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Shiv Aum Steels Ltd.

BSE: 535347 Sector: Others
NSE: SHIVAUM ISIN Code: INE719F01016
BSE 05:30 | 01 Jan Shiv Aum Steels Ltd
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Shiv Aum Steels Ltd. (SHIVAUM) - Auditors Report

Company auditors report

TO THE MEMBERS OF

Shiv Aum Steels Ltd.

REPORT ON THE FINANCIAL STATEMENTS

We have audited the accompanying financial statements of Shiv Aum Steels Ltd. (theCompany) which comprise the Balance Sheet as at March 31 2020 the Profit and LossStatement and the Cash Flow Statement for the year then ended and a summary of thesignificant accounting policies and other explanatory information.

MANAGEMENT'S RESPONSIBILITY FOR THE 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 financial statements that give a true and fair view of the financial positionfinancial performance and cash flows of the Company in accordance with the accountingprinciples generally accepted in India including Accounting Standards prescribed underSection 133 of the Act.

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 the 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 financialstatements that give a true and fair view and are free from material mis-statementwhether due to fraud or error.

AUDITORS' RESPONSIBILITY

Our responsibility is to express an opinion on these financial statements based on ouraudit.

We have taken into account the provisions of the Act the accounting and auditingstandards and matters which are required to be included in the audit report under theprovisions of the Act and the Rules made thereunder and the Order under section 143 (11)of the Act.

We conducted our audit of the financial statements in accordance with the Standards onAuditing specified under Section 143(10) of the Act. Those Standards require that wecomply with ethical requirements and plan and perform the audit to obtain reasonableassurance about whether the financial statements are free from material misstatement.

An audit involves performing procedures to obtain audit evidence about the amounts andthe disclosures in the financial statements. The procedures selected depend on theauditor's judgment including the assessment of the risks of material misstatement of thefinancial statements whether due to fraud or error. In making those risk assessments theauditor considers internal financial control relevant to the Company's preparation of thefinancial statements that give a true and fair view in order to design audit proceduresthat are appropriate in the circumstances. An audit also includes evaluating theappropriateness of the accounting policies used and the reasonableness of the accountingestimates made by the Company's Board of Directors as well as evaluating the overallpresentation of the financial statements.

Opinion

We have audited the accompanying financial statements of Shiv Aum Steels Limited("the Company") which comprise the balance sheet as at March 31 2021 theStatement of Profit and Loss and the Cash Flow Statement for the year then ended andnotes to the financial statements including a summary of significant accounting policiesand other explanatory information.

In our opinion and to the best of our information and according to the explanationsgiven to us the aforesaid financial statements give the information required by theCompanies Act 2013 as amended ("the Act") in the manner so required and give atrue and fair view in conformity with the accounting principles generally accepted inIndia of the state of affairs of the Company as at March 31 2021 its profit/loss &its cash flows for the year ended on that date.

Basis for Opinion

We conducted our audit of the financial statements in accordance with the Standards onAuditing (SAs) as specified under section 143(10) of the Act. Our responsibilities underthose Standards are further described in the 'Auditor's Responsibilities for the Audit ofthe Financial 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 together with the ethical requirements that are relevant to our audit of thefinancial statements under the provisions of the Act and the Rules thereunder and we havefulfilled our other ethical responsibilities in accordance with these requirements and theCode of Ethics. We believe that the audit evidence we have obtained is sufficient andappropriate to provide a basis for our audit opinion on the financial statements.

Key Audit Matters

Key audit matters are those matters that in our professional judgment were of mostsignificance in our audit of the financial statements for the financial year ended March31 2021. These matters were addressed in the context of our audit of the financialstatements as a whole and in forming our opinion thereon and we do not provide aseparate opinion on these matters. For each matter below our description of how our auditaddressed the matter is provided in that context.

We have determined the matters described below to be the key audit matters to becommunicated in our report. We have fulfilled the responsibilities described in theAuditor's responsibilities for the audit of the financial statements section of ourreport including in relation to these matters. Accordingly our audit included theperformance of procedures designed to respond to our assessment of the risks of materialmisstatement of the financial statements. The results of our audit procedures includingthe procedures performed to address the matters below provide the basis for our auditopinion on the accompanying financial statements.

• We have determined that there are no key audit matters to communicate in ourreport.

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 financial statements and our auditor's report thereon.]

Our opinion on the financial statements does not cover the other information and we donot express any form of assurance conclusion thereon.

In connection with our audit of the financial statements our responsibility is to readthe other information and in doing so consider whether such other information ismaterially inconsistent with the financial statements or our knowledge obtained in theaudit or otherwise appears to be materially misstated. If based on the work we haveperformed we conclude that there is a material misstatement of this other information weare required to report that fact. We have nothing to report in this regard.

Responsibilities of Management for the 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 financial statements that givea true and fair view of the financial position financial performance and cash flows ofthe Company in accordance with the accounting principles generally accepted in India. Thisresponsibility also includes maintenance of adequate accounting records in accordance withthe provisions of the Act for safeguarding of the assets of the Company and for preventingand detecting frauds and other irregularities; selection and application of appropriateaccounting policies; making judgments and estimates that are reasonable and prudent; andthe design implementation and maintenance of adequate internal financial controls thatwere operating effectively for ensuring the accuracy and completeness of the accountingrecords relevant to the preparation and presentation of the financial statements thatgive a true and fair view and are free from material misstatement whether due to fraud orerror.

In preparing the financial statements management is responsible for assessing theCompany's ability to continue as a going concern disclosing as applicable mattersrelated to going concern and using the going concern basis of accounting unless managementeither intends to liquidate the Company or to cease operations or has no realisticalternative 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 Financial Statements

Our objectives are to obtain reasonable assurance about 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 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.

We communicate with those charged with governance regarding among other matters theplanned scope and timing of the audit and significant audit findings including anysignificant deficiencies in internal control that we identify during our audit.

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

[From the matters communicated with those charged with governance we determine thosematters that were of most significance in the audit of the financial statements for thefinancial year ended March 31 2021 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 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 [based on our audit and on the consideration of report of the other auditors onseparate financial statements and the other financial information of the branches and / orjoint operations as noted in the 'Other Matter' paragraph] we give in the "Annexure1" a statement on the matters specified in paragraphs 3 and 4 of the Order.

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

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

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

(c) The Balance Sheet the Statement of Profit and Loss and the Cash Flow Statementdealt with by this Report are in agreement with the books of account.

(d) In our opinion the aforesaid financial statements comply with the AccountingStandards specified under Section 133 of the Act.

(e) On the basis of the written representations received from the directors as on March31 2021 taken on record by the Board of Directors none of the directors is disqualifiedas on March 31 2021 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 with reference tofinancial statements and the operating effectiveness of such controls refer to ourseparate Report in "Annexure A" to this report;

(g) In our opinion the managerial remuneration for the year ended March 31 2021 hasbeen paid / provided by the Company to its directors in accordance with the provisions ofsection 197 read with Schedule V to the Act;

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

i. The Company does not have any pending litigations which would impact its financialposition;

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.

ANNEXURE "A"

To the Independent Auditors' Report on the Financial Statements of Shiv Aum SteelsLimited (Referred to in paragraph 1 (f) under 'Report on Other Legal and RegulatoryRequirements' of our report of even date)

REPORT ON THE INTERNAL FINANCIAL CONTROLS OVER FINANCIAL REPORTING UNDER CLAUSE (i) OFSUBSECTION 3 OF SECTION 143 OF THE COMPANIES ACT 2013 ("THE ACT")

We have audited the internal financial controls over financial reporting of Shiv AumSteels Limited ("the Company") as of March 31 2021 in conjunction with ouraudit of the financial statements of the Company for the year ended on that date.

