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Transpek Industry Ltd.

BSE: 506687 Sector: Industrials
NSE: TRANSPEK ISIN Code: INE687A01016
BSE 00:00 | 08 Aug 1998.80 101.25
(5.34%)
OPEN

1941.00

HIGH

2010.00

LOW

1875.05

NSE 05:30 | 01 Jan Transpek Industry Ltd
OPEN 1941.00
PREVIOUS CLOSE 1897.55
VOLUME 4822
52-Week high 2695.00
52-Week low 1329.95
P/E 17.07
Mkt Cap.(Rs cr) 1,117
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00
OPEN 1941.00
CLOSE 1897.55
VOLUME 4822
52-Week high 2695.00
52-Week low 1329.95
P/E 17.07
Mkt Cap.(Rs cr) 1,117
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

Transpek Industry Ltd. (TRANSPEK) - Auditors Report

Company auditors report

To the Members of Transpek Industry Limited

Report on the Audit of the Standalone Financial Statements

Opinion

We have audited the accompanying standalone financial statements of TranspekIndustry Limited ("the Company") which comprise the Balance Sheet as atMarch 31 2021 the Statement of Profit and Loss (including Other Comprehensive Income)the Statement of Changes in Equity the Statement of Cash Flows for the year then endedand notes to the Standalone Financial Statements including a summary of the significantaccounting policies and other explanatory information (hereinafter referred to as ''thestandalone financial statements").

In our opinion and to the best of our information and according to the explanationsgiven to us the aforesaid standalone financial statements give the information requiredby the Companies Act 2013 as amended ("the Act") in the manner so required andgive a true and fair view in conformity with the Indian Accounting Standards prescribedunder Section 133 of the Act read with the Companies (Indian Accounting Standards) Rules2015 as amended ("Ind AS") and other accounting principles generally acceptedin India of the state of affairs of the Company as at March 31 2021 its profit andtotal comprehensive income the changes in equity and its cash flows for the year ended onthat date.

Basis for Opinion

We conducted our audit of the standalone financial statements in accordance with theStandards on Auditing specified under Section 143(10) of the Act (SAs). Ourresponsibilities under those Standards are further described in the "Auditor'sResponsibilities for the Audit of the Standalone Financial Statements" section of ourreport. We are independent of the Company in accordance with the "Code ofEthics" issued by the Institute of Chartered Accountants of India ("ICAI")together with the ethical requirements that are relevant to our audit of the standalonefinancial statements under the provisions of the Act and the Rules thereunder and wehave fulfilled our other ethical responsibilities in accordance with these requirementsand the Code of Ethics. We believe that the audit evidence we have obtained is sufficientand appropriate to provide a basis for our audit opinion on the standalone financialstatements.

Key Audit Matters

Key audit matters are those matters that in our professional judgement were of mostsignificance in our audit of the standalone financial statements of the current period.These matters were addressed in the context of our audit of the standalone financialstatements as a whole for the year ended March 31 2021 and in forming our opinionthereon and we do not provide a separate opinion on these matters. We have determined thematters described below to be the key audit matters to be communicated in our report:

