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Starlite Components Ltd.

BSE: 517548 Sector: Others
NSE: N.A. ISIN Code: INE035C01022
BSE 14:39 | 26 Feb 2.55 0.12
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NSE 05:30 | 01 Jan Starlite Components Ltd
OPEN 2.31
PREVIOUS CLOSE 2.43
VOLUME 1750
52-Week high 4.02
52-Week low 2.09
P/E
Mkt Cap.(Rs cr) 4
Buy Price 2.55
Buy Qty 1850.00
Sell Price 2.55
Sell Qty 150.00
OPEN 2.31
CLOSE 2.43
VOLUME 1750
52-Week high 4.02
52-Week low 2.09
P/E
Mkt Cap.(Rs cr) 4
Buy Price 2.55
Buy Qty 1850.00
Sell Price 2.55
Sell Qty 150.00

Starlite Components Ltd. (STARLITECOMP) - Auditors Report

Company auditors report

To The Members of STARLITE COMPONENTS LIMITED Report on the Audit of the StandaloneFinancial Statements

Opinion

We have audited the standalone financial statements of Starlite Components Limited("the Company") which comprise the balance sheet as at 31 March 2019 thestatement of profit and loss (including other comprehensive income) the statement ofchanges in equity and the statement of cash flows for the year then ended and notes tothe standalone financial statements including a summary of the significant accountingpolicies 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 ("the Act") in the manner so required andgive a true and fair view in conformity with the Ind AS and accounting principlesgenerally accepted in India of the state of affairs of the Company as at 31 March 2019and profit (including other comprehensive income) changes in equity and its cash flowsfor the year ended on that date.

We draw attention to:

(i) The fact that figures for the corresponding year ended 31 March 2018 included instandalone financial statements are based on the previously issued standalone financialstatements that were audited by predecessor auditors vide their unmodified audit opinion.We have relied and considered the figures as reported by the predecessor auditors for thecorresponding period.

Basis for Opinion

We conducted our audit in accordance with the Standards on Auditing (SAs) specifiedunder Section 143(10) of the Act. Our responsibilities under those Standards are furtherdescribed in the Auditor's Responsibilities section of our report. We are independent ofthe Company in accordance with the Code of Ethics issued by the Institute of CharteredAccountants of India together with the ethical requirements that are relevant to our auditof the standalone financial statements under the provisions of the Act and the Rulesthereunder and we have fulfilled our other ethical responsibilities in accordance withthese requirements and the Code of Ethics. We believe that the audit evidence we haveobtained is sufficient and appropriate to provide a basis for our opinion.

Emphasis of Matter

1. We draw attention to note 31 to the financial statements relating to remunerationpaid to the Managing Director & Executive Director of the Company for the financialyear ended 31 March 2019 being in excess of the limits prescribed under Section 197 ofthe Act by INR 21.15 lakhs which is subject to the approval of the shareholders.

2. As per the scheme of Board of Industrial and Financial Reconstruction (BIFR) orderdated 10th October 2013 the promoters were required to bring in equity in thecompany for meeting the liabilities arising in the company. The company had borrowed fundsfrom the Promoters and its affiliates on time & need basis. The Board of Directors inthe meeting held on 29/08/2017 decided to convert the amount due towards these UnsecuredLoans raised from Promoters and its affiliates into Securities of the Company andaccordingly converted an amount of INR 132171345/- as Share Application money on31/03/2018.

During the year in line with special resolution passed in the Annual General Meetingof the Company held on

28/09/2017 and as per BIFR scheme; the Company decided to issue Share Warrants toPromoter s Affiliate from its above Share Application Money. Accordingly the Board ofDirectors in their meeting held on 28/09/2018 decided to issue 680005 no. of ShareWarrants at INR 54/- each convertible into equity shares of the company. As a part ofcompliance to BSE the company did not receive the in-principal approval from BSE. So theBoard of Directors in their meeting held on 31/01/2019 decided to reverse the ShareWarrants issue to Promoter s Affiliate; and reconverts the amount due as share applicationmoney into Unsecured Loans from Promoters and its affiliates.

