steel strips ltd Directors report

To The Members,

Your Directors are pleased to present the 43rd Annual Report together with the audited accounts of the Company for the year ended March 31, 2020.

FINANCIAL HIGHLIGHTS

PARTICULARS	2019-20	2018-19
Revenue from Operations	-	-
Other Income	0.22	280.12
Total Revenue	0.22	280.12
Pro t before Exceptional item, depreciation, interest & Tax (PBDIT)	-98.55	227.15
Interest & other financial expenses	-	-
Depreciation and amortization expenses	-	-
Pro t before Tax (PBT)	-98.55	227.15
Tax Expenses- Current / Deferred	-	18.00
Pro t after Tax (PAT)	-98.55	209.15
Other Comprehensive Income	-	-
Total Comprehensive	-98.55	209.15
Income for the period
Earning per share-Basic/ Diluted	-1.19	2.52

Note: The financial statements of the Company for the year ended 31st March, 2020, are prepared in accordance with Indian Accounting Standards (Ind AS).

During the year under review, the operations continued to be inoperative. The Company earned other income of R0.22 lakhs as against other income of R280.12 lakhs in previous year earned on account of Settlement of claims with Debtors and written o other liabilities. After accounting for Financial Cost and Other Expenses, the Company has incurred a net loss of R98.55 lakhs during the year under review as against a net profit of R209.15 lakhs during the previous year.

IMPACT OF COVID-19 PANDEMIC

In the last month of FY 2020, the COVID-19 pandemic developed rapidly into a global crisis, forcing governments to enforce lock-downs of all economic activity. For the Company, the focus immediately shifted to ensuring the health and well-being of all employees. The Company is sensitive about the impact of the Pandemic which will be realized only over next few months. The Company has been monitoring the situation closely and has taken proactive measures to comply with various directions/ regulations/ guidelines issued by the Government and local bodies to ensure safety of workforce across its workplace.

FINANCIAL STATUS

There is no change in ued and subscribed capital of R828.31 lakhs. There are no equity shares with differential rights or sweat equity or ESOP or scheme of purchase of Company shares by employees or their trustees.

SCHEME OF AMALGAMATION

The proposed Scheme for Amalgamation of Steel Strips Limited (Transferor Company) with SAB Industries Ltd. (Transferee Company) has been approved by BSE vide its Observation Letter No. DCS/AMAL/ BA/R37/1572/2019-20 dated 12th September, 2019. The Company has also led merger petition under Section 230 to Section 232 and other applicable rules and provisions under Companies Act, 2013 with National Company Law Tribunal (NCLT), Chandigarh Bench on 26th September 2019. NCLT vide its order dated June 12, 2020 has directed to convene meeting of shareholders at the Registered officeof the Company on 29.08.2020 for their approval on the scheme.

DIVIDEND

As Company does not have any distributable profits computed under provisions of Companies Act, 2013, no dividend is being recommended.

FIXED DEPOSITS

The Company has not accepted any fixed deposits during the year under review.

OPERATIONS

The Company did not have any manufacturing activity. Your Directors have to state that the Company has led suits for recovery against certain debtors, suppliers and others, who have also led counter claims against the Company. The claims against the Company, which amount to R 376.75 lakhs (Previous year R 376.75 lakhs), have been stayed in the courts U/S 22 of Sick Industrial Companies Special Provisions Act, 1985 or under Section 10 of Code of Civil Procedure Act. Your Directors are con dent that no liability will arise on the Company on this account. Accordingly, no provision for the same has been made in the books of accounts.

MATERIAL CHANGES AND COMMITMENTS, IF ANY, AFFECTING THE FINANCIAL POSITION OF THE COMPANY

There are no significant and material changes occurred subsequent to the close of the financial year to which the Financial Statements relate and up to the date of report that would impact the going concern status of the Company and its future operations.

CORPORATE SOCIAL RESPONSIBILITY AND GOVERNANCE COMMITTEE

Since the Company does not have net profits in any financial year in accordance with Section 135 of the Companies Act, 2013, the Company is not required to undertake any activity under CSR Rules.

DETAILS OF SUBSIDIARY, JOINT VENTURES OR ASSOCIATE COMPANY

The Company is not having any Joint Venture, Associate Company or Subsidiary Company reportable under Section 129(3) of the Companies Act, 2013.