Key Audit Matter How the matter was addressed in our audit
Adoption of Ind AS 116 Leases
Our audit procedures included among others the following :
Ind AS 116 as adopted by the Company from the financial year 2019-20 introduces a new lease accounting model wherein lessees are required to recognise a Right-of-Use Asset and a Lease Liability arising from a lease on the balance sheet. • Assessed and tested processes and controls in respect of lease accounting and modification thereof;
The lease liabilities are initially measured by discounting future lease payments during the lease term as per the contract/ arrangement. • Assessed the Company's evaluation on the identification of modification of leases based on the changes in contractual agreements;
Reduction in lease rentals and hire off of ISO tanks during the year has resulted in change in consideration of leases that is a lease modification. Considering the materiality of lease modification this matter is considered as a key audit matter. • Assessed changes in key terms and conditions on sample basis of each lease with the underlying lease contract and evaluated re-computation of Lease Liabilities and Right-of-Use Assets in terms of the requirements of lease modifications under
[Refer Note 2.1(R) and Note 42 to the standalone financial statements]. Ind AS 116 and its effect on standalone financial statements.
Evaluation of uncertain tax positions and litigations
The Company has uncertain tax matters pending litigations under direct tax and various indirect tax laws. Our audit procedures included among others the following :
The litigation involves significant judgement to determine the possible outcome based on which accounting treatment is given to the disputed amount. • Obtained from the management details of all completed/pending tax assessments and other litigations;
These matters are considered to be key audit matter given the magnitude of potential outflow of economic resources and uncertainty of potential outcome. • Gained the understanding of the status of pending tax demands and potential liability for other pending litigations;
[Refer Note 37 to the standalone financial statements]. • Read and analysed relevant communication with the authorities;
• Considered the legal advice obtained by the management for determining the possible outcome of the litigation;
• Discussed with senior management and evaluated management's assumptions regarding provisions made;
• Assessed the disclosures in accordance with the requirements of Ind AS 37 on "Provisions Contingent Liabilities and Contingent Assets".
Transactions with Related Parties
The Company in its course of operations has entered into transactions with related parties. The identification of these related parties transactions entered into with them and the determination of arm's length price involves significant judgement and estimates. Our audit procedures included among others the following :
Considering the volume of transactions and materiality of the amounts this matter is considered to be key audit matter. • Evaluated and tested the design of internal controls and the secretarial process followed relating to identification of related parties and transactions with these parties;
[Refer Note 44 to the standalone financial statements]. • Confirmed the regulatory requirements for the identification of related parties and transactions with these related parties the determination of arm's length pricing and the disclosures for the same in the standalone financial statements;
• Evaluated management judgments and assumptions regarding transactions with Related Parties at Arm's Length Price;
• Reviewed sample agreements/contracts to compare the terms of the related parties' transaction to those of identical or similar transaction with one or more unrelated parties and evaluated the business rationale for the same;
• Assessed whether the disclosures for Related Party Transactions are in accordance with Ind AS 24.

Information Other than the Standalone Financial Statements and Auditor's Report Thereon

The Company's Board of Directors is responsible for the other information. The otherinformation comprises the information included in the Board's Report including Annexuresto Board's Report Management Discussion and Analysis Corporate Governance andShareholder's Information but does not include the standalone financial statements andour auditor's 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 our audit of the standalone financial statements our responsibilityis to read the other information and in doing so consider whether the other informationis materially inconsistent with the standalone financial statements or our knowledgeobtained during the course of our audit or otherwise appears to be materially misstated.

If based on the work we have performed we conclude that there is a materialmisstatement of this other information we are required to report that fact. We havenothing to report in this regard.

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 Act with respect to the preparation and presentation of these standalonefinancial statements that give a true and fair view of the financial position financialperformance (including other comprehensive income) changes in equity and cash flows ofthe Company in accordance with the accounting principles generally accepted in Indiaincluding the Ind AS specified under Section 133 of the Act read with the Companies(Indian Accounting Standards) Rules 2015 as amended.

This responsibility also includes maintenance of adequate accounting records inaccordance with the provisions of the Act for safeguarding the assets of the Company andfor preventing and detecting frauds and other irregularities; selection and application ofappropriate accounting policies; making judgements and estimates that are reasonable andprudent; and the design implementation and maintenance of adequate internal financialcontrols that were operating effectively for ensuring the accuracy and completeness ofthe accounting records relevant to the preparation and presentation of the standalonefinancial statements that give a true and fair view and are free from materialmisstatement whether due to fraud or error.

In preparing the standalone financial statements the Board of Directors is responsiblefor assessing the Company's ability to continue as a going concern disclosing asapplicable matters related to going concern and using the g oi ng concern basis ofaccounting unless the management either intends to liquidate the Company or to ceaseoperations or has no realistic alternative but to do so.

The Board of Directors is also responsible for overseeing the Company's financialreporting process.

Auditor's Responsibilities 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 standalone financial statements.

