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Raj Oil Mills Ltd.

BSE: 533093 Sector: Industrials
NSE: ROML ISIN Code: INE294G01026
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VOLUME 4982
52-Week high 150.85
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P/E 35.49
Mkt Cap.(Rs cr) 92
Buy Price 0.00
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OPEN 61.30
CLOSE 60.50
VOLUME 4982
52-Week high 150.85
52-Week low 55.45
P/E 35.49
Mkt Cap.(Rs cr) 92
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

Raj Oil Mills Ltd. (ROML) - Auditors Report

Company auditors report

TO THE MEMBERS AND BOARD OF DIRECTORS OF RAJ OIL MILLS LTD.

Opinion

We have audited the accompanying Ind AS Financial Statements of Raj OilMills Limited ("the Company")which comprise the Balance Sheet as at March312022 the Statement of Profit and Loss (including Other Comprehensive Income) theStatement of Changes in Equity and the Statement of Cash Flows for the year then endedand notes to the Financial Statements including a summary of the significant accountingpolicies and other explanatory information (hereinafter referred to as the 'Ind ASFinancial Statements')

In our opinion and to the best of our information and according to theexplanations given to us the aforesaid Ind AS Financial Statements give the informationrequired by the Companies Act 2013 ('the Act') in the manner so required and give a trueand fair view in conformity with the Indian Accounting Standards prescribed under Section133 of the Act read with the Companies (Indian Accounting Standards) Rules 2015 asamended (Ind AS) and other accounting principles generally accepted in India of thestate of affairs of the Company as at March 31 2022 and its profit total comprehensiveincome its cash flows and the changes in equity for the year 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 (SAs). Our responsibilities under those SAsare further described in the 'Auditors' Responsibilities for the Audit of the Ind ASFinancial Statements section of our report. We are independent of the Company inaccordance with the Code of Ethics issued by the Institute of Chartered Accountants ofIndia (ICAI) together with the ethical requirements that are relevant to our audit of theInd AS Financial Statements under the provisions of the Act and the Rules thereunder andwe have fulfilled our other ethical responsibilities in accordance with these requirementsand ICAIs Code of Ethics. We believe that the audit evidence we have obtained issufficient and appropriate to provide a basis for our opinion.

Emphasis of Matter

We draw your attention to Note no. 20 & 21 of the Ind AS financialstatements in relation to payments required to be made to the unsecured operationalcreditors & public fixed deposits in accordance with the Resolution plan approved bythe Hon'ble NCLT vide its order dated April 19 2018. Unsecured operational creditors& public fixed deposits as on March 31 2022 include certain non-traceable partieswhose payments cannot be made. As per the information and explanation given to us by theManagement the payments made to the said parties have been reversed during the financialyear on account of cheques returned and nontraceability.

The Company has an outstanding amount payable of Rs. 8101184 as onMarch 31 2022 pertaining to the aforementioned unsecured operational creditors &public fixed deposits.

Sr. No. Particulars Amount payable as per Approved Resolution Plan Amount paid till date Amount outstanding as on March 312022
1 Unsecured Operational Creditors 12200000 10837659 1362341
2 Public Fixed Deposits 53600000 46861157 6738843

As per the information and explanation given to us the Company is inthe process of filling an application to the Hon'ble NCLT seeking directions for paymentsrequired to be made in relation to the outstanding amount standing in respect of such nontraceable unsecured operational creditors & public fixed deposits in the books ofaccounts as on March 31 2022. Our opinion is not qualified with respect to the saidabove.

Key Audit Matters

Key audit matters are those matters that in our professional judgmentwere of most significant in our audit of the Ind AS Financial Statements of the currentperiod. These matters were addressed in the context of our audit of the Ind AS FinancialStatements as a whole and in forming our opinion thereon and we do not provide aseparate opinion on these matters.

