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STEL Holdings Ltd.

BSE: 533316 Sector: Financials
NSE: STEL ISIN Code: INE577L01016
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OPEN 115.15
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VOLUME 2981
52-Week high 121.20
52-Week low 48.10
P/E 23.90
Mkt Cap.(Rs cr) 207
Buy Price 111.80
Buy Qty 51.00
Sell Price 112.40
Sell Qty 1.00
OPEN 115.15
CLOSE 113.80
VOLUME 2981
52-Week high 121.20
52-Week low 48.10
P/E 23.90
Mkt Cap.(Rs cr) 207
Buy Price 111.80
Buy Qty 51.00
Sell Price 112.40
Sell Qty 1.00

STEL Holdings Ltd. (STEL) - Director Report

Company director report

Dear members

The Board of Directors have pleasure in presenting the Thirtieth Annual Report of yourcompany along with the audited financial statements and related annexures for thefinancial year ended March 31 2020. performance of the Company and its subsidiaries hasbeen referred to wherever required.

1. Financial Highlights

The revenue of the Company predominantly consist of dividend income. The net profitafter tax for the year ended March 31 2020 was Rs. 1517.52 lakhs.

(In lakhs)

Particulars

Standalone

Consolidated

For the year ended 31.03.2020 For the year ended 31.03.2019 For the year ended 31.03.2020 For the year ended 31.03.2019
Total Income 1625.71 980.72 1625.71 980.72
Profit / Loss before Tax 1549.33 919.74 1548.61 919.05
Provision for Taxation 31.81 20.44 31.71 20.44
Profit/Loss after Tax 1517.52 899.30 1516.90 898.61

2. Operations of the Company

Investments are made in various companies and dividend constitutes

Company. Apart from dividend income the company has interest income from fixeddeposits maintained with banks. During the year total income of the company was Rs.1625.71lakhs as against Rs.980.72 lakhs in the previous year. The Company recorded the Net profit(after tax) of Rs.1517.52 lakhs as against Profit after tax of Rs.899.30 in the previousyear. During the year the consolidated profit after tax was Rs.1516.90 lakhs . comparedtoprofitof Rs 898 61lakhsinthe previousyear The impact of Covid-19 pandemic in theoperations ourcompany is detailed in the Management of Discussion and Analysis Report which forms partof the Annual Report.

3. Material Changes and Commitments affecting the financialposition between theend of the financial year of the company to which the financial statements relate and thedate of the report

No material changes and commitments affecting the financial position the end of thefinancial year to which this financial statements relate on the date of this report.

However the company continues to Services Ltd ( CFL CFSL) amounting to an investmentcost of Rs.127344645/-.The Hon'ble High Court of Calcutta has passed an order onOctober 06 2015 for liquidation of CFL CFSL based on an application by a creditor of thecompany. The office of the official liquidator Calcutta had took over possession of theRegistered office of CFL CFSL on November 192015 along with books records and assets.

4. Change in the Nature of Business

During the year under review there was no change in the nature of the business. TheCompany is an Investment Holding Company which invests in the securities of groupcompanies.

5. Dividend

Your Directors have not declared any dividend on equity shares for the year ended March31 2020 in order to conserve the resources for the future years. There are no amounts tobe transferred to Investor Education and Protection Fund.

Total amount lying in the Unpaid Dividend Account of the company in respect of the lastseven years - Nil When such unpaid Dividend is due for transfer to the IEPF - NA.

The amount of Dividend if any transferred by the company to the Investor Educationand Protection Fund during the year - NA

6. Amount transferred to the Reserves:

Your Directors does not propose transfer of any amount to the reserves.

7. Extract of Annual Return

The Extract of Annual Return in form MGT-9 pursuant to the provisions of Section 92read with rule 12 of the Companies (Management and Administration) Rules2014 is annexedto Annual Report and placed on the website of the Company and can be accessed at:https://www.stelholdings.com/SFin.

8. Listing

The Equity Shares of the Company continue to remain listed on BSE Limited and NationalStock Exchange of India Limited.

9. Deposits

The Company has not accepted any deposit within the meaning of subsection 31 of Section2 and Section 73 of the Companies Act 2013 and the Rules framed there under. As on March31 2020 there were no deposits lying unpaid or unclaimed.

10. Particulars of Loans Guarantees or Investments

Particulars under section 186 made during the year if any isofloansguaranteesorinvestments detailed in the Notes to the Financial Statements formingpart of this Annual Report.

11. Conservation of Energy Technology Absorption

The Additional information required under the read with the Companies (Accounts) Rules2014 and forming part of the Report is reproduced herewith: (a) Conservation of energy andtechnology absorption: As the Company holds investments in the other Companies there areno particulars conservation of energy and technology absorption as required underprovisions of the Act and rules made thereunder.

(b) Foreign Exchange earnings and outgo: Total foreign exchange inflow: Nil Totalforeign exchange outflow: Nil

12. Subsidiary & Associate Company

As on March 31 2020 the Company has a subsidiary Doon Dooars Plantations shall bemade available to the shareholders of the Company seeking such information

The Consolidated Financial Statements of the Company along with its subsidiary preparedfor the year 2019-20 in accordance with relevant Indian Accounting Standard issued byInstitute of India forms part of the Annual Report. None of the companies has become orceased to be a subsidiary or associate of the Company.

The Company holds 48.81% in the share capital of CFL Capital Financial ServicesLimited. The Hon'ble High Court of Calcutta has passed an order on October 06 2015 forliquidation of CFL CFSL based on an application filed by a creditor of the company. Theoffice of the official liquidator Calcutta had took over possession the Registered officeof CFL CFSL on November 19 2015 along with books records and assets. As the financialstatements of the Associate Company are not available on time the same has not beenconsolidated as per the requirements under Companies Act 2013. A Report on theperformance and financial position of the Subsidiary and Associate Company pursuant toRule 5 of Companies (Accounts) Rules 2014 is annexed as Annexure - B and forms a part ofthis Report.

The Company has framed a policy for determining material subsidiaries and has uploadedthe same on website and link for the same is as below:http://stelholdings.com/docs/POLICY_ON_MATERIAL_SUBSIDIARIES.pdf Further pursuant to theprovisions of Section 136 of the Act the financial statements of the Companyconsolidated financial statements along with relevant documents and separate audited inrespect of subsidiaries are available on the website of the Company.

