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Savita Oil Technologies Ltd.

BSE: 524667 Sector: Industrials
NSE: SOTL ISIN Code: INE035D01012
BSE 00:00 | 08 Jul 692.00 0
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695.00

HIGH

697.90

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691.10

NSE 09:48 | 09 Jul 695.00 4.90
(0.71%)
OPEN

699.00

HIGH

700.00

LOW

695.00

OPEN 695.00
PREVIOUS CLOSE 692.00
VOLUME 576
52-Week high 1050.55
52-Week low 497.00
P/E 8.98
Mkt Cap.(Rs cr) 974
Buy Price 681.00
Buy Qty 3.00
Sell Price 692.00
Sell Qty 6.00
OPEN 695.00
CLOSE 692.00
VOLUME 576
52-Week high 1050.55
52-Week low 497.00
P/E 8.98
Mkt Cap.(Rs cr) 974
Buy Price 681.00
Buy Qty 3.00
Sell Price 692.00
Sell Qty 6.00

Savita Oil Technologies Ltd. (SOTL) - Auditors Report

Company auditors report

To the Members of Savita Oil Technologies Limited Report on the Standalone FinancialStatements

OPINION

We have audited the accompanying standalone financial statements of SAVITA OILTECHNOLOGIES LIMITED ("the Company") which comprise the Balance Sheet as at 31stMarch 2019 the Statement of Profit and Loss (including Other ComprehensiveIncome) the Statement of Changes in Equity and the Statement of Cash Flows for the yearended on that date and a summary of the significant accounting policies and otherexplanatory information (hereinafter referred to as "the standalone financialstatements").

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 trueand fair view in conformity with the Indian Accounting Standards prescribed under section133 of the Act read with the Companies (Indian Accounting Standards) Rules 2015 asamended ("Ind AS") and other accounting principles generally accepted in Indiaof the state of affairs of the Company as at 31st March 2019 the profit andtotal comprehensive income changes in equity and its cash flows for the year ended onthat 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 ethical /independence requirements that are relevant to our audit of the standalone financialstatements under the provisions of the Act and the Rules made thereunder and we havefulfilled our other ethical responsibilities in accordance with these requirements and theICAI's Code of Ethics. We believe that the audit evidence we have obtained is sufficientand appropriate to provide a basis for our audit opinion on the standalone financialstatements.

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 key audit matters to be communicated in our report.

Sr. Key Audit Matter No. Auditor's Response
1. Accuracy of recognition measurement presentation and disclosures of revenues and other related balances in view of adoption of Ind AS 115 "Revenue from Contracts with Customers" (new revenue accounting standard) We assessed the Company's process to identify the impact of adoption of the new revenue accounting standard.
The application of the new revenue accounting standard involves certain key judgements relating Our audit approach consisted testing of the design and operating effectiveness of the internal controls and substantive testing as follows;
to identification of distinct performance obligations determination of transaction price of the identified performance obligations the appropriateness of the basis used to measure revenue recognised over 1. Evaluated the design of internal controls relating to implementation of the new revenue accounting standard.
a period. Additionally new revenue accounting standard contains disclosures which involve collation of information in respect of disaggregated revenue and periods over which the remaining performance obligations will be satisfied subsequent to the balance sheet date. 2. Selected a sample of continuing and new contracts and tested the operating effectiveness of the internal control relating to identification of the distinct performance obligations and determination of transaction price. We carried out a combination of procedures involving enquiry and observation reperformance and inspection of evidence in respect of operation of these controls.
3. Selected a sample of continuing and new contracts and performed the following procedures:
• Read analysed and identified the distinct performance obligations in these contracts.
• Compared these performance obligations with those identified and recorded by the Company.
• Considered the terms of the contracts to determine basis of recognising the revenue 'at a point' or 'over the period the transaction price including any variable consideration to verify the transaction price used to compute revenue and to test the basis of estimation of the variable consideration.
• Verified whether the revenue has been recognised only post the fulfilment of the performance obligations and related conditions.
• Verified whether the revenue is appropriately recognised only after the transfer of control over the said goods.
2. Inventory valuation and consumption of raw and packing materials: We have performed the following procedures in relation to the accuracy of recorded consumption and inventory:
Accuracy of recording of inventory & related consumption at appropriate values. Understood evaluated and tested the key controls over the recording of inventory and booking of consumption.
We selected a sample of transactions and:
• Checked the goods receipt notes and material issue slips on a sample basis to ensure correct recording of materials receipts & consumption.
• Tested and verified the weighted average rate of inputs at which consumption was recorded.
• Tested and verified the Overhead absorption rate calculation used for inventory valuation.
• Reviewed the process of physical verification of inventories carried out by the management at various locations by participating in the said process.
• Verified the reports of physical verification of inventory carried out by the management and corrective actions taken to rectify the identified discrepancies (if any).
3. Evaluation of uncertain tax positions: We have performed the following procedures:
The Company has material uncertain tax positions Obtained understanding of key uncertain tax positions;
including matters under dispute which involves significant judgment to determine the possible outcome of these disputes. Obtained details of completed tax assessments and demands upto the year ended 31st March 2019 from the management;
We have;
i. Discussed with management and evaluated the management's underlying key assumptions in estimating the tax provision;
ii. Assessed management's estimate of the possible outcome of the disputed cases; and
iii. Considered legal precedence and other rulings in evaluating management's position on these uncertain tax positions.
Additionally considered the effect of new information in respect of uncertain tax positions as at 1st April 2018 to evaluate whether any change was required to management's position on these uncertainties.

