euro multivision ltd Auditors report

To

The Members of Euro Multivision Limited Report on the Audit of Financial Statements

Qualified Opinion

We have audited the accompanying financial statements of Euro Multivision Limited ("the Company"), which comprise the Balance Sheet as at March 31, 2022, the Statement of Profit and Loss (including Other Comprehensive

Income), the Statement of Cash Flows and the Statement of Changes in Equity for the year then ended and a summary of the significant accounting policies and other explanatory information.

In our opinion and to the best of our information and according to the explanations given to us, the aforesaid 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 the Act read with the Companies (Indian Accounting Standards) Rules, 2015, as amended and other accounting principles generally accepted in India, of the state of affairs of the Company as at March 31, 2022, the loss and total comprehensive income, changes in equity and its cash flows for the year ended on that date.

Basis for Qualified Opinion

Our audit opinion is Qualified for the following matters:

(a) The Company has been continuously incurring substantial losses since past few years. The Companys current liabilities exceed its current assets and further the net worth of the Company has been fully eroded, these events indicate a material uncertainty that casts a significant doubt on the Companys ability to continue as a going concern and therefore it may be unable to realize its assets and discharge its liabilities in the normal course of business. The financial statements do not disclose the fact that the fundamental accounting assumption of going concern has not been followed.

(b) We draw attention towards the fact that the Companys financial facilities/arrangements including Term

Loans, Working Capital Facilities and Non Fund Based Credit Facilities have expired and the accounts with the Banks have turned into Non Performing Assets.

The Company is unable to renegotiate, restructure or obtain replacement of financing arrangements and the banks have initiated legal proceedings for the recovery from the Company u/s. 19 of the Debt Recovery Tribunal (DRT), u/s. 13(2) of the Securitization & Reconstruction of Financial Assets & Enforcement of Security (Second) Interest (SARFAESI) Act, 2002. The Company has not provided for interest on its banking credit facilities amounting to Rs. 9767.65 lakhs, for the year ended March 31, 2022. Had the same been accounted for; the net loss (after tax) for the year ended March 31, 2022, would have increased by Rs. 9767.65 lakhs. Total amount which the Company has not recorded cumulatively upto March 31, 2022 amounted to Rs.63,541.20 lakhs.

(c) On November 27, 2019, the order of Debt Recovery Tribunal was passed, wherein it has been directed to the Company to clear dues amounting to Rs. 13,971.99 lakhs and interest and penalty within a period of 2 months from the date of order, failing which the Bank will be entitled to sell the hypothecated assets, mortgage properties and other personal movable and immovable properties of the Company and guarantors. The Company received a letter dated 25-Feb-2022, for e-auction of movable and immovable properties on 19-Apr-22. No communication has been received from Debt Recovery Tribunal or any other authority with respect to the same till the date of this report. Also, no action has been taken by the Company till the date of this report and consequential impact is unascertainable.

Application has been filed against the Company by one of the secured financial lender with The Honble

National Company Law Tribunal (NCLT), Mumbai Bench on June 18, 2020, to initiate Corporate Insolvency and Resolution Process (CIRP), which is pending for final hearing at NCLT. The consequential impact is unascertainable.

(d) Attention is also drawn to the fact that the Company has not provided for impairment or diminishing value of its assets/investment as per ‘Ind AS 36 Impairment of Assets as notified under Section 133 of the Companies Act, 2013. The effect of such Impairment or diminishing value has not been quantified by the management and hence the same is not ascertainable.

(e) We also draw attention to the fact of non-receipt of confirmations of balances from the Sundry Debtors, Deposit Accounts, Unsecured Loans, Loans & Advances, Investments, Banks, Sundry Creditors and other liabilities. Pending receipt of confirmation of these balances and consequential reconciliations / adjustments, if any, the resultant impact on the financial statements is not ascertainable.

(f) We draw attention to the fact towards the non-ascertainment of complete particulars of dues to Micro, Small and Medium enterprises, if any under MSMED Act, 2006, and provisions towards interest, if any, at this stage which is not in conformity with ‘Ind AS 37-Provision, Contingent Liabilities and Contingent Assets.

