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Shalimar Paints Ltd.

BSE: 509874 Sector: Consumer
NSE: SHALPAINTS ISIN Code: INE849C01026
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VOLUME 2425
52-Week high 126.00
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Buy Price 102.05
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OPEN 102.00
CLOSE 101.70
VOLUME 2425
52-Week high 126.00
52-Week low 70.55
P/E
Mkt Cap.(Rs cr) 555
Buy Price 102.05
Buy Qty 27.00
Sell Price 102.25
Sell Qty 1.00

Shalimar Paints Ltd. (SHALPAINTS) - Auditors Report

Company auditors report

To

The Members of

Shalimar Paints Limited

Report on the Audit of Standalone Financial Statements

Opinion

We have audited the accompanying standalone Ind AS financial statements of ShalimarPaints Limited ("the Company") which comprise the Balance Sheet as at 31stMarch 2020 and the Statement of Profit and Loss (including Other Comprehensive Income)the Cash Flow Statement and the Statement of Changes in Equity for the year ended on thatdate and Notes to the standalone Ind AS financial statements(including a summary of thesignificant accounting policies and other explanatory information (herein after referredto as "the Standalone financial statements").

In our opinion and to the best of our information and according to the explanationsgiven to us the aforesaid standalone Ind AS financial statements give the informationrequired by the Companies Act 2013 (the ‘Act') in the manner so required and give atrue and fair view in conformity with the accounting principles generally accepted inIndia and the Indian Accounting Standards (Ind AS) prescribed under section 133 of the Actread together with Companies (Indian Accounting Standards) Rules 2015 of the state ofaffairs of the Company as at 31st March 2020 and its loss totalcomprehensive income its cash flows and the changes in equity for the year ended on thatdate.

Basis for Opinion

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

Emphasis of Matter

We draw your attention to note no 58 of standalone financial statements which explainsthe management's assessment/evaluation of the financial impact due to lockdown arisingwith the advent of COVID 19.

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

Sr.No. Key Audit Matter Auditor's Response
1 Evaluation of Trade receivables: Principal Audit Procedures
The Company's Trade receivables included material disputed receivables & receivables against which legal proceedings have been initiated or to be initiated by the Company. While reviewing the quality of trade receivables from realization perspective based on information & explanation made available to us we also have relied upon the management representation with respect to fair valuation of trade receivable in accordance of applicable Ind AS which have been confirmed by the IBBI Registered Valuer recognized under Companies Act 2013 (hereinafter referred to as ‘Registered Valuer').
The Company has made provision for trade receivables (which are significantly disputed and which are subjected to legal proceedings) for Rs. 2601.25 Lakh under the head ‘Life Time Expected Credit Loss' besides regular provisioning for expected credit loss of Rs. 53.00 Lakh under the head ‘12 months Expected Credit Loss'. [(Refer Note 47(ii) of the Standalone Financial Statement] Trade receivables which carried significant credit risk and /or credit impaired as evaluated in terms of provisioning thereof have been broadly reviewed by us on selective basis.
The provision for Life Time credit loss is 100% of receivables (disputed) whereas in the previous year it was 40%. Our audit approach was a combination of test of internal controls with respect to Trade receivable management and substantive procedures.
The Audit Committee of the Company has also reviewed and approved the provisioning of Trade receivables for fair value thereof.
2 Evaluation of Exceptional Expenses Principal Audit Procedures
The Company during the year has written off / provided for /paid substantial amount of Rs. 704.95 lakh in relation to transactions of earlier years. The said amount included ‘Other balances written off - Rs. 509.87 lakh [Refer Note (39.1) of the Standalone Financial Statement] ‘Other balances written off - Rs. 509.87 lakh
It comprises- (i) Sales/CST/VAT deposits written off- ' 384.10 lakh (on assessments completed under relevant Acts) (ii) Irrecoverable Other deposits written off - Rs. 84.22 lakh (iii) Unrealizable Receivables written off - Rs. 41.55 lakh net of credit balance of Rs.171.77 Lakh. We have relied upon the management representation & certification while carrying out our audit.
We have broadly reviewed ‘Exceptional Expenses' on selective basis as per information and explanation furnished to us.
The Audit Committee of the Company has also reviewed and approved the said write off for fair valuation of current assets.
3 Evaluation of un-ascertained tax & other liabilities Principal Audit Procedures
The Company has material unascertained disputed taxes & other liabilities shown as continent liabilities the determination of which involves significant management judgment. (Refer Notes 43 of the Standalone Financial Statements) We have obtained the details of completed tax assessments and demands for the year ended and up to March 31 2020 from management. We evaluated the management's underlying assumptions in estimating the tax provision and the possible outcome of the disputes. We have also evaluated the disputed tax demands of earlier years having regard to legal precedence and other rulings in evaluating management's position on these uncertain tax positions.
The material uncertain tax position & uncertain other liabilities giving rise to disputed liabilities shown as contingent liabilities have been examined by us having regard to material information & explanation furnished to us by the management. We review material uncertain tax position & uncertain other liabilities from year to year basis for changes therein.