Our opinion is not modified in respect of this matter.

Key Audit Matters

Key audit matters ( KAM ) are those matters that in our professional judgment were ofmost significance in our audit of the standalone financial statements of the currentperiod. These matters were addressed in the context of our audit of the standalonefinancial statements as a whole and in forming our opinion thereon and we do not providea separate opinion on these matters.

For each matter below our description of how our audit addressed the matter isprovided in that context. We have determined the matters described below to be the keyaudit matters to be communicated in our report. We have fulfilled the responsibilitiesdescribed in the Auditor s responsibilities for the audit of the financial statementssection of our report including in relation to these matters. Accordingly our auditincluded the performance of procedures designed to respond to our assessment of the risksof material misstatement of the AS financial statements. The results of audit proceduresperformed by us including those procedures performed to address the matters belowprovide the basis for our audit opinion on the accompanying financial statements.

The Key Audit Matter How the matter was addressed in our audit
1. Revenue Recognition
Our audit procedures included:
Revenue is measured net of discounts rebates and incentives earned by customers on the Company s sales. ? Assessing the appropriateness of the revenue recognition accounting policies including those relating to discounts rebates and incentives by comparing with applicable Ind AS.
Revenue is recognized when the control of the underlying products has been transferred to the customer. There is a risk of revenue being overstated due to fraud resulting from the pressure on management to achieve performance targets at the reporting period end. ? Performing substantive testing (including year- end cutoff testing) by selecting samples of revenue transactions recorded during the year by verifying the underlying documents which included sales invoices/contracts and shipping documents.
? Assessing manual journals posted to revenue to identify unusual items.
? Considered the adequacy of the Company s disclosures in respect of revenue.
2. Inventory Valuation
Our audit procedures included:
Inventories are held at the lower of cost and net realizable value (NRV). ? Assessing the appropriateness of the inventory valuation method followed by the management and by comparing with applicable Ind AS.
Due to high volume and nature of products the company is dealing with and the absence of adequate records valuation of inventory may be misstated. ? Performing substantive testing (including year end cut off testing) by selecting samples of inward and outward movement of inventory during the year by verifying the underlying documents which included sales invoices / purchase invoice and bill of entry.
Also NRV is being based on the assumptions / judgment of the management. Inappropriate assumptions of NRV can impact the assessment of the carrying value of inventories.
? Evaluating the design and implementation of the Company s internal controls over the Net Realizable Value (NRV) assessment.
? Considered the valuation certificate provided by the management.
3. Litigations & Claims
The Company operates in complex regulatory Our procedures included:
environment exposing it to a variety of different central and state laws regulations and interpretations thereof. ? Reviewing the outstanding litigations against the Company for consistency with the previous years.
In this regulatory environment there is an inherent risk of litigations and claims. Enquire and obtain explanations for movement during the year.
Consequently provisions and contingent liability disclosures may arise from direct and indirect tax proceedings legal proceedings including regulatory and other government / department proceedings as well as investigations by authorities and commercial claims. ? Discussing the status of significantly known actual and potential litigations with the senior management personnel who have knowledge of these matters and assessing their responses.
Management applies significant judgment in estimating the likelihood of the future outcome in each case when considering whether and how much to provide or in determining the required disclosure for the potential exposure of each matter. ? Reading the latest correspondence between the Company and the various tax / legal authorities and review of correspondence with / legal opinions obtained by the management from external legal advisors where applicable for significant matters and considering the same in evaluating the appropriateness of the Company s provisions or disclosures on such matters.
These estimates could change substantially over time as new facts emerge as each legal case progress.
Given the inherent complexity and magnitude of potential exposures across the Company and the judgment necessary to estimate the amount of provisions required or to determine required disclosures this is a key audit matter. ? Examining the Company s legal expenses and reading the minutes of the board meetings in order to ensure that all cases have been identified.
? With respect to tax matters involving our tax specialists and discussing with the Company s tax officers their views and strategies on significant cases as well as the related technical grounds relating to their conclusions based on applicable tax laws.
? Assessing the decisions and rationale for provisions held or for decisions not to record provisions or make disclosures.
? For those matters where management concluded that no provisions should be recorded considered the adequacy and completeness of the Company s disclosures.

