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S.A.L Steel Ltd.

BSE: 532604 Sector: Metals & Mining
NSE: SALSTEEL ISIN Code: INE658G01014
BSE 00:00 | 23 Oct 2.68 0.24
(9.84%)
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2.66

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2.68

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2.61

NSE 00:00 | 23 Oct 2.75 0.25
(10.00%)
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2.75

HIGH

2.75

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2.50

OPEN 2.66
PREVIOUS CLOSE 2.44
VOLUME 8200
52-Week high 4.36
52-Week low 1.60
P/E 1.49
Mkt Cap.(Rs cr) 23
Buy Price 2.62
Buy Qty 5000.00
Sell Price 2.68
Sell Qty 4500.00
OPEN 2.66
CLOSE 2.44
VOLUME 8200
52-Week high 4.36
52-Week low 1.60
P/E 1.49
Mkt Cap.(Rs cr) 23
Buy Price 2.62
Buy Qty 5000.00
Sell Price 2.68
Sell Qty 4500.00

S.A.L Steel Ltd. (SALSTEEL) - Auditors Report

Company auditors report

To the Members of

S.A.L STEEL LIMITED

Report on the Audit of the Standalone Financial Statements

Opinion

We have audited the accompanying standalone financial statements of M/s S.A.L STEELLIMITED (''the Company") which comprise the balance sheet as at March 31 2019and the statement of profit and loss (including other comprehensive income) statement ofchanges in equity and statement of cash flows for the year then ended and notes to thefinancial statements including a summary of significant accounting policies and otherexplanatory information.

In our opinion and to the best of our information and according to the explanationsgiven to us the aforesaid standalone financial statements give the information requiredby the Companies Act 2013 (the Act) in the manner so required and give a true and fairview in conformity with the accounting principles generally accepted in India includingIndian Accounting standards (Ind AS) specified under section 133 of the Act of the stateof affairs (financial Position )of the Company as at March 31 2019 and its losses(financial performance including other comprehensive income) its Cash flows and changesin equity for the year ended on that date.

Basis for Opinion

We conducted our audit in accordance with the Standards on Auditing specified undersection 143(10) of the Act. Our responsibilities under those Standards are furtherdescribed in the Auditor's Responsibilities for the Audit of the Financial Statementssection of our report. We are independent of the Company in accordance with the Code ofEthics issued by the Institute of Chartered Accountants of India (ICAI) together with theethical requirements that are relevant to our audit of the financial statements under theprovisions of the Act and the Rules thereunder and we have fulfilled our other ethicalresponsibilities in accordance with these requirements and the Code of Ethics. We believethat the audit evidence we have obtained is sufficient and appropriate to provide a basisfor our opinion.

Material Uncertainty Related to Going Concern

The Company's current liabilities exceeded its current assets as at the previous yearbalance sheet date. These conditions indicate the existence of a material uncertainty thatmay cast significant doubt about the Company's ability to continue as a going concern.However considering the profit earned by the company in the year ended on 31st March 2019and considering the management viewthe financial results of the Company have beenprepared on a going concern basis.(Refer Note No 31 of notes forming part of Standalonefinancial statement)

Key Audit Matters

Key audit matters are those matters that in our professional judgment were of mostsignificance in our audit of the standalone financial statements of the current period.These matters were addressed in the context of our audit of the financial statements as awhole and in forming our opinion thereon and we do not provide a separate opinion onthese matters.

Key Audit Matter:

Description of Key audit Matter Our response and results
REVENUE (Refer note 44) to the standalone financial statements) Our key audit procedures to assess the recognition of revenue on sale of goods included the following:
Revenue of the company comprises of sale of Sponge Iron Ferro alloys sale of power. The company sells its products directly to the end use customers. • We assessed the appropriateness of the Company's revenue recognition policies including those related to discounts and incentives;
Revenue recognition is a significant audit risk across the company. Specifically there is a risk that revenue is recognized on sale of goods before the control in the goods is transferred. • We obtained an understanding of process and assessed the design implementation and operating effectiveness of management's key internal controls in relation to revenue recognition from sale of goods. We also tested the Company's controls over timing of revenue recognition;
• We also tested on a sample basis whether specific revenue transactions around the year end had been recognized in the appropriate period on the basis of the terms of sale of the contract particularly with reference to the transfer of control in the goods in question with regard to the year end transactions.
Description of Key audit Matter Our response and results
We inspected key customer contracts/ purchase orders to identify terms and conditions related to acceptance of goods and the right to return and assessing the Company's revenue recognition policies with reference to the requirements of the prevailing accounting standards;
Litigations and claims Our audit procedures inter alia included following:
(Refer note 30A) to the standalone financial statements) - Discussed disputed litigation matters with the company's management.
The cases are pending with multiple tax authorities like Service tax Excise sales tax. & customs . and there are claims against the company which have not been acknowledged as debt by the company. - Evaluated the management's judgment of tax risks estimates of tax exposures other claims and contingencies. Past and current experience with the tax authorities and management's correspondence/response including on the claims lodged by customers were used to assess the appropriateness of management's best estimate of the most likely outcome of each uncertain contingent liability.
In normal course of business financial exposures may arise from pending proceedings and from claims of the customers not acknowledged as debt by the company. Whether a claim needs to be recognized as liability or disclosed as contingent liability in the financial statements is dependent on a number of significant assumptions and judgments. The amounts involved are potentially significant and determining the amount if any to be recognised or disclosed in the financial statements is inherently subjective.
We have considered Litigations and claims a Key Audit Matter as it requires significant management judgement including accounting estimates that involves high estimation uncertainty. - Critically assessed the entity's assumptions and estimates in respect of claims included in the contingent liabilities disclosed in the financial statements. Also assessed the probability of negative result of litigation and the reliability of estimates of related obligations.
Conclusion:
Based on the procedures described above we did not find any material exceptions to the management's assertions and treatment presentation & disclosure of the subject matter in the standalone financial statements.

Emphasis of Matter

1. The Company's current liabilities exceeded its current assets as at the previousyear balance sheet date. These conditions indicate the existence of a material uncertaintythat may cast significant doubt about the Company's ability to continue as a goingconcern. However considering the profit earned by the company in the year ended on 31stMarch 2019 and considering the management view the financial results of the Company havebeen prepared on a going concern basis. (Refer Note No 31 of notes forming part ofStandalone financial statement)

2. Financial statements describes about the Non disclosure of Reportable Segments asrequired under Indian Accounting Standard – 108 'Operating Segments'. As IND AS 108Operating Segments mandates the disclosure requirements there is no impact on thefinancial results due to non disclosure. (Refer Note No 32 of notes forming part ofStandalone financial statement)

3. During the Year under review the company has written off an amount of Rs. 912.32Lakhs paid as advances for capital projects shown under the heading of "Long termloans and advances" up to the Financial year 2017-18. (Refer Note No 35 of notesforming part of Standalone financial statement)

4. The balance confirmation from the suppliers customers as well as to various loansor advances given have been called for but the same are awaited till the date of audit.Thus the balances of receivables trade payables as well as loans and advances have beentaken as per the books of accounts submitted by the company and are subject toconfirmation from the respective parties. (Refer Note No 38 of notes forming part ofStandalone financial statement)

5. During the year under ended on 31st March 2019 the company has carried out a technoeconomic assessment for the valuations of its Capital Projects to identify the impairmentloss and provision thereof if any. Based on the said techno economic assessment of thecapital projects the company has provided Rs 2001.00 Lakhs as impairment of Capital workin progress and the same is shown as Exceptional item in the Standalone statement ofProfit and loss account. The same is in accordance with Indian Accounting Standard –36 ' IMPAIRMENT OF ASSETS' which states that impairment loss is recognized when thecarrying amount of an assets exceeds its recoverable amount. (Refer Note No 40 of notesforming part of Standalone financial statement)

Our opinion is not Modified on the above matters.

Information other than the Financial Statements and Auditor's Report thereon

The Company's Board of Directors is responsible for the other information. The otherinformation comprises the information included in the Annual report. but does not includethe financial statements and our auditor's report thereon.

