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Trigyn Technologies Ltd.

BSE: 517562 Sector: IT
NSE: TRIGYN ISIN Code: INE948A01012
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VOLUME 2327
52-Week high 218.60
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P/E 300.91
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OPEN 100.05
CLOSE 100.10
VOLUME 2327
52-Week high 218.60
52-Week low 86.65
P/E 300.91
Mkt Cap.(Rs cr) 306
Buy Price 98.95
Buy Qty 1.00
Sell Price 99.40
Sell Qty 319.00

Trigyn Technologies Ltd. (TRIGYN) - Auditors Report

Company auditors report

To the members of Trigyn Technologies Limited

Report on the Standalone Indian Accounting Standard ("Ind AS") FinancialStatements for the year ended 31st March 2021

OPINION

We have audited the standalone financial statements of Trigyn Technologies Limited ("theCompany") which comprise the Balance Sheet as at 31 March 2021 and the Statement ofProfit and Loss (including other comprehensive income) Statement of Changes in Equity andStatement of Cash Flows for the year then ended and notes to the standalone financialstatements including a summary of significant accounting policies and other explanatoryinformation (hereinafter referred to as "the standalone 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 ("the Act") in the manner so required and give a trueand fair view in conformity with the accounting principles generally accepted in India ofthe state of affairs of the Company as at 31 March 2021 and profit (including othercomprehensive income) changes in equity and its cash flows for the year ended on thatdate.

BASIS FOR OPINION

We conducted our audit in accordance with the Standards on Auditing (SAs) specifiedunder Section 143(10) of the Act. Our responsibilities under those SAs are furtherdescribed in the Auditor’s Responsibilities for the Audit of the Standalone FinancialStatements section of our report. We are independent of the Company in accordance with theCode of Ethics issued by the Institute of Chartered Accountants of India together with theethical requirements that are relevant to our audit of the standalone financial statementsunder the provisions of the Act and the Rules thereunder and we have fulfilled our otherethical responsibilities in accordance with these requirements and the Code of Ethics. Webelieve that the audit evidence we have obtained is sufficient and appropriate to providea basis for our opinion.

KEY AUDIT MATTERS

Key audit matters (‘KAM’) 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 thestandalone financial statements as a whole and in forming our opinion thereon and we donot provide a separate opinion on these matters.

