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Sterlite Technologies Ltd.

BSE: 532374 Sector: Engineering
NSE: STRTECH ISIN Code: INE089C01029
BSE 00:00 | 22 Sep 145.70 -3.50
(-2.35%)
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146.70

HIGH

149.90

LOW

140.40

NSE 00:00 | 22 Sep 145.45 -3.80
(-2.55%)
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149.25

HIGH

149.70

LOW

140.55

OPEN 146.70
PREVIOUS CLOSE 149.20
VOLUME 86917
52-Week high 179.95
52-Week low 59.80
P/E 16.08
Mkt Cap.(Rs cr) 5,757
Buy Price 145.70
Buy Qty 10.00
Sell Price 145.70
Sell Qty 799.00
OPEN 146.70
CLOSE 149.20
VOLUME 86917
52-Week high 179.95
52-Week low 59.80
P/E 16.08
Mkt Cap.(Rs cr) 5,757
Buy Price 145.70
Buy Qty 10.00
Sell Price 145.70
Sell Qty 799.00

Sterlite Technologies Ltd. (STRTECH) - Auditors Report

Company auditors report

To the Members of Sterlite Technologies Limited

Report on the audit of the Standalone financial statements

Opinion

1. We have audited the accompanying standalone financial statements ofSterlite Technologies Limited ("the Company") which comprise the Balance Sheetas at March 31 2020 and the Statement of Profit and Loss (including Other ComprehensiveIncome) Statement of Changes in Equity and Statement of Cash Flows for the year thenended and notes to the standalone financial statements including a summary ofsignificant accounting policies and other explanatory information.

2. In our opinion and to the best of our information and according tothe explanations given to us the aforesaid standalone financial statements give theinformation required by the Companies Act 2013 ("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 2020and total comprehensive income (comprising of profit and other comprehensive income)changes in equity and its cash flows for the year then ended.

Basis for opinion

3. We conducted our audit in accordance with the Standards on Auditing(SAs) specified under section 143(10) of the Act. Our responsibilities under thoseStandards are further described in the Auditor's Responsibilities for the Audit ofthe standalone financial statements section of our report. We are independent of theCompany 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

4. We draw attention to Note 46 to the standalone financial statementswhich describes that the Company had recognised Goodwill on amalgamation during

the financial year ended March 31 2016 which is being amortised overa period of five years from the appointed date of September 29 2015 in accordance withthe accounting treatment prescribed under the Scheme of amalgamation approved by theGujarat High Court. Our opinion is not modified in respect of this matter.

5. We draw your attention to Note 43 to the standalone financialstatements which explains the uncertainties and the management's assessment of thefinancial impact on the standalone financial statements of the Company due to thelock-downs and other restrictions imposed by the Government of India and other conditionsrelated to the COVID-19 pandemic situation which might impact the operations of theCompany for which a definitive assessment in the subsequent period is highly dependentupon circumstances as they evolve. Further we have attended physical inventoryverification at locations where it was practicable. For those locations where it wasimpracticable for us to attend the physical verification under the current lockdownrestrictions imposed by the government we have relied on the related alternate auditprocedures to obtain comfort over the existence and condition of inventory at thoselocations. Our opinion is not modified in respect of this matter.

Key audit matters

6. Key audit matters are those matters that in our professionaljudgment were of most significance in our audit of the standalone financial statements ofthe current period. These matters were addressed

in the context of our audit of the standalone financial statements as awhole and in forming our opinion thereon and we do not provide a separate opinion onthese matters.

