You are here » Home » Companies ยป Company Overview » PNB Gilts Ltd

PNB Gilts Ltd.

BSE: 532366 Sector: Financials
NSE: PNBGILTS ISIN Code: INE859A01011
BSE 10:42 | 24 Mar 57.58 -0.43
(-0.74%)
OPEN

57.40

HIGH

58.00

LOW

57.25

NSE 10:29 | 24 Mar 57.40 -0.65
(-1.12%)
OPEN

57.25

HIGH

58.10

LOW

57.25

OPEN 57.40
PREVIOUS CLOSE 58.01
VOLUME 5693
52-Week high 78.95
52-Week low 56.75
P/E
Mkt Cap.(Rs cr) 1,037
Buy Price 57.40
Buy Qty 125.00
Sell Price 57.58
Sell Qty 187.00
OPEN 57.40
CLOSE 58.01
VOLUME 5693
52-Week high 78.95
52-Week low 56.75
P/E
Mkt Cap.(Rs cr) 1,037
Buy Price 57.40
Buy Qty 125.00
Sell Price 57.58
Sell Qty 187.00

PNB Gilts Ltd. (PNBGILTS) - Auditors Report

Company auditors report

To The Members of PNB Gilts Ltd

This revised Independent Auditor's Report is being issued in supersession of ourearlier Independent Auditors' Report dated 22nd June 2021 at the instance ofComptroller & Auditor General (C&AG) of India. The revised report is being issuedin view of certain modification in Annexure "B" of Companies Auditors ReportOrder 2016 as pointed out by C&AG of India in our earlier report. Further we confirmthat these changes do not affect true & fair view and our opinion as expressed earlierand also none of the figures have undergone any change in the Financial Statements of theCompany as at 31st March 2021.

Report on the Audit of the Ind AS Financial Statements

We have audited the accompanying financial statements of PNB Gilts Ltd. ("theCompany") which comprise the Balance Sheet as at 31st March 2021 the Statement ofProfit and Loss (including Other Comprehensive Income) the Statement of Changes in Equityand the Cash Flow Statement for the year ended on that date and a summary of thesignificant accounting policies and other explanatory information (hereinafter referred toas "the financial statements").

Opinion

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 Indian Accounting Standards prescribed under section 133of the Act read with the Companies (Indian Accounting Standards) Rules 2015 as amended("Ind AS") and other accounting principles generally accepted in India of thestate of affairs of the Company as at 31st March

2021 its profit changes in equity and its cash flows for the year ended on that date.

Basis for Opinion

We conducted our audit of the financial statements in accordance with the standards onAuditing as specified under section 143(10) of the Act (SAs). Our responsibilities underthose standards are further described in the Auditor's Responsibilities for the Audit ofthe Financial Statements section of our report. We are Independent to the Company inaccordance with the Code of Ethics issued by the Institute of Chartered Accountants ofIndia (ICAI) together with the independence requirements that are relevant to our audit ofthe financial statements under the provisions of the Act and the Rules made thereunderand we have fulfilled our other ethical responsibilities in accordance with theserequirements and the ICAI's Code of Ethics. We believe that the audit evidence we haveobtained is sufficient and appropriate to provide a basis for our audit opinion on thefinancial statements

Key Audit Matters

Key audit matters are those matters that in our professional judgment were of mostsignificance in our audit of the financial statements of the current period. These matterswere addressed in the context of our audit of the financial statements as a whole and informing our opinion thereon and we do not provide a separate opinion on these matters. Wehave determined the matters described below to be the key audit matters to be communicatedin our report.