Sr. No. Key Audit Matter Auditor’s Response
1 Accounting for fixed price contracts :
In respect of Andhra Pradesh State Fibernet Limited We have examined the status report provided to us by the management of the company from time to time.
(APSFL) Project which was a fixed price contract awarded through tendering process where over 90% work has been completed by March 2021 there has been undue delay in completion of the balance work as APSFL is yet to provide the sites for balance classrooms and Central Studio. Also civil works which is the responsibility of APSFL is pending at 2 district studios. APSFL has not given go live certificate which is one of the conditions under the contract. As per the terms of the contract the company has raised 3 milestone bills. The total amount outstanding against this project as at 31.03.2021 amounted to Rs. 61.55 Crores which is outstanding for more than 365 days. As of the date of the reporting work has not commenced for completion of the remaining portion of the contract and there is uncertainty regarding expected completion of the balance work and collection of dues. The management has adopted a cautious approach towards booking of Quarterly Guaranteed Revenue (QGR) amounting to Rs. 53.36 Crores including GST on account of uncertainty of collection. (Refer note No. 51A). We have also been provided with certain correspondence which the company’s project team has had with APSFL in respect of balance work and recovery of dues which indicates the company’s preparedness to execute the balance work and the lack of response from APSFL.
It is observed that there have been considerable delays in getting the invoices approved by the authorities at APSFL and there has been collection of only Rs. 2.45 Crores during the year.
Under IND AS-115 one of the conditions to recognize revenue is the probability that the entity will collect the consideration due under the contract. The company has obtained opinion from subject matter expert in support of their stand towards non booking of Quarterly Guaranteed Revenue (QGR). We have relied on the expert’s opinion in this regard.
We have also relied on company’s representation for non-consideration of the outstanding dues as doubtful of recovery (only provision is made for expected credit loss) as the outstanding is from a Government entity.
2 Disputed Tax Matters Procedures performed by the Auditor :
a) In respect of contingent liability of Rs. 985.14 lakhs on account of Revenue filing an appeal before the Honorable Bombay High Court for the quantum and penalty for Assessment Year 2007-08 (Refer Note No. No. For tax matters our procedures included examining the company’s tax consultants views and discussions with Company’s legal counsel assessing management’s conclusions;
x b) In respect of interest levied by the income tax department amounting to Rs. 1.56 Crores for Assessment Year 2003-04 appearing on the Income Tax website (Refer Note No. 34 - Contingent Liabilities) We also involved our internal tax specialists to gain an understanding and to determine the chances of verdict favouring the company.
This being a technical matter we have relied upon the company’s decision for non-provision of interest.
3 Disputed GST demand Procedures performed by the Auditor:
Andhra Government had initiated departmental audit u/s. 73 of the GST Act in respect of the company’s Andhra Pradesh branch. The department has raised a demand for Rs. 3.20 crores including interest and penalty for FY 2017-18 and FY 2018-19. For GST matters our procedures included examining the company’s GST consultants views and discussions with Company’s legal counsel; assessing management’s conclusions;
In this regard the company is in the process of filing an appeal. We also involved our internal GST specialists to gain an understanding and to determine the chances of verdict favouring the company.
(Refer to Note No.- 58) This being a technical matter we have relied upon the company’s decision for non provision of liability as it is disputed by the company.
4 Litiaation Matters
In respect of legal cases filed by the company and against the company as at 31st March 2021 (Refer Note No. 34 a to g) We have assessed the management’s position through discussions and correspondence with the in-house legal expert on both the probability of success in the aforesaid cases and the magnitude of any potential loss.
We have discussed with the management on the development in these litigations during the year ended 31st March 2021.
Reviewed the disclosures made by the Company in the financial statements in this regard.
5 Expected Credit Loss
The company makes use of a simplified approach for trade and other receivables as well as contract assets and records the loss allowance as lifetime expected credit losses. These are the expected shortfalls in contractual cash flows considering the potential for default at any point during the life of the financial instrument. The company has appointed an external consultant who has evaluated the historical experience and forward looking information to calculate the expected credit losses using a provision matrix.
In calculating the company uses its historical experience external indicators and forward-looking information to calculate the expected credit losses using a provision matrix. We have test checked the working provided by the external consultant including development of the methodology for the allowance for credit losses.
Provisioning for Expected Credit Loss on doubtful assets during the year amounted to Rs. 347.18 lakhs (net) under the head "Other Expenses." (Refer to Note no.- 55) We have checked the completeness and accuracy of information used in the estimation of probability of default and the computation of the allowance for credit losses.
We identified allowance for credit losses as a key audit matter because the Company exercises significant judgment in calculating the expected credit losses which appears to be reasonable.

Other Information

The Company’s management and Board of Directors are responsible for the otherinformation. The other information comprises the information included in theCompany’s annual report but does not include the standalone financial statements andour auditors’ report thereon. Our opinion on the standalone financial statements doesnot cover the other information and we do not express any form of assurance conclusionthereon. In connection with our audit of the standalone financial 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.

Management's Responsibility for the Standalone Financial Statements

The Company's management and Board of Directors are responsible for the matters statedin Section 134(5) of the Act with respect to the preparation of these standalone financialstatements that give a true and fair view of the state of affairs profit / loss(including other comprehensive income) changes in equity and cash flows of the Company inaccordance with the accounting principles generally accepted in India including theIndian Accounting Standards (Ind AS) specified under Section 133 of the Act. Thisresponsibility also includes maintenance of adequate accounting records in accordance withthe provisions of the Act for safeguarding of the assets of the Company and for preventingand detecting frauds and other irregularities; selection and application of appropriateaccounting policies; making judgments and estimates that are reasonable and prudent; anddesign implementation and maintenance of adequate internal financial controls that wereoperating effectively for ensuring the accuracy and completeness of the accountingrecords relevant to the preparation and presentation of the standalone financialstatements that give a true and fair view and are free from material misstatement whetherdue to fraud or error. In preparing the standalone financial statements management andBoard of Directors are responsible for assessing the Company’s ability to continue asa going concern disclosing as applicable matters related to going concern and using thegoing concern basis of accounting unless management either intends to liquidate theCompany or to cease operations or has no realistic alternative but to do so. Board ofDirectors is also responsible for overseeing the Company’s financial reportingprocess.