1) Adherence to the Approved Resolution Plan passed by Hon'be NCLT

See Note 2A to the IndAS financial statements

Key Audit Matter How the matter was addressed in our Audit
The Hon'ble National Company Law Tribunal Mumbai Bench vide its order dated April 19 2018 had approved the Resolution Plan submitted by its promoters. The Ind AS financial statements for the year ended March 31 2022 have been prepared on a going-concern basis taking into consideration the settlement payments crystallised under the 'Debt Restructuring Scheme' prescribed under the Approved Resolution Plan. • Assessing and compiling all the information in relation to the payments made and required to be made in pursuance to the NCLT order about each line items included in relevant notes together with information disclosed in the Financial Statements.
During the year the Company has affected various payments in pursuance to the aforementioned High Court Order. With respect to the repayment pertaining Public Deposits the Company has taken relevant steps for repayment of the Public Deposits and unsecured operational creditors as per the Resolution Plan (amount outstanding as on March 31 2022 - INR 81.01 lakhs) however the Company is still in process to repay the full amount of such public deposits and unsecured operational creditors liable to paid in pursuance to the sanctioned Scheme of NCLT. • Evaluating the process of payment mechanism and control mechanism followed by the Company's management in relation to all the payments affected stated as per the NCLT Order.
• Applying procedures to verify the reconciliations put in place to document the accruals and payments.
• On a sample basis verifying payments from the underlying bank statements to identify the settlement payments to the parties made in accordance with the Resolution Plan.

2) Revenue recognition

See Note 24 to the IndAS financial statements

Key Audit Matter How the matter was addressed in our Audit
As disclosed in Note to the Ind AS financial statements revenue is measured net of any discounts / rebates and incentive schemes / price reductions/ rate differences to the distributors ("discounts and rebates"). Discounts given include rebates price reductions and other incentives given to customers. Accumulated experience is used to estimate and provide for the discounts and returns. The volume discounts are assessed based on anticipated annual purchases. Certain discounts and rebates for goods sold during the year are only finalised when the precise amounts are known. The Company recognises provision for sales return based on the historical results measured on net basis of the margin of the sale Our audit procedures included but were not limited to the following:
• Evaluated the appropriateness of the Company's accounting policy for revenue recognition and understanding the process followed by the Company to determine the amount of discounts incentives and rebates.
• Evaluating the design and implementation and testing operating effectiveness of Company's general IT controls key manual and application control over the company's IT systems including controls over discounts scheme related payments and offers provided along-with rebate payments / settlements and company's review over the rebate accruals.
• Performing substantive testing by selecting samples of discounts and rebates transactions recorded during the year as well as period end discounts and rebates accruals and matching the parameters used in the computation with the relevant source documents.
• Tested the mathematical accuracy of the underlying calculations
• Checking completeness and accuracy of the data used by the company for accrual of discounts rebates incentives schemes provided.

• Testing a selection of discounts given schemes recorded afterMarch 312022 and assessing whether the same is recorded in the correct period.

• Testing a selection of payments made after March 31 2022 andwhere relevant comparing the payment to the related scheme or discounts.

• Critically assessing journal entries posted to revenue on asample basis to identify unusual items and examining the underlying documentation.

Information other than the Financial Statements and Auditor's Reportthereon

The Board of Directors of the Companyare responsible for the otherinformation. The other information comprises the information included in the Company'sannual report but does not include the financial statements and our auditors' reportthereon.

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

In connection with our audit of the financial statements ourresponsibility is to read the other information and in doing so consider whether theother information is materially inconsistent with the financial statements or ourknowledge obtained in the audit or otherwise appears to be materially misstated.If basedon the work we have performed we conclude that there is a material misstatement of thisother information we are required to report that fact. We have nothing to report in thisregard.

Management's responsibility for the Ind AS Financial Statements

The Board of Directors of the Company are responsible for the mattersstated in section 134(5) of the Act with respect to the preparation of these IndASfinancial statements that give a true and fair view of the State of Affairs (financialposition) Profit or Loss (financial performance including Other Comprehensive Income)Changes in Equity and Cash Flows of the Company in accordance with the Ind AS and otheraccounting principles generally accepted in India. This responsibility also includesmaintenance of adequate accounting records in accordance with the provisions of the Actfor safeguarding of the assets of the company and for preventing and detecting frauds andother irregularities; selection and application of appropriate implementation andmaintenance of accounting policies; making judgments and estimates that are reasonable andprudent and design implementation and maintenance of adequate internal financialcontrols that were operating effectively for ensuring the accuracy and completeness of theaccounting records relevant to the preparation and presentation of the Ind AS FinancialStatements that give a true and fair view and are free from material misstatement whetherdue to fraud or error.

