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Shiva Global Agro Industries Ltd.

BSE: 530433 Sector: Agri and agri inputs
NSE: N.A. ISIN Code: INE960E01019
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NSE 05:30 | 01 Jan Shiva Global Agro Industries Ltd
OPEN 65.70
PREVIOUS CLOSE 65.60
VOLUME 4563
52-Week high 83.05
52-Week low 27.05
P/E 8.07
Mkt Cap.(Rs cr) 65
Buy Price 63.50
Buy Qty 100.00
Sell Price 64.80
Sell Qty 7.00
OPEN 65.70
CLOSE 65.60
VOLUME 4563
52-Week high 83.05
52-Week low 27.05
P/E 8.07
Mkt Cap.(Rs cr) 65
Buy Price 63.50
Buy Qty 100.00
Sell Price 64.80
Sell Qty 7.00

Shiva Global Agro Industries Ltd. (SHIVAGLOBAL) - Auditors Report

Company auditors report

To

The Members of

SHIVA GLOBAL AGRO INDUSTRIES LIMITED

Report on the audit of the Standalone Financial Statements

Opinion

We have audited the accompanying Consolidated financial statements of Shiva Global AgroIndustries Limited ("the Parent") and its subsidiaries (the Parent and itssubsidiaries together referred to as "the Group") which comprise theConsolidated Balance sheet as at March 31 2020 the Consolidated Statement of Profit andLoss (including Other Comprehensive Income) the Consolidated Statement of Cash Flows andthe Consolidated Statement of Changes in Equity for the year then ended and notes to thefinancial statements including a summary of the significant accounting policies and otherexplanatory information (hereinafter referred to as "the consolidated financialstatements".)

In our opinion and to the best of our information and according to the explanationsgiven to us the aforesaid Consolidated financial statements give the information requiredby the Companies Act 2013 ("the Act") in the manner so required and give a trueand fair view in conformity with the Indian Accounting Standards prescribed under Section133 of the Act read with the Companies (Indian Accounting Standards) Rules 2015 asamended ("Ind AS") and other accounting principles generally accepted in Indiaof the consolidated state of affairs of the Group as at March 31 2020 and theirconsolidated profit their consolidated total comprehensive income their consolidatedcash flows and their consolidated changes in equity for the year ended on that date.

Basis for Opinion

We conducted our audit of the consolidated 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'sResponsibility for the Audit of the Consolidated 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 ethicalrequirements that are relevant to our audit of the consolidated 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 obtained by us is sufficient and appropriate toprovide a basis for our audit opinion on the consolidated financial statements.

Key Audit Matters

Key audit matters are those matters that in our professional judgment were of mostsignificance in our audit of the consolidated financial statements of the current period.These matters were addressed in the context of our audit of the consolidated financialstatements as a whole and in forming our opinion thereon and we do not provide aseparate opinion on these matters. We have determined the matters described below to bethe key audit matters to be communicated in our report.