(g) Attention is drawn, regarding the fact that the Company for its Optical Discs manufacturing unit, had imported various Capital Goods under the Export Promotion Capital Goods Scheme (EPCG), of the

Government of India, through various licenses, at concessional rates of Custom Duty on an undertaking to fulfill quantified exports within a period of eight years from the date of issue of respective licenses. The Custom Duties so saved amounted to Rs. 2,538.56 lakhs and the corresponding Export obligation to be fulfilled amounted to Rs. 20,308.50 lakhs, however as on March 31, 2022, the Export obligation yet to be fulfilled amounted to Rs. 19,121.60 lakhs. The stipulated period of 8 years to fulfill Export obligation has already expired and the company is required to pay the said saved Custom Duty together with interest @ 15% p.a. but the same has not been provided in books of accounts by the Company and the final liability is presently unascertainable (h) Attention is drawn to the fact that, the Company Secretary had resigned from the Company and the

Company has not appointed any other person and the position stands vacant till the date of our report and therefore the company is not in compliance with Regulation 6 of LODR which requires Company Secretary to be appointed as Compliance Officer.

(i) Attention is also drawn, to the fact that, the Companys Solar Photovoltaic Cells manufacturing unit which is located in self-owned sector specific Special Economic Zone (SEZ). According to the SEZ Rules 2006, the units should have positive Net Foreign Exchange Earnings (NFE), which shall be calculated as per applicable rules in cumulative blocks of five years, starting from the commencement of production. The company could not achieve positive Net Foreign Exchange Earnings in the first block of five years, hence the Director General of Foreign Trade (DGFT) has imposed a penalty of Rs. 2,500.00 lakhs under Rule 54 of the SEZ Rules 2006, and the same has not been provided in books of accounts by the Company.

(j) We also draw attention towards the fact that, in respect of deposits accepted by the company before the commencement of this Act, within the meaning of section 74 & 75 of the Act and the Rules framed there under, the principal amount of such deposits and interest due thereon remained unpaid even after expiry of one year from such commencement and the Company had not filed a statement within a period of three months from such commencement or from the date on which such payments, were due, with the

Registrar, details as prescribed u/s.74(1)(a). Further no application has been made for extension of time with the National Company Law Tribunal u/s. 74(2) of the Companies Act, 2013 in this regards.

Further, the Company has deposits in contravention to Section 73 read with Section 76 of the Companies Act, 2013.

(k) We also draw your attention towards overdue receivables aggregating to Rs. 41.16 lakhs as on March 31, 2022, towards sale of goods included under "Trade Receivables" owed to the Company by its Foreign Customers due for more than 6 months as on March 31, 2022. These balances have not been settled till March 31, 2022. The Company is yet to make an application to the authorized dealer or Reserve Bank of India (RBI) for overdue receivable balances beyond the prescribed time limits in accordance with Foreign Exchange Management Act (FEMA). Any penalties that may be levied by RBI are presently not known and not given effect to in the IND AS financial statements.

Also, of the total amount receivable, as disclosed in the financial statement, amounting to Rs. 65.18 lakhs, provisions for doubtful debts have been created at Rs. 64.42 lakhs. The allowance for bad and doubtful debts have been made based on the estimates and best possible judgement of the Company.

The Expected Credit Loss Method as required under Ind AS 109, has not been followed while making provision for doubtful debts. Based on the above, we are unable to comment over the recoverability of trade receivables, provisioning and its overall impact on the financial results.

(l) We draw attention towards amounts aggregating to Rs. 37.91 lakhs disclosed under Trade Payables, in respect of purchase of raw materials, spares and consumables from entities outside India, which are outstanding for more than 6 months, which is not in compliance with the Regulations / Guidelines of the Foreign Exchange Management Act, 1999. Any penalties that may be levied by the Reserve Bank of India and/or any changes to the disclosure of the amounts in the financial results in this regard are not presently ascertainable.