In preparing the Ind AS Financial Statements the Management and Boardof Directors are responsible for assessing the ability of the Companyto continue as agoing concern disclosing as applicable matters related to going concern and using thegoing concern basis of accounting unless the Management and Board of Directors eitherintend to liquidate the Company or to cease operations or has no realistic alternativebut to do so.

The Board of Directors are also responsible for overseeing financialreporting process of the Company.

Auditor's Responsibilities for the Audit of Ind ASFinancial Statements

Our objectives are to obtain reasonable assurance about whether the IndAS Financial Statements as a whole are free from material misstatement whether due tofraud or error and to issue an auditors' 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 scepticism throughout the audit. We also:

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

b) Obtain an understanding of internal control relevant to the audit inorder to design audit procedures that are appropriate in the circumstances. Under Section143(3)(i) of the Act we are also responsible for expressing our opinion on whether theCompany has adequate internal financial controls with reference to financial statements inplace and the operating effectiveness of such controls

c) Evaluate the appropriateness of accounting policies used and thereasonableness of accounting estimates and related disclosures made by management andBoard of Directors in the financial statements.

d) Conclude on the appropriateness of management's use of the goingconcern basis of accounting and based on the audit evidence obtained whether a materialuncertainty exists related to events or conditions that may cast significant doubt on theCompany's ability to continue as a going concern. If we conclude that a materialuncertainty exists we are required to draw attention in our auditor's report to therelated disclosures in the Ind AS 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 conditions maycause the Company to cease to continue as a going concern.

e) Evaluate the overall presentation structure and content of the IndAS Financial Statements including the disclosures and whether the Ind AS FinancialStatements represent the underlying transactions and events in a manner that achieves fairpresentation.

f) Obtain sufficient appropriate audit evidence regarding the financialinformation of the Company to express an opinion on the Ind AS Financial Statements.

Materiality is the magnitude of misstatements in the financialstatements that individually or in aggregate makes it probable that the economicdecisions of a reasonably knowledgeable user of the financial statements may beinfluenced. We consider quantitative materiality and qualitative factors in i) planningthe scope of our audit work and in evaluating the results of our work and ii) to evaluatethe effect of any identified misstatements in the financial statements.

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 financialstatementsof the current period and are therefore the key audit matters. We describe thesematters in

our auditors' 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 required by the Companies (Auditor's Report) Order 2016 ('theOrder') issued by the Central Government of India in terms of Section 143 (11) of theAct we give in the "Annexure A" a statement on the matters specified inparagraphs 3 and 4 of the Order to the extent applicable

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

(a) We have sought and obtained all the information and explanationswhich to the best of our knowledge and belief were necessary for the purposes of ouraudit;

(b) In our opinion proper books of account as required by law havebeen kept by the Company so far as it appears from our examination of those books.

(c) The Balance Sheet the Statement of Profit and Loss including OtherComprehensive Income the Statement of Cash Flows Statement and Changes in Equity dealtwith by this report are in agreement with the books of account.

(d) In our opinion the aforesaid financial statements comply with theInd AS specified under Section 133 of the Act read with Rule 7 of the Companies(Accounts) Rules 2014;

(e) On the basis of the written representations received from thedirectors as on March 31 2022 taken on record by the Board of Directors none of thedirectors aredisqualified as on March 31 2022 from being appointed as a Director in termsof Section 164 (2) of the Act.

(f) With respect to the adequacy of the internal financial controlsover financial reporting of the Company and the operating effectiveness of such controlsrefer to our separate Report in "Annexure B". Our report expresses an unmodifiedopinion on the adequacy and operating effectiveness of the internal financial controlsover financial reporting of the Company.

(g) With respect to the other matters to be included in the Auditor'sReport in accordance with Rule 11 of the Companies (Audit and Auditors) Rules 2014 asamended in our opinion and to the best of our information and according to theexplanations given to us:

(i) The Company has disclosed the impact of pending litigations as atMarch 31 2022 on its financial position in its Ind AS Financial Statements.

(ii) The Company did not have any long-term contracts includingderivative contracts for which there were any material foreseeable losses.

(iii) There were no amounts which were required to be transferred tothe Investor Education and Protection Fund by the Company.

(iv) a) The Company has represented that no funds have been advanced orloaned or invested (either from borrowed

funds or share premium or any other sources or kind of funds) by thecompany to or in any other persons or entities including foreign entities("Intermediaries") with the understanding whether recorded in writing orotherwise that the Intermediary shall whether directly or indirectly lend or invest inother persons or entities identified in any manner whatsoever by or on behalf of theCompany ("Ultimate Beneficiaries") or provide any guarantee security or thelike on behalf of the Ultimate Beneficiaries other than those disclosed in the notes toaccounts.