Sr.No. Key Audit Matter Auditor's Response
1 Revenue recognition (as described in note 1.16 of the standalone financial statements)
For the year ended March 31 2020 the Company has recognized revenue from sale of products of Rs.48963.36 lakhs. Our audit procedures included the following :
•Our audit procedures included the following:
Revenue from sale of products is recognized when the significant risk and rewards of ownership of the goods have been transferred to the customer which generally coincide with the •Evaluated the Company's revenue recognition policy and its compliance in terms of Ind AS 115 ‘Revenue from contracts with customers'.
•Understood and tested the operating effectiveness of internal controls as established by the management in relation to revenue recognition.
delivery of goods recovery of consideration is probable the associated costs and possible return of goods can be estimated reliably there is no continuing management involvement with the goods and the amount of revenue can be measured reliably. The Company considers estimated time of delivery of goods and this has an impact on the timing and extent of revenue recognition from sale of products. The varied terms that define when title risk and rewards are transferred to the customer as well as the high volume of transactions give rise to the risk that revenue could be recognized in the incorrect period for sales transactions occurring on and around the year end. •Performed sales transactions testing based on a representative sampling and traced to sales invoices and other related documents to ensure that the related revenues and trade receivables are recorded appropriately taking into consideration the terms and conditions of the agreements with customers including the shipping terms.
•Tested sales transactions made near the year end by agreeing a sample of sales transactions occurring around the year end to supporting documentation including customer confirmation of receipt of goods to establish that sales and corresponding trade receivables are properly recorded in the correct period.
•Performed monthly analytical review of revenue from sale of goods by streams to identify any unusual trends.
Accordingly due to the significant risk associated with revenue recognition it has been determined to be a key audit matter in our audit of the Consolidated financial statements. •Assessed the relevant disclosures made within the Consolidated financial statements
2 Impact of government policies/ notifications on recognition of subsidy accruals/claims and their recoverability (as described in note 1.16 of the standalone financial statements) Our audit procedures included the following:
Subsidy income pertaining to fertilizer business is recognised on the basis of the rates notified •Obtained an understanding of the process and tested
from time to time by the Department of Fertilizers the design and operating effectiveness of controls as
Government of India (‘GOI') in accordance with established by management in recognition and
the Nutrient Based Subsidy (‘NBS') policy on the quantity of fertilizers sold by the Company for the period for which notification has been issued and for the remaining period based on estimates when there is a reasonable assurance that the Company will comply with all necessary conditions attached to Subsidy including Direct Benefit Transfer (‘DBT') System which was introduced by Government of India. assessment of the recoverability of the subsidy
•Evaluated the management's assessment regarding reasonable certainty for complying with the relevant conditions as specified in the notifications and policies and collections of subsidy
•Read all the notifications issued by Department of Fertilizers applicable for subsidy recognized during the year
For the year ended March 31 2020 subsidy income of Rs.1985.71 lakhs is recognized. •Considered the relevant notifications and policies issued by Department of Fertilizers to ascertain the recognition of subsidy adjustments thereto recognised pursuant to changes in the rates and basis for determination of subsidy.
Recognition and realisability of subsidy income
is dependent on GOI Policy and its various initiatives/schemes.
•Tested the ageing analysis and assessed the information used by the management to determine the recoverability of the subsidy by considering collections against historical trends the level of credit loss charged over time and provisions made.
•Correlated the sales quantity considered for subsidy income with the actual sales made by the Company.
•Agreed the quantities sold as per the Company books with the customer acknowledgements as per the iFMS portal of the Department of Fertilisers and tested the DBT claims made by the Company.
•Enquired from the Management and discussed with the Board of Directors the appropriateness of the subsidy rates applied to recognise subsidy income.
•Assessed the related disclosure in Consolidated financial statements

Other Information

The Parent's Board of Directors is responsible for the other information. The otherinformation comprises the information included in the Directors' Report and ManagementDiscussion and Analysis but does not include the consolidated financial statementsstandalone financial statements and our auditor's report thereon.

Our opinion on the consolidated 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 consolidated financial statements ourresponsibility is to read the other information and in doing so consider whether theother information is materially inconsistent with the consolidated 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 Consolidated Financial Statements

The Parent's Board of Directors is responsible for the matters stated in Section 134(5)of the Act with respect to the preparation of these consolidated financial statements thatgive a true and fair view of the consolidated financial position consolidated financialperformance including other comprehensive income consolidated cash flows and consolidatedchanges in equity of the Group in accordance with the Ind AS and other accountingprinciples generally accepted in India. The respective Board of Directors of the companiesincluded in the Group are responsible for maintenance of adequate accounting records inaccordance with the provisions of the Act for safeguarding the assets of the Group and forpreventing 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 consolidatedfinancial statements that give a true and fair view and are free from materialmisstatement whether due to fraud or error which have been used for the purpose ofpreparation of the consolidated financial statements by the Directors of the Parent asaforesaid.