Key audit matter How our audit addressed the key audit matter
1. Revenue Recognition
(Refer note 2.1(b) 3 and 26 to the Standalone Financial Statements) We performed the following procedures:
The Company recognises revenue in accordance with Ind AS 115 "Revenue from Contracts with Customers". This involves application of significant judgements by Management with respect to: Understood and evaluated the design and tested the operating effectiveness of controls relating to revenue recognition.
In respect of certain large and complex contracts and certain other contracts our procedures included among other things:
• Combination of contracts entered into with the same customer; • Identification of distinct performance obligations;
• Total consideration when the contract involves variable consideration involved; • Reading of selected contracts to identify significant terms of the contracts;
• Allocation of consideration to identified performance obligations; • Assessing appropriateness of management's significant judgements in accounting for identified contracts such as
• Recognition of revenue over a period of time or at a point in time based on timing when control is transferred to customer. For assessment of the date of transfer of control Management has obtained legal opinion in respect of certain arrangements. Further for contracts where revenue is recognised over a period of time the Company makes estimates which impact the revenue recognition. Such estimates include but are not limited to: identification of performance obligation and allocation of consideration to identified performance obligation;
• Evaluation of the contract terms and also consideration of the legal opinion obtained by Management with respect to assessment of the date of transfer of control;
• Testing of timing of recognition of revenue (including procedures related to cut off) in line with the terms of contracts;
• costs to complete
• contract risks
• price variation claims
• liquidated damages
Further in determining the above estimates for ongoing contracts
• Testing the appropriateness of key assumptions used by Management including the appropriateness and reasonability of Management's conclusion regarding the expected delays in estimated completion of the performance obligations and possible impact on key estimates. Reading of the related contract terms and communications with the customers to assess the likelihood of availability of contractual remedies.
Management has also evaluated the estimates especially those resulting from expected delays in the completion of the performance obligations and available contractual remedies. • Testing of journal entries for unusual/irregular revenue transactions; and • Evaluating adequacy of presentation and disclosures.
We focused on this area because a significant portion of the revenue generated requires management to exercise judgement and therefore could be subject to material misstatement due to fraud or error. Based on above procedures we did not note any significant exceptions in the estimates and judgements applied by the Management in revenue recognition including those relating to presentation and disclosures as required by the applicable accounting standard.
2. First time adoption of Ind AS - 116 ‘Leases'
(Refer note 2.1(i) 3 and 52 to the standalone financial statements) Our audit procedures included the following:
Effective April 12019 Ind AS 116 Leases has replaced Ind AS 17 "Leases". Obtain an understanding of the process followed by the management and testing of the design and operating effectiveness of key controls around accounting for leases.
The Company has applied the standard retrospectively and has chosen to recognise the cumulative effect of initially applying this Standard as an adjustment to the opening balance of retained earnings. • Obtain understanding of the Company's implementation process including evaluating of the Company policy and election of exemptions in accordance with Ind AS 116
To assess the impact of initial application of Ind AS 116 Management • Evaluating the underlying lease contracts to verify the accuracy of the underlying data for a representative sample of leases.
has applied judgements and estimates with respect to: • Assessing the completeness of identified leases by reviewing key
• Identifying if a contract is or contains lease. service and supply contracts to assess whether they contain a lease under Ind AS 116.
• Segregation of lease and non-lease components where applicable.
• Assessment of the lease term considering the renewal and termination options in the contract and other factors eg leasehold improvements intention to continue etc. • Assessing the appropriateness of the assumptions used in determination of lease terms and interest rate used by the Management for determining lease liability.
• Determine the interest rate implicit in the lease. • Testing of the mathematical accuracy by recalculating the amount of Lease Liabilities and Right of Use asset for a sample of lease contracts.
We considered the first time application of the standard as a key audit matter due to the material impact of the same on the financial statements and the significance of the judgements and estimates used by the Management. Further implementation process requires extraction and processing of extensive data which required significant audit efforts to test the completeness and adequacy of such information.
• Assessing whether the disclosures in the financial statements are appropriate and are in line with the requirements of Ind AS 116. Based on the above procedures we did not note any significant exceptions in the estimates and judgements applied by the management in recording right of use asset and lease liability in accordance with Ind AS 116 and related presentation and disclosure requirements

Other Information

7. The Company's Board of Directors is responsible for the otherinformation. The other information comprises the information included in theDirector's report but does not include the standalone financial statements and ourauditor's report thereon.

Our opinion on the standalone financial statements does not cover theother information and we do not express any form of assurance conclusion thereon.

In connection with our audit of the standalone financia statements ourresponsibility is to read the other information and in doing so consider whether theother information is materially inconsistent with the standalone financial statements orour knowledge obtained in the audit or otherwise appears to be materially misstated. Ifbased on the work we have performed we conclude that there is a material misstatement ofthis other information we are required to report that fact. We have nothing to report inthis regard.