13. Corporate Governance Report and Management Discussion and Analysis Report

Your company has taken adequate steps to adhere to all the relevant stipulations laiddown in the SEBI

(Listing Obligations and Disclosure Requirements) Regulations 2015 on Corporate reporton the Corporate Governance (Annexure-D) The Management Discussion and Analysis(Annexure- C) and the Practicing Company Secretary's Certificate regarding compliance ofconditions of Corporate Governance are made part of the Annual Report.

14. Directors and Key Managerial Personnel

The Board of your Company consists of the following Seven Directors:

Category Name of Directors
Mr. Sunil Bhandari
Non-Executive Non - Independent Director Mr.Anant Vardhan Goenka
Mr.Kaushik Roy
Mr. H.C Dalal
Mr.Umang Kanoria
Non- Executive Independent Director
Mr.Prem Kapil
Ms.Kusum Dadoo

The composition of the Board is in line with the (Listing Obligations and Disclosurevast knowledge and experience in their relevant fields and the Company had benefittedimmensely by their presence in the Board. The key Board qualifications expertiseattributes are given in details in the Report on Corporate Governance forming part of thisReport.

During the year under review the non-executive directors of the Company had nopecuniary relationship or transactions with the Company other than sitting feescommission and reimbursement of expenses Company incurredbythemforthepurposeofattendingmeetingsof the Board/Committeeof the 149 of the Companies Act 2013 and Regulation 17 (1)(a) of the SEBI IntermoftheprovisionsofSection (LODR) Regulations 2015 the Company shallhave at least one Woman Director on the Board. Your Company has Ms. Kusum Dadoo as womanDirector on the Board.

The Company has Mr. Abraham Ittyipe as its Manager Mr.Sivaramakrishnan as its ChiefFinancial Officer and Ms. Lakshmi P.S as its Company Secretary who are designated as KeyManagerial Personnel within the meaning of Section 203 of the Companies Act 2013. asManager of the company at the annual general meeting of the Mr.AbrahamIttyipe company heldon 03.08.2017 for a period of five years with effect from 30.05.2017.

14.1 Changes in Directors and Key Managerial Personnel (KMP)

Appointment/ Re-appointment :

As per the provisionsoftheCompaniesAct2013Mr.KaushikRoyretiresby rotation at theensuing Annual

General Meeting and being eligible offers himself for reappointment.

The Detailed profile of Mr. Kaushik Roy recommended for re-appointment is enclosedwith the Notice for the 30th AGM of the Company as per Regulation 36 of the SEBI (ListingObligations and Disclosure Requirements) Regulations 2015.

The Board recommends the re-appointment of Mr. Kaushik Roy as stated above in theensuing Annual General Meeting.

During the year under review Mr. H.C Dalal Mr. Umang Kanoria and Mr. Prem Kapil werere-appointed as " Independent Directors" for the second term of five consecutiveyears commencing from October 01 2019 up to September 30 2024. Ms. Kusum Dadoo was alsomade as an Independent Director on the Board with effect from February 08 2019 up toFebruary 07 2024 for the first term of 5 years.

All the above appointment/re-appointments were approved by the Members of the Companyat the last Annual General Meeting by passing the requisite resolutions in this regard.

20 Therewasnoinduction orcessationof anyotherdirectors during the financialyear2019-During the year under review 5 (Five) meetings of the Board of Directors were helddetails of which are set out in the Corporate Governance Report which forms a part of thisReport.

14.2 Declaration by Independent Directors

149 of the Act and Regulation Interms oftheprovisionsofsub-section 16 of SEBI Listing

Regulations including amendments thereof the Company has received declarations fromall the Independent Directors of the Company that they meet with the criteria ofindependence as provided in the Act and SEBI Listing Regulations. There has been nochange in the circumstances affecting their status as an Independent Director during theyear. Further the Non-Executive Directors of the Company had no pecuniary relationship ortransactions with the Company other than sitting fees and reimbursement of expenses ifany incurred by them for the purpose of attending meetings of the Company.

The Board is of the opinion that the Independent Directors of the Company possessrequisite qualifications experience and expertise and they hold highest standards ofintegrity.

The Independent Directors have confirmed that they have registered their names in thedata bank maintained withtheIndianInstituteofCorporateAffairs(‘IICA'). In terms ofSection 150 of the Act read with Rule 6(4) of the Companies (Appointment &Qualification of Directors) Rules 2014 the Independent Directors are required toundertake online proficiency self-assessment test conducted by the IICA within a period ofone year from the date of inclusion of their names in the data bank. The IndependentDirectors to whom the provisions of proficiency test are applicable will take the saidonline proficiency test in due course.

14.3 Board Evaluation

The Board has carried out annual performance evaluation of its own performance theDirectors individually and of its Committees as mandated under the Act and SEBI ListingRegulations. In order to have a fair and unbiased view of all the Directors the Companyengaged the services of an external agency to facilitate the evaluation process. TheDirectors were provided with an electronic platform to record their views and aconsolidated report was generated by the agency based on the views expressed by all theDirectors. The reports generated out of the evaluation process were placed before theBoard at its meeting and noted by the Directors.

Further the Independent Directors of the Company met once during the year on February07 2020 to review the performance of the Non-executive directors Chairman of the Companyand performance of the Board as a whole and to assess the quality quantity and timelinessof flow of information management and the Board.

14.4. Policy on Appointment and Remuneration of Directors KMP Senior ManagementPersonnel and Other employees

The Board based on the recommendation of the Nomination and RemunerationCommittee hasformulated a policy on remuneration of Directors Key Managerial Personnel and SeniorManagement of the Company pursuant to the provisions of subsection (3) of Section 178 ofthe Act and SEBI ListingRegulations covers the appointment including criteria fordetermining qualification positive and remuneration of its Directors KeyManagerial Personnel Senior Management Personnel and other employees. The Nomination andRemuneration Policy is annexed as Annexure E to this report.

14.5 Policy on Board Diversity

The Policy on Company's diversity on the Board is provided on the website of theCompany and can be assessed at https://www.stelholdings.com/SInvestor.html.

15. Board Committees

Detailed composition of the mandatory Board Remuneration Committee and Stakeholder'sRelationship Committee year under review and other related details including attendanceare set out in the Corporate Governance Report which forms a part of this Report.situations where the Board has not accepted any recommendation of the AuditTherehavebeenno Committee.