CORPORATE GOVERNANCE REPORT- DISCLOSURE REQUIREMENTS

As prescribed in Regulation 15(2) of SEBI (LODR) Regulations, 2015 compliance of corporate governance provisions is not applicable to the Company. However, as a good practice taking steps to maintain transparency, accountability and equity in order to improve its dealings with all concerned, The Company not only complies with the regulatory requirements but is also responsive to the stakeholders as well as associates needs. The Company already has an Audit Committee, a Stakeholder Relationship Committee and Nomination and Remuneration Committee duly constituted by the Board to look after various activities. The Corporate Governance practices followed by the Company are enclosed as Annexure to this report.

MANAGEMENT DISCUSSION AND ANALYSIS

The Company is not having any manufacturing activity for any article covered by Schedule-1 of the IDR Act.

ANNUAL RETURN

The extract of the annual return as provided under Section

92(3) of the Act, in Form MGT-9, is attached and forms part of this report.

DIRECTORS RESPONSIBILITY STATEMENT

Pursuant to Section 134(5) of the Companies Act, 2013, the Directors con rm that: a. in preparation of the annual accounts for the year ending 31st March, 2020, the applicable accounting standards had been followed along with proper explanation relating to material departures, if any. b. the Directors had selected such accounting policies and applied them consistently and made judgments and estimates that are reasonable and prudent so as to give a true and fair view of the state of a airs of the Company at the end of the financial year and of the profit and loss of the Company for that period; c. the Directors had taken proper and sufficient care for the maintenance of adequate accounting records in accordance with the provisions of this Act for safeguarding the assets of the Company and for preventing and detecting fraud and other irregularities; d. the Directors had prepared the annual accounts on a going concern basis; and e. the Directors had laid down internal financial control to be followed by the Company and that such internal financial controls were adequate and were operating effectively. f. the Directors had devised proper systems to ensure compliance with the provisions of all applicable laws and that such systems were adequate and operating effectively.

INTERNAL FINANCIAL CONTROL SYSTEMS AND THEIR ADEQUACY

The internal control systems and processes of the Company cover operational efficiency, accuracy and promptness in financial reporting, compliance with laws and regulations and development of mature, disciplined and effective processes. The processes are also designed to meet the goals of cost, schedule, functionality and quality, thus resulting in higher levels of customer satisfaction.

An independent Audit Committee of the Board reviews the adequacy of internal controls.

DIRECTORS

A) hanges in Directors and Key Managerial Personnel

Since the last Annual General Meeting, there are no changes in the Board of Directors of the Company. As per the provisions of Companies Act, 2013, Shri Rajinder Kumar Garg (DIN-00034827), retires by rotation at the forthcoming Annual General Meeting and, being eligible, offers himself for re-appointment.

B) Declaration by an Independent Director(s) and reappointment, if any.

A declaration by Independent Directors stating that he/they meet the criteria of independence as provided in Sub-section (6) of Section 149 of the Companies Act, 2013 has been taken at the time of their appointment.

C) Formal Annual Evaluation

The Board of Directors has carried out an annual evaluation of its own performance, Board committees and individual directors pursuant to the provisions of the Act and the corporate governance requirements as prescribed by Securities and Exchange Board of India ("SEBI") under LODR Regulations, 2015.

The performance of the Board was evaluated by the Board after seeking inputs from all the directors on the basis of the criteria such as the Board composition and structure, effectiveness of board processes, information and functioning, etc.

The performance of the committees was evaluated by the Board after seeking inputs from the committee members on the basis of the criteria such as composition of committees, effectiveness of committee meetings, etc.

The Board and the Nomination and Remuneration Committee ("NRC") reviewed the performance of the individual directors on the basis of the criteria such as the contribution of the individual director to the Board and committee meetings like preparedness on the issue to be discussed, meaningful and constructive contribution and inputs in meetings etc. In addition, the Chairman was also evaluated on the key aspects of his role.

In a separate meeting of Independent Directors, performance of non-independent directors, performance of the board as a whole and performance of the Chairman was evaluated, taking into account the views of executive directors and non-executive directors, The same was discussed in the Board meeting, at which the performance of the Board, its committees and individual directors was also discussed.

NUMBER OF MEETINGS OF THE BOARD OF DIRECTORS

During the year under review, 5 Board Meetings were held, one each on 30th May 2019, 2nd July, 2019, 14th August, 2019,14th November 2019 and 10th February 2020.

