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Star Paper Mills Ltd.

BSE: 516022 Sector: Industrials
NSE: STARPAPER ISIN Code: INE733A01018
BSE 00:00 | 08 Dec 194.25 0.70
(0.36%)
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193.60

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195.50

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193.00

NSE 00:00 | 08 Dec 194.05 0.85
(0.44%)
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193.85

HIGH

195.70

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OPEN 193.60
PREVIOUS CLOSE 193.55
VOLUME 3931
52-Week high 220.75
52-Week low 110.45
P/E 4.93
Mkt Cap.(Rs cr) 303
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00
OPEN 193.60
CLOSE 193.55
VOLUME 3931
52-Week high 220.75
52-Week low 110.45
P/E 4.93
Mkt Cap.(Rs cr) 303
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

Star Paper Mills Ltd. (STARPAPER) - Auditors Report

Company auditors report

To the Members of STAR PAPER MILLS LIMITED

Report on the Audit of the Standalone Ind AS Financial Statements

Opinion

We have audited the accompanying Standalone Ind AS financial statements of STAR PAPERMILLS LIMITED ("the Company") which comprise the Balance sheet as at March 312022 the Statement of Profit and Loss including the statement of Other ComprehensiveIncome the Cash Flow Statement and the statement of Changes in Equity for the year thenended and notes to the financial statements including a summary of significantaccounting policies and other explanatory information.

In our opinion and to the best of our information and according to the explanationsgiven to us the aforesaid Standalone Ind AS financial statements give the informationrequired by the Companies Act 2013 as amended ("the Act") in the manner sorequired and give a true and fair view in conformity with the accounting principlesgenerally accepted in India of the state of affairs of the Company as at March 31 2022its profit including other comprehensive income its cash flows and the changes in equityfor the year ended on that date.

Basis for Opinion

We conducted our audit of the Standalone Ind AS financial statements in accordance withthe Standards on Auditing (SAs) as specified under section 143(10) of the Act. Ourresponsibilities under those Standards are further described in the ‘Auditor'sResponsibilities for the Audit of the Standalone Ind

AS Financial Statements' section of our report. We are independent of the Company inaccordance with the ‘Code of Ethics' issued by the Institute of Chartered Accountantsof India together with the ethical requirements that are relevant to our audit of thefinancial statements under the provisions of the Act and the Rules there under and wehave fulfilled our other ethical responsibilities in accordance with these requirementsand the Code of Ethics. We believe that the audit evidence we have obtained is sufficientand appropriate to provide a basis for our audit opinion on the Standalone Ind ASfinancial statements.

Emphasis of Matters

(a) Remuneration aggregating to Rs. 724.13 Lacs paid/provided to one erstwhile directoris recoverable depending upon the outcome of decision of the competent authority (Note No.30.5) (b) Fair value of investment in ISG Traders Limited has not been evaluated after31.12.2019 (Note No. 30.4). Our opinion is not modified in respect of this matter.

Key Audit Matters

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

S.no Key Audit Matter Auditor's Response
1 Valuation of Trade Receivable Our audit procedure included among others:
Trade receivables is a significant item in the Company's financial statements as at March 31 2022 and assumptions used for estimating the credit loss on certain receivables is an area which is determined by management's judgment. • Evaluated the accounting policy of the company.
• Inquired with senior management regarding status of collectability of the receivable.
• Amount recovered subsequent to the Balance Sheet date.
The Company makes an assessment of the estimated credit losses on certain trade receivables based on credit risk project status past history latest discussion/ correspondence with the customer. • Discussion of material outstanding balances with the audit committee.
Given the significance of these receivables in the financial statements as at 31st March 2022 we determined this to be a key audit matter. • Assessed the information/assumptions used by the Management to determine the expected credit losses by considering credit risk of the customer cash collection and the level of credit loss over time;
Based on our work as stated above no significant deviations were observed in respect of management's assessment of valuation of trade receivables

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 Standalone

Report 2021-22. Our opinion on the standalone Ind AS financial statements does notcover the other information and we do not express any form of assurance conclusionthereon.