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. Reasonableassurance is a high level of assurance but is not a guarantee that an audit conducted inaccordance with SAs will always detect a material misstatement when it exists.Misstatements can arise from fraud or error and are considered material if individuallyor in the aggregate they could reasonably be expected to influence the economic decisionsof users taken on the basis of these standalone financial statements

As part of an audit in accordance with SAs we exercise professional judgment andmaintain professional scepticism 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 procedures that are appropriate in the circumstances. Under Section 143(3)(i)of the Act we are also responsible for expressing our opinion on whether the company hasadequate internal financial controls with reference to standalone financial statements inplace and the operating effectiveness of such controls.

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

• Conclude on the appropriateness of management’s use of the going concernbasis of accounting and based on the audit evidence obtained whether a materialuncertainty exists related to events or conditions that may cast significant doubt on theCompany’s ability to continue as a going concern. If we conclude that a materialuncertainty exists we are required to draw attention in our auditor’s report to therelated disclosures in the standalone financial statements or if such disclosures areinadequate to modify our opinion. Our conclusions are based on the audit evidenceobtained up to the date of our auditors' report. However future events or conditions maycause the Company to cease to continue as a going concern.

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

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 auditors’ report unless law or regulation precludes public disclosure aboutthe matter or when in extremely rare circumstances we determine that a matter should notbe communicated in our report because the adverse consequences of doing so wouldreasonably be expected to outweigh the public interest benefits of such communication.

Emphasis of matter

We draw attention to

1. Note No - 47 of the financial statements with respect to necessary approval andpermissions from RBI under FEMA regulations and carrying forward of balances in respect ofwound up overseas subsidiaries and step down overseas subsidiaries. These balances whichare fully provided for have no bearing on profitability nor on the assets and liabilitiesposition of the company (as fully explained in the notes).

2. Note No - 51 A) of the financial statements in respect of Andhra Pradesh StateFibernet Ltd. project which is fully explained in the Notes. The company has obtainedindependent expert’s opinion to validate their stand. We have relied on theindependent expert’s opinion.

3. Note No - 34 (a) to (g) of the financial statements regarding pending legal suitsfiled by the company and against the company and its wholly own subsidiary as fullyexplained in the Notes."

4. Note No - 55 of the financial statements regarding provision for Expected CreditLoss on doubtful assets as fully explained in the Notes.

5. Note No - 58 of the financial statements in respect of departmental audit initiatedby GST department of Andhra Pradesh Government u/s. 73 of the GST Act for TrigynTechnologies Ltd. Andhra Pradesh Branch as fully explained in the Notes.

Our opinion is not qualified in the above matter.

Report on Other Legal and Regulatory Requirements

1. As required by the Companies (Auditors’ Report) Order 2016 ("theOrder") issued by the Central Government of India in terms of Section 143(11) of theAct we give in "Annexure A" a statement on the matters specified in paragraphs3 and 4 of the Order to the extent applicable.

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

(a) We have sought and obtained all the information and explanations which to the bestof our knowledge and belief were necessary for the purposes of our audit.

(b) In our opinion proper books of account as required by law have been kept by theCompany so far as it appears from our examination of those books.

(c) The Balance Sheet the Statement of Profit and Loss (including other comprehensiveincome) the Statement of Changes in Equity and the Statement of Cash Flows dealt with bythis Report are in agreement with the books of account.

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

(e) On the basis of the written representations received from the directors as on 31March 2021 taken on record by the Board of Directors none of the directors isdisqualified as on 31 March 2021 from being appointed as a director in terms of Section164(2) of the Act.