16. Directors' Responsibility Statement as required under Section 134 of the CompaniesAct

Pursuant to the provisionsofclause(c)ofsub-section(3) and sub-section (5) ofBoardofDirectorsoftheCompanyherebyconfirmthat:

a) in the preparation of the annual accounts for accounting standards had been followedand there were no material departures;

b) the directors had selected such accountingpolicies and applied them consistently andmade judgments and estimates that are reasonable and prudent so as to give a true and fairview of the state of affairs of the company at the end of the financial year as at March31 2020 and of the profit of the company for the period ending March 31 2020;

c) the directorshadtakenproperandsufficient care for the maintenance of adequateaccounting records in accordance with the provisions of this Act for safeguarding theassets of the company and ; irregularities forpreventingand detectingfraud andother

d) the directors had prepared the annual accounts for the financial year ended on March312020 on a going concern basis;

e) the directors had laid down internal financial controls to be followed by thecompany and that such internal financial controls are adequate and were operating

f) the directors had devised proper systems to ensure compliance with the provisions ofall applicable laws and that such systems were adequate and operating effectively.

17. Auditors: 17.1. Statutory Auditors

M/s. J Krishnan & Associates Chartered Accountants (Registration No.: 001523S)were appointed as the

Statutory Auditors of the Company for a term of five years in the Annual GeneralMeeting of the Company held on 03.08.2017 till the conclusion of the Annual GeneralMeeting to be held for the financial year ended 31.03.2022.

The requirement of seeking ratification of appointment of the Statutory Auditors by theMembers at every Annual General Meeting has been done away with effective May 07 2018 bymaking amendment to the provisions of theCompaniesAct2013bytheMinistryofCorporateAffairsand accordingly M/s. J Krishnan &Associates continue to hold the office of Statutory Auditors for FY 2020-The Board hasduly examined the Statutory Auditors' Report to the accounts which is self-explanatory.Clarifications wherever necessary have been included in the Report.

There is no qualification disclaimer reservation Auditors' Report.

Details in respect of frauds

Detailsinrespectoffraudsreportedbyauditorsundersub-section( 12) of section 143of the other than those which are reportable to the Central Government - Nil

17.2. Secretarial Auditors

Pursuant to the provisions of Section 204 of the Act and the Companies (Appointment andRemuneration of Managerial Personnel) Rules 2014 the Board of the Directors of theCompany had appointed M/s. SVJS

& Associates Company Secretaries to undertake the Secretarial Audit of the Companyfor the year ended March 31 2020. The Secretarial Audit Report is annexed as Annexure -F.

The said Secretarial Audit Report does not contain any qualifications reservations oradverse remarks and no frauds were reported by the Secretarial Auditors to the Companyunder sub-section of the Act.

17.3. Internal Auditor

The Board had appointed M/s.CaesarPintoJohn & Associates LLP Company Secretariesas Internal Auditor for the financial year 2019-20.

The Company was not required to maintain Cost records as specified by the CentralGovernment under Section 148 (1) of the Companies Act 2013 and Rules made thereunder.

18. Corporate Social Responsibility

The Company does not come under the purview of Section 135 read with relevant rules ofthe Act. It is not mandatorily required to constitute Corporate Social ResponsibilityCommittee. has voluntarily constituted a Corporate Social monitor the CSR activitiesundertaken by the Company if any. The CSR Committee of the formulated and recommended tothe Board a Corporate Social Responsibility Policy (CSR Policy) indicating theactivitiesto be undertaken by the Company which has been approved by the Board. TheCompany's CSR

Policy is committedtowardsCSRactivitiesas envisaged in Schedule VII of the CompaniesAct 2013. The CSR Policy is available on the website of the Company athttps://www.stelholdings.com/SInvestor.html.

During the year under review the Company has not undertaken any CSR activity.

19. Whistle Blower Policy

The Company promotes ethical behavior in all its business activities and has amechanism for reporting unethical behavior actual or suspected frauds or violation of theCompany's Code of Conduct or ethics policy. Pursuant to Section 177 (9) & 177 (10) ofthe Companies Act 2013 and as

& 34 (3) read with Para 10 of Part C of Schedule V of the SEBI (LODR) Regulations2015 the Company has a Whistle Blower Policy or Vigil Mechanism in place. The mechanismprovide for adequate safeguards against victimization of Director(s)/Employee(s) who availof the mechanism and also provides for direct access to the Chairman of the AuditCommittee in exceptional Chairman of the Audit Committee for making complaint on anyIntegrity issue.

The said policy is available on the website of the Company which can be accessed byfollowing the below link. http://stelholdings.com/docs/Whistleblowerpolicy.pdf

20. Related Party Transactions the related parties Therewasnomateriallysignificantthat could have had a potential transaction conflict with the interests ofthe Company. There are no related party transactions which are not on an arm's lengthbasis. There are also no material contracts or arrangements or transactionswith relatedparties. Hence Form AOC-2 is not applicable for the company.

The policy on materiality of related party transactions and on dealing with relatedparty transactions as approved by the Board is uploaded on the Company's website on thebelow link: http://stelholdings.com/docs/Relatedpartytrans.pdf

21. Risk Management

The Company is exposed to inherent uncertainties owing to the sector in which itinvests and operates. A detailed report on Risk Management is included in ManagementDiscussion and Analysis which forms part of this Report. The report clearly statesdevelopment and implementation of a risk management policy for the company includingidentification therein of elements of risks along with risk mitigation plan.

22. Particulars of Employees

During the year under review none of the employees throughout the year or part of theyear were in receipt of remuneration in excess of the sums as prescribed pursuant toSection 197 read with rule 5 of the Companies (Appointment and Remuneration of managerialpersonnel) Rules 2014.

The information required under Rule 5(1) of the Companies (Appointment and Remunerationof Managerial Personnel) Rules 2014 is annexed as Annexure G and forms a part of thisreport.

23. Internal Financial Control

The Company has in place a stabilized and effective Internal Audit and FinancialControl System calibrated to the size and scale of operations of the Company. Apart fromstatutory audit in compliance with Section 138 of the Companies Act 2013 had engagedM/s. Caesar Pinto John & Associates LLP Company Secretaries as the Internal Auditorsof the Company for the FY 2019-20. Details in respect of adequacy of internal financialcontrols with reference to the Financial Statements are stated in Management Discussionand Analysis which forms part of this Report. During the year under review there were noreportable material weaknesses in the systems or operation.