MANAGEMENT'S RESPONSIBILITY FOR INTERNAL FINANCIAL CONTROLS

The Company's management is responsible for establishing and maintaining internalfinancial controls based on the internal control over financial reporting criteriaestablished by the Company considering the essential components of internal control statedin the Guidance Note on Audit of Internal Financial Controls Over Financial Reporting (the"Guidance Note") issued by the Institute of Chartered Accountants of India.These responsibilities include the design implementation and maintenance of adequateinternal financial controls that were operating effectively for ensuring the orderly andefficient conduct of its 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 Companies Act 2013.

AUDITORS' RESPONSIBILITY

Our responsibility is to express an opinion on the Company's internal financialcontrols over financial reporting based on our audit. We conducted our audit in accordancewith the Guidance Note and the Standards on Auditing prescribed under Section 143(10) ofthe Companies Act 2013 to the extent applicable to an audit of internal financialcontrols. Those Standards and the Guidance Note require that we comply with ethicalrequirements and plan and perform the audit to obtain reasonable assurance about whetheradequate internal financial controls over financial reporting was established andmaintained and if such controls 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 auditor's judgement 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 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 and paymentsof the company are being made only in accordance with authorisations of management anddirectors of the company; and (3) provide reasonable assurance regarding prevention ortimely detection of unauthorised acquisition use or disposition of the company's assetsthat 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 controlover financial reporting may become inadequate because of changes in conditions or thatthe degree of compliance with the policies or procedures may deteriorate.

OPINION

In our opinion to the best of our information and according to the explanations givento us the Company has in all material respects an adequate internal financial controlssystem over financial reporting and such internal financial controls over financialreporting were operating effectively as at March 31 2021 based on the internal controlover financial reporting criteria established by the Company considering the essentialcomponents of internal control stated in the Guidance Note.

In terms of our report of even date attached.

ANNEXURE "B"

Companies (Auditor's Report) Order 2016

The Annexure referred to in Independent Auditors' Report to the members of the Shiv AumSteels Limited on the standalone financial statements for the year ended 31st March 2021we report that:

(i) In respect of its Fixed Assets:

(b) The Company has maintained proper records showing full particulars includingquantitative details and situation of all fixed assets on the basis of availableinformation.

(c) As Company has explained to us all the Fixed assets have been physical verified bythe Management in phased periodical manner which in our opinion is reasonable havingregard to the size of the company and nature of assets. No material discrepancies werenoticed on such physical verification.

(d) According to the information and explanations given to us and on the basis of ourexamination of the records of the Company the title deeds of immovable properties areheld in the name of the Company.

(ii) In our opinion the Inventories has been Physically verified during the year bythe management at reasonable intervals and as explained to us no material discrepancieswere noticed on Physical verification.

(iii) The Company has not granted any loans secured or unsecured to Companies firmslimited liability Partnership or other parties covered in the register maintained undersection 189 of the Companies Act 2013 ('the Act'). Accordingly the Provisions of clause3 (iii) (a) to (c) of the order are not applicable to the company and not commented upon.

(iv) In our opinion and according to the information and explanations given to usprovisions of section 186 of the Act in respect of loans and advances given investmentsmade and guarantees given has been complied with by the Company. The provisions ofsection 185 in respect of loans to directors including entities in which they areinterested and provisions of section 186 with respect to securities given are notapplicable to the Company and hence not commented upon.

(v) According to Information and explanation given to us the Company has not acceptedany deposits within the meaning of Sections 73 to 76 of the Act and the Companies(Acceptance of Deposits) Rules 2014 (as amended). Accordingly the provisions of clause3(v) of the Order are not applicable.

(vi) As informed to us the maintenance of Cost record as prescribed by the CentralGovernment under subsection (1) of section 148 of the act is not applicable.