Responsibilities of management and those charged with governance forthe standalone financial statements

8. The Company's Board of Directors is responsible for the mattersstated in section 134(5) of the Act with respect to the preparation of these standalonefinancial statements that give a true and fair view of th < financial positionfinancial performance changes in equity and cash flows of the Company in accordance withthe accounting principles generally accepted in India including the Accounting Standardsspecified under section 133 of the Act. 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 design implementation andmaintenance of adequate internal financial controls that were operating effectively forensuring the accuracy and completeness of the accounting records relevant to thepreparation and presentation of the standalone financial statements that give a true andfair view and are free from materia misstatement whether due to fraud or error.

9. In preparing the standalone financial statements management isresponsible 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. Those Board of Directors arealso responsible for overseeing the Company's financial reporting process.

Auditor's responsibilities for the audit of the standalonefinancial statements

10. Our objectives are to obtain reasonable assurance about whether thestandalone financial statements as a whole are free from material misstatement whetherdue to fraud or error and to issue an auditor's report that includes our opinion.Reasonable assurance is a high level of assurance but is not a guarantee that an auditconducted in accordance with SAs will always detect a material misstatement when itexists. Misstatements can arise from fraud or error and are considered material ifindividually or in the aggregate they could reasonably be expected to influence theeconomic decisions of users taken on the basis of these standalone financial statements.

11. As part of an audit in accordance with SAs we exerciseprofessional judgment and maintain professional scepticism throughout the audit. We also:

• Identify and assess the risks of material misstatement of thestandalone financial statements whether due to fraud or error design and perform auditprocedures responsive to those risks and obtain audit evidence that is sufficient andappropriate to provide a basis for our opinion. The risk of not detecting a materialmisstatement resulting from fraud is higher than for one resulting from error as fraudmay involve collusion forgery intentional omissions misrepresentations or the overrideof internal control.

• Obtain an understanding of internal control relevant to theaudit in order to design audit procedures that are appropriate in the circumstances. UnderSection 143(3)(i) of the Act we are also responsible for expressing our opinion onwhether the company has adequate internal financial controls with reference to standalonefinancial statements in place and the operating effectiveness of such controls.

• Evaluate the appropriateness of accounting policies used and thereasonableness of accounting estimates and related disclosures made by management.

• Conclude on the appropriateness of management's use of thegoing concern basis of accounting and based on the audit evidence obtained whether amaterial uncertainty exists related to events or conditions that may cast significantdoubt on the Company's ability to continue as a going concern. If we conclude that amaterial uncertainty exists we are required to draw attention in our auditor'sreport to the related disclosures in the standalone financial statements or if suchdisclosures are inadequate to modify our opinion. Our conclusions are based on the auditevidence obtained up to the date of our auditor's report. However future events orconditions may cause the Company to cease to continue as a going concern.

• Evaluate the overall presentation structure and content of thestandalone financial statements including the disclosures and whether the standalonefinancial statements represent the underlying transactions and events in a manner thatachieves fair presentation.

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

13. We also provide those charged with governance with a statement thatwe have 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.

14. From the matters communicated with those charged with governancewe determine those matters that were of most significance in the audit of the standalonefinancial statements of the current year and are therefore the key audit matters. Wedescribe these matters in our auditor's report unless law or regulation precludespublic disclosure about the matter or when in extremely rare circumstances we determinethat a matter should not be communicated in our report because the adverse consequences ofdoing so would reasonably be expected to outweigh the public interest benefits of suchcommunication.

Report on other legal and regulatory requirements

15. As required by the Companies (Auditor's Report) Order 2016("the Order") issued by the Central Government of India in terms of sub-section(11) of section 143 of the Act we give in the Annexure B a statement on the mattersspecified in paragraphs 3 and 4 of the Order to the extent applicable.

16. As required by Section 143(3) of the Act we report that:

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

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

(c) The Balance Sheet the Statement of Profit and Loss (includingother comprehensive income) the Statement of Changes in Equity and Cash Flow Statementdealt with by this Report are in agreement with the books of account.

(d) In our opinion the aforesaid standalone financial statementscomply with the Accounting Standards specified under Section 133 of the Act.

