beryl securities ltd Auditors report

To,

The Members of

Beryl Securities Limited Indore

Report on the Audit of the Financial Statements (IND AS)

I. Opinion

We have audited the accompanying Financial statements (Ind AS) of Beryl Securities Limited ("the Company"), which comprise the Balance Sheet as at 31 March 2023, the Statement of Profit and Loss (including statement of other comprehensive income), the statement of Changes in Equity and Statement of Cash Flows for the year then ended, and notes to the financial statements, including a summary of significant accounting policies and other explanatory information (hereinafter referred to as "the financial statements").

In our opinion and to the best of our information and according to the explanations given to us, the aforesaid IND AS financial statements give the information required by the Companies Act, 2013 ("the Act") in the manner so required and give a true and fair view in conformity with the Indian accounting standards prescribed under section 133 of principles generally accepted in India, of the state of affairs of the Company as at 31 March 2023, and Profit (including other comprehensive income), changes in equity and its cash flows for the year ending on that date.

II. Basis for Opinion

We conducted our audit in accordance with the Standards on Auditing (SAs) specified under Section 143(10) of the Act. Our responsibilities under those standards are further described in the Auditors Responsibilities for the Audit of the financial statements section of our report. We are independent of the Company in accordance with the Code of Ethics issued by the Institute of Chartered Accountants of India ("ICAI") together with the ethical requirements that are relevant to our audit of the financial statements under the provisions of the Act and the Rules there under, and we have fulfilled our other ethical responsibilities in accordance with these requirements and the ICAIs Code of Ethics. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion on the financial statements.

III. Key Audit Matters

Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the financial statements for the financial year ended 31st March, 2023. These matters were addressed in the context of our audit of the financial statements as a whole, and in forming our opinion on these matters, and we do not provide a separate opinion on these matters.

We have determined the matters described below to be the key audit matters to be communicated in our report. We have fulfilled the responsibilities described in the Auditors responsibilities for the audit of the financial statements section of our report, including in relation to these matters. Accordingly, our audit included the performance of procedures designed to respond to our assessment of the risks of material misstatement of the financial statements. The results of our audit procedures, including the procedures performed to address the matters below, provide the basis for our audit opinion on the accompanying financial statements.

Key audit matters	How our audit addressed the key audit matter
Assessment of impairment loss allowance based on expected credit loss (ECL) on Loans (Refer Note 06 of the financial statements)	The audit procedures performed by us to assess appropriateness of the impairment allowance based on ECL on loans included the following:
The loan balances towards demand loan to INR 888.09 Lakhs and the associated impairment allowances aggregating to INR 15.76 Lakhs are significant to the financial statements and involves judgement around the determination of the impairment allowance in line with the requirements of the IND AS 109 "Financial Instruments". Impairment allowances represent managements estimate of the losses incurred within the loan portfolios at the balance sheet date and are inherently judgmental. Impairment, based on ECL model, is calculated using main variables, viz. ‘Staging, ‘Exposure At Default, ‘Probability of Default and ‘Loss Given Default as specified under IND AS 109.	We understood and evaluated the design and tested the operating effectiveness of the key controls put in place by the management over:
The Company determines the allowance for credit losses based on historical loss experience adjusted to reflect current and estimated future economic conditions.	i. the assumptions used in the calculation of ECL and its various aspects such as determination of Probability of Default, Loss Given Default, Exposure At Default, Staging of Loans, etc.;
The Company considered current and anticipated future economic conditions and has taken into account estimates of possible effect from the pandemic relating to COVID -19. We identified allowance for credit losses as a key audit matter because the Company exercises significant judgment in calculating the expected credit losses. Quantitative factors like days past due, behaviour of the portfolio, historical losses incurred on defaults and macro-economic data points identified by the Managements expert and qualitative factors like nature of the underlying loan, deterioration in credit quality, correlation of macro- economic variables to determine expected losses, uncertainty over realisability of security, judgement in relation to management overlays and related Reserve Bank of India (RBI) guidelines, to the extent applicable, etc. have been taken into account in the ECL computation. Given the inherent judgmental nature and the complexity of model involved, we determined this to be a Key Audit Matter.	ii. the completeness and accuracy of source data used by the Management in the ECL computation; and
	iii. ECL computations for their reasonableness.
	We, along with the assistance of the auditors our expert, verified the appropriateness of methodology and models used by the Company and reasonableness of the assumptions used within the computation process to estimate the impairment provision
	We test-checked the completeness and accuracy of source data used.
	We recomputed the impairment provision for a sample of loans across the loan portfolio to verify the arithmetical accuracy and compliance with the requirements of Ind AS 109.
	We evaluated the reasonableness of the judgement involved in management overlays that form part of the impairment provision, and the related approvals.
	We evaluated the adequacy of presentation and disclosures in relation to impairment loss allowance in the Financial Statements