Sr.No. Key Audit Matter Auditor's Response
1. Evaluation of uncertain income tax positions: Principal Audit Procedures:
The Company has material uncertain income tax positions including matters under dispute which involves significant judgment to determine the possible outcome of these disputes. Obtained detailed positions of tax assessments and demands from the management duly certified by the tax retainers of the Company. We involved our internal experts to challenge the management's
Refer Note 37 to the Financial Statements. underlying assumptions in estimating the tax provision and the possible outcome of the disputes. Our internal experts also considered legal precedence and other rulings in evaluating management's position on these uncertain tax positions. Additionally we considered the effect of new information in respect of uncertain tax positions as at the time of audit to evaluate whether any change was required to management's position on these uncertainties.
2. Classification and Valuation of Investments Identification of and provisioning for Non- Performing Investments (Note 17 read with Note 30 to the financial Statements) Investments include investments made by the Company in various Government Securities Bonds Debentures Shares Security receipts and other approved securities. Investments constitute 89.83 per cent of the Company's total assets. These are governed by the circulars and directives of the RBI. Our audit approach towards Investments with reference to the RBI Circulars/directives included the understanding of internal controls and substantive audit procedures in relation to valuation classification identification of non- performing investments (NPIs) provisioning related to Investments. In our audit –
These directions of RBI inter-alia cover valuation of investments classification of investments identification of non-performing investments the corresponding non-recognition of income and provision there against. The valuation of unquoted investments and thinly traded investments is an area of inherent risk because of market volatility unavailability of reliable prices and macro- economic uncertainty. Accordingly our audit was focused on valuation of investments classification identification of non-performing investments and provisioning related to investments. The valuation of each category (type) of the aforesaid securities is to be done as per the method prescribed in circulars and directives issued by the RBI which involves collection of data/information from various sources such as FIMMDA rates rates quoted on BSE/NSE financial statements of unlisted companies etc. Considering the complexities and extent of judgment involved in the valuation volume of transactions investments on hand and degree of regulatory focus we determined the above area as a Key Audit Matter. a) We evaluated and understood the Company's internal control system to comply with relevant RBI guidelines regarding valuation and provisioning related to investments.
b) For the selected sample of investments in hand we tested accuracy and compliance with the RBI Master Circulars and directions by re-performing valuation.
c) We assessed and evaluated the process of identification of NPIs and corresponding reversal of income and creation of provision;
d) We carried out substantive audit procedures to re-compute independently the provision to be maintained in accordance with the circulars and directives of the RBI.
Accordingly we selected samples and tested for NPIs as per the RBI guidelines and recomputed the valuations and provision to be maintained in accordance with the RBI Circular for those selected sample.

Information other than the Financial Statements and Auditor's 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 ManagementDiscussion and Analysis Board's Report including Annexures to Board's Report BusinessResponsibility Report Corporate Governance and Shareholder's Information 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 during thecourse of our audit or otherwise appears to be materially misstated.

If based on the work we have performed we conclude that there is a materialmisstatement of this other information we are required to report that fact. We havenothing to report in this regard.

Management's Responsibility for the Financial Statements

The Company's Management / Board of Directors is responsible for the matters stated inSection 134(5) of the Act with respect to preparation and presentation of these financialstatements that give a true and fair view of the equity and financial positioncash flows offinancialthe Company in accordance with the accounting principles generallyaccepted in India. This responsibility also includes maintenance of adequate accountingrecords in accordance with the provisions of the Act for safeguarding the assets of theCompany and for preventing and detecting frauds and other irregularities; selection andapplication of appropriate accounting policies; making judgments and estimates that arereasonable and prudent; and design implementation and maintenance of adequate internalfinancial controls that were operating effectively for ensuring the accuracy andcompleteness of the accounting records relevant to the preparation and presentation ofthe financial statements that give a true and fair view and are free from materialmisstatement whether due to fraud or error.

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.

The Board of Directors is responsible for overseeing the Company's financialreportingprocess.

Auditor's Responsibilities for the Audit of the Financial Statements

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.

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 financial statementswhether due to fraud or error design and perform audit procedures responsive to thoserisks and obtain audit evidence that is sufficient and appropriate to provide a basis forour opinion. The risk of not detecting a material misstatement resulting from fraud ishigher than for one resulting from error as fraud may involve collusion forgeryintentional omissions misrepresentations or the override of internal control.

Obtain an understanding of internal financial controls relevant to the audit in orderto design audit procedures that are appropriate in the circumstances. Under section143(3)(i) of the Act we are also responsible for expressing our opinion financialcontrolssystem in place and whethertheCompanyhasadequateinternal the operating effectivenessof such controls.

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

Conclude on the appropriateness of management's use of the going concern basis ofaccounting and based on the audit evidence obtained whether a material uncertaintyexists related to events or conditions that may cast significant doubt on the Company'sability to continue as a going concern. If we conclude that a material uncertainty existswe are required to draw attention in our auditor's report to the related disclosures inthe 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 financial statementsincluding the disclosures and whether the financial statements represent the underlyingtransactions and events in a manner that achieves fair presentation.

Materiality is the magnitude of misstatements in the financial statements thatindividually or in aggregate makes it probable that the economic decisions of areasonably knowledgeable user of the financial statements may be influenced. We considerquantitative materiality and qualitative factors in

(i) planning the scope of our audit work and in evaluating the results of our work; and(ii) to evaluate the effect of any identifiedmisstatements in the 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 anysignificant deficiencies in internal control that we identify during our audit.

