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SRM Energy Ltd.

BSE: 523222 Sector: Infrastructure
NSE: N.A. ISIN Code: INE173J01018
BSE 00:00 | 08 Feb 5.70 -0.30
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NSE 05:30 | 01 Jan SRM Energy Ltd
OPEN 6.15
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VOLUME 366
52-Week high 9.13
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OPEN 6.15
CLOSE 6.00
VOLUME 366
52-Week high 9.13
52-Week low 5.18
P/E
Mkt Cap.(Rs cr) 5
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

SRM Energy Ltd. (SRMENERGYLTD) - Auditors Report

Company auditors report

To The Members of

SRM Energy Limited

Report on the Audit of the Standalone Ind AS Financial Statements

Opinion

We have audited the accompanying standalone Ind AS Financial Statementsof SRM Energy Limited (“the Company”) which comprise the Balance Sheet as atMarch 31 2022 the statement of Profit and Loss (including other Comprehensive Income)the Cash Flow Statement and the Statement of Changes in Equity for the year then endedand notes to the Financial Statement including a summary of the significant accountingpolicies and other explanatory information.

In our opinion and to the best of our information and according to theexplanations given to us the aforesaid s tandalone Financial Statements give theinformation required by the Act in the manner so required and give a true and fair view inconformity with the accounting principles generally accepted in India of state of affairsof the Company as at March 2022 and loss Changes in equity and its cash flows for theyear ended on that date.

Basis for Opinion

We conducted our audit in accordance with the standards on Auditingspecified under section 143 (10) of the Companies Act 2013. Our responsibilities underthose Standards are further described in the auditor's responsibilities for the auditof the 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 opinion.

Material Uncertainty Related to Going Concern

Attention of the matters is invited to note no.28 of the notes toaccounts regarding the Financial Statements of the Company having been prepared on a GoingConcern basis the Company's net worth has been significantly reduced and it has beenincurring cash losses and the promoters/ directors/ Subsidiary Company have infused fundsby way of unsecured loan and are committed to provide necessary funding to meet theliabilities and future running expenses of the Company. Further pursuant to approvalobtained from s hareholders to sale/transfer assign deliver or otherwise dispose off theLand for the Power plant admeasuring 215.14 acres currently in the name of its WhollyOwned Subsidiary the Subsidiary Company has sold its land admeasuring 159.44 acres forRs. 403.51 Lacs till the end of current Financial Year and the sale proceeds as receivedis being used to partially settle the pending loan. The Subsidiary Company incurred a lossof Rs. 15.60 Lacs during the current Financial Year on sale of land. Till now approx. 26%of the lands are unsold. In view of aforesaid the accounts have been prepared under goingconcern basis.

Our opinion is not modified in respect to this matter.

Key Audit Matters

Key audit matters are those matters that in our professional judgmentwere of most significance in our audit of the standalone Ind AS Financial Statements ofthe current period. These matters were addressed in the context of our audit of thestandalone Ind AS Financial Statements as a whole and in forming our opinion thereon andwe do not provide a separate opinion on these matters. For each matter below ourdescription of how our audit addressed the matter is provided in that context.

We have determined the matters described below to be the key auditmatters to be communicated in our report. We have fulfilled the responsibilities describedin the Auditor's responsibilities for the audit of the standalone Ind AS FinancialStatements section of our report including in relation to these matters. Accordingly ouraudit included the performance of procedures designed to respond to our assessment of therisks of material misstatement of the standalone Ind AS Financial Statements. The resultsof our audit procedures including the procedures performed to address the matters belowprovide the basis for our audit opinion on the accompanying standalone Ind AS FinancialStatements.