The Company has represented that no funds have been received by thecompany from any persons or entities including foreign entities ("FundingParties") with the understanding whether recorded in writing or otherwise that theCompany shall whether directly or indirectly lend or invest in other persons orentities identified in any manner whatsoever by or on behalf of the Funding Party("Ultimate Beneficiaries") or provide any guarantee security or the like onbehalf of the Ultimate Beneficiaries other than those disclosed in the notes to accounts.

Based on audit procedures considered reasonable and appropriate in thecircumstances nothing has come to our notice that has caused us to believe that therepresentations under sub-clause (a) and (b) above contain any material misstatement.

For Kailash Chand Jain & Co.

Chartered Accountants

Firm Registration No.: 112318W

Saurabh Chouhan Partner

Membership No.: 167453

Place: Mumbai

Date: May 20 2022

UDIN: : 22167453AJIKIL5777

"ANNEXURE A" TO THE INDEPENDENT AUDITOR'S REPORT TO THEMEMBERS OF THE COMPANY ON THE IND AS FINANCIAL STATEMENTS FOR THE YEAR ENDED MARCH 312022 WE REPORT THAT:

(i) a) 1) The Company has maintained proper records showing fullparticulars including quantitative details and situation

of its Property Plant and Equipment.

a) 2) The Company has maintained proper records showing fullparticulars of intangible asset.

b) According to the information and explanation given to us and on thebasis of our examination of the records of the Company the Company has program ofverification to cover all the items in a phased manner which in our opinion is reasonablehaving regard to the size of the Company and the nature of its assets. Pursuant to theprogram certain fixed assets have been physically verified by the Management during theyear. According to the information and explanations given to us no material discrepancieswere noticed on such verification.

c) According to the information and explanation given to us and on thebasis of our examination of the records of the Company the title deeds of Immovableproperties disclosed in the financial statements are held in the name of the Company.

d) According to the information and explanation given to us and on thebasis of our examination of the records of the Company the Company has not revalued itsProperty Plant & Equipment orintangible assets or both during the year.

e) According to information provided by the management no proceedingshave been initiated or are pending against the company for holding any benami propertyunder the Benami Transactions (Prohibition) Act 1988 and rules made thereunder.

(ii) a) According to the information and explanations provided by themanagement physical verification of inventory has been conducted at reasonable intervalsby the management and no material discrepancies were noticed on such verification which inour opinion is reasonable having regards to size of the Company and nature of its assets.

b) The company hasnot been sanctioned any working capital limits frombanks or financial institutions. Therefore this clause is not applicable to the company.

(iii) (a) (b) (c) According to the information and explanations givento us and on the basis of our examination of the records of the Company the Company hasnot provided any guarantee or security or granted any advances in the nature of loanssecured or unsecured to companies firms limited liability partnership or any otherparties during the year. Further the Company has not made any investments in or grantedany loans secured or unsecured to companies firms and limited liability partnershiporother parties listed in the register maintained under Section 189 of the Companies Act2013. Accordingly the provisions of clauses iii (a) (b) and (c)of the order are notapplicable to the Company.

d) According to the information and explanations given to us and on thebasis of our examination of the records of the Company there is no overdue amount formore than ninety days in respect of secured and unsecured loans given. Further theCompany has not given any advances in the nature of loans to any party during the year.

e) According to the information and explanations given to us and on thebasis of our examination of the records of the Company there is no loan granted fallingdue during the year which has been renewed or extended or fresh loans granted to settlethe over-dues of existing loans given to same parties. Further the Company has not givenany advances in the nature of loans to any party.

f) According to the information and explanations given to us and on thebasis of our examination of the records of the Company the Company has not granted anyloans or advances in the nature of loans either repayable on demand or without specifyingany terms or period of repayment.

(iv) According to the information and explanations given to us and onthe basis of our examination of records of the Company the Company has not made anyinvestments granted loans or provided any guarantee or security as specified underSections 185 and 186 of the Act. Accordingly clause (iv) of the Order is not applicableto the Company.

