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Saurashtra Cement Ltd.

BSE: 502175 Sector: Industrials
NSE: SAURASHCEM ISIN Code: INE626A01014
BSE 00:00 | 03 Dec 71.45 0.35
(0.49%)
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70.05

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72.35

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NSE 05:30 | 01 Jan Saurashtra Cement Ltd
OPEN 70.05
PREVIOUS CLOSE 71.10
VOLUME 13779
52-Week high 138.90
52-Week low 44.00
P/E 8.63
Mkt Cap.(Rs cr) 501
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00
OPEN 70.05
CLOSE 71.10
VOLUME 13779
52-Week high 138.90
52-Week low 44.00
P/E 8.63
Mkt Cap.(Rs cr) 501
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

Saurashtra Cement Ltd. (SAURASHCEM) - Auditors Report

Company auditors report

To

The Members of Saurashtra Cement Limited

Report on the Standalone Financial Statements

Opinion

We have audited the accompanying standalone financial statements of Saurashtra CementLimited (‘the Company') which comprise the Balance Sheet as at March 31 2020 theStatement of Profit and Loss (including other Comprehensive Income) the Statement ofChanges in Equity and the Statement of Cash Flows for the year then ended and a summary ofsignificant accounting policies and other explanatory information (herein after referredto as ‘standalone financial statements').

In our opinion and to the best of our information and according to the explanationsgiven to us the aforesaid financial statements give the information required by theCompanies Act 2013 ("the Act") in the manner so required and give a true andfair view in conformity with the Indian Accounting Standards prescribed under section 133of the Act read with the Companies (Indian Accounting Standards) Rules 2015 as amended("Ind AS") and other accounting principles generally accepted in India of thestate of affairs of the Company as at March 31 2020 the profit and total comprehensiveincome changes in equity and its cash flows for the year ended on that date.

Basis for Opinion

We conducted our audit of the standalone financial statements in accordance with theStandards on Auditing (SAs) specified under section 143(10) of the Act. Ourresponsibilities under those Standards are further described in the Auditor'sResponsibilities for the Audit of the Standalone Financial Statements section of ourreport. We are independent of the Company in accordance with the Code of Ethics issued bythe Institute of Chartered Accountants of India (ICAI) together with the independencerequirements that are relevant to our audit of the standalone financial statements underthe provisions of the Act and the Rules made thereunder and we have fulfilled our otherethical responsibilities in accordance with these requirements and the ICAI's Code ofEthics. We believe that the audit evidence we have obtained is sufficient and appropriateto provide a basis for our audit opinion on the standalone financial statements.

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 standalone financialstatements as a whole and in forming our opinion thereon and we do not provide aseparate opinion on these matters. We have determined the matters described below to bethe general key audit matters to be communicated in our report.

