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P B A Infrastructure Ltd.

BSE: 532676 Sector: Infrastructure
NSE: PBAINFRA ISIN Code: INE160H01019
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OPEN 9.82
PREVIOUS CLOSE 10.23
VOLUME 2576
52-Week high 22.73
52-Week low 7.50
P/E 27.87
Mkt Cap.(Rs cr) 14
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00
OPEN 9.82
CLOSE 10.23
VOLUME 2576
52-Week high 22.73
52-Week low 7.50
P/E 27.87
Mkt Cap.(Rs cr) 14
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

P B A Infrastructure Ltd. (PBAINFRA) - Auditors Report

Company auditors report

To the Members of

M/s PBA Infrastructure Limited.

Report on the Audit of the Standalone Financial Statements

Opinion

We have audited the accompanying financial statements of M/s. PBAInfrastructure Limited (“the Company”) which comprise the Balance Sheet as atMarch 312020 the Statement of Profit and Loss (including Other Comprehensive Income)the Cash Flow Statement and the Statement of Changes in Equity for the 12 months periodended and a summary of the significant accounting policies and other explanatoryinformation.

In our opinion and to the best of our information and according to theexplanations given to us the aforesaid financial statements give the information requiredby the Companies Act 2013 (‘Act') in the manner so required and give a true andfair view in accordance with the accounting principles generally accepted in Indiaincluding the Indian Accounting Standards (‘Ind AS') specified under Section 133of the Act of the state of affairs(financial position) of the Company as at 31st March2020 and its profit and loss (financial performance including other comprehensive income)its cash flows and changes in equity for the 12 months ended on that date.

Basis for Opinion

We conducted our audit in accordance with the Standards on Auditingspecified under Section 143(10) of the Act. Our responsibilities under those Standards arefurther described in the Auditor's Responsibilities for the Audit of the FinancialStatement section of our report. We are independent of the Company in accordance with theCode of Ethics issued by the Institute of Chartered Accountants of India (ICAi) togetherwith the ethical requirements that are relevant to our audit of the financial statementsunder the provisions of the Act and the rules thereunder and we have fulfilled our otherethical responsibilities in accordance with these requirements and the Code of Ethics. Webelieve that the audit evidence we have obtained is sufficient and appropriate to providea basis for our opinion.

Key Audit Matters

Complexities arising from COVID 19 on the verification aspects of thefinancial statements -

The opinion expressed in the present report is based mainly on theinformation facts and input data made available to us through electronic means by themanagement. We wish to highlight that due to COVID - 2019 induced restrictions on physicalmovement and strict timelines and the fact that place of business falls under Red Zone forlockdown implementation and there were constraints on actually visiting the place ofbusiness for verification. Hence as regards audit for the last quarter we were unable tovisit the office had to rely on information provided to us digitally for conduct of auditprocedures. Besides the Company being an EPC contractor has been impacted on account ofthe imposed lockdown by the GOI and the pandemic caused globally the effect of whichshall be seen in the current fiscal year.

Emphasis of Matter

a) Loan Statements pertaining to certain current/cash credit/term loanaccounts loans from banks & financial institutions have not been received hence notreconciled with the books of accounts. Hence to that effect in any of such pendingreconciliation of financial statements remain unascertained. Lead Bank under consortiumhas approached CMM Court to take physical possession of the various secured assets againsttotal consortium sanctioned / overdue limit of Rs.417.51 crores under SARFASEI Act 2002.The Company has also received notice of physical possession of various secured assets.Company has proposed One Time Settlement with the Banks in December 2017 and has furtherimproved the offer to Rs.150 crores in August 2018. Since the loan is NPA in the books ofthe Banks / FI's interest on these loans is not provided in the fiscal year 2019-20.

b) There were / are defaults in repayment of its Public Deposits andInter Corporate Deposits on maturity and payment of interest thereon for the past fewyears with repayment being delayed.

c) There are arbitration proceedings / legal cases against by / theCompany which may result in Compensation / interest / penalties.