(v) In our opinion and according to the information and explanationgiven to us the Hon'ble NCLT vide its order dated April 19 2018 directed to company torepay the public fixed deposit amounting to INR 5.36 Crores in quarterly instalments inaccordance with the approved Resolution Plan. In our opinion the company is repaying thedeposits in accordance with the approved Resolution Plan.Further the Company during theyear has not accepted any deposits from the public within the meaning of Sections 73 to 76of the Act and the Companies (Acceptance of Deposits) Rules 2014 (As amended).

(vi) The Central Government has specified maintenance of cost recordsunder sub-section (1) of Section 148 of the Act in respect of the products of the Company.We have broadly reviewed the books of accounts and records maintained by the Companyandare of the opinion that prima facie the prescribed accounts and records have been madeand maintained. However we have not made a detailed examination of the cost records witha view to determine whether they are accurate or complete.

(vii) a) According to the information and explanations given to us andon the basis of our examination of the records of the

Company amounts deducted / accrued in the books of account in respectof undisputed statutory dues including Goods and Services Tax Provident fund Employees'State Insurance Income-Tax Duty of Customs Cess and other statutory dues have beenregularly deposited by the Company with the appropriate authorities by the Company thoughthere have been slight delays in a few cases.

According to the information and explanations given to us noundisputed amounts payable in respect of Goods and Services Tax Provident fundEmployees' State Insurance Income-Tax Duty of Customs Cess and other statutory dueswere in arrears as at March 31 2022 for a period of more than six months from the datethey became payable.

b) According to the information and explanations given to us there areno dues of relating to Goods and Service Tax Provident fund Employees' State InsuranceIncome-Tax Duty of Customs Cess and other statutory dueson account of any dispute whichhave not been deposited except for the ones mentioned below:

No Name of the Statue Nature of dues Amount (INR) Period to which the amount relates Forum where the dispute is pending
1 The Income Tax Act 1961 Income Tax 833284 F.Y 04-05 Honorable Supreme Court
2 The Income Tax Act 1961 Income Tax 27280862 FY 05-06 Honorable Supreme Court
3 The Income Tax Act 1961 Income Tax 166551585 FY 06-07 Honorable Supreme Court
4 The Income Tax Act 1961 Income Tax 1184327727 FY 07-08 Honorable Supreme Court
5 The Income Tax Act 1961 Income Tax 671334189 FY 08-09 Honorable Supreme Court
6 The Income Tax Act 1961 Income Tax 1199548263 FY 09-10 Honorable Supreme Court
7 The Income Tax Act 1961 Income Tax 136496264 F.Y 10-11 Honorable Supreme Court
8 The Income Tax Act 1961 Income Tax 844490 FY 17-18 Section 143 (1) (a)
9 The Income Tax Act 1961 Income Tax 418870 F.Y 18-19 Section 143 (1) (a)
10 The Income Tax Act 1961 Income Tax 394552 F.Y 19-20 Section 143 (1) (a)
11 The Central Sales Tax Act 1956 VAT & CST 27032118 F.Y. 05-06 Honorable Supreme Court
12 The Central Sales Tax Act 1956 VAT & CST 82892311 F.Y. 06-07 Honorable Supreme Court
13 The Central Sales Tax Act 1956 VAT & CST 118974376 F.Y. 07-08 Honorable Supreme Court
14 The Central Sales Tax Act 1956 VAT & CST 71484990 F.Y. 08-09 Honorable Supreme Court
15 The Central Sales Tax Act 1956 VAT & CST 158498784 F.Y. 09-10 Honorable Supreme Court
16 The Central Sales Tax Act 1956 VAT & CST 104765921 F.Y 10-11 Honorable Supreme Court
17 The Central Sales Tax Act 1956 VAT & CST 322639829 F.Y 11-12 Honorable Supreme Court
18 The Central Sales Tax Act 1956 VAT & CST 119317964 F.Y. 12-13 Honorable Supreme Court
19 The Central Sales Tax Act 1956 VAT & CST 55795871 F.Y. 13-14 Honorable Supreme Court
20 The Central Sales Tax Act 1956 VAT & CST 40239418 F.Y. 14-15 Honorable Supreme Court
21 The Central Sales Tax Act 1956 VAT & CST 1200196 F.Y. 15-16 Honorable Supreme Court
22 The Central Sales Tax Act 1956 VAT & CST 39957773 F.Y. 16-17 Honorable Supreme Court
23 The Central Sales Tax Act 1956 VAT & CST 14951580 F.Y. 17-18 Honorable Supreme Court
24 SEBI SEBI 500000 Honorable Supreme Court

(viii) According to the information and explanations given to us notransactions were surrendered or disclosed as income during the year in the taxassessments under the Income Tax Act 1961 (43 of 1961) which have not been recorded inthe books of account.

