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RCI Industries & Technologies Ltd.

BSE: 537254 Sector: Metals & Mining
NSE: N.A. ISIN Code: INE140B01014
BSE 00:00 | 29 Nov 9.09 0.19
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NSE 05:30 | 01 Jan RCI Industries & Technologies Ltd
OPEN 8.60
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VOLUME 703
52-Week high 11.99
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Sell Price 0.00
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OPEN 8.60
CLOSE 8.90
VOLUME 703
52-Week high 11.99
52-Week low 6.00
P/E
Mkt Cap.(Rs cr) 14
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

RCI Industries & Technologies Ltd. (RCIINDUSTRIES) - Auditors Report

Company auditors report

TO THE MEMBERS OF RCI INDUSTRIES & TECHNOLOGIES LIMITED

Report on the Audit of the Standalone Financial Statements

Qualified Opinion

We have audited the standalone financial statements of RCI INDUSTRIES &TECHNOLOGIES LIMITED (“the Company”) which comprise the balance sheet as atMarch 31 2020 and the statement of profit and loss statement of changes in equity andstatement of cash flows for the year then ended and notes to the financial statementsincluding a summary of significant accounting policies and other explanatory information

In our opinion and to the best of our information and according to the explanationsgiven to us except for the effect of the matter described in the Basis for QualifiedOpinion section of our report the aforesaid standalone financial statements give theinformation required by the Companies Act 2013 in the manner so required and give a trueand fair view in conformity with the accounting principles generally accepted in India ofthe state of affairs of the Company as at March 31 2020 and its loss changes in equityand its cash flows for the year ended on that date.

Basis for Qualified Opinion

a) Company borrowings were declared as non performing asset (NPA) during the currentyear. Due to this we have not been provided with any document confirming balances as atMarch 31 2020 for certain loans granted by financial institutions BG Invocationliability towards banks bill discounting liability towards banks certain currentaccounts and fixed deposits held by the Company. In the absence of such document we cannotcomment on the accuracy and completeness of these balances. The amount of theseborrowings current account balances and fixed deposits as per financial statement as atMarch 31 2020 is Rs. 47.51 crores Rs. 3.51 Lacs and Rs. 73.64 Lacs respectively.

b) The Company has not recognized interest expenses in its financial statement on someof its outstanding borrowings. The total amount of such interest expenses is Rs. 10.46crores approx. (This is an approximate amount without considering the penal interestprovisions and the amount cannot be confirmed with bank levy of interest as many bankshave stopped charging interest in their statement and for certain borrowings confirmationof interest amount is not available). Accordingly loss after tax and other comprehensiveloss for current year ended March 31 2020 is lower by Rs. 10.46 crores.

c) As mentioned in Note no 28 of the financial results Company has recognized meltinglosses amounting to Rs. 24.41 crores in the current year (recognized in the second quarterended September 30 3019). The amount includes losses for prior period amounting to Rs.16.36 crores. This error arises because in earlier years the melting loss is booked basedon approximate loss percentage due to continuous production process in plant. However inthe current year Company has identified the actual melting loss pertaining to previousyear and the same has been recognized as a prior period expense. As per Para 41 to 49 ofInd AS 8 "Accounting Policies Changes in Accounting Estimates and Errors ”prior period errors needs to be recognized in the financial statements of prior years byrestating the accounts. However Company has not restated previous year financialstatements and all the losses have been recognized in the current year. Accordingly lossafter tax and other comprehensive loss for current year ended March 31 2020 is higher byRs. 16.36 crores.

d) As per Section 135 of the Companies Act 2013 Companies are required to spend aspecified amount of its profit towards Corporate Social Responsibility (CSR). If theCompanies are not able to spend such amount than the amount needs to be transferred to aspecific fund/Bank Account created for this purposes. In relation to financial year2019-20 Company was required to spend a total of Rs. 39.83 lacs towards CSR. However theamount was neither spent by the Company nor transferred to a specified find/bank account.Accordingly loss after tax and other comprehensive loss for current year ended March 312020 is lower by Rs. 39.83 Lacs.