Key Audit Matter Auditor's Response
Recognition of Deferred Tax Assets
The Company has recognized Deferred Tax Assets on tax credit (MAT) which involves significant judgment to determine whether there will be reasonable certainty of taxable income against which the tax credit will be utilized. Our audit procedures include the following substantive procedures:
We have considered this matter to be key audit matter considering the significant judgement involved in estimating future taxable income against which such assets can be realized. - Obtained details of completed tax assessments up to year ended March 31 2020 from management.
Refer Note No 18 to the Standalone Financial Statements - We involved our internal experts to review management's underlying assumptions in estimating the tax provision.
- Our internal experts also considered legal precedence and other rulings in evaluating management's position on these tax provisions.
- We evaluated the estimates of profitability made by the management on the basis of which it is considered that the company will have sufficient taxable income against which tax credit will be utilized.
- Verified that recognition of such assets is made in accordance with Ind AS 12 "Income Taxes".
Uncertain tax position under Indirect Tax Laws
The company has material tax litigations pending under various indirect tax laws. The litigation involves significant judgement to determine the possible outcome based on which accounting treatment is given to the disputed amount. Our audit procedures include the following substantive procedures:
We have considered these matters to be key audit matter given the magnitude of potential outflow of economic resources and uncertainty of potential outcome. - Obtained the details of uncertain tax position and gained understanding thereof.
Refer Note Nos 22 & 32 to the Standalone Financial Statements - Read and analyzed relevant communication with the authorities and legal consultants.
- We have perused the opinion of legal consultant obtained by the management on possible outcome of the litigation.
- Discussed with senior management and evaluated management's assumptions regarding provisions made.
- Verified that accounting treatment / disclosure in respect of pending litigations is in accordance with Ind AS 37 "Provisions Contingent Liabilities and Contingent Assets".
Impairment of Capital Work in Progress (CWIP)
The company has incurred the expenditure of Rs. 8107.17 Lakhs on expansion project in earlier years. Our audit procedures include the following substantive procedures:
The expenditure comprised of cost of imported plant & machineries (including related stores and spares) civil work and pre-operative expenses (including interest capitalized). Balance of Rs. 7892.10 Lakhs on March 31 2020 is shown under Capital Work in Progress in balance sheet. The project was suspended in the year 2005. - Obtained the details of assets and expenditure incurred in respect of expansion project.
However the company intends to install the assets at a later date depending upon the market condition. - Carried out physical verification of the assets and assessed their condition.
Considering this the valuation of assets has been done by obtaining report of project consultant. Based on the valuation report aggregate provision of Rs.4597.78 up to March 31 2020 has been made for impairment of the said assets which includes Rs. 56.64 Lakhs provision for the current year. - Discussed with senior management about their plan for utilization of the assets at a later date.
We have considered this matter to be key audit matter considering the significant judgement involved in valuation of assets for the purpose of determining Impairment. Refer Note No 2 to the Standalone Financial Statements - Assessed the valuation expert's competency and objectivity.
- Perused the valuation report of the valuation expert and reviewed methods and underlying assumptions on the basis of which valuation has been made.
- Verified the working of the amount of provision made for impairment of the assets.
- Verified that accounting treatment / disclosure in respect of impairment of assets is in accordance with Ind AS 36 "Impairment of Assets".
Estimation of Incentives to customers
The Company sells its products through various channels such as dealers and commission agents; (customers) and recognise liabilities related to incentives payable to them under various marketing schemes. Our audit procedures include the following substantive procedures:
As per the accounting policy of the Company the revenue is recognised upon transfer of control of goods to the customer and thus requires an estimation of the revenue taking into consideration the incentives as per the scheme. With regard to the determination of revenue the management is required to make significant estimates in respect of the followings: - Obtained an understanding from the management with regard to controls relating to recording of incentives and period end outstanding value of performance obligations and tested the operating effectiveness of such controls.
- The incentives linked to sales which will be given to the customers pursuant to schemes offered by the Company; - Tested the inputs used in the estimation of revenue in context of incentives.
- Benefits offered by the dealers to the ultimate consumers is also considered on behalf of the company. - Ensured the completeness of liabilities recognised by evaluating the parameters for the schemes.
The matter has been determined to be a key audit matter in view of the involvement of significant estimates by the management. Refer Note No 22 to the Standalone Financial Statements - Analysed past trends by comparing actuals with the estimates of earlier periods.
- Verified that accounting treatment is in accordance with Ind AS 115 "Revenue from Contracts with Customers".
Based on the above procedures we did not identify any significant deviation to assessment made by management in respect of estimation of liabilities for incentives.

Information Other than the Financial Statements and Auditor's Report Thereon

The Company's Board of Directors is responsible for the preparation of the otherinformation. The other information comprises the information included in the Board'sReport including Annexures to Board's Report and Shareholder's Information but does notinclude the 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 during thecourse of our audit or otherwise appears to be materially misstated. If based on the workwe have performed we conclude that there is a material misstatement of this otherinformation we are required to report that fact. We have nothing to report in thisregard.

