer paragraph 4 of our Main AuditReport).

For Price Waterhouse & Co Chartered Accountants LLP

Firm Registration Number: 304026E/ E-300009 Chartered Accountants

Annexure B to Independent Auditors' Report

Referred to in paragraph 14 of the Independent Auditors' Report of even date to themembers of Orient Paper & Industries Limited on the financial statements as of and forthe year ended March 31 2021 Page 1 of 4

i. (a) The Company is maintaining proper records showing full particulars includingquantitative details and situation of fixed assets (property plant and equipment).

(b) The fixed assets (property plant and equipment) are physically verified by theManagement according to a phased programme designed to cover all the items over a periodof 3years which in our opinion is reasonable having regard to the size of the Companyand the nature of its assets.

Pursuant to the programme a portion of the fixed assets (property plant andequipment) has been physically verified by the Management during the year and no materialdiscrepancies have been noticed on such verification.

(c) The title deeds of immovable properties as disclosed in Note 3 on property plantand equipment and Note 4 on investment properties to the financial statements are held inthe name of the Company except for the cases below:

Asset Category Gross Block as at March 31 2021 (in lacs) Net Block as at March 31 2021 (in lacs) Remarks
Freehold Land 243.33 243.33 Correction in land records in Company's name is pending
Leasehold Land 2.17 2.17 Correction in land records in Company's name is pending
Investment properties 432.94 432.94 Registration in the name of the Company is pending

ii. The physical verification of inventory have been conducted at reasonable intervalsby the Management during the year.The discrepancies noticed on physical verification ofinventory as compared to book records were not material. iii. The Company has notgrantedany loans secured or unsecured to companies firms Limited LiabilityPartnerships or other parties covered in the register maintained under Section 189 of theAct. Therefore the provisions of Clause 3(iii) (iii)(a) (iii)(b) and (iii)(c) of thesaid Order are not applicable to the Company. iv. In our opinion and according to theinformation and explanations given to us the Company has complied with the provisions ofSection 185 and 186 of the Companies Act 2013 in respect of the loans and investmentsmade and guarantees and security provided by it. v. The Company has not accepted anydeposits from the public within the meaning of Sections 73 74 75 and 76 of the Act andthe Rules framed there under to the extent notified. vi. Pursuant to the rules made by theCentral Government of India the Company is required to maintain cost records as specifiedunder Section 148(1) of the Act in respect of its products.

We have broadly reviewed the same and are of the opinion that prima facie theprescribed accounts and records have been made and maintained. We have not however madea detailed examination of the records with a view to determine whether they are accurateor complete. vii. (a) According to the information and explanations given to us and therecords of the Company examined by us in our opinion except for dues in respect ofIndustrial License Fees under Orissa Municipal Act the Company is generally regular indepositing undisputed statutory dues including provident fund income tax andprofessional tax though there has been a slight delay in a few cases and is regular indepositing undisputed statutory dues including employees' state insurance sales taxservice tax duty of customs duty of excise value added tax cessgoods and service taxand other material statutory dues as applicable with the appropriate authorities.

Further for the period 1 April 2020 to 31 May 2020 the company has paid Goods andService Tax and filed GSTR 3B (after the due date but) within the timelines allowed byCentral Board of Indirect Taxes and Customs under the Circular No. 136/06/2020-GST datedApril 3 2020 on fulfilment of conditions specified therein.

The extent of the arrears of statutory dues outstanding as at March 31 2021 for aperiod of more than six months from the date they became payable are as follows:

Name of the statute Nature of dues Amount (Rs. In lacs) Period to which the amount relates Due date Date of Payment
Orissa Municipal Act Industrial License Fees 35.17 1996-97 to 2020- 21 Beginning of the respective years Not yet paid

Also refer note 47(iv) to the financial statements regarding management's assessment oncertain matters relating to provident fund.