In preparing the consolidated financial statements the respective Board of Directorsof the companies included in the Group are responsible for assessing the ability of theGroup to continue as a going concern disclosing as applicable matters related to goingconcern and using the going concern basis of accounting unless management either intendsto liquidate or cease operations or has no realistic alternative but to do so.

The respective Board of Directors of the companies included in the Group are alsoresponsible for overseeing the financial reporting process of the Group.

Auditor's Responsibility for the Audit of the Consolidated Financial Statements

Our objectives are to obtain reasonable assurance about whether the consolidatedfinancial statements as a whole are free from material misstatement whether due to fraudor error and to issue an auditor's report that includes our opinion. Reasonable assuranceis a high level of assurance but is not a guarantee that an audit conducted in accordancewith SAs will always detect a material misstatement when it exists. Misstatements canarise from fraud or error and are considered material if individually or in theaggregate they could reasonably be expected to influence the economic decisions of userstaken on the basis of these consolidated 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 consolidatedfinancial 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 control 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 theParent 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 the management.

•Conclude on the appropriateness of management's use of the going concern basis ofaccounting and based on the audit evidence obtained whether a material uncertaintyexists related to events or conditions that may cast significant doubt on the Group'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 consolidated financial statements or if such disclosures are inadequate to modifyour opinion. Our conclusions are based on the audit evidence obtained up to the date ofour auditor's report. However future events or conditions may cause the Group to cease tocontinue as a going concern.

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

•Obtain sufficient appropriate audit evidence regarding the financial informationof the entities or business activities within the Group to express an opinion on theconsolidated financial statements. We are responsible for the direction supervision andperformance of the audit of the financial statements of such entities or businessactivities included in the consolidated financial statements of which we are theindependent auditors. We remain solely responsible for our audit opinion.

Materiality is the magnitude of misstatements in the consolidated financial statementsthat individually or in aggregate makes it probable that the economic decisions of areasonably knowledgeable user of the consolidated financial statements may be influenced.We consider quantitative materiality and qualitative factors in (i) planning the scope ofour audit work and in evaluating the results of our work; and (ii) to evaluate the effectof any identified misstatements in the consolidated financial statements.

We communicate with those charged with governance of the parent regarding among othermatters the planned scope and timing of the audit and significant audit findingsincluding any significant deficiencies in internal control that we identify during ouraudit.

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

From the matters communicated with those charged with governance we determine thosematters that were of most significance in the audit of the consolidated 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 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 purpose of our audit of the aforesaidconsolidated financial statements.

b. In our opinion proper books of account as required by law relating to preparationof the aforesaid consolidated financial statements have been kept by the Company so far asit appears from our examination of those books.

c. The Consolidated Balance Sheet the Consolidated Statement of Profit and Lossincluding Other Comprehensive Income the Consolidated Statement of Cash Flows and theConsolidated Statement of Changes in Equity dealt with by this Report are in agreementwith the relevant books of account maintained for the purpose of the preparation of theconsolidated financial statements.

d. In our opinion the aforesaid consolidated financial statements comply with theAccounting Standards prescribed under section 133 of the Act.

e. On the basis of the written representations received from the directors of theParent as on March 31 2020 taken on record by the Board of Directors of the Parent andits subsidiary companies incorporated in India none of the directors of the Groupcompanies is disqualified as on March 31 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 and the operating effectiveness of such controls refer to our separate Reportin "Annexure A" which is based on the auditors' reports of the Parent and itssubsidiary companies incorporated in India. Our report expresses an unmodified opinion onthe adequacy and operating effectiveness of internal financial controls over financialreporting of those companies for the reasons stated therein.

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

i. The consolidated financial statements disclose the impact of pending litigations onthe consolidated financial position of the Group;

ii. The Group did not have any material foreseeable losses on long-term contractsincluding derivative contracts.

iii. There has been no delay in transferring amounts required to be transferred tothe Investor Education and Protection Fund by the Parent and its subsidiary companiesincorporated in India.