(m) The Company has borrowings, which are repayable on demand, classified under Non-Current Financial

Liabilities, which are borrowed from various related parties and other lenders, the repayment terms of which have not been agreed between the Company and the lenders. The Company has not fair valued such sums received in accordance with the provisions of ‘Ind AS 109 Financial Instrument and ‘Ind AS 113 Fair Value Measurement. The impact has not been quantified by the management and hence the same is unascertainable.

(n) The Company has not obtained actuarial valuation report and had not made any provision for Gratuity and Leave Encashment for the year. The impact of such non-provisioning of liability is unascertainable on the financial statements accordingly relevant disclosures as required under Ind AS 15, Employees Benefit have not been given.

(o) The Company has on the basis of their internal evaluation, valued inventories at Rs. 16.67 lakhs. In the absence of valuation report or other documentary evidences confirming net realizable value of inventories, we are unable to comment on realization value of the inventories.

(p) The Company has Gratuity liability payable to the employees amounting to Rs. 32.93 lakhs, which are long outstanding. No interest has been provided by the Company over the same during the preparation of financial statements. The effect of such treatment has not been quantified by the management hence the same is not ascertainable.

(q) The system of Internal Financial Controls over financial reporting with regards to the Company were not made available to us to determine if the Company has established adequate internal financial control over financial reporting and whether such internal financial controls were operating effectively under Clause (i) of Sub-section 3 of Section 143 of the Companies Act, 2013. Refer to our separate report on Internal Financial Controls "Annexure B to Independent Auditor Report", where we have disclaimed our opinion.

(r) The Company has TDS demand outstanding amounting to Rs. 2.19 lakhs, pertaining to the previous financial years. The Company is in the process of ascertaining the liabilities and rectifying such returns, wherever required. No adjustment has been made for the said sums in the financial statements.

We conducted our audit of the financial statements in accordance with the Standards on Auditing 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 independence requirements that are relevant to our audit of the financial statements under the provisions of the Act and the Rules made thereunder, and we have fulfilled our other ethical responsibilities in accordance with these requirements and the ICAIs Code of Ethics. We believe that the audit evidences which we have obtained are sufficient and appropriate to provide a basis for our qualified opinion on the financial statements.

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 of the current period. These matters were addressed in the context of our audit of the financial statements as a whole, and in forming our opinion thereon, 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:

Sr. No.	Key Audit Matter	Auditors Response
i)	Evaluation of Uncertain Tax Positions	Our audit procedures includes:
	The Company has material uncertain tax positions in direct as well as indirect laws including matters under dispute which involves significant judgement to determine the possible outcome of the disputes.	• Obtained details of tax assessments from management and positions of legal and disputed matters.
	(Refer Accounting Policies and Note – 34 of the Financial Statements)	•We assessed the managements underlying assumptions in relation to estimating the probable cash outflow and possible outcome of the disputed matters lying with the tax authorities.
		• Discussed with tax consultants of the management about the implications and possibilities of outcome of various litigation matters.
		• Reviewed the disclosures of the litigation matters and impact on the financial statements.
		Considered the effect of new information in respect of uncertain tax positions as at April 1, 2022 to evaluate whether any change was required to managements position on the uncertainty.

Information Other than the Financial Statements and Auditors Report Thereon

The Companys Board of Directors is responsible for the other information. The other information comprises the information included in the Annual Report, but does not include the financial statements and our auditors report thereon. The annual report is expected to be made available to us after the date of this auditors report.

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 the 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 during the course of our audit or otherwise appears to be materially misstated. When we read the Annual Report, if we conclude that there is a material misstatement therein, we are required to communicate the matter to those charged with governance.

Managements Responsibility for the Ind AS Financial Statements

The Companys Board of Directors is responsible for the matters stated in Section 134(5) of the Companies Act, 2013 ("the Act") with respect to the preparation of these Ind AS financial statements to give a true and fair view of the financial position, financial performance including other comprehensive income, cash flows and changes in equity of the Company in accordance with the accounting principles generally accepted in India, including the Indian Accounting Standards ("Ind AS") specified in the Companies (Indian Accounting Standards) Rules, 2015 (as amended) under Section 133 of the Act.