 

Related Party Transactions
We identified related party transactions as a key audit matter due to the significance of related party transactions, regulatory compliance and risk of such transactions remaining undisclosed in the financial statements.	Evaluated the Companys policies, processes and procedures in respect of identifying and disclosing related party transactions. .
	Read the minutes of meetings of the shareholders, Board and Audit Committee regarding the Companys assessment of related party transactions for arms length pricing
	Assessed the compliance with Companies Act 2013, including authorisation and approvals as specified in sections 177 and 188 of the Companies Act, 2013, and Rules thereon and the Securities and Exchange Board of India regulations with respect to related party transactions.
	Tested on a sample basis related party transactions with the underlying contracts and other documents.

IV. Emphasis of Matter

1. We draw attention to Note 11 & 43 of the financial statements, which describes that The Company has paid Rs. 33.20 Lakhs advance against purchase of one residential flat at Jaypee Greens, Noida, Rs 30.45 Lakhs one flat at Sohna, Haryana & Rs 20.00 Lakhs paid advance of purchase of a plot at R.R. Industrial Park, Indore in earlier years. However, Registry of one properties situated at Sohna, Haryana registered after year end but registration of other one flat & plot is still pending. Management has opined the said Capital Advance are good and recoverable.

2. We draw attention to Note 45 of the financial statements that Company had given public Notice dated 11/05/2023 for appointment of three new Additional directors whose name are (i) Anshul Gupta (DIN: 09356735) (ii) Sanyam Jain (DIN: 08604083) (iii) Vineet Bajpai (DIN: 08098068) in the Company for broad base management and expansion of business operation of the Company which was approved by RBI dated 14/11/2022 but appointment as an additional director is still pending.

Further company has been also applied before RBI under Article 61 and 63 of Master Direction DNBR.PD.007/03.10.119/2016-17 for approval of takeover, acquisition of control and change in the shareholding of Beryl Securities Limited by way of transfer of shareholding of 26 per cent or more of the paid-up equity capital through open offer under monitoring and guidance of Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011 but said approval for the same is still under process before RBI Bhopal.

3. We draw attention to Note 47 of the financial statements, The Company has send balance confirmation to Debtors and creditors but the confirmation is still pending from them.

Our opinion is not modified in respect of this matter.

V. Information other than the financial statements and Auditors Report thereon

The Companys management and Board of Directors are responsible for the other information. The other information comprises the information included in the Companys annual report, but does not include the Financial Statements and our auditors report thereon.

Our opinion on the Financial Statements does not cover the other information and we do not express any form of assurance conclusion thereon.

In connection with our audit of financial statements, our responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent with the Financial Statements or our knowledge obtained in the audit or otherwise appears to be materially misstated. If, based on the work we have performed, we conclude that there is a material misstatement of this other information; we are required to report that fact.

We have nothing to report in this regard.

VI. Responsibilities of management and those charged with governance for the financial statements

The Companys management and Board of Directors are responsible for the matters stated in Section 134(5) of the Act with respect to the preparation of the Financial Statements that give a true and fair view of the financial position, financial performance including other comprehensive income, changes in equity and cash flows of the Company in accordance with the accounting principles generally accepted in India, including the Indian Accounting Standards (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 in accordance with the provisions of the Act for safeguarding of the assets of the Company and for preventing and detecting frauds and other irregularities; selection and application of appropriate accounting policies; making judgments and estimates that are reasonable and prudent; and design, implementation and maintenance of adequate internal financial controls that were operating effectively for ensuring the accuracy and completeness of the accounting records, relevant to the preparation and presentation of the Financial Statements that give a true and fair view and are free from material misstatement, whether due to fraud or error.

In preparing the financial statements, management and Board of Directors are responsible for assessing the Companys ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless Board of Directors and management either intends to liquidate the Company or to cease operations, or has no realistic alternative but to do so.

The Board of Directors is also responsible for overseeing the Companys financial reporting process.