Key audit matters How our audit addressed the key audit matter
Accuracy and completeness of disclosure of related party transactions and compliance with the provisions of the Companies Act 2013 and SEBI (Listing Obligations and Disclosure Requirements) Regulations 2015 as amended (‘SEBI (LODR) 2015') ( as described in note 23 of the standalone Ind AS Financial Statements)
We identified the accuracy and completeness of disclosure of related party transactions as set out in respective notes to the standalone Ind AS Financial Statements as a key audit matter due to: Our procedures in relation to the disclosure of related party transactions included:
The significance of transactions with related parties during the year ended March 31 2022. Obtaining an understanding of the Company's policies and procedures in respect of the capturing of related party transactions and how management ensures all transactions and balances with related parties have been disclosed in the standalone Ind AS Financial Statements.
Related party transactions are subject to the compliance requirements under the Companies Act 2013 and SEBI (LODR) 2015. Obtaining an understanding of the Company's policies and procedures in respect of evaluating approval process by the Board of Directors.
Agreeing the amounts disclosed to underlying documentation and reading relevant agreements on a sample basis as part of our evaluation of the disclosure.
Assessing management evaluation of compliance with the provisions of Section 177 and Section 188 of the Companies Act 2013 and SEBI (LODR) 2015.
Evaluating the disclosures through reading of statutory information books and records and other documents obtained during the course of our audit.

Information Other than the Financial Statements and auditors'report thereon The Company's Board of Directors is responsible for the preparation ofthe other information. The other information comprises the information included in theBoard's Report including Annexures to Board's Report Business ResponsibilityReport but does not include the Financial Statements and our auditor's reportthereon.

Our opinion on the Financial Statements does not cover the otherinformation and we do not express any form of assurance conclusion thereon. In connectionwith our audit of the Financial Statements our responsibility is to read the otherinformation and in doing so consider whether the other information is materiallyinconsistent with the standalone Financial Statements or our knowledge obtained during thecourse of our audit or otherwise appears to be materially misstated.

If based on the work we have performed we conclude that there is amaterial misstatement of this other information we are required to report that fact. Wehave nothing to report in this regard.

Management's responsibility for the Financial Statements

The Company's Board of Directors are responsible for the mattersstated in section 134 (5) of the Act with respect to the preparation of these FinancialStatements that give a true and fair view of the financial position financial performanceand cash flows of the Company in accordance with the accounting principles generallyaccepted in India including the accounting standards specified under section 133 of theAct. This responsibility also includes maintenance of adequate accounting records inaccordance with the provisions of the Act for safeguarding of the assets of the Companyand for preventing and detecting frauds and other irregularities; selection andapplication of appropriate accounting policies; making judgments and estimates that arereasonable and prudent; and design implementation and maintenance of adequate internalfinancial controls that were operating effectively for ensuring the accuracy andcompleteness of the accounting records relevant to the preparation and presentation ofthe Financial Statement that give a true and fair view and are free from materialmisstatement whether due to fraud or error.

In preparing the Financial Statements management is responsible forassessing the Company's ability to continue as a going concern disclosing asapplicable matters related to going concern and using the going concern basis ofaccounting unless management either intends to liquidate the Company or to ceaseoperations or has no realistic alternative but to do so.

The Board of Directors is also responsible for overseeing theCompany's financial reporting process.

Auditor's responsibilities for the audit of the FinancialStatements

Our objectives are to obtain reasonable assurance about whether theFinancial 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. Reasonableassurance is a high level of assurance but is not a guarantee that an audit conducted inaccordance with SAs will always detect a material misstatement when it exists.Misstatements can arise from fraud or error and are considered material if individuallyor in the aggregate they could reasonably be expected to influence the economic decisionsof users taken on the basis of these Financial Statements.

As part of an audit in accordance with SAs we exercise professionaljudgment and maintain professional skepticism throughout the audit. We also: Identify andassess the risks of material misstatement of the Financial Statements whether due tofraud or error design and perform audit procedures responsive to those risks and obtainaudit evidence that is sufficient and appropriate to provide a basis for our opinion. Therisk of not detecting a material misstatement resulting from fraud is higher than for oneresulting from error as fraud may involve collusion forgery intentional omissionsmisrepresentations or the override of internal control. Obtain an understanding ofinternal control relevant to the audit in order to design audit procedures that areappropriate in the circumstances.

Under section 143(3)(i) of the Companies Act 2013 we are alsoresponsible for expressing our opinion on whether the Company has adequate internalfinancial controls system in place and the operating effectiveness of such controlsEvaluate the appropriateness of accounting policies used and the reasonableness ofaccounting estimates and related disclosures made by management.