Other Information

The Company s management and Board of Directors are responsible for the preparation ofother information. The other information comprises the information included in theManagement Discussion and Analysis Board s Report including Annexure s to Board s ReportCorporate Governance and Shareholder s Information but does not include the standalonefinancial statements and our auditors report thereon.

Our opinion on the standalone financial statements does not cover the other informationand we do not express any form of assurance conclusion thereon. In connection with ouraudit of the standalone 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 in theaudit or otherwise appears to be materially misstated. If based on the work we haveperformed we conclude that there is a material misstatement of this other information; weare required to report that fact. We have nothing to report in this regard.

Management s Responsibility for the Standalone Financial Statements

The Company s Board of Directors is responsible for the matters stated in Section134(5) of the Companies Act 2013 ("the Act") with respect to the preparation ofthese standalone Ind AS financial statements that give a true and fair view of thefinancial position financial performance including other comprehensive income cash flowsand changes in equity of the Company in accordance with the accounting principlesgenerally accepted in India including the Indian Accounting Standards (Ind AS) prescribedunder section 133 of the Act read with Companies (Indian Accounting Standard) Rules 2015as amended and other accounting principles generally accepted in India. Thisresponsibility also includes maintenance of adequate accounting records in accordance withthe provisions of the Act for safeguarding the assets of the Company and for preventingand detecting frauds and other irregularities; selection and application of appropriateaccounting policies; making judgments and estimates that are reasonable and prudent; anddesign implementation and maintenance of adequate internal financial controls that wereoperating effectively for ensuring the accuracy and completeness of the accountingrecords relevant to the preparation and presentation of the standalone Ind AS financialstatements that give a true and fair view and are free from material misstatement whetherdue to fraud or error.

In preparing the standalone financial statements management and Board of Directors areresponsible for assessing the Company s ability to continue as a going concerndisclosing as applicable matters related to going concern and using the going concernbasis of accounting unless management either intends to liquidate the Company or to ceaseoperations or has no realistic alternative but to do so.

Board of Directors is also responsible for overseeing the Company s financial reportingprocess.

Auditors Responsibility for the Audit of the Standalone Financial Statements

Our objectives are to obtain reasonable assurance about whether the standalonefinancial 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 financial statements. As part of an audit in accordance withSAs we exercise professional judgment and maintain professional skepticism throughout theaudit. We also:

? Identify and assess the risks of material misstatement of the financial statementswhether due to fraud or error design and perform audit procedures responsive to thoserisks and obtain audit evidence that is sufficient and appropriate to provide a basis forour opinion. The risk of not detecting a material misstatement resulting from fraud ishigher than for one resulting from error as fraud may involve collusion forgeryintentional omissions misrepresentations or the override of internal control. ? Obtainan understanding of internal control relevant to the audit in order to design auditprocedures that are appropriate in the circumstances. Under Section 143(3)(i) of the Actwe are also responsible for expressing our opinion on whether the company has adequateinternal financial controls with reference to standalone financial statements in place andthe operating effectiveness of such controls. ? Evaluate the appropriateness of accountingpolicies used and the reasonableness of accounting estimates and related disclosures madeby 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 Company sability to continue as a going concern. If we conclude that a material uncertainty existswe are required to draw attention in our auditor s report to the related disclosures inthe standalone financial statements or if such disclosures are inadequate to modify ouropinion. Our conclusions are based on the audit evidence obtained up to the date of ourauditors' report. However future events or conditions may cause the Company to cease tocontinue as a going concern. ? Evaluate the overall presentation structure and content ofthe standalone financial statements including the disclosures and whether the standalonefinancial statements represent the underlying transactions and events in a manner thatachieves fair presentation. We communicate with those charged with governance regardingamong other matters the planned scope and timing of the audit and significant auditfindings including any significant deficiencies in internal control that we identifyduring our audit. We also provide those charged with governance with a statement that wehave complied 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 matterscommunicated with those charged with governance we determine those matters that were ofmost significance in the audit of the standalone financial statements of the currentperiod and are therefore the key audit matters. We describe these matters in our auditorsreport unless law or regulation precludes public disclosure about the matter or when inextremely rare circumstances we determine that a matter should not be communicated in ourreport because the adverse consequences of doing so would reasonably be expected tooutweigh the public interest benefits of such communication.