VII. Auditors Responsibilities for the Audit of the financial statements

Our objectives are to obtain reasonable assurance about whether the Financial Statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditors report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with SAs will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these financial statements.

As part of an audit in accordance with SAs, we exercise professional judgment and maintain professional skepticism throughout the audit. We also:

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

Obtain an understanding of internal control relevant to the audit in order to design 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 has adequate internal financial controls with reference to Financial Statements in place and the operating effectiveness of such controls.

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

Conclude on the appropriateness of managements use of the going concern basis of accounting and, based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Companys ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditors report to the related disclosures in the 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 auditors report. However, future events or conditions may cause the Company to cease to continue as a going concern.

Evaluate the overall presentation, structure and content of the financial statements, including the disclosures, and whether the Financial Statements represent the underlying transactions and events in a manner that achieves fair presentation.

We believe that the Audit Evidence obtained by us is sufficient and appropriate to provide a basis for our Audit opinion and the Financial Statements.

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

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

From the matters communicated with those charged with governance, we determine those matters that were of most significance in the audit of the Financial Statements of the current period and are therefore the key audit matters. We describe these matters in our auditors report unless law or regulation precludes public disclosure about the matter or when, in extremely rare circumstances, we determine that a matter should not be communicated in our report because the adverse consequences of doing so would reasonably be expected to outweigh the public interest benefits of such communication.

VIII. Other Matter

The financial statements of the Company for the year ended March 31, 2022, were audited by another firm of Chartered Accountants under the Companies Act, 2013 who, vide their report dated May 28, 2022, on which unmodified opinion expressed by then auditor on those financial statements.

Our opinion is not modified in respect of above matter.

IX. Report on Other Legal and Regulatory Requirements

1. As required by the Companies (Auditors Report) Order, 2020 ("the Order") issued by the Central Government of India in terms of Section 143(11) of the Act, we give in the "Annexure A" a statement on the matters specified in paragraphs 3 and 4 of the Order, to the extent applicable.

2. With respect to the matter to be included in the Auditors Report under section 197(16), we report that, In our opinion and according to the information and explanation given to us, the remuneration paid by the Company to its directors during the current year is in accordance with the provisions of Section 197 of the Act.

3. As required by Section 143(3) of the Act, based on our Audit we report to the extent applicable that:

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

b) In our opinion, proper books of account as required by law relating to the preparation of the aforesaid Financial Statements have been kept by the Company so far as it appears from our examination of those books.

c) The Balance Sheet and the Statement of Profit and Loss (including other comprehensive income), statement of changes in equity and statement of cash flows dealt with by this Report are in agreement with the books of account maintained for the purpose of preparation of the Financial Statements.

d) With respect to the adequacy of the internal financial controls with reference to Financial Statements of the Company and the operating effectiveness of such controls, refer to our separate Report in "Annexure B" to this report.

e) In our opinion, the aforesaid Financial Statements comply with the Ind AS specified under Section 133 of the Act.

f) On the basis of the written representations received from the directors as on 31 March 2022 taken on record by the Board of Directors, none of the directors is disqualified as on 31 March 2023 from being appointed as a director in terms of Section 164(2) of the Act.

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

i. The Company does not have any pending litigation which would impact in its financial position .

ii. The Company does not required to make provisions, as required under the applicable law or accounting standards, for material foreseeable losses, if any, on long term contracts.

iii. There were no amounts which were required to be transferred to the investor education & protection fund by the company

iv. a) The Management has represented that, to the best of its knowledge and belief, no funds (which are material either individually or in the aggregate) have been advanced or loaned or invested (either from borrowed funds or share premium or any other sources or kind of funds) by the Company to or in any other person or entity, including foreign entity ("Intermediaries"), with the understanding, whether recorded in writing or otherwise, that the Intermediary shall,

directly or indirectly lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the Company ("Ultimate Beneficiaries") or

provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries;

b) The management has represented, that, to the best of its knowledge and belief, no funds have been received by the Company from any persons or entities, including foreign entities ("Funding Parties"), with the understanding, whether recorded in writing or otherwise, that the Company shall:

directly or indirectly, lend or invest in other persons or entities identified in any manner whatsoever ("Ultimate Beneficiaries") by or on behalf of the Funding Party or provide any guarantee, security or the like from or on behalf of the Ultimate Beneficiaries; and

c) Based on such audit procedures as considered reasonable and appropriate in the circumstances, nothing has come to our notice that has caused us to believe that the representations under subclause (iv) (a) and (iv) (b) contain any material mis-statement.

v. The company has not declared any dividend during the year.

vi. Proviso to Rule 3(1) of the Companies (Accounts) Rules, 2014 for maintaining books of account using accounting software which has a feature of recording audit trail (edit log) facility is applicable to the Company w.e.f. April 1, 2023, and accordingly, reporting under Rule 11(g) of Companies (Audit and Auditors) Rules, 2014 is not applicable for the financial year ended March 31, 2023.

