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Rajvir Industries Ltd.

BSE: 532665 Sector: Industrials
NSE: RAJVIR ISIN Code: INE011H01014
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OPEN 8.20
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VOLUME 2
52-Week high 10.53
52-Week low 6.78
P/E
Mkt Cap.(Rs cr) 3
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
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Rajvir Industries Ltd. (RAJVIR) - Auditors Report

Company auditors report

To

The Members of Rajvir Industries Limited

Report on the Audit of the financial statements

Opinion

We have audited accompanying financial statements of Rajvir Industries Limited(‘the Company') which comprise of the balance sheet as at March 312020 thestatement of Profit and Loss (including other comprehensive income) statement of changesin equity and statement of cash flows for the year ended on that date and notes to thefinancial statements including a summary of significant accounting policies and otherexplanatory information (hereafter referred to as “the audited financialstatements”).

In our opinion and to the best of our information and according to the explanationsgiven to us except for the effects of the matter described in the ‘Basis forQualified Opinion' section of our report the aforesaid financial statements give theinformation required by The Companies Act 2013 as amended (“The Act”) in themanner so required and give a true and fair view in conformity with the Indian accountingstandards prescribed under section 133 of the Act read with the Companies (IndianAccounting Standards) Rules 2015 as amended (“Ind AS”) and other accountingprinciples generally accepted in India of the state of affairs of the Company as at March312020 its loss including total comprehensive income changes in equity and its cashflows for the year ended on that date. Basis for Qualified Opinion

(i) We draw attention to Note No. 36 to the financial statements wherein the companyhas been incurring significant operational losses since earlier years whereby the networth of the company is completely eroded. We have not been able to corroborate theManagement's contention regarding preparation of financial statements of the company ongoing concern basis notwithstanding the fact that the company continue to incur cashlosses its net worth has been fully eroded defaulted in repayment of principle andinterest to its lenders loans have been called back by secured lenders non-currentassets are significantly impaired current liabilities exceeded the total assets of thecompany etc. this conditions indicate the existence of a material uncertainty that maycast significant doubt on the company's ability to continue as going concern. Thatappropriateness of assumption of going concern is critically dependent upon the company'sability to raise requisite fi- nance/generate cash flows in future to meet itsobligations.

(ii) The attached financial statements for which no provision for impairment offinancial assets has been made by the company as per Ind AS 109 for Assets included under?ssets held for sale and discontinued operations" pertaining to Claim of refund ofinterest subsidy made under TUFS receivable of Rs. 1288.86 lakhs Insurance claimreceivable of Rs.337.87 lakhs accounted in earlier years pending acceptance by theInsurance company and Incentive receivable from Government of Telangana of Rs.740.09 lakhspertaining to financial year 2013-14 to 2015-16 has not been recovered till the date ofaudit for which the management is of view that these financial assets are recoverable.

(iii) During the year under audit there was sale of land directly by the bankers ofthe company in the month of June 2019 amounting to Rs.295 lakhs as reported in Form 26ASwhich according to company the transfer of aforesaid property has been challenged and hasfiled a Securitisation Application numbered as S.A 528 of 2018 by the company and matterpending before Honourable Debt Recovery Tribunal – II Hyderabad and is subject tofinal decree and judgement. The said application has also challenged the variousunilateral and arbitrary action taken by the bankers. Had the sale of land was accountedin the financial statements which according to information and explanation given to usshould have been accounted as sale of property resulting in gain on sale of Rs.252.48lakhs thereby the losses before tax would have been lower by Rs.252.48 lakhs deferredtax asset lower by Rs.43.67 lakhs and corresponding retained earnings would have higher byRs.208.81 lakhs Property Plant and Equipment would have been lower by Rs.42.52 lakhs andLoans from banks would have been lower by Rs.295 lakhs. The Interest payable onoutstanding loans due to bankers is accounted without considering the sale proceeds fromsale of Land and thereby the finance cost would have been lower by Rs.26.54 lakhs lossesfor the year would have been lower by Rs.26.54 lakhs and corresponding Loans would havebeen lower by Rs.26.54 lakhs and Retained earnings would have been higher by Rs.26.54lakhs.