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

For Aditya Falor & Associates
Chartered Accountants
Firm Registration No. 127273W
Aditya G. Falor
Place : Nanded Proprietor
Date : July 03 2020 Membership No. 122487
UDIN: 20122487AAAACG3329

A n n e x u r e t o I n d e p e n d e n t A u d i t o r 's R e p o r t

"Annexure A" to Independent Auditors' Report

(Referred to in Paragraph 1(f) under the heading of "Report on Other Legal andRegulatory Requirements" of our report of even date:) i. FIXED ASSETS :

(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')

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')

In conjunction with our audit of the consolidated financial statements of the Companyas of and for the year ended March 31 2020 we have audited the internal financialcontrols over financial reporting of Shiva Global Agro Industries Limited (hereinafterreferred to as "the Parent") and its subsidiary companies which are companiesincorporated in India as of that date.

Management's Responsibility for Internal Financial Controls

The respective Board of Directors of the Parent and its subsidiary companies which arecompanies incorporated in India are responsible for establishing and maintaining internalfinancial controls based on the internal control over financial reporting criteriaestablished by the respective Companies 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 its business including adherence to the respective 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.

Auditor's Responsibility

Our responsibility is to express an opinion on the internal financial controls overfinancial reporting of the Parent and its subsidiary companies which are companiesincorporated in India based on our audit. We conducted our audit in accordance with theGuidance Note on Audit of Internal Financial Controls Over Financial Reporting (the"Guidance Note") issued by the Institute of Chartered Accountants of India andthe Standards on Auditing prescribed under Section 143(10) of the Companies Act 2013 tothe extent applicable to an audit of internal financial controls. 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 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 referred to in the Other Mattersparagraph below is sufficient and appropriate to provide a basis for our audit opinion onthe internal financial controls system over financial reporting of the Parent and itssubsidiary companies which are companies incorporated in India

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 the 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 to the best of our information and according to the explanations givento us the Parent and its subsidiary companies which are companies incorporated in Indiahave in all material respects an adequate internal financial controls system overfinancial reporting and such internal financial controls over financial reporting wereoperating effectively as at March 31 2020 based on the criteria for internal financialcontrol over financial reporting established by the respective companies considering theessential components of internal control stated in the Guidance Note on Audit of InternalFinancial Controls Over Financial Reporting issued by the Institute of CharteredAccountants of India.

For Aditya Falor & Associates
Chartered Accountants
Firm Registration No. 127273W
Aditya G. Falor
Place : Nanded Proprietor
Date : July 03 2020 Membership No. 122487
UDIN: 20122487AAAACG3329

Annexure B to Independent Auditors' Report

(Referred to in Paragraph 2 under the heading of "Report on Other Legal andRegulatory Requirements" of our report of even date:) i. FIXED ASSETS:

(a) The Company has maintained proper records showing full particulars includingquantitative details and situation of its fixed assets.

(b) The fixed assets have been physically verified by the management at reasonableintervals. No material discrepancies were noticed on such verification.

(c) According to the information & explanations given to us & on the basis ofour examination of the records of the Company title deeds of all immovable properties areheld in the name of company.

ii. INVENTORY :

As explained to us the inventories except goods-in-transit were physically verifiedduring the year by the management at reasonable intervals. According to the information& explanation given to us no material discrepancies were noticed on suchverification.

iii. LOANS GRANTED TO PARTIES COVERED U/S 189 OF COMPANIES ACT 2013 :

The company has not granted any loans secured or unsecured to companies firmslimited liability partnerships or other parties covered in the register maintained undersection 189 of the Act during the year. Accordingly paragraph 3(iii)of the Order is notapplicable to the Company.

iv. COMPLIANCE WITH SEC. 185 & SEC. 186 OF THE COMPANIES ACT 2013 :

In our opinion & according to the information & explanations given to us theCompany has duly complied with the provisions of Section 185 & Section 186 of theCompanies Act 2013 with respect to the loans & investments made.

v. DEPOSIT :