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

Responsibilities of Management for the Standalone Ind AS Financial Statements

The Company's Board of Directors is responsible for the matters stated in section134(5) of the Act with respect to the preparation of these Standalone Ind AS financialstatements that give a true and fair view of the financial position financial performanceincluding other comprehensive income cash flows and changes in equity of the Company inaccordance with the accounting principles generally accepted in Standards (Ind AS)specified under section 133 of the Act read with [the Companies (Indian AccountingStandards) Rules 2015 as amended. This responsibility also includes maintenance ofadequate accounting records in accordance with the provisions of the Act for safeguardingof the assets of the Company and for preventing and detecting frauds and otherirregularities; selection and application of appropriate accounting policies; makingjudgments and estimates that are reasonable and prudent; and the design implementationand maintenance of adequate internal financial controls that were operating effectivelyfor ensuring the accuracy and completeness of the accounting records relevant to thepreparation and presentation of the standalone Ind AS financial statements that give atrue and fair view and are free from material misstatement whether due to fraud or error.

In preparing the standalone Ind AS financial statements management is responsible forassessing the Company's ability to continue as a going concern disclosing as applicablematters related to going concern and using the going concern basis of accounting unlessmanagement either intends to liquidate the Company or to cease operations or has norealistic alternative but to do so.

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

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

Our objectives are to obtain reasonable assurance about whether the Standalone Ind ASfinancial statements as a whole are free from material misstatement whether due to fraudor error and to issue an auditor's report that includes our opinion. Reasonable assuranceis a high level of assurance but is not a guarantee that an audit conducted in accordancewith 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 standalone Ind AS financial statements.

As part of an audit in accordance with SAs we exercise professional judgment andmaintain professional skepticism throughout the audit. We also:

• Identify and assess the risks of material misstatement of the Standalone Ind ASfinancial statements whether due to fraud or error design and perform auditprocedures responsive to those risks and obtain audit evidence that is sufficientandappropriate to provide a basis for our opinion. The risk of not detecting amaterial misstatement resulting from fraud is higher than for one resulting from error asfraud may involve collusion forgery intentional omissions misrepresentations orthe 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 ouropinion on whether the Company has adequate internal financial controls system in placeand the 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 materialuncertainty exists related to eventsorconditionsthatmaycastsignificantdoubt 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 areinadequate to modify our opinion. Our conclusions are based on the audit evidenceobtained up to the date of our auditor's report. However future events or conditions maycause the Company to cease to continue as a going concern.

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

We communicate with those charged with governance regarding among other matters theplanned scope and timing of the audit and significant audit findings including anysignificant deficiencies in internal control . thatwe identifyduringouraudit We alsoprovide those charged with governance with a statement that we have complied with relevantethical requirements regarding independence and to communicate with them allrelationships and other matters that may reasonably be thought to bear on ourindependence and where applicable related safeguards.

From the matters communicated with those charged with governance we determine thosematters that were of most significance in the audit of the standalone Ind AS financialstatements for the financialyear ended March 31 2022 and are therefore the key auditmatters. We describe these matters in our auditor's report unless law or regulationprecludes public disclosure about the matter or when in extremely rare circumstances wedetermine that a matter should not be communicated in our report because the adverseconsequences of doing so would reasonably be expected to outweigh the public interestbenefits of such communication.

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 in terms of Section 143(11) of the Act we give in"Annexure A"

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 the Cash Flow Statement andStatement of Changes in Equity dealt with by this Report are in agreement with the booksof account

d) In our opinion the aforesaid Ind AS financial statements comply with the IndianAccounting Standards prescribed under section 133 of the Act.

e) On the basis of the written representations received from the directors as on 31stMarch 2022 taken on record by the Board of Directors none of the directors isdisqualified as on 31st March 2022 from being appointed as a director in terms of Section164(2) of theAct.

f) With respect to the adequacy of the internal financial controls over financialreporting of the Company and the operating effectiveness of such controls refer to ourseparate Report in "Annexure B".

g) In our opinion Managerial remuneration for the year ended 31.03.2022 has been paid/provided by the company to its director in accordance with the provisions of section 197read 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 in our opinionand to the best of our information and according to the explanations given to us: i. TheCompany has disclosed the impact of pending litigations on its financial position in itsInd AS financial statements; ii. The Company did not have any long-term contractsincluding derivative contracts for which there were any material foreseeable losses. iii.There were no amounts which were required to be transferred to the Investor Education andProtection Fund by the Company.