POLICY ON DIRECTORS APPOINTMENT AND REMUNERATION AND OTHER DETAILS

The Companys policy on Directors appointment and remuneration and other matters provided in Section 178(3) of the Act has been disclosed in the corporate governance report, which forms part of the Directors Report.

AUDIT COMMITTEE

The Audit & Compliance Committee comprises of three non-executive Independent Directors viz. Shri S S Virdi, Shri M M Chopra and Smt. Manju Lakhanpal and one Non-executive Director, Shri H K Singhal. During the year, the committee held five meetings. Other details of the Audit Committee are included in the Corporate Governance Report which forms part of this report.

The Board had accepted all recommendation of the Audit Committee.

DETAILS OF ESTABLISHMENT OF VIGIL MECHANISM/ WHISTLE BLOWER POLICY FOR DIRECTORS AND EMPLOYEES

The Company has formulated and published a Whistle Blower Policy to provide vigil mechanism for employees including Directors of the Company to report genuine concerns. The provisions of this Policy are in line with the provisions of Section 177(9) of the Act and Regulation 22 of SEBI (LODR) Regulations, 2015.

There are no cases reported during the year.

NOMINATION AND REMUNERATION COMMITTEE

The committee has been constituted to review and recommend compensation payable to the whole-time directors including Chairman and senior management of the Company. The committee reviews the overall compensation structure and policies of the Company with a view to attract, retain and motivate employees, reviewing compensation levels of the Company vis-a-vis other Companies and industry in general. The "Nomination & Remuneration Policy" may be accessed on the Companys website at http//www.sslindia.net

PARTICULARS OF LOANS, GUARANTEES OR INVESTMENTS UNDER SECTION 186

There were no Loans/ Guarantee given or Investments made by the Company during the year exceeding the limits prescribed under section 186 of Companies Act, 2013.

PARTICULARS OF CONTRACTS OR ARRANGEMENTS WITH RELATED PARTIES: All contracts /arrangements/transactions entered by the company during the financial year with related parties were in the ordinary course of business and on an arms length basis, During the year, the Company had not entered into any contract/arrangement/transaction with related parties which could be considered material in accordance with the policy of the Company on materiality of related party transactions. The policy on materiality of Related Party Transactions and dealing with related party transactions as approved by the Board is uploaded on the Website of the Company.

Disclosures as required under Indian Accounting Standards (Ind AS-24) have been made in the financial statements of the company, enclosed with this report.

BUSINESS RISK MANAGEMENT

The Company has policy to regularly review the payments of Creditors and statutory dues etc. and manage its cash flow activity from time to time. As such the Company su ers no risk, if any, which may threaten the existence of the Company.

AUDITORS

As per the Provisions of Section 139 of Companies Act, 2013, M/s AKR & Associates, Chartered Accountants, were appointed as Statutory Auditors of the Company to hold officetill the conclusion of Annual General Meeting to be held in the calendar year 2022 (subject to rati cation of their appointment at every AGM). The Company has received a certificate from them pursuant to Companies (Audit & Auditors) Rules 2014 read with Section 139 & 141 of the Companies Act, 2013, confirming their eligibility for reappointment, and that they were not disqualified for reappointment.

In accordance with the Companies (Amendment) Act, 2017, enforced on 7th May, 2018 by the Ministry of Corporate A airs, the appointment of Statutory Auditors is not required to be ratified at every Annual General Meeting.

AUDITORS REPORT AND SECRETARIAL AUDITORS REPORT

The Auditors Report and Secretarial Auditors Report do not contain any quali cations, reservations or adverse remarks. Report of Secretarial Auditor is attached as an annexure which forms part of this report.

LISTING OF SHARES

Equity shares of the Company are listed on Bombay Stock Exchange. BSE has revoked suspension of trading of its Equity Shares on 14th May 2019 and trading in equity shares has been resumed from 22nd May 2019.

DEMATERIALISATION

Shares of the company are available for dematerialization for

6 the investors. ISIN of the Company has been activated by Central Depository Services Limited (CDSL) on 10.10.2018 and the National Depository Services Limited (NSDL) on 19.10.2018. As on 31.03.2020, 5918795 shares (71.46%) of the shares of Company are held under Demat inculding that 2768775 shares (33.43%) of promoters. ISIN number allotted to the Company is INE01RN01014.