INFORMATION OTHER THAN THE STANDALONE 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 ManagementDiscussion and Analysis Board's Report including Annexures to Board's Report BusinessResponsibility Report Corporate Governance and Shareholder's Information but does notinclude the standalone financial statements and our auditor's report thereon.

Our opinion on the standalone financial statements does not cover the other informationand we do not express any form of assurance conclusion thereon.

In connection with our audit of the standalone financial statements our responsibilityis to read the other information identified above when it becomes available and in doingso consider whether the other information is materially inconsistent with the standalonefinancial statements or our knowledge obtained during the course of our audit or otherwiseappears to be materially misstated.

When we read other information if we conclude that there is a material misstatementtherein we are required to communicate the matter to those charged with governance anddescribe actions applicable in the applicable laws and regulations.

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 Act with respect to the preparation of these standalone financial statementsthat give a true and fair view of the financial position financial performance totalcomprehensive income changes in equity and cash flows of the Company in accordance withthe Ind AS and other accounting principles generally accepted in India. Thisresponsibility also includes maintenance of adequate accounting records in accordance withthe provisions of the Act for safeguarding the assets of the Company and for preventingand detecting frauds and other irregularities; selection and application of appropriateaccounting policies; making judgments and estimates that are reasonable and prudent; anddesign implementation and maintenance of adequate internal financial controls that wereoperating effectively for ensuring the accuracy and completeness of the accountingrecords relevant to the preparation and presentation of the standalone financialstatements that give a true and fair view and are free from material misstatement whetherdue 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 no realisticalternative but to do so.

The Board of Directors are responsible for overseeing the Company's financial reportingprocess.

AUDITOR'S RESPONSIBILITIES FOR THE AUDIT OF THE STANDALONE 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 standalone financial statements. As part of an audit inaccordance with SAs we exercise professional judgment and maintain professionalskepticism throughout the audit. We also:

• Identify and assess the risks of material misstatement of the standalonefinancial statements whether due to fraud or error design and perform audit proceduresresponsive to those risks and obtain audit evidence that is sufficient and appropriate toprovide a basis for our opinion. The risk of not detecting a material misstatementresulting from fraud is higher than for one resulting from error as fraud may involvecollusion forgery intentional omissions misrepresentations or the override of internalcontrol.

• Obtain an understanding of internal financial controls relevant to the audit inorder to design audit procedures that are appropriate in the circumstances. Under section143(3)(i) of the Act 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 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 uncertainty exists related to events or conditions that may cast significantdoubt on the Company's ability to continue as a going concern. If we conclude that amaterial uncertainty exists we are required to draw attention in our auditor's report tothe related disclosures in the standalone financial statements or if such disclosures areinadequate to modify our opinion. Our conclusions are based on the audit evidenceobtained up to the date of our auditor's report. However future events or conditions maycause the Company to cease to continue as a going concern.

• Evaluate the overall presentation structure and content of the standalonefinancial statements including the disclosures and whether the standalone financialstatements represent the underlying transactions and events in a manner that achieves fairpresentation.