iv. The Management has represented that to the best of its knowledge and belief nofunds (which are material either individually or in the aggregate) have been advanced orloaned or invested (either from borrowed funds or share premium or any other sources orkind of funds) by the Company to or in any other person or entity including foreignentity ("Intermediaries") with the understanding whether recorded in writingor otherwise that the Intermediary shall whether directly or indirectly lend or investin other persons or entities identified in any manner whatsoever by or on behalf of theCompany ("Ultimate Beneficiaries") or provide any guarantee security or thelike on behalf of the Ultimate Beneficiaries;

v. The Management has represented that to the best of its knowledge and belief nofunds (which are material either individually or in the aggregate) have been received bythe Company from any person or entity including foreign entity ("FundingParties") with the understanding whether recorded in writing or otherwise that theCompany shall whether directly or indirectly lend or invest in other persons orentities identified in any manner whatsoever by or on behalf of the Funding Party("Ultimate Beneficiaries") or provide any guarantee security or the like onbehalf of the Ultimate Beneficiaries;

vi. Based on the audit procedures that have been considered reasonable andappropriate in the circumstances nothing has come to our notice that has caused us tobelieve that the representations under sub-clause (i) and (ii) of Rule 11(e) as providedunder (a) and (b) above contain any material misstatement.

vii. (a) The final dividend proposed in the previous year declared and paid by theCompany during the year is in accordance with section

123 of the Companies Act 2013 to the extent it applies to payment of dividend.

(b) The Board of Directors of the Company have proposed dividend for the year which issubject to the approval of the members at the ensuing Annual General Meeting. The amountof dividend proposed is in accordance with section 123 of the Act as applicable.

For Jain Pramod Jain & Co.
Chartered Accountants
(Firm Registration No. 016746N)
Place: New Delhi (P.K.Jain)
Date:27.05.2022 Partner
Membership No. 010479
UDIN: 22010479AJTECV6162

Annexure - A to Independent Auditors' Report of STAR PAPER MILLS LIMITED

(Referred to in Paragraph 1 under the heading of "Report on Other Legal andRegulatory Requirements" of our report of even date) i. In respect of the Company'sProperty Plant and Equipment and Intangible Assets: (a) (A) The Company has maintainedproper records showing full particulars including quantitative details and situation ofProperty Plant and Equipment. (B) The Company has maintained proper records showing fullparticulars of intangible assets.

(b) Property Plant and Equipment have been physically verified by the managementaccording to the regular programme of periodical verification which in our opinion isreasonable having regard to the size of the Company and the nature of its Property Plantand Equipment. No material . discrepancieswerenoticedonsuchverification (c) According tothe information and explanations given to us and on the basis of our examination ofrecords of the Company the title deeds of immovable properties (other than propertieswhere the company is the lessee & the lease agreements are duly executed in favour ofthe lessee) disclosed in the financial statement are held in the name of the Company. (d)The Company has not revalued any of its Property Plant and Equipment and intangibleassets during the year.

(e) According to the information and explanation provided to us no proceedings havebeen initiated during the year or are pending against the Company as at March 31 2022 forholding any Benami property under the Benami Transactions (Prohibition) Act 1988 (asamended in 2016) and rules made thereunder. ii. (a) The inventories of the company at allits locations (except stock in transit) have been physically verified by the management atreasonable intervals. In our opinion the procedure and coverage of such physicalverificationby the management is appropriate. Further no material discrepancies werenoticedonsuchphysicalverification . bythe management (b) The Company has not beensanctioned working capital limits in excess of Rs. 5 Crore in aggregate at any points oftime during the year from banks or financial institutions on the basis of security ofcurrent assets and hence reporting under clause 3(ii) (b) of the Order is not applicable.iii. The Company has not made investments in provided any guarantee or security orgranted any loans secured or unsecured to companies firms limited liabilitypartnership or any other parties except unsecured loan to employees as per company'sestablished policy during the year in respect of which: (a) The Company has not providedany loans or advances in the nature of loans or stood guarantee or provided security toany other entity during the year and hence reporting under clause 3(iii) (a) of the Orderis not applicable.