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(iv) Note no. 38 of the financial statement wherein the confirmation/ reconciliationsof balances of secured and unsecured loans balances with banks trade payable tradereceivable other payable and loans and advances have not been received and are subjectedto reconciliation review and adjustment thereof;

We conducted our audit of the financial statements in accordance with the Standards onAuditing (SAs) specified under section 143(10) of the Companies Act 2013. Ourresponsibilities under those Standards are further described in the Auditor'sResponsibilities for the Audit of the financial statements section of our report. We areindependent of the Company in accordance with the Code of Ethics issued by the Instituteof Chartered Accountants of India together with the independent requirement that arerelevant to our audit of the financial statements under the provisions of the Act and therules made there under and we have fulfilled our other ethical responsibilities inaccordance with these requirements and the ICAI's Code of Ethics. We believe that theaudit evidence we have obtained is sufficient and appropriate to provide a basis for ouropinion on financial statements.

Emphasis of Matter We draw attention to -

Note no. 31.1(b): contingency related to ‘recompense payable in lieu of banksacrifice' as per Corporate Debt Restructuring by banks the outcome of which ismaterially uncertain and cannot be determined currently;

Note No. 36 : The Company continued to present the financials of Tandur unit asdiscontinued operations which is not in accordance with Ind AS 105 as the specified periodof one year from date of classification is completed and there are no evidence for sale tobe highly probable.

Note No.37 of the financial statements as regards to the management's evaluation ofCOVID - 19 impact on the future performance of the Company.

Our opinion is not qualified in respect of above matters. 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:

S No. Key Audit Matter Auditors Response
1 Contingent Liabilities and Commitments: Principal Audit Procedures :
The Company is exposed to a variety of different laws regulations and interpretations thereof which encompasses taxation and legal matters. In the normal course of business provisions and contingent liabilities may arise from legal proceedings including regulatory and other Governmental proceedings constructive obligations and commercial claims. Based on the nature of regulatory and legal cases management applies significant judgment when considering whether and how much to provide for the potential exposure of each matter. These estimates could change substantially over time as new facts emerge as each legal case or matters progresses. Given the different views possible basis of the interpretations complexity and the magnitude of the potential exposures and the judgment necessary to determine required disclosures this is a key audit matter. Our audit procedures included the following:
We understood the processes evaluated the design and implementation of controls and tested the operating effectiveness of the Company's controls over the recording and re-assessment of uncertain legal positions claims and contingent liabilities;
We held discussions with the person responsible for legal and compliance to obtain an understanding of the factors considered in classification of the matter as 'probable' and 'possible'
We read the correspondence from competent authorities and considered legal opinion obtained by the Company from external law firms to challenge the basis used for provisions recognised or the disclosures made in the financial statements; For those matters where Company concluded that no provision should be recorded we also considered the adequacy and completeness of the Company's disclosures made in relation to contingent liabilities.
2 Inventory of raw material work in progress finished goods Stores & Spares etc. (Existence at close of the year) With respect to the existence of Inventory as at the yearend:
a) Evaluated the design and implementation of the controls over physical verification of inventory and tested the operating effectiveness of these controls during the interim periods.
Physical verification of Inventory was performed by the management subsequent to the yearend due to the restrictions imposed on account of COVID-19.
b) Due to the COVID-19 related lock-down we were not able to participate in the physical verification of inventory that was carried out by the management subsequent to the year end. Consequently we have participated in the physical verification of inventories conducted by the management subsequent to the year end through video calls and performed roll back procedures.

Information other than financial statements and Auditor's report thereon

The company's Board of Directors are responsible for the preparation of the otherinformation. The other information comprises of the information included in the managementdiscussion and analysis Boards report including Annexure to Boards Report CorporateGovernance and Shareholders information but does not include the financial statements andour auditor's report thereon. Our opinion on financial statements does not cover the otherinformation and we do not express any form of assurance or conclusion thereon.

In connection with our audit of the financial statement our responsibility is to readthe other information and in doing so consider whether the other information ismaterially inconsistent with the financial statement or other information obtained duringthe course 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.

Responsibilities of Management for the financial statements

The Company's Board of Directors are responsible for the

matters stated in section 134(5) of the Companies Act 2013 (“the Act”) withrespect to the preparation of these financial statements that give a true and fair view ofthe financial position financial performance total comprehensive income changes inequity and cash flows of the Company in accordance with the accounting principlesgenerally accepted in India including the accounting Standards specified under section133 of the Act. This responsibility also includes maintenance of adequate accountingrecords in accordance with the provisions of the Act for safeguarding of 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 statement 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 are responsible for overseeing theCompany's financial reporting process.

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 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 collusion forgeryintentional omissions misrepresentations or the override of internal control.