(ix) a) In our opinion and according to the information andexplanations given to us by the Management and on the basis of

examination of the records of the Company the Company has notdefaulted in repayment of loans and borrowing or in the payment of interest thereon tobanks or financial institution during the year. Further the Company does not have anyoutstanding loans or borrowings from any other lender during the year. Accordingly clause3(ix)(a) of the Order is not applicable to the Company

b) According to the information and explanations given to us by theManagement and on the basis of our audit procedures the Company has not been declared asa wilful defaulter by any bank or financial institution or government or governmentalauthority.

c) According to the information and explanations given to us and on thebasis of our examination of the records of the Company the Company has not taken any termloans from any lender. Accordingly clause 3(ix)(c) of the Order is not applicable to theCompany.

d) According to the information and explanations given to us and on anoverall examination of the balance sheet of the Company we report that no funds raised onshort-term basis have been used for long-term purposes by the Company.

e) According to the information and explanations given to us and on anoverall examination of the financial statements of the Company we report that the Companyhas not taken any funds from any entity or person on account of or to meet the obligationsof its subsidiaries or associates as defined under the Act. The Company does not hold anyinvestment in any joint venture (as defined under the Act) during the year ended March 312022.

f) According to the information and explanations given to us andprocedures performed by us we report that the Company has not raised loans during theyear on the pledge of securities held in its subsidiaries or associate companies (asdefined under the Act).

(x) a) The company has not raised moneys by way of initial public offeror further public offer (including debt instruments). Accordingly clause 3(x)(a) of theOrder is not applicable to the Company.

b) According to the information and explanations given to us and on thebasis of our examination of the records of the Company the Company has not made anypreferential allotment or private placement of shares or fully or partly convertibledebentures during the year. Accordingly clause 3(x)(b) of the Order is not applicable tothe Company

(xi) a) Based on examination of the books and records of the Companyand according to the information and explanations given to us considering the principlesof materiality as outlined in the Standards on Auditing we report that no fraud by theCompany or on the Company has been noticed or reported during the course of the audit.

b) According to information and explanations given to us no reportunder sub-section (12) of section 143 of the Companies Act 2013 has been filed bytheauditors of the company in Form ADT-4 with the Central Government as prescribed underRule the Companies (Audit and Auditors) Rules 2014.

c) As represented to us by the Management there are no whistle-blowercomplaints received by the Company during the year.

(xii) According to the information and explanations given to us theCompany is not a Nidhi Company. Accordingly clause 3(xii) of the Order is not applicableto the Company

(xiii) In our opinion and according to the explanations and informationgiven to us all the transactionswith the related parties at the Companyare in compliancewith Section 177 and 188 of the Act and the details of the related parties have beendisclosed in the financial statements as required by the applicable Indian AccountingStandards.

(xiv) a) Based on information and explanations provided to us and ouraudit procedures in our opinion the Company has an internal audit system commensuratewith the size and nature of its business.

b) We have considered the internal audit reports of the Company issuedtill date for the period under audit.

(xv) According to the information and explanation given to us theCompany has not entered into any non-cash transaction with directors or persons connectedwith the directors and hence provisions of Section 192 of the Companies Act 2013 are notapplicable to the Company.

(xvi) a) The Company is not required to be registered under section45-IA of the Reserve Bank of India Act 1934. Accordingly clause 3(xvi)(a) and clause3(xvi)(b)of the Order is not applicable to the Company.

b) The Company is not a Core Investment Company (CIC) as defined in theregulations made by the Reserve Bank of India. Accordingly clause 3(xvi)(c) and clause3(xvi)(d)of the Order is not applicable to the Company

(xvii) According to the explanations and information given to us theCompany has not incurred any cash losses in the financial year and in the immediatelypreceding financial year.

(xviii) There has been no instance of any resignation of the statutoryauditors occurred during the year.Accordingly clause 3(xviii) of the Order is notapplicable to the Company.