(b) In our opinion the terms and conditions of the grant of loans or advances in thenature of loans during the year are prima facie not prejudicial to the Company'sinterest.

(c) In respect of loans and advances in the nature of loan granted by the Company theschedule of repayment of principal is stipulated and the repayments of principal amountsis regular as per stipulation except in the case of unsecured loan of Rs. 45 Lacs given toEmperor Commercial And Tradco Pvt. Ltd. which is overdue.

(d) In respect of loans or advances in the nature of loans granted by the Companythereis no overdue amount in respect of loans in excess of ninety days except in the case ofunsecured loan of Rs. 45 Lacs given to Emperor Commercial And Tradco Pvt. Ltd. which isoverdue against which reasonable steps have been taken by the company for recovery of theprincipal and interest.

(e) No loan or advances in the nature of loans granted by the Company which has fallendue during the year has been renewed or extended or fresh loans granted to settle theover dues of existing loans given to the same parties.

(f) The Company has not granted any loans or advances in the nature of loans eitherrepayable on demand or without specifying any terms or period of repayment during theyear. Hence reporting under clause 3(iii) (f) is not applicable. iv. In our opinion andaccording to the information and explanation given to us the Company has complied withthe provisions of Sections 185 and 186 of the Companies Act 2013 in respect of loans investments made and guarantees and securities provided as applicable. v. The Company hasnot accepted any deposit or amounts which are deemed to be deposits within section 73 to76 of the act and the companies (Acceptance of deposit) Rules 2014 (as amended). Hencereporting under clause 3(v) of the Order is not applicable. vi. We have broadly reviewedthe books of account maintained by the Company pursuant to the rules made by the CentralGovernment for the maintenance of cost records under Section 148(1) of the Companies Act2013 and are of the opinion that prima-facie prescribed accounts and records have beenmade and maintained. We have however not made a detailed examination of the said recordswith a view to determine whether they are accurate and complete; vii. In respect ofstatutory dues:

(a) In our opinion the Company has generally been regular in depositing undisputedstatutory dues including Goods and Services tax Provident Fund Employees' StateInsurance Income Tax Sales Tax Service Tax duty of Custom duty of Excise Value AddedTax Cess and other material statutory dues applicable to it with the appropriateauthorities.

There were no undisputed amounts payable in respect of Goods and Service tax ProvidentFund Employees' State Insurance Income Tax Sales Tax Service Tax duty of Custom dutyof Excise Value Added Tax Cess and other material statutory dues in arrears as at March31 2022 for a period of more than six months from the date they became payable.

(b) Details of statutory dues referred to in sub-clause (a) above which have not beendeposited as on March 31 2022 on account of disputes are given below:

(Rs. in lakhs)
Name of Statue Nature of Dues Amount involved Period to which it relates Forum where matter is pending
Central Goods and Service Tax Act 2017 Goods and Service Tax 5.98 FY. 2017-18 2019-20 Commissioner Appeal
Central Goods and Service Tax Act 2017 Goods and Service Tax 160.88 FY. 2019-20 2020-21 Joint Commissioner Corporate office Mfr
Income Tax Act 1961 Income Tax 107.40 A.Y. 2014-15 2015- 162017-18 CIT Appeal Faceless
The UP Vat Act 2008 Sales Tax 20.28 FY 2010-2011 2014-15 Tribunal Saharanpur
The UP Vat Act 2008 Sales Tax 24.40 2009-2010 Tribunal Saharanpur
The CST Act 1956 Sales Tax 406.00 1995-1996 Tribunal Saharanpur
The CST Act 1956 Sales Tax 118.29 2010-2011 2011-2012 2015-2016 Addl. Commissioner (A) Trade Tax CESTAT Allahabad
The Entry Tax Act 2007 Sales Tax 49.00 Fuel (2008-09 to 2011-12) High court Allahabad
The Entry Tax Act 2007 Sales Tax 75.37 Petcoke (2015-16 to 2017-18) Add Commissioner appeals
The Central Excise Act 1944 Excise duty 4.84 2009-2010 to 2011-12 CESTAT Allahabad
The ESIC Act 1948 ESIC 5.00 1998 High Court Allahabad
The ESIC Act 1948 ESIC 5.00 1998 High Court Allahabad
The ESIC Act 1948 ESIC 1.40 F.Y. 1993-94 & 1994-95 High Court Allahabad
The ESIC Act 1948 ESIC 0.17 1998 High Court Allahabad
The Municipal Corporation Taxes -Nagar Nigam Act 1959 Property Taxes 146.00 2015-16 & 2016-17 JSCC Judge Saharanpur
The Municipal Corporation Taxes -Nagar Nigam Act 1959 Property Taxes 73.00 2019-20 JSCC Judge Saharanpur
The Krishi utpadan Mandi adhiniyam -1964 Mandi Samiti 272.00 2004-09 High Court Allahabad
The Krishi utpadan Mandi adhiniyam -1964 Mandi Samiti 288.00 2009-16 High Court Allahabad

viii. There were no transactions relating to previously unrecorded income that havebeen surrendered or disclosed as income during the year in the tax assessments under theIncome Tax Act 1961 (43 of 1961).

ix. a) The Company has not raised any loan /borrowings from banks financialinstitution or Government therefore reporting under clause 3(ix) (a) of the Order is notapplicable.

b) Company has not been declared wilful defaulter by any bank or financial institutionor government or any government authority or by other lender.

c) The Company has not taken any term loan during the year and there are no outstandingterm loans at the beginning of the year and hence reporting under clause 3(ix)(c) of theOrder is not applicable.

d) The Company has not raised any loan /borrowings from banks financialinstitution orGovernment therefore reporting under clause 3(ix) (d) of the Order is not applicable.

e) On an overall examination of the financial statements of the Company the Companyhas not taken any funds from any entity or person on account of or to meet the obligationsof its subsidiary.

f) The Company has not raised any loans during the year on the pledge of securitiesheld in its subsidiary and hence reporting on clause 3(ix) (f) of the  Order is notapplicable.

x. a) The Company has not raised moneys by way of initial public offer or furtherpublic offer (including debt instruments) during the year and hence reporting under clause3(x)(a) of the Order is not applicable.

b) During the year the Company has not made any preferential allotment or privateplacement of shares or convertible debentures (fully or partially or optionally) and hencereporting under clause 3(x) (b) of the Order is not applicable.

xi. a) No fraud by the Company and no material fraud on the Company has been noticed orreported during the year.

b) No report under sub-section (12) of section 143 of the Companies Act has been filedin Form ADT-4 as prescribed under rule 13 of Companies (Audit and Auditors) Rules 2014with the Central Government during the year and upto the date of this report.

c) The company has not received any whistle blower complaints hence reporting underclause 3(xi)(c) is not applicable.

xii. The Company is not a Nidhi Company and hence reporting under clause (xii) of theOrder is not applicable.

xiii. In our opinion the Company is in compliance with Section 177 and 188 of theCompanies Act 2013 with respect to applicable transactions with the related parties andthe details of related party transactions have been disclosed in the standalonefinancialstatements as required by the applicable accounting standards.

xiv. (a) In our opinion the Company has an adequate internal audit system commensuratewith the size and the nature of its business. (b) We have considered the internal auditreports for the year under audit. xv. The Company has not entered in to any non-cashtransaction with director or persons connected with them.

xvi. (a) In our opinion the Company is not required to be registered under section45-IA of the Reserve Bank of India Act 1934. Hence reporting under clause 3(xvi) (a)(b) and (c) of the Order is not applicable.

(b) In our opinion there is no core investment company within the Group (as defined inthe Core Investment Companies (Reserve Bank) Directions 2016) and accordingly reportingunder clause 3(xvi) (d) of the Order is not applicable.

xvii. The Company has not incurred cash losses during the financial year covered by ouraudit and the immediately preceding financial year.

xviii. There has been no resignation of the statutory auditors of the Company duringthe year.

xix. On the basis of the financialratios ageing andexpecteddatesofrealizationoffinancialassets and payment of financial liabilities otherinformation accompanying the financial statements and our knowledge of the Board ofDirectors and Management plans and based on our examination of the evidence supporting theassumptions nothing has come to our attention which causes us to believe that anymaterial uncertainty exists as on the date of the audit report indicating that Company isnot capable of meeting its liabilities existing at the date of balance sheet as and whenthey fall due within a period of one year from the balance sheet date. We however statethat this is not an assurance as to the future viability of the Company. We further statethat our reporting is based on the facts up to the date of the audit report and we neithergive any guarantee nor any assurance that all liabilities falling due within a period ofone year from the balance sheet date will get discharged by the Company as and when theyfall due.