d) Fixed Asset register is under compilation to have proper recordsshowing full particulars including quantitative details and situation of property plantand equipment. Company to have a regular program of physical verification of its fixedassets periodically.

e) Company follows accounting practice of recognizing revenue on thebasis percentage completion method. Company being an EPC contractor raises claims /arbitration money with employers / Customers for the delay on obtaining approvals costescalation etc. As per Company policy though the claims are raised for the actual lossincurred by the Company (SOC) the same is recognized in the books at realizable valuedetermined by the internal team of the Company. Though these claims are not acknowledgedby the employer / Customer the same being intangible in nature is being classified aswork in progress. The said claims though classified under WIP (Current Asset) are subjectto uncertainty as to recoverability. Unbilled work in progress of Rs.116 crores and tradereceivables amounting to Rs.46.87 crores as on 31st March 2020 which representvarious claims raised in the earlier years in respect of projects substantially closed orsuspended and where the claims are currently under negotiations. Based on discussions withemployers / customers arbitrations litigations and on legal opinion / past experiencewith respect to such claims management is of the view that the aforementioned balancesare fully recoverable.

f) Due to aforesaid reasons the existence of a material uncertaintythat may cast apprehension about the Company's ability to function as a goingconcern. However the financial statements of the Company have been prepared on a goingconcern basis & do not include any adjustments that might result from the outcome ofthis uncertainty.

g) Equity Shares of the Company are still under suspension w.e.f.09.04.2019 as per BSE notice dated 18.03.2019 vide No.20190318141 and NSE letter dated05.04.2019 vide No. NSE/SOP/SUS/ 78387. Further the Company had received show causenotice on account of suspension of shares from NSE dated 27th November 2019 for whichCompany had replied vide their letter dated 5.12.2019. The entire penalties as per thesaid letters has been paid in July 2020 by the Company as per the notices & necessaryaction for revocation of suspension of Trading of securities needs to be taken by theCompany and Exchange.

Information other than the Financial Statements and

Auditor's Report thereon.

The Company's Board of Directors is responsible for the otherinformation. The other information comprises the information included in the Annualreport but does not include the Financial statements and our auditor's reportthereon. The annual report is expected to be made available to us after the date of thisauditor's report.

Our opinion on the financial statements does not cover the otherinformation and we will not express any form of assurance thereon.

In connection with our audit of the financial statements ourresponsibility is to read the other information identified above when it becomes availableand in doing so consider whether the other information is materially inconsistent withthe financial statements or our knowledge obtained in the audit or otherwise appears to bematerially misstated. When we read the Annual Report if we conclude that there is amaterial misstatement therein we are required to communicate the matter to those chargedwith governance.

Responsibility of Management and Those Charged with Governance for theFinancial Statements

The Company's Board of Directors is responsible for the mattersstated in Section 134(5) of the Companies Act 2013 (“the Act”) with respect tothe preparation and presentation of these financial statements that give a true and fairview of the state of affairs(financial position) profit and loss (financial performanceincluding other comprehensive income) cash flows and changes in equity of the Company inaccordance with the accounting principles generally accepted in India including the IndAS specified under Section 133 of the Act. This responsibility also includes maintenanceof adequate accounting records in accordance with the provisions of the Act forsafeguarding of the assets of the Company and for preventing and detecting frauds andother irregularities; selection and application of appropriate accounting policies; makingjudgments and estimates that are reasonable and prudent; and design implementation andmaintenance of adequate internal financial controls that were operating effectively forensuring the accuracy and completeness of the accounting records relevant to thepreparation and presentation of the financial statements that give a true and fair viewand are free from material misstatement whether due to fraud or error.

In preparing the financial statements management is responsible forassessing the Company's ability to continue as a going concern disclosing asapplicable matters related to going concern and using the going concern basis ofaccounting unless management either

intends to liquidate the Company or to cease operations or has norealistic alternative 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 FinancialStatements.