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 Ind AS 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 is 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 management either intends to liquidate the Company or to cease operations, or has no realistic alternative but to do so.

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

Auditors Responsibility for Audit of 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 financial controls 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 system 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.

Materiality is the magnitude of misstatements in the financial statements that, individually or in aggregate, makes it probable that the economic decisions of a reasonably knowledgeable user of the financial statements may be influenced. We consider quantitative materiality and qualitative factors in (i) planning the scope of our audit work and in evaluating the results of our work; and (ii) to evaluate the effect of any identified misstatements in 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 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 determined 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.

Report on Other Legal and Regulatory Requirements

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

(a) We have sought and except for the possible effect of the matter described in the Basis of Qualified Opinion paragraph above, 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) Except for the possible effect of the matter described in the Basis of Qualified Opinion paragraph above, in our opinion, proper books of account as required by law have been kept by the Company so far as appears from our examination of those books;

(c) The Balance Sheet, the Statement of Profit and Loss (including other comprehensive income), the Statement of

Cash Flows and the Statement of Changes in Equity dealt with by this Report are in agreement with the books of account;

(d) Except for the possible effect of the matter described in the Basis of Qualified Opinion paragraph above, in our opinion, the aforesaid Ind AS financial statements comply with the Indian Accounting Standards specified under section 133 of the Act read with Rules issued thereunder;

(e) The matters described in the ‘Basis of Qualified Opinion paragraph above, in our opinion may have an adverse effect on the functioning of the Company;

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

(g) With respect to the adequacy of the internal financial controls over financial reporting of the Company and the operating effectiveness of such controls, refer to our separate Report in "Annexure B" dated May 25, 2022 where we have disclaimed our opinion; (h) With respect to the other matters to be included in the Auditors Report in accordance with the requirements of section 197(16) of the Act, as amended: In our opinion and to the best of our information and according to the explanations given to us, no remuneration is paid by the Company to its directors during the year and hence disclosure with respect to provisions of section 197 of the Act are not applicable to the Company.

(i) 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 knowledge and belief and according to the information and explanations given to us:

i. The Company has disclosed the impact, of pending litigations as at March 31, 2022 on its financial position in its financial statements; ii. The Company did not have any long-term contracts including derivative contracts as at March 31, 2022; and iii. There were no amounts required to be transferred to the Investor Education and Protection Fund by the Company during the year ended March 31, 2022; and iv. a) The management has represented that, to the best of its knowledge and belief, no funds have been advanced or loaned or invested (either from borrowed funds or share premium or any other sources or kinds of funds) by the company to or in any other person(s) or entities, including foreign entities

("Intermediaries"), with the understanding that the intermediary shall whether directly or indirectly lend or invest in other persons or entities identified in any manner by or on behalf of the company (Ultimate Beneficiaries) or provide any guarantee, security or the like on behalf of ultimate beneficiaries.

b) The management has represented, that, to the best of its knowledge and its belief, no funds have been received by the company from any person(s) or entities including foreign entities ("Funding Parties") with the understanding that such company shall whether, directly or indirectly, lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the funding party (ultimate beneficiaries) or provide guarantee, security or the like on behalf of the Ultimate beneficiaries. c) Based on audit procedures that were considered reasonable and appropriate in the circumstances, nothing has come to our notice that has caused us to believe that representations under sub clause (a) and (b) contain any material mis-statement. v. The Company has neither paid nor declared any dividend during the year.

2. As required by the Companies (Auditors Report) Order, 2016, issued by the Central Government of India in terms of sub-section (11) of section 143 of the Act ("the Order"), and on the basis of such checks of the books and records of the Company as we considered appropriate and according to the information and explanations given to us, we give in the "Annexure A" a statement on the matters specified in paragraphs 3 and 4 of the Order.

	For S.S. Singhvi & Associates
	Firm Registration Number: 114980W
	Chartered Accountants
	CA Ankit B. Rathi
Place: Surat	Partner
Date: 25th May, 2022	Membership Number: 164582
	UDIN : 22164582ANMBUA1056

Annexure - ‘A to the Independent Auditors Report

The Annexure ‘A referred to in our Independent Auditors Report to the members of the Company on the standalone Ind AS financial statements of Euro Multivision Limited for the year ended March 31, 2022, we report that: i. (a) (A) The Company has maintained proper records showing full particulars, including quantitative details and situation of its fixed assets.

