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Scintilla Commercial & Credit Ltd.

BSE: 538857 Sector: Financials
NSE: N.A. ISIN Code: INE892C01018
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OPEN 9.17
CLOSE 9.17
VOLUME 1
52-Week high 10.00
52-Week low 8.35
P/E
Mkt Cap.(Rs cr) 9
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

Scintilla Commercial & Credit Ltd. (SCINTILLACOMM) - Auditors Report

Company auditors report

TO

THE MEMBERS OF

SCINTILLA COMMERCIAL & CREDIT LIMITED

REPORT ON THE AUDIT OFTHE FINANCIAL STATEMENTS

Opinion

We have audited the accompanying standalone financial statements of ScintillaCommercial & Credit Ltd ("the Company") which comprise the Balance Sheet asat March 312021 the Statement of Profit and Loss (including the Statement of OtherComprehensive Income) the Statement of Changes in Equity and the Statement of Cash Flowsfor the year then ended and notes to the financial statements including a summary ofsignificant accounting policies and other explanatory information (hereinafter referred toas "the Standalone Financial Statements").

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 as amended ("the Act") in the mannerso required andgive a true and fair view in conformity with the Indian Accounting Standards as prescribedunder section 133 of the Act read with the Companies (Indian Accounting Standards) Rules2015 as amended ("Ind AS") and other accounting principles generally acceptedin India of the state of affairs of the Company as at March 312021 its profit includingother comprehensive income changes in equity and its cash flowsfortheyearthen ended.

Basisfor Opinion

We conducted our audit in accordance with the Standards on Auditing (SAs) specifiedunder section 143(10) of the Companies Act 2013. Our responsibilities under thoseStandards are further described in the Auditor's Responsibilities for the Audit of theFinancial Statements section of our report. We are independent of the Company inaccordance with the Code of Ethics issued by the Institute of Chartered Accountants ofIndia ("the ICAI") together with the ethical requirements that are relevant toour audit of the financial statements under the provisions of the Act and the Rules madethere under and we have fulfilled our other ethical responsibilities in accordance withthese requirements and the ICAI's Code of Ethics. We believe that the audit evidence wehave obtained is sufficient and appropriate to provide a basis forouropinion.

Emphasis of Matter

We draw your attention to Note 5.11 to the standalone financial statements whichexplains the uncertainties and management's assessment of the financial impact due to thelock-down / restrictions related to the Covid-19 pandemic imposed by the Governments forwhich a definitive assessment of the impact is dependent upon future economic conditions.

Ouropinion is not modified in respect ofthis matter

Key Audit Matters

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

We have determined the matters described below to be the key audit matters to becommunicated in our report.

Description of Key Audit Matter

Classification and measurement of financial assets - Business model assessment

Sr. No. Key Audit Matter How the matter was addressed in our audit
Classification and measurement of financial assets - Business model assessment Assessment of carrying value of equity investments in quoted and unquoted sharesand securities. Our audit procedures included: Desian / controls
(Refer to Note 7 to the financial state me nts - " Use of esti mates a nd critica 1 accounting assumptions and Judgments" Note no 5.2 "Financial Instruments") The Company has equity investments in various quoted shares as well as unquoted shares. It has also made investments in preference shares which are unquoted. -Assessing the design implementation and operating effectiveness of key internal controls over management's intent of purchasing a financial assets and classification of such financial assets on the basis of management's intent (business model). • For financial assets classified at Amortized cost we tested controls over the classification of such assets and subsequent measurement of assets at Amortized cost
The Company accounts for equity investments both in quoted and unquoted shares at fair value subject to the carrying value of unquoted equity shares and preference shares which are carried at cost being the transaction value as recorded at the time of acquisitions. • For financial assets classified at FVOCI we tested controls over the classification of such assets and subsequent measurement of assets atfair value.
For invest me nts ca rried at fair values a fair valuation is done at the year-end as required by Ind AS 109. In case of certain investments cost is considered as an appropriate estimate of fair value since there is a wide rage of possible fair value measurements and costs represents the best estimate of fair value within that range as permitted under Ind AS 109. Substantive tests.
The accounting for investments is a Key Audit Matter as the determination of recoverable value for impairment assessment/ fair valuation involves significant management judgement and estimates. • Test of details over classification and measurement of financial assets in accordance with management's intent. (Business model).
• We selected a sample of financial assets to test whether their classification as at the balance sheet date is in accordance with management's intent.
• We selected a sample (based on quantitative thresholds) of financial assets sold during the year to check whether there have been any sales offinancial assets classified at amortized cost FVOCI or FVTPL.
• We have also checked that there have been no reclassifications of assets in the current period.
• We had discussions with management to obtain understanding of the relevant factors in respect of certain investments carried at fair value where a wide range of fair value were possible due to various factors such as absence of of recent observable transactions restrictions on transfer of shares existence of multiple valuation techniques investee's varied nature of portfolio of investments for which significant estimates/ Judgements are required to arrive at fair value.
• We have discussed the key assumptions and sensitivities for certain investments with those charge with Governance.
• We evaluated the adequacy of the disclosures made in the financial statements.
Based on the above procedures performed we did not identify any significant exceptions in the management's assessment in relation to the carrying value of the investments in equity and preference shares.