	For SUBHASH CHAND JAIN ANURAG & ASSOCIATES
	CHARTERED ACCOUNTANTS
	FRN-004733C
	(AKSHAY JAIN)
	PARTNER
Date : 27/05/2023	M.No. 447487
Place : Indore	UDIN:23447487BGUEBR9602

ANNEXURE "A" TO THE INDEPENDENT AUDITORS REPORT

ON THE FINANCIAL STATEMENTS OF BERYL SECURITIES LIMITED FOR THE YEAR ENDED 31ST MARCH 2023.

(Referred to paragraph 1 under ‘Report on Other Legal and Regulatory Requirements section of our report of even date)

To the best of our information and according to the explanations provided to us by the Company and the books of account and records examined by us in the normal course of audit, we state that:

(i) In respect of its Property, plant & equipment and Intangible Assets:

a) The Company has maintained proper records showing full particulars including quantitative details and situation of Property, Plant and Equipment (PPE).

The Company does not have any Intangible Assets in during the year.

b) According to the information and explanations given to us and on the basis of our examination of the records of the Company, all items of Property, plant and equipment and have been physically verified by the management in during the year. According to the information and explanations given to us, no material discrepancies were noticed on such verification.

c) According to the information and explanations given to us, the Company does not have any immovable properties, however the company had given advances to acquire immovable properties of Land & Building much earlier but the possession and registry of said properties were pending till 31st March 2023. Accordingly, the reporting under Clauses 3(i)(c) of the Order is not applicable to the Company.

d) According to the information and explanations given to us and the records examined by us, company has not revalued its Property, Plant and Equipment during the year, hence the reporting under clause 3(1)(d) of the order is not applicable to the company.

e) As explained by the management of the company, no proceedings have been initiated or are pending against the company for holding any benami property under the Benami Transactions (Prohibition) Act, 1988 and rules made thereunder.

(ii) In respect of Inventory and Working Capital

a) The Company is in the business of providing loans & Advances being NBFC Company and does not have any physical inventories hence reporting under clause 3(ii)(a) of the Order is not applicable.

b) The Company has not been sanctioned any working capital limits in excess of Rs. 5 crore, in aggregate, at any points of time during the year, from banks or financial institutions on the basis of security of current assets, hence reporting under clause 3(ii)(b) of the Order is not applicable.

(iii) In respect of Investments, Loan, Guarantee or Security given by Company

a) Since the Companys principal business is to give loans. Accordingly, the provision of clause 3(iii) (a) of the Order is not applicable to it.

b) The Company, being a Non-Banking Financial Company (‘NBFC), registered under provisions of RBI Act, 1934. In our opinion and according to the information and explanations given to us, that the terms and conditions on which loans and advances in the nature of loans, provided during the year are, prima facie, not prejudicial to the Companys interest. Further Company has not made any investment and also not provided any guarantee to the Company, Firm, and LLP in during the year.

c) The Company, being a Non-Banking Financial Company (‘NBFC), registered under provisions of RBI Act, 1934 and rules made thereunder, in pursuance of its compliance with provisions of the said Act/Rules, particularly, the Income Recognition, Asset Classification and Provisioning Norms, monitors repayments of principal and payment of interest by its customers as stipulated. In respect of loans and advances in the nature of loans granted by the Company, the schedule of repayment of principal and payment of interest has been stipulated. Being a Non-Banking Finance Company, there are instances where the repayment of principal and interest are not as per the stipulated terms. (Refer Note 06.02 to the Financial Statement).

d) The Company, being a NBFC, registered under provisions of RBI Act, 1934 and rules made thereunder, in pursuance of its compliance with provisions of the said Act/Rules, particularly, the Income Recognition, Asset Classification and Provisioning Norms, monitors and report total amount overdue including principal and/or payment of interest by its customers for more than 90 days. According to the information and explanation made available to us, there is no loan or advance is overdue (except stated otherwise) where schedule of repayment of principal and payment of interest has been stipulated.

e) Since the Companys principal business is to give loans. Accordingly, the provision of clause 3(iii) (e) of the Order is not applicable to it.

f) According to the information and explanations given to us, the Company has not granted any loans or advances in the nature of loans either repayable on demand or without specifying any terms or period of repayment to promoter related parties as defined in clause 76 of sec 2 of the Companies Act, 2013.