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

In connection with our audit of the financial statements our responsibility is to readthe other information and in doing so consider whether the other information ismaterially inconsistent with the financial statements or our knowledge obtained in theaudit or otherwise appears to be materially misstated. If based on the work we haveperformed we conclude that there is a material misstatement of this other information weare required to report that fact. We have nothing to report in this regard.

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 Act with respect to the preparation of these standalone financial statementsthat give a true and fair view of the state of affairs (financial position)Profit orloss(financial performance including other comprehensive income) changes in equity andcash flows of the Company in accordance with the accounting principles generally acceptedin India including the Indian Accounting Standards ('Ind AS') specified under section 133of the Act. This responsibility also includes maintenance of adequate accounting recordsin accordance with the provisions of the Act for safeguarding of the assets of the Companyand 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 statements that give a true and fair view and are free from materialmisstatement whether due. to fraud or error.

In preparing the financial statements management is responsible for assessing theCompany's ability to continue as a going concern disclosing as applicable mattersrelated to going concern and using the going concern basis of accounting unless managementeither intends to liquidate the Company or to cease operations or has no realisticalternative but to do so.

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

Auditors' 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 error.and 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 withStandards on Auditing will always detect a material misstatement when it exists.Misstatements can arise from fraud or error and are considered material if; individuallyor in the aggregate they could reasonably be expected to influence the economic decisionsof users taken on the basis of these financial statements

As part of an audit in accordance with Standards on Auditing we exercise professionaljudgment and maintain 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 Act we are also responsible for expressing our opinion on whether the company hasadequate internal financial controls system in place and the operating effectiveness ofsuch 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 statement 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.

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 section 197(16) of the Act we report that the company has paidremuneration to its directors during the year in accordance with the provisions of andlimits laid down under section 197 read with schedule V to the Act. The remuneration paidto any director is not in excess of the limit laid down under section 197 of the Act. TheMinistry of Corporate Affairs has not prescribed other details under Section 197(16) whichare required to be commented upon by us.

2. 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 Act we give in the "Annexure A" a statement on the matters specified inparagraphs 3 and 4 of the Order.

3. 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 Statement of Changes in

Equity and the Statement of Cash Flow Statement dealt with by this Report are inagreement with the. books of account.

d. The matter described under the Emphasis of Matters paragraph above in our opinionmay have an adverse effect on the functioning of the Company

e. In our opinion the aforesaid standalone financial statements comply with the IndianAccounting Standards specified under section 133 of the Act read with Rule 7 of theCompanies (Accounts) Rules 2014.

f. On the basis of written representations received from the directors as on March312019 taken on record by the Board of

Directors none of the Directors is disqualified as on March 312019 from beingappointed as a director in terms of Section 164(2) of the Act.

g. With respect to the adequacy of the internal financial controls over financialreporting of the Company and the operating effectiveness of such controls refer to ourseparate Report in "Annexure B".Our report express an unmodified opinion on theadequacy and operating effectiveness of the company's internal financial control overfinancial reporting.

h. 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 2014as amended in our opinion and to the best of ourinformation and according to the explanations given to us:

i. The Company has disclosed the impact of pending litigations on its financialposition in the standalone Financial

Statements ( Refer Note No 30 Ato the Standalone Financial Statements.)

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

iii. There were no amounts which were required to be transferred to the InvestorEducation and Protection Fund by the Company.

For Parikh & Majmudar
Chartered Accountants
FR No. 107525W
Sd/-
[C.A (Dr) Hiten M. Parikh]
Place:Ahmedabad PARTNER
Date: 30/05/2019 Membership No. 40230

ANNEXURE A –TO THE INDEPENDENT AUDIT REPORT

OF EVEN DATE TO THE MEMBERS OF S.A.L STEEL LIMITED

ON THE STANDALONE FIANCIAL STATEMENTS FOR THE YEAR ENDED 31st MARCH 2019

(i) In respect of its PropertyPlant & Equipments:

(a) The Company has maintained proper records showing full particulars includingquantitative details and situation of Property Plant & Equipments on the basis ofavailable information.