24. Significant and Material Orders Passed by the Regulators or Courts

There were no significant and material orders passed going concern status and company'soperations in future.

25. Disclosure as per the Sexual Harassment of Women at Workplace (PreventionProhibition Act 2013

The Company has in place an Anti Sexual Harassment Policy in line with the requirementsof The Sexual Harassment of Women at the Workplace (Prevention Committee (ICC) has beenset up to redress complaints received (Permanent Contractual temporary trainees) arecovered under this policy.

The following is a summary of sexual harassment complaints received and disposed offduring the year 2019-20 No. of complaints received: NIL

No. of complaints disposed off: N A

The company has been complied with provisions relating to the constitution of InternalComplaints Committee under the Sexual Harassment of Women at Workplace (PreventionProhibition Act 2013

26. Compliance of Secretarial Standards

The Company has in compliance with applicable Secretarial Standards issued by theInstitute of Company Secretaries of India during the financial year.

27. Acknowledgements

Your Directors wish to place on record their appreciation to the Company by thebankers employees and shareholders.

For and on behalf of the board of directors
Mr. H.C Dalal Mr. Sunil Bhandari
(DIN : 00206232) (DIN: 00052161)
Director Director

Place : Kochi

Date : June 25 2020

Form No. MGT-9

EXTRACT OF ANNUAL RETURN

As on the financial year ended on March 31 2020

[Pursuant to section 92(3) of the Companies Act 2013 and rule 12(1) of the Companies(Management and Administration) Rules 2014]

I. REGISTRATION AND OTHER DETAILS

i) CIN L65993KL1990PLC005811
ii) Registration date 21.09.1990
iii) Name of the Company STEL Holdings Limited
iv) Category/Sub category of the Company Company Limited by Shares.
v) Address of the Registered office and contact Indian Non-Government Company details24/1624 Bristow RoadWillingdon Island Cochin - 682003 Kerala
Tel. No.: 0484 6624335
Fax No.: 0484 2668024
Email: secretarial@stelholdings.com
vi) Whether listed company Yes
vii) Name Address and Contact details of Registrar and Transfer Agent if any Link Intime India Pvt. Ltd.
Surya 35 Behind Senthil Nagar Sowripalayam Road Coimbatore 641028 Tamil Nadu
Phone: +91 422 2314792 2315792
Fax: +91 422 2314792

II. PRINCIPAL BUSINESS ACTIVITIES OF THE COMPANY

All the business activities contributing 10 % or more of the total turnover of thecompany shall be stated:-

Sl. No. Name and Description of main products / services NIC Code* of the Product/ service % to total turnover of the company
1 Activities of holding Companies 642 100

* as per NIC -2008

III. PARTICULARS OF HOLDING SUBSIDIARY AND ASSOCIATE COMPANIES

Sl. No. Name and Address of the Company CIN/GLN Holding/ Subsidiary/ Associate % of shares held Applicable Section
1 Doon Dooars Plantations Limited U01132MH1994PLC273639 Subsidiary Company 100% 2(87)(ii)
2 CFL Capital Financial Services Limited (UNDER LIQUIDATION) L67120WB1983PLC036805 Associate Company 48.81% Section

IV) SHARE HOLDING PATTERN (Equity Share Capital Breakup as percentage of Total Equity)i) Category-wise Share Holding as of March 31 2020

Sr No. Category of Shareholders Shareholding at the begining of the year - 2019 Shareholding at the End of the year - 2020 % change during the year
Demat Physical Total % of Total Shares Demat Physical Total % of Total Shares
(A) Shareholding of Promoter and Promoter Group
[1] Indian
(a) Individuals / Hindu 90030 0 90030 0.4878 90030 0 90030 0.4878 0.0000
Undivided Family
(b) Central Government / 0 0 0 0.0000 0 0 0 0.0000 0.0000
State Government(s)
(c) Financial Institutions 0 0 0 0.0000 0 0 0 0.0000 0.0000
/ Banks
(d) Any Other (Specify)
Promoter Trust 262140 0 262140 1.4204 262180 0 262180 1.4206 0.0002
Bodies Corporate 9533876 0 9533876 51.6590 9533876 0 9533876 51.6590 0.0000
Sub Total (A)(1) 9886046 0 9886046 53.5672 9886086 0 9886086 53.5674 0.0002
[2] Foreign
(a) Individuals (Non- 0 0 0 0.0000 0 0 0 0.0000 0.0000
Resident Individuals /
Foreign Individuals)
(b) Government 0 0 0 0.0000 0 0 0 0.0000 0.0000
(c) Institutions 0 0 0 0.0000 0 0 0 0.0000 0.0000
(d) Foreign Portfolio 0 0 0 0.0000 0 0 0 0.0000 0.0000
Investor
(e) Any Other (Specify)
Sub Total (A)(2) 0 0 0 0.0000 0 0 0 0.0000 0.0000
Total Shareholding 9886046 0 9886046 53.5672 9886086 0 9886086 53.5674 0.0002
of Promoter and
Promoter Group(A)=(A)
(1)+(A)(2)
(B) Public Shareholding
[1] Institutions
(a) Mutual Funds / UTI 6500 530 7030 0.0381 6500 530 7030 0.0381 0.0000
(b) Venture Capital Funds 0 0 0 0.0000 0 0 0 0.0000 0.0000
(c) Alternate Investment 0 0 0 0.0000 0 0 0 0.0000 0.0000
Funds
(d) Foreign Venture Capital 0 0 0 0.0000 0 0 0 0.0000 0.0000
Investors
(e) Foreign Portfolio 0 0 0 0.0000 0 0 0 0.0000 0.0000
Investor
(f) Financial Institutions 1875 410 2285 0.0124 1955 410 2365 0.0128 0.0004
/ Banks
(g) Insurance Companies 33570 0 33570 0.1819 33570 0 33570 0.1819 0.0000
(h) Provident Funds/ 0 0 0 0.0000 0 0 0 0.0000 0.0000
Pension Funds
(i) Any Other (Specify)
Foreign Bank 38 0 38 0.0002 38 0 38 0.0002 0.0000
Sub Total (B)(1) 41983 940 42923 0.2326 42063 940 43003 0.2330 0.0004
[2] Central Government/ State Government(s)/ President of India
Sub Total (B)(2) 0 0 0 0.0000 0 0 0 0.0000 0.0000
[3] Non-Institutions
(a) Individuals
(i) Individual shareholders holding nominal share capital upto Rs. 1 lakh. 3909492 835891 4745383 25.7127 3941277 793536 4734813 25.6554 -0.0573
(ii) Individual shareholders holding nominal share capital in excess of Rs. 1 lakh 2109161 0 2109161 11.4284 2094749 0 2094749 11.3503 -0.0781
(b) NBFCs registered with RBI 25280 0 25280 0.1370 0 0 0 0.0000 -0.1370
(d) Overseas Depositories(holding DRs) (balancing figure) 0 0 0 0.0000 0 0 0 0.0000 0.0000
(e) Any Other (Specify)
Trusts 2390 0 2390 0.0130 90 0 90 0.0005 -0.0125
Hindu Undivided Family 249555 0 249555 1.3522 295705 0 295705 1.6023 0.2501
Non Resident Indians 29427 0 29427 0.1594 30573 0 30573 0.1657 0.0063
(Non Repat)
Non Resident Indians 89343 4280 93623 0.5073 108349 4080 112429 0.6092 0.1019
(Repat)
Unclaimed Shares 184745 0 184745 1.0010 184745 0 184745 1.0010 0.0000
Clearing Member 28210 0 28210 0.1529 10768 0 10768 0.0583 -0.0946
Market Maker 2768 0 2768 0.0150 113 0 113 0.0006 -0.0144
Bodies Corporate 1045794 10100 1055894 5.7213 1052511 9820 1062331 5.7562 0.0349
Sub Total (B)(3) 7676165 850271 8526436 46.2002 7718880 807436 8526316 46.1996 -0.0006
Total Public 7718148 851211 8569359 46.4328 7760943 808376 8569319 46.4326 -0.0002
Shareholding(B)=(B)
(1)+(B)(2)+(B)(3)
Total (A)+(B) 17604194 851211 18455405 100.0000 17647029 808376 18455405 100.0000 0.0000
(C) Non Promoter - Non Public
[1] Custodian/DR Holder 0 0 0 0.0000 0 0 0 0.0000 0.0000
[2] Employee Benefit Trust (under SEBI (Share based Employee Benefit) Regulations 2014) 0 0 0 0.0000 0 0 0 0.0000 0.0000
Total (A)+(B)+(C) 17604194 851211 18455405 100.0000 17647029 808376 18455405 100.0000