Report on Other Legal and Regulatory Requirements

1. As required by the Companies (Auditors Report) Order 2016 ("the Order")issued by the Central Government of India in terms of Section 143(11) of the Act we givein the "Annexure A" a statement on the matters specified in paragraphs 3and 4 of the Order to the extent applicable.

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 (including other comprehensiveincome) the Statement of Changes in Equity and the Statement of Cash Flows dealt with bythis Report are in agreement with the books of account.

d) In our opinion the aforesaid standalone financial statements comply with the Ind ASspecified under Section 133 of the Act read with Rule 7 of the Companies (Accounts)Rules 2014.

e) On the basis of the written representations received from the directors as on 31March 2019 taken on record by the Board of Directors none of the directors isdisqualified as on 31 March 2019 from being appointed as a director in terms of Section164(2) of the Act.

f) With respect to the adequacy of the internal financial controls with reference tofinancial statements of the Company and the operating effectiveness of such controlsrefer to our separate Report in "Annexure B". g) With respect to theother matters to be included in the Auditors Report in accordance with Rule 11 of the

Companies (Audit and Auditors) Rules 2014 in our opinion and to the best of ourinformation and according to the explanations given to us: i. The Company has disclosedthe impact of pending litigations as at 31 March 2019 on its financial position in itsstandalone financial statements - Refer Note 40 to the standalone financial statements;ii. The Company did not have any long-term contracts including derivative contracts forwhich there were any material foreseeable losses; and iii. There were no amounts whichwere required to be to the Investor Education and Protection Fund by the Company duringthe year ended 31 March 2019;

For M/s. Jain Chhajed & Associates
Chartered Accountants
Firm Registration No. 127911W
CA. Dinesh Burad
Partner
Membership No: 151551
Place: Nashik
Date: 30th May 2019

ANNEXURE A TO THE INDEPENDENT AUDITORS REPORT 31 MARCH 2019

With reference to the Annexure A referred to in the Independent Auditors Report to themembers of the Company on the standalone financial statements for the year ended 31 March2019 we report the following:

1. Property Plant and Equipments

(a) The Company has maintained records but the same has not been properly updatedshowing full particulars including quantitative details and situation of property plantand equipment and investment properties. (b) The management at the end of the year hasphysically verified the fixed assets and we have been informed that no discrepancies werenoticed on such verification as compared to book records in respect of assets verifiedduring the year. (c) According to the information and explanations given to us and on thebasis of our examination of the records of the Company there are no immovable propertiesheld in the name of the Company.

2. Inventories

(a) The inventory has been physically verified during the year by the management. Inour opinion the frequency of verification is reasonable. (b) The management has conductedphysical verification of inventory at reasonable intervals during the year. Thediscrepancies noticed on verification between physical stock and book records were notmaterial as reported by the management and the same has been properly dealt within thebooks of accounts. There was no inventory lying with third parties.

3. Loans granted

As informed to us company has not granted any loans secured or unsecured tocompanies firms or other parties covered in the register maintained under section 189 ofthe Companies Act 2013. Hence our comments on following matters are not attracted: - (a)Whether the terms and conditions of the grant of such loans are not prejudicial to thecompany s interest. (b) Whether the schedule of repayment of principal and payment ofinterest has been stipulated; and (c) Whether the repayments or receipts are regular.

4. Loans Investments Guarantees and Security:

In our opinion and according to the information and explanations given to us and basedon the audit procedures conducted by us the Company has not granted any loans or givenguarantees directly or indirectly to directors or any other person in whom directors areinterested in contravention of Section 185 of the Companies Act 2013. Accordinglycompliance under Section 185 and 186 of the Act in respect of providing securities is notapplicable to the Company.