Our objectives are to obtain reasonable assurance about whether thefinancial statements as a whole are free from material misstatement whether due to fraudor error and to issue an auditor's report that includes our opinion. Reasonableassurance is a high level of assurance but is not a guarantee that an audit conducted inaccordance with SAs will always detect a material misstatement when it exists.Misstatements can arise from fraud or error and are considered material if individuallyor in the aggregate they could reasonably be expected to influence the economic decisionsof users taken on the basis of these financial statements.

As part of an audit in accordance with SAs we exercise professionaljudgment and maintain professional skepticism throughout the audit. We also:

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

• Obtain an understanding of internal control relevant to theaudit in order to design audit procedures that are appropriate in the circumstances. Undersection 143(3)(i) of the Companies Act 2013 we are also responsible for expressing ouropinion on whether the company has adequate internal financial controls system in placeand the operating effectiveness of such controls.

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

• Conclude on the appropriateness of management's use of thegoing concern basis of accounting and based on the audit evidence obtained whether amaterial uncertainty exists related to events or conditions that may cast significantdoubt on the Company's ability to continue as a going concern. If we conclude that amaterial uncertainty exists we are required to draw attention in our auditor'sreport to the related disclosures in the financial statements or if such disclosures areinadequate to modify our opinion. Our conclusions are based on the audit evidenceobtained up to the date of our auditor's report. However future events or conditionsmay cause the Company to cease to continue as a going concern.

• Evaluate the overall presentation structure and content of thefinancial statements including the disclosures and whether the financial statementsrepresent the underlying transactions and events in a manner that achieves fairpresentation.

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

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

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

Report on Other Legal and Regulatory Requirements

1. As requi red by section 197 (16) of the Act we report that theCompany has paid remuneration to its Director's during the 12 months period ended 31stMarch 2020 in accordance with the provisions of and limits laid down under section197 read with Schedule V to the Act.

2. As required by the Companies (Auditor's Report) Order 2016(‘the Order') issued by the Central Government of India in terms of section143(11) of the Act we give in the Annexure A a statement on the matters specified inparagraphs 3 and 4 of the Order.

Further to our comments in Annexure A as required by Section 143(3) ofthe Act we report that:

a) We have sought and obtained all the information and explanationswhich to the best of our knowledge and belief were necessary for the purposes of our auditof the aforesaid financial statements;

b) Except for the possible effect of the matters described in the‘Emphasis of Matter' paragraph above in our opinion proper books of account asrequired by law have been kept by the Company so far as it appears from our examination ofthose books;

c) the Balance Sheet the Statement of Profit and Loss including OtherComprehensive Income the Cash Flow Statement and the Statement of changes in Equity dealtwith by this report are in agreement with the books of account;

d) Except for possible effect of the matters described in the‘Emphasis of Matter' paragraph above in our opinion the aforesaid Ind-ASfinancial statements comply with the Accounting Standards specified under Section 133 ofthe Act read with Companies (Indian Accounting Standards) Rules 2015 as amended

e) On the basis of written representations received from the Directorsas on 31st March 2020 taken on record by the Board of Directors none of theDirectors is disqualified as on 31st March 2020 from being appointed as adirector in terms of Section 164(2) of the Act; and

f) With respect to the adequacy of the internal financial controls overfinancial reporting of the Company and the operating effectiveness of such controls referto our separate report in “Annexure B” to this report.

g) With respect to the other matters to be included in theAuditor's Report in accordance with the Rule 11 of Companies (Audit and Auditors)Rules 2014 (as amended) in our opinion and to the best of our information and accordingto the explanation given to us:

i. Company has disclosed the impact of pending litigations on itsfinancial position in its financial statements Refer Note No.A-25 to the financialstatements;

ii. Company did not have any Long term contract including derivativescontract as such the question of commenting on any material foreseeable losses thereondoes not arise.

iii. There has been no delay in transferring amount required to betransferred to the Investor Education and Protection Fund by the Company.