Management's Responsibility for the Standalone Financial 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 total comprehencive income changes in equity and cashflows of the Company in accordance with the accounting principles generally accepted inIndia including the accounting standards specified under section 133 of the Act. Thisresponsibility also includes maintenance of adequate accounting records in accordance withthe provisions of the Act for safeguarding of the assets of the Company and for preventingand detecting frauds and other irregularities; selection and application of appropriateimplementation and maintenance of accounting policies; making judgements and estimatesthat are reasonable and prudent; and design implementation and maintenance of adequateinternal financial controls that were operating effectively for ensuring the accuracy andcompleteness of the accounting records relevant to the preparation and presentation ofthe financial statement that give a true and fair view and are free from materialmisstatement whether due to fraud or error.

In preparing the Standalone Financial Statements management 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 unlessmanagement either intends to liquidate the Company or to cease operations or has norealistic alternative but to do so. The Board of Directors are also responsible foroverseeing the Company's financial reporting process.

Auditor's Responsibilities for the Audit of the Financial Statements

Our objectives are to obtain reasonable assurance about whether the StandaloneFinancial Statements as a whole are free from material misstatement whether due to fraudor error and to issue an auditor's report that includes our opinion. Reasonable assuranceis a high level of assurance but is not a guarantee that an audit conducted in accordancewith SAs will always detect a material misstatement when it exists. Misstatements canarise from fraud or error and are considered material if individually or in theaggregate they could reasonably be expected to influence the economic decisions of userstaken on the basis 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 financial statementswhether due to fraud or error design and perform audit procedures responsive to thoserisks and obtain audit evidence that is sufficient and appropriate to provide a basis forour opinion. The risk of not detecting a material misstatement resulting from fraud ishigher than for one resulting from error as fraud may involve collusion forgeryintentional omissions misrepresentations or the override of internal control.

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

- Evaluate the appropriateness of accounting policies used and the reasonableness ofaccounting estimates and related disclosures made by management.

- Conclude on the appropriateness of management's use of the going concern basis ofaccounting 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 standalone 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 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 the Statement of Changes inEquity and the Statement of Cash Flows dealt with by this Report are in agreement with thebooks of account.

d) In our opinion the aforesaid Standalone Financial Statements comply with the IndianAccounting Standards prescribed under Section 133 of the Act read with Rule 7 of theCompanies (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 A. Our report expresses an unmodified opinion on theadequacy and operating effectiveness of the Company's internal financial controls overfinancial reporting.

g) With respect to the other matters to be included in the Auditor's Report inaccordance with the requirements of section 197(16) of the Act as amended we reportthatin our opinion and to the best of our information and according to the explanationsgiven to us the remuneration paid by the Company to its Managing and Executive Directorsduring the year is in accordance with the provisions of section 197 of the Act.

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 2014 as amended inour opinion and to the best of our information and according to the explanations given tous:

(i) The Company has disclosed the impact of pending litigations on its financialposition in its Standalone Financial statements - Refer Note 32 to the StandaloneFinancial statements.

(ii) The Company did not have any long-term contracts including derivative contractsfor which 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 during the year ended March 31 2020.

2. As required by the Companies (Auditor's Report) Order 2016 ("the Order")issued by the Central Government in terms of section 143 (11) of the Act we give in the AnnexureB a statement on the matters specified in the paragraphs 3 and 4 of the order.

For Manubhai & Shah LLP
Chartered Accountants
ICAI Firm Registration No. 106041W /W100136
(K C Patel)
Partner
Place : Ahmedabad Membership No. 30083
Date : May 18 2020 UDIN: 20030083AAAABG9098

ANNEXURE- A

TO THE INDEPENDENT AUDITOR'S REPORT

(Referred to in paragraph 1(f) under "Report on Other Legal and RegulatoryRequirements" section of our report to the members of Saurashtra Cement Limited ofeven 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")

In conjunction with our audit of the Standalone Financial statements of SaurashtraCement Limited (The Company) as of and for the year ended March 31 2020 we have alsoaudited the internal financial controls over financial reporting of the Company.