(f) With respect to the adequacy of the internal financial controls with reference tofinancial statements of the Company and the operating effectiveness of such controlsrefer to our separate Report in "Annexure B".

(g) The entire statutory audit of the company has been carried out based on remoteaccess of the data as provided by the company due to COVID -19 pandemic across India. Werelied on alternative audit procedures as per the Standards on Auditing prescribed by theInstitute of Chartered Accountants of India (ICAI). As a result of the above the audithas been carried out based on the data provided for our audit purposes which we relied ascorrect complete and are directly generated by the accounting system of the companywithout any further manual modifications. The financial performance of the unit has beenthus prepared and presented by the company and audited by us in the aforesaid conditions.

(B) With respect to the other matters to be included in the Auditors’ Report inaccordance with Rule 11 of the Companies (Audit and Auditors) Rules 2014 in our opinionand to the best of our information and according to the explanations given to us:

i. The Company has disclosed the impact of pending litigations as at 31stMarch 2021 on its financial position in its standalone IND AS financial statements matters(Refer Note 34 (a) to (g) of the standalone financial statements);

ii. As represented by the Company there are no long-term contracts includingderivative contracts for which there were any material foreseeable losses - (Refer Note 60to the standalone financial statements);

iii. There were no amounts which were required to be transferred to the InvestorEducation and Protection Fund by the Group (Refer Note No. 61 to the standalone financialstatements).

(C) With respect to the matter to be included in the Auditors’ Report undersection 197(16):

I n our opinion and according to the information and explanations given to us theremuneration paid by the company to its directors during the current year is in accordancewith the provisions of Section 197 of the Act. The remuneration paid to any director 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) which arerequired to be commented upon by us.

For FORD RHODES PARKS & CO.LLP
Chartered Accountants
ICAI FR No. - 102860W/W100089
A.D.Shenoy
Partner
Place: Mumbai Membership No. - 011549
Date: May 12 2021 UDIN: 21011549AAAADG9840

Annexure A to the Independent Auditors' Report

[Referred to in paragraph pertaining to "Report on Other Legal and RegulatoryRequirement" of our Report of even date to the members of Trigyn Technologies Limitedon the standalone Ind AS financial statements for the year ended 31st March2021]

i. a) The company is maintaining proper records showing full particulars includingquantitative details and situation of fixed assets.

b) We are informed that fixed assets could not be physically verified by the managementduring the year due to Covid-19 pandemic.

c) The title deeds of immovable properties are held in the earlier name of company viz.Leading Edge Systems Limited and process to change to present name is still in progress.

ii. The Company’s inventory comprises of traded hardware and software.

Inventories have been physically verified by the management at reasonable intervals andno material discrepancies were noticed on such verification.

iii. The Company has granted unsecured loans to companies firms or other partiescovered in the register maintained under Section 189 of the Companies Act 2013. Theseloans are interest free and there are no stipulations as to repayment of the loan. In ouropinion and according to the information and explanation given to us the terms andconditions of the loans given by the company are prima facie not prejudicial to theinterest of the company for the reasons fully explained in Note No.40.

iv. In our opinion and according to information and explanation given to us thecompany has complied with the provision of Section 185 and 186 of the Companies Act withrespect of providing or granting of loans making investments and providing guarantees andsecurities.

v. The company has not accepted deposits from public within the meaning of Sections 73to 76 or any other relevant provisions of the Companies Act 2013.

vi. The Central Government has not prescribed maintenance of cost records under section(1) of Section 148 of the act in respect of any of company’s products oractivitiesas such clause vi of the order is not applicable to the company.

a) According to the information and explanation given to us and records of the companyexamined by us in our opinion the Company is regular in depositing undisputed statutorydues including Provident Fund employee state insurance income tax sales tax valueadded tax service tax custom duty excise duty cess and any other statutory dues withthe appropriate authorities. There are no undisputed statutory dues payable for a periodof more than six month from the date they become payable as at 31st March 2021.