INSURANCE

All the assets of the Company have been adequately insured.

PARTICULARS OF EMPLOYEES

Relations with the employees during the period under review continued to be peaceful and harmonious.

PERSONNEL AND RELATED DISCLOSURES

The information required under Section 197 of the Act read with rule 5 of the Companies (Appointment and remuneration of managerial personnel) rules 2014 is enclosed with this report. The Board expresses deep appreciation of employees for their support.

HEALTH, SAFETY AND ENVIRONMENT PROTECTION

Our Company has complied with all the applicable health & Safety standards, environment laws and labour laws and has been taking all necessary measures to protect the environment and provide workers a safe work environment. Our Company is committed for continual improvement in Health & Safety as well as Environmental performance by involving all the employees to provide a Safe & healthy work environment to all its employees

DISCLOSURE AS PER SEXUAL HARASSMENT OF WOMEN AT WORK PLACE (PREVENTION, PROHIBITION AND REDRESSAL) ACT, 2013

The Company has adopted a policy against sexual harassment in line with the provisions of Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and the rules framed thereunder. During the financial year 2019-20, the Company has not received any complaint on sexual harassment and hence no complaints remain pending as on 31st March, 2020.

CONSERVATION OF ENERGY, TECHNOLOGY ABSORPTION AND FOREIGN EXCHANGE EARNINGS AND OUTGO

Information in accordance with the provisions of Section 134(3) (m) of the Companies Act, 2013 regarding Conservation of Energy, Technology Absorption and Foreign Exchange Earnings and Outgo is not applicable as the Company did not have any manufacturing facility during the period under consideration. There were no foreign exchange earnings/ outgo during the period.

ACKNOWLEDGEMENT

Your Directors acknowledge with gratitude the assistance, cooperation and support received by the Company from Statutory/ Govt. Bodies, Customers and Shareholders of the Company.

For and on behalf of Board
S. S. VIRDI	SANJAY GARG
Director	Executive Director
DIN-00035408	DIN-00030956

Place: Chandigarh

Date : 30th June 2020

FORM NO. MGT 9

EXTRACT OF ANNUAL RETURN

As on financial year ended on 31.03.2020

Pursuant to Section 92 (3) of the Companies Act, 2013 and rule 12(1) of the Company (Management & Administration) Rules,2014 I. REGISTRATION & OTHER DETAILS:

i. CIN	L45202PB1975PLC003610
ii. Registration Date	23/12/1975
iii. Name of the Company	STEEL STRIPS LIMITED
iv. Category/Sub-category of the Company	PUBLIC LIMITED
v. Address of the Registered office & contact details	VILLAGE HARKISHANPURA, BHAWANIGARH TEHSIL, DISTT. SANGRUR (PB) 148026.
	TEL:+91-01672-278106, 278104
	FAX: +91-01672-278110
vi. Whether listed company	LISTED COMPANY
vii. Name, Address & contact details of the Registrar & Transfer Agent, if any.	SKYLINE FINANCIAL SERVICES PVT. LTD.,
	D-153/A, 1 FLOOR, OKHLA INDUSTRIAL AREA, PHASE-1,
	NEW DELHI-110020.
	PHONE: 011-26812682-83

II. PRINCIPALBUSINESS ACTIVITIES OF THE COMPANY

(All the business activities contributing 10 % or more of the total turnover of the company shall be stated) The Company did not have any manufacturing activity.

III. PARTICULARS OF HOLDING, SUBSIDIARY AND ASSOCIATE COMPANIES

The company has no holding, subsidiary or associate company holding at least twenty percent of total share capital of the company.

