Reliance Capital Limited
Report on the audit of the Standalone financial statements
We have audited the standalone financial statements of Reliance Capital Limited (the Company) which comprise the Standalone Balance Sheet as at March 31 2020 the Standalone Statement of Profit and Loss (including other comprehensive income) Standalone Statement of Changes in Equity and Standalone Statement of Cash Flows for the year then ended and summary of significant accounting policies and other explanatory information (hereinafter referred to as the standalone financial statements). In our opinion and to the best of our information and according to the explanations given to us the aforesaid standalone financial statements give the information required by the Companies Act 2013 (the Act) in the manner so required and give a true and fair view in conformity with the accounting principles generally accepted in India of the state of affairs of the Company as at March 31 2020 its loss and other comprehensive income/(loss) its changes in equity and its cash flows for the year ended on that date.
Basis for opinion
We conducted our audit in accordance with the Standards on Auditing (SAs) specified under section 143(10) of the Act. Our responsibilities under those Standards are further described in the Auditor's Responsibilities for the Audit of the standalone financial statements section of our report. We are independent of the Company in accordance with the Code of Ethics issued by the Institute of Chartered Accountants of India together with the ethical requirements that are relevant to our audit of the standalone financial statements under the provisions of the Act and the Rules thereunder and we have fulfilled our other ethical responsibilities in accordance with these requirements and the Code of Ethics. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.
Material Uncertainty related to Going Concern
We draw attention to Note no. 41(h) of the standalone financial statements wherein the Company has defaulted in repayment of the obligations to its lenders and debenture holders which is outstanding as on March 31 2020 and also has incurred losses during the year which indicate material uncertainty exists that may cast a significant doubt on the Company's ability to continue as a Going Concern. The Company is in the process of meeting its obligations by way of time bound monetization of its assets and accordingly the financial statements of the Company have been prepared on a Going Concern basis.
Our opinion is not modified in respect of this matter.
Emphasis of Matter
(a) We draw attention to Note no. 41(a) of the standalone financial statements wherein the Company has exposure by way of Loans Investments (including interest accrued thereon) and Guarantees in its associate company and subsidiary company viz. Reliance Home Finance Limited (RHF) and Reliance Commercial Finance Limited (RCF) aggregating to Rs.4935 crore outstanding as on March 31 2020. The lenders of these subsidiaries have entered into an Inter Creditor Agreement and their resolution plan is being finalized. Though the Company is confident of implementation of the resolution plan pending finalisation of the same the Company on a conservative basis made an impairment provision of Rs.742 crore against the above exposure in the books of account.
(b) We draw attention to Note no. 41(f) of the standalone financial statements referring to filing under Section 143(12) of the Companies Act 2013 to Ministry of Corporate Affairs by one of the previous auditors for the financial year 2018-19. Based on the facts fully described in the aforesaid note views of the Company in-depth examination carried out by the independent legal experts of the relevant records there were no matters attracting the said Section.
(c) We draw attention to Note no. 57 of the standalone financial statements as regards to the management evaluation of COVID - 19 impact on the future performance of the Company. Our opinion is not modified in respect of the above matters.
Key Audit Matters
Key audit matters are those matters that in our professional judgment were of most significance in our audit of the standalone financial statements of the current period. These matters were addressed in the context of our audit of the standalone financial statements as a whole and in forming our opinion thereon and we do not provide a separate opinion on these matters. For each matter below our description of how our audit addressed the matter is provided in that context.
In addition to the matters described in the Material Uncertainty related to Going Concern section we have determined the matters described below to be the key audit matters to be communicated in our report. We have fulfilled the responsibilities described in the Auditor's responsibilities for the audit of the standalone financial statements section of our report including in relation to these matters. Accordingly our audit included the performance of procedures designed to respond to our assessment of the risks of material misstatement of the standalone financial statements. The results of our audit procedures including the procedures performed to address the matters below provide the basis for our audit opinion on the accompanying standalone financial statements.
|Key Audit Matters||How our audit addressed the Key Audit Matter|
|1. Impairment of financial assets and Corporate Guarantee (CG) Issued (expected credit losses) (as described in Note Nos. 7 and 18 of the standalone financial statements)|
|Ind AS 109 requires the Company to recognise impairment loss allowance towards its financial assets (designated at amortised cost and corporate guarantee issued) using the expected credit loss (ECL) approach. Such ECL allowance is required to be measured considering the guiding principles of Ind AS 109 including:|
| We read and assessed the Company's accounting policies for impairment of financial assets and their compliance with Ind AS 109.|
| We tested the criteria for staging of loans/CG based on their past-due status to check compliance with requirement of Ind AS 109. Tested a sample of performing (stage 1) loans to assess whether any loss indicators were present requiring them to be classified under stage 2 or 3 and vice versa.|
| unbiased probability weighted outcome under various scenarios;|
| time value of money;|
| impact arising from forward looking macro-economic factors and;|
| We evaluated the reasonableness of the Management estimates|
| availability of reasonable and supportable information without undue costs.||by understanding the process of ECL estimation and tested the controls around data extraction and validation.|
|Applying these principles involves significant estimation in various aspects such as:|| Tested the ECL model including assumptions and underlying computation.|
| grouping of borrowers based on homogeneity by using appropriate statistical techniques;|
| staging of loans and estimation of behavioural life; |
| determining macro-economic factors impacting credit quality of receivables;|
| estimation of losses for loan products/corporate guarantee with no/minimal historical defaults.|
|Considering the significance of such allowance to the overall financial statements and the degree of estimation involved in computation of expected credit losses this area is considered as a key audit matter.|
|2. Impairment assessment for Investments in subsidiaries and associates (as described in Note No. 8 of the standalone financial statements)|
|As detailed in Note no. 8 the Company has equity and preference share investments (net of provision for impairment) in subsidiary companies amounting to Rs.1 3340 crore and associate companies amounting to Rs.843 crore.||Our audit procedures in respect of testing impairment assessment for investments in subsidiaries and associates included the following:|
| Obtained understanding of the process evaluated the design and tested operating effectiveness of controls in respect of impairment assessment of investments in subsidiaries and associates.|
|Such investments are carried at cost as per Ind AS 27 - Separate Financial Statements and are individually assessed for impairment as per Ind AS 36 - Impairment of Assets. Such impairment assessment commences with management's evaluation on whether there is an indication of impairment loss. As part of such evaluation management considers financial information liquidity and solvency position of investments in subsidiaries and associates. Management also considers other factors such as assessment of company's operations business performance and modifications if any by the auditors of such subsidiaries and associates. Based on such evaluation the Company has made impairment provisions against the above investment. |
|We focused on this area due to magnitude of the carrying value of investments in subsidiaries and associates which comprise 62% of the total assets as at March 31 2020 and are subject to annual impairment assessment.|| held discussions with management regarding appropriate implementation of policy on impairment.|
| reconciled financial information mentioned in impairment assessment to underlying source details. Also assessed of management's estimates considered in such assessment.|
| obtained and read latest audited financial statements of subsidiaries and associates. Noted key financial attributes.|
| We evaluated the impairment assessment performed by management.|
|3. Valuation of Market Linked Debentures (as described in Note No. 15 of the standalone financial statements)|
|The Company has issued Market Linked Debentures (MLD) during current and previous years. The outstanding balance of MLD as on March 31 2020 is Rs.490 crore. These MLDs are economically hedged with Exchange instruments like Nifty Bank Nifty & Stock Options.|| Audit procedures included an assessment of internal controls over valuation methodologies inputs judgments made and assumptions used by management in determining fair valuation of MLD.|
|The Company has done an internal valuation of the outstanding MLD using internal valuation techniques.|| Assessed and reviewed the fair valuation of MLD by the Company for compliance with Ind AS.|
|Considering that internal valuation of MLD is significant to overall financial statements and the degree of management's judgement involved in the estimate any error in the estimate could lead to material misstatement in the financial statements. Therefore it is considered as a key audit matter.|| Compared resulted valuations against independent sources and externally available market valuation data for sample cases.|
The Company's Board of Directors is responsible for the other information. The other information comprises the information included in Company's annual report but does not include the standalone financial statements and our auditor's report thereon.
Our opinion on the standalone financial statements does not cover the other information and we do not express any form of assurance conclusion thereon. In connection with our audit of the standalone financial statements our responsibility is to read the other information and in doing so consider whether the other information is materially inconsistent with the standalone financial statements or our knowledge obtained in the audit or otherwise appears to be materially misstated. If based on the work we have performed we conclude that there is a material misstatement of this other information; we are required to report that fact. We have nothing to report in this regard.
Management Responsibilities for the standalone financial statements
The Company's Board of Directors is responsible for the matters stated in section 134(5) of the Act with respect to the preparation of these standalone financial statements that give a true and fair view of the financial position financial performance changes in equity and cash flows of the Company in accordance with the accounting principles generally accepted in India including the Accounting Standards specified under section 133 of the Act. This responsibility also includes maintenance of adequate accounting records in accordance with the provisions of the Act for safeguarding of the assets of the Company and for preventing and detecting frauds and other irregularities; selection and application of appropriate implementation and maintenance of accounting policies; making judgments and estimates that are reasonable and prudent; and design implementation and maintenance of adequate internal financial controls that were operating effectively for ensuring the accuracy and completeness of the accounting records relevant to the preparation and presentation of the standalone financial statement that give a true and fair view and are free from material misstatement whether due to fraud or error.
In preparing the standalone financial statements management is responsible for assessing the Company's ability to continue as a going concern disclosing as applicable matters related to going concern and using the going concern basis of accounting unless management either intends to liquidate the Company or to cease operations or has no realistic alternative but to do so. Those Board of Directors are also responsible for overseeing the Company's financial reporting process.
Auditor's responsibilities for the audit of the standalone financial statements
Our objectives are to obtain reasonable assurance about whether the standalone financial statements as a whole are free from material misstatement whether due to fraud or error and to issue an auditor's report that includes our opinion. Reasonable assurance is a high level of assurance but is not a guarantee that an audit conducted in accordance with SAs will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if individually or in the aggregate they could reasonably be expected to influence the economic decisions of users taken on the basis of these standalone financial statements. As part of an audit in accordance with SAs we exercise professional judgment and maintain professional skepticism throughout the audit. We also:
Identify and assess the risks of material misstatement of the standalone financial statements whether due to fraud or error design and perform audit procedures responsive to those risks and obtain audit evidence that is sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error as fraud may involve collusion forgery intentional omissions misrepresentations or the override of internal control.
Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances.
Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and related disclosures made by management.
Conclude on the appropriateness of management's use of the going concern basis of accounting and based on the audit evidence obtained whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Company's ability to continue as a going concern. If we conclude that a material uncertainty exists we are required to draw attention in our auditor's report to the related disclosures in the standalone 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's report. However future events or conditions may cause the Company to cease to continue as a going concern.
Evaluate the overall presentation structure and content of the standalone financial statements including the disclosures and whether the standalone financial statements represent the underlying transactions and events in a manner that achieves fair presentation.
We communicate with those charged with governance regarding among other matters the planned scope and timing of the audit and significant audit findings including any significant deficiencies in internal control that we identify during our audit. We also provide those charged with governance with a statement that we have complied with relevant ethical requirements regarding independence and to communicate with them all relationships and other matters that may reasonably be thought to bear on our independence and where applicable related safeguards.
From the matters communicated with those charged with governance we determine those matters that were of most significance in the audit of the standalone financial statements of the current period and are therefore the key audit matters. We describe these matters in our auditor's report unless law or regulation precludes public disclosure about the matter or when in extremely rare circumstances we determine that a matter should not be communicated in our report because the adverse consequences of doing so would reasonably be 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 Government of India in terms of subsection (11) of section 143 of the Companies Act 2013 we give in Annexure B a statement on the matters specified in paragraphs 3 and 4 of the Order 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 best of 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 the Company so far as it appears from our examination of those books.
c) The standalone balance sheet the standalone statement of profit and loss (including other comprehensive income the standalone statement of changes in equity and the standalone statement of cash flow dealt with by this Report are in agreement with the books of account.