5. Deposits

In our opinion and according to the information and explanations given to us theCompany has not accepted deposits as per the directives issued by the Reserve Bank ofIndia and the provisions of Sections 73 to 76 or any other relevant provisions of the Actand the rules framed there under. Accordingly paragraph 3 (v) of the Order is notapplicable to the Company.

6. Cost records

According to the information and explanations given to us and on the basis of ourexamination of books of account the Company need not maintain cost records as per theCompanies (Cost Accounting Records) Rules 2011 prescribed by the Central Government underSection 148(1) of the Act.

7. Statutory dues

(a) According to the information and explanations given to us and on the basis of ourexamination of books of accounts the Company is moderately regular in depositingundisputed statutory dues including

Provident Fund Employees State Insurance Goods and Service Tax Labour CessProfessional Tax

Property Tax Cess and other material statutory dues with the appropriate authoritiesduring the year. Amounts deducted / accrued in the books of account in respect ofundisputed statutory dues of Income tax have generally been regularly deposited during theyear by the Company with the appropriate authorities though there have been nominaldelays on occasions. As explained to us the Company did not have any dues on account ofwealth tax.

(b) According to the information and explanations given to us undisputed amountpayable which were outstanding as on March 31 2019 for a period of more than six monthsfrom the due date consist of: Old BST / CST dues Rs. 1489890/-; Deferred BST LiabilityRs. 251439/-; Deferred CST Liability Rs. 414305/-; CST Rs.14750/-; VAT Rs.110432370/-; ESIC Rs.187009/-; Provident Fund Rs.419187/- and Profession TaxRs.72065/-

(c) No such dues of Income-tax Service Tax Custom Duty Excise Duty and GST wereoutstanding on account of any dispute pending with any forum. Disputed dues notprovided for in the books of accounts are disclosed under Contingent Liabilities.

8. Defaults in repayment

In our opinion and according to the information and explanations given to us theCompany has not defaulted except occasional delays during the year in repayment of loansor borrowings to banks or financial institutions or dues to debenture holders. The Companydoes not have any loans or borrowings from government during the year.

9. Utilization of funds

The Company has not raised any money by way of initial public offer or further publicoffer (including debt instruments). In our opinion and according to the information andexplanations given to us the proceeds of term loans have been applied by the Company forthe purposes for which they were raised.

10. Fraud

During the course of our examination of the books and records of the Company carriedout in accordance with the generally accepted auditing practices in India and accordingto the information and explanations given to us we have neither come across any instanceof material fraud by the Company or on the Company by its officers or employees noticedor reported during the year nor have we been informed of any such case by the management.

11. Managerial Remuneration

According to the information and explanations given to us and based on our examinationof the records of the Company due to inadequate profits during the current year themanagerial remuneration paid to the directors of the company is in excess of the limitsspecified under Section 197 of the Act read with Schedule V to the Act. The Company is inthe process of obtaining approval from Shareholders for such excess remuneration paid.

12. Nidhi Company

In our opinion and according to the information and explanations given to us theCompany is not a Nidhi company and the Nidhi Rules 2014 are not applicable to it.Accordingly paragraph 3 (xii) of the Order is not applicable to the Company.

13. Related Party Transactions

In our opinion and according to the information and explanations given to us theCompany has entered into transactions with related parties in compliance with theprovisions of Sections 177 and 188 of the Act. The details of such related partytransactions have been disclosed in the standalone financial statements as required byIndian Accounting Standard (Ind AS) 24 Related Party Disclosures specified under Section133 of the Act.

14. Preferential Allotment & Private Placement of Shares or Debentures

According to the information and explanations given to us and on the basis of ourexamination of the records of the Company the Company has not made any preferentialallotment or private placement of shares or fully or partly convertible debentures duringthe year and hence reporting under clause (xiv) of paragraph 3 of the Order is notapplicable to the Company.