(B) The Company has maintained proper records showing full particulars, of its intangible assets.

(b) The property, plant and equipment covering significant value were physically verified during the year by the management at such intervals which in our opinion, provides for the physical verification of all the property, plant and equipment at reasonable intervals having regard to the size of the Company and nature of its business. 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 and the records examined by us, we report that, the title deeds, comprising all the immovable properties of land and buildings, are held in the name of the Company as at the balance sheet date.

(d) The Company has not revalued its property, plant and equipment (including right of use of assets) or intangible asset of both during the financial year;

(e) No proceedings against the Company have been initiated or are pending against the Company for holding any benami property under the Benami Transactions (Prohibition) Act, 1988 (45 of 1988) and rules made thereunder. Therefore the provisions of Clause (i) (e) of Paragraph 3 of the order are not applicable to the Company.

ii. (a) In our opinion, the management has conducted physical verification of inventory at reasonable intervals during the year and no material discrepancies between physical inventory and book records were noticed on physical verification.

(b) The Company has working capital limits which were sanctioned in the earlier financial years, from banks, which were exceeding five crore rupees on the security of current assets of the Company. No quarterly returns / statements have been filed by the Company during the year with such banks. Also, The Company has defaulted in the repayment of such facilities, which has been mentioned in our audit report of the even date. iii. According to the information and explanation given to us, the Company has not made investments, provided security or granted any loans, secured or unsecured, to companies, firms or other parties covered in the register maintained under section 189 of the Act. Therefore, the provisions of clause 3(iii)(a) to 3(iii)(f) of the order are not applicable to the Company. iv. In our opinion and according to the information and explanation given to us, the Company has neither granted any loans nor provided any guarantees nor any securities in respect of any loans to any party covered under section 185 or section 186 of the Act.

v. In our opinion and according to the information and explanations given to us, the Company during the year has not accepted any deposits from the public within the meaning of section 73 & 76 of the Act and the Rules framed there under to the extent notified. However in respect of deposits accepted by the company before the commencement of this Act, within the meaning of section 74 & 75 of the Act and the Rules framed there under to the extent notified, the principal amount of such deposits and interest due thereon remained unpaid even after expiry of one year from such commencement and the Company had not filed a statement within a period of three months from such commencement or from the date on which such payments, were due, with the Registrar details as prescribed u/s.74(1)(a). Further no application has been made for extension of time with the National Company Law Tribunal u/s.74 (2) of the Companies Act, 2013 in this regards. vi. The Central Government has not specified maintenance of cost records under sub-Section (1) of Section 148 of the Act, in respect of Companys products. Accordingly, the provisions of clause 3(vi) of the Order are not applicable.

vii. (a) According to the information and explanation given to us and the records of the Company examined by us, in our opinion the Company has been facing liquidity stress since past few years due to which there were delays in depositing various undisputed statutory dues with appropriate authorities including income tax, duty of customs, goods and service tax, cess and other material statutory dues, as applicable. There were delays in depositing professional tax with the authorities amounting to Rs. 0.07 lakhs as on the year ending. No other statutory dues was outstanding as at the last day of the financial year concerned for a period of more than six months from the date they become payable, except for professional tax.

(b) According to the information and explanation given to us and the records of the Company examined by us, there are no dues of income tax, goods and service tax, duty of customs, as at March 31, 2022, which have not been deposited on account of any dispute, except the following:

Sr. No.	Dispute Pending Under	Year of Dispute	Authority Where Dispute Is Pending	Amount Disputed (Rs. In Lakhs)
1.	Rule 54 of SEZ Rules 2006	Block of 5 years from 2010 - 2015	The Honble Secretary, Ministry of Commerce, New Delhi	2500.00
2.	Foreign Trade Policy 2004-2009	2004-2007	DGFT, New Delhi	2538.56
3.	Income Tax Act, 1961	AY 2009-10	Assessing Officer	34.50
4.	Income Tax Act, 1961	AY 2012-13	Assessing Officer	43.08

viii. According to the information and explanations given to us, there are no transactions which are not accounted in the books of account which have been surrendered or disclosed as income during the year in Tax Assessment of the Company. Also, there are no previously unrecorded income which has been now recorded in the books of account. Hence, the provision stated in paragraph 3(viii) of the Order is not applicable to the Company.

ix. (a) In our opinion and according to the information and explanations given to us the Company has defaulted in repayment of loans and interests dues to the banks. The bank lenders have initiated legal proceedings against the Company for recovery of their respective debts at the Debt Recovery Tribunal and have taken symbolic possession of the securities u/s. 13(4) of the SARFAESI Act, 2002.

Name of the Bank	Principal Outstanding	Interest Outstanding	Default since
	(Rs. in Lakhs)	(Rs. in Lakhs)
State Bank of India	12391.62	41746.64	April 2011
The Cosmos Co-Op Bank Ltd	7915.88	21794.55	January 2011
Total	20307.50	63541.19

(b) According to the information and explanations given to us and on the basis of our audit procedures, we report that the company has been declared wilful defaulter by lender banks.

(c) According to the information and explanations given to us and on the basis of our audit procedures, no loans have been obtained during the year, therefore reporting under Clause 3 (ix) (c) of the order is not applicable. However, the Company had obtained Term loans, Working Capital and other facilities which are currently under default and not repaid by the Company. On enquiry from the management, they have confirmed that the funds were obtained during the earlier years and were applied for the purposes for which they were obtained. (d) According to the information and explanations given to us and on the basis of our audit procedures, no loans have been obtained during the year, therefore reporting under Clause 3 (ix) (d) of the order is not applicable.

(e) The Company does not have any subsidiary, associate or joint venture, hence reporting under the clause 3 (ix) (e) and 3 (ix) (f) of the order is not applicable to the Company. x. (a) The Company did not raise any money by way of initial public offer or further public offer (including debt instruments) during the year. Accordingly, the provisions stated in paragraph 3 (x)(a) of the Order are not applicable to the Company.

(b) According to the information and explanations given to us and based on our examination of the records of the Company, the Company has not made any preferential allotment or private placement of shares or fully, partly or optionally convertible debentures during the year. Accordingly, the provisions stated in paragraph 3 (x)(b) of the Order are not applicable to the Company.

xi. (a) During the course of our audit, examination of the books and records of the Company, carried out in accordance with the generally accepted auditing practices in India, and according to the information and explanations given to us, we have neither come across any instance of fraud by the Company nor on the Company.

(b) We have not come across of any instance of fraud by the Company or on the Company during the course of audit of the financial statement for the year ended March 31, 2022, accordingly the provisions stated in paragraph

(xi)

(b) of the Order is not applicable to the Company.

(c) As represented to us by the management, there are no whistle-blower complaints received by the Company during the year. Accordingly, the provisions stated in paragraph (xi)(c) of the Order is not applicable to company. xii. In our opinion and according to the information and explanations given to us, the Company is not a Nidhi Company. Accordingly, the provisions stated in paragraph 3(xii) (a) to (c) of the Order are not applicable to the Company. xiii. In our opinion and according to the information and explanations given to us the Company is in compliance with Section 177 and 188 of the Act, where applicable, for all transactions with the related parties and the details of related party transactions have been disclosed in the financial statements as required by the applicable Ind AS.

xiv. (a) The Company has internal audit system in place which commensurate with the size of business and nature of its business.

(b) The report of internal auditor were considered by the Statutory Auditors of the Company. xv. In our opinion and according to the information and explanations given to us, during the year the Company has not entered into any non-cash transactions with its Directors or persons connected to its Directors and hence provisions of Section 192 of the Act are not applicable. Accordingly, the provisions stated in paragraph 3(xv) of the Order are not applicable to the Company. xvi. (a) The company is not required to be registered under Section 45 IA of the Reserve Bank of India Act, 1934 and hence reporting under clause 3 (xvi) of the Order are not applicable to the Company.

