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Tulsyan NEC Ltd.

BSE: 513629 Sector: Metals & Mining
NSE: TULSYAN ISIN Code: INE463D01016
BSE 00:00 | 04 Mar Tulsyan NEC Ltd
NSE 05:30 | 01 Jan Tulsyan NEC Ltd
OPEN 15.75
PREVIOUS CLOSE 15.75
VOLUME 100
52-Week high 15.75
52-Week low 0.00
P/E
Mkt Cap.(Rs cr) 24
Buy Price 15.75
Buy Qty 100.00
Sell Price 0.00
Sell Qty 0.00
OPEN 15.75
CLOSE 15.75
VOLUME 100
52-Week high 15.75
52-Week low 0.00
P/E
Mkt Cap.(Rs cr) 24
Buy Price 15.75
Buy Qty 100.00
Sell Price 0.00
Sell Qty 0.00

Tulsyan NEC Ltd. (TULSYAN) - Auditors Report

Company auditors report

To

The Members TULSYAN NEC LIMITED Chennai

Report on the Audit of the Standalone Ind AS Financial Statements

Opinion

We have audited the accompanying standalone Ind AS financial statements of TULSYAN NECLIMITED ("the Company") which comprise the Balance Sheet as at 31 March 2020the Statement of Profit and Loss (including Other Comprehensive Income) the Statement ofChanges in Equity and the Statement of Cash Flows for the year then ended and a summaryof the significant accounting policies and other explanatory information.

In our opinion and to the best of our information and according to the explanationsgiven to us except for the effects of the matter described in the Basis for QualifiedOpinion section of our report 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 Indian Accounting Standardsprescribed under section 133 of the Act read with the Companies (Indian AccountingStandards) Rules 2015 as amended("Ind AS") and other accounting principlesgenerally accepted in India of the state of affairs of the Company as at March 31 2020and loss (changes in equity) and its cash flows for the year ended on that date.

Basis for Qualified Opinion

We draw attention to the fact that the Company is continuously incurring losses and itsnet worth is totally eroded on 31.03.2020. During the Financial year 2015-16 the Company'sloans and liabilities were restructured under the corporate debt Restructuring Scheme. Asper the scheme the company's repayment obligations were restructured. The Banks alsoprovided certain reliefs/waivers/sacrifices by reducing the rate of interest. Interest wasprovided in the books at the lowered rates of interest. However the bankers had withdrawnthe concession with retrospective effect and charged the interest at original rates.Consequent to the withdrawal of concessions few banks have debited the account of thecompany for the differential amount of interest and other concessions given as per CDRscheme. The period of withdrawal relates from May 1st 2014 to the date of debit. TheCompany had sought waiver of the said debits in the various restructuring proposalssubmitted to the Bank which has not yet been accepted by the Bank pending acceptance thecharges as debited have been recognized as Finance charges in the period of debit.

Based on information and explanation given to us the company is also in the process ofrestructuring its borrowings from banks and finalizing alternative business plan which areexpected to result in profits in the near future. The Company's ability to continue asgoing concern is dependent on the implementation of the same. The above indicates asignificant uncertainty and doubt about the Company's ability to continue as a GoingConcern.

We conducted our audit in accordance with the Standards on Auditing specified underSection 143(10) of the Act. Our responsibilities under those standards are furtherdescribed in the Auditor's Responsibilities for the Audit of the Financial Statementssection of our report. We are independent of the Company in accordance with the Code ofEthics issued by the Institute of Chartered Accountants of India (‘ICAI') togetherwith the ethical requirements that are relevant to our audit of the 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 are those matters that in our professional judgment 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 financial statements as awhole and in forming our opinion thereon and we do not provide a separate opinion onthese matters. In addition to the matter described in the Basis of Qualified Opinionsection we have determined the matters described below to be the key audit matters to becommunicated in our report.