15. Non-cash transactions with Directors

According to the information and explanations given to us and on the basis of ourexamination of the records of the Company the Company has not entered into any non-cashtransactions with directors or persons connected with them. Accordingly paragraph 3 (xv)of the Order is not applicable to the Company.

16. Registration under 45-IA of Reserve Bank of India Act 1934

In our opinion and according to the information and explanations given to us theCompany is not required to be registered under Section 45-IA of the Reserve Bank of IndiaAct 1934. Accordingly paragraph 3 (xvi) of the Order is not applicable to the Company.

For Jain Chhajed & Associates
Chartered Accountants
Firm Registration No. 127911W
CA. Dinesh Burad
Partner
Membership No: 151551
Place: Nashik
Date: 30th May 2019

ANNEXURE B TO THE INDEPENDENT AUDITORS REPORT 31 MARCH 2019

Report on the Internal Financial Controls with reference to the aforesaid standalonefinancial statements under Clause (i) of Sub-section 3 of Section 143 of the CompaniesAct 2013 (gthe Acth)

(Referred to in paragraph (A) (f) under Report on Other Legal and RegulatoryRequirements section of our report of even date)

We have audited the internal financial controls over financial reporting of STARLITECOMPONENTS LIMITED ("the Company") as of 31st March 2019 inconjunction with our audit of the standalone Ind AS financial statements of the Companyfor the year ended on that date.

Management s Responsibility for Internal Financial Controls

The Company s management and the Board of Directors are responsible for establishingand maintaining internal financial controls based on the internal controls with referenceto standalone financial statements criteria established by the Company considering theessential components of internal control stated in the Guidance Note. 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 Company s policies the safeguardingof its assets the prevention and detection of frauds and errors the accuracy andcompleteness of the accounting records and the timely preparation of reliable financialinformation as required under the Companies Act 2013.

Auditor s Responsibility

Our responsibility is to express an opinion on the Company s internal financialcontrols over financial reporting based on our audit. We conducted our audit in accordancewith the Guidance Note on Audit of Internal Financial

Controls Over Financial Reporting (the "Guidance Note") issued by theInstitute of Chartered Accountants of India and the Standards on Auditing prescribed underSection 143(10) of the Act to the extent applicable to an audit of internal financialcontrols. Those Standards and the Guidance Note require that we comply with ethicalrequirements and plan and perform the audit to obtain reasonable assurance about whetheradequate internal financial controls over financial reporting was established andmaintained and if such controls operated effectively in all material respects.

Our audit involves performing procedures to obtain audit evidence about the adequacy ofthe internal financial controls system over financial reporting and their operatingeffectiveness. Our audit of internal financial controls over financial reporting includedobtaining an understanding of internal financial controls over financial reportingassessing the risk that a material weakness exists and testing and evaluating the designand operating effectiveness of internal control based on the assessed risk. The proceduresselected depend on the auditor s judgment including the assessment of the risks ofmaterial misstatement of the financial statements whether due to fraud or error.

We believe that the audit evidence we have obtained is sufficient and appropriate toprovide a basis for our audit opinion on the Company s internal financial controls systemover financial reporting.

Meaning of Internal Financial Controls Over Financial Reporting

A company s internal financial 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 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.

Qualified Opinion

According to the information and explanation given to us and based on our audit thefollowing material weakness has been identified as at March 31 2019:

(a) The company has designed and implemented internal financial controls in theorganization and the same are operating effectively. However as informed documentationof such control framework is in progress at the year end.

A material weakness is a deficiency or a combination of deficiencies in internalfinancial control over financial reporting; such that there is reasonable possibility thata material misstatement of the company s annual financial statements will not be preventedor detected on a timely basis.

In our opinion except for the effects / possible effects of the material weaknessdescribed above on the achievement of the objectives of the control criteria the companyhas maintained an adequate and effective internal financial controls system over financialreporting and such internal financial controls over financial reporting were operatingeffectively as at 31 March 2019 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".

For Jain Chhajed & Associates
Chartered Accountants
Firm Registration No. 127911W
CA. Dinesh Burad
Partner
Membership No: 151551
Place: Nashik
Date: 30th May 2019

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