(xix) According to the information and explanations given to us and onthe basis of the financial ratios ageing and expected dates of realisation of financialassets and payment of financial liabilities other information accompanying the standalonefinancial statements our knowledge of the plans of the Board of Directors and managementand based on our examination of the evidence supporting the assumptions nothing has cometo our attention which causes us to believe that any material uncertainty exists as onthe date of the audit report that Company is not capable of meeting its liabilitiesexisting at the date of balance sheet as and when they fall due within a period of oneyear from the balance sheet date. We however state that this is not an assurance as tothe future viability of the Company. We further state that our reporting is based on thefacts up to the date of the audit report and we neither give any guarantee nor anyassurance that all liabilities falling due within a period of one year from the balancesheet date will get discharged by the Company as and when they fall due.

(xx) According to the information and explanationsgiven to us there isno unspent amount of CSR to be transferred to Fund specified in Schedule VII to theCompanies Act within a period of six months of the expiry of the financial year incompliance with second proviso to sub-section (5) of section 135 of the Act. Accordinglyclause (xx) is not applicable to the Company.

(xxi) According to the explanations information given to us thecompany does not prepare consolidated financials since it does not have any subsidiaryassociate or joint venture. Accordingly clause (xxi) is not applicable to the Company.

For Kailash Chand Jain & Co.

Chartered Accountants

Firm Registration No.: 112318W

Saurabh Chouhan

Partner

Membership No.: 167453

Place: Mumbai.

Date: May 20 2022

UDIN: 22167453AJIKIL5777

ANNEXURE "A" TO THE INDEPENDENT AUDITOR'S REPORT - MARCH312022

Referred to in Paragraph 1(g) under Report on Other Legal andRegulatory Requirement's section of our report to the Members of Raj Oils Mills Limited ofeven date

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 Raj Oil Mills Limited ("the Company") as of March 31 2022 inconjunction with our audit of the standalone financial statements of the Company for theyear ended on that date.

Management's Responsibility for Internal Financial Controls

The Board of Director of the Company is responsible for establishingand maintaining 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 ('Guidance Note') issued by the Institute of Chartered Accountants ofIndia ("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 of fraudsand errors the accuracy and completeness of the accounting records and the timelypreparation of reliable financial information as required under the Companies Act 2013.

Auditors' Responsibility

Our responsibility is to express an opinion on the Company's internalfinancial controls over financial reporting based on our audit. We conducted our audit inaccordance with the Guidance Note issued by ICAI and the Standards on Auditing prescribedunder section 143 (10) of the Companies Act 2013 to the extent applicable to an audit ofinternal financial controls both applicable to an audit of Internal Financial Controlsboth issued by the Institute of Chartered Accountants of India. Those Standards and theGuidance Note require that we comply with ethical requirements and plan and perform theaudit to obtain reasonable assurance about whether adequate internal financial controlsover financial reporting was established and maintained and if such controls operatedeffectively in all material respects except which stated in Audit Report.

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 the risksof material misstatement of the financial statements whether due to fraud or error.

We believe that the audit evidence we have obtained is sufficient andappropriate except which stated in Audit Report to provide a basis for our audit opinionon the company's internal financial controls system over financial reporting.

Meaning of Internal Financial Controls Over Financial Reporting

A 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 control overfinancial reporting includes those policies and procedures that (1) pertain to themaintenance of records that in reasonable detail accurately and fairly reflect thetransactions and dispositions of the assets of the company; (2) provide reasonableassurance that transactions are recorded as necessary to permit preparation of financialstatements in accordance with generally accepted accounting principles and that receiptsand expenditures of the company are being made only in accordance with authorizations ofmanagement and directors of the company; and (3) provide reasonable assurance regardingprevention or timely detection of unauthorized acquisition use or disposition of thecompany's assets that could have a 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 and to the best of our information and according to theexplanations given to us the Company has in all material respects an adequate internalfinancial controls system over financial reporting and such internal financial controlsover financial reporting were operating effectively as at March 312022 based on theinternal control over financial reporting criteria established by the Company consideringthe essential components of internal control stated in the Guidance Note on Audit ofinternal Financial Controls over Financial Reporting issued by the ICAI.

For Kailash Chand Jain & Co.

Chartered Accountants Firm Registration No.: 112318W

Saurabh Chouhan

Partner Membership No.: 167453

Place: Mumbai

Date: May 20 2022

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