ii) Shareholding of Promoters:

Sr. N0. Shareholder's Name

Shareholding at the begining of the year - 2019

Shareholding at the End of the year - 2020

% change in the shareholding during the year
No of Shares Held % of the Total of the Company % of shares pledged/ encumbered to total shares No of Shares Held % of total shares of the company % of shares pledged/ encumbered to total shares
1 RAINBOW INVESTMENTS LIMITED 4471438 24.2283 0 4471438 24.2283 0 0
2 INSTANT HOLDINGS LIMITED 1605200 8.6977 0 1605200 8.6977 0 0
3 CARNIWAL INVESTMENTS LTD 1363580 7.3885 0 1363580 7.3885 0 0
4 SWALLOW ASSOCIATES LLP 914097 4.953 0 914097 4.953 0 0
5 SUMMIT SECURITIES LIMITED 878501 4.7601 0 878501 4.7601 0 0
6 CASTOR INVESTMENTS LIMITED 300900 1.6304 0 300900 1.6304 0 0
7 HARSH VARDHAN GOENKA 45000 0.2438 0 0 0 0 -0.2438
8 PRADIP KUMAR KHAITAN 43680 0.2367 0 43680 0.2367 0 0
9 PRADIP KUMAR KHAITAN 43680 0.2367 0 43680 0.2367 0 0
10 PRADIP KUMAR KHAITAN 43680 0.2367 0 43680 0.2367 0 0
11 PRADIP KUMAR KHAITAN 43680 0.2367 0 43680 0.2367 0 0
12 PRADIP KUMAR KHAITAN 43680 0.2367 0 43680 0.2367 0 0
13 PRADIP KUMAR KHAITAN 43680 0.2367 0 43680 0.2367 0 0
14 SANJIV GOENKA 35000 0.1896 0 35000 0.1896 0 0
15 RAMA PRASAD GOENKA 10000 0.0542 0 10000 0.0542 0 0
16 SAREGAMA INDIA LIMITED 100 0.0005 0 100 0.0005 0 0
17 ATLANTUS DWELLINGS AND INFRASTRUCTURE LLP 10 0.0001 0 10 0.0001 0 0
18 CHATTARPATI APARTMENTS LLP 10 0.0001 0 10 0.0001 0 0
19 EKTARA ENTERPRISES LLP 10 0.0001 0 10 0.0001 0 0
20 MALABAR COASTAL HOLDINGS LLP 10 0.0001 0 10 0.0001 0 0
21 SOFREAL MERCANTRADE PVT LTD 10 0.0001 0 10 0.0001 0 0
22 VAYU UDAAN AIRCRAFT LLP 10 0.0001 0 10 0.0001 0 0
23 ANANT VARDHAN GOENKA 10 0.0001 0 10 0.0001 0 0
24 HARSH VARDHAN GOENKA 10 0.0001 0 10 0.0001 0 0
25 HARSH VARDHAN GOENKA 10 0.0001 0 10 0.0001 0 0
26 HARSH VARDHAN GOENKA 10 0.0001 0 10 0.0001 0 0
27 HARSH VARDHAN GOENKA 10 0.0001 0 10 0.0001 0 0
28 HARSH VARDHAN GOENKA 10 0.0001 0 10 0.0001 0 0
29 HARSH VARDHAN GOENKA 10 0.0001 0 10 0.0001 0 0
30 MALA GOENKA 10 0.0001 0 10 0.0001 0 0
31 RADHA ANANT GOENKA 10 0.0001 0 10 0.0001 0 0
32 HARSHVARDHAN RAMPRASAD GOENKA 0 0 0 45000 0.2438 0 0.2438
33 ANANT VARDHAN GOENKA 0 0 0 10 0.0001 0 0.0001
34 HARSH VARDHAN GOENKA 0 0 0 10 0.0001 0 0.0001
35 HARSH VARDHAN GOENKA 0 0 0 10 0.0001 0 0.0001
36 ANANT VARDHAN GOENKA 0 0 0 10 0.0001 0 0.0001
Total 9886046 53.5672 0 9886086 53.5674 0 0.0002

iii) Change in promoters' shareholding :