For R V Luharuka & Co LLP
Chartered Accountants
FRN No. 105662W / W100174R
Ramesh Luharuka
Place: Mumbai Partner
Dated: 31st July 2020 Membership No: 031765

Annexure I to the Independent Auditor's Report of even date to themembers of PBA Infrastructure Ltd. on the financial statements for the twelve monthsperiod ended 31st March 2020.

Referred to in Paragraph 2 under the heading ‘Report on OtherLegal & Regulatory Requirements' of our report of even date to the financialstatement of the Company for the year ended March 31 2020 Based on the audit proceduresperformed for the purpose of reporting a true and fair view on the financial statements ofthe Company and taking into consideration the information and explanations given to us andthe books of account and other records examined by us in the normal course of audit andto the best of our knowledge and belief we report that:

i. In respect of the Company's fixed assets

a. Company has not been maintaining proper records showing fullparticulars including quantitative details and situation of property; plant andequipment.

b. Company does not have a regular program of physical verification ofits fixed assets by which fixed assets are verified in a phased manner. In accordancecertain fixed assets

wherein projects have been completed are not identifiable; hencediscrepancies exist. In our opinions this periodicity of physical verification needs tobe reasonable having regard to the size of the Company and the nature of its assets.

c. According to the information and explanations given to us and on thebasis of our examination of the records of the Company the title deeds of immovableproperties are held in the name of the company.

ii. In respect of the Company's Inventory

a. As explained to us the inventories have been physically verifiedduring the year by the management. In our opinion having regard to the nature andlocation of stocks the frequency of the physical verification is reasonable.

b. Company follows accounting practice of recognizing revenue underIndAS-11 on the basis percentage completion method. The Company being an EPC contractorraises claims / arbitration money with employers/ Customers with regard to delay onobtaining approvals cost escalation etc. As per Company policy though the claim may beraised for the actual loss incurred by the Company on account of delay with respect to theemployer/customer the same is recognized in the books depending upon the realizable valueof the same which is determined by the internal team of the Company. Though these claimsare not acknowledged by the employer / debtor the same being intangible in nature isbeing classified as WIP by the Company. As on 31st March 2020 WIP includesclaims of Rs.116.00 crores.

iii. Company has not granted any loan secured or unsecured to bodiescorporate covered in the register maintained under section 189 of the Companies Act2013(‘the Act'). Accordingly the provisions of Clauses 3(iii)(a) 3(iii)(b) and3(iii)(c) of the order are not applicable.

iv. In our opinion and according to the information and explanationsgiven to us the company has complied with the provisions of section 185 and 186 of theCompanies Act 2013 in respect of loans investments guarantees and security.

v. Company has accepted deposits from the public in previous years.Company has generally complied with the provisions of directives issued by Reserve Bank ofIndia and the provisions of Section 73 to 76 of the Companies Act 2013 and rules framedthere under except filing of Return of Deposit with Registrar of Companies and default inpayment of Interest and principal on maturity. As per the information and explanationgiven to us no order under the aforesaid sections have been passed by the Company LawBoard National Company Law Tribunal or Reserve Bank of India or any Court or any othertribunal on the Company. Presently Company has been making interest and principal paymenttowards public deposits to individuals who have initiated legal action.

vi. We have broadly reviewed the books of accounts maintained by theCompany pursuant to the Companies (Cost records and audit) Rules 2014 and as prescribed bythe Central Government under section 148(1) of the Act and are of the opinion thatprima-facie the prescribed accounts and cost records have been made and maintained by theCompany. We have not however made a detailed examination of the cost records with a viewto determining whether they are accurate or complete.

vii. According to the information and explanations given to us:-

a. Undisputed amounts payable in respect of provident fund income taxsales tax wealth tax service tax duty of excise duty of customs Value Added TaxGoods & Service Tax cess have generally been regularly deposited to theappropriateauthorities except for the following which were in arrears as at 31stMarch 2020 for a period of more than six months from the date they became payable:-

Particulars Amount (In Lakhs)
Entry Tax 4.53
Profession 1.21
TDS 18.68
GST 76.36
Provident Fund Payable 1.24

b. There are no material dues of wealth tax duty of customs and cesswhich have not been deposited with the appropriate authorities on account of any dispute.However the following dues of income tax sales tax service tax and value added tax havebeen disputed by the Company:-

Name of the Statute Nature of dues Amount (In Lakhs) Forum where dispute is pending
MVAT Act Tax & Penalty 5392.93 Appellate Authority VAT Mumbai
Rajasthan Entry Tax Tax & Penalty 325.00 High Court
Income Tax Tax 119.90 CIT (A) Mumbai
Gujarath VAT Tax & Penalty 10.91 Appellate Authority VAT Ahmedabad

viii. In our opinion and according to the information and explanationsgiven to us the Company has defaulted in the repayment of dues to financial institutionsand banks. The details of such default are given below. There are no loans or borrowingspayable to Government and debenture holders.

Long Term Borrowings

(Amount in Rs.)

Sr. No Name of Bank Total Default Amount (including Principal and Interest) Continuing Default Period
1 Royal Bank of Scotland 970000 Sep-12
2 Shriram Equipment Finance Ltd 21899393 Since Jan-14

Short Term Borrowings

Sr. No Name of Bank Total Default Amount (including Principal and Interest) Continuing Default Period
1 Canara Bank -LTL-1(CDR) 334006784 Since April 13
2 Canara Bank -CC 906755675 Since June2013
3 Canara Bank FITL 61160587 Since April 2013
4 Canara Bank -LTL-II (CDR) 430525168 Since April 2013
5 Canara Bank-BG Invoked 700440142 Since July2013
6 Canara Bank-EMD 152981004 Since April 2013
7 KarurVysya Bank -FITL 3504739 Since Dec-14
8 KarurVysya Bank-CC 136841773 Since Nove2014
9 KarurVysya Bank-CDR 64454165 Since Oct14
10 Punjab & Sind Bank -CC 197815748 Since Sept2015
11 State Bank of India -FITL 3460643 Since June14
12 State Bank of India -BG 116013986 Since Sept2017
13 State Bank of India a-CC 148541444 Since Jan2014
14 State Bank of India-CDR 48640729 Since June14
15 Union Bank -FITL-I 4899361 Since March14
16 Union Bank -FITL-II 770053 Since April 14
17 Union Bank -LTL-I ( CDR) 72781487 Since Oct-13
18 Union Bank -LTL-II ( CDR 11311470 Since July 13
19 Union Bank of India -EMD 21690816 Since April 2013
20 Union Bank of India -OD 198335200 Since March 2014
21 Union Bank of India-BG Invoked 193588568 Since March 2014
22 Union Bank of India-CC 17725991 Since Jan2014

ix. According to the i nformation and explanations given to us theCompany has not raised moneys by way of initial public offer or further public offerincluding debt instruments. Accordingly the provisions of clause 3 (ix) of the Order arenot applicable to the Company and hence not commented upon.

x. Based upon the audit procedures performed and the information andexplanations given by the management we report that no fraud by the Company or on thecompany by its officers or employees has been noticed or reported during the year.

xi. According to the information and explanations given to us themanagerial remuneration has been paid / provided in accordance with the requisiteapprovals mandated by the provisions of section 197 read with Schedule V to the CompaniesAct 2013

xii. In our opinionand according to the information and explanationsgiven to us the Company is not a Nidhi Company. Therefore the provisions of clause 3(xii) of the Order are not applicable to the Company and hence not commented upon.

xiii. In our opinion all transactions with the related parties are incompliance with section 177 and 188 of Companies Act 2013 and the details have beendisclosed in the Notes to Financial Statements as required by the applicable accountingstandards.

xiv. According to the information and explanations given by themanagement the Company has not made any preferential allotment or private placement ofshares or 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 and hence not commented upon.

xv. According to the information and explanations given by themanagement the Company has not entered into any non-cash transactions with directors orpersons connected with him. Accordingly the provisions of clause 3 (xv) of the Order arenot applicable to the Company and hence not commented upon.

xvi. In our opinion and according to the information given to us thecompany is not required to be registered under section 45-1A of the Reserve Bank of IndiaAct 1934 and accordingly the provisions of clause 3 (xvi) of the Order are notapplicable to the Company and hence not commented upon.