(iv) In respect of Loan to Directors and Investment by the Company

According to the information and explanations given and clarifications made by the management, the Company has not given any loans or guarantees or has not made investment covered under section 185 and 186 of Companies Act, 2013. The Company has not provided any security for which the provisions of section 185 and 186 of the Act are applicable.

(v) In respect of Deposits Accepted by the Company

According to the information and explanations given to us, the Company has not accepted deposits under the provisions of Sections 73 to 76 or any other relevant provisions of the Act and the rules framed there under. Accordingly, the reporting under Clause 3(v) of the Order is not applicable to the Company.

(vi) In respect of Cost Records Maintenance

According to the information and explanations given and records made available to us, the provisions of sub section (1) of Section 148 of the Act with regards to maintenance of cost records are not applicable to the company.

(vii) In respect of payment of Statutory Dues

a. According to the records made available to us, the company is regular in depositing undisputed statutory dues including Goods and Services Tax, provident fund, employees state insurance, income-tax, sales-tax, service tax, duty of customs, duty of excise, value added tax, cess and any other statutory dues to the appropriate authorities. According to the information and explanation given to us there were no outstanding statutory dues as on 31st of March, 2023 for a period of more than six months from the date they became payable except the following:

(Rs. in Lakhs)

Sr. No.	Nature of the Statute	Nature of Dues	Amount	Period to which the amount relates
1	GST Act, 2017	GST Payable	0.09	F.Y. 2017-18
2	GST Act, 2017	Goods & Service Tax	0.25	FY 2022-23
3	Finance Act, 1994	Service Tax	0.08	F.Y. 2016-17
4	MP Professional Tax Act, 1995	Professional Tax Payable	0.48	FY 1999-2000 to FY 2016-17
5	Income Tax Act, 1961	Income Tax Demand	6.46	FY 2006-07
6	Income Tax Act, 1961	Income Tax Demand	4.56	FY 2008-09
7	Wealth Tax Act, 1957	Wealth Tax	1.17	Up to FY 2015-16

b. In our opinion and according to the information and explanations given to us, there are no statutory dues which have not been deposited with the appropriate authority on account of any dispute.

(viii) In respect of Unrecorded Transactions of Income

According to the information and explanations given to us and on the basis of our examination of the records made available to us by the management and on the basis of our test checks performed during the Audit, the Company has not surrendered or disclosed any transactions, previously unrecorded as income in the books of account, in the tax assessments under the Income-tax Act, 1961 as income during the year.

(ix) In respect of Repayment of Loans and Borrowings

a) According to the information and explanations given and records made available to us, the company neither borrowed any loans in during the year nor any outstanding such borrow loan. Hence comment on defaulted in repayment of secured as well as unsecured loans or other borrowings to any lender does not applicable.

b) According to the information and explanations given and records made available to us, Since the company has not taken any loans from any Bank and Financial Institution Hence Comment on declared willful defaulter by any bank or financial institution or any other lender does not applicable.

c) According to the information and explanations given to us and based on the audit procedures performed by us, the Company has not availed any term loans during the year. Accordingly, the reporting under Clause 3(ix)c of the Order is not applicable to the Company.

d) According to the information and explanations given to us and on an overall examination of the Balance Sheet of the Company we report that no funds are raised on short-term basis by company. Accordingly, the reporting under Clause 3(ix) (d) of the Order is not applicable to the Company.

e) As per the information & explanations given by the management, the company does not have any subsidiary, associate or joint venture during the year. Accordingly, provisions of Para (e) and (f) of the said clause (ix) are not applicable to the Company.

(x) In respect of Utilization of Public Funds

a) As per the information & explanations given by the management and on the basis of our test checks performed during the Audit, the company has not raised any money by way of initial public offer or further public offer (including debt instruments) during the year. Accordingly, the reporting under Clause 3(x) (a) of the Order is not applicable to the Company.

b) Further, the company has not made any preferential allotment or private placement of shares or convertible debentures (fully, partially or optionally convertible) during the year for any purpose. Accordingly, the reporting under Clause 3(x) (b) of the Order is not applicable to the Company.