Sr. No. Name & Type Of Transaction

Shareholding at the beginning of the year - 2019

Transactions During The Year

Cumulative Shareholding at the end of the year - 2020

No. of Shares Held % of total Shares of the Company Date Of Transaction No.of Shares No. of Shares Held % of total Shares of the Company
1 RAINBOW INVESTMENTS LIMITED 4471438 24.2283 4471438 24.2283
AT THE END OF THE YEAR 4471438 24.2283
2 INSTANT HOLDINGS LIMITED 1605200 8.6977 1605200 8.6977
AT THE END OF THE YEAR 1605200 8.6977
3 CARNIWAL INVESTMENTS LTD 1363580 7.3885 1363580 7.3885
AT THE END OF THE YEAR 1363580 7.3885
4 SWALLOW ASSOCIATES LLP 914097 4.9530 914097 4.9530
AT THE END OF THE YEAR 914097 4.9530
5 SUMMIT SECURITIES LIMITED 878501 4.7601 878501 4.7601
AT THE END OF THE YEAR 878501 4.7601
6 CASTOR INVESTMENTS LIMITED 300900 1.6304 300900 1.6304
AT THE END OF THE YEAR 300900 1.6304
7 HARSHVARDHAN RAMPRASAD GOENKA 0 0.0000 0 0.0000
Transfer 06 Mar 2020 45000 45000 0.2438
AT THE END OF THE YEAR 45000 0.2438
8 TRIVIKRAM KHAITAN 43680 0.2367 43680 0.2367
AT THE END OF THE YEAR 43680 0.2367
9 TRIVIKRAM KHAITAN 43680 0.2367 43680 0.2367
AT THE END OF THE YEAR 43680 0.2367
10 TRIVIKRAM KHAITAN 43680 0.2367 43680 0.2367
AT THE END OF THE YEAR 43680 0.2367
11 TRIVIKRAM KHAITAN 43680 0.2367 43680 0.2367
AT THE END OF THE YEAR 43680 0.2367
12 TRIVIKRAM KHAITAN 43680 0.2367 43680 0.2367
AT THE END OF THE YEAR 43680 0.2367
13 TRIVIKRAM KHAITAN 43680 0.2367 43680 0.2367
AT THE END OF THE YEAR 43680 0.2367
14 SANJIV GOENKA 35000 0.1896 35000 0.1896
AT THE END OF THE YEAR 35000 0.1896
15 RAMA PRASAD GOENKA 10000 0.0542 10000 0.0542
AT THE END OF THE YEAR 10000 0.0542
16 SAREGAMA INDIA LIMITED 100 0.0005 100 0.0005
AT THE END OF THE YEAR 100 0.0005
17 RADHA ANANT GOENKA 10 0.0001 10 0.0001
AT THE END OF THE YEAR 10 0.0001
18 HARSH VARDHAN GOENKA 10 0.0001 10 0.0001
AT THE END OF THE YEAR 10 0.0001
19 HARSH VARDHAN GOENKA 0 0.0000 0 0.0000
Transfer 13 Dec 2019 10 10 0.0001
AT THE END OF THE YEAR 10 0.0001
HARSH VARDHAN GOENKA 10 0.0001 10 0.0001
AT THE END OF THE YEAR 10 0.0001
21 HARSH VARDHAN GOENKA 10 0.0001 10 0.0001
AT THE END OF THE YEAR 10 0.0001
22 ANANT VARDHAN GOENKA 0 0.0000 0 0.0000
Transfer 13 Dec 2019 10 10 0.0001
AT THE END OF THE YEAR 10 0.0001
23 HARSH VARDHAN GOENKA 10 0.0001 10 0.0001
AT THE END OF THE YEAR 10 0.0001
24 HARSH VARDHAN GOENKA 0 0.0000 0 0.0000
Transfer 13 Dec 2019 10 10 0.0001
AT THE END OF THE YEAR 10 0.0001
25 MALA GOENKA 10 0.0001 10 0.0001
AT THE END OF THE YEAR 10 0.0001
26 ATLANTUS DWELLINGS AND 10 0.0001 10 0.0001
INFRASTRUCTURE LLP
AT THE END OF THE YEAR 10 0.0001
27 ANANT VARDHAN GOENKA 10 0.0001 10 0.0001
AT THE END OF THE YEAR 10 0.0001
28 ANANT VARDHAN GOENKA 0 0.0000 0 0.0000
Transfer 05 Jul 2019 10 10 0.0001
AT THE END OF THE YEAR 10 0.0001
29 EKTARA ENTERPRISES LLP 10 0.0001 10 0.0001
AT THE END OF THE YEAR 10 0.0001
30 CHATTARPATI APARTMENTS LLP 10 0.0001 10 0.0001
AT THE END OF THE YEAR 10 0.0001
31 VAYU UDAAN AIRCRAFT LLP 10 0.0001 10 0.0001
AT THE END OF THE YEAR 10 0.0001
32 HARSH VARDHAN GOENKA 10 0.0001 10 0.0001
AT THE END OF THE YEAR 10 0.0001
33 HARSH VARDHAN GOENKA 10 0.0001 10 0.0001
AT THE END OF THE YEAR 10 0.0001
34 SOFREAL MERCANTRADE PVT LTD 10 0.0001 10 0.0001
AT THE END OF THE YEAR 10 0.0001
35 MALABAR COASTAL HOLDINGS LLP 10 0.0001 10 0.0001
AT THE END OF THE YEAR 10 0.0001
36 HARSH VARDHAN GOENKA 45000 0.2438 45000 0.2438
Transfer 28 Feb 2020 (45000) 0 0.0000
AT THE END OF THE YEAR 0 0.0000

iv) Share holding pattern of top ten shareholders (other than directors Promoters& Holders of GDRs & ADRs)