Conclude on the appropriateness of management's use of the goingconcern basis of accounting and based on the audit evidence obtained whether a materialuncertainty exists related to events or conditions that may cast significant doubt on theCompany's ability to continue as a going concern. If we conclude that a materialuncertainty exists we are required to draw attention in our auditor's report to therelated disclosures in the Financial Statements or if such disclosures are inadequate tomodify our opinion. Our conclusions are based on the audit evidence obtained up to thedate of our auditor's report. However future events or conditions may cause theCompany to cease to continue as a going concern.

Evaluate the overall presentation structure and content of theFinancial Statements including the disclosures and whether the Financial Statementsrepresent the underlying transactions and events in a manner that achieves fairpresentation.

Materiality is the magnitude of misstatements in the StandaloneFinancial Statements that individually or in aggregate makes it probable that theeconomic decisions of a reasonably knowledgeable user of the Standalone FinancialStatements may be influenced. We consider quantitative materiality and qualitative factorsin (i) planning the scope of our audit work and in evaluating the results of our work; and(ii) to evaluate the effect of any identified misstatements in the Standalone FinancialStatements.

We communicate with those charged with governance regarding amongother matters 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 wehave c omplied with relevant ethical requirements regarding independence and tocommunicate with them all relationships and other matters that may reasonably be thoughtto bear on our independence and where applicable related safeguards.

From the matters communicated with those charged with governance wedetermine those matters that were of most significance in the audit of the 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 publicdisclosure about the matter or when in extremely rare circumstances we determine that amatter should not be communicated in our report because the adverse consequences of doingso would reasonably be expected to outweigh the public interest benefits of suchcommunication.

Report on Other Legal and Regulatory Requirements

1. With respect to the matter to be included in theAuditors' Report under Section 197(16):

In our opinion and according to the information and explanations givento us the Company has not paid managerial remuneration to its directors during thecurrent year.

2. As required by Section 143(3) of the Act based on our auditwe report that:

a) We have sought and obtained all the information and explanationswhich to the best of our knowledge and belief were necessary for the purposes of ouraudit.

b) In our opinion proper books of account as required by law have beenkept by the Company so far as it appears from our examination of those books.

c) The Balance Sheet the Statement of Profit and Loss including OtherComprehensive Income the Cash Flow Statement and Statement of Changes in Equity dealtwith by this Report are in agreement with the books of account.

d) In our opinion the aforesaid standalone Ind AS Financial Statementscomply with the Indian Accounting Standards prescribed under section 133 of the Act readwith rule 7 of the Companies (Accounts) Rule 2014.

e) On the basis of the written representations received from thedirectors as on March 31 2022 taken on record by the Board of Directors none of thedirectors are disqualified as on March 31 2022 from being appointed as a director interms of Section 164(2) of the Act.

f) With respect to the adequacy of the internal financial controls overfinancial reporting of the Company and the operating effectiveness of such controls referto our separate report in “Annexure A”. Our report expresses an unmodifiedopinion on the adequacy and operating effectiveness of the Company's internalfinancial controls over financial reporting.

g) In our opinion and to the best of our information and according tothe explanations given to us we report as under with respect to other matters to beincluded in the Auditor's Report in accordance with Rule 11 of the Companies (Auditand Auditors) Rules 2014:-

(i) The Company has disclosed the impact of pending litigations on itsfinancial position in its Financial Statements-Refer Note 18 on Contingent Liabilities;

(ii) The Company did not have any long-term contracts includingderivative c ontracts; as such the question of commenting on any material foreseeablelosses thereon does not arise; and

(iii) There has not been an occasion in case of the Company during theyear under report to transfer any sums to the Investor Education and Protection Fund. Thequestion of delay in transferring such sums does not arise.

h) (a) The management has represented that to the best of itsknowledge and belief no funds have been advanced or loaned or invested (either fromborrowed funds or securities premium or any other sources or kind of funds) by the Companyto or in any person(s) or entity(ies) including foreign entities (‘theintermediaries') with the understanding whether recorded in writing or otherwisethat the intermediary shall whether directly or indirectly lend or invest in otherpersons or entities identified in any manner whatsoever by or on behalf of the Company(‘the Ultimate Beneficiaries') or provide any guarantee s ecurity or the likeon behalf the Ultimate Beneficiaries;