(e) On the basis of the written representations received from thedirectors as on March 31 2020 taken on record by the Board of Directors none of thedirectors is disqualified as on March 31 2020 from being appointed as a director in termsof Section 164 (2) of the Act.

(f) With respect to the adequacy of the internal financial controlswith reference to standalone financial statements of the Company and the operatingeffectiveness of such controls refer to our separate Report in "Annexure A".

(g) With respect to the other matters to be included in theAuditor's Report in accordance with Rule 11 of the Companies (Audit and Auditors)Rules 2014 in our opinion and to the best of our information and according to theexplanations given to us:

i. The Company has disclosed the impact of pending litigations on itsfinancial position in its standalone financial statements

- Refer Note 22 39 and 44 to the financial statements;

ii. The Company has made provision as required under the applicablelaw

or accounting standards for material foreseeable losses if any onlong-term contracts including derivative contracts - Refer Note 20 to the standalonefinancial statements;

iii. There has been no delay in transferring amounts required to betransferred to the Investor Education and Protection Fund by the Company.

iv. The reporting on disclosures relating to Specified Bank Notes isnot applicable to the Company for the year ended March 31 2020.

17. The Company has paid/ provided for managerial remuneration inaccordance with the requisite approvals mandated by the provisions of Section 197 readwith Schedule V to the Act.

For Price Waterhouse Chartered Accountants LLP
Firm Registration Number: 012754N/N500016 Neeraj Sharma
Partner
Membership Number: 108391
UDIN: 20108391AAAACZ7325
Place: Pune
Date: May 12 2020

Annexure A to Independent Auditors' Report

Referred to in paragraph 16(f) of the Independent Auditors' Reportof even date to the members of Sterlite Technologies Limited on the standalone financialstatements for the year ended March 312020

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

1. We have audited the internal financial controls with reference tostandalone financial statements of Sterlite Technologies Limited ("the Company")as of March 31 2020 in conjunction with our audit of the standalone financial statementsof the Company for the year ended on that date.

Management's Responsibility for Internal Financial Controls

2. The Company's management is responsible for establishing andmaintaining internal financial controls based on the internal control over financialreporting criteria established by the Company considering the essential components ofinternal control stated in the Guidance Note on Audit of Internal Financial Controls OverFinancial Reporting issued by the Institute of Chartered Accountants of India (ICAI).These responsibilities include the design implementation and maintenance of adequateinternal financial controls that were operating effectively for ensuring the orderly andefficient conduct of its business including adherence to company's policies thesafeguarding of its assets the prevention and detection of frauds and errors theaccuracy and completeness of the accounting records and the timely preparation ofreliable financial information as required under the Act.

Auditor's Responsibility

3. Our responsibility is to express an opinion on the Company'sinternal financial controls with reference to standalone financial statements based on ouraudit. We conducted our audit in accordance with the Guidance Note on Audit of InternalFinancial Controls Over Financial Reporting (the "Guidance Note") and theStandards on Auditing deemed to be prescribed under section 143(10) of the Act to theextent applicable to an audit of internal financial controls both applicable to an auditof internal financial controls and both issued by the ICAI. Those Standards and theGuidance Note require that we comply with ethical requirements and plan and perform theaudit to obtain reasonable assurance about whether adequate internal financial controlswith reference to standalone financial statements was established and maintained and ifsuch controls operated effectively in all material respects.

4. Our audit involves performing procedures to obtain audit evidenceabout the adequacy of the internal financial controls system with reference to standalonefinancial statements and their operating effectiveness.

Our audit of internal financial controls with reference to standalonefinancial statements included obtaining an understanding of internal financial controlswith reference to standalone financial statements assessing the risk that a materialweakness exists and testing and evaluating the design and operating effectiveness ofinternal control based on the assessed risk. The procedures selected depend on theauditor's judgement including the assessment of the risks of material misstatementof the standalone financial statements whether due to fraud or error.

5. We believe that the audit evidence we have obtained is sufficientand appropriate to provide a basis for our audit opinion on the Company's internalfinancial controls system with reference to standalone financial statements.