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 Annual reportcomprising Management Discussion and Analysis Board's Report including Annexures toBoard's Report Business Responsibility Report Corporate Governance and Shareholder'sInformation among others ; but does not include the standalone financial statements andour 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 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 financial statements orour knowledge obtained during the course of our audit or otherwise appears to bematerially misstated.

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.

Management's Responsibility for the Standalone Ind AS Financial Statements

The Company's Board of Directors is responsible for the matters stated in Section134(5) of the Companies Act 2013 ("the Act") with respect to the preparation ofthese standalone Ind AS financial statements that give a true and fair view of thefinancial position financial performance including other comprehensive income cash flowsand changes in equity of the Company in accordance with the accounting principlesgenerally accepted in India including the Indian Accounting Standards (Ind AS) prescribedunder Section 133 of the Act read with relevant rules issued thereunder.

This responsibility also includes maintenance of adequate accounting records inaccordance with the provisions of the Act for safeguarding the assets of the Company andfor preventing and detecting frauds and other irregularities; selection and application ofappropriate accounting policies; making judgments and estimates that are reasonable andprudent; and design implementation and maintenance of adequate internal financialcontrols that were operating effectively for ensuring the accuracy and completeness ofthe accounting records relevant to the preparation and presentation of the standalone IndAS financial statements that give a true and fair view and are free from materialmisstatement whether due to fraud or error.

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.

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

Auditor's responsibility for the audit of the 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 (SAs)will always detect 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 SAs we exercise professional judgment andmaintain 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 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 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 financial statements or if such disclosures are inadequate to modify ouropinion. Our conclusions are based on the audit evidence obtained up to the date of ourauditor's report. However future events or conditions may cause the Company to cease tocontinue as a going concern.

• Evaluate the overall presentation structure and content of the standalone IndAS financial statements including the disclosures and whether the Ind AS standalonefinancial statements represent the underlying transactions and events in a manner thatachieves fair presentation.

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 chargedwith governance regarding among other matters the planned scope and timing of the auditand significant audit findings including any significant deficiencies in internal controlthat 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.

Other Matters

(i) As per information and explanation furnished to us the insurance claims of lossfor damage of immovable & movable assets and for Loss of profit due to fire inCompany's plant located at Nasik are yet to be assessed by the Insurer & claim havebeen accounted for on estimated/realization basis. The Company is in arbitration foradditional claim on account of fire claim at Howrah Plant (Note 53 & 54 of standalonefinancial statements).

(ii) Some of the financial assets & liabilities including trade receivables tradepayables & advances are pending confirmation /reconciliation and their impact onfinancial statements if any is unascertained (Note 59 of standalone financialstatements)

(iii) As regard disclosure in Note 44 of standalone financial statements regardingMicro Small & Medium Enterprise we have relied upon the information &explanation to the extent made available to us by the management.

Our opinion on the standalone Ind AS financial statements and our report on Other Legaland Regulatory Requirements below is not modified in respect of these matters.

Report on Other Legal and Regulatory Requirements

1. As required by Section 143(3) of the Act based on our audit we report to theextent 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.

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 relevant books of account.

d) In our opinion the aforesaid standalone Ind AS financial statements comply with theIndian Accounting Standards prescribed under Section 133 of the Act& Rules madethereunder.

e) On the basis of the written representations received from the directors as on 31stMarch 2020 taken on record by the Board of Directors none of the directors isdisqualified as on 31st March 2020 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 ourseparate Report in "Annexure A". Our report expresses an unmodifiedopinion on the adequacy and operating effectiveness of the Company's internal financialcontrols over financial reporting.

g) With respect to the other matters to be included in the Auditor's Report inaccordance with the requirements of section 197 (16) of the Act as amended:

In our opinion and to the best of our information and according to the explanationsgiven to us the remuneration paid by the Company to its directors during the year is inaccordance with the provisions of section 197 of the Act.

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

i. The Company has disclosed the impact of pending litigations on its financialposition in its standalone Ind AS financial statements. (Note 43(i) to the standalone IndAS financial statements)

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

iii. There has been no delay in transferring amounts required to be transferred to theInvestor Education and Protection Fund.