Materiality is the magnitude of misstatements in the standalone financial statementsthat individually or in aggregate makes it probable that the economic decisions of areasonably knowledgeable user of the financial statements may be influenced. We considerquantitative materiality and qualitative factors in (i) planning the scope of our auditwork and in evaluating the results of our work; and (ii) to evaluate the effect of anyidentified misstatements in the financial statements.

We communicate with those charged with governance regarding among 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 standalone financial statementsof the current period and are therefore the key audit matters. We describe these mattersin our auditor's report unless law or regulation precludes public disclosure about thematter or when in extremely rare circumstances we determine that a matter should not becommunicated

in our report because the adverse consequences of doing so would reasonably be expectedto outweigh the public interest benefits of such communication.

REPORT ON OTHER LEGAL AND REGULATORY REQUIREMENTS

I. As required by Section 143 (3) of the Act we report

that:

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

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

c) The Balance Sheet the Statement of Profit and Loss (including other comprehensiveincome) the Cash Flow Statement and Statement of Changes in Equity dealt with by thisReport are in agreement with the books of account.

d) In our opinion the aforesaid Standalone Ind AS Financial Statements comply with theInd AS specified under Section 133 of the Act read with Rule 3 of the Companies (IndianAccounting Standards) Rules 2015.

e) On the basis of the written representations received from the directors as on 31stMarch 2019 taken on record by the Board of Directors none of the directors isdisqualified as on 31st March 2019 from being appointed as a director in termsof Section 164 (2) of the Act.

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 our separate Report in "Annexure A" to thisreport.

g) With respect to the other matters to be included in the Auditor's Report inaccordance with Rule 11 of the Companies (Audit and Auditors) Rules 2014 read withNotification No G.S.R 307(E) dated 30.3.2017 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 its Standalone Financial Statements - Refer Note No. 28 to the StandaloneFinancial Statements.

ii. The Company has made provision as required under the applicable law or accountingstandards for material foreseeable losses if any on long term contracts includingderivative contracts.

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

II. 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 B a statement on the matters specified in paragraphs 3and 4 of the Order to the extent applicable.

For G. D. Apte & Co.
Chartered Accountants
Firm registration number: 100515W
Chetan R. Sapre
Place : Mumbai Partner
Date: 29th May 2019 Membership No: 116952

ANNEXURE "A" TO THE INDEPENDENT AUDITORS' REPORT ON STANDALONE FINANCIALSTATEMENTS OF SAVITA OIL TECHNOLOGIES LIMITED

(Referred to in paragraph I (f) under ‘Report on Other Legal and RegulatoryRequirements' of our report of even date to the members of Savita Oil Technologies Limitedon the Standalone Financial Statements for the year ended 31st March 2019)

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

We have audited the internal financial controls over financial reporting of Savita OilTechnologies Limited ("the Company") as of 31st March 2019 inconjunction with our audit of the Standalone Ind AS Financial Statements of the Companyfor the year ended on that date.

MANAGEMENT'S RESPONSIBILITY FOR INTERNAL FINANCIAL CONTROLS

The Company's management is responsible for establishing and maintaining internalfinancial controls based on the internal control over financial reporting criteriaestablished by the Company considering the essential components of internal control statedin the Guidance Note on Audit of Internal Financial Controls Over Financial Reporting("the Guidance Note") issued by the Institute of Chartered Accountants of India(ICAI). These responsibilities include the design implementation and maintenance ofadequate internal financial controls that were operating effectively for ensuring theorderly and efficient conduct of its business including adherence to company's policiesthe safeguarding of its assets the prevention and detection of frauds and errors theaccuracy and completeness of the accounting records and the timely preparation ofreliable financial information as required under the Companies Act 2013.

AUDITORS' RESPONSIBILITY

Our responsibility is to express an opinion on the Company's internal financialcontrols over financial reporting based on our audit. We conducted our audit in accordancewith the Guidance Note and the Standards on Auditing issued by the ICAI and deemed to beprescribed under Section 143(10) of the Companies Act 2013 to the extent applicable toan audit of internal financial controls. Those Standards and the Guidance Note requirethat we comply with ethical requirements and plan and perform the audit to obtain

reasonable assurance about whether adequate internal financial controls over financialreporting was established and maintained and if such controls operated effectively in allmaterial 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 Standalone Financial Statements whether due to fraud orerror.