Meaning of Internal Financial Controls with reference to standalonefinancial statements

6. A company's internal financial controls with reference tostandalone financial statements is a process designed to provide reasonable assuranceregarding the reliability of financial reporting and the preparation of standalonefinancial statements for external purposes in accordance with generally acceptedaccounting principles. A company's internal financial controls with reference tostandalone financial statements includes those policies and procedures that (1) pertain tothe maintenance of records that in reasonable detail accurately and fairly reflect thetransactions and dispositions of the assets of the company; (2) provide reasonableassurance that transactions are recorded as necessary to permit preparation of standalonefinancial statements in accordance with generally accepted accounting principles and thatreceipts and expenditures of the company are being made only in accordance withauthorisations of management and directors of the company; and (3) provide reasonableassurance regarding prevention or timely detection of unauthorised acquisition use ordisposition of the company's assets that could have a material effect on thestandalone financial statements.

Inherent Limitations of Internal Financial Controls with reference tostandalone financial statements

7. Because of the inherent limitations of internal financial controlswith reference to standalone financial statements including the possibility of collusionor improper management override of controls material misstatements due to error or fraudmay occur and not be detected. Also projections of any evaluation of the internalfinancial controls with reference to standalone financial statements to future periods aresubject to the risk that the internal financial control with reference to standalonefinancial statements may become inadequate because of changes in conditions or that thedegree of compliance with the policies or procedures may deteriorate.

Opinion

8. In our opinion the Company has in all material

respects an adequate internal financial controls system with referenceto standalone financial statements and such internal financial controls with reference tostandalone financial statements were operating effectively as at March 31 2020 based onthe internal control over financial reporting criteria established by the Companyconsidering the essential components of internal control stated in the Guidance Note onAudit of Internal Financial Controls Over Financial Reporting issued by the Institute ofChartered Accountants of India. (Also refer paragraph 5 of the main standalone auditreport).

For Price Waterhouse Chartered Accountants LLP
Firm Registration Number: 012754N/N500016
Neeraj Sharma
Partner
Membership Number: 108391
UDIN: 20108391AAAACZ7325
Place: Pune
Date: May 12 2020

Annexure B to Independent Auditors' Report

Referred to in paragraph 15 of the Independent Auditors' Report ofeven date to the members of Sterlite Technologies Limited on the standalone financialstatements as of and for the year ended March 31 2020

i. (a) The Company is maintaining proper records showing fullparticulars including quantitative details and situation of fixed assets.

(b) The fixed assets are physically verified by the Managementaccording to a phased programme designed to cover all the items over a period of threeyears which in our opinion is reasonable having regard to the size of the Company andthe nature of its assets. Pursuant to the programme

a portion of the fixed assets has been physically verified by theManagement during the previous year and no material discrepancies have been noticed onsuch verification. Further the physical verification of cables is impractical due themanne in which they have been installed/laid.

(c) The title deeds of immovable properties as disclosed in Note 4 onfixed assets to the standalone financial statements are held in the name of the Company.

ii. The physical verification of inventory excluding stocks with thirdparties have been conducted at reasonable intervals by the Management during the year. Inrespect of inventory lying with third parties these have substantially been confirmed bythem.

The discrepancies noticed on physical verification of inventory ascompared to book records were not material and have been appropriately dealt with in thebooks of accounts.

iii. The Company has not granted any loans secured or unsecured tocompanies firms Limited Liability Partnerships or other parties covered in the registermaintained under Section 189 of the Act. Therefore the provisions of Clause 3(iii)(iii)(a) (iii)(b) and (iii)(c) of the said Order are not applicable to the Company.

iv. In our opinion and according to the information and explanationsgiven to us the Company has complied with the provisions of Section 185 and 186 of theCompanies Act 2013 in respect of the loans and investments made and guarantees andsecurity provided by it.

v. The Company has not accepted any deposits from the public within themeaning of Sections 73 74 75 and 76 of the Act and the Rules framed there under to theextent notified.

vi. Pursuant to the rules made by the Central Government of India theCompany is required to maintain cost records as specified under Section 148(1) of the Actin respect of manufacture of copper cables. We have broadly reviewed the same and are ofthe opinion that prima facie the prescribed accounts and records have been made andmaintained. We have not however made a detailed examination of the records with a viewto determine whether they are accurate or complete.

vii. (a) According to the information and explanations given to us andthe records of the Company examined by us in our opinion the Company is generallyregular in depositing the undisputed statutory dues in respect of income tax goods andservice tax labour welfare fund and professional tax though there has been a slightdelay in few cases and is regular in depositing undisputed statutory dues includingprovident fund employees' state insurance duty of customs cess and other materialstatutory dues as applicable with the appropriate authorities.