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

For A K Dubey & Co.
Chartered Accountants
Firm Registration No. 329518E
Place : Kolkata
Date : 30th June 2020 Arun Kumar Dubey
Partner
Membership No.- 057141
UDIN: 20057141AAAAAU6839

Annexure "A" to the independent Auditors' Report

(Referred to in paragraph 1(f) under ‘Report on Other Legal and RegulatoryRequirements' Section of our report of even date to the Members of Shalimar PaintsLimited)

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 ShalimarPaints Limited ("the Company") as of 31st March 2020 in conjunctionwith our audit of the standalone Ind AS financial statements of the Company for the yearended on that date.

Management's Responsibility for Internal Financial Controls

The Company's management represented by the Board of directors is responsible forestablishing and maintaining internal financial controls based on the internal controlover financial reporting criteria established by the Company considering the essentialcomponents of internal control stated in the Guidance Note on Audit of Internal FinancialControls over the Financial Reporting issued by the Institute of Chartered Accountants ofIndia ("ICAI"). These responsibilities include the design implementation andmaintenance of adequate internal financial controls that were operating effectively forensuring the orderly and efficient conduct of its business including adherence tocompany's policies the safeguarding of its assets the prevention and detection of fraudsand errors the accuracy and completeness of the accounting records and the timelypreparation of reliable 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 of the Company based on our audit. We conducted ouraudit in accordance with the Guidance Note on Audit of Internal Financial Controls OverFinancial Reporting (the "Guidance Note") issued by the Institute of CharteredAccountants of India and the Standards on Auditing prescribed under Section 143(10) of theCompanies Act 2013 to the extent applicable to an audit of internal financial controls.Those Standards and the Guidance Note require that we comply with ethical requirements andplan and perform the audit to obtain reasonable assurance about whether adequate internalfinancial controls over financial reporting was 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 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 auditors' 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 controls 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 controls over financialreporting includes those policies and procedures that (1) pertain to the maintenance ofrecords that in reasonable detail accurately and fairly reflect the transactions anddispositions of the assets of the company; (2) provide reasonable assurance thattransactions are recorded as necessary to permit preparation of financial statements inaccordance with generally accepted accounting principles and that receipts andexpenditures of the Company are being made only in accordance with authorizations ofmanagement and directors of the Company; and (3) provide reasonable assurance regardingprevention or timely detection of unauthorized acquisition use or disposition of thecompany's assets that could have a material effect on the financial statements.

Inherent Limitations of Internal Financial Controls Over Financial Reporting

Because of the inherent limitations of internal financial controls over financialreporting including the possibility of collusion or improper management override ofcontrols material misstatements due to error or fraud may occur and not be detected.Also projections of any evaluation of the internal financial controls over financialreporting to future periods are subject to the risk that the internal financial controlsover 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 controlssystem over financial reporting and such internal financial controls over financialreporting were operating effectively as at 31st March 2020 based on theinternal control over financial reporting criteria established by the Company consideringthe essential components of internal control stated in the Guidance Note on' Audit ofInternal Financial Controls Over Financial Reporting' issued by the Institute of CharteredAccountants of India.

For A K Dubey & Co.
Chartered Accountants
Place : Kolkata Firm Registration No. 329518E
Date : 30th June 2020
Arun Kumar Dubey
Partner
Membership No.- 057141
UDIN: 20057141AAAAAU6839

Annexure "B" to the independent Auditors' Report

(Referred to in paragraph 2 under ‘Report on Other Legal and RegulatoryRequirements section of our report of even date to the Members of Shalimar Paints Limited)

i. (a) The Company has maintained proper records showing full particulars includingquantitative details and situation of property plant and equipment.

(b) The Company has a regular programme /policy of physical verification of its fixedassets included in Property Plant & Equipment (PPE) by which all fixed assets areverified in a phased manner. In our opinion this periodicity of physical verification isreasonable having regard to the size of the Company and the nature of its assets. As perthe policy certain property plant and equipment were physically verified by theManagement during the year. According to the information and explanations given to us nomaterial discrepancies were noticed on such verification.

(c) According to the information and explanations given to us and the records examinedby us on test basis we report that the title deeds in respect of freehold immovableproperties of land and buildings are held in the name of the Company as at the BalanceSheet date. In respect of leasehold immovable properties the lease agreements are in thename of the Company.

ii. The inventory (except material/ goods-in-transit) have been physically verifiedby the management during the year. In our opinion the frequency of such verification isreasonable. The discrepancies noticed on verification between the physical stocks and thebook records were not material and have been dealt with in books of account.

iii. The Company is to receive ' 750.92 lakh (previous year ' 722.09lakh) from its subsidiary Shalimar Adhunik Nirman Limited( SANL) which is shown under thehead ‘Loans (Non-current) under sub head ‘Loan to Related parties' in Note 9 ofthe Financial Statement. The said loan includes '492.00 lakh (Note 50) beingconsideration money for transfer of Land by the Company to SANL and the same is interestfree. The terms and conditions of said advances are not prejudicial to the Company'sinterest.