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

From the matters communicated with those charged with governance we determine thosematters that were of most significancein the audit of the financial statements of thecurrent period 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

1. As required by Section 143(3) of the Act based on our audit 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 Statement of Changes in Equity and the Statement of Cash Flow dealt with by thisReport are in agreement with the relevant books of account. d. In our opinion theaforesaid financial statements comply with the Ind AS specified under Section 133 of theAct read with Rule 7 of the Companies (Accounts) Rules 2014.

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

f. With respect to the adequacy of the internal financial controls over financialreporting of the Company and the operating effectiveness of such controls refer to ourseparate Report in "Annexure A".

g. With respect to the other matters to be included in the Report in accordance withthe requirements of section 197(16) of the Act as amended: In our opinion and to the bestof our information and according to the explanations given to us the remuneration paid bythe Company to its directors during the year is in accordance with the provisions ofsection 197 of the Act. h. With respect to the other matters to be included in the Reportin accordance with Rule 11 of the Companies (Audit and Auditors) Rules 2014 as amendedin our opinion and to the best of our information and according to the explanations givento us:

i. The Company has disclosed the impact of pending litigations on its financialposition in its financial statements

ii. The Company has made provision as required under the applicable law or accountingstandards for material foreseeable losses if any on long-term contracts includingderivative contracts.

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

Protection Fund by the Company.

2. As required by the Companies (Auditor's Report) Order 2016 ("the Order")issued by the Central Government of India in terms of sub-section (11) of Section 143 ofthe Act we give in Annexure "B" a statement on the matters specified inparagraphs 3 and 4 of the Order.

3. As required by the Comptroller and Auditor General of India through directionsissued under section 143(5) of the Act we give a report in the attached Annexure"C".

"Annexure- A" to the Independent Auditor's Report

(Referred to in paragraph 1(f) under ‘Report on Other Legal and RegulatoryRequirements' section of our report to the Members of PNB Gilts Limited of even date)

Report on the Internal Financial Controls with reference to financial statements underClause (i) of Sub- section 3 of Section 143 of the Companies Act 2013 ("theAct")

We have audited the internal financial controls over financial reporting ofPNB GiltsLtd. ("the Company") as of 31st March 2021 in conjunction with our audit ofthe financial statements of the Company for the year ended on that date.

Management's Responsibility for Internal Financial Controls

The Board of Directors of the Company is responsible for establishing and maintaininginternal financial controls based on the internal control over financial reportingcriteria established by the Company considering the essential components of internalcontrol stated in the Guidance Note on Audit of Internal Financial Controls Over Financial

Reporting issued by the Institute of Chartered Accountants of India. 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 respective company's policies thesafeguarding of its assets the prevention and detection of frauds and errors theaccuracy and completeness of the accounting records and the timely preparation ofreliable financial information as required under the Companies

Act 2013.

Auditor's Responsibility

Our responsibility is to express an opinion on the internal financial controls overfinancial reporting of the Company based on our audit. We conducted our audit inaccordance with the Guidance Note on Audit of Internal Financial Controls Over FinancialReporting (the "Guidance Note") issued by the Institute of Chartered Accountantsof India and the Standards on Auditing prescribed under Section 143(10) of the CompaniesAct 2013 to the extent applicable to an audit of internal financial controls. 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 controls system over financial reporting and their operating effectiveness.Our audit of internal financial controls over financial reporting included obtaining anunderstanding of internal financial controls over financial reporting assessing the riskthat a material weakness exists and testing and evaluating the design and operatingeffectiveness of internal control based on the assessed risk. The procedures selecteddepend on the auditor's judgment including the assessment of the risks of materialmisstatement of the financial statements whether due to fraud or error.

We believe that the audit evidence we have obtained is sufficientand 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 internal financial control over financial reportingincludes those policies and procedures that-Pertain to the maintenance of recordsthatinreasonabledetailaccuratelyandfairlyreflectthe transactions and dispositions of theassets of the company;

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

Provide reasonable assurance regarding prevention or timely detection of unauthorisedacquisition use or disposition of the assets that could have a material effect on thefinancial statements. Inherent Limitations of Internal Financial Controls Over FinancialReporting

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 and material respects an adequateinternalfinancialcontrolssystem over financial such internal financial controls over financial reporting wereoperating effectively as at March 31 2021 based on the internal control over financialreporting criteria approved by the Board considering the essential components of internalcontrol stated in the Guidance Note on Audit of Internal Financial Controls Over FinancialReporting issued by the

Institute of Chartered Accountants of India.