In respect of deposits accepted in our opinion and according to the information andexplanations given to us directives issued by the Reserve Bank of India and theprovisions of

Section 73 to 76 or any other relevant provisions of the Companies Act 2013 and therules framed there under to the extent applicable have been complied with. We areinformed by the management that no order has been passed by the National Company LawTribunal or Reserve Bank of India or any Court or any other Tribunal.

vi. COST RECORDS :

The Central Government has prescribed the maintenance of Cost Records u/s 148(1) of theCompanies Act 2013 for Fertilizers. We have broadly reviewed the books of accountmaintained by the Company pursuant to the Rules made by the Central Government for themaintenance of cost records under section 148 of the Act and are of the opinion thatprima facie the prescribed cost records have been made and maintained by the Company. Wehave however not made a detailed examination of the cost records with a view todetermine whether they are accurate or complete.

vii. STATUTORY DUES :

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 Sales Tax Customs DutyExcise Duty Value Added Tax Cess and other material statutory dues applicable to it withthe appropriate authorities.

(b) There were no undisputed amounts payable in respect of Provident Fund Employees'State Insurance Income-tax Sales Tax Services Tax Customs Duty Excise Duty ValueAdded Tax Cess and other material statutory dues in arrears as at March 31 2020 for aperiod of more than six months from the date they became payable.

(c) Details of dues of Customs Duty which has not been deposited as on March 31 2020on account of disputes are given below:

Name of Statute Nature of Dues Amount (Rs) Period to which the amount relate Forum where the dispute is pending
The Customs Act1962 Custom Duty 1836639 2009-10 The Customs Excise and Service Tax Appellate Tribunal
The Central Sales Tax Act 1956. Central Sales Tax 593168 2015-16 Appellate Deputy Commissioner Secunderabad.

viii.DUES TO FINANCIAL INSTITUTION/BANKS/GOVT./ DEBENTUREHOLDERS:

The Company has not defaulted in repayment of loans or borrowings to the financialinstitution banks government or has not issued any debentures.

ix. APPLICATION OF MONEY RAISED FROM INITIAL PUBLIC OFFER & TERM LOAN:

The Company has not raised any money by way of initial public offer or further publicoffer (including debt instruments) & term loans during the year. Accordinglyparagraph 3(ix) of the order is not applicable to the company.

x. FRAUD:

To the best of our knowledge and according to the information and explanations given tous no fraud by the Company or on the Company by its officers or employees has beennoticed or reported during the year.

xi. MANAGERIAL REMUNERATION:

The Managerial Remuneration has not been paid or provided and accordingly the requisiteapprovals mandated by the Provisions of Section 197 read with Schedule V of the CompaniesAct are not required.

xii. NIDHI COMPANY:

As the Company is not a Nidhi Company and hence reporting under paragraph 3(xii) of theOrder is not applicable.

xiii.RELATED PARTIES:

According to the information & explanations given to us & based on ourexamination of the records of the Company transactions with related parties are incompliance with the provisions of Section 177 & Section 188 of the Act whereapplicable & the details of the transactions are disclosed in the Financial Statementsas required by the applicable accounting standards.

xiv. PREFERENTIAL ALLOTMENT OR PRIVATE PLACEMENT OF SHARES/ CONVERTIBLE DEBENTURES :

The Company has not made any preferential allotment or private placement of shares orfully or partly paid convertible debentures during the year.

xv. COMPLIANCE OF SECTION 192 WITH REGARD TO NON-CASH TRANSACTIONS WITH DIRECTORS &CONNECTED PERSONS :

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

xvi.REGISTRATION U/S 45-IA OF THE RBI ACT1934:

The Company is not required to be registered u/s 45-IA of the Reserve Bank of IndiaAct 1934.

For Aditya Falor & Associates
Chartered Accountants
Firm Registration No. 127273W
Aditya G. Falor
Place : Nanded Proprietor
Date : July 3 2020 Membership No.122487
UDIN: 20122487AAAACG3329

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