(b) The management has represented that to the best of its knowledgeand belief no funds have been received by the Company from any person(s) or entity(ies)including foreign entities (‘the Funding Parties') with the understandingwhether recorded in writing or otherwise that the Company shall whether directly orindirectly lend or invest in other persons or entities identified in any mannerwhatsoever by or on behalf of the Funding Party (‘Ultimate Beneficiaries') orprovide any guarantee security or the like on behalf of the Ultimate Beneficiaries; and

(c) Based on such audit procedures performed as considered reasonableand appropriate in the circumstances nothing has come to our notice that has caused us tobelieve that the management representations under sub-clauses (a) and (b) above containany material misstatement.

i) The Company has not declared or paid any dividend during the yearended 31 March 2022.

3. As required by the Companies (Auditor's Report) Order2016 (“the Order”) issued by the Central Government in terms of Section 143(11)of the Act we give in the “Annexure B” a statement on the matters specified inparagraphs 3 and 4 of the Order to the extent applicable.

ANNEXURE “A”

TO THE INDEPENDENT AUDITORS' REPORT

(Referred to in paragraph 1 (f) under ‘Report on Other Legal andRegulatory Requirements' of our Report of even date)

Report on the Internal Financial Controls under Clause (i) ofSubsection 3 of Section 143 of the Companies Act 2013 (“the Act”)

We have audited the internal financial controls over financialreporting of SRM ENERGY LIMITED (“the Company”) as of March 31 2022 inconjunction with our audit of the Financial Statements of the Company for the year endedon that date.

Management's Responsibility for Internal Financial Controls

The Company's management is responsible for establishing andmaintaining internal financial controls based on the internal control over financialreporting criteria established by the Company considering the essential components ofinternal control stated in the Guidance Note on Audit of Internal Financial Controls overFinancial reporting issued by the Institute of Chartered Accountants of India. Theseresponsibilities include the design implementation and maintenance or adequate internalfinancial controls that were operating effectively for ensuring the orderly and efficientconduct of its business including adherence to Company's policies the safeguarding ofits assets the prevention and detection of frauds and errors the accuracy andcompleteness of the accounting records and the timely preparation or reliable financialinformation as required under the Companies Act 2013.

Auditors' Responsibility

Our responsibility is to express an opinion on the Company's internalfinancial controls over financial reporting based on our audit. We conducted our audit inaccordance with the Guidance Note on Audit of Internal Financial Controls Over FinancialReporting (the “Guidance Note") issued by the Institute of Chartered Accountantsof India and the Standards on Auditing prescribed under s ection 143(10) of the CompaniesAct 2013 to the extent applicable to an audit of internal financial controls. ThoseStandards and the Guidance Note require that we comply with ethical requirements and planand perform the audit to obtain reasonable assurance about whether adequate internalfinancial controls over financial reporting were established and maintained and if suchcontrols operated effectively in all material respects.

Our audit involves performing procedures to obtain audit evidence aboutthe adequacy of the internal financial controls system over financial reporting and theiroperating effectiveness. Our audit of internal financial controls over financial reportingincluded obtaining an understanding of internal financial controls over financialreporting assessing the risk that a material weakness exists and testing and evaluatingthe design and operating effectiveness of internal control based on the assessed risk. Theprocedures selected depend on the auditor's judgment including the assessment or therisks of material misstatement of the Financial Statements whether due to fraud or error.

We believe that the audit evidence we have obtained is sufficient andappropriate to provide a basis for our audit opinion on the Company's internal financialcontrols system over financial reporting.

Meaning of Internal Financial Controls over Financial Reporting

A Company's internal financial control over financial reporting is aprocess designed to provide reasonable assurance regarding the reliability of financialreporting and the preparation of Financial Statements for external purposes in accordancewith generally accepted accounting principles. A Company's internal financial control overfinancial reporting includes those policies and procedures that (1) pertain to themaintenance of records that in reasonable detail accurately and fairly reflect thetransactions and dispositions of the assets of the Company; (2) provide reasonableassurance that transactions are recorded as necessary to permit preparation of FinancialStatements in accordance with generally accepted accounting principles and that receiptsand expenditures 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 FinancialReporting

Because of the inherent limitations of internal financial controls overfinancial reporting including the possibility of collusion or improper managementoverride of controls material misstatements due to error or fraud may occur and not bedetected. Also projections of any evaluation of the internal financial controls overfinancial reporting to future periods are subject to the risk that the internal financialcontrol over financial reporting may become inadequate because of changes in conditionsor that the degree of compliance with the policies or procedures may deteriorate.