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

• Identify and assess the risks of material misstatement of the standalonefinancial statements whether due to fraud or error design and perform audit proceduresresponsive to those risks and obtain audit evidence that is sufficient and appropriate toprovide a basis for our opinion. The risk of not detecting a material misstatementresulting from fraud is higher than for one resulting from error as fraud may involvecollusion forgery intentional omissions misrepresentations or the override of internalcontrol.

• Obtain an understanding of internal control relevant to the audit in order todesign audit p ro c e d u re s t h a t a re a p p ro p ri a te i n t h e circumstances.Under Section 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 financial st a t e m e n t s i n p l a c e a n d t h e o p e ra t i n g effectiveness of suchcontrols.

• Evaluate the appropriateness of accounting po l i ci e s u se d a n d th e re aso n a bl e n ess of accounting estimates and related disclosures made by management.

• Conclude on the appropriateness of management's use of the going concern basisof accounting and based on the audit evidence obtained whether a 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 ourauditor's report. However future events or conditions may cause the Company to cease tocontinue as a going concern.

• Evaluate the overall presentation structure and content of the standalonefinancial statements including the disclosures and whether the standalone financialstatements represent the underlying transactions and events in a manner that achieves fairpresentation.

Materiality is the magnitude of misstatements in the standalone financial statementsthat individually or in aggregate makes it probable that the economic decisions of areasonably knowledgeable user of the standalone financial statements may be influenced. We

consider quantitative materiality and qualitative factors in (i) planning the scope ofour audit work and in evaluating the results of our work; and (ii) to evaluate the effectof any identified misstatements in the standalone financial statements.

We communicate with those charged with governance regarding among other matters theplanned scope and timing of the audit and significant audit findings including anysignificant deficiencies in internal control that we identify during our audit.

We also provide those charged with governance with a statement that we have compliedwith relevant ethical requirements regarding independence and to communicate with themall relationships and other matters that may reasonably be thought to bear on ourindependence and where applicable related safeguards.

From the matters communicated with those charged with governance we determine thosematters that were of most significance in the audit of the standalone financial statementsof the current period and are therefore the key audit matters. We describe these mattersin our auditor's report unless law or regulation precludes public disclosure about thematter or when in extremely rare circumstances we determine that a matter should not becommunicated in our report because the adverse consequences of doing so would reasonablybe expected to outweigh the public interest benefits of such communication.

Other Matter

The comparative financial information of the Company for the year ended March 31 2020included in these standalone financial statements are based on the previously issuedfinancial statements and financial i n form a ti o n prepa red i n a cco rd a n ce wi thth e Companies (Indian Accounting Standards) Rules 2015 and other accounting principlesgenerally accepted in India and audited by the predecessor auditors who expressed anunmodified opinion by their report of June 24 2020.

Our opinion on the standalone financial statements and our report on Other Legal andRegulatory Requirements below is not modified in respect of the above matter.

Report on Other Legal and Regulatory Requirements

1. 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 purpose 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 the Statement of Cash Flows and notes to thestandalone financial statements dealt with by this Report are in agreement with the booksof account;

d. In our opinion the aforesaid standalone financial statements comply with the Ind ASspecified under Section 133 of the Act read with the Companies (Indian AccountingStandards) Rules 2015 as amended;

e. On the basis of written representations received from the directors as on March 312021 taken on record by the Board of Directors none of the directors is disqualified ason March 31 2021 from being appointed as a director in terms of Section 164(2) of theAct;

f. With respect to the internal financial controls with reference to financialstatements of the Company and the operating effectiveness of such controls refer to ourseparate report in "Annexure A";

g. With respect to the matters to be included in the Auditor's Report in accordancewith requirement of Section 197(16) of the Act as amended

In our opinion and to the best of our information and according to the explanationsgiven to us the remuneration paid during the current year by the Company to its directorsis in accordance with the provisions of Section 197 read with Schedule V of the Act and isnot in excess of the limit laid down under Section 197 of the Act. The Ministry ofCorporate Affairs has not prescribed other details under Section 197(16) of the Act whichare required to be commented upon by us.

h. With respect to the other matters to be included in the Auditor's Report inaccordance with Rule 11 of the Companies (Audit and Auditors) Rules 2014 as amended inour opinion and to the best of our information and according to the explanations given tous:

i. The Company has disclosed the impact of pending litigations on its financialposition in its standalone financial statements - Refer Note 37 to the standalonefinancial statements;

ii. The Company did not have any long term contracts including derivative contracts forwhich there were any material foreseeable losses as required under the applicable law oraccounting standards;

iii. There has been no delay in transferring amounts required to be transferred to theInvestor Education and Protection Fund by the Company during the year ended March 312021.

