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Shah Alloys Ltd.

BSE: 513436 Sector: Metals & Mining
NSE: SHAHALLOYS ISIN Code: INE640C01011
BSE 00:00 | 17 May 76.00 1.05
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NSE 00:00 | 17 May 75.65 0.80
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OPEN 72.70
PREVIOUS CLOSE 74.95
VOLUME 9989
52-Week high 135.35
52-Week low 9.93
P/E 2.33
Mkt Cap.(Rs cr) 150
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00
OPEN 72.70
CLOSE 74.95
VOLUME 9989
52-Week high 135.35
52-Week low 9.93
P/E 2.33
Mkt Cap.(Rs cr) 150
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

Shah Alloys Ltd. (SHAHALLOYS) - Auditors Report

Company auditors report

To the Members of SHAH ALLOYS LIMITED

Report on the Audit of the Standalone Ind AS Financial Statements

Qualified Opinion

We have audited the accompanying standalone Ind AS financial statements of M/s SHAHALLOYS LIMITED (''the Company") which comprise the standalone balance sheet asat March 31 2021 and the standalone statement of profit and loss (including othercomprehensive income) standalone statement of changes in equity and standalone statementof cash flows for the year then ended and notes to the financial statements including asummary of significant accounting policies and other explanatory information.

In our opinion and to the best of our information and according to the explanationsgiven to us except for the effects of the matter described in the Basis for QualifiedOpinion Section of our report the aforesaid standalone Ind AS financial statements givethe information required by the Companies Act 2013 (the Act) in the manner so requiredand give a true and fair view in conformity with the Indian Accounting Standardsprescribed under section 133 of the Act read with the Companies (Indian AccountingStandards) Rules 2015 as amended ("Ind AS") and other accounting principlesgenerally accepted in India of the state of affairs (financial Position )of the Company asat March 31 2021 and its losses (financial performance including other comprehensiveincome) its Cash flows and changes in equity for the year ended on that date.

Basis for Qualified Opinion

1. For the Year ending on 31st March 2021 the company has discontinued to make theprovision of interest on loans from banks and financial institutions (excluding on thesettlement entered with ARCs for specific loans which are assigned to them and also on theloans which are time barred under the law of limitation). Had the company continued thesaid practice of making provision of interest on loans from banks and financialinstitutions for the year ended on 31st March 2021 the loss for the year would have beenhigher by Rs 146.61 lacs and current liabilities would have been higher to that extent.(Refer Note No 33 of notes forming part of standalone IND AS financial statements)

2. The Company has not assessed the impact of Effective Interest Method to the financecost as per the requirement of lnd AS 109 'Financial Instruments and hence the effect ofthe same if any on the financial results is not identifiable therefore we are unable tocomment upon its impact on the Financial results for the year ended March 31 2021. (ReferNote No 43 of notes forming part of standalone IND AS financial statements)

3. The Company has not evaluated the provisioning requirement of a loss allowance onits financial assets so as to give impact of impairment if any as per the expected creditloss method as per the requirement of lnd AS 109 'Financial Instruments' and hence theeffect of the same if any on the Financial Results is not identifiable therefore. We areunable to comment upon its impact on the financial results for the year ended March 312021. (Refer Note No 44 of notes forming part of standalone IND AS financial statements)

We conducted our audit in accordance with the Standards on Auditing specified undersection 143(10) of the Act. Our responsibilities under those Standards are furtherdescribed in the Auditor's Responsibilities for the Audit of the standalone Ind ASFinancial 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 (ICAI) together with the ethical requirements that are relevant to our audit of thestandalone Ind AS financial statements under the provisions of the Act and the Rulesthereunder and we have fulfilled our other ethical responsibilities in accordance withthese requirements and the Code of Ethics. We believe that the audit evidence we haveobtained is sufficient and appropriate to provide a basis for our opinion on thestandalone Ind AS Financial statement.