Opinion

In our opinion to the best our information and according to theexplanation given to us the Company has in all material respects an adequate internalfinancial controls system over financial reporting and such internal financial controlsover financial reporting were operating effectively as at March 31 2022 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.

ANNEXURE “B”

Annexure to the Independent Auditors' Report

The Annexure referred to in our Independent Auditors' Report ofeven date to the members of SRM ENERGY LIMITED on the accounts of the Company for the yearended 31st March 2022

i. The Company does not have fixed assets. Hence clause 3(i)(a) to3(i)(c) of the order are not applicable to the Company;

ii. The nature of business of the Company does not require it to haveany inventory. Hence the requirement of clause (ii) of paragraph 3 of the said Order isnot applicable to the Company;

iii. In our opinion and according to the information and explanationsgiven to us the Company has not made investments in or provided any guarantee orsecurity or granted any loans or advances in the nature of loans secured or unsecured tocompanies firms limited liability partnerships or any other parties during the year.Accordingly reporting under clause 3(iii)(a) to clause 3(iii)(f) of the Order is notapplicable to the Company.

iv. In our opinion and according to the information and explanationsgiven to us the Company has not granted any loans or provided any guarantees or securityto the parties covered under sections 185 of the Act. According to the information andexplanations given to us the provisions of Section 186 of the Act in respect of the loansgiven guarantees given s ecurities provided or investments made not applicable to theCompany. Accordingly reporting under clause 3(iv) of the Order is not applicable to theCompany.

v. In our opinion and according to the information and explanationsgiven to us the Company has not accepted any deposits or there is no amount which hasbeen considered as deemed deposit within the meaning of sections 73 to 76 of the Act andthe Companies (Acceptance of Deposits) Rules 2014 (as amended). Accordingly reportingunder clause 3(v) of the Order is not applicable to the Company.

vi. The Central Government has not specified the maintenance of costrecords under sub-section (1) of section 148 of the Act in respect of Company'sproducts/business activity. Accordingly reporting under clause 3(vi) of the Order is notapplicable to the Company.

vii. (a) According to the information and explanations given to us andbased on the records of the Company examined by us the Company is regular in depositingthe undisputed statutory dues including Goods and Service Tax Income-tax and any otherstatutory dues applicable to it though there has been a slight delay in few cases.Provident Fund Employees State Insurance Sales Tax Wealth tax Customs duty ValueAdded tax are not applicable on the Company. According to the information and explanationsgiven to us no undisputed amounts payable in respect of the above were in arrears as atMarch 31 2022 for a period of more than six months from the date on when they becomepayable;

(b) According to the information and explanations given to us and basedon the records of the Company examined by us no dues has been outstanding with respectto Income Tax Wealth Tax Good and Service Tax Sales Tax Customs Duty and Excise Dutyor cess as applicable to it on account of any dispute.

viii. According to the information and explanations given to us notransactions were surrendered or disclosed as income during the year in the taxassessments under the Income Tax Act 1961 (43 of 1961) which have not been recorded inthe books of accounts.

ix. (a) According to the records of the Company examined by us and theinformation and explanations given to us the Company has not defaulted in repayment ofloans or other borrowings or in the payment of interest to any lender during the year.

(b) According to the information and explanations given to us includingconfirmations received from banks and representation received from the management of theCompany and on the basis of our audit procedures we report that the Company has not beendeclared a willful defaulter by any bank.

(c) In our opinion and according to the information and explanationsgiven to us the Company has not raised any money by way of term loans during the year andthere has been no utilization during the current year of the term loans obtained by theCompany during any previous years. Accordingly reporting under clause 3(ix)(c) of theOrder is not applicable to the Company.

