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Raj Oil Mills Ltd.

BSE: 533093 Sector: Industrials
NSE: RAJOIL ISIN Code: INE294G01018
BSE 00:00 | 27 Jun Raj Oil Mills Ltd
NSE 05:30 | 01 Jan Raj Oil Mills Ltd
OPEN 2.05
PREVIOUS CLOSE 1.88
VOLUME 271454
52-Week high 2.05
52-Week low 0.00
P/E
Mkt Cap.(Rs cr) 3
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00
OPEN 2.05
CLOSE 1.88
VOLUME 271454
52-Week high 2.05
52-Week low 0.00
P/E
Mkt Cap.(Rs cr) 3
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

Raj Oil Mills Ltd. (RAJOIL) - Auditors Report

Company auditors report

TO THE MEMBERS OF RAJ OIL MILLS LIMITED

REPORT ON STANDALONE FINANCIAL STATEMENTS

Opinion

We have audited the accompanying Standalone financial statements of M/s. Raj OilMills Limited ("the Company") which comprises the Balance Sheet as at March31 2019 the Statement of Profit and Loss statement of Changes in Equity and Statementof Cash Flows for the year ended on that date and notes to the financial statementsincluding a summary of significant accounting policies and other explanatory information(herein after referred to as "standalone Ind AS financial statements").

Basis of Qualified Opinion

We conducted our audit of the standalone Ind AS financial statements in accordance withthe Standards on Auditing (SA's) specified under Section 143(10) of the Companies Act(‘the Act'). Our responsibilities under those Standards are further described in theAuditor's responsibility for the Audit of the standalone Financial Statements section ofour report. We are independent of the Company in accordance with the Code of Ethics issuedby the Institute of Chartered Accountants of India (ICAI) together with the independencerequirements that are relevant to the audit of the standalone financial statements underthe provisions of the Act and the Rules made thereunder and we have fulfilled our otherethical responsibilities in accordance with these requirements and the ICAI's Code ofEthics. We believe that the audit evidence we have obtained is sufficient and appropriateto provide a basis for our audit opinion on the standalone financial statements except forthe matters stated hereunder:

1) A petition has been filed against Dipti Veg Oil Limited for recovery of INR 1.75crorebefore National Company Law Tribunal Mumbai Bench and the same is disclosed under‘Trade Receivables' in the books of accounts of the Company. In this regard noprovision has been made in the books of accounts of the Company.

2) As per section 148 of the Companies Act 2013 read with Rule 3 (B)-20 -"Non-Regulated Sector –Edible Oil" and Rule 5 – of Companies (CostRecords and Audit) Rules 2014 the company is required to maintain the cost record forthe manufacturing process. However the Company is in the process of maintaining recordsof cost of materials consumed on actual consumption basis. Further as per Rule 6 ofCompanies (Cost Records and Audit) Rules 2014 no cost audit has been carried out by thecompany during the year under audit.

3) We planned our audit so as to obtain all the information and explanations which weconsidered necessary in order to provide us with sufficient evidence to give reasonableassurance that the financial statements are free from material misstatement except for theimpact on the aforementioned qualifications in the Ind AS Financial Statement of theCompany.

Qualified opinion

In our opinion and to the best of our information and according to the explanationsgiven to us except for the matter described in the Basis of Qualified Opinion paragraphabove the aforesaid standalone Ind AS financial statements give the information requiredby the Act in the manner so required and give a true and fair view in conformity with theIndian Accounting Standards prescribed under section 133 of the Act read with theCompanies (Indian Accounting Standards) Rules 2015 as amended accounting principlesgenerally accepted in India of the state of affairs of the Company as at March 31 2019and loss(including other comprehensive income)changes in equityand its cash flows for theyear ended on that date.

Key Audit Matters

Key audit matters are those matters that in our professional judgement were of mostsignificant in our audit of standalone financial statements of the current period. Thesematters were addressed in the context of our audit of the standalone financial statementsas a whole and in forming our opinion thereon and we do not provide a separate opinionon these matters. We have determined the matters described below to be the key auditmatters to be communicated in our report.

No Key Audit Matters

1 Implementation of Approved Resolution Plan passed by the Hon'ble NCLT

The Hon'ble NCLT Mumbai Bench vide its order dated April 19 2018 had approved theResolution Plan submitted by the New Promoters i.e. Rubberwala Housing and InfrastructureLimited and Mukhi Industries Limited in- charge and taken over the Management from May 042018. The Ind AS financial statements have been prepared considering the settlementpayments stated under the Approved Resolution Plan.