2. As required by the Companies (Auditor's Report) Order 2016 ("the Order")issued by the Central Government of India in terms of Section 143(11) of the Act weenclose in the "Annexure B" a statement on the matters specified in paragraphs3 and 4 of the Order to the extent applicable.

For BANSI S. MEHTA & CO.
Chartered Accountants
Firm Registration No. 100991W
PARESH H. CLERK
Partner
PLACE : Mumbai Membership No. 36148
DATED : May 25 2021 UDIN : 21036148AAAABX2941

ANNEXURE A TO THE INDEPENDENT AUDITORS' REPORT

Referred to in paragraph 1 (f) under the heading of "Report on Other Legal andRegulatory Requirements" in our Independent Auditor's Report of even date on theStandalone Financial Statements for the year ended March 312021.

Report on the Internal Financial Controls with reference to Financial Statements underClause (i) of Sub-section 3 of Section 143 of the Companies Act 2013 ("theAct")

We have audited the internal financial controls with reference to standalone financialstatements of Transpek Industry Limited ("the Company") as of

March 31 2021 in conjunction with our audit of the standalone financial statements ofthe Company for the year ended on that date.

Management's Responsibility for Internal Financial Controls

The Company's Board of Directors is responsible for establishing and maintaininginternal financial controls based on the internal financial controls with reference tofinancial statements criteria established by the Company considering the essentialcomponents of internal control stated in the Guidance Note on Audit of Internal FinancialControls Over Financial Reporting ("the Guidance Note") issued by the Instituteof Chartered Accountants of India ("ICAI"). These responsibilities include thedesign implementation and maintenance of adequate internal financial controls that wereoperating effectively for ensuring the orderly and efficient conduct of its businessincluding adherence to the Company's policies the safeguarding of its assets theprevention and detection of frauds and errors the accuracy and completeness of theaccounting records and the timely preparation of reliable financial information asrequired under the Act.

Auditor's Responsibility

Our responsibility is to express an opinion on the Company's internal financialcontrols with reference to financial statements based on our audit. We conducted our auditin accordance with the Guidance Note and the Standards on Auditing issued by ICAI anddeemed to be prescribed under Section 143(10) of the Act to the extent applicable to anaudit of internal financial controls with reference to financial statements. ThoseStandards and the Guidance Note require that we comply with ethical requirements and planand perform the audit to obtain reasonable assurance about whether adequate internalfinancial controls with reference to financial statements were established and maintainedand 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 with reference to financial statements and their operatingeffectiveness. Our audit of internal financial controls with reference to financialstatements included obtaining an understanding of internal financial controls withreference to financial statements assessing the risk that a material weakness exists andtesting and evaluating the design and operating effectiveness of internal control based onthe assessed risk. The procedures selected depend on the auditor's judgement includingthe assessment of the risks of material misstatement of the standalone financialstatements 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 withreference to financial statements.

Meaning of Internal Financial Controls with reference to Financial Statements

A company's internal financial control with reference to financial statements is aprocess designed to provide reasonable assurance regarding the reliability of financialreporting and the preparation of financial statements for external purposes in accordancewith generally accepted accounting principles. A company's internal financial controlswith reference to financial statements includes those policies and procedures that

a. pertain to the maintenance of records that in reasonable detail accurately andfairly reflect the transactions and dispositions of the assets of the company;

b. provide reasonable assurance that transactions are recorded as necessary to permitpreparation of the financial statements in accordance with generally accepted accountingprinciples and that receipts and expenditures of the company are being made only inaccordance with authorisations of management and directors of the company; and

c. provide reasonable assurance regarding prevention or timely detection ofunauthorised acquisition use or disposition of the company's assets that could have amaterial effect on the financial statements.