(b) In our opinion, the Company has not conducted any Non-Banking Financial or Housing Finance activities without any valid Certificate of Registration from Reserve Bank of India. Hence, the reporting under paragraph clause 3

(xvi)(b) of the Order are not applicable to the Company.

(c) The Company is not a Core investment Company (CIC) as defined in the regulations made by Reserve Bank of

India. Hence, the reporting under paragraph clause 3 (xvi)(c) of the Order are not applicable to the Company. (d) The Company does not have any CIC as part of its group. Hence the provisions stated in paragraph clause 3 (xvi) (d) of the order are not applicable to the company. xvii. Based on the overall review of financial statements, the Company has incurred cash losses in the current financial year and in the immediately preceding financial year. The details of the same are as follows:

Particulars	March 31, 2022	March 31, 2021
	(Rs. in Lakhs)	(Rs. in Lakhs)
Cash Loss	40.20	31.82

xviii. There has been no resignation of the statutory auditors during the year. Hence, the provisions stated in paragraph clause 3 (xviii) of the Order are not applicable to the Company. xix. According to the information and explanations given to us and based on our examination of financial ratios, ageing and expected date of realisation of financial assets and payment of liabilities, other information accompanying the financial statements, our knowledge of the Board of Directors and management plans, we are of the opinion that a material uncertainty exists as on the date of audit report. The Company may not be 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. Also, we have qualified our opinion on the Going Concern Basis of the Company as the Company has been unable to meet its liabilities in the past and defaulted dues payable to its financial lenders.

xx. According to the information and explanations given to us, the provisions of section 135 of the Act are not applicable to the Company. Hence, the provisions of Clause 3 (xx)(a) to (b) of the Order are not applicable to the Company. xxi. According to the information and explanations given to us, the Company does not have any Subsidiary, Associate or Joint Venture. Accordingly, reporting under clause 3(xxi) of the Order is not applicable

	For S.S. Singhvi & Associates
	Firm Registration Number: 114980W
	Chartered Accountants
	CA Ankit B. Rathi
Place: Surat	Partner
Date: 25th May, 2022	Membership Number: 164582

Annexure – ‘B to the Independent Auditors Report

Referred to in paragraph 2(g) of the Independent Auditors Report of even date to the Members of Euro Multivision Limited on standalone financial statement for the year ended March 31, 2022

Report on the Internal Financial Controls under Clause (i) of Sub-section 3 of Section 143 of the Companies Act, 2013 ("the Act")

We have audited the internal financial controls over financial reporting of Euro Multivision Limited ("the Company") as of March 31, 2022 in conjunction with our audit of the financial statements of the Company for the year ended on that date.

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 ("the Act").

Auditors Responsibility

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 and the Standards on Auditing, issued by ICAI and deemed to be 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 all material respects.

Because of the matter described in Basis for Disclaimer of Opinion paragraph below, we were not able to obtain sufficient appropriate audit evidence to provide a basis for an audit opinion on internal financial controls system financial reporting of the Company.

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 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 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 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.

Basis for Disclaimer of Opinion

According to the information and explanations given to us, the Company has not established its internal financial control over financial reporting on criteria based on or 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.

Disclaimer of Opinion

Because of the significance of the matter described in the Basis for Disclaimer of Opinion paragraph above, we are unable to obtain sufficient appropriate audit evidence to provide a basis for our opinion whether the Company had adequate internal financial controls over financial reporting and whether such internal financial controls were operating effectively as at March 31, 2022. According we do not express an opinion on the Companys internal control over financial reporting.

We have considered the disclaimer reported above in determining the nature, timing, and extent of audit tests applied in our audit of the financial statements of the Company for the year ended March 31, 2022, and the disclaimer does not affect our opinion on the financial statements of the Company.

	For S.S. Singhvi & Associates
	Firm Registration Number: 114980W
	Chartered Accountants
	CA Ankit B. Rathi
Place: Surat	Partner
Date: 25th May, 2022	Membership Number: 164582