Provision for Expected Credit Losses (ECL) on Loans (refer note no 5.2(f) note no. 10and note no. 30(l)(a) of the financial statements)

Sr. No. Key Audit Matter How the matter was addressed in our audit
2- Management estimates impairment provision using Expected Credit loss model for the loan assets. Measurement of loan impairment involves application of significant judgement by the management. The most significant judgements are: Our audit procedures included:
Timely identification and classification of the impaired loans. 1) In our audit approach we assessed the basis upon which the ECL model is build and discussed with the management of the Company in orderto understand the mechanics of ECL deployed by the company to measure the loan impairment.
Determination of probability of defaults (PD) and estimation of loss given defaults (LGD) based on the premise that loans made by the company are unsecured and re levant factors 2) We examined that Board does not have approved policy for computation of ECL but have in place the internal guidelines for computation of ECL. These internal guidelines address procedures and controls for assessing and measuring the credit risk on its loan portfolio.
The estimation of Expected Credit Loss (ECL) on financial instruments involve significant judgments and estimates. Following are points with increased level of auditfocus: 3) We evaluated the operating effectiveness of controls across the process relevant to ECL including the judgments and estimates.
Classification of assets to stage 1 2 or 3 using criteria in accordance with Ind AS 109 which also include considering the impact of recent RBI's Covid-19 regulatorycirculars. 4) We evaluated the nature of loan assets of the company and held discussions with the management and assessed that the company has only one class of loan i.e. unsecured loans repayable on demand and 12 month ECL is just the same as lifetime ECL because the all the loans are repayable on demand which is shorter than 12 months as a result life time of a loan is that short period required to transfer cash when demanded bythecompany.
Accounting interpretations assumptions and data used to build the models; 5) We tested the completeness of loans and advances included in the Expected Credit Loss calculations as of March 31 2021 by reconciling it with the balances as per loan balance registerason date.
Inputs and judgements used by the management at various assets stages considering the current uncertain economic environment with the range of possible effects unknown to the country arising out of the Covid-19 pandemic. 6) We tested assets on sample basis to verify that they we re allocated to the appropriate stage.
The disclosures made in the financial statements for ECL especially in relation to judgements and estimates made by the management in determination of the ECL. 7) For samples of exposure we tested the appropriateness of determining EAD PD and LGD
Considering the significance of such allowances to the overall financial statements and degree of judgement and estimation involved in computation of expected credit losses this area is considered as key audit matter. 8) For forward looking assumptions used in ECL calculations we held discussions with management assessed the assumptions used to determine the probability weights assigned to the possible outcomes. During our examination we assessed that company estimates the PD based on historical observed default rates adjusted for forward looking estimates based upon macro-economic developments occurring in the economy and market it operates in.
9) We performed an overall assessment of the ECL provision including the management's assessment on Covid-19 impact to determine if they were reasonable considering the Company's portfolio risk profile credit risk management practices and the macro-economic environment. We held discussions with the management on its assessment on Covid-19 impact and we assessed that management does not expect any significant haircuts in view of Covid-19. However we could not assess the appropriateness of the future scenarios and assumptions made by the management in response to Covid-19 related economic uncertainty as we do not have the access of the detailed data (like Income tax returns financial statements projected financial statements cash flow statements etc.) of the borrowers of the company.
10) We assessed the adequacy and appropriateness of disclosures in compliance with accounting standards in relation to judgements used in esti mation of ECL provisions.