(xi) In respect of Reporting of Frauds

a) As per the information & explanations given by the management and on the basis of our test checks performed during the Audit, no instances of fraud by the company or any fraud on the company by the officers or employees has been noticed or reported during the year.

b) There has been No report filed by us under sub-section (12) of section 143 of the Companies Act has been filed in Form ADT-4 as prescribed under rule 13 of Companies (Audit and Auditors) Rules, 2014 with the Central Government, during the year and upto the date of this report. Accordingly, the reporting under Clause 3(xi) (b) of the Order is not applicable to the Company.

c) As per the information & explanations given by the management, no whistle-blower complaints received by the company during the year.

(xii) In respect of Provisions of Nidhi Company

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

(xiii) In respect of Related Party Transaction

In our opinion and according to the information and explanations given to us, the Company has entered into transactions with related parties in compliance with the provisions of Sections 177 and 188 of the Act. The details of such related party transactions have been disclosed in the Financial Statements as required by IND AS 24, Related Party Disclosures specified under Section 133 of the Act.

(xiv) In respect of Internal Audit System

(a) In our opinion and based on our examination, the Company has an internal audit system commensurate with the size and nature of its business.

(b) We have considered, during the course of our audit, the reports of the Internal Auditor for the period under audit, issued to the Company during the year till date, in determining the nature, timing and extent of our audit procedures in accordance with the guidance provided in SA 610 "Using the work of Internal Auditors".

(xv) In respect of Non Cash Transaction

According to the information and explanations given to us, the Company has not entered into any non cash transactions with its directors or directors of its holding company, or subsidiary companies or persons connected with them during the year and hence, the provisions of Section 192 of the Act are not applicable to the Company. Accordingly, the reporting under Clause 3(xv) of the Order is not applicable to the Company.

(xvi) In respect of Registration u/s 45-IA of RBI Act, 1934

a) The Company is NBFC Company hence duly registered under section 45-IA of the Reserve Bank of India Act 1934, vide Registration No. 03.0040 dt. 03/03/1998.

b) In our opinion and according to the information and explanations given to us, the Company has conducted Non-Banking Financial activities with a valid certificate of Registration (COR) from Reserve Bank of India under RBI Act, 1934.

c) In our opinion and according to the information and explanations given to us, the Company is not a Core Investment Company (CIC) as defined in the regulations made by the Reserve Bank of India. Accordingly, the reporting under Clause 3(xvi)c of the Order is not applicable to the Company.

d) Based on the information and explanations given to us, we report that the Company (as defined in the Core Investment Companies (Reserve Bank) Directions, 2016) is not belongs to any group of Core Investment Companies. Hence the reporting under clause 3 (xvi)(d) of the order is not applicable to the company.

(xvii) In respect of Cash Losses

The Company has not incurred any cash losses during the financial year covered by our audit and the immediately preceding financial year.

(xviii) In respect of Resignation of the Statutory Auditor

Due to applicable Provisions under Companies Act 2013 for rotation of Auditor, Hence Statutory Auditor of the company, M/s Prateek Jain & Co, Chartered Accountants has mandatorily resigned with effect from 29 September 2022 and we have adequately considered the view expressed by the previous auditors in their comments. Nevertheless, there have been no issues, objections or concerns raised by the said outgoing statutory auditors of the Company.

(xix) In respect of Financial Position of the Company

According to the information and explanations given to us and on the basis of the financial ratios, ageing and expected dates of realization of financial assets and payment of financial liabilities, other information accompanying the financial statements, our knowledge of the Board of Directors and management plans and based on our examination of the evidence supporting the assumptions, nothing has come to our attention, which causes us to believe that any material uncertainty exists as on the date of the audit report that the Company is not capable of meeting its liabilities existing at the date of balance sheet as and when they fall due within a period of one year from the balance sheet date. We, however, state that this is not an assurance as to the future viability of the Company. We further state that our reporting is based on the facts up to the date of the audit report and we neither give any guarantee nor any assurance that all liabilities falling due within a period of one year from the balance sheet date, will get discharged by the Company as and when they fall due.

(xx) In respect of Corporate Social Responsibilities

On the basis of examination of the records and books of accounts, provisions related to corporate social Responsibility (CSR) defined under section 135 of the Act are not applicable to the company. Accordingly, the reporting under Clause 3(xx) of the Order is not applicable to the Company.