(vii) In respect of statutory dues:

(a) According to the information and explanation given to us and records examined byus the company is regular in depositing undisputed statutory dues including providentfund employees' state insurance income-tax sales-tax service tax duty of customsduty of excise value added tax Cess and any other statutory dues to the appropriateauthorities. According to the information and explanation given to us there were noundisputed amounts payable in respect of Income Tax and any other statutory duesoutstanding as on 31st March 2021 for a period more than six months from the date theybecame payable.

(b) According to the information and explanations given to us the details of dues ofIncome Tax Sales Tax Service Tax Custom Duty Excise Duty and Value Added Tax whichhave not be deposited as on March 31 2021 on account of disputes are given below:

Particulars Period Demand Outstanding
1. Income Tax U/s 143 (3) A.Y. 2008-09 Rs. 505085/-
2. Income Tax U/s 115-WE A.Y. 2009-10 Rs. 30165/-
3. Income Tax U/s 143 (3) A.Y. 2012-13 Rs. 8970/-
4. Income Tax U/s 143 (3) A.Y. 2014-15 Rs. 123400/-

(viii) In our opinion and according to information and explanation given to us theCompany has not defaulted in Repayment of loans or borrowings to a financial Institutionbank government or debenture holder's. Accordingly paragraph 3(viii) of the Order is notapplicable.

(ix) In our opinion and according to information and explanation given to us theCompany was raised money by way of initial public offer during the year and money raisedby initial public offer were applied for the purpose for which they were raised.

(x) In our opinion and according to the information and explanations given to us nomaterial fraud by the Company or on the Company by its officers or employees has beennoticed or reported during the course of our audit.

(xi) In our opinion and according to the information and explanations given to us andbased on our examination of our records of the Company the Company has paid/ provided formanagerial remuneration in accordance with the requisite approvals mandated by theprovisions of Section 197 read with schedule V to the Act.

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

(xiii) In our opinion and according to the information and explanations given to us andbased on our examination of the records of the Company transactions with the relatedparties are in compliance with Sections 177 and 188 of the Act where applicable anddetails of such transactions have been disclosed in the financial statements as requiredby the applicable Generally accepted accounting standards.

(xiv) In our opinion and according to the information and explanations given to us andbased on our examination of the records of the Company the Company has not made anypreferential allotment or private placement of shares or fully or partly convertibledebentures during the year and the requirement of section 42 of the companies act 2013have been complied with and amount raised have been used for the purposes for which thefunds were raised.

(xv) In our opinion and according to the information and explanations given to us andbased on our examination of the records of the Company the Company has not entered intonon-cash transactions with directors or person connected with him as referred to insection 192 of the Act. Hence reporting under clause (xv) of paragraph 3 of the order isnot applicable to the company.

(xvi) In our opinion and according to the information and explanation given to us TheCompany is not required to be registered under Section 45-IA of the Reserve Bank of IndiaAct 1934.

ANNEXURE "B"

Companies (Auditor's Report) Order 2016

The Annexure referred to in Independent Auditors' Report to the members of the ShivAum Steels Limited on the standalone financial statements for the year ended 31stMarch 2020 we report that:

(i) In respect of its Fixed Assets:

(a) The Company has maintained proper records showing full particulars includingquantitative details and situation of all fixed assets on the basis of availableinformation.

(b) As Company has explained to us all the Fixed assets have been physical verified bythe Management in phased periodical manner which in our opinion is reasonable havingregard to the size of the company and nature of assets. No material discrepancies werenoticed on such physical verification.

(c) According to the information and explanations given to us and on the basis of ourexamination of the records of the Company the title deeds of immovable properties areheld in the name of the Company.

(ii) In our opinion the Inventories has been Physically verified during the year bythe management at reasonable intervals and as explained to us no material discrepancieswere noticed on Physical verification.

(iii) The Company has not granted any loans secured or unsecured to Companies firmslimited liability Partnership or other parties covered in the register maintained undersection 189 of the Companies Act 2013 ('the Act'). Accordingly the Provisions of clause3 (iii) (a) to (c) of the order are not applicable to the company and not commented upon.