IV. SHARE HOLDING PATTERN (Equity Share Capital Breakup as percentage of Total Equity)

(i) Category-wise Share Holding

Category of Shareholders	No. of Shares held at the beginning of the year [As on 01-April-2019]				No. of Shares held at the end of the year [As on 31-March-2020]				% Change during the year
	Demat	Physical	Total	% of Total Shares	Demat	Physical	Total	% of Total Shares
A. Promoters
(1) Indian
a) Individual/ HUF	505285	-	505285	6.10	505285	-	505285	6.10	-
	-	-	-	-	-	-	-	-	-
b) Central Govt
c) State Govt(s)
d) Bodies Corp.	2263490		2263490	27.33	2263490	-	2263490	27.33	-
e) Banks / FI
f) Any other
Total shareholding of	2768775	-	2768775	33.43	2768775	-	2768775	33.43	-
Promoter (A)
B.Public Shareholding
1. Institutions
a) Mutual Funds	-	4570	4570	0.05		4570	4570	0.05	-
b) Banks / FI	-	900	900	0.01	-	900	900	0.01	-
c) Central Govt
d) State Govt(s)
e) Venture CapitalFunds
f) Insurance Companies	437901	800	438701	5.30	437901	800	438701	5.30	-
g) FIIs
h) Foreign Venture
Capital Funds
i) Others (specify)
Sub-total (B)(1):-	437901	6270	444171	5.36	437901	6270	444171	5.36	-

Category of Shareholders	No. of Shares held at the beginning of the year [As on 01April-2019]				No. of Shares held at the end of the year [As on 31 March-2020]				% Change during the year
	Demat	Physical	Total	% of Total Shares	Demat	Physical	Total	% of Total Shares
2. Non-Institutions
a) Bodies Corp.	1656775	1062600	2719375	32.83	2674376	45049	2719425	32.83	-
i) Indian
ii) Overseas
b) Individuals
i) Individual
Shareholders
Holding nominal share capital
upto R2 lakhs	24810	2325972	2350782	28.38	37743	2312989	2350732	28.38	-
ii) Individual shareholders holding nominal share capital in excess of R 2. lakhs	-				-				-
c) Others (specify)
Non Resident Indians					-				-
	-
Overseas Corporate
Bodies
Foreign Nationals
Clearing Members
Trusts
Foreign Bodies - D R Sub total (B)(2):	1681585	3388572	5070157	61.21	2712119	2358038	5070157	61.21	-
Total Public	2119486	3394842	5514328	66.57	3150020	2364308	5514328	66.57	-
Shareholding
(B)=(B)(1)+ (B)(2)
C. Shares held by Custodian for GDRs & ADRs
Grand Total (A+B+C)	4888261	3394842	8283103	100	5918795	2364308	8283103	100	-

ii) Shareholding of promotor

S.No. Shareholders Name	Shareholding at the beginning of the year			Shareholding at the end of the year			% change in shareholding during the year
	No. of Shales	% of total Shares of the company	%of Shares Pledged / encumbered to total shares	No. of Shares	% of total Shares of the company	%of Shares Pledged / encumbered to total shares
1 Shri R K Garg	451300	5.45	-	451300	5.45	-	-
2 Shri R K Garg & Sons (HUF)	250	0.00		250	0.00
3 Smt. Sunena Garg	4690	0.06		4690	0.06	-	-
4 Shri Dheeraj Garg	31175	0.38	-	31175	0.38	-	-
5 Ms. Priya Garg	17870	0.22	-	17870	0.22	-	-
6 Sab Industries Ltd.	885934	8.28	-	685934	8.28	-	-
7 Sab Udyog Ltd.	953395	11.51	-	953395	11.51	-	-
8 Steel Strips Mercantile Pvt. Ltd.	11625	0.14		11625	0.14	.	.
9 Steel Strips Financiers Pvt. Ltd.	6075	0.07	_	6075	0.07	_	_
10 Munak International Pvt. Ltd.	97600	1.18		97600	1.18
11 S S Credits Pvt. Ltd.	150	0.00	-	150	0.00	-	-
12 S J Mercantile Pvt. Ltd.	1165	U.U1	-	1165	0.01	-	-
13 Malwa Holding Pvt. Ltd.	1563	0.02		1563	0.02
14 Steel Strips Holding Pvt. Ltd.	8033	0.10	-	8033	0.10	-	-
15 Steel Strips Industries Ltd.	83325	1.01	-	83325	1.01	-	-
16 Munak Financiers Pvt. Ltd.	5625	0.07	-	5625	0.07	-	-
17 Steel Strips Infrastructures Ltd	409000	4.94		409000	4.94	"	-
	2768775	33.43	-	2768775	33.43	-	-

(III) Change In Promoters Shareholding (please specify, If there is no change)

There is no change in promoters shareholding during the year.