"Annexure- B" to the Independent Auditor's Report

(Referred to in paragraph 2 under ‘Report on Other Legal and RegulatoryRequirements' section of our report to the Members of PNB Gilts Limited of even date).

Based upon the information and explanations furnished to us and the books and recordsexamined by us in the normal course of our audit we report that:

i) (a) The Company has maintained proper records showing full particulars includingquantitative details and situation of fixed assets.

(b) As reported by the management of the company the physical verification of itsfixed assets is conducted by its own staff on quarterly basis for the head office andyearly for the branch offices. No discrepancies were reported during the physicalverification of assets.

(c) The Company owns 19 flats as immovable properties and 3 flats as InvestmentProperties. The title deeds of the flats are in the name of the company.

(ii) The Company's inventory comprising of Treasury Bills and Dated GovernmentSecurities are held in the form of Subsidiary General Ledger (SGL) account maintained withthe Reserve Bank of India and the said stock is verified by the management with theconfirmation certificates received from Reserve Bank of India on a monthly basis. Thestock of other securities held by the Company in de-materialized form with NSDL/SHCIL isverified by the management with the confirmation certificates received from them on amonthly basis. In our opinion the frequency of such verification is reasonable. Nodiscrepancies were observed during the physical verification of inventory as compared tobook records.

(iii) The Company has not granted any loans secured or unsecured to companies firms orother parties covered in the register maintained u/s 189 of the Act. The Company has nottaken any loans secured or unsecured from companies firms or other parties covered in theregister maintained u/s 189 of the Act.

(iv) According to the information and explanations given to us no loans investmentsguarantees and securities have been given by the Company to concerns which are coveredunder section 185 of the Companies Act

2013 and section 186 of the Companies Act 2013.

(v) According to the information and explanations given to us the Company has notaccepted any deposits from the public within the meaning of Section 73 to 76 of theCompanies Act 2013 or any other relevant provisions of the Companies Act 2013 and rulesframed there under.

(vi) According to the information/explanations given to us maintenance of the costrecords for the products/services/activities of the Company has not been prescribed by theCentral Government under Section148(1)oftheCompaniesAct2013.

vii) (a) According to the information/explanations given to us the Company is regularin depositing undisputed statutory dues including Provident fund Employees' StateInsurance Income Tax Sales Tax Service Tax Duty of Customs Duty of Excise ValueAdded Tax Cess and any other statutory dues to the appropriate authorities.

(b) According to the information/explanations given to us the Company has somedisputes which have resulted into demands under the Income Tax Act 1961 which have beennot deposited. The details of which are given below:

Name of the Statute Nature of the Dues Amount Provided in the books and not paid Amount not provided for and treated as contingent liability Period to which the amount relates (Assessment Year)

Forum where dispute is pending

Remarks if any
Income Tax Act 1961 Income Tax Dues 0.40 3.59 2008-09 AO --
Income Tax Act 1961 Income Tax Dues 2.11 - 2009-10 AO --
Income Tax Act 1961 Income Tax Dues 200.91 - 2010-11 AO --
Income Tax Act 1961 Income Tax Dues 6.64 - 2011-12 AO --
Income Tax Act 1961 Income Tax Dues 4.76 - 2013-14 AO --
Income Tax Act 1961 Income Tax Dues 48.17 120.53 2016-17 CIT(A) --
Income Tax Act 1961 Income Tax Dues 9.95 31.57 2017-18 CIT(A) --
Income Tax Act 1961 Income Tax Dues 26.74 40.02 2018-19 CIT(A) --
Total 299.68 195.71

(viii) According to the information and explanations given to us the Company has notdefaulted in repayment of dues to a financial institution or banks.

(ix) According to the information and explanations given to us the Company has notraised any money out of initial public offer or further public offer (including debtinstruments). Term loans and short term borrowings through commercial paper raised by theCompany were applied for the purposes for which those are raised.

(x) According to the information and explanations given to us we have neither comeacross any instance of fraud on or by the Company noticed or reported during the year norhave we been informed of such case by the management during the course of our audit.

(xi) According to the information and explanations given to us the managerialremuneration paid by the Company is in accordance with provisions of Section 197 read withSchedule V to the Companies Act 2013. The Company has also taken requisite approvals asmandated by the provisions of section 197 in terms of managerial remuneration being paid.