Auditors Response:

As at March 31 2019 the effect of adjustments taking into account the settlementpayments to the secured and unsecured financial liabilities loans amounting to INR81.00 crores and INR 71.19 crores by way of reduction in Equity ShareCapital and the same has been recognised under ‘Other Equity'. Further the impact ofadjustments on account of settlement payments to operational creditors/trade payablesworkmen dues statutory liabilitieshave been recognised under ‘Statement of Profitand Loss' amounting to INR 28.57 crores(net) Refer Note 2A of the standalone Ind ASfinancial statement for the financial impact of the said NCLT order.

2 Recoverability of uncertain trade receivables and Long-Term Loans

The Company has trade receivables (considered doubtful and more than 3 years) amountingto INR 8.83 crores and receivables by way of loan amounting to INR 52.45 crorestotal aggregating to INR 61.28 crores.

Auditors Response:

As at March 31 2019the Company has made a provision in the books of accounts basisthe information available considering the nature of the amounts recoverablesustainability and the likelihood of the recovery from the such receivables.

Information other than the Standalone Financial Statements and Auditor's Report Thereon

The Company's Board of Directors is responsible for the other information. The otherinformation comprises the information included in the Annual Report but does not includethe standalone financial statements and our auditor's report thereon. Our opinion on thefinancial statements does not cover the other information and we will not express any formof assurance conclusion thereon.

In connection with our audit of the financial statements our responsibility is to readthe other information identified above and in doing so consider whether the otherinformation is materially inconsistent with the financial statements or our knowledgeobtained in the audit or otherwise appears to be materially misstated.

When we read the report ifwe conclude that there is a material misstatement thereinwe are required to communicate the matter to those charged with governance.

Responsibilities of Management and Those Charged with Governance for the FinancialStatements

The Company's Board of Directors is responsible for the matters stated in Section 134(5) of the Companies Act 2013 with respect to the preparation of these standalone Ind ASfinancial statements that give a true and fair view of the state of affairs profit/lossand other total comprehensive income changes in equity and cash flows of the Company inaccordance with the accounting principles generally accepted in India including theIndian Accounting Standards ("Ind AS") prescribed under Section 133 of the Act.

This responsibility also includes maintenance of adequate accounting records inaccordance with the provisions of the Act for safeguarding the assets of the Company andfor preventing and detecting frauds and other irregularities; selection and application ofappropriate 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 standalone Ind ASfinancial 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.

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

• Obtain an understanding of internal control relevant to the audit in order todesign audit procedures that are appropriate in the circumstances. Under section 143(3)(i)of the Companies Act 2013 we are also responsible for expressing our opinion on whetherthe company has adequate internal financial controls system in place and the operatingeffectiveness of such controls.

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

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

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

Materiality is the magnitude of misstatements in the standalone financial statementsthat individually or in aggregate makes it probable that the economic decisions of areasonably knowledgeable user of the financial statements may be influenced. We considerquantitative materiality and qualitative factors in (i) planning the scope of our auditwork and in evaluating the results of our work; and (ii) to evaluate the effect of anyidentified misstatements in the financial statements. We communicate with those chargedwith governance regarding among other matters the planned scope and timing of the auditand significant audit findings including any significant deficiencies in internal controlthat 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 significance in 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 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 Companies Act 2013 we give in "Annexure A" a statement on thematters specified in paragraphs 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 except for the possible effect of the matter described in theBasis of Qualified Opinion paragraph above obtained all the information and explanationswhich to the best of our knowledge and belief were necessary for the purposes of ouraudit.

b) Except for the possible effect of the matter described in the Basis of QualifiedOpinion paragraph above 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 other comprehensiveincome) the Statement of Changes in Equity and the Statement of Cash Flows dealt with bythis Report are in agreement with the books of accounts.

d) Except for the possible effect of the matter described in the Basis of QualifiedOpinion paragraph above in our opinion the aforesaid standalone Ind AS financialstatements comply with the Indian Accounting Standards prescribed under Section 133 of theAct read with Rule 7 of the Companies (Accounts) Rules 2014.