Statutory and Legal Matters (Refer Note no. 29(2)(c)

Sr. No. Key Audit Matter How the matter was addressed in our audit
3. The Company received a notice from BSE dated August 10 2017 regarding issue related to suspected shell companies. BSE requested to submit various documents from time to time in this regard along with the queries and other information from the Company. Further BSE appointed M/s BDO India LLP Chartered Accountants to carry out the forensic audit of the Company. The Company replied to all the queries issued by the BSE and provided all the necessary information /documents to the forensic auditors in this regard. and the matter is sub-judice as on March 31 2021. Our audit procedures included:
1) We have checked up the order of the BSE issued pursuant to the SEBI's aforesaid directions and other relevant correspondence with the BSE and with the forensic auditors appointed by the BSE in this regard since inception.
2) We have also checked all the relevant legal petitions applications affidavits rejoinders interlocutory applications as filed by the Company with Hon'ble High Court at Kolkata.
3) We communicated with the Management and those charged with Governance with respect to this matter and the Company is regular in replying to all the queries raised and all the documents sought by the Exchange (BSE) and by the forensic auditors. The forensic audit is in process and the matter is subjudice at present.

I 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 Management's Discussion andAnalysis Board's Report including Annexure to Board's Report Corporate Governance Reportincluded in the Company's annual report but does not include the standalone financialstatements and our auditor's report thereon. The other information is expected to be madeavailable to us after the date of this auditor's report. Our opinion on the standardfinancial statements does not cover the other information and we do not express any formof assurance conclusion thereon.

I n connection with our audit of the standalone financial statements ourresponsibility is to read the other information identified above when it becomes availableand in doing so consider whether such other information is materially inconsistent withthe financial statements or our knowledge obtained during the course of the audit orotherwise appears to be materially misstated.

If based on the work we have performed; we conclude that there is a materialmisstatement of this other information; we a re required to re port that fact. We havenothing to report in this regard.

Management's Responsibility and those charged with Governance forthe FinancialStatements.

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 changesin equity and cash flows of the Company in accordance with the Indian Accounting Standards(Ind AS) specified under Section 133 of the Act and other accounting principles generallyaccepted in India. This responsibility also includes maintenance of adequate accountingrecords in accordance with the provisions of the Act for safe guarding of the assets ofthe Company and for preventing and detecting frauds and other irregularities; selectionand application of appropriate accounting policies; making judgments and estimates thatare 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 standalone financial statements that give a true and fair view and a re free frommaterial misstatement 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 a bout whether the financialstatements as a whole are free from material misstatement whether due to fraud or errorand to issue an auditor's report that includes our opinion. Reasonable assurance is a highlevel of assurance but is not a guarantee that an audit conducted in accordance with SAswill always detect a material misstatement when it exists. Misstatements can arise fromfraud or error and are considered material if individually or in the aggregate theycould reasonably be expected to influence the economic decisions of users taken on thebasis of these standalone financial statements.

As part of an audit in accordance with SAs we exercise professional judgment andmaintain professional skepticism throughout the audit. We also:

• Identify and assess the risks of material misstatement of the financialstatements whether due to fraud or error design and perform audit procedures responsiveto those risks and obtain audit evidence that is sufficient and appropriate to provide abasis for our opinion. The risk of not detecting a material misstatement resulting fromfraud is higher than for one resulting from error as fraud may involve collusionforgery intentional omissions misrepresentations or the override of internal control.

• Obtain an understanding of internal control relevant to the audit in order todesign audit procedures that are appropriate in the circumstances. Under section 143(3)(i)of the Act we are also responsible for expressing our opinion on whether the Company hasadequate internal financial controls with reference to financial statements in place andthe operating effectiveness of such controls.

• Evaluate the appropriateness of accounting policies used and the reasonablenessof accounting estimates and related disclosures made by management.