d) In our opinion the aforesaid standalone financial statements comply with the Ind AS specified under Section 133 of the Act.
e) On the basis of the written representations received from the directors as on March 31 2020 taken on record by the Board of Directors none of the directors is disqualified as on March 31 2020 from being appointed as a director in terms of Section 164 (2) of the Act.
f) The going concern matter described in Material Uncertainty Related to Going Concern section above in our opinion may have an adverse effect on the functioning of the Company.
g) With respect to the adequacy of the internal financial controls with reference to standalone financial statements of the Company and the operating effectiveness of such controls refer to our separate Report in Annexure A.
h) With respect to matter to be included in the Auditors' Report under section 197(16) of the Act: In our opinion and according to the information and explanation given to us the Company has paid/provided for managerial remuneration in accordance with the requisite approvals mandated by provision of section 197 read with Schedule V to the Act.
i) With respect to the other matters to be included in the Auditor's Report in accordance with Rule 11 of the Companies (Audit and Auditors) Rules 2014 in our opinion and to the best of our information and according to the explanations given to us:
a. The Company has disclosed the impact of pending litigations on its financial position in its standalone financial statements - Refer Note no. 39 to the standalone financial statements;
b. The Company has made provision as required under the applicable law or Ind AS for material foreseeable losses if any on long-term contracts including derivative contracts - Refer Note no. 52 to the standalone financial statements;
c. Other than for dividend amounting to Rs.0.11 crore pertaining to financial year 2010-11 and financial year 2011-12 which could not be transferred on account of pendency of various investor legal cases there has been no delay in transferring amounts required to be transferred to the Investor Education and Protection Fund by the Company.
For Pathak H.D. & Associates LLP
Firm's Registration No: 107783W/W100593
Vishal D. Shah
Membership No: 119303
Date : May 8 2020
Annexure A to the Independent Auditors' Report on the Standalone financial statements
[Annexure to the Independent Auditor's Report referred to in paragraph under the heading Report on other legal and regulatory requirements of our report of even date on the financial statements of Reliance Capital Limited for year ended March 31 2020.] Report on the Internal Financial Controls with reference to standalone financial statements under Clause (i) of Subsection 3 of Section 143 of the Companies Act 2013 (the Act)
1. We have audited the internal financial controls with reference to financial statements of Reliance Capital Limited (`the Company') as of March 31 2020 in conjunction with our audit of the standalone financial statements of the Company for the year ended on that date.
Management's Responsibility for Internal Financial Controls
2. The Company's management is responsible for establishing and maintaining internal financial controls based on the internal control with reference to financial statements criteria established by the Company considering the essential components of internal control stated in the Guidance Note on Audit of Internal Financial Controls over Financial Reporting issued by the Institute of Chartered Accountants of India (ICAI). These responsibilities include the design implementation and maintenance of adequate internal financial controls that were operating effectively for ensuring the orderly and efficient conduct of its business including adherence to company's policies the safeguarding of its assets the prevention and detection of frauds and errors the accuracy and completeness of the accounting records and the timely preparation of reliable financial information as required under the Act.
3. Our responsibility is to express an opinion on the Company's internal financial controls with reference to financial statements based on our audit. We conducted our audit in accordance with the Guidance Note on Audit of Internal Financial Controls Over Financial Reporting (the Guidance Note) and the Standards on Auditing issued by ICAI and deemed to be prescribed under section 143(10) of the Act to the extent applicable to an audit of internal financial controls both applicable to an audit of Internal Financial Controls and both issued by the ICAI. Those Standards and the Guidance Note require that we comply with ethical requirements and plan and perform the audit to obtain reasonable assurance about whether adequate internal financial controls over financial reporting was established and maintained and if such controls operated effectively in all material respects.
4. Our audit involves performing procedures to obtain audit evidence about the adequacy of the internal financial controls system with reference to financial statements and their operating effectiveness. Our audit of internal financial controls with reference to financial statements included obtaining an understanding of internal financial controls with reference to financial reporting assessing the risk that material weakness exists and testing and evaluating the design and operating effectiveness of internal control based on the assessed risk. The procedures selected depend on the auditor's judgment including the assessment of the risks of material misstatement of the financial statements whether due to fraud or error.
5. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our qualified audit opinion on the Company's internal financial controls system with reference to financial statements.
Meaning of Internal Financial Controls with reference to financial statements
6. A company's internal financial control with reference to financial statements is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of the standalone financial statements for external purposes in accordance with generally accepted accounting principles. A company's internal financial control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that in reasonable detail accurately and fairly reflect the transactions and dispositions of the assets of the Company; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of the Standalone financial statements in accordance with generally accepted accounting principles and 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 unauthorized acquisition use or disposition of the company's assets that could have a material effect on the Standalone financial statements.
Inherent Limitations of Internal Financial Controls with reference to financial statements
7. Because of the inherent limitations of internal financial controls with reference to financial statements including the possibility of collusion or improper management override of controls material misstatements due to error or fraud may occur and not be detected. Also projections of any evaluation of the internal financial controls with reference to financial statements to future periods are subject to the risk that the internal financial controls with reference to financial statements may become inadequate because of changes in conditions or that the degree of compliance with the policies or procedures may deteriorate.
Basis for Qualified Opinion
8. Based on our audit information & explanation provided by the management following weakness have been observed with regard to internal financial control.
The Company needs to strengthen loan processing documentation including justification for sanctioning the loans/exposures risk assessment of exposures and its mitigation monitoring of end use of funds evaluation of borrower's repayment capacity and the policy of sanctioning the loan to entities with weaker credit worthiness.
9. In our opinion and to the best of information and according to explanations given to us the Company has maintained adequate internal financial controls with reference to financial statements as at March 31 2020 based on the internal control with reference to financial statements criteria established by the Company considering the essential components of internal control stated in the Guidance Note on Audit of Internal Financial Controls Over Financial Reporting issued by the ICAI and except for possible effects of the material weakness described in the Basis of Qualified Opinion paragraph above on the achievement of the objectives of the Control criteria the Company's internal financial control with reference to financial statements were operating effectively as at March 31 2020.
A `material weakness' is a deficiency or a combination of deficiencies in internal financial control with reference to financial statements such that there is a reasonable possibility that a material misstatement of the Company's annual or interim financial statements will not be prevented or detected on a timely basis.
10. We have considered the material weakness identified and reported above in determining the nature and extent of audit tests applied in our audit of the standalone financial statements of the Company for the year ended March 31 2020 and these material weaknesses do not affect our opinion on the standalone financial statements of the Company.
For Pathak H.D. & Associates LLP
Firm's Registration No: 107783W/W100593
Vishal D. Shah
Membership No: 119303
Date : May 8 2020
Annexure B to the Independent Auditors' Report on the Standalone financial statements
Referred to in the Independent Auditors' Report of even date to the members of Reliance Capital Limited (the Company') on the standalone financial statements as of and for the year ended March 31 2020
i. (a) The Company is maintaining proper records showing full particulars including quantitative details and situation of property plant and equipment.
(b) The property plant and equipment are physically verified by the Management according to a phased programme designed to cover all the items over a period of three years which in our opinion is reasonable having regard to the size of the Company and the nature of its assets.
Pursuant to the programme a portion of the property plant and equipment has been physically verified by the Management during the year and no material discrepancies have been noticed on such verification.
(c) The title deeds of immovable properties as disclosed in Note No. 11 and 12 on Investment Property and Property Plant and Equipment respectively to the standalone financial statements are held in the name of the Company.
ii. The Company is in the business of rendering services and consequently does not hold any inventory. Therefore the provisions of Clause 3(ii) of the said Order are not applicable to the Company.
iii. The Company has not granted any loans secured or unsecured to companies firms Limited Liability Partnerships or other parties covered in the register maintained under Section 189 of the Act. Therefore the provisions of Clause 3(iii) of the said Order are not applicable to the Company.
iv. The Company has not granted any loan or provided any guarantee or security in connection with any loan taken by parties covered under section 185 of the Act. Therefore the provisions of section 185 are not applicable to the Company. The Company is registered as Core Investment Company with RBI. Thus the provision of Section 186 except sub-section (1) of the Act is not applicable to the Company. In our opinion and according to the information and explanations given to us during the year the Company has not made any investments through more than two layers of investment companies as mentioned in sub section (1) of Section 186 of the Act.