We conducted our audit in accordance with the Standards on Auditing (SAs) specifiedunder section 143(10) of the Companies Act 2013. Our responsibilities under thoseStandards are further described in the Auditor's Responsibilities for the Audit of theFinancial 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 together with the ethical requirements that are relevant to our audit of thefinancial statements under the provisions of the Companies Act 2013 and the Rulesthereunder and we have fulfilled our other ethical responsibilities in accordance withthese requirements and the Code of Ethics. We believe that the audit evidence we haveobtained is sufficient and appropriate to provide a basis for our qualified opinion.

Emphasis of Matter

1. As mentioned in Note no 39 of the financial Statements Company has incurred heavylosses amounting to Rs. 142.40 crores during the year ended March 31 2020 (Rs. 54.92crores for quarter ended March 31 2020). Further the Company borrowings are beingdeclared as Non performing asset (NPA) by the lenders due to non-payment of interest andborrowed amount on due dates. (Refer note 35 of financial statements for details of NPA).Due to these factors there is significant erosion in net worth of the Company. Howeverthe current financial statements are being prepared on going concern basis as the networth of the company as at March 31 2020 is positive.

2. The Company inventory balance as at March 31 2020 is Rs. 49.40 crores. Theoutbreak of COVID 19 pandemic in India led the Government of India impose a nationwidelockdown starting March 25 2020. Due to closures of non essential offices andmanufacturing units along with a severe restriction in movement of people the physicalverification of inventory balances was not carried out by us for March 31 2020. Themanagement was able to perform year end physical verification of inventories subsequent tothe year-end only after the local movement restrictions were lifted by the StateGovernment. Consequently we have performed alternate procedures to audit the existence ofinventory as per the guidance issued by the Institute of Chartered Accountants of India.

Our opinion in not modified in respect of these matters

Other Information

The Company's Board of Directors is responsible for the other information. The otherinformation comprises the information included in the director's report managementdiscussion and analysis and report on corporate governance but does not include thefinancial statements and our auditor's report thereon. The director's report managementdiscussion and analysis and report on corporate governance are expected to be madeavailable to us after the date of this auditor's report.

Our opinion on the financial statements does not cover the other information and wewill not express any form of assurance conclusion thereon.

In connection with our audit of the financial statements our responsibility is to readthe other information identified above when it becomes available and in doing soconsider whether the other information is materially inconsistent with the financialstatements or our knowledge obtained in the audit or otherwise appears to be materiallymisstated.

When we read the annual report if we conclude that there is a material misstatementtherein we are required to communicate the matter to those charged with governance.

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.There are no key audit matters to communicate

Responsibilities of Management and Those Charged with Governance for the StandaloneFinancial Statements

The Company's Board of Directors is responsible for the matters stated in section134(5) of the Companies Act 2013 (“the Act”) with respect to the preparation ofthese standalone financial statements that give a true and fair view of the financialposition financial performance changes in equity and cash flows of the Company inaccordance with the accounting principles generally accepted in India including theIndian Accounting Standards specified under section 133 of the Act. This responsibilityalso includes maintenance of adequate accounting records in accordance with the provisionsof the Act for safeguarding of the assets of the Company and for preventing and detectingfrauds and other irregularities; selection and application of appropriate accountingpolicies; making judgments and estimates that are reasonable and prudent; and designimplementation and maintenance of adequate internal financial controls that wereoperating effectively for ensuring the accuracy and completeness of the accountingrecords relevant to the preparation and presentation of the financial statements thatgive a true and fair view and are free from material misstatement whether due to fraud orerror.

In preparing the financial statements the Board of Directors is responsible forassessing the Company's ability to continue as a going concern disclosing as applicablematters related to going concern and using the going concern basis of accounting unlessthe Board of Directors either intends to liquidate the Company or to cease operations orhas no realistic alternative but to do so.

Those Board of Directors are also responsible for overseeing the Company's financialreporting 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 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.

We communicate with those charged with governance regarding among other matters theplanned scope and timing of the audit and significant audit findings including anysignificant deficiencies in internal control that we identify during our audit.

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

From the matters communicated with those charged with governance we determine thosematters that were of most 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 the “Annexure A” a statement on the mattersspecified 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. Except for the effect of the matter described in the Basis for Qualified OpinionPara of our report we have sought and obtained all the information and explanations whichto the best of our knowledge and belief were necessary for the purposes of our audit.

b. Except for the effect of the matter described in the Basis for Qualified OpinionPara of our report in our opinion proper books of account as required by law have beenkept by the Company so far as it appears from our examination of those books

c. The Balance Sheet the Statement of Profit and Loss the Statement of Changes inEquity and the Cash Flow Statement dealt with by this Report are in agreement with thebooks of account

d. Except for the effect of the matter described in the Basis for Qualified OpinionPara of our report in our opinion the aforesaid standalone financial statements complywith the Indian Accounting Standards specified under Section 133 of the Act read withRule 7 of the Companies (Accounts) Rules 2014.

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 31 2020 from being appointed as a director in terms of Section 164(2) of theAct.

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

g. With respect to the other matters to be included in the Auditor's Report inaccordance with Rule 11 of the Companies (Audit and Auditors) Rules 2014 in our opinionand to the best of our information and according to the explanations given to us:

i. The Company has disclosed the impact of pending litigations on its financialposition in its financial statements - Refer Note No. 37 to the financial statements

ii. The Company did not have any long-term contracts including derivative contractsfor which there were any material foreseeable losses.

iii. There has been no delay in transferring amounts required to be transferredto the Investor Education and Protection Fund by the Company.

For KRA & Co.
Chartered Accountants
(Firm Registration No.020266N)
Rajat Goyal
Partner
Membership No.: 503150
Place: Delhi
Date: August 31 2020.

ANNEXURE - A TO THE INDEPENDENT AUDITORS' REPORTOF EVEN DATE ON THE STANDALONEFINANCIAL STATEMENTS of RCI INDUSTRIES & TECHNOLOGIES LIMITED

(Referred to in Paragraph 1 under the heading of “Report on Other Legal andRegulatory Requirements” of our report of even date)

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

(b) In accordance with the phased programme for verification of fixed assets certainitems of fixed assets were physically verified by the management during the year and nomaterial discrepancies were noticed on such verification.

(c) According to the information and explanations given to us and the records examinedby us and based on the examination of the registered sale deed / transfer deed /conveyance deed provided to us we report that the title deeds of immovable propertiesare held in the name of the company.

(ii) Stocks of inventories have been physically verified during the year by themanagement. The Company has a perpetual inventory system. In our opinion the frequency ofsuch verification is reasonable.

As explained to us the management was able to perform year end physical verificationof inventories subsequent to the year-end only after the local movement restrictions dueto COVID 19 were lifted by the State Government. Due to closures of non essential officesand manufacturing units along with a severe restriction in movement of people thephysical verification of inventory balances was not carried out by us for March 31 2020.Consequently we have performed alternate procedures to audit the existence of inventoryas per the guidance issued by the Institute of Chartered Accountants of India.

(iii) According to the information and explanations given to us the Company has notgranted any loans secured or unsecured to companies firms or other parties covered inthe register maintained under Section 189 of the Companies Act 2013. Consequently clause(iii) of the Order is not applicable to the Company.

(iv) In our opinion and according to the information and explanations given to us theCompany has complied with the provisions of Sections 185 and 186 of the Companies Act2013 in respect of grant of loans making investments and providing guarantees andsecurities as applicable.

(v) According to the information and explanations given to us the Company has notaccepted any deposit during the year. Consequently clause (v) of the Order is notapplicable to the Company.

(vi) The maintenance of cost records has been specified by the Central Government undersection 148(1) of the Companies Act 2013 in respect of certain products manufactured bythe Company. We have broadly reviewed the cost records maintained by the Company pursuantto the Companies (Cost Records and Audit) Rules 2014 as amended and prescribed by theCentral Government of India under sub-section (1) of Section 148 of the Act and are of theopinion that prima facie the prescribed cost records have been made and maintained. Wehave however not made a detailed examination of the cost records with a view todetermine whether they are accurate or complete.