Inherent Limitations of Internal Financial Controls with reference to FinancialStatements

Because of the inherent limitations of internal financial controls with reference tofinancial statements including the possibility of collusion or improper managementoverride of controls material misstatements due to error or fraud may occur and not bedetected. Also projections of any evaluation of the internal financial controls withreference to financial statements to future periods are subject to the risk that theinternal financial controls with reference to financial statements may become inadequatebecause of changes in conditions or that the degree of compliance with the policies orprocedures may deteriorate.

Opinion

In our opinion to the best of our information and according to the explanations givento us the Company has in all material respects an adequate internal financial controlswith reference to the standalone financial statements and such internal financial controlswith reference to standalone financial statements were operating effectively as at March31 2021 based on the internal controls over financial reporting criteria established bythe Company considering the essential components of internal control stated in theGuidance Note.

For BANSI S. MEHTA & CO.
Chartered Accountants
Firm Registration No. 100991W
PARESH H. CLERK
Partner
PLACE : Mumbai Membership No. 36148
DATED : May 25 2021 UDIN : 21036148AAAABX2941

ANNEXURE B TO THE INDEPENDENT AUDITORS' REPORT

Referred to in paragraph 2 under the heading of "Report on Other Legal andRegulatory Requirements" of our Independent Auditors' Report of even date on theStandalone Financial Statements for the year ended March 312021.

Report on the Companies (Auditor's Report) Order 2016 issued in terms of Section143(11) of the Companies Act 2013 ("the Act") of Transpek Industry Limited("the Company"):

i. a. The Company has maintained proper records showing full particulars includingquantitative details and situation of Property Plant and Equipment ("PPE").

b. PPE have been physically verified by the m a n a g e m en t a cco rd i n g to a ph ase d programme designed to cover all the PPE over a period of three years which in ouropinion provides for physical verification of all the items of PPE at reasonableintervals. The discrepancies reported on such verification are not material and have beenproperly dealt with in the books of account.

c. According to the information and explanations given to us and on the basis of ourexamination of the records of the Company the title deeds of immovable properties asincluded in Note 3 to the standalone financial statements are held in the name of theCompany.

ii. Inventories have been physically verified by the management during the year. In ouropinion the frequency of verification is reasonable. The discrepancies noticed onverification between physical stock and book records were not material in relation to theoperations of the Company and the same have been properly dealt with in the books ofaccount.

iii. According to the information and explanations given to us the Company has notgranted any loans secured or unsecured to companies firms limited liability partnershipor any other parties covered in the register maintained under section 189 of the CompaniesAct 2013. Therefore reporting requirements as per provisions of Clause 3(a) 3(b) and3(c) of the Order are not applicable to the Company.

iv. In our opinion and according to the information and explanations given to us theCompany has complied with the provisions of Sections 185 and 186 of the Act with respectto the loans and investments made. The Company has not given any guarantee or provided anysecurity in connection with a loan to any person or other body corporate and accordinglythe question of commenting on compliance with the provisions in respect thereof does notarise.

v. In our opinion and according to the information and explanations given to us theCompany has complied with directives issued by Reserve Bank of India and the provision ofSections 73 to 76 or any other relevant provisions of the Act and the Companies(Acceptance and Deposits) Rules 2014 as amended with regard to deposit accepted fromthe public. According to the information and explanations given to us no order has beenpassed by the Company Law Board or National Company Law Tribunal or Reserve Bank of Indiaor any Court or any other Tribunal.

vi. We have broadly reviewed the books of account and records maintained by the Companypursuant to the Companies (Cost Records and Audit) Rules 2014 as specified by the CentralGovernment for maintenance of cost records under Section 148(1) of the Act in respect ofthe products manufactured by the Company and are of the opinion that prima facie theprescribed accounts and records have been made and maintained. However we have not made adetailed examination of the said accounts and records with a view to determine whetherthey are accurate or complete.