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 Standalone Financial Statements for external purposes in accordance withgenerally accepted accounting principles. A company's internal financial control overfinancial reporting includes those policies and procedures that (1) pertain to themaintenance of records that in reasonable detail accurately and fairly reflect thetransactions and dispositions of the assets of the company; (2) provide reasonableassurance that transactions are recorded as necessary to permit preparation of StandaloneFinancial Statements in accordance with generally accepted accounting principles and thatreceipts and expenditures of the company are being made only in accordance withauthorizations of management and directors of the company; and (3) provide reasonableassurance regarding prevention or timely detection of unauthorized acquisition use ordisposition of the company's assets that could have a material effect on the StandaloneFinancial Statements.

INHERENT LIMITATIONS OF INTERNAL FINANCIAL CONTROLS OVER FINANCIAL REPORTING

Because of the inherent limitations of internal financial controls over financialreporting including the possibility of collusion or improper management override ofcontrols material misstatements due to error or fraud may occur and not be detected.Also projections of any evaluation of the internal financial controls over financialreporting to future periods are subject to the risk that the internal financial controlover financial reporting may become inadequate because of changes in conditions or thatthe degree of compliance with the policies or procedures may deteriorate.

OPINION

In our opinion to the best of our information and according to the explanations givento us the Company has in all

material respects an adequate internal financial controls system over financialreporting and such internal financial controls over financial reporting were operatingeffectively as of 31st March 2019 based on the internal control overfinancial reporting criteria established by the Company considering the essentialcomponents of internal control stated in the Guidance Note issued by the ICAI.

For G. D. Apte & Co.
Chartered Accountants
Firm registration number: 100515W
Chetan R. Sapre
Place : Mumbai Partner
Date: 29th May 2019 Membership No: 116952

ANNEXURE - B TO THE INDEPENDENT AUDITORS' REPORT ON STANDALONE FINANCIAL STATEMENTS OFSAVITA OIL TECHNOLOGIES LIMITED

(Referred to in paragraph I under the heading "Report on Other Legal andRegulatory Requirements" of our report of even date to the members of Savita OilTechnologies Limited on the Standalone Financial Statements for the year ended 31stMarch 2019)

i. a) The Company has maintained proper records

showing full particulars including quantitative details and situation of propertyplant and equipment.

b) As informed to us the fixed assets having substantive value have been physicallyverified by the management during the period according to a phased programme. In ouropinion such programme is reasonable having regard to the size of the Company and thenature of its assets. We have been further informed that no material discrepancies werenoticed on such verification by the management between the book records and physicalverification.

c) According to the information and explanations given to us and based on the recordsproduced the title deeds of the immovable properties held by the Company are in the nameof the Company.

ii. The inventories have been physically verified during the year by the management. Inour opinion the frequency of verification is reasonable. The discrepancies noticed

on verification between the physical stocks and the book records were not materialhaving regard to the size of the operations of the Company and the same have been properlydealt with.

iii. According to the information and explanations given to us the Company has notgranted any loans secured or unsecured to companies firms Limited LiabilityPartnerships or other parties covered in the register maintained under section 189 of theCompanies Act 2013. Accordingly the provisions of sub clauses (a) (b) (c) of clause(iii) of the order are not applicable to the company.

iv. The Company has not granted any loans or made any investment or provided anyguarantee or security in respect of which provisions of section 185 of the Act areapplicable. Accordingly the provisions of clause (iv) of the order are not applicable tothe company.

v. In our opinion and according to the information and explanations given to us theCompany has complied with the directives issued by the Reserve Bank of India and theprovisions of sections 73 to 76 or any other relevant provisions of the Act and the rulesframed there under to the extent applicable. We are informed by the Management that noorder has been passed by the Company Law Board or National Company Law Tribunal or ReserveBank of India or any court or any other Tribunal in this regard.

vi. We have broadly reviewed accounts and records maintained by the Company pursuant torules made by the Central Government for the maintenance of cost records under Section148(1) of the Act in respect of Company's products to which the said rules are madeapplicable and are of the opinion that prima facie the prescribed accounts and recordshave been made and maintained. We have however not made a detailed examination ofrecords with a view to determine whether they are accurate.

vii. a) According to the information and explanations

given to us and according to the records of the Company examined by us in our opinionthe Company is generally regular in depositing with the appropriate authorities undisputedstatutory dues including Provident Fund Employees' State