(vii) According to the information and explanations given to us and on the basis of ourexamination of the books of account in respect of statutory dues:

(a) The Company has generally been regular in depositing undisputed statutory duesincluding

Provident Fund Employees State Insurance Income-tax Sales-tax Service Tax CustomDuty Excise Duty value added tax GST cess and any other dues during the year withthe appropriate authorities.

(b) The undisputed amounts payable in respect of Provident Fund Employees StateInsurance Income-tax Sales-tax Service Tax Custom Duty Excise Duty value added taxGST cess and other material statutory dues in arrears as at March 31 2020 for a periodof more than six months from the date they became payable are as follows:

Statute Nature of Dues Period to which amount relates Amount unpaid
Income Tax Act 1961 Tax Liability FY 2017-18 & 2018-19 Rs. 171959897

(c) Details of dues of Income-tax Sales-tax Excise Duty GST and Service Tax whichhave not been deposited as on March 31 2020 on account of disputes with the relatedauthorities.

Statute Nature of Dues Forum where pending Period to which amount relates Amount unpaid
Value Added Tax Act Assessment for VAT and CST Hon'ble High Court of Himachal Pradesh FY 2009-10 to 2012-13 Rs. 453761967
Goods and Service Tax Act Show Cause Notice for GST credit Director General of GST Intelligence 01.07.2017 to 31.03.2019 Rs. 2143449040

(viii) The Company has defaulted in the repayment of dues to financial institutions andbanks. The Company account has been classified as Non Performing Asset (NPA) by all thelenders. The detail of such default is presented in the table below:

Lender Name Type of facility Loan Amount Interest Charged by the bank in statement but not booked by the Company Interest Provision on outstanding Amount Total
Indian Bank Cash Credit 193595136 1946128 2040141 197581405
J&K Bank Cash Credit 106721389 5073459 111794848
Punjab National Bank Cash Credit 259041412 12021324 271062736
State Bank of India Cash Credit 227078214 16595194 243673408
South Indian Bank Cash Credit 145586125 7620427 153206552
Karur Vysya Bank Cash Credit 131218579 1408165 132626744
Union Bank of India Cash Credit 371306297 16537777 387844074
CLIX Finance India Pvt Ltd Equipment Financing 34537755 1523861 36061616
Hero Fincorp Limited Equipment Financing 29457770 1282504 30740274
UGRO CAPITAL LTD. Bill Discounting 203242064 2476377 205718441
Can Bank Factors Limiited Bill Discounting 39732433 2450797 42183230
Lakshmi Vilas Bank Limited Bill Discounting 19992205 1243636 21235841
Punjab National Bank Bill Discounting 28739078 1513800 30252878
SBI Global Factors Limited Bill Discounting 29830951 1580791 31411742
South Indian Bank Limited Bill Discounting 129900771 6840188 136740958
Corporation Bank Bill Discounting 78385060 11139691 89524751
Union Bank of India Bill Discounting 138937250 14203 7479563 146431016
Union Bank of India BG Invocation 68937456 - 3840749 72778205
2236239945 25793908 78834868 2340868720

Note 1 - The default is continuing till balance sheet date.

Note 2 - Company has not recognized interest expenses in its financial statements forthe period after the following dates:

• Cash Credit Accounts - Date of declaration of NPA by the Bank

• Equipment Financing - Since Dec'19 onwards

• Bill Discounting - Due date of payment

• BG Invocation - Date of invocation of BG

Note 3 - In additional to the details specified above. In the current financial year(Upto the date of this financial result) one operational creditor named Sizer Metals PteLtd. and one financial creditor named SBI Global Factors Limited have approachedInsolvency and Bankruptcy court for initiating bankruptcy proceeding against the Companyas per provision of Insolvency and Bankruptcy Code. The application is still pendingbefore the authority and no order has been initiated on same.