(d) In our opinion and according to the information and explanationsgiven to us the Company has not used funds raised on short term basis for long termpurpose during the year.

(e) According to the information and explanations given to us and on anoverall examination of the standalone Financial Statements of the Company we report thatthe Company has not taken any funds from any entity or person on account of or to meet theobligations of its subsidiaries associates or joint ventures.

(f) According to the information and explanations given to us and on anoverall examination of the standalone Financial Statements of the Company we report thatthe Company has not raised loans during the year on the pledge of Securities held in itsSubsidiary Joint Venture or Associate Company.

x. (a) The Company has not raised any moneys by way of initial publicoffer or further public offer (including debt instruments) Accordingly clause 3(x)(a) ofthe Order is not applicable.

(b) According to the information and explanations given to us and onthe basis of 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. Accordingly clause 3(x)(b) of the Order is not applicable.

xi. (a) Based on examination of the books and records of the Companyand according to the information and explanations given to us no material fraud by theCompany or on the Company has been noticed or reported during the course of the audit.

(b) According to the information and explanations given to us noreport under sub-section (12) of Section 143 of the Act has been filed by the auditors inForm ADT-4 as prescribed under Rule 13 of the Companies (Audit and Auditors) Rules 2014with the Central Government.

(c) We have taken into consideration the whistle blower complaintsreceived by the Company during the year while determining the nature timing and extent ofour audit procedures.

xii. According to the information and explanations given to us theCompany is not a Nidhi Company. Accordingly clause 3(xii) of the Order is not applicable.

xiii. In our opinion and according to the information and explanationsgiven to us and on the basis of examination of the records of the Company thetransactions with related parties are in compliance with Section 177 and 188 of theCompanies Act 2013 where applicable and the details of the related party transactionshave been disclosed in the s tandalone Financial Statements as required by the applicableaccounting standards.

xiv. (a) Based on information and explanations provided to us and ouraudit procedures in our opinion the Company has an internal audit system commensuratewith the size and nature of its business.

xv. (b) We have considered the internal audit reports of the Companyissued till date for the period under audit.

xvi. In our opinion and according to the information and explanationsgiven to us the Company has not entered into any non-cash transactions with its directorsor persons connected to its directors and hence provisions of Section 192 of the Act arenot applicable to the Company.

xvii. The Company is not required to be registered under section 45-IAof the Reserve Bank of India Act 1934. Accordingly reporting under clause 3(xvi) of theOrder is not applicable to the Company

xviii. The Company not incurred cash loss of Rs. 4.90 Millions in thecurrent as well as Rs. 4.29 Millions the immediately preceding Financial Year.

xix. There has been no resignation of the statutory auditors during theyear. Accordingly reporting under clause 3(xviii) of the Order is not applicable to theCompany.

xx. According to the information and explanations given to us and onthe basis of the financial ratios ageing and expected dates of realisation of financialassets and payment of financial liabilities other information accompanying the FinancialStatements our knowledge of the plans of the Board of Directors and management and basedon our examination of the evidence supporting the assumptions nothing has come to ourattention which causes us to believe that any material uncertainty exists as on the dateof the audit report that Company is not capable of meeting its liabilities existing at thedate of balance sheet as and when they fall due within a period of one year from thebalance sheet date. We however state that this is not an assurance as to the futureviability of the Company.

We further state that our reporting is based on the facts up to thedate of the audit report and we neither give any guarantee nor any assurance that allliabilities falling due within a period of one year from the balance sheet date will getdischarged by the Company as and when they fall due.

xxi. According to the information and explanations given to us theCompany does not fulfill the criteria as specified under section 135(1) of the Act readwith the Companies (Corporate Social Responsibility Policy) Rules 2014 and accordingreporting under clause 3(xx) of the Order is not applicable to the Company.

xxii. The reporting under clause 3(xxi) is not applicable in respect ofaudit of Financial Statements of the Company. Accordingly no comment has been included inrespect of said clause under this report.

For Saini Pati Shah & Co LLP
Chartered Accountants
FRN - 137904W/W100622
(Pawan Kumar Jain)
Partner
(M/N: 418772)
UDIN: 22418772AMGSML4002
Place: New Delhi
Dated: 18/05/2022

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