• Obtain an understanding of internal financial controls relevant to the audit inorder to design audit procedures that are appropriate in the circumstances. Under section143(3)(i) of the Companies Act 2013 we are also responsible for expressing our opinionon whether the company has adequate internal financial controls with reference to thefinancial statements in place and the operating effectiveness of such controls.

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

• Conclude on the appropriateness of management's use of the going concern basisof accounting and based on the audit evidence obtained whether a material uncertaintyexists related to events or conditions that may cast significant doubt on the Company'sability to continue as a going concern. If we conclude that a material uncertainty existswe are required to draw attention in our auditor's report to the related disclosures inthe financial statements or if such disclosures are inadequate to modify our opinion. Ourconclusions 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 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 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 charged with governance regarding among othermatters 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 we havecomplied with relevant ethical requirements regarding independence and to communicatewith them all relationships and other matters that may reasonably be thought to bear onour independence and

where applicable related safeguards.

• From the matters communicated with those charged with governance we determinethose matters that were of most significance in the audit of the financial statements ofthe current period and are therefore the key audit matters. We describe these matters inour auditor's report unless law or regulation precludes public disclosure about the matteror when 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 As required by the Companies(Auditor's Report) Order 2016 (“the Order”) issued by the Central Governmentof India in terms of sub-section (11) of section 143 of the Companies Act 2013 we givein the Annexure A a statement on the matters specified in paragraphs 3 and 4 of theOrder to the extent applicable. As required by Section 143(3) of the Act we report that:

a) We have sought and obtained all the information and explanations which to the bestof our knowledge and belief were necessary for the purposes of our audit.

b) In our opinion proper books of account as required by law have been kept by theCompany so far as it appears from our examination of those books.

c) The Balance Sheet the Statement of Profit and Loss including other comprehensiveincome the statement of change in equity and the Cash Flow Statement dealt with by thisReport are in agreement with the relevant books of account.

d) In our opinion the aforesaid financial statements comply with the AccountingStandards specified under Section 133 of the Act read with Companies (Indian AccountingStandards) Rules 2015 as amended including the Companies (Indian Accounting Standards)Amendment Rules 2019;

e) On the basis of the written representations received from the directors as on March31 2020 taken on record by the Board of Directors none of the directors is disqualifiedas on March 312020 from being appointed as a director in terms of Section 164 (2) of theAct.

f) With respect to the other matters to be included in the Auditor's Report inaccordance with the requirements of Section 197(16) of the Act as amended in our opinionand to the best of our information and according to the explanations given to us theremuneration paid by the Company to its directors during the year is in accordance withthe provisions of Section 197 of the Act.

g) With respect to the adequacy of the internal financial controls with reference tofinancial statements of the Com-

pany and the operating effectiveness of such controls refer to our separate Report in“Annexure B”. h) With respect to the other matters to be included in theAuditors Report in accordance with Rule 11 of the Companies (Audit and Auditors) Rules2014 in our opinion and to the best of our information and according to the explanationsgiven to us

i. The Company has disclosed the impact of pending litigations on its financialposition in its Ind AS financial statements - Refer Note 32;

ii. The Company has made provision as required under the applicable law or AccountingStandards for material foreseeable losses if any on long term contracts. The Companyneither entered into any derivative contract during the year nor have any outstandingderivative contract at the end of the year;

iii. There has been no delay in transferring amounts required to be transferred tothe Investor Education and Protection Fund by the Company during the year ended March312020.

For K.C. Bhattacharjee & Paul.

Chartered Accountants (ICAI FRN: 303026E)

(Manoj Kumar Bihani)

Partner

Membership No. 234629 UDIN No. 20234629AAAABE8536

Place: Hyderabad Date: 31.07.2020

Annexure - A to the Independent Auditors' Report

Referred to in Report on Other Legal and Regulatory Requirements of the IndependentAuditors' Report of even date to the members of Rajvir Industries Limited on the Ind ASfinancial statements as of and for the year ended March 312020

1. (a)The Company is maintaining proper records showing full particulars includingquantitative details and situation of Property Plant and Equipment

(b) Property Plant and Equipment have been physically verified by the management duringthe year and no material discrepancies between the book records and the physical inventoryhave been noticed.

(c) The title deeds of immovable properties as disclosed in Note no. 1 on PropertyPlant and Equipment to the financial statements are held in the name of the company exceptthe sale of land by the bankers valued of Rs.42.52 lakhs which is not in the possession ofthe Company.