Sr. No. Name & Type of Transaction

Shareholding at the beginning of the year - 2019

Transactions during the year

Cumulative Shareholding at the end of the year - 2020 % OF TOTAL SHARES OF THE COMPANY
NO.OF SHARES HELD % OF TOTAL SHARES OF THE COMPANY DATE OF TRANSACTION NO. OF SHARES NO OF SHARES HELD
1 HITESH RAMJI JAVERI 759601 4.1159 759601 4.1159
AT THE END OF THE YEAR 759601 4.1159
2 ROYAL CALCUTTA GOLF CLUB 0 0.0000 0 0.0000
Transfer 25 Oct 2019 272641 272641 1.4773
AT THE END OF THE YEAR 272641 1.4773
3 CHINAPPA MUCKATIRA 46245 0.2506 46245 0.2506
BHEMAIAH
Transfer 30 Aug 2019 200000 246245 1.3343
AT THE END OF THE YEAR 246245 1.3343
4 VLS FINANCE LTD 234583 1.2711 234583 1.2711
Transfer 26 Apr 2019 (400) 234183 1.2689
Transfer 22 Nov 2019 (1000) 233183 1.2635
AT THE END OF THE YEAR 233183 1.2635
5 STEL HOLDINGS LIMITED 184745 1.0010 184745 1.0010
UNCLAIMED SUSPENSE
ACCOUNT
AT THE END OF THE YEAR 184745 1.0010
6 HARSHA HITESH JAVERI 160000 0.8670 160000 0.8670
AT THE END OF THE YEAR 160000 0.8670
7 JAISUKH VINIMOY PVT. LTD. 117205 0.6351 117205 0.6351
Transfer 26 Jul 2019 3840 121045 0.6559
Transfer 13 Sep 2019 464 121509 0.6584
Transfer 20 Sep 2019 (3322) 118187 0.6404
Transfer 30 Sep 2019 6588 124775 0.6761
Transfer 15 Nov 2019 (2557) 122218 0.6622
Transfer 20 Dec 2019 15050 137268 0.7438
Transfer 27 Dec 2019 (950) 136318 0.7386
Transfer 31 Dec 2019 (5929) 130389 0.7065
Transfer 03 Jan 2020 (5179) 125210 0.6784
Transfer 10 Jan 2020 (210) 125000 0.6773
Transfer 06 Mar 2020 4500 129500 0.7017
Transfer 13 Mar 2020 1820 131320 0.7116
AT THE END OF THE YEAR 131320 0.7116
8 BODEPUDI JEEVAN KISHORE 80051 0.4338 80051 0.4338
AT THE END OF THE YEAR 80051 0.4338
9 KONDEPUDI PALLAVI 71700 0.3885 71700 0.3885
AT THE END OF THE YEAR 71700 0.3885
10 PONDURI SUBBARAO 7160 0.0388 7160 0.0388
Transfer 05 Apr 2019 1400 8560 0.0464
Transfer 12 Apr 2019 4434 12994 0.0704
Transfer 19 Apr 2019 608 13602 0.0737
Transfer 26 Apr 2019 14853 28455 0.1542
Transfer 03 May 2019 2900 31355 0.1699
Transfer 10 May 2019 5357 36712 0.1989
Transfer 17 May 2019 258 36970 0.2003
Transfer 24 May 2019 40 37010 0.2005
Transfer 31 May 2019 500 37510 0.2032
Transfer 14 Jun 2019 150 37660 0.2041
Transfer 21 Jun 2019 3338 40998 0.2221
Transfer 29 Jun 2019 2000 42998 0.2330
Transfer 26 Jul 2019 4680 47678 0.2583
Transfer 02 Aug 2019 685 48363 0.2621
Transfer 09 Aug 2019 300 48663 0.2637
Transfer 16 Aug 2019 15 48678 0.2638
Transfer 30 Aug 2019 2599 51277 0.2778
Transfer 20 Sep 2019 (1200) 50077 0.2713
Transfer 18 Oct 2019 1540 51617 0.2797
Transfer 25 Oct 2019 520 52137 0.2825
Transfer 01 Nov 2019 (600) 51537 0.2793
Transfer 08 Nov 2019 (200) 51337 0.2782
Transfer 15 Nov 2019 (1000) 50337 0.2727
Transfer 22 Nov 2019 1000 51337 0.2782
Transfer 29 Nov 2019 480 51817 0.2808
Transfer 06 Dec 2019 6000 57817 0.3133
Transfer 13 Dec 2019 8620 66437 0.3600
Transfer 20 Dec 2019 2001 68438 0.3708
Transfer 17 Jan 2020 (2000) 66438 0.3600
Transfer 24 Jan 2020 (400) 66038 0.3578
Transfer 07 Feb 2020 (1240) 64798 0.3511
Transfer 21 Feb 2020 3000 67798 0.3674
Transfer 28 Feb 2020 (200) 67598 0.3663
Transfer 06 Mar 2020 (200) 67398 0.3652
Transfer 13 Mar 2020 1000 68398 0.3706
Transfer 20 Mar 2020 320 68718 0.3723
Transfer 27 Mar 2020 (200) 68518 0.3713
AT THE END OF THE YEAR 68518 0.3713
11 STANLEY VYAPAAR PVT LIMITED 83600 0.4530 83600 0.4530
Transfer 12 Apr 2019 (86) 83514 0.4525
Transfer 05 Jul 2019 (900) 82614 0.4476
Transfer 06 Mar 2020 (62267) 20347 0.1102
AT THE END OF THE YEAR 20347 0.1102
12 VINEET NAHATA 345274 1.8709 345274 1.8709
Transfer 05 Apr 2019 (4242) 341032 1.8479
Transfer 21 Jun 2019 1500 342532 1.8560
Transfer 29 Jun 2019 (1500) 341032 1.8479
Transfer 02 Aug 2019 5598 346630 1.8782
Transfer 30 Aug 2019 10046 356676 1.9326
Transfer 06 Sep 2019 452 357128 1.9351
Transfer 20 Sep 2019 7618 364746 1.9764
Transfer 27 Sep 2019 9992 374738 2.0305
Transfer 30 Sep 2019 486 375224 2.0331
Transfer 04 Oct 2019 (6400) 368824 1.9985
Transfer 11 Oct 2019 (2232) 366592 1.9864
Transfer 18 Oct 2019 (8000) 358592 1.9430
Transfer 25 Oct 2019 (276566) 82026 0.4445
Transfer 01 Nov 2019 (59525) 22501 0.1219
Transfer 08 Nov 2019 (21160) 1341 0.0073
Transfer 15 Nov 2019 9551 10892 0.0590
AT THE END OF THE YEAR 11002 0.0596
13 RELIANCE FINANCIAL LIMITED 200000 1.0837 200000 1.0837
Transfer 30 Aug 2019 (200000) 0 0.0000
AT THE END OF THE YEAR 0 0.0000

1) Paid up Share Capital of the Company (Face Value Rs. 10.00) at the end of the yearis 18455405 Shares.