Material Uncertainty Related to Going Concern

The Company's current liabilities exceeded its current assets as at the previous yearbalance sheet date. These conditions indicate the existence of a material uncertainty thatmay cast significant doubt about the Company's ability to continue as a going concern.However in the view of the management the Company is making sincere efforts for therevival of the Business & the management is confident to recover the losses throughimproved profitability in foreseeable future and therefore the financial results of theCompany have been prepared on a "going concern basis". (Refer Note no 42 ofnotes forming part of standalone Ind AS 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 Ind AS financial statements of the currentperiod. These matters were addressed in the context of our audit of the standalone Ind ASfinancial statements as a whole and in forming our opinion thereon and we do not providea separate opinion on these matters.

Description of Key audit Matter Our response and results
Litigations and claims Our audit procedures inter alia included following:
(Refer note 37) to the standalone financial statements) - Discussed disputed litigation matters with the company's management.
The cases are pending with multiple tax authorities like Service tax and Excise and there are claims against the company which have not been acknowledged as debt by the company. - Evaluated the management's judgment of tax risks estimates of tax exposures other claims and contingencies.
In normal course of business financial exposures may arise from pending proceedings and from claims of the customers not acknowledged as debt by the company. Whether a claim needs to be recognized as liability or disclosed as contingent liability in the standalone Ind AS financial statements is dependent on a number of significant assumptions and judgments. The amounts involved are potentially significant and determining the amount if any to be recognized or disclosed in the standalone Ind AS financial statements is inherently subjective. Past and current experience with the tax authorities and management's correspondence/response including on the claims lodged by customers were used to assess the appropriateness of management's best estimate of the most likely outcome of each uncertain contingent liability.
We have considered Litigations and claims a Key Audit Matter as it requires significant management judgement including accounting estimates that involves high estimation uncertainty. - Critically assessed the entity's assumptions and estimates in respect of claims included in the contingent liabilities disclosed in the standalone Ind AS financial statements. Also assessed the probability of negative result of litigation and the reliability of estimates of related obligations.
Conclusion:
Based on the procedures described above we did not find any material exceptions to the management's assertions and treatment presentation S disclosure of the subject matter in the standalone Ind AS financial statements.

Emphasis of Matter

1. The company has regarded the Loan/Debt of one Bank and one Financial Institutions inrespect of which no claim for recovery of either Interest or Principal has been made sincemore than last 10 fiscal years as no longer payable. Thus the company has identified suchLoan/Debt of Rs.1642.78 Lakhs as no longer payable and the same has been credited to"Capital Reserve Account" in the Statement of Assets and Liabilities as at 31stMarch 2021. Further the Interest Liability on the above Loan/Debt amounting to Rs 1618.86lakhs relating to the earlier years has also been written back to the Statement of Profit& Loss for the year under review and accordingly has been reflected as an ExceptionalItem in the Statement of Profit and loss for the year ended on 31st March 2021. (ReferNote No 45 of notes forming part of standalone IND AS financial statements)

2 The Company's current liabilities exceeded its current assets as at the previous yearbalance sheet date. These conditions indicate the existence of a material uncertainty thatmay cast significant doubt about the Company's ability to continue as a going concern.However in view of the management the Company is making sincere efforts for the revivalof the Business S the management is confident to recover the losses through improvedprofitability in foreseeable future and therefore the financial results of the Companyhave been prepared on a "going concern basis". (Refer Note No 42 of notesforming part of standalone IND AS financial statements) Our opinion is not modified on theabove matters.

Our opinion is not modified on the above matters.

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

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

Our opinion on the standalone Ind AS financial statements does not cover the otherinformation and we do not express any form of assurance conclusion thereon.

In connection with our audit of the standalone Ind AS financial statements ourresponsibility is to read the other information and in doing so consider whether theother information is materially inconsistent with the standalone Ind AS financialstatements or our knowledge obtained in the audit or otherwise appears to be materiallymisstated. If based on the work we have performed we conclude that there is a materialmisstatement of this other information we are required to report that fact. We havenothing to report in this regard.