2. (a) The inventory has been physically verified by the management during the year. Inour opinion the frequency of verification is reasonable.

(b) On the basis of our examination of the inventory records the company ismaintaining proper records of inventory. The discrepancies noticed on physicalverification of inventory as compared to book records have been properly dealt with by thecompany.

3. The Company has not granted any loans secured or unsecured loan to companies firmsor other parties covered in the register maintained under Section 189 of the CompaniesAct 2013.

4. In respect of loans investments guarantees and securities which are covered underthe provisions of Section 185 and 186 of the Companies Act 2013 as per information andexplanations given to us the company has complied with the provisions of the Act.

5. In our opinion and according to the information and explanation given to us thecompany has not paid the interest on public deposits of Rs.32.30 lakhs as on 31.03.2020and as such has not complied with the relevant provisions of section 73 to 76 and otherrelevant provisions of the Companies Act and the Companies (Acceptance of Deposit) Rules2015 as applicable with regards to the deposits accepted from members and the public. Asinformed by the management no order has been passed by the Company Law Board or NationalCompany Law Tribunal or Reserve Bank of India or any Court or any other Tribunal withregard to the Deposits.

6. We have broadly reviewed the books of accounts main-

tained by the Company pursuant to the rules made by the Central Government of Indiathe maintenance of cost records specified under sub-section (1) of Section 148 of the Actand are of the opinion that prima facie the prescribed accounts and records have beenmade and maintained. We have not however made a detailed examination of the Records witha view to determine whether they are accurate or complete.

7. (a) According to the information and explanations given to us and the records of theCompany examined by us in our opinion the Company is irregular in depositing undisputedstatutory dues including provident fund employees state insurance income tax sales taxvalue added tax service tax custom duty excise duty cess GST and other statutory duesas applicable to it with appropriate authorities and there have been serious delays inlarge number of cases. There are no undisputed statutory dues except as stated below whichremained unpaid for a period of more than six months as on the reporting date -

Particulars Period Amount (In lakhs)
Provident fund April 2017 to September 2019 45.91
Tax deducted and collected at source April 2016 to September 2019 166.93
Service Tax April 2015 to June 2017 22.26
Sales tax deferment Upto March 2020 354.67
Employees State Insurance January 2019 to September 2019 10.03

(b) According to the information and explanations given to us there are no disputedstatutory dues as at the year end.

8.According to the records examined by us the Company has defaulted in principalrepayment of dues to financial institutions/banks during the current financial year. Thelender wise details of the amount of default as at Balance sheet date are as under:

Particulars (Name of the Lender) Amount of default as at the Balance sheet date (RS In lakhs) Period of Default Remarks if any
Central Bank of India 142.18 Jan.2018 to March 2020 The account is classified as NPA by bank.
State Bank of India 1532.31 Jan.2018 to March 2020 The account is classified as NPA by S B I.
IDBI Bank 363.96 Jan.2018 to March 2020 The account is classified as NPA by IDBI Bank
Axis Bank 635.05 July 2017 to March 2020 The account is classified as NPA by bank.

9. On the basis of our review of utilization of funds pertaining to term loans onoverall basis and related information and explanations as made available to us the termloans taken by the company has been utilized for the purpose of which they were obtained.Further the company has not raised moneys by way of initial public offers or furtherpublic offers during the year.

10. During the course of our examination of the books and records of the companycarried out in accordance with the generally accepted auditing practices in India andaccording to the information and explanations given to us we have neither come across anyinstance of material fraud by the company or on the company its officers or employeesnoticed or reported during the year nor have we been informed by any such case by themanagement.

11. The company has paid/provided for managerial remuneration in accordance with therequisite approvals mandated by the provisions of Section 197 read with Schedule V to theAct.

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

13. The company has entered into transactions with related parties in compliance withthe provisions of Section 177 and 188 of the Act. The details of such related partytransactions have been disclosed in the financial statements as required under AccountingStandards (AS) 18 Related Party Disclosures specified under Section 133 of the Act readwith Rule 7 of the Companies (Accounts) Rules

16th Annual Report 2019-2020

14. The Company has not made any preferential allotment or private placement of sharesor fully or partly convertible debentures during the year under review. Accordingly theprovisions of Clause 3(xiv) of the Order are not applicable to the Company.

15. The Company has not entered into any non cash transactions with its directors orpersons connected with him. Accordingly the provisions of Clause 3(xv) of the Order arenot applicable to the Company.