• Conclude on the appropriateness of management's use of the going concern basisof accounting and based on the audit evidence obtained whether a material uncertaintyexists related to events or conditions that may cast significant doubt on the Company'sability to continue as a going concern. If we conclude that a material uncertainty existswe are required to draw attention in our auditor's report to the related disclosures inthe financial statements or if such disclosures are inadequate to modify our opinion.Our conclusions are based on the audit evidence obtained up to the date of our auditor'sreport. However future events or conditions may cause the Company to cease to continue asa going concern.

• Evaluate the overall presentation structure and content of the financialstatements including the disclosures and whether the financial statements represent theunderlying transactions and events in a manner that achieves fair presentation.

Materiality is the magnitude of misstatements in the financial statements thatindividually origin aggregate makes it probable that the economic decisions of areasonably knowledgeable user of the Ind AS financial statements may be influenced. Weconsider quantitative materiality and qualitative factors in

(i) planningthe scope of our audit work and in evaluating the results of our work; and

(ii) to evaluate the effect of any identified misstatements in the financialstatements.

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 ouraudit.

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

From the matters communicated with those charged with governance we determine thosematters that were of most significance in the audit of the financial statements of thecurrent period and are therefore the key audit matters. We describe these matters in ourauditor's report unless law or regulation precludes public disclosure about the matter orwhen in extremely rare circumstances we determine that a matter should not becommunicated in our report because the adverse consequences of doing so would reasonablybe expected to outweigh the public interest benefits of such communication.

Report on Other Legal and Regulatory Requirements

1) As required by the Companies (Auditor's Report) Order 2016 ("the Order")issued by the Central Government in terms of Sectionl43(ll) of the Act we give in the"Annexure A" a statement on the matters specified in paragraphs 3 and 4 of theorder to the extent applicable.

2) Further to our comments in Annexure A as required by Section 143(3) of the Act wereport to the extent applicable 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 of theaccompanying standalone financial statements.

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 standalone financial statements dealt with by this report are in agreement withthe books of account.

d) In our opinion the aforesaid standalone financial statements comply with IndianAccounting Standards ("Ind AS") specified under Section 133 of the Act readwith Companies (Indian Accounting Standards) Rules 2015 as amended.

e) On the basis of the written representations received from the directors and taken onrecord by the Board of Directors none of the directors is disqualified as on 31 March2021 from being appointed as a director in terms of Section 164(2) of the Act;

f) With respect to the adequacy of the internal financial controls with reference tofinancial statements of the Company for the year ended on that date refer to our separateReport as per "Annexure B".

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

i) The Company as detailed in note 29(1) to the financial statements has disclosedthe impact of pending litigations on its financial position as at March 312021;

ii) The Company did not have any long-term contracts including derivative contracts forwhich there were any material foreseeable losses as at March 312021

iii) There has been no delay in transferring amounts required to be transferred tothe Investor Education and Protection Fund by the Company during the year endedMarch312021.

iv) The disclosure requirements relating to holdings as well as dealings in specifiedbank notes were applicable for the period from 8 November 2016 to 30 December 2016 whichare not relevant to these financial statements. Hence reporting under this clause is notapplicable.

3) With respect to the matter to be included in the Auditor's Report under Section197(16) of the Act:

In our opinion and according to the information and explanations given to us theremuneration paid by the Company to its directors during the current year is in accordancewith the provisions of Section 197 read with Schedule V to the Act.

Annexure-"A" to the Independent Auditors' Report on the Financial Statements

[Referred to in Paragraph 1 under 'Report on Other Legal and Regulatory Requirements'in the Independent Auditor's Report of even date to the Members of Scintilla Commercial& Credit Ltd on the financial statements for the year ended March 312021].