e) The matters described in the ‘Basis of Qualified Opinion' paragraphs above inour opinion may have an adverse effect on the functioning of the Company;

f) The erstwhile Board of Directors has been suspended as on the balance sheet date31st March 2019 as regard to Section 17(1) (b) of "The Insolvency and BankruptcyCode 2016". The Hon'ble NCLT vide its order dated April 19 2018 appointed Mr SufyanAbdul Razak Maknojia as the Managing Director of the Company authorising him toreconstitute the Board of Directors.On the basis of the written representations receivedfrom the Management as on 31st March 2019 taken on record by the reconstituted Board ofDirectors none of the directors is disqualified as on 31st March 2019 from beingappointed as a director in terms of Section 164 (2) of the Act.

g) With respect to the adequacy of the internal financial controls with reference tofinancial statements of the Company and the operating effectiveness of such controlsrefer to our separate report in "Annexure B". h) With respect to theother matters to be included in the Auditor's Report in accordance with Rule 11 of theCompanies (Audit and Auditors) Rules 2014 in our opinion and to the best of ourinformation and according to the explanations given to us:

1. The Company has disclosed the impact of pending litigations on its financialposition in its standalone Ind AS financial statements.

2. The Company does not have any long-term contracts including derivatives contractsfor which there were any material foreseeable losses; and

3. There are no amounts required to be transferred to the Investor Education andProtection Fund by the Company.

For Kailash Chand Jain & Co.

Chartered Accountants

Firm Registration No.: 112318W

Saurabh Chouhan

Partner

Membership No.: 167453

Place: Mumbai

Date: May 24 2019

Annexure - A to the Independent Auditors' Report to the members of the company on thefinancial statements for the year ended March 31 2019.

Referred to in Paragraph 1 under ‘Report on other legal and regulatoryrequirements' Section of our report of even date.

(i) (a) The Company has maintained records showing full particular includingquantitative detail and situation of Fixed Assets.

(b) The Company has program of verification to cover all the items in a phased mannerwhich in our opinion is reasonable having regard to the size of the Company and thenature of its assets. Pursuant to the program certain fixed assets have been physicallyverified by the Management during the year. According to the information and explanationsgiven to us no material discrepancies were noticed on such verification.

(c) According to the information and explanations given to us and on the basis of ourexamination of the records of the Company the title deeds of immovable properties areheld in the name of the Company.

(ii) As explained to us the inventories were physically verified during the year bythe Management and the discrepancies noticed on physical verification have been properlydealt with in the books of accounts.

(iii) In our opinion and according to the information and explanations given by themanagement the Company has not granted any loan secured or unsecured to companiesfirms Limited Liability Partnerships (LLPs) or other parties covered in the registermaintained under Section 189 of the Act. Accordingly the provisions of clauses 3(iii)(a)3(iii) (b) and 3(iii)(c) of the Order are not applicable.

(iv) The Company has not granted any loans or made any investments or provided anyguarantees or security to the parties covered under Section 185 and 186. Therefore theprovisions of Clause 3(iv) of the said Order are not applicable to the Company.

(v) During the year the National Company Law Tribunal (‘NCLT') vide its orderdated April 19 2018 had approved the Resolution Plan (‘NCLT Order') submitted bythe Resolution Professional in accordance with the Insolvency and Bankruptcy Code 2016.In view of the NCLT order liability with respect to the Public Fixed Deposit Holderswhich are in the books of the Company verified and accepted will be settled and paid at100% of the principal amount not exceeding INR 5.36 Crore. The said amount shall be paidin eight quarterly instalments and the Company is complying with the same as provided inthe NCLT order.

Further the Company during the year has not accepted any deposits from the publicwithin the meaning of Sections 73 74 75 and 76 of the Act and the Rules framed thereunder to the extent notified.

(vi) The Central Government has prescribed the maintenance of cost records underSection 148 (1) of the Act. However as per information and explanation given by themanagement the prescribed accounts and records have not been made and maintained by thecompany.

(vii) According to the information & explanation given to us in respect ofstatutory dues:

a) The Company has generally been regular in depositing the undisputed statutory duesincluding Provident Fund Employees State Insurance Income Tax Goods and Services TaxCustoms duty Cess and any other material statutory dues as applicable to it with theappropriate authorities though there has been a slight delay in a few cases.