16. 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 K.C. Bhattacharjee & Paul.

Chartered Accountants (ICAI FRN: 303026E)

(Manoj Kumar Biham)

Partner

Membership No. 234629

Place: Hyderabad Date: 31.07.2020

Annexure - B to the Independent Auditors' Report

Report on the Internal Financial Controls with reference to the financial statementsunder Clause (i) of Sub-section 3 of Section 143 of the Companies Act 2013 (“theAct”)

We have audited the internal financial controls with reference to the financialstatements of Rajvir Industries Limited (“the Company”) as of 31st March 2020 inconjunction with our audit of the Ind AS financial statements of the Company for the yearended on that date.

Management's Responsibility for Internal Financial Controls

The Company's management is responsible for establishing and maintaining internalfinancial controls based on the internal financial controls with reference to thefinancial statements criteria established by the Company considering the essentialcomponents of internal control stated in the Guidance Note on Audit of Internal FinancialControls over Financial Reporting issued by the Institute of Chartered Accountants ofIndia. These responsibilities include the design implementation and maintenance ofadequate internal financial controls that were operating effectively for ensuring theorderly and efficient conduct of its business including adherence to company's policiesthe

safeguarding 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.

Auditors' Responsibility

Our responsibility is to express an opinion on the Company's internal financialcontrols with reference to financial statements based on our audit. We conducted our auditin accordance with the Guidance Note and the Standards on Auditing issued by ICAI anddeemed to be prescribed under section 143(10) of the Companies Act 2013 to the extentapplicable to an audit of internal financial controls with reference to financialstatements. Those Standards and the Guidance Note require that we comply with ethicalrequirements and plan and perform the audit to obtain reasonable assurance about whetheradequate internal financial controls with reference to financial statements wasestablished and maintained and if such controls operated effectively in all materialrespects.

Our audit involves performing procedures to obtain audit evidence about the adequacy ofthe internal financial controls with reference to financial statements and their operatingeffectiveness. Our audit of internal financial controls with reference to financialstatements included obtaining an understanding of such internal financial controlsassessing the risk that a material weakness exists and testing and evaluating the designand operating effectiveness of internal control based on 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 appropriate toprovide a basis for our audit opinion on the Company's internal financial controls withreference to financial statements.

Meaning of Internal Financial Controls with reference to financial statements:

A company's internal financial control with reference to financial statements is aprocess designed to provide reasonable assurance regarding the reliability of financialreporting and the preparation of Ind AS financial statements for external purposes inaccordance with generally accepted accounting principles. A company's internal financialcontrols with reference to financial statements includes those policies and proceduresthat (1) pertain to the maintenance of records that in reasonable detail accurately andfairly reflect the transactions and dispositions of the assets of the company; (2) providereasonable assurance that transactions are recorded as necessary to permit preparation ofInd AS financial statements in accordance with generally accepted accounting principlesand that receipts and expenditures of the company are being made

only in accordance with authorizations of management and directors of the company; and(3) provide reasonable assurance regarding prevention or timely detection of unauthorizedacquisition use or disposition of the company's assets that could have a material effecton the Ind AS financial statements.

Inherent Limitations of Internal Financial Controls with reference to financialstatements

Because of the inherent limitations of internal financial controls with reference tofinancial statements 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 withreference to financial statements to future periods are subject to the risk that theinternal financial control with reference to financial statements may become inadequatebecause of changes in conditions or that the degree of compliance with the policies orprocedures may deteriorate.

Qualified Opinion

According to the information and explanations given to us and based on our audit amaterial weakness has been identified in the Company's internal financial controls overfinancial reporting as at March 312020 as regards evaluation of uncertainty on goingconcern.

A material weakness is a deficiency or a combination of deficiencies in internalfinancial control over financial reporting such that there is a reasonable possibilitythat a material misstatement of the Company's annual or interim financial statements willnot be prevented or detected on a timely basis.

In our opinion except for the possible effects of the material weakness describedabove the Company has in all material respects an adequate internal financial controlsystem with reference to financial statements and such internal financial controls wereoperating effectively as at March 312020 based on the internal financial control withreference to financial statements 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 Institute of CharteredAccountants of India.

For K.C. Bhattacharjee& Paul.

Chartered Accountants (ICAI FRN: 303026E)

(Manoj Kumar Bihani)

Partner

Membership No. 234629

Place: Hyderabad

Date: 31.07.2020

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