Responsibilities of Management and Those Charged with Governance for the Standalone IndAS 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 Ind AS financialstatements that give a true and fair view of the state of affairs (financial position)Profit or loss(financial performance including other comprehensive income) changes inequity and cash flows of the Company in accordance with the accounting principlesgenerally accepted in India including the Indian Accounting Standards ('Ind AS')specified under section 133 of the Act. This responsibility also includes maintenance ofadequate accounting records in accordance with the provisions of the Act for safeguardingof the assets of the Company and for preventing and detecting frauds and otherirregularities; selection and application of appropriate accounting policies; makingjudgments and estimates that are reasonable and prudent; and design implementation andmaintenance of adequate internal financial controls that were operating effectively forensuring the accuracy and completeness of the accounting records relevant to thepreparation and presentation of the standalone Ind AS financial statements that give atrue and fair view and are free from material misstatement whether due. to fraud orerror.

In preparing the standalone Ind AS 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.

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

Auditor's Responsibilities for the Audit of the Standalone Ind AS Financial Statements

Our objectives are to obtain reasonable assurance about whether the standalone Ind ASfinancial 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 Standards on Auditing will always detect a material misstatement when it exists.Misstatements can arise from fraud or error and are considered material if; individuallyor in the aggregate they could reasonably be expected to influence the economic decisionsof users taken on the basis of these standalone Ind AS financial statements

As part of an audit in accordance with Standards on Auditing we exercise professionaljudgment and maintain professional skepticism throughout the audit. We also:

• Identify and assess the risks of material misstatement of the standalone Ind ASfinancial 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 control relevant to the audit in order todesign audit procedures that are appropriate in the circumstances. Under section 143(3)(i)of the Act we are also responsible for expressing our opinion on whether the company hasadequate internal financial controls system in place and the operating effectiveness ofsuch controls.

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

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

• Evaluate the overall presentation structure and content of the standalone IndAS financial statements including the disclosures and whether the standalone Ind ASfinancial statements represent the underlying transactions and events in a manner thatachieves 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 standalone Ind AS financialstatements of the current period and are therefore the key audit matters. We describethese matters in our auditor's report unless law or regulation precludes public disclosureabout the matter or when in extremely rare circumstances we determine that a mattershould not be communicated in our report because the adverse consequences of doing sowould reasonably be expected to outweigh the public interest benefits of suchcommunication.

Report on Other Legal and Regulatory Requirements

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

2. As required by the Companies (Auditor's Report) Order 2016 (''the Order")issued by the Central Government of India in terms of sub-section (11) of section 143 ofthe Act we give in the "Annexure A" a statement on the matters specified inparagraphs 3 and 4 of the Order.

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

a. We have sought and except for the matters described in the Basis for Qualifiedopinion obtained all the information and explanations which to the best of our knowledgeand belief were necessary for the purposes of our audit

b. Except for the possible effects of the matter described in the Basis for Qualifiedopinion paragraph above In our opinion proper books of account as required by law havebeen kept by the Company so far as it appears from our examination of those books

c. The standalone Balance Sheet the standalone Statement of Profit and Loss includingother Comprehensive Income standalone Statement of Changes in Equity and the standaloneStatement of Cash Flow dealt with by this Report are in agreement with the. books ofaccount.

d. Except for the possible effects of the matter described in Basis of Qualifiedopinion paragraph In our opinion the aforesaid standalone financial statements complywith the Indian Accounting Standards specified under section 133 of the Act.

e. On the basis of written representations received from the directors as on March312021 taken on record by the Board of Directors none of the Directors is disqualifiedas on March 312021 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 B". Our report express an unmodified opinion on theadequacy and operating effectiveness of the company's internal financial control overfinancial reporting.

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 2014as 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 the standalone Ind AS financial statements (Refer Note No 37 the StandaloneInd AS financial statements.)