2. The details of holding has been clubbed based on PAN.

3. % of total Shares of the Company is based on the paid up Capital of the Company atthe end of the Year. v) Shareholding of Directors and Key Managerial Personnel:

No. Directors and KMP decrease in shareholding

shareholding during the year

No. of shares at beginning 1.4.19 /end of the year 31.3.20 % of total shares of the Company No. of shares % of total shares of the Company
Shareholding of Director:
1 Nil
Shareholding of Key
Managerial Personnel:
1 Mr. Abraham Ittyipe 101 - 01.04.2019 - - 101 -
Manager 101 - 31.03.2020
2 Mr. Sivaramakrishnan - - 01.04.2019 - - - -
Chief Financial Officer - - 31.03.2020
4 Ms. Lakshmi P.S - - 01.04.2019 - - - -
Company Secretary - - 31.03.2020

Note: Apart from above no other Director and Key Managerial Personnel holds anyshares at the beginning and end of the Financial year 2019-20 in the Company.

Further apart from above there was no increase / decrease in shareholding of any otherDirector and Key Managerial Personnel.

V. INDEBTEDNESS

Indebtedness of the Company including interest outstanding/accrued but not due forpayment

(Amount in Rs.)

Indebtedness at the beginning of the financial year - 1.4.19 Secured Loans excluding deposits Unsecured Loans Deposits Total Indebtedness
i) Principal Amount Nil Nil Nil Nil
ii) Interest due but not paid Nil Nil Nil Nil
iii) Interest accrued but not due Nil Nil Nil Nil
Total (i+ii+iii)
Change in Indebtedness during the financial year
* Addition Nil Nil Nil Nil
* Reduction Nil Nil Nil Nil
Net Change Nil Nil Nil Nil
Indebtedness at the end of the financial year 31.3.20
i) Principal Amount Nil Nil Nil Nil
ii) Interest due but not paid Nil Nil Nil Nil
iii) Interest accrued but not due Nil Nil Nil Nil
Total (i+ii+iii) Nil Nil Nil Nil

VI) REMUNERATION OF DIRECTORS AND KEY MANAGERIAL PERSONNEL A. Remuneration to ManagingDirector Whole-timeDirectors and/or Manager:

Sl. No. Particulars of Remuneration Name of the Manager Mr. Abraham Total Amount (Rs.)
1 Gross salary (Amount in Rs.)
a. Salary as per provisions contained in Section 17(1) of the Income- tax Act 1961 120000 120000
b. Value of perquisites u/s 17(2) Income-tax Act 1961* - -
c. Profits in lieu of salary under section 17(3) Income-Tax Act 1961 - -
2 Stock Option - -
3 Sweat Equity - -
4 Commission: - -
- As a % of Profit - -
- Others specify - -
5 Others please specify
Contribution to PF - -
Contribution to Gratuity - -
Contribution to Superannuation Fund - -
Consolidated Allowances - -
Car Perquisite - -
Total (A) 120000 120000
Ceiling as per the Act - (being 5% of the net profit of the Company calculated as per Section 198 of the Companies Act 2013) 7603919 7603919

Note :

*Excludes the value of employee stock options exercised and provision for compensatedabsences/Gratuity in respect of separate actuarial valuation reports for key managerialpersonnel

B. Remuneration to other directors:

Sl. No. Particulars of Remuneration Mr. Anant Goenka Mr. Sunil Bhandari Mr. Umang Kanoria Mr. H.C. Dalal Mr. Prem Kapil Mr. Kaushik Roy Ms. Kusum Dadoo Total
1 Independent Directors
- Fees for attending Board/ - - 34000 39000 37000 - 37000.00
Committee Meetings 147000
- Commission - - - - - - -
- Others - - - - - - -
Total (1) - - 34000 39000 37000 -

37000 147000

2 Other Non- Executive
Directors
- Fees for attending Board/ 5000 34000 - - - 20000 -
Committee Meetings
- Commission - - - - - - -
- Others - - - - - - -
Total (2) 5000 34000 - - - 20000 59000
Total (B) = (1+2) 5000 34000 34000 39000 37000 20000 37000 206000
Total Managerial 326000
Remuneration #
Overall Ceiling as per the 100000 100000 100000 100000 100000 100000 100000
Act @

Notes:

# Total remuneration to Managing Director/Manager Whole-Time Directors and otherDirectors (being the total of A and B).

@ Sitting fees paid have not been considered as a component for reckoning overallceiling as per Companies Act 2013 Overall ceiling as per the Act Rs.100000/-

C. REMUNERATION TO KEY MANAGERIAL PERSONNEL OTHER THAN MD/MANAGER/WTD

(Amount in Rs.)

Particulars of Remuneration

Key Managerial Personnel

Total
Sl. No. Mr. Siva Rama Krishnan Chief Financial Officer Ms. Lakshmi P.S Company Secretary
1 Gross salary
(a) Salary as per provisions contained in section Income-tax Act 196 17(1) of the 240000 462186 702186
(b) Value of perquisites u/s 17(2) Income-tax Act 1961*
(c) Profits in lieu of salary under section 17(3) Income-tax Act 1961
2 Stock Option Nil Nil -
3 Sweat Equity - - -
4 Commission - - -
- As % of profit - - -
- Others specify - - -
5 Others please specify None None -
Total 240000 462186 702186

VII. PENALTIES / PUNISHMENT/ COMPOUNDING OF OFFENCES:

Type Section of the Companies Act Brief Description Details of Penalty / Punishment/ Compounding fees imposed Authority [RD / NCLT / COURT] Appeal made if any (give Details)
A. Company
Penalty NIL NIL NIL NIL NIL
Punishment NIL NIL NIL NIL NIL
Compounding NIL NIL NIL NIL NIL
B. Directors
Penalty NIL NIL NIL NIL NIL
Punishment NIL NIL NIL NIL NIL
Compounding NIL NIL NIL NIL NIL
C. Other Officers in Default
Penalty NIL NIL NIL NIL NIL
Punishment NIL NIL NIL NIL NIL
Compounding NIL NIL NIL NIL NIL
For and on behalf of the board of directors
Mr. H.C Dalal Mr. Sunil Bhandari
(DIN : 00206232) (DIN: 00052161)
Director Director

Place : Kochi

Date : June 25 2020

.