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 control statedin the Guidance Note on Audit of Internal Financial Controls over Financial Reportingissued 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 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.

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 Guidance Note on Audit of Internal Financial Controls over Financial Reporting(the "Guidance Note") and the Standards on Auditing issued by ICAI and deemedto be prescribed under section 143(10) of the Companies Act 2013 to the extentapplicable to an audit of internal financial controls both applicable to an audit ofInternal Financial Controls and both issued by the ICAI. Those Standards and the GuidanceNote require that we comply with ethical requirements and plan and perform the audit toobtain reasonable assurance about whether adequate internal financial controls overfinancial 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. Acompany's internal financial control over financialreporting includes those policies and procedures that:

1) pertain to the maintenance of records that in reasonable detail accurately andfairly reflect the transactions and dispositions of the assets of the company;

2) provide reasonable assurance that transactions are recorded as necessary to permitpreparation of financial statements in accordance with generally accepted accountingprinciples and that receipts and expenditures of the company are being made only inaccordance with authorizations of management and directors of the company; and

3) provide reasonable assurance regarding prevention or timely detection ofunauthorized acquisition use or disposition of the company's assets that could have amaterial 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 control system over financial reporting and such internal financial controlsover financial reporting were operating effectively as at March 31 2020 based on theinternal control over financial reporting criteria established by the Company consideringthe essential components of internal control stated in the Guidance Note on Audit ofInternal Financial Controls Over Financial Reporting issued by the Institute of CharteredAccountants of India.

For Manubhai & Shah LLP
Chartered Accountants
ICAI Firm Registration No. 106041W /W100136
(K C Patel)
Partner
Place : Ahmedabad Membership No. 30083
Date : May 18 2020 UDIN: 20030083AAAABG9098

ANNEXURE-B

TO THE INDEPENDENT AUDITOR'S REPORT

(Referred to in paragraph 2 under "Report on Other Legal and RegulatoryRequirements" section of our report to the members of Saurashtra Cement Limited ofeven date)

Report on the Companies (Auditor' Report) Order 2016 issued in terms of section 143(11) of the Companies Act 2013(‘the Act') of Saurashtra Cement Limited (‘theCompany')

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

(b) The Company has a program of verification to cover all the items of fixed assets ina phased manner of three years which in our opinion is reasonable having regard to thesize of the Company and the nature of its assets. Pursuant to the program portion of thefixed assets were physically verified by the Management during the year. According toinformation and explanation given to us no material discrepancies were noticed on suchverification.

(c) According to the information and explanations given to us and on the basis of ourexamination of the records of the Company the title deeds of immovable properties otherthan self-constructed immovable properties (buildings) are held in the name of Company.The self-constructed Building having Gross book value of Rs.2411.45 Lakhs (Net BlockRs.120.57 Lakhs) is on the land of Gujarat Maritime Board which has given license. Thepresent agreement is for 10 years effective from November 01 2015 and valid upto October31 2025.

(ii) Physical verification of inventory has been conducted at reasonable intervals bythe management and no material discrepancies were noticed.

(iii) (a) According to information and explanations given to us the Company hasgranted unsecured loan to its subsidiary which is a company covered in the registermaintained under Section 189 of the Act. The Company has not granted any other loanssecured or unsecured to firms Limited Liabilities Partnerships or other parties coveredunder Section 189 of the Act.

(b) In respect of aforesaid loan the rate of interest and terms of repayment have beenstipulated. Considering the amount involved and the fact that is given to a subsidiary andfor the purpose of which it is given in our opinion the same is not prima facieprejudicial to the interest of 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 Act with respectto the loans and investments made. The company has not given any guarantee or provided anysecurity in connection with the loan to any person or other body corporate andaccordingly the question of commenting on compliance with the provisions in respectthereof does not arise.