(b) As explained to us major portion of Property Plant & Equipments arephysically verified by the management during the year in accordance with a phased programof verification adopted by company. in our opinion the frequency of verification isreasonable having regard to the size of the Company and nature of its assets. As informedto usno material discrepancies were noticed on such physical verification.

(c) According to the information and explanation given to us and on the basis of ourexamination of records of the company title deeds of the immovable properties held are inthe name of the company.

(ii) As explained to us inventories(excluding goods in transit and goods lying atport) were physically verified by management at reasonable intervals during the year. Inour opinion the frequency of the verification is reasonable. The discrepancies noticed onverification between the physical stocks and the book records were not material.

(iii) In respect of loans Secured or unsecured granted by the company to thecompanies firms limited liability partnership or other parties covered in the registermaintained u/s 189 of the companies Act 2013:

According to the information and explanations given to us and on the basis of recordsproduced before usthe company has not granted any loan secured or unsecured to thecompanieslimited liability partnership or firms or other parties covered in the registermaintained u/s 189 of the companies Act2013 and hence sub-clause (a)&(b) & (c) ofparagraph 3 of companies auditor's report order 2016 are not applicable to the company.

(iv) According to the information and explanations given to us the company has notmade any investment or given any loans during the year under review Accordingly paragraph3(iv) of the Order is not applicable.

(v) The Company has not accepted any deposits from the public.

(vi). We have broadly reviewed the books of accounts maintained by the company pursuantto the rules made by the Central

Government of India for the maintenance of Cost records specified under section 148 ofCompanies Act 2013 and are of the opinion that prima facie the prescribed accounts &records have been made and maintained. We have however not made a detailed examination ofthe cost records with a view to determine whether they are accurate or complete.

(vii) : (a) According to the information and explanation given to us and on the basisof examination of the records of the Company amounts deducted/ accured in the books ofaccounts in respect of undisputed statutory dues including provident fund ESICincome-tax sales tax Goods & ServIce Tax service tax duty of customs duty ofexcise value added tax cess and other statutory dues have not been generally regularlydeposited during the year with the appropriate authorities.

According to the information and explanation given to us no undisputed amounts payablein respect of provident fund ESIC income-tax Goods & ServIce Tax service tax duty of customs duty of excise cess and other statutory dues were resaid dues wereoutstanding as at 31st March2019 for a period of more than six months from the date ofbecoming payable except dues for (1) deferred sales tax liability amounting to Rs. 22.63lakhs(2) dues of value added tax (VAT) during the year to the tune of Rs. 2523.25 lakhs.-

b) On the basis of records produced before us for our verification and according to theinformation and explanations given to us the details of disputed dues that have not beendeposited as on 31st March 2019 on account of matters pending before the appropriateauthorities are as under:

Sr. Name of the statue Nature of Dues Financial year to which it relates From where the dispute is pending Amount under dispute not yet deposited (Net of Payments) (in Rs lakhs.)
1 Central Excise Act1994 Central Excise Duty 2006-07 Appellate Tribunal Ahmedabad 5.56
2 Central Excise Act1994 Central Excise Duty 2008-09 Appellate Tribunal Ahmedabad 10.41
3 Custom Act 1962 Custom Duty 2011-12 Appellate Tribunal Ahmedabad 50.00
4 Central Excise Act1994 Central Excise Duty 2012-13 Appellate Tribunal Ahmedabad 449.85
5 Central Excise Act1994 Central Excise Duty 2008-09 to 2010-2011 Supreme Court 590.14
6 Central Excise Act1994 Central Excise Duty 2005-06 to sep 2014 Central Excise Commissioner 626.28
7 Gujarat Value Added Tax Act2003 Value Added Tax 2011-12 Jt. Value Added Tax Commissioner(Appeal) 220.12
8 Gujarat Value Added Tax Act2003 Value Added Tax 2013-14 Jt. Value Added Tax Commissioner Appeal) 253.70
9 Central Service Tax Act1994 Service Tax 2017-18 Asst. Commissioner Audit Gandhi dham 33.09
10 Central Service Tax Act1994 Service Tax 2016-17 & 2017-18 Deputy commissioner Audit Rajkot 15.03
11 Gujarat Value Added Tax Act2003 Value added Tax 2014-15 Jt. Value Added Tax Commissioner (Appeal) 230.73

(viii) According to information & explanations given to us the company has notdefaulted in repayment of its dues to Financial Institutions. The company does not haveany borrowings from debenture holders Banks or Government

(ix) The Company did not raise any money by way of initial public offer or furtherpublic offer (including debt instruments) and term loans during the year. Accordinglyparagraph 3 (ix) of the Order is not applicable.