For R V Luharuka & Co LLP
Chartered Accountants
FRN No. 105662W / W100174R
Ramesh Luharuka
Place: Mumbai Partner
Dated: 31st July 2020 Membership No: 031765

Annexure II to the Independent Auditor's Report of even date tothe members of PBA Infrastructure Limited on the financial statements for the 12 monthsperiod ended on 31st March 2020

Referred to in paragraph 2(g) under the heading ‘Report on OtherLegal & Regulatory Requirement' of our report of even date to the financialstatements of the Company for the year ended March 31 2020.

Report on the Internal Financial Controls under Clause (i) ofSub-section 3 of Section 143 of the Companies Act 2013 (“the Act”)

We have audited the internal financial controls over financialreporting of M/s. PBA Infrastructure Limited (“the Company”) as of March 312020 in conjunction with our audit of the financial statements of the Company for the yearended on that date.

Management's Responsibility for Internal Financial Controls

Company's management is responsible for establishing andmaintaining internal financial controls based on the internal control over financialreporting criteria established by the Company considering the essential components ofinternal control stated in the Guidance Note on Audit of Internal Financial Controls overFinancial Reporting issued by the Institute of Chartered Accountants of India(‘ICAI'). These responsibilities include the design implementation andmaintenance of adequate internal financial controls that were operating effectively forensuring the orderly and efficient conduct of its business including adherence tocompany's policies the safeguarding of its assets the prevention and detection offrauds and errors the accuracy and completeness of the accounting records

and the timely preparation of reliable financial information asrequired under the Companies Act 2013.

Auditors' Responsibility

Our responsibility is to express an opinion on the Company'sinternal financial controls over financial reporting based on our audit. We conducted ouraudit in accordance with the Guidance Note on Audit of Internal Financial Controls OverFinancial Reporting (the “Guidance Note”) and the Standards on Auditing issuedby ICAI and deemed to be prescribed under section 143(10) of the Companies Act 2013 tothe extent applicable to an audit of internal financial controls both applicable to anaudit of Internal Financial Controls and both issued by the Institute of CharteredAccountants of India. Those Standards and the Guidance Note require that we comply withethical requirements and plan and perform the audit to obtain reasonable assurance aboutwhether adequate internal financial controls over financial reporting was established andmaintained and if such controls operated effectively in all material respects.

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

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

Meaning of Internal Financial Controls Over Financial Reporting

Company's internal financial control over financial reporting is aprocess designed to provide reasonable assurance regarding the reliability of financialreporting and the preparation of financial statements for external purposes in accordancewith generally accepted accounting principles. A company's internal financial controlover financial reporting includes those policies

and procedures that (1) pertain to the maintenance of records that inreasonable detail accurately and fairly reflect the transactions and dispositions of theassets of the company; (2)provide reasonable assurance that transactions are recorded asnecessary to permit preparation of financial statements in accordance with generallyaccepted accounting principles and that receipts and expenditures of the company arebeing made only in accordance with authorizations of management and directors of thecompany; and (3) provide reasonable assurance regarding prevention or timely detection ofunauthorized acquisition use or disposition of the company's assets that could havea material effect on the financial statements.

Inherent Limitations of Internal Financial Controls Over FinancialReporting

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

Opinion

In our opinion the Company has in all material respects an adequateinternal financial controls system over financial reporting and such internal financialcontrols over financial reporting were operating effectively as at March 31 2020 basedon the internal control over financial reporting criteria established by the Companyconsidering the essential components of internal control stated in the Guidance Note onAudit of Internal Financial Controls Over Financial Reporting issued by the Institute ofChartered Accountants of India.

For R V Luharuka & Co LLP
Chartered Accountants
FRN No. 105662W / W100174R
Ramesh Luharuka
Place: Mumbai Partner
Dated: 31st July 2020 Membership No: 031765

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