(Iv) Shareholding Pattern of top ten Shareholders (Other than Directors, Promoters and Holders of GDRs

andADRs):

S.No. Top 10 Shareholders*	Shareholding at the beginning of the year		Cumulative Shareholding end of the year
	No. Of Shares	% of total shares of the company	No. Of Shares	% of total shares of the company
1. Steel Strips Wheels Invt. Ltd.	413000	4.99	413000	4.99
2. 3a Capital Services Ltd.	752901	9.09	753101	9.09
3. Life Insurance Corpn. of India	424701	5.13	424701	5.13
4. Priya Tools Pvt. Ltd	825100	9.96	825100	9.96
5. Bloomen Flora Ltd.	826000	9.97	417000	5.03
6. APS Investments Pvt. Ltd.	264400	3.19	264400	3.19
7. Jagman Singh	15100	0.18	15100	0.18
8. Narendra C Malia	15000	0.18	15000	0.18
9. Gen. Insurance Corpn. of India	11409	0.14	11409	0.14
10. Umesh Mehta	11100	0.13	11100	0.13

The shares of the Company are not/infrequently traded on a daily basis and hence the date wise increase/ decrease in shareholding is not indicated.

(v) Shareholding of Directors and Key Managerial Personnel:

S.No. Folio/Beni ciary Account No.	Name of the Share Holder	Date	Reason	Shareholding at the beginning of the year		Cumulative Shareholding during the year
				No. of shares	% of total shares of the company	No. of shares	% of total shares of the company
1. IN300476 10368502	Sh. R K Garg	01.04.2019	At the beginning of the year	451300	5.45	451300	5.45
		31.03.2020	At the end of the year.	451300	5.45	-do-	-do-
2. 44221	Sh. Sanjay Garg	01.04.2019	At the beginning of the year	200	0.00	200	0.00
		31.03.2020	At the end of the year	200	0.00	-do-	-do-
3. 11984	Sh. H K Singhal	01.04.2019	At the beginning of the year	1250	0.01	1250	0.01
		31.03.2020	At the end of the year	1250	0.01	-do-	-do-

V. INDEBTEDNESS -Indebtedness of the Company including interest outstanding/accrued but not due for payment.

NIL

VI. REMUNERATION OF DIRECTORS AND KEY MANAGERIAL PERSONNEL

ii) Shareholding of promotor

S.No. Shareholders Name	Shareholding at the beginning of the year			Shareholding at the end of the year			% change in shareholding during the year
	No. of Shales	% of total Shares of the company	%of Shares Pledged / encumbered to total shares	No. of Shares	% of total Shares of the company	%of Shares Pledged / encumbered to total shares
1 Shri R K Garg	451300	5.45	-	451300	5.45	-	-
2 Shri R K Garg & Sons (HUF)	250	0.00		250	0.00
3 Smt. Sunena Garg	4690	0.06		4690	0.06	-	-
4 Shri Dheeraj Garg	31175	0.38	-	31175	0.38	-	-
5 Ms. Priya Garg	17870	0.22	-	17870	0.22	-	-
6 Sab Industries Ltd.	885934	8.28	-	685934	8.28	-	-
7 Sab Udyog Ltd.	953395	11.51	-	953395	11.51	-	-
8 Steel Strips Mercantile Pvt. Ltd.	11625	0.14		11625	0.14	.	.
9 Steel Strips Financiers Pvt. Ltd.	6075	0.07	_	6075	0.07	_	_
10 Munak International Pvt. Ltd.	97600	1.18		97600	1.18
11 S S Credits Pvt. Ltd.	150	0.00	-	150	0.00	-	-
12 S J Mercantile Pvt. Ltd.	1165	U.U1	-	1165	0.01	-	-
13 Malwa Holding Pvt. Ltd.	1563	0.02		1563	0.02
14 Steel Strips Holding Pvt. Ltd.	8033	0.10	-	8033	0.10	-	-
15 Steel Strips Industries Ltd.	83325	1.01	-	83325	1.01	-	-
16 Munak Financiers Pvt. Ltd.	5625	0.07	-	5625	0.07	-	-
17 Steel Strips Infrastructures Ltd	409000	4.94		409000	4.94	"	-
	2768775	33.43	-	2768775	33.43	-	-

(III) Change In Promoters Shareholding (please specify, If there is no change)

There is no change in promoters shareholding during the year.

(Iv) Shareholding Pattern of top ten Shareholders (Other than Directors, Promoters and Holders of GDRs

andADRs):

S.No. Top 10 Shareholders*	Shareholding at the beginning of the year		Cumulative Shareholding end of the year
	No. Of Shares	% of total shares of the company	No. Of Shares	% of total shares of the company
1. Steel Strips Wheels Invt. Ltd.	413000	4.99	413000	4.99
2. 3a Capital Services Ltd.	752901	9.09	753101	9.09
3. Life Insurance Corpn. of India	424701	5.13	424701	5.13
4. Priya Tools Pvt. Ltd	825100	9.96	825100	9.96
5. Bloomen Flora Ltd.	826000	9.97	417000	5.03
6. APS Investments Pvt. Ltd.	264400	3.19	264400	3.19
7. Jagman Singh	15100	0.18	15100	0.18
8. Narendra C Malia	15000	0.18	15000	0.18
9. Gen. Insurance Corpn. of India	11409	0.14	11409	0.14
10. Umesh Mehta	11100	0.13	11100	0.13

A. Remuneration to Managing Director, Whole-time Directors and/or Manager:

Shri Sanjay Garg, Executive Director has been reappointed w.e.f. 12/08/2016 for ve years without any remuneration B. Remuneration to other directors

S.No. Particulars of Remuneration	Name of Directors			Total Amount ( r)
	Sh. M M Chopra	Sh. S.S. Virdi	Mrs Manju Lakhanpal
1 Independent Directors
Fee for attending board committee meetings	-	1,20,000	1,40,000	2,60,000
Commission	-	-	-
Others, please specify
Total (1)	-	1,20,000	1,40,000	2,60,000
2 Other Non-Executive Directors	Sh. R K Garg	Sh. H K Singhal
Fee for attending board committee meetings	1,00,000	1,10,000
Commission	-	-
Others, please specify
Total (2)	1,00,000	1,10,000		2,10,000
Total (B)=(1+2)				4,70,000
Total Managerial
Remuneration				Nil
Overall Ceiling	Not Applicable as only sitting fees paid.

C. REMUNERATION TO KEY MANAGERIAL PERSONNEL OTHER THAN MD/MANAGER/WTD

SN Particulars of Remuneration	KeyManagerial Personnel CS (Ms. Jyotsana Bajaj)
Gross salary
(a) Salary as per provisions contained in section 17(1) of the Income- tax Act, 1961	3,06,600
(b) Value of perquisites u/s 17(2) Income-tax Act, 1961	-
(c) Pro ts in lieu of salary under section 17(3) Income-tax Act, 1961
Stock Option	-
Sweat Equity Commission	-
- as % of pro t	-
Others, specify…	-
Others, please specify	-
Total (r)	3,06,600

VII. PENALTIES / PUNISHMENT/ COMPOUNDING OF OFFENCES:

There were no penalties, punishment or compounding of o ences during the year ended March 31, 2020

DETAILS OF DIRECTORS SEEKING APPOINTMENT/RE-APPOINTMENT IN ANNUAL GENERAL MEETING

Name of Director (DIN)	Shri Rajinder Kumar Garg (DIN:00034827)
Date of Birth	18/08/1943
Date of first Appointment	26/12/1975
Quali cation Experience in	Shri Rajinder Kumar Garg, a qualified F.I.E and an eminent
Speci c functional areas	Industrialist, is Promoter and Chairman of the Company. He has wide and varied experience in business development operations and has made significant contribution to the progress of the Company.
List of companies in which	Steel Strips Wheels Ltd.
outside Directorships held	Steel Strips Infrastructures Ltd.
(excluding Private Ltd./	SAB Industries Ltd.
Foreign Companies)	Indian Acrylics Ltd.
Chairman/ Member of the Committee of Board of Directors of the Company includes only Audit Committee and Stakeholders Relationship Committee	Nil
Chairman/ Member of the Committee of Directors of other Companies in which he is a Director includes only Audit Committee and Stakeholders Relationship Committee No. of shares held in the Company	Nil 451300 equity shares
Relationship with other Directors/ Key Managerial Personnel	Nil

For other details, such as, Number of meetings of the Board attended during the financial year, Remuneration last drawn, remuneration proposed to be paid,terms and conditions of Appointment/re-appointment, please Refer to the attached Boards Report, MGT 9, Corporate Governance Report and the notes alongwith Explanatory Statement.