S.No Key Audit Matter Auditor's Response
Litigations - Contingencies Principal Audit Procedures
Assessment of litigations and related disclosure of contingent liabilities [Refer to Note 2 (a) to the Standalone financial statements- "Use of estimates and critical accounting judgements - Provisions and contingent liabilities" Note 44 to the Standalone Financial Statements - "Contingencies". As at March 31 2020 the Company has exposures towards litigations relating to various matters as set out in the aforesaid Notes. Our audit procedures included the following:
• We understood assessed and tested the design and operating effectiveness of key controls surrounding assessment of litigations relating to the relevant laws and regulations;
1. Significant management judgement is required to assess such matters to determine the probability of occurrence of material outflow of economic resources and whether a provision should be recognised or a disclosure should be made. The management judgement is also supported with legal advice in certain cases as considered appropriate. As the ultimate outcome of the matters are uncertain and the positions taken by the management are based on the application of their best judgement related legal advice including those relating to interpretation of laws/regulations it is considered to be a key audit matter. • We discussed with management the recent developments and the status of the material litigations which were reviewed and noted by the audit committee;
• We performed our assessment on a test basis on the underlying calculations supporting the contingent liabilities/ other significant litigations made in the Standalone Financial Statements;
• We considered external opinions where relevant obtained by management;
• We evaluated management's assessments and assessed the reliability of the management's past estimates/judgements;
• We assessed the adequacy of the Company's disclosures.
Based on the above work performed assessment in respect of litigations and related disclosures relating to contingent liabilities/ other significant litigations in the Standalone Financial Statements are considered to be reasonable.
Physical verification of inventory Observed the physical verification of inventories carried out by the management at the select locations subsequent to year-end through virtual mediums to verify the compliance with the standard operating procedures issued by the management for physical verification of inventory to determine existence and condition of inventory.
2. Management has carried out alternate procedures to validate the existence and condition of its inventory as at the year end such as roll back procedures for inventories which were physically verified subsequent to year end and carrying out consumption analysis and to determine the quantities of the inventory at the balance sheet date.
On a sample basis performed roll back procedures from the inventory quantities physically verified by the management subsequent to the year end to arrive at the quantities at the balance sheet date. Compared such quantities at the balance sheet date based on such roll back with the quantities as per the inventory records and obtained explanations for differences if any.
Further due to Covid-19 related lockdown we could participate in the physical verification of inventory that was carried out by the management subsequent to the year end only through virtual medium.
In view of the foregoing obtaining sufficient appropriate audit evidence regarding existence and condition of inventories as at the balance sheet date is identified as a key audit matter.
3. Impact of Covid-19 pandemic on the Company's operations We assessed the Company's process to identify assess and respond to risks of material misstatement considering the uncertainties and the impact of Covid-19 pandemic on the Company's operations and results for the year under consideration. We have designed performed procedures and modified previously planned audit procedures as a result of the necessity for carrying out part of the audit procedures remotely including verification of the source and completeness of data provided for audit. This includes performing alternative audit procedures to obtain audit comfort in respect of significant account balances for recognition measurement and disclosures. We specifically discussed the impact of COVID-19 with the management and critically challenged the key assumptions and their reasonableness in making such key accounting estimates. We have considered management's adjustments or disclosures which includes the impact of the changes in the environment on the recognition and measurement of account balances and transactions in the financial statements or other specific disclosures.

Emphasis of Matter

We draw your attention to the following matter Note 3(s) to the standalone financialstatements which explains the uncertainties and management's assessment of the financialimpact due to lockdown / restrictions related to the COVID-19 pandemic imposed by theGovernments for which a definitive assessment of the impact is dependent upon futureeconomic conditions. Our opinion is not modified in respect of this matter.

Information other than the 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 Annual Report but does not includethe financial statements and our auditor's report thereon.

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

In connection with our audit of the financial statements our responsibility is to readthe other information and in doing so consider whether the other information ismaterially inconsistent with the financial statements or our knowledge obtained in theaudit or otherwise appears to be materially misstated. If based on the work we haveperformed we conclude that there is a material misstatement of this other information weare required to report that fact. We have nothing to report in this regard.

Responsibilities of Management and Those Charged with Governance for the standalonefinancial statements

The Company's Board of Directors is responsible for the matters stated in Section134(5) of the Act with respect to the preparation of these standalone financial statementsthat give a true and fair view of the state of affairs (financial position) profit orloss (financial performance including other comprehensive income) changes in equity andcash flows of the Company in accordance with the accounting principles generally acceptedin India including the Ind AS specified under Section 133 of the Act. This responsibilityalso includes maintenance of adequate accounting records in accordance with the provisionsof the Act for safeguarding of the assets of the Company and for preventing and detectingfrauds and other irregularities; selection and application of appropriate accountingpolicies; making judgments and estimates that are reasonable and prudent; and designimplementation 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 financial statements thatgive a true and fair view and are free from material misstatement whether due to fraud orerror.