vii. a. According to the information and explanations given to us and on the basis ofthe books and records examined by us the Company has been regular in depositing u n d i spu ted s ta tu to ry d u es i n cl u d i n g Provident Fund Income-tax Goods and ServiceTax Duty of Customs Employees' State Insurance Cess and other material statutory duesas applicable to it with the appropriate authorities. There are no arrears of outstandingstatutory dues on the last day of the financial year for a period of more than six monthsfrom the date they become payable.

b. According to the information and explanations given to us and on the basis of thebooks and records of the Company examined by us as may be applicable given herein beloware the details of dues of Income-tax Goods and Service Tax Sales-tax Duty of CustomsDuty of Excise Value Added Tax which have not been deposited on account of disputes andthe forum where the dispute is pending:

Sr. No. Name of Statute Nature of the dues Amount (Rs. in lakhs) Period to which the Amount Relates Forum where dispute is pending
1. Central Excise Act 1944 Excise Duty (including penalty) 26.06 *(1.50) 2006 to 2012 CESTAT Ahmedabad
2. Service Tax Service Tax (including penalty) 121.52 *(4.56) 2015 to 2017 Commissioner (Appeals) Vadodara
3. Service Tax Service Tax (including penalty) 167.86 *(7.08) 2013 to 2015 CESTAT Ahmedabad
4. Service Tax Service Tax (including penalty) 259.81 *(22.16) 2013 to 2017 Commissioner Vadodara
5. Central Excise Act 1944 Excise Duty (including penalty) 30.57 *(4.93) 2007 to 2014 CESTAT Mumbai

* indicates amount deposited or paid under dispute.

viii. According to the information and explanations given to us as also on the basisof the books and records examined by us the Company has not defaulted in repayment ofdues to financial institutions or banks. The Company has not taken any loan or borrowingfrom Government and has not issued any debenture during the year.

ix. According to the information and explanations given to us and on the basis of thebooks and records examined by us the Company has not raised any money by way of initialpublic offer or further public offer (including debt instruments) during the year.Accordingly paragraph 3 (ix) of the Order in respect thereof is not applicable. Moneysraised by way of term loans were applied for the purposes for which those are raised.

x. During the course of our examination of the books of account and records of theCompany carried out in accordance with the generally accepted auditing practices in Indiaand according to the information and explanations given to us we have neither come acrossany incidence of fraud on or by the Company noticed or reported during the year nor wehave been informed of any such case by the management.

xi. According to the information and explanations given to us and based on ourexamination of the records of the Company the Company has paid/provided for managerialremuneration during the financial year 2020-21 in accordance with the requisite approvalsmandated by the provisions of Section 197 read with Schedule V to the Act.

xii. The Company is not a Nidhi Company. Accordingly paragraph 3(xii) of the Order isnot applicable to the Company.

xiii. According to the information and explanations given to us and based on ourexamination of the records of the Company transactions with the related parties are incompliance with Sections 177 and 188 of the Act where applicable and the details of suchtransactions have been disclosed in the standalone financial statements as required by theapplicable accounting standards.

xiv. According to the information and explanations given to us and on the basis of thebooks and records examined by us the Company has not made any preferential allotment orprivate placement of shares or fully or partly convertible debentures during the year.Accordingly reporting under paragraph 3(xiv) of the Order is not applicable.

xv. According to the information and explanations given to us and on the basis of thebooks and records examined by us the Company has not entered into non-cash transactionswith directors or persons connected with him. Accordingly paragraph 3(xv) of the Order isnot applicable.

xvi. According to the information and explanations given to us and on the basis of thebooks and records examined by us the Company is not required to be registered underSection 45-IA of the Reserve Bank of India Act 1934. Accordingly paragraph 3(xvi) of theOrder is not applicable to the Company.

For BANSI S. MEHTA & CO.
Chartered Accountants
Firm Registration No. 100991W
PARESH H. CLERK
Partner
PLACE : Mumbai Membership No. 36148
DATED : May 25 2021 UDIN : 21036148AAAABX2941

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