v. The Company has not accepted any deposits from the public within the meaning of directives issued by the Reserve Bank of India and sections 73 74 75 and 76 of the Act and the Rules framed there under to the extent notified. Therefore the provisions of Clause 3(v) of the said Order are not applicable to the Company.
vi. The Central Government of India has not specified the maintenance of cost records under sub-section (1) of Section 148 of the Act for any of the products of the Company. Therefore the provisions of Clause 3(vi) of the said Order are not applicable to the Company.
vii. (a) According to the information and explanations given to us and the records of the Company examined by us in our opinion the Company is generally regular in depositing undisputed statutory dues in respect of provident fund income tax and profession tax though there has been a slight delay in a few cases and is regular in depositing undisputed statutory dues including goods and service tax cess and other material statutory dues as applicable with the appropriate authorities. There are no undisputed amounts payable in respect of such applicable statutory dues as at March 31 2020 for a period of more than six months from the date they became payable.
(b) According to the information and explanations given to us and the records of the Company examined by us there are no dues of sales tax service-tax value added tax goods and service tax which have not been deposited on account of any dispute. The particulars of dues of income tax as at March 31 2020 which have not been deposited on account of a dispute is as under:
|Name of the statute||Nature of dues||Amount (Rs. crore)||Period to which the amount relates||Forum where the dispute is pending|
|Income tax Act 1961||Income Tax||12||A.Y. 2017-18||Commissioner of Income Tax Appeals Mumbai|
viii. According to the records of the Company examined by us & the information and explanation given to us and as per the additional terms of repayment wherever applicable the Company has not defaulted in repayment of loans or borrowings to any financial institutions or banks or dues to debenture holders except for the following instances of default in repayment of principal amounts and interest:
Amount of Default as at the Balance Sheet Date (Rs. in crore)
Period of Default (Days)
|Name of the lenders/ISIN ||Principal|
|1. Loans from Bank and financial institutions|
|Housing Development Finance||24|
|Axis Bank Limited||10|
|2. Debenture Holders - Series|
|INE013A07A33 *||1 070|
|INE013A077M0 *||1 500|
* Recalled during the year.
The Company did not have any loans or borrowing from government during the year.
ix. The Company has not raised any moneys by way of initial public offer or further public offer (including debt instruments). In our opinion and according to the information and explanations given to us the moneys raised by way of term loans have been applied for the purposes for which they were obtained.
x. Attention is invited to Note no. 41(f) of the standalone financial statements and para (b) of emphasis of matter paragraph in our report in addition thereto during the course of our examination of the books and records of the Company carried out in accordance with the generally accepted auditing practices in India and according to the information and explanations given to us we have neither come across any instance of material fraud by the Company or on the Company by its officers or employees noticed or reported during the year nor have we been informed of any such case by the Management.
xi. The Company has paid/ provided for managerial remuneration in accordance with the requisite approvals mandated by the provisions of Section 197 read with Schedule V to the Act.
xii. As the Company is not a Nidhi Company and the Nidhi Rules 2014 are not applicable to it the provisions of Clause 3(xii) of the Order are not applicable to the Company.
xiii. The Company has entered into transactions with related parties in compliance with the provisions of Sections 177 and 188 of the Act. The details of related party transactions have been disclosed in the standalone financial statements as required by the applicable Accounting Standard.
xiv. The Company has not made any preferential allotment or private placement of shares or fully or partly convertible debentures during the year. Accordingly the provisions of Clause 3(xiv) of the Order are not applicable to the Company.
xv. The Company has not entered into any non-cash transactions with its directors or persons connected with him. Accordingly the provisions of Clause 3(xv) of the Order are not applicable to the Company.
xvi. According to the information and explanations given to us the Company is registered as Core Investment Company under section 45-IA of the Reserve Bank of India Act 1934.
For Pathak H.D. & Associates LLP
Firm's Registration No: 107783W/ W100593
Vishal D. Shah
Membership No: 119303
Date : May 8 2020.