In preparing the financial statements management is responsible for assessing theCompany's ability to continue as a going concern disclosing as applicable mattersrelated to going concern and using the going concern basis of accounting unless managementeither intends to liquidate the Company or to cease operations or has no realisticalternative but to do so.

Those Board of Directors are also responsible for overseeing the Company's financialreporting process. Auditor's Responsibilities for the Audit of the financial statements

Our objectives are to obtain reasonable assurance about whether the financialstatements as a whole are free from material misstatement whether due to fraud or errorand to issue an auditor's report that includes our opinion. Reasonable assurance is a highlevel of assurance but is not a guarantee that an audit conducted in accordance withStandards on Auditing 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 financial statements.

As part of an audit in accordance with Standards on Auditing we exercise professionaljudgment and maintain professional skepticism throughout the audit. We also:

• Identify and assess the risks of material misstatement of the financialstatements whether due to fraud or error design and perform audit procedures responsiveto those risks and obtain audit evidence that is sufficient and appropriate to provide abasis for our opinion. The risk of not detecting a material misstatement resulting fromfraud is higher than for one resulting from error as fraud may involve collusionforgery intentional omissions misrepresentations or the override of internal control.

• 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 explaining our opinion on whether the Company hasadequate internal financial controls system in place and the operating effectiveness ofsuch 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 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 financial statements or if such disclosures are inadequate to modify our opinion.Our conclusions are based on the audit evidence obtained up to the date of our auditor'sreport.

• Evaluate the overall presentation structure and content of the financialstatements including the disclosures and whether the financial statements represent theunderlying transactions and events in a manner that achieves fair presentation.

Materiality is the magnitude of misstatements in the Financial Statements thatindividually or in aggregate makes it probable that the economic decisions of areasonably knowledgeable user of the financial statements may be influenced. We considerquantitative materiality and qualitative factors in (i) planning the scope of our auditwork and in evaluating the results of our work; and (ii) to evaluate the effect of anyidentified misstatements in the 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 financial statements of thecurrent period and are therefore the key audit matters. We describe these matters in ourauditor's report unless law or regulation precludes public disclosure about the matter orwhen 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.

Report on other Legal and Regulatory Requirements

1. 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 we givein the Annexure A a statement on the matters specified in paragraphs 3 and 4 of theOrder.

2. As required by Section 143 (3) of the Act based on our audit 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 standalone financial statements dealt with by this report are in agreement withthe books of account;

d) The balance sheet the statement of profit and loss including other comprehensiveincome statement of changes in equity and the statement of cash flow dealt with by thisreport are in agreement with the books of accounts

e) on the basis of the written representations received from the directors and taken onrecord by the Board of Directors none of the directors is disqualified as on 31 March2020 from being appointed as a director in terms of Section 164(2) of the Act;

f) With respect to the adequacy of the internal financials controls over financialreporting of the company and the operating effectiveness of such controls refer to ourseparate report in Annexure "B". Our report expresses and unmodified opinion onthe adequacy and operating effectiveness of the company's internal financial controls overfinancial reporting; and

g) 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:

h) With respect to the other matters to be included in the Auditor's Report inaccordance with the requirements of section 197(16) of the Act as amended in our opinionand to the best of our information and according to the explanations given to us theremuneration paid by the Company to its directors during the year is in accordance withthe provisions of section 197 of the Act.

i) 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 the standalone financial statements - refer note 44 to the financialstatements;

ii. The Company has made provision as required under the applicable law or Ind AS formaterial foreseeable losses if any on long-term contracts including derivativecontracts;

iii. There has been no delay in transferring amounts required to be transferred tothe Investor Education and Protection Fund by the Company during the year ended 31 March2020;

For M/s CNGSN & ASSOCIATES LLP

CHARTERED ACCOUNTANTS

Firm Registration No: 004915S/S200036

K Parathasarathy

Partner

Membership No: 018394

Place: Chennai

Date: 15-09-2020

UDIN 20018394AAAAGN2253

Annexure -A to the Independent Auditors' Report

Referred to in paragraph 1 under the heading ‘Report on Other Legal &Regulatory Requirement' of our report of even date to the financial statements of theCompany for the year ended March 312020:

1) (a) The Company has maintained proper records showing full including quantitativedetails and situation of fixed assets;

(b) We are informed that the company has formulated a programme for physicalverification of all fixed assets over a period of three year which in our opinion isreasonable considering the size of the company and the nature of its assets. Accordinglythe fixed assets have been physically verified by the management during the year and nomaterial discrepancies were noticed on such verification.