a. According to the information and explanations given to us and the records of theCompany examined by us there are no dues of wealth tax service tax customs duty andcess as at 31st March 2021 which has not been deposited on account of dispute except theIncome tax dues which are disputed /pending rectification and not paid are as under:

Sr. No Period to which the amount relates Name of the statute Nature of dues Amount (Rs.) Forum where the dispute is pending
1 A.Y. 2003-04 Income Tax Act 1961 Interest on Income Tax demand 15635806 The company is in the process of filing rectification online
2 A.Y. 2007-08 Income Tax Act 1961 Income Tax demand 98513683 Bombay High court
3 A.Y. 2011-12 Income Tax Act 1961 Income Tax demand 200000 CIT (Appeal)
4 A.Y. 2012-13 Income Tax Act 1961 Income Tax demand 300000 Rectification filed against Claims for adjustment of carry forward losses
5 A.Y. 2014-15 Income Tax Act 1961 Income Tax demand 22040 The Company is in process of filing rectification
6 A.Y. 2015-16 Income Tax Act 1961 Income Tax demand 898480 Assistant CIT / CPC Rectification u/s 154
7 A.Y. 2017-18 Income Tax Act 1961 Income Tax demand 2146500 CPC Rectification u/s 154
8 A.Y. 2018-19 Income Tax Act 1961 Income Tax demand 789200 ITO- Summary Assessment u/s 143(1)
9 A.Y. 2019-20 Income Tax Act 1961 Income Tax demand 45466430 Asst. Director of Income Tax CPC
10 Various Years Income Tax Act 1961 TDS 119534 ITO TDS - Rectification filed/ to be filed.
11 F.Y. 2017-18 & 2018-19 GST Act GST demand 32021554 In the process of filing an appeal

vii. The Company has not raised any fund by way of debentures or through bankfinancial institution or Government. Hence Clause viii of the Order is not applicable.

viii. The Company has not raised any Initial Public Offer or further public offerduring the year. The company has obtained term Loan under Hire purchase arrangement andthe same was applied for the purpose for which they were raised.

ix. Based upon the audit procedures performed and information and explanations given bythe management we report that we have not come across any instances of fraud by thecompany or any material fraud on the company by its officers or employees that have beennoticed or reported during the year nor have we been informed of such case by management.

x. According to information and explanations given to us and on the basis of ourexamination of records of the company the managerial remuneration for the year ended 31stMarch 2021 has been paid or provided in accordance with the requisite approvals mandatedby the provisions of section 197 read with schedule V to Companies Act 2013 and rulesframed thereunder.

xi. The Company is not a Chit Fund Company/or nidhi/ mutual benefit fund/society. Assuch Clause xii of the order is not applicable to the Company.

xii. All transactions with related parties are in compliance with Sections 177 and 188of Companies Act 2013 where applicable and the details have been disclosed in theStandalone Ind AS financial Statement as required by the applicable Accounting Standards.

xiii. The Company has not made any preferential allotment or private placement ofshares or fully or partly convertible debentures during the year. As such Clause xiv ofthe order is not applicable to the Company.

xiv. The Company has not entered into non-cash transactions covered by Section 192 ofCompanies Act 2013 with directors or persons connected with them.

xv. The Company is not engaged in the business of non-banking financial institution(NBFI) and not required to obtain a Certificate of Registration (CoR) from Reserve Bank ofIndia in terms of Section 45-IA of the RBI Act 1934.

For FORD RHODES PARKS & CO.LLP
Chartered Accountants
ICAI Firm R No. 102860W/W100089
A.D. Shenoy
Place: Mumbai Partner
Date: May 12 2021 Membership No.011549
UDIN: 21011549AAAADG9840

Annexure B to the Independent Auditors' Report

[Referred to in paragraph pertaining to "Report on Other Legal and RegulatoryRequirement" of our Report of even date to the Members of Trigyn Technologies Limitedon the Standalone Ind AS financial statements for the year ended 31st March2021]

Report on the Internal Financial Controls under Clause (i) of Sub-section 3 of Section143 of the Companies Act 2013 ("the Act")

We have audited the internal financial controls over financial reporting of TrigynTechnologies Limited ("the Company") as of March 312021 in conjunction withour audit of the Standalone IND AS financial statements of the Company for the year endedon that date.