(ix) In our opinion and according to the information and explanations given to us theCompany has not availed any long term loans during the year. The Company has not made aninitial public offer during the year. Consequently clause (ix) of the Order is notapplicable to the Company.

(x) To the best of our knowledge and according to the information and explanationsgiven to us no material fraud by the Company or on the Company by its officers oremployees has been noticed or reported during the year.

(xi) In our opinion and according to the information and explanations given to us theCompany has paid Managerial remuneration in accordance with the requisite approvalsmandated by the provisions of section 197 read with Schedule V of the Companies Act 2013.

(xii) In our opinion and according to the information and explanations given to us theCompany is not a Nidhi Company. Accordingly clause (xii) of the Order is not applicableto the Company.

(xiii) In our opinion and according to the information and explanations given to usall transactions with the related parties are in compliance with section 177 and 188 ofCompanies Act 2013 and corresponding details have been disclosed in the financialstatements as required by the applicable Indian Accounting Standards.

(xiv) In our opinion and according to the information and explanations given to us theCompany has made preferential allotment / private placement of shares during the year. Theshares have been issued by converting compulsory convertible expenditure. Consequently noamount has been raised during the year from such issue and Company has complied with therequirements of section 42 of the Companies Act 2013.

(xv) In our opinion and according to the information and explanations given to us theCompany has not entered into non-cash transactions with directors or persons connectedwith him. Accordingly requirement under clause (xv) is not applicable to the Company.

(xvi) The Company is not required to be registered under section 45-IA of the ReserveBank of India Act 1934.

For KRA & Co.
Chartered Accountants
(Firm Registration No.020266N)
Rajat Goyal
Partner
Membership No.: 503150
Place: Delhi
Date: August 31 2020.

ANNEXURE “B” TO THE INDEPENDENT AUDITORS' REPORT OF EVEN DATE ON THESTANDALONE FINANCIAL STATEMENTS OF RCI INDUSTRIES & TECHNOLOGIES LIMITED

(Referred to in Paragraph 2 point (f) under the heading of “Report on Other Legaland Regulatory Requirements” of our report of even date)

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

We have audited the internal financial controls over financial reporting of RCIINDUSTRIES & TECHNOLOGIES LIMITED (“the Company”) as at March 31 2020in conjunction with our audit of the standalone financial statements of the Company forthe year ended 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 control over financial reporting criteriaestablished by the Company considering the essential components of internal controlstated in the Guidance Note on Audit of Internal Financial Controls Over FinancialReporting issued by the Institute of Chartered Accountants of India. Theseresponsibilities include the design implementation and maintenance of adequate internalfinancial controls that were operating effectively for ensuring the orderly and efficientconduct of its business including adherence to company's policies the safeguarding ofits assets the prevention and detection of frauds and errors the accuracy andcompleteness of the accounting records and the timely preparation of reliable financialinformation as required under the Companies Act 2013.

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 on Audit of Internal Financial Controls Over Financial Reporting(the “Guidance Note”) issued by Institute of Chartered Accountants of India andthe Standards on Auditing prescribed under section 143(10) of the Companies Act 2013 tothe extent applicable to an audit of internal financial controls 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.

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 appropriate toprovide a basis for our audit opinion on the Company's internal financial controls systemover financial reporting.

Meaning of Internal Financial Controls over Financial Reporting

A company's internal financial control over financial reporting is a process designedto provide reasonable assurance regarding the reliability of financial reporting and thepreparation of financial statements for external purposes in accordance with generallyaccepted accounting principles. A 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 to the best of our information and according to the explanation givento us the Company has in all material respects an adequate internal financial controlssystem over financial reporting and such internal financial controls over financialreporting were operating effectively as at March 31 2020 based on the internal controlover financial reporting 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.

For KRA & Co.
Chartered Accountants
(Firm Registration No.020266N)
Rajat Goyal
Partner
Membership No.: 503150
Place: Delhi
Date: August 31 2020

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