(c) The title deeds of immovable properties are held in the name of the company.

2) (a) The management has conducted the physical verification of inventory atreasonable intervals.

(b) The discrepancies noticed on physical verification of the inventory as compared tobooks records which has been properly dealt with in the books of account were notmaterial.

3) According to the information and explanations given to us the Company has notgranted any loans secured or unsecured to companies firms limited liability partnershipsor other parties covered in the Register required to be maintained under section 189 ofthe Companies Act. Accordingly clause (iii) of the order is not applicable for the yearunder consideration

4) In our opinion and according to the information and explanations given to us thecompany has complied with the provisions of section 185 and 186 of the Companies Act 2013In respect of loans investments guarantees and security.

5) According to the information and explanations given to us the Company has notaccepted any deposits within the meaning of Sections 73 to 76 or any other relevantprovisions of the Companies Act 2013 and the rules framed there under. Accordinglyreporting under clause 3 (v) of the Order does not arise.

6) We have reviewed the cost records maintained by the company as prescribed by thecentral government under section 148(1) of the companies act 2013 and are of the opinionthat prima facie the prescribed cost records made and maintain. We have however not madea detailed examination of the records with a view to determine whether they are accurateor complete.

7) (a) According to information and explanations given to us and on the basis of ourexamination of the books of account and records the Company has been generally regularin depositing undisputed statutory dues including Provident Fund Employees StateInsurance Income-Tax Sales tax Service Tax Duty of Customs Duty of Excise Valueadded Tax Cess and any other statutory dues with the appropriate authorities. Accordingto the information and explanations given to us there are no arrears of statutory dueswhich are outstanding as at 31st March 2020 for a period of more than six months from thedate they become payable.

(b) According to the records of the company and the information and explanation givento us the details of disputed Excise Value Added Tax and Income Tax not deposited are asfollows:

Nature of Dues Amount in Lacs. Period to which it relates Forum where the Dispute is pending
Excise 1.02 2003-04 CESTAT
Excise 25.65 2002-03 CESTAT
Excise 1444.94 Up to June 2017 CESTAT
Excise/Service Tax 235.27 Apr 2013-Jun 17 CESTAT Bangalore
Classification of FIBC and demand for repayment of duty drawback 168.18 Feb 2010-Sep 2011 Ministry of Finance - Secretary
Nature of Dues Amount in Lacs. Period to which it relates Forum where the Dispute is pending
VAT 0.87 2004-09 Hon'ble High Court Madras
VAT 506.58 2013-14 Commercial Tax Department
VAT 18.82 2012-13 Commercial Tax Department
VAT 14.22 2013-14 Commercial Tax Department
INCOME TAX 34.19 2011-12 CIT (A)
TNEB 265.54 2013-14 TNEB

8) According to information and explanation given to us the company has defaulted incertain repayments of principal amount to banks and financial institution.

(Rs in Lacs)

Period Canara Bank Syndicate bank SBI Andhra Bank IOB Total for the quarter Cumulative Total No. of days
30-06-2016 253 221 51 53 127 705 705 1370
30-09-2016 263 193 77 84 127 743 1448 1278
31-12-2016 263 193 77 84 127 743 2191 1186
31-03-2017 263 193 77 84 127 743 2934 1096
30-06-2017 435 303 103 166 234 1240 4174 1005
30-09-2017 435 303 103 166 234 1240 5414 913
31-12-2017 435 303 103 166 234 1240 6654 821
31-03-2018 435 303 103 166 234 1240 7894 731
30-06-2018 584 308 103 265 359 1618 9512 640
30-09-2018 584 308 103 265 359 1618 11130 548
31-12-2018 584 308 103 265 359 1618 12748 456
31-03-2019 584 308 103 265 359 1618 14366 366
30-06-2019 687 369 103 305 416 1880 16246 275
30-09-2019 687 369 103 305 416 1880 18126 183
31-12-2019 687 369 103 305 416 1880 20006 91
31-03-2020 687 369 103 305 416 1880 21886 0

9) The Company has not raised any money by way of initial public offer or furtherpublic offer (including debt Instruments) during the year. In our opinion and according tothe information and explanations given to us on an overall basis the term loans havebeen applied for the purposes for which they were obtained.