xx. (a) There are no unspent amounts towards Corporate Social Responsibility (CSR) onother than ongoing projects requiring a transfer to a Fund specified in Schedule VII tothe Companies Act in compliance with second proviso to sub-section (5) of Section 135 ofthe said Act. Accordingly reporting under clause 3(xx) (a) of the Order is not applicablefor the year.

(b) No amount remains unspent under sub section (5) of section 135of the Companies Actpursuant to any ongoing project.

For Jain Pramod Jain & Co.
Chartered Accountants)
(Firm Registration No. 016746 N)
(P.K.Jain)
Partner
Membership No. 010479
UDIN: 22010479AJTECV6162
Place: New Delhi
Date: 27.05.2022

Annexure - B to the Independent Auditors' report of even date on the FinancialStatement of STAR PAPER MILLS LIMITED.

Report on the Internal Financial Controls under Clause (i) of sub section 3 of section143 of the Companies Act 2013

We have audited the internal financial controls over financial reporting ofSTARPAPER MILLS LIMITED. as at March 312022 in conjunction with our audit of thefinancial 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 "the

Internal Financial Controls over Financial Reporting issued by the Institute ofChartered Accountants of India." These responsibilities include the designimplementation and maintenance of adequate Internal Financial Controls that were operatingeffectively for ensuring the orderly and efficient conduct of its business includingadherence to Company's policies the safeguarding of its assets the prevention anddetection of frauds and errors the accuracy and completeness of the accounting recordsand the timely preparation of reliable financial information as required under theCompanies 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 Guidance note on Audit of Internal Financial Controls over Financial Reporting(the" Guidance Note") and the Standards on Auditing issued by ICAI and deemedto be prescribed under section 143 (10) of the Companies Act 2013 to the extentapplicable to an audit of internal financial controls both applicable to an audit ofInternal Financial Controls and both issued by the Institute of Chartered Accountants ofIndia. 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 and maintained andif such controls operated effectively in all material respects. Our audit involvesperforming procedures to obtain audit evidence about the adequacy of the Internalfinancial controls system over financial reporting and their operating effectiveness ouraudit of internal financial controls over financial reporting included obtaining andunderstanding of internal financial controls over financial reporting assessing the riskthat a material weakness exists and testing and evaluating the design and operatingeffectiveness of internal control based on the assessed risk. The procedures selecteddepend on the auditor's judgement including the assessment of the risks of materialmisstatement of the financial statement 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 report ing.

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 details accurately and fairly reflect the transactions anddisposition of the assets of the company;(2) provide reasonable assurance thattransactions are recorded as necessary to permit preparation of financial statement inaccordance with generally accepted accounting principles and that receipts andexpenditures of the Company are being made only in accordance with authorizations ofmanagement and directors of the Company; and (3) provide reasonable assurance regardingprevention or timely detection of unauthorized acquisition use or disposition of thecompany's assets that could have a material effect on the financial statements.

Inherent Limitations of Internal Financial Controls over Financial Reporting

Because of the inherent limitation 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 may not be detected.Also projections of any evaluation of the internal financial controls over financialreporting to future periods are subject to the risk that the internal financial controlover financial reporting may become inadequate because of changes in conditions or thatthe degree of compliance with the policies or procedures may deteriorate.

Opinion

In our opinion the Company has in all material respects an adequate internalfinancial control system over financial reporting and such internal financial controlsover financial reporting were operating effectively as at March 31 2022 based on"the internal control over financial reporting criteria established by the CompanyConsidering the essential components of internal control stated in the "Guidance Noteon Audit of Internal Financial Controls over Financial Reporting issued by the Instituteof Chartered Accountants of India".

For Jain Pramod Jain & Co.
Chartered Accountants)
(Firm Registration No. 016746 N)
(P.K.Jain)
Partner
Place: New Delhi Membership No. 010479
Date: 27.05.2022 UDIN: 22010479AJTECV6162

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