ANNEXUREA

Based on the audit procedures performed for the purpose of reporting a true and fairview on the standalone financial statements of the Company and taking into considerationthe information and explanations given to us and the books of account and other recordsexamined by us in the normal course of audit and to the best of our knowledge and beliefwe report that:

i. (a) Based on our scrutiny of the Company's books of accounts and other records andaccording to the information and explanation received by us from the management we are ofopinion that the question of commenting on the maintenance of proper records of PropertyPlant and Equipment physical verification of Property Plant and Equipment and title deedof Property Plant and Equipment including immovable properties does not arise since theCompany had no Property Plant and Equipmentason31March2021.

ii. The Company is in the business of lending and lnvestments in shares and securitiesand consequently does not hold any tangible inventory. However shares and securities heldas stock-in trade comprises the intangible inventory for the company. The inventorycomprises of securities held as stock-in trade are verified by the management with theconfirmation statements received from the depository on a regular basis. In our opinionthe frequency of such verification is reasonable. The Company is maintaining properrecords of securities held as stock-in trade and no discrepancies were noticed oncomparing the statement from custodian with books of account.

iii. The Company has granted unsecured loans repayable on demand to companies and otherparties covered in the register maintained under section 189 of the Companies Act 2013and with respect to the same:

(a) According to the information and explanations given to us and based on the auditprocedures conducted by us we are of the opinion that the terms and conditions of theaforesaid loans granted by the Company a re not prejudicial to the interest of theCompany.

(b) The Schedule of repayment of principal and payment of interest has not beenstipulated and hence we are unable to comment as to whether repayments/receipts of theprincipal amount and interest are regular.

(c) The aforesaid loans are repayable on demand accordingly provision of Clause3(iii) (b) and (c) of the Order are not applicable to the Company.

iv. Based on information and explanations given to us in respect of loans andinvestments the Company has complied with the provisions of Section 185 and 186 of theCompanies Act as applicable in respect of loans and investments.

v. In our opinion the Company has not accepted any deposits within the meaning ofsections 73 to 76 of the Companies Act 2013 (as amended) and the Companies (Acceptance ofDeposits) Rules 2014 (as amended). Accordingly the provisions of Clause 3{v)oftheOrderare not applicable.

vi. The Central Government has not specified maintenance of cost records for any of theproducts or services of the Company under Sub-section (1) of Section 148 of the Act andrules framed there under. Accordingly the provisions of Clause (vi) oftheOrderare notapplicable.

vii. (a) The Company is regular in depositing with appropriate authorities undisputedstatutory dues including Income tax provident fund employees state insurance Goods andServices tax cess and other statutory dues applicable to it and the extent of the arrearsof outstanding dues as on the last day of the financial year concerned were not for aperiod of more than six months from the date they became payable.

As informed the provisions of provident fund employees state insurance and goods andservices tax are currently not applicable to the Company.

(b) However according to information and explanation given to us the following dues ofIncome tax have not been deposited by the Company on account of disputes.

Name of the Statute Nature of dues Amount under dispute Period to which the amount relates Forum where dispute is pending
Income Tax Act 1961 Income Tax and Interest Rs 189160/- A.Y 2014-15 CIT(Appeals)

viii. The Company has not taken any loans or borrowings from financial institutionsbanks and government or has not issued any debentures. Hence reporting under clause 3(viii) of the Order are not applicable to the Company.

ix. According to the information and explanations given by the management the Companyhas not raised moneys byway of initial public offer or further public offer (includingdebt instruments) or term loans and hence reporting under clause 3 (ix) of the Order a renot applicable to the Company.

x. To the best of our knowledge and according to the information and explanations givento us no fraud by the Company and no material fraud on the Company by its officers oremployees has been noticed or reported during the year nor have we been informed of anysuch case by the Management.

xi. In our opinion the Company has paid/provided managerial remuneration in accordancewith the requisite approvals mandated by the provisions of section 197 read with ScheduleV to the Act.

xii. In our opinion the Company is not a Nidhi Company. Accordingly provisions ofclause 3 (xii) of the Orderare notapplicable.

xiii. The Company has entered into transactions with related parties in compliance withthe provisions of Section 177 and 188 of the Companies Act 2013 where applicable. Thedetails of related party transactions have been disclosed in the financial statements asrequired by the applicable Indian accountingstandard ("Ind AS")

xiv. The Company has not made any preferential allotment or private placement of sharesor fully or partly convertible debentures during the year. Accordingly the provisions ofClause (xiv) of this Order are not applicable to the Company.

xv. In our opinion the Company has not entered into any non-cash transactions with theDirectors or persons connected with them covered under Section 192 of the Act.Accordingly the provisions of Clause (xv) of the Orderare notapplicable to the Company.

xvi. According to the information and explanations given to us the Company is a Nondeposit taking Systematically not important Non-Banking Financial Company and is dulyregistered under Section 45- lAof the Reserve Bank of India Act 1934.