10) During the course of our examination of the books and records of the Companycarried out in accordance with the generally accepted auditing practices in India andaccording to the information and explanations given to us we have neither come across anyinstances of fraud by the Company or any instances of frauds on the Company by itsofficers or employees noticed or reported during the year nor we have been informed ofsuch cases by the management..

11) According to the information and explanations given to us and the records of theCompany examined by us in our opinion managerial remuneration has been paid / providedfor in accordance with the requisite approvals mandated by the provisions of Section 197read with Schedule V to the Companies Act 2013..

12) According to the information and explanations given to us the Company is not aNidhi Company. Accordingly reporting under clause 3(xii) of the Order does not arise.

13) According to the information and explanations given to us and the records of theCompany examined by us in our opinion all transactions with the related parties are incompliance with Sections 177 and 188 of the Companies Act 2013 where applicable and thedetails have been disclosed in the Financial Statements as required by the applicableaccounting standards14) In our opinion all transactions with the related parties are incompliance with section 177 and 188 of Companies Act 2013 and the details have beendisclosed in the Financial Statements as required by the applicable accounting standards.

14) According to the information and explanations given to us the Company has not madeany preferential allotment or private placement of shares or fully or partly convertibledebentures during the year under review. Accordingly reporting under clause 3 (xiv) ofthe Order does not arise.

15) According to the information and explanations given to us the Company has notentered into non-cash transactions with directors or persons connected with the directorsduring the year. Accordingly reporting under clause 3 (xv) of the Order does not arise.

16) According to the information and explanations given to us the Company is notrequired to be registered under Section 45-IA of the Reserve Bank of India Act 1934.Accordingly reporting under clause 3 (xvi) of the Order does not arise.

For M/s CNGSN & ASSOCIATES LLP

CHARTERED ACCOUNTANTS

Firm Registration No: 004915S/S200036

K Parathasarathy

Partner

Membership No: 018394

Place: Chennai

Date: 15-09-2020

UDIN 20018394AAAAGN2253

Annexure B to The Independent Auditor's Report

(Referred to in paragraph 2(f) under ‘Report on Other Legal and Regulatoryrequirements' section of our report to the Members of Tulsyan NEC Limited of even date)

Report on the Internal Financial Controls over Financial Reporting under Clause (i) ofSub - Section 3 of Section 143 of the Companies Act 2013 ("the Act")

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 control over financial reportingcriteria established by the Company considering the essential components of internalcontrol stated in the Guidance Note on Audit of Internal Financial Controls over FinancialReporting (the "Guidance Note") issued by the Institute of Chartered Accountantsof India (ICAI). These responsibilities include the design implementation and maintenanceof adequate internal financial controls that were operating effectively for ensuring theorderly and efficient conduct of the Company's business including adherence to Company'spolicies the safeguarding of its assets the prevention and detection of frauds anderrors the accuracy and completeness of the accounting records and the timelypreparation of reliable financial information as required under the Act.

Auditors' Responsibility

Our responsibility is to express an opinion on the Internal Financial Controls overFinancial Reporting based on our audit. We conducted our audit in accordance with theGuidance Note on Audit of Internal Financial Controls over Financial Reporting (the"Guidance Note") issued by the Institute of Chartered Accountants of India andthe Standards on Auditing prescribed under Section 143(10) of the Act to the extentapplicable to an audit of Internal Financial Controls. Those Standards and the GuidanceNote require that we comply with ethical requirements and plan and perform the audit toobtain reasonable assurance about whether adequate Internal Financial Controls overFinancial Reporting were established and maintained and if such controls operatedeffectively in all material respects.

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

We believe that the audit evidence we have obtained is sufficient and appropriate toprovide a basis for our audit opinion on the Company's Internal Financial Controls overFinancial Reporting.

Meaning of Internal financial Controls over financial Reporting

A Company's Internal Financial Controls 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 Controls 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 Internal Financial Controls overFinancial Reporting may become inadequate because of changes in conditions or that thedegree of compliance with the policies or procedures 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 adequate internal financial controlsover financial reporting and such internal financial controls over financial reportingwere operating effectively as at 31 March 2020 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.

For M/s CNGSN & ASSOCIATES LLP

CHARTERED ACCOUNTANTS

Firm Registration No: 004915S/S200036

K Parathasarathy

Partner

Membership No: 018394

Place: Chennai Date: 15-09-2020

UDIN 20018394AAAAGN2253

.