(iv) In our opinion and according to the information and explanations given to usprovisions of section 186 of the Act in respect of loans and advances given investmentsmade and guarantees given has been complied with by the Company. The provisions ofsection 185 in respect of loans to directors including entities in which they areinterested and provisions of section 186 with respect to securities given are notapplicable to the Company and hence not commented upon.

(v) According to Information and explanation given to us the Company has not acceptedany deposits within the meaning of Sections 73 to 76 of the Act and the Companies(Acceptance of Deposits) Rules 2014 (as amended). Accordingly the provisions of clause3(v) of the Order are not applicable.

(vi) As informed to us the maintenance of Cost record as prescribed by the CentralGovernment under subsection (1) of section 148 of the act is not applicable.

(vii) In respect of statutory dues:

(a) According to the information and explanation given to us and records examined byus the company is regular in depositing undisputed statutory dues including providentfund employees' state insurance income-tax sales-tax service tax duty of customsduty of excise value added tax Cess and any other statutory dues to the appropriateauthorities. According to the information and explanation given to us there were noundisputed amounts payable in respect of Income Tax and any other statutory duesoutstanding as on 31st March 2020 for a period more than six months from the date theybecame payable.

(b) According to the information and explanations given to us the details of dues ofIncome Tax Sales Tax Service Tax Custom Duty Excise Duty and Value Added Tax whichhave not be deposited as on March 31 2020 on account of disputes are given below:

Sr. No. Particulars Period Demand Outstanding
1. Income Tax U/s 143 (3) A.Y. 2008-09 Rs. 505085/-
2. Income Tax U/s 115-WE A.Y. 2009-10 Rs. 30165/-
3. Income Tax U/s 143 (3) A.Y. 2012-13 Rs. 8970/-
4. Income Tax U/s 143 (3) A.Y. 2014-15 Rs. 123400/-

(viii) In our opinion and according to information and explanation given to us theCompany has not defaulted in Repayment of loans or borrowings to a financial Institutionbank government or debenture holder's. Accordingly paragraph 3(viii) of the Order is notapplicable.

(ix) In our opinion and according to information and explanation given to us theCompany was raised money by way of initial public offer during the year and money raisedby initial public offer were applied for the purpose for which they were raised.

(x) In our opinion and according to the information and explanations given to us nomaterial fraud by the Company or on the Company by its officers or employees has beennoticed or reported during the course of our audit.

(xi) In our opinion and according to the information and explanations given to us andbased on our examination of our records of the Company the Company has paid/ provided formanagerial remuneration in accordance with the requisite approvals mandated by theprovisions of Section 197 read with schedule V to the Act.

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

(xiii) In our opinion and according to the information and explanations given to us andbased on our examination of the records of the Company transactions with the relatedparties are in compliance with Sections 177 and 188 of the Act where applicable anddetails of such transactions have been disclosed in the financial statements as requiredby the applicable Generally accepted accounting standards.

(xiv) In our opinion and according to the information and explanations given to us andbased on our examination of the records of the Company the Company has not made anypreferential allotment or private placement of shares or fully or partly convertibledebentures during the year and the requirement of section 42 of the companies act 2013have been complied with and amount raised have been used for the purposes for which thefunds were raised.

(xv) In our opinion and according to the information and explanations given to us andbased on our examination of the records of the Company the Company has not entered intonon-cash transactions with directors or person connected with him as referred to insection 192 of the Act. Hence reporting under clause (xv) of paragraph 3 of the order isnot applicable to the company.

(xvi) In our opinion and according to the information and explanation given to us TheCompany is not required to be registered under Section 45-IA of the Reserve Bank of IndiaAct 1934.

In terms of our report of even date attached.
For AGRAWAL JAIN & GUPTA
Chartered Accountants
Firm Registration No. 013538C
s/d
CA Narayan Swami
Partner
Membership No. 409759
Mumbai: 23rd July 2020

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