Further in accordance with the NCLT order the statutory liabilities (i.e. income taxand Sales/VAT and employees related dues) will be settled at the amounts crystallised inthe table below:

Nature of dues Amounts settled
(INR in crores)
Income Tax Tax Deducted at Source 2.58
Sales tax/VAT/Service Tax 0.89
Employee related dues (including Provident Fund Employee State Insurance Profession Tax) 0.51
Total 3.98

Accordingly the un-disputed amounts payable as on date in respect thereof which wereoutstanding at the year-end for a period of more than six months from the date they becamepayable have been provided in the books and the payments are been settled as stated in thetable above as prescribed under the aforementioned Order of the NCLT.

b) According to the information and explanations given to us by the management thedetail of statutory dues of sales tax / VAT and income tax which have not been depositedon account of dispute is as under:

Name of the statute Nature of dues Amount (INR in Crores) Period to which the amount relates Forum where dispute is pending
Sales Tax VAT & CST 2.70 F.Y. 2005-06 Sales Tax Appeal
Sales Tax VAT & CST 7.15 F.Y. 2008-09 Sales Tax Appeal
Sales Tax VAT & CST 8.29 F.Y. 2006-07 Sales Tax Appeal
Sales Tax VAT & CST 15.85 F.Y. 2009-10 Sales Tax Appeal
Sales Tax VAT & CST 11.89 F.Y. 2007-08 Sales Tax Appeal
Sales Tax VAT & CST 10.48 F.Y. 2010-11 Sales Tax Appeal
Sales Tax VAT & CST 32.26 F.Y. 2011-12 Order dated 04.10.2017 received on 31.10.2017. Appeal is yet to be filed.
Sales Tax VAT & CST 11.93 F.Y. 2012-13 Order dated 22.02.2018 received on 28.02.2018. Appeal is yet to be filed.
Sales Tax VAT & CST 5.57 F.Y. 2013-14 Order dated 16.02.2018 received on 28.02.2018. Appeal is yet to be filed.
Income Tax Act 1961 Income Tax 0.05 F.Y. 2004-05 CIT Appeal
Income Tax Act 1961 Income Tax 76.90 F.Y. 2007-08 CIT Appeal
Income Tax Act 1961 Income Tax 49.73 F.Y. 2008-09 CIT Appeal
Income Tax Act 1961 Income Tax 85.94 F.Y. 2009-10 CIT Appeal
Income Tax Act 1961 Income Tax 1.77 F.Y. 2005-06 ITAT
Income Tax Act 1961 Income Tax 10.82 F.Y. 2006-07 ITAT
Income Tax Act 1961 Income Tax 8.86 F.Y. 2010-11 ITAT

The above Income tax and Sales Tax/VAT dues will be settled for a settlement amount of1% of the crystallised demand for a maximum of INR 2.58 crores in case of Income Tax andINR 0.89 crores in case of Sales Tax/VAT which shall be paid in four quarterly equalinstallments in accordance with the Approved NCLT Order.

(viii) The Company has defaulted in repayment of loans and borrowings to the banks andfinancial institutions. Pursuant to the continuing defaults of the Company with respect tothe loans and borrowings to banks and financial institutions a Corporate InsolvencyResolution Process under the Insolvency and Bankruptcy Code 2016 was initiated againstthe Company on July 10 2017. The NCLT vide its order dated April 19 2018 approved theResolution Plan and crystallized the settlement payments to be made to the said banks andfinancial institutions pursuant to which debts owed by the Company as at that date havebeen partially settled through repayments and the balance amounts has subsequently beenwaived off. Accordingly the table below provides the relevant information in respect ofsuch debts:

Sr. No. Particulars Amount Outstanding as on March 31 2019 (INR Crores)
Name of the lenders: Fund Based
1 SVC Bank 13.00
2 Edelweiss Assets Reconstruction Co. Ltd. 9.00
3 Public Deposits (inclusive of interest) 4.83
4 Inter-Corporate Deposit 0.05
5 Citi Bank Equity Home Loan -
6 L &T Home Finance Mortgage Loan -
Name of the lenders: Non-Fund Based
1 SICOM (Bill Discounting) 0.54
2 SIDBI (Bill Discounting) 0.13
3 IFCI Factors (Bill Discounting) 0.54

(ix) The Company has not raised moneys by way of initial public offer or further publicoffer (including debt instruments) or term loans and hence reporting under Clause 3(ix) ofthe CARO 2016 Order is not applicable.

(x) According to the information and explanations given by the management we reportthat no fraud by the Company or on the Company by its officers and employees has beennoticed or reported during the year. We have reported one instance under the IndependentAuditors Report Point 1 as stated under the Emphasis of Matter.