As per information & explanation given to us the repayment schedule is beingadhered to so far as it relates to payment of principal & interest whenever they falldue. As certified by management there is no overdue amount of loan & interest.

Except loan and advances to the aforesaid subsidiary the Company has not granted anyloans secured or unsecured to companies firms Limited Liability Partnership or otherparties covered in the register maintained under section 189 of the Companies Act 2013.

iv. In our opinion and according to information and explanations given to us inrespect of loans investments guarantees and security the Company has complied with theprovisions of section 185 & 186 of the Companies Act 2013 to the extent applicable.

v. I n our opinion and according to the information and explanations given to us theCompany has not accepted any deposit from the public in accordance with the provisions ofSections 73 to 76 or any other relevant provisions of the Act and the rules framedthereunder. Accordingly Clause 3(v) of the Order is not applicable to the Company.

vi. The Central Government has prescribed Cost Records under Section 148(1) of theCompanies Act2013 in respect of certain manufacturing activities of the Company. Howeveras per information and explanation furnished to us the said cost records are notstatutorily required to be maintained during the year under audit.

vii. According to the information and explanations given to us in respect of statutorydues:

(a) The Company has generally been regular in depositing undisputed statutory duesincluding Provident Fund Employees' State Insurance Income Tax Goods and Service TaxSales Tax Service Tax Customs Duty Excise Duty Value Added Tax cess and othermaterial statutory dues applicable to it to the appropriate authorities though there havebeen slight delays in few cases.

(b) There were no undisputed amounts payable in respect of Provident Fund Employees'State Insurance Income Tax Goods and Service Tax Sales Tax Service Tax Customs DutyExcise Duty Value Added Tax cess and other material statutory dues in arrears as at 31stMarch 2020 for a period of more than six months from the date they became payable exceptexcise & Custom duty of ' 406.98 lakh (included in note no 28 of Other currentliabilities-"Statutory Dues") of Financial Statements.

(c) Details of disputed dues of Income Tax Sales Tax Service Tax Excise Duty andValue Added Tax which have not been deposited as on 31st March 2020 on accountof disputes are given below:

Name of Statute Nature of dues Forum where dispute is pending Amount Involved (Rs. lakh)
Central Excise Act 1944 Excise Duty Various Assessing Appellate & Tribunal Authorities 461.07
Sales Tax Act Central Sales Tax & VAT Various Assessing Appellate Tribunal & Revision Board Authorities 1851.94
Income Tax Act 1961 Income Tax Various Assessing & Appellate Authorities 67.50

viii. As per the information and explanations given to us the Company has notdefaulted in repayment of loans or borrowings to a financial institution bank governmentor dues to debenture holders.

ix. The Company has not raised money by way of initial public offer or further publicoffer (including debt instruments) According to information & explanation given to usthe term loans are applied for the purposes for which those are raised.

x. Based upon the audit procedures performed for the purpose of reporting the true andfair view of the financial statements and according to the information and explanationsgiven by the management we report that no fraud by the Company or on the Company by theofficers and employees of the Company has been noticed or reported during the year.

xi. According to the information and explanations given by the management themanagerial remuneration has been paid / provided in accordance with the requisiteapprovals mandated by the provisions of section 197 read with Schedule V to the CompaniesAct 2013.

xii. The Company is not a Nidhi Company & accordingly reporting under Clause (xii)of the Order is not applicable to the Company.

xiii. According to the information and explanations given to us all transactions withthe related parties are in compliance with Section 177 and 188 of Act where applicable;and the details have been disclosed in the Financial Statements as required by theapplicable Indian Accounting Standards.

xiv. During the year the Company has made preferential allotment of equity shares[Refer Note no 19 (iii) of the Standalone Financial Statements] and complied with theprovisions of section 42 of Companies Act 2013. The said allotment is made againstdischarge of ECB loan availed by the Company. As per information and explanationsfurnished to us the amount raised has been used for intended purposes. The Company hasnot made any private placement of shares or fully or partly convertible debentures.

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 its directors or persons connected with them; hence provisions ofSection 192 of the Companies Act 2013 & Clause (xv) of the Order are not applicable.

xvi. The Company is not required to be registered under Section 45 IA of the ReserveBank of India Act 1934. Hence Clause (xvi) of the Order are not applicable.

For A K Dubey & Co.
Chartered Accountants
Place : Kolkata Firm Registration No. 329518E
Date : 30th June 2020
Arun Kumar Dubey
Partner
Membership No.- 057141
UDIN: 20057141AAAAAU6839

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