Insurance Income-tax Sales Tax Service Tax Goods and Service Tax duty of Customduty of Excise Value Added Tax Cess and any other statutory dues wherever applicable.According to the information and explanations given to us no undisputed amounts payablein respect of aforesaid dues were outstanding as at 31st March 2019 for aperiod of more than 6 months from the date they became payable.

b) According to the information and explanations given to us there were no dues inrespect of Income Tax Duty of Excise Duty of Customs Sales Tax Service Tax Goods andService Tax and Value Added Tax which have not been deposited on account of any disputeexcept the following:

(Rs in lacs)

Name of the Statue Nature of Dues Forum where the case is pending Period to which the Amount relates (Financial Year) Gross Amount Involved Amount Paid in Protest Amount Unpaid
Superintendent Assistant/ Deputy/ Joint/ Additional Commissioner and 2002-2016 96.26 2.50 93.77
Central Excise Act Excise Commissioner of Central Excise Department
1944 Duty Commissioner of Central Excise (Appeals) 2006-2017 54.78 3.72 51.05
Customs Excise and Service Tax Appellate Tribunal 1999-2002 2004-2017 969.02 40.50 928.52
Total (A) 1120.06 46.72 1073.34
Finance Act 1994 Service Tax Joint Commissioner Service Tax 2006-2011 20.16 - 20.16
Total (B) 20.16 - 20.16
Customs Act 1962 Customs Duty Commissioner of Customs (Imports) 1992-1993 2006-2007 402.63 - 402.63
Total(C) 402.63 - 402.63
Commercial Tax Officer 2005-2006

7.44

7.44

(Assessing Authority) 2008-2009
Central Sales Tax Act & Sales Tax Act of various Central Sales Tax Assistant/ Additional Deputy Commissioner of Commercial Taxes 2000-2001 2003-2004 0.21 - 0.21
Acts Deputy/ Joint/ Additional Commissioner (Appeal) 2002-2009 2010-2016 2003.94 38.42 1965.52
Sales Tax Tribunal 1998-1999 0.75 0.25 0.50
Total (D) 2012.34 38.67 1973.67
Tamil Nadu Panchayat Act 1994 House Tax Thadichery Panchayat Theni 2012-13 33.49 - 33.49
Total (E) 33.49 - 33.49
Grand Total ( A + B + C + D + E ) 3588.68 85.40 3503.29

viii. We have been informed that the Company has not defaulted in repayment of loans orborrowings to financial institutions banks and Government. The Company has not raised anyfunds through debentures.

ix. According to the information and explanations given to us and on the basis ofexamination of records the Company has neither obtained new term loans nor raised anymoney by way of initial public offer or further public offer of shares and/or debtinstruments during the year. Therefore the provisions of clause (ix) of the Order are notapplicable to the Company.

x. Based on our audit procedures performed for the purpose of reporting the true andfair view of the Standalone Financial Statements and on the basis of information andexplanations given by the management no fraud by the Company or on the Company by itsofficers or employees has been noticed or reported during the year.

xi The managerial remuneration has been paid in accordance with the requisite approvalsmandated by the provisions of section 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 and accordingly the provisions of clause (xii) of the Orderare not applicable to the Company.

xiii. According to the information and explanations given to us and based on ourexamination of records of the Company the transactions entered with related parties arein compliance with provisions of section

177 and 188 of the Act where applicable and the details of such transactions aredisclosed in the Standalone Financial Statements as required by the applicable accountingstandards.

xiv. According to the information and explanations given to us and based on ourexamination of records of the Company the Company during the year has not made anypreferential allotment or private placement of shares or fully or partly convertibledebentures. Accordingly the provisions of clause (xiv) of the Order are not applicable tothe Company.

xv. In our opinion and according to the information and explanations given to us andbased on our examination of records of the Company the Company during the year has notentered into any non cash transactions with directors or persons connected with thedirectors covered under the provisions of sec 192 of the Act and accordingly theprovisions of clause (xv) of the Order are not applicable to the Company.

xvi. In our opinion and according to the information and explanations given to us theCompany is not required to be registered under section 45-IA of the Reserve Bank of IndiaAct 1934.

For G. D. Apte & Co.
Chartered Accountants
Firm registration number: 100515W
Chetan R. Sapre
Place : Mumbai Partner
Date: 29th May 2019 Membership No: 116952