(xxi) In respect of Consolidated Financial Statement

Since company is not liable to prepare Consolidated Financial Statements, the provisions of the said Clause (xxi) are not applicable to the company.

	For SUBHASH CHAND JAIN ANURAG & ASSOCIATES
	CHARTERED ACCOUNTANTS
	FRN-004733C
	(AKSHAY JAIN)
	PARTNER
Date : 27/05/2023	M.No. 447487
Place : Indore	UDIN:23447487BGUEBR9602

ANNEXURE "B" TO THE INDEPENDENT AUDITORS REPORT

ON THE FINANCIAL STATEMENTS OF BERYL SECURITIES LIMITED FOR THE YEAR ENDED 31ST MARCH 2023.

(Referred to point 3(d) of paragraph IX under ‘Report on Other Legal and Regulatory Requirements section of our Report of even date)

Report on the Internal Financial Controls over Financial Reporting under Section 143(3)(I) of The Companies Act, 2013 ("the Act")

We have audited the internal financial controls over financial reporting of Beryl Securities Limited ("the Company") as of 31st March, 2023 in conjunction with our audit of the Financial Statements (Ind AS) of the Company for the year ended on that date.

I. Managements Responsibility for Internal Financial Controls

The Companys management is responsible for establishing and maintaining internal financial controls based on the internal control over financial reporting criteria established by the Company considering the essential components of internal control stated in the Guidance Note on Audit of Internal Financial Controls Over Financial Reporting (the "Guidance Note") issued by the Institute of Chartered Accountants of India ("ICAI"). These responsibilities include the design, implementation and maintenance of adequate internal financial controls that were operating effectively for ensuring the orderly and efficient conduct of its business, including adherence to Companys policies, the safeguarding of its assets, the prevention and detection of frauds and errors, the accuracy and completeness of the accounting records, and the timely preparation of reliable financial information, as required under the Companies Act, 2013.

II. Auditors Responsibility for the Audit of Internal Financial Controls

Our responsibility is to express an opinion on the Companys internal financial controls over financial reporting based on our audit. We conducted our audit in accordance with the Guidance Note on audit of Internal financial controls over financial reporting (the "Guidance Note") and the Standards on Auditing issued by ICAI and deemed to have been prescribed under Section 143(10) of the Companies Act, 2013, to the extent applicable to an audit of internal financial controls, both applicable to an audit of Internal financial controls and, both issued by the Institute of Chartered Accountants of India. Those Standards and the Guidance Note require that we comply with ethical requirements and plan and perform the audit to obtain reasonable assurance about whether adequate internal financial controls over financial reporting was established and maintained and if such controls operated effectively in all material respects.

Our audit involves performing procedures to obtain audit evidence about the adequacy of the internal financial controls system over financial reporting and their operating effectiveness. Our audit of internal financial controls over financial reporting included obtaining an understanding of internal financial controls over financial reporting, assessing the risk that a material weakness exists, and testing and evaluating the design and operating effectiveness of internal control based on the assessed risk. The procedures selected depend on the auditors judgment, including the assessment of the risks of material misstatement of the standalone Ind AS financial statements, whether due to fraud or error.

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion on the Companys internal financial controls system over financial reporting.

III. Meaning of Internal Financial Controls Over Financial Reporting

A companys internal financial control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of Ind AS financial statements for external purposes in accordance with generally accepted accounting principles. A companys internal financial control over financial reporting includes those policies and procedures that

(1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the company;

(2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the company are being made only in accordance with authorizations of management and directors of the company; and

(3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of the companys assets that could have material effect on the financial statements.

IV. Inherent Limitations of Internal Financial Controls over Financial Reporting

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

V. Opinion

In our opinion, to the best of our information and according to the explanations given to us, the Company has, in all material respects, an adequate internal financial controls system over financial reporting and such internal financial controls over financial reporting were operating effectively as at 31st March, 2023, based on the internal control over financial reporting criteria established by the Company considering the essential components of internal control stated in the Guidance Note on audit of internal financial controls over financial reporting issued by the institute of chartered accountants of India ("ICAI") .

	For SUBHASH CHAND JAIN ANURAG & ASSOCIATES
	CHARTERED ACCOUNTANTS
	FRN-004733C
	(AKSHAY JAIN)
	PARTNER
Date : 27/05/2023	M.No. 447487
Place : Indore	UDIN:23447487BGUEBR9602