(xi) According to the information and explanations given by the management the companydoes not pay any managerial remuneration during the year and therefore the provisions ofclause 3(xi) of the order are not applicable to the company.

(xii) In our opinion the Company is not a Nidhi Company. Therefore the provisions ofClause 3(xii) of the Order are not applicable to the Company.

(xiii) In our opinion and according to the information and explanation given to us theCompany is in compliance with section 177 and 188 of Companies Act 2013 where applicablefor all transactions with the related parties and the details of related partytransactions have been disclosed in the standalone financial Statements as required by theapplicable Ind AS.

(xiv) According to the information and explanation given to us the Company has notmade any preferential allotment or private placement of shares or fully or partlyconvertible debentures during the year under review and hence reporting under theprovisions of Clause 3(iv) of the Order are not applicable to the Company. However as perthe NCLT Order the Company has issued 11241513 shares of INR 10/- each amounting toINR 112415130/-

(xv) According to the information and explanations given to us the Company has notentered into any non cash transactions with its directors or persons connected with thedirectors and hence the provisions of Clause 3(xv) of the Order are not applicable to theCompany.

(xvi) The Company is not required to be registered under Section 45-IA of the ReserveBank of India Act 1934. Accordingly the provisions of Clause 3(xvi) of the Order are notapplicable to the Company.

For Kailash Chand Jain & Co.

Chartered Accountants

Firm Registration No.: 112318W

Saurabh Chouhan

Partner

Membership No.: 167453

Place: Mumbai

Date: May 24 2019

Annexure - B to the Independent Auditors' Report

Referred to in Paragraph 1(g) under Report on Other Legal and Regulatory Requirement'ssection of our report to the Members of Raj Oils Mills Limited of even date

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

We have audited the internal financial controls over financial reporting of Raj OilMills Limited ("the Company") as of March 31 2019 in conjunction with ouraudit of the standalone financial statements of the Company for the year ended on thatdate.

Management's Responsibility for Internal Financial Controls

The Board of Director 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 FinancialReporting (‘Guidance Note') 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 of fraudsand errors the accuracy and completeness of the accounting records and the timelypreparation of reliable financial information as required under the Companies Act2013.

Auditors' Responsibility

Our responsibility is to express an opinion on the Company's internal financialcontrols over financial reporting based on our audit. We conducted our audit in accordancewith the Guidance Note issued by ICAI and the Standards on Auditing prescribed undersection 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 about the adequacy ofthe internal financial controls system over financial reporting and their operatingeffectiveness. Our audit of internal financial controls over financial reporting includedobtaining an understanding of internal financial controls over financial reportingassessing the risk that a material weakness exists and testing and evaluating the designand operating effectiveness of internal control based on the assessed risk. The proceduresselected depend on the auditor's judgement including the assessment of the risks ofmaterial misstatement of the financial statements whether due to fraud or error.

We believe that the audit evidence we have obtained is sufficient and appropriateexcept which stated in Audit Report to provide a basis for audit opinion on the company'sinternal financial controls system over financial reporting.

Meaning of Internal Financial Controls Over Financial Reporting

A company's internal financial control over financial reporting is a process designedto provide reasonable assurance regarding the reliability of financial reporting and thepreparation of financial statements for external purposes in accordance with generallyaccepted accounting principles. A company's internal financial control over financialreporting includes those policies and procedures that (1) pertain to the maintenance ofrecords that in reasonable detail accurately and fairly reflect the transactions anddispositions of the assets of the company; (2) provide reasonable assurance thattransactions are recorded as necessary to permit preparation of financial statements inaccordance with generally accepted accounting principles and that receipts andexpenditures of the company are being made only in accordance with authorisations ofmanagement and directors of the company; and (3) provide reasonable assurance regardingprevention or timely detection of unauthorised 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 Financial Reporting

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

Opinion

In our opinion and to the best of our information and according to the explanationsgiven to us the Company has in all material respects an adequate internal financialcontrols system over financial reporting and such internal financial controls overfinancial reporting were operating effectively as at March 31 2019 based on the internalcontrol over financial reporting criteria established by the Company considering theessential components of internal control stated in the Guidance Note on Audit of internalFinancial Controls over Financial Reporting issued by the ICAI.

Referred to in our report of even date

For Kailash Chand Jain & Co.

Chartered Accountants

Firm Registration No.: 112318W

Saurabh Chouhan

Partner

Membership No.: 167453

Place: Mumbai

Date: May 24 2019