Management's Responsibility for Internal Financial Controls

The Company’s management is responsible for establishing and maintaining internalfinancial controls based on the internal control over financial reporting criteriaestablished by the Company considering the essential components of internal control statedin the Guidance Note on Audit of Internal Financial Controls over Financial Reporting (IFCOFR)issued by the Institute of Chartered Accountants of India. These responsibilities includethe design implementation and maintenance of adequate internal financial controls thatwere operating effectively for ensuring the orderly and efficient conduct of its businessincluding adherence to 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 Companies Act 2013.

Auditors' Responsibility

Our responsibility is to express an opinion on the Company's internal financialcontrols over Financial reporting based on our audit. We conducted our audit in accordancewith the Guidance Note on Audit of Internal Financial Controls Over Financial Reporting(the "Guidance Note") and the Standards on Auditing issued by ICAI and deemedto be prescribed under section 143(10) of the Companies Act 2013 to the extentapplicable to an audit of internal financial controls both applicable to an audit ofInternal Financial Controls and both issued by the Institute of Chartered Accountants ofIndia. Those Standards and the Guidance Note require that we comply with ethicalrequirements and plan and perform the audit to obtain reasonable assurance about whetheradequate internal financial controls over financial reporting was established andmaintained and if such controls operated effectively in all material respects.

Our audit involves performing procedures to obtain audit evidence about the adequacy ofthe internal financial controls system over financial reporting and their operatingeffectiveness.

Our audit of internal financial controls over financial reporting included obtaining anunderstanding of internal financial controls over financial reporting assessing the riskthat a material weakness exists and testing and evaluating the design and operatingeffectiveness of internal control based on the assessed risk. The procedures selecteddepend on the auditor’s judgments including the assessment of the risks of materialmisstatement of the financial statements whether due to fraud or error.

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

Meaning of Internal Financial Controls Over Financial Reporting

A company's internal financial control over financial reporting is a process designedto provide reasonable assurance regarding the reliability of financial reporting and thepreparation of financial statements for external purposes in accordance with generallyaccepted accounting principles. A company's internal financial control over financialreporting includes those policies and procedures that (1) pertain to the maintenance ofrecords that in reasonable detail accurately and fairly reflect the transactions anddispositions of the assets of the company; (2) provide reasonable assurance thattransactions are recorded as necessary to permit preparation of financial statements inaccordance with generally accepted accounting principles and that receipts andexpenditures of the company are being made only in accordance with authorisations ofmanagement and directors of the company; and (3) provide reasonable assurance regardingprevention or timely detection of unauthorised acquisition use or disposition of thecompany's assets that could have a material effect on the financial statements.

Inherent Limitations of Internal Financial Controls over Financial Reporting

Because of the inherent limitations of internal financial controls over financialreporting including the possibility of collusion or improper management override ofcontrols material misstatements due to error or fraud may occur and not be detected.Also projections of any evaluation of the internal financial controls over financialreporting to future periods are subject to the risk that the internal financial controlover financial reporting may become inadequate because of changes in conditions or thatthe degree of compliance with the policies or procedures may deteriorate.

Opinion

In our opinion to the best of our information and according to explanation given to usthe Company has in all material respects an adequate internal financial controls systemover financial reporting and such internal financial controls over financial reportingwere operating effectively as at March 312021 based on the internal control overfinancial reporting criteria established by the Company considering the essentialcomponents of internal control stated in the Guidance Note on Audit of Internal FinancialControls Over Financial Reporting issued by the Institute of Chartered Accountants ofIndia. Based on our suggestion and with a view to adopt best practices the company is inthe process of updating an internal control manual.

For FORD RHODES PARKS & CO.LLP
Chartered Accountants
ICAI FR No. 102860W/W100089
A.D.Shenoy
Partner
Place: Mumbai Membership No.-011549
Date: May 12 2021 UDIN: 21011549AAAADG9840

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