(x) According to the information and explanations given to us no fraud by the Companyor on the Company by its officers or employees has been noticed or reported during thecourse of our audit.

(xi) According to the information and explanations give to us and based on ourexamination of the records of the Company the Company has paid/provided for managerialremuneration in accordance with the requisite approvals mandated by the provisions ofsection 197 read with Schedule V to the Act.

(xii) In our opinion and according to the information and explanations given to us theCompany is not a nidhi company. Accordingly paragraph 3(xii) of the Order is notapplicable.

(xiii) According to the information and explanations given to us and based on ourexamination of the records of the Company transactions with the related parties are incompliance with sections 177 and 188 of the Act where applicable and details of suchtransactions have been disclosed in the financial statements as required by the applicableaccounting standards.

(xiv) According to the information and explanations given to us and based on ourexamination of the records of the Company the Company has not made any preferentialallotment or private placement of shares or fully or partly convertible debentures duringthe year.

(xv) According to the information and explanations given to us and based on ourexamination of the records of the Company the Company has not entered into non-cashtransactions with directors or persons connected with him. Accordingly paragraph 3(xv) ofthe Order is not applicable.

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

For Parikh & Majmudar
Chartered Accountants
FR No. 107525W
Sd/-
[C.A (Dr) Hiten M. Parikh]
Place:Ahmedabad PARTNER
Date: 30/05/2019 Membership No. 40230

Annexure B to the Independent Auditor's Report of Even Date to the Members of S.A.LSTEEL LIMITED on the Standalone Financial Statements of the year ended on 31st March 2019

Independent Auditor's Report on the Internal Financial Controls under Clause (i) ofSub-section 3 of Section 143 of the Companies Act 2013 ("the Act")

In conjunction with our audit of the standalone financial statements of M/s S.A.LSTEEL LIMITED ("the Company") as at and for the year ended 31st March 2019We have audited the internal financial controls over financial reporting of the company asof that date.

Management's Responsibility for Internal Financial Controls

The Company's Board of Directors is responsible for establishing and maintaininginternal financial controls based on the internal control over financial reportingcriteria established by the Company considering the essential components of internalcontrol stated in the Guidance Note on Audit of Internal Financial Controls over FinancialReporting issued by the Institute of Chartered Accountants of India (‘ICAI'). Theseresponsibilities include the design implementation and maintenance of adequate internalfinancial controls that were operating effectively for ensuring the orderly and efficientconduct of the company's business including adherence to company's policies thesafeguarding 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 Act.

Auditor's' 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 Standards on Auditing issued by ICAI and deemed to be prescribed under section143(10) of the Act to the extent applicable to an audit of internal financial controlsover financial reporting and the Guidance Note issued by ICAI. 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 judgment 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 authorizations ofmanagement and directors of the company; and (3) provide reasonable assurance regardingprevention or timely detection of unauthorized acquisition use or disposition of thecompany's assets that could have a material effect on the financial statements.

Inherent Limitations of Internal Financial Controls over 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 the Company has in all material respects an adequate internalfinancial controls system over financial reporting and such internal financial controlsover financial reporting were operating effectively as at 31st March 2019 based on theinternal control over financial reporting criteria established by the Company consideringthe essential components of internal control stated in the Guidance Note issued by theICAI.

For Parikh & Majmudar
Chartered Accountants
FR No. 107525W
Sd-
[C.A (Dr) Hiten M. Parikh]
Place:Ahmedabad PARTNER
Date: 30/05/2019 Membership No. 40230

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