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

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

For Parikh & Majmudar
Chartered Accountants
FR No. 107525W
UDIN: 21040230AAAAHD9631
Sd/-
[C.A (Dr) Hiten M. Parikh]
Place:Ahmedabad PARTNER
Date: 30/06/2021 Membership No. 40230

ANNEXURE A -TO THE INDEPENDENT AUDIT REPORT

OF EVEN DATE TO THE MEMBERS OF SHAH ALLOYS LIMITED ON THE STANDALONE FIANCIALSTATEMENTS FOR THE YEAR ENDED 31ST MARCH 2021

(i) In respect of its Property Plant & Equipments:

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

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

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

(ii) As explained to us inventories (excluding goods lying at port) were physicallyverified by management at reasonable intervals during the year. In our opinion thefrequency of the verification is reasonable. The discrepancies noticed on verificationbetween the physical stocks and the book records were not material.

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

(iv) According to the information and explanations given to us the company has notmade any investment or given any loans during the year under review. Accordinglyparagraph 3(iv) of theOrder is not applicable.

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

(vi) We have broadly reviewed the books of accounts maintained by the company pursuantto the rules made by the Central Government of India for the maintenance of Cost recordsspecified under section 148 of Companies Act 2013 and are of the opinion that prima faciethe prescribed accounts & records have been made and maintained. We have however notmade a detailed examination of the cost records with a view to determine whether they areaccurate or complete.

(vii)(a) According to the information and explanation given to us and on the basis ofexamination of the records of the Company amounts deducted/ accured in the books ofaccounts in respect of undisputed statutory dues including provident fund ESICincome-tax Goods& Service Tax duty of customs cess and other statutory dues havenot been generally regularly deposited during the year with the appropriate authorities.

According to the information and explanation given to us no undisputed amounts payablein respect of provident fund ESIC income-tax Goods & ServIce Tax duty ofcustoms cess and other statutory dues were outstanding as at 31st March2021 for a periodof more than six months from the date of becoming payable

b) On the basis of records produced before us for our verification and according to theinformation and explanations given to us the details of disputed dues that have not beendeposited as on 31st March 2021 on account of matters pending before the appropriateauthorities are as under:

Sr. no Name of the statue Nature of Dues Financial year to which it relates From where the dispute is pending Amount under dispute not yet deposited (Net of Payments) (in Rs lakhs.)
1 Custom Service tax and Excise Service tax January 2005 to July 2011 The Commissioner of Central Excise Ahmedabad III 51.58
2 Custom Service tax and Excise Service tax November 2012 to March 2013 The Addl. Commissioner of Central Excise Ahmedabad III 1.71
3 Custom Service tax and Excise Service tax 2013-14 The Joint Commissioner of Central Excise Ahmedabad III 1.48
4 Custom Service tax and Excise Service tax November 1997 to June 1998 Gujarat High Court 25.43
5 Custom Service tax and Excise Excise duty September 2010 to Dec. 2013 Custom Excise and Service Tax Appellate Tribunal Ahmedabad 1909.76
6 Custom Service tax and Excise Service tax Dec. 2014 to May 2015 The Dy Commissioner of Central Excise Division Kalol Ahmedabad III 0.87
7 Custom Service tax and Excise Service tax June 2015 to Dec. 2015 The Asst. Commissioner of Central Excise & CGST Div.Kalol 5.75
8 Custom Service tax and Excise Service tax January 2016 to July 2016 The Asst. Commissioner of Central Excise & CGST Division Kalol 1.22
9 Custom Service tax and Excise Service tax August 2016 to June 2017 The Asst. Commissioner of Central Excise & CGST Division Kalol 1.83
10 Custom Service tax and Excise Service tax 2012-13 The Dy. Commissioner of Central Excise & CGST Division Kalol 10.11

(viii) Consequent upon the sanction of the restructuring package given under CDRmechanism by bank the company was required to start repaying the loans sanctioned by bankfrom June 2011 onwards however the company has made default in repaying the dues as perthe terms stipulated in CDR Rework Proposal. The amount and the period of default inrespect of term loan Funded interest term Loans Interest Payable on the said loan frombank is as under :