(v) The Company has not accepted deposits during the year and does not have anyunclaimed deposits as at March 31 2020 and therefore the provisions of the clause 3(v)of the Order are not applicable to the Company.

(vi) We have broadly reviewed the books of account maintained by the Company in respectof cement produced by the Company where pursuant to the rules made by the CentralGovernment of India the maintenance of cost records has been prescribed under sub-section(1) of Section 148 of the Act and are of the opinion that prima facie the prescribedaccounts and records have been made and maintained. We have not however made a detailedexamination of the records with a view to determine whether they are accurate or complete.

(vii) (a) According to the information and explanations given to us and based onrecords of the Company examined by us the Company has generally been regular indepositing undisputed statutory dues including Provident Fund Employees' StateInsurance Income Tax Customs Duty income tax deducted at source Goods and Service Taxand other material statutory dues as applicable.

According to the information and explanations given to us and the records of theCompany examined by us in our opinion no undisputed amounts payable were in arrears asat March 312020 for a period of more than six months from the date they became payable.As informed to us the provisions of the Employees' State Insurance Act are not applicableto the Company.

(b) According to the information and explanations given to us and the records of theCompany examined by us the details of disputed statutory dues of Income Tax Service TaxSales Tax Value Added Tax Excise Duty and other material statutory dues which have notbeen deposited as at March 31 2020 on account of dispute are as under:

Name of the Statute Nature of the Dues Amount (Rs. In Lakhs)* Year to which amount relates Forum where dispute is pending
Central Excise Act 1944 Excise Duty 174.05 2006-07 & 2007-08 High Court of Gujarat
1142.89 2007-08 to 2016-17 CESTAT
405.57 2009-10 to 2013-14 CESTAT
The Finance Act 1994 Service Tax 4.31 2006-07 to 2011-12 Jt.Commissioner Excise Bhavnagar
Customs Act 1962 Custom Duty 1218.58 2011-12 & 2012-13 CESTAT
Gujarat Sales Tax Act 1969 Sales Tax 2.09 2005-06 Jt.Commissioner Commercial Tax Rajkot
Maharashtra Value Added Tax Act 2002 Value Added Tax 1.32 2015-16 Jt.Commissioner (A) Mumbai (#)

* Amount Includes the amount of Interest to the extent provided by the Company in thebooks of account.

# Order is passed by the assessing officer however appeal is yet to be filed beforeappellate authority.

(viii) To the best of our knowledge and according to information and explanations givento us the Company has not defaulted in the repayment of loans to banks. The Company hasnot taken any loans either from financial institution or Government or has not issued anydebentures.

(ix) The Company has raised money by way of Term Loan from Banks and the proceeds wereapplied for the purposes for which those are raised. The Company has not raised moneys byway of initial public offer or further public offer (Including debt instruments).

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

(xi) In ouropinion and according to information and explanation given to us theCompany has paid/provided managerial remuneration in accordance with the requisiteapprovals mandated by the provisions of Section 197 read with Schedule V to the Act.

(xii) The Company is not a Nidhi Company and hence reporting under clause 3(xii) of theOrder is not applicable to the Company.

(xiii) In our opinion and according to the information and explanations given to usthe Company is in compliance with Sections 177 and 188 of the Companies Act 2013 whereapplicable for all transactions with the related parties and the details of related partytransactions have been disclosed in the standalone financial statements as required by theapplicable accounting standards.

(xiv) During the year the Company has not made any preferential allotment or privateplacement of shares or fully or partly paid convertible debentures and hence reportingrequirement under paragraph 3 (xiv) of the order is not applicable to the Company.

(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 any non-cashtransactions with Directors or persons connected to directors and hence provisions ofSection 192 of the Companies Act 2013 are not applicable to the Company.

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

For Manubhai & Shah LLP
Chartered Accountants
ICAI Firm Registration No. 106041W /W100136
(K C Patel)
Partner
Place : Ahmedabad Membership No. 30083
Date : May 18 2020 UDIN: 20030083AAAABG9098

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