(b) According to the information and explanations given to us and the records of theCompany examined by us there are no dues of service-taxduty of customs and goods andservice tax which have not been deposited on account of any dispute. The particulars ofdues of income tax sales taxduty of excise value added tax and energy development cessincluding surcharge as at March 31 2021 which have not been deposited on account of adispute are as follows:

Name of the statute Nature of dues Amount (Rs. In lacs) Period to which the amount relates Forum where the dispute is pending
Central Sales Tax Act 1956 Sales Tax 0.50 1986-87 High Court
6.27 1995-96 Sales Tax Tribunal
83.27 2001-02 2007-08 and 2010-11 to Appellate and Revision Board
2012-13
0.12 1979-80 to 1982- 83 Sales Tax Commissioner
12.22 1985-86 and 1999-2000 Assistant Commissioner
0.85 2013-14 Additional Commissioner
88.80 2016-17 Additional Commissioner
West Bengal Value Added Tax 2003 Value Added Tax 40.82 2007-08 West Bengal Commercial Taxes Appellate and Revision Board
Bihar Finance Act 1981 Sales Tax 39.74 1994-95 to 1996- 97 Commissioner of Commercial Tax
7.90 1994-95 to 1997- 98 Joint Commissioner of Commercial Taxes
Orissa Sales Tax Act 1947 Sales Tax 2.06 1985-86 and 1986-87 High Court
0.02 1983-84 Assistant Commissioner
Madhya Pradesh VAT Act 2002 Value Added Tax 14.63 2006-07 to 2009- 10 High Court
11.11 2008-09 Commercial Tax Appellate Board
M.P. Commercial Tax Act 1994 Sales Tax 7.00 2001-02 High Court
M.P. Sales Tax Act 1961 Sales Tax 14.65 1998-99 High Court
1.07 1986-87 Commercial Tax Appellate Board
Central Excise Act 1944 Excise Duty 878.93 1975-76 1976-77 1982-83 1989-90 1994-95 1995-96 2005-06 to 2008- 09 2011-12 Customs Excise & Service Tax Appellate Tribunal
23.45 2007-08 2010- 11 2011-12 and 2014-15 Commissioner (Appeals)
46.21 1975-76 to 1978- 79 and 1986-87 to 1997-98 Assistant Commissioner
Income Tax Act 1961 Income Tax 18.27 2018-19 Commissioner of Income Tax (Appeals)
Madhya Pradesh Upkar (Sanshodan) Energy Development 13734.30 2001-02 to 2020-21 Supreme Court
Adhiniyam 2004 Cess including Surcharge *

* including interest accrued by the Company- Rs 12104.68 lacs

viii. According to the records of the Company examined by us and the information andexplanation given to us the Company has not defaulted in repayment of loans or borrowingsto any financial institution or bank or Government or dues to debenture holders as at thebalance sheet date.

ix. In our opinion and according to the information and explanations given to us themoneys raised by way of term loans have been applied on an overall basis for thepurposes for which they were obtained.The Company has not raised any moneys by way ofinitial public offer or further public offer (including debt instruments).

x. During the course of our examination of the books and records of the Companycarried out in accordance with the generally accepted auditing practices in India andaccording to the information and explanations given to us we have neither come across anyinstance of material fraud by the Company or on the Company by its officers or employeesnoticed or reported during the year nor have we been informed of any such case by theManagement. xi. The Company has paid/ provided for managerial remuneration in accordancewith therequisite approvals mandated by the provisions of Section 197 read with Schedule Vto the Act.

Also refer paragraph 16 of our main audit report.

xii. As the Company is not a Nidhi Company and the Nidhi Rules 2014 are not applicableto it the provisions of Clause 3(xii) of the Order are not applicable to the Company.

xiii. The Company has entered into transactions with related parties in compliance withthe provisions of Sections 177 and 188 of the Act. The details of such related partytransactions have been disclosed in the financial statements as required under IndianAccounting Standard (Ind AS) 24 Related Party Disclosure specified under Section 133 ofthe Act.

xiv. The Company has not made any preferential allotment or private placement of sharesor fully or partly convertible debentures during the year under review.

Accordingly the provisions of Clause 3(xiv) of the Order are not applicable to theCompany. xv. The Company has not entered into any non-cash transactions with its directorsor persons connected with him. Accordingly the provisions of Clause 3(xv) of the Orderare not applicable to the Company.

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

Accordingly the provisions of Clause 3(xvi) of the Order are not applicable to theCompany.

For Price Waterhouse & Co Chartered Accountants LLP

Firm Registration Number: 304026E/ E-300009

Chartered Accountants

Avijit Mukerji

Partner

Membership Number 056155

UDIN: 21056155AAAABG5892

Kolkata

June 28 2021

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