NAME OF THE BANK/FINANCIAL INSTITUTIONS NATURE OF FACILITY AMOUNT OF DEFAULT AS AT 31-03-2021 (Rs in lacs) PERIOD OF DEFAULT (No. of days )
HDFC BANK Term Loan 1196.46 1-3561
Funded Interest Term loan 449.41 1-2646
Interest Payable 877.89 1-3895

Except above the company has not defaulted in repayment of its dues to FinancialInstitutions. The company does not have any borrowings from Debenture holders orGovernment

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

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

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

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

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

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

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

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

For Parikh & Majmudar
Chartered Accountants
FR No. 107525W
UDIN: 21040230AAAAHD9631
Sd/-
[C.A (Dr) Hiten M. Parikh]
Place:Ahmedabad PARTNER
Date: 30/06/2021 Membership No. 40230

Annexure B to the Independent Auditor's Report of Even Date to the Members of SHAHALLOYS LIMITED on the Standalone Ind AS Financial Statements for the year ended on 31stMarch 2021 Independent Auditor's Report on the Internal Financial Controls under Clause(i) of Sub-section 3 of Section 143 of the Companies Act 2013 ("the Act")

In conjunction with our audit of the standalone Ind AS financial statements of M/sSHAH ALLOYS LIMITED ("the Company") as at and for the year ended 31st March2021. We have audited the internal financial controls over financial reporting of thecompany as of that date.

Management's Responsibility for Internal Financial Controls

The Company's Board of Directors is responsible for establishing and maintaininginternal financial controls based on the internal control over financial reportingcriteria established by the Company considering the essential components of internalcontrol stated in the Guidance Note on Audit of Internal Financial Controls over FinancialReporting issued by the Institute of Chartered Accountants of India ('ICAI'). Theseresponsibilities include the design implementation and maintenance of adequate internalfinancial controls that were operating effectively for ensuring the orderly and efficientconduct of the company's business including adherence to company's policies thesafeguarding of its assets the prevention and detection of frauds and errors theaccuracy and completeness of the accounting records and the timely preparation ofreliable financial information as required under the Act.

Auditor's' Responsibility

Our responsibility is to express an opinion on the Company's internal financialcontrols over financial reporting based on our audit. We conducted our audit in accordancewith the Standards on Auditing issued by ICAI and deemed to be prescribed under section143(10) of the Act to the extent applicable to an audit of internal financial controlsover financial reporting and the Guidance Note issued by ICAI. Those Standards and theGuidance Note require that we comply with ethical requirements and plan and perform theaudit to obtain reasonable assurance about whether adequate internal financial controlsover financial reporting was established and maintained and if such controls operatedeffectively in all material respects.

Our audit involves performing procedures to obtain audit evidence about the adequacy ofthe internal financial controls system over financial reporting and their operatingeffectiveness. Our audit of internal financial controls over financial reporting includedobtaining an understanding of internal financial controls over financial reportingassessing the risk that a material weakness exists and testing and evaluating the designand operating effectiveness of internal control based on the assessed risk. The proceduresselected depend on the auditor's judgment including the assessment of the risks ofmaterial misstatement of the financial statements whether due to fraud or error.

We believe that the audit evidence we have obtained is sufficient and appropriate toprovide a basis for our audit opinion on the Company's internal financial controls systemover financial reporting.

Meaning of Internal Financial Controls over Financial Reporting

A company's internal financial control over financial reporting is a process designedto provide reasonable assurance regarding the reliability of financial reporting and thepreparation of financial statements for external purposes in accordance with generallyaccepted accounting principles. A company's internal financial control over financialreporting includes those policies and procedures that:

(1) pertain to the maintenance 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 controls system over financial reporting and such internal financial controlsover financial reporting were operating effectively as at 31st March 2021 based on theinternal control over financial reporting criteria established by the Company consideringthe essential components of internal control stated in the Guidance Note issued by theICAI.

For Parikh & Majmudar
Chartered Accountants
FR No. 107525W
UDIN: 21040230AAAAHD9631
Sd/-
[C.A (Dr) Hiten M. Parikh]
Place: Ahmedabad PARTNER
Date: 30/06/2021 Membership No. 40230

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