Annexure -"B" to the Independent Auditors' Report on the Financial Statementsfor the year ended 31 March 2021

[Referred to in Paragraph 2(f) under 'Report on Other Legal and RegulatoryRequirements' in the Independent Auditor's Report of even date to the Members of ScintillaCommercial & Credit Ltd on the financial statements for the year ended 31stMarch 2021].

ANNEXURE B

Independent Auditor's Report on the Internal Financial Controls with reference to theFinancial Statements under Clause (i) of Sub-section 3 of Section 143 of the CompaniesAct 2013 (the "Act")

In conjunction with our audit of the financial statements of Scintilla Commercial &Credit Ltd ('the Company') as at and for the year ended 31 March 2021 we have audited theinternal financial controls with reference to the financial statements of the Company asat that date.

Responsibility of Management and Those Charged with Governance for Internal FinancialControls

The Company's Board of Directors is responsible for establishing and maintaininginternal financial controls based on the internal financial controls with reference tofinancial statements criteria established by the Company considering the essentialcomponents of internal control stated in the Guidance Note on Audit of Internal FinancialControls Over Financial Reporting (‘the Guidance Note') issued by the Institute ofChartered Accountants of India (‘the ICAI"). These responsibilities include thedesign implementation and maintenance of adequate internal financial controls that wereoperating effectively for ensuring the orderly and efficient conduct of its businessincluding adherence to company's policies the safeguarding of its assets the preventionand detection of frauds and errors the accuracy and completeness of the accountingrecords and the timely preparation of reliablefinancial information as requiredundertheAct.

Auditor's Responsibility for the Audit of the Internal Financial Controls withReference to Financial Statements:

Our responsibility is to express an opinion on the Company's internal financialcontrols with reference to financial statements based on our audit. We conducted our auditin accordance with the Guidance Note on Audit of Internal Financial Controls OverFinancial Reporting (the "Guidance Note") issued by the Institute of CharteredAccountants of India ("the ICAI") and the Standards on Auditing prescribed underSectionl43(10) of the Companies Act2013 to the extent applicable to an audit of internalfinancial controls with reference to financial statements. 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 controlswith reference to financial statements were established and maintained and if suchcontrols operated effectively in all material respects.

Our audit involves performing procedures to obtain audit evidence about the adequacy ofthe internal financial controls with reference to financial statements and their operatingeffectiveness. Our audit of internal financial controls with reference to financialstatements included obtaining an understanding of such internal financial controlsassessing the risk that a material weakness exists and testing and evaluating the designand operating effective 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 interna I financial controls withreference to financial statements.

Meaning of Internal Financial Controls with reference to Financial Statements

A company's internal financial control with reference to financial statement is aprocess designed to provide reasonable assurance regarding the reliability of financialreporting and the preparation of financial statements for external purposes in accordancewith generally accepted accounting principles. A company's internal financial control withreference to financial statement includes those policies and procedures that:-

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

(ii) 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 managementand directors of the company; and

(iii) provide reasonable assurance regarding prevention ortimely 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 with Reference to FinancialStatements

Because of the inherent limitations of internal financial controls with reference tofinancial statements including the possibility of collusion or improper managementoverride of controls material misstatements due to error orfraud may occur and not bedetected. Also projections of any evaluation the internal financial controls withreference to financial statements to future periods are subject to the risk that theinternal financial control with reference to financial statements may become inadequatebecause of changes in conditions or that the degree of compliance with the policies orprocedu res may deteriorate.

Opinion

In our opinion the Company has in all material respects an adequate internalfinancial control with reference to financial statements and such controls were operatingeffectively as at March 31 2021 based on the internal financial control with referenceto the financial statements criteria established by the Company considering the essentialcomponents of internal control stated in the Guidance Note issued by the Institute ofChartered Accountants of India ("the ICAI").

For and on behalf of
C.K. CHANDAK& CO
Chartered Accountants
Firm Registraon Number: 326844E
CA Chandra Kumar Chandak
Proprietor
Membership Number: 054297
UDIN: 21054297AAAAGA8875
Place: Kolkata
Date: 30/06/2021

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