(b) According to the information and explanations given to us and therecords of the Company examined by us there are no dues of Central Sales Tax ServiceTax Goods and Service Tax which have not been deposited on account of any dispute. Theparticulars of dues of income tax sales tax duty of customs and duty of excise as atMarch 31 2020 which have not been deposited on account of a dispute are as follows:

Name of the statute Nature of Dues Amount ' Cr Period to which the amount relates Forum where the dispute is pending
Central Excise Act 1944 Excise Duty 18.50 2014-17 Commissioner Central Excise Goods & Services Tax Aurangabad
Customs Act 1962 Customs Duty 67.82 2001-03 CESTAT Mumbai
Customs Duty 1.61 2013-14 The commissioner of Customs (appeals)
Income tax act 1961 Income Tax 3.88 AY 2013-14 AY 2015-16 Commissioner (Appeals) - Mumbai
Income Tax 1.27 AY 2001-02 AY 2002-03 Mumbai High Court
Income Tax 0.57 AY 2011-12 AY 2013-14 AY 2014-15 AY 2015-16 Commissioner (Appeals) - Ahmedabad
Income Tax 0.53 AY 2012-13 Gujarat High Court
Income Tax 0.12 AY 2009-10 AY 2010-11 Income Tax Appellate Tribunal - Ahmedabad

viii. According to the records of the Company examined by us and theinformation and explanation given to us the Company has not defaulted in repayment ofloans or borrowings to any financial institution or bank or Government or dues todebenture holders as at the balance sheet date. As stated in Note 39 to the standalonefinancial statements the Company continues to dispute amounts aggregating Rs 18.87 croresclaimed by a bank in the earlier years towards import consignments under letter of creditnot accepted by the Company owing to discrepancies in documents. Since the matter is indispute we are unable to determine whether there is a default in repayment of dues to thesaid bank.

ix. In our opinion and according to the information and explanationsgiven to us the moneys raised by way of term loans (including debt instruments) have beenapplied for the purposes for which they were obtained. The Company has not raised anymoneys by way of initial public offer or further public offer.

x. During the course of our examination of the books and records of theCompany carried out in accordance with the generally accepted auditing practices inIndia and according to the information and explanations given to us we have neither comeacross any instance of material fraud by the Company or on the Company by its officers oremployees noticed or reported during the year nor have we been informed of any such caseby the Management.

xi. The Company has paid/ provided for managerial remuneration inaccordance with the requisite approvals mandated by the provisions of Section 197 readwith Schedule V to the Act.

Also refer paragraph 17 of our standalone audit report.

xii. As the Company is not a Nidhi Company and the Nidhi Rules 2014are not applicable to it the provisions of Clause 3(xii) of the Order are not applicableto the Company.

xiii. The Company has entered into transactions with related parties incompliance with the provisions of Sections 177 and 188 of the Act. The details of suchrelated party transactions have been disclosed in the financial statements as requiredunder Indian Accounting Standard (Ind AS) 24 Related Party Disclosures specified underSection 133 of the Act.

xiv. The Company has not made any preferential allotment or privateplacement of shares or fully or partly convertible debentures during the year underreview. Accordingly the provisions of Clause 3(xiv) of the Order are not applicable tothe Company.

xv. The Company has not entered into any non-cash transactions with itsdirectors or persons connected with him. Accordingly the provisions of Clause 3(xv) ofthe Order are not applicable to the Company.

xvi. The Company is not required to be registered under Section 45-IAof the Reserve Bank of India Act 1934. Accordingly the provisions of Clause 3(xvi) ofthe Order are not applicable to the Company.

For Price Waterhouse Chartered Accountants LLP
Firm Registration Number: 012754N/N500016
Neeraj Sharma
Partner
Membership Number: 108391
UDIN: 20108391AAAACZ7325
Place: Pune
Date: May 12 2020

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