(xii) According to the information and explanations given to us the Company is not aNidhi Company thus this para does not apply to it.

(xiii) According to the information and explanations given to us the Company hascomplied with requirements of section 177 of the Companies Act 2013 and Section 188 ofthe Companies Act 2013 in relation to the related parties. The Company has also disclosedthe requirements as laid down in the accounting standards in the relation to the relatedparties in the financial statements in the note No. 34 Related Party Information. (xiv)According to the information and explanations given to us the Company has not made anypreferential allotment or private placement of shares or convertible debentures during theyear under review.

(xv) According to the information and explanations given to us the Company has notentered into any non-cash transactions with the Directors or persons connected with itduring the year under review.

(xvi) According to the information and explanations given to us the Company is a NBFIalready registered under section 45 I-A of the Reserve Bank of India Act 1934.

Annexure ‘C' to the Independent Auditor's Report

Directions indicating the areas to be examined by the Statutory Auditors during thecourse of audit of annual accounts of PNB Gilts Limited for the year 2020-21 issued by theComptroller & Auditor General of India under Section

143 (5) of the Companies Act 2013.

Sr. No. Area Examined Observations/Findings
1. Whether the Company has 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 any may be stated. The Company has system of processing of accounting transactions partially through system with human intervention and partially by direct feeding manually. The implication of processing of accounting transactions outside IT system has no effect on the integrity of the accounts.
2. Whether there is any restructuring of an 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. There is no case of restructuring / waiver/ write off of debts / loans / interest reported by the management and / or observed during our audit of the year.
3. Whether funds received / receivable for specific schemes from Central / State agencies were properly accounted for / utilized as per its terms and condition? List the cases of deviations. There is no case of funds received / receivable for specific schemes from Central / State agencies reported by the management and / or observed during our audit of the year.
4. Whether the security controls for digital payment products and services are in compliance with the directions of RBI for Digital Payment Security Controls dated 18 February 2021? The company is not dealing in any Digital Payment Product / Services and as such directions of RBI for Digital Payment Security Controls dated 18 February 2021 are not applicable to the company.
5. RBI provided a window (vide circular dated 6 August 2020) under the prudential framework to implement a resolution plan to borrowers having stress on account of Covid 19 as per which existing loans can be restructured without downgrading the asset classification. Are there any cases of restructuring involving the new provision and if so are they in compliance with the RBI circular? The Company has granted loans to its employees only and there is no case of restructuring of such loans as reported by the Management and observed by us during our audit.

Non-Banking Financial Companies Auditor's Report for the Year Ended 31.03.2021

To

The Board of Directors PNB Gilts Limited

5Sansad Marg New Delhi-110001

In terms of Reserve Bank of India Master Direction-Non Banking Financial CompaniesAuditor's Report (Reserve Bank) Directions 2016 dated September 29 2016 we report that–The Company is engaged in the business of Non–Banking Financial Institution asPrimary Dealer (PD). The Company has received Registration Certificate No.14.00007 asprovided in Section 45-IA of the Reserve Bank of India Act 1934 (2 of 1934) from ReserveBank of India on February 10 1998. The Company is entitled to continue to holdCertificate of Registration in terms of its Principal Business criteria (financial

2021.

The Company is meeting the required net owned fund required in terms of MasterDirection-Non-Banking Financial Company-Systemically Important Non-Deposit Taking Companyand Deposit taking Company (Reserve bank) Directions 2016.

A resolution for non-acceptance of any public deposits was passed in the meeting of theBoard held on April 23 2020 and the Company has not accepted any public deposits duringthe year ended March 31 2021 The Company has complied with the prudential norms relatingto income recognition accounting standards assets classification and provisioning forbad and doubtful debts as applicable to it in terms of Master Direction Non-

Banking Financial Company-Systemically Important Non- Deposit Taking Company andDeposit taking Company (Reserve Bank) Directions 2016.

The Company has correctly arrived at the Capital Adequacy Ratio (CRAR) as disclosed inthe return submitted to Reserve Bank of India in Form NBS-7 and this ratio is incompliance with the minimum CRAR prescribed. The Company has furnished the annualstatement of Capital Fund Risk Assets/Exposure and Risk Asset Ratio (NBS-7) withinstipulated period to Reserve Bank of India.

For Rasool Singhal & Co
Chartered Accountants
(FRN: 500015N)
(CA Akshay Goel)
Date : June 22 2021 Partner
Place : New Delhi Membership No. 453555
UDIN: 21453555AAAAAY4040

.