Action Construction Equipment Auditors Report


to the Members of action construction equipment limited

report on the Audit of the Standalone financial Statements

Opinion

We have audited the standalone financial statements of Action the standalone sheet as at 31 March 2023, and the standalone statement of profit and loss (including other comprehensive income), standalone statement of changes in equity and standalone statement of cash flows for the year then ended, and notes to the standalone financial statements, including a summary of significant accounting In our opinion and to the best of our information and according to the explanations given to us, the aforesaid standalone financial statements give the information required by the Companies Act, 2013, ("Act") in the manner so required and give a true and fair view in conformity with the accounting principles generally accepted in India, of the state of affairs of the Company as at 31 March 2023, and its flows for the year profitand other ended on that date.

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 SAs are furtherdescribedintheAuditorsResponsibilitiesfor the Audit of the Standalone 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 together with the ethical requirements that are relevant to our audit of the standalone financial statements under the provisions of the Act and the Rules thereunder, and we have fulfilled our other ethical responsibilities in accordance with these requirements and the 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 standalone financial statements

. emphasis of Matter

We draw attention to Note 46 to the standalone financial statements, which sets out that the comparative information presented 01 April 2021 and as at and for the year ended 31 March 2022 has been restated.

Our opinion is not modified in respect of this matter.

Key audit Matters

Key audit matters are those matters that, in our professional judgment, were of most significance in our statements of the current period. These matters were addressed in the context of our audit of the standalone financial statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters.

description of Key audit Matter

See Note 21 to Standalone financial statements

the key audit matter

how the matter was addressed in our audit

revenue recognition (sale of products)

Our audit procedures included: revenue recognition as per the relevant accounting standard;

As disclosed in Note 21 to the standalone financial statements,theAssessed the appropriateness of the accounting policy for Companys revenue from sale of products for the year ended 31 March 2023 was 212,939.88 lakhs.

Revenue is recognized upon transfer of control of promised product to the customers and when the collection of consideration by the relation to revenue recognition and tested the operating Company is "probable". In specifically, revenue from sale of products is recognised at a point in time when performance obligation is

Evaluated the design and implementation of key controls in effectiveness of such controls for a sample of transactions;

Involved our IT specialists to assist us in testing of key IT system controls which impact revenue recognition;

satisfied and is based on the transfer of control to the customer as per terms of the contract.

There is a risk during the year and at the end of the year, of revenue being recognized from sale of products without transfer of the control of products to the customer or revenue is not recorded in thecorrectaccounting period

Performed detailed testing by selecting samples of revenue transactions recorded during and after the year. For such samples, verified the underlying documents supporting the revenue recognition as per the accounting policy in the correct accounting year; and the year, selected based on specifiedrisk-based criteria, to identify unusual transactions.

There is presumption of fraud risk with regard to revenue recognition as per the Standards on Auditing. Also, revenue is one Tested sample journal entries for revenue recognized during of the key performance indicators of the Group which makes it susceptible to misstatement.

other information

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

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

In connection with our audit of the standalone financialstatements, our responsibility is to read the other information identified above when it becomes available and, in doing so, consider whether the other information is materially inconsistent with the standalone financial statements or our knowledge obtained in the audit, or otherwise appears to be materially misstated.

Managements and Board of directors responsibilities for the standalone 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 these standalone financialstatements that give a true and fair view of the state of affairs, profit/loss 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. This 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; selectionand 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 standalone financial statements that give a true and fair view and are free from material misstatement, whether due to fraud or error.

In preparing the standalone financial statements, the 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 the Board of Directors 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.

auditors responsibilities for the audit of the standalone Financial statements

Our objectives are to obtain reasonable assurance about whether the standalone 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 standalone 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 standalone financialstatements, 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 the Management and Board of Directors.

Conclude on the appropriateness of the Management and Board of Directors use of the going concern basis of accounting in preparation of Standalone financial statements 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 disclosure in the standalone 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 toceasetocontinueasa

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

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 controls that we We also provide those charged with governance with a statement that we have complied with relevant ethical requirements regarding relationshipand other matters that may reasonably be thought to bear on our independence,andtocommunicatewiththemall 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 standalone financial statements of the current period and are therefore the key audit 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

. other Matter

The standalone financial statements of the Company as at and for the years ended 31 March 2022 and 31 March 2021 (from which the balance sheet as at 1 April 2021 has been derived), excluding the adjustments described in Note 46 to the standalone financial statements, were audited by another auditor who expressed an unmodifiedopinion on those standalone financial statements on 23 May 2022 and 28 May 2021, respectively.

As part of our audit of the standalone financial statements as at and for the year ended 31 March 2023, we audited the adjustments described in Note 46 that were applied to restate the comparative information presented as at and for the year ended 31 March 2022 and the standalone balance sheet as at 1 April 2021. We were not engaged to audit, review, or apply any procedures to the standalone financial statements for the years ended 31 March 2022 or 31 March 2021 (not presented herein) or to the standalone balance sheet as at 1 April 2021, other than with respect to the adjustments described in Note 46 to the standalone financial statements. Accordingly, we do not express an opinion or any other form of assurance on those respective standalone financial statements taken as a whole. However, in our opinion, the adjustments described in Note 46 are appropriate and have been properly applied.

Our opinion is not modified in respect of this matter.

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.

2A. As required by Section 143

(3) of the Act, we report that:

a. We have sought and obtained all the information and explanations which to the 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 have been kept by the Company so far as it appears from our examination of those books.

c. The standalone balance sheet, the standalone statement of profit and loss (including other comprehensive income), the standalone statement of changes in equity and the standalone statement of cash flows dealt with by this Report are in agreement with the books of account.

d. In our opinion, the aforesaid standalone financial statements comply with the Ind AS specified under Section 133 of the Act.

e. On the basis of the written representations received from the directors as on 31 March 2023 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.

f. 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".

B. 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,according to the explanations given to us: ouropinionandtothebestofourinformationand

a. The Company has disclosed the impact of pending litigations as at 31 March 2023 on its financial position in its standalone financial statements-ReferNote34tothestandalonefinancialstatements.

b. The Company did not have any long-term contracts including derivative contracts for which there were any material foreseeable losses.

c. There has been no delay in transferring amounts, required to be transferred, to the Investor Education and Protection Fund by the Company.

d.

(i) The management has represented that, to the best of their knowledge and belief, as disclosed in the Note 45 to the standalone financial statements, no funds 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

(s) or entity(ies), including foreign entities ("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 ("UltimateBeneficiaries")or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries.

(ii) The management has represented that, to the best of their knowledge and belief, as disclosed in the Note 45 to the standalone financial statements, no funds have been received by the Company from any person

(s) or entity(ies), including foreign entities ("Funding Parties"), with the understanding, whether recorded in writing the Company Shall directly or indirectly, lend or invest in other persons or entities identified in any manner whatsoever or provide any guarantee, security or the like on behalf byoronbehalfofthefundingParties("UltimateBeneficiaries") of the Ultimate Beneficiaries.

(iii) Based on the audit procedures performed that have been considered reasonable and appropriate in the circumstances, nothing has come to our notice that has caused us to believe that the representations under sub-clause

(i) and

(ii) of Rule 11

(e), as provided under

(i) and

(ii) above, contain any material misstatement.

e. The final dividend paid by the Company during the year, in respect of the same declared for the previous year, is in accordance with Section 123 of the Act to the extent it applies to payment of dividend.

As stated in Note 14 to the standalone financial statements, the Board of Directors of the Company has proposed final dividend for the year which is subject to the approval of the members at the ensuing Annual General Meeting. The dividend declared is in accordance with Section 123 . ofthe Acttotheextentitappliestodeclaration of dividend

f. As proviso to rule 3

(1) of the Companies (Accounts) Rules, 2014 is applicable for the Company only with effect from 1 April 2023, reporting under Rule 11

(g) of the Companies (Audit and Auditors) Rules, 2014 is not applicable.

C. With respect to the matter to be included in the Auditors Report under Section 197 (16) of the Act:

In our opinion and according to the information and explanations 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. The remuneration paid and payable to any director is not in excess of the limit laid down under Section 197 of the Act. The Ministry of Corporate Affairs has not prescribed other details under Section 197

(16) of the Act which are required to be commented upon by us.

For B s r & co. llP
Chartered Accountants
Firm registration no.:101248W/W-100022
Sd/-
kunal kapur
partner

Place : Faridabad

Membership no. 509209

date : 30 May 2023

icai udin: 23509209BgYgKg4387

annexure a to the independent auditors report

on the standalone Financial statements of action construction equipment limited for the year ended 31 March 2023

(referred to in paragraph 1 under report on other legal and regulatory requirements section of our report of even date)

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

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

(i) (b) According to the information and explanations given to us and on the the Company has a regular programme of physical verification of its Property, Plant and Equipment by phased manner over a period of three years. In accordance with this programme, plantandequipmentareverified certain property, plant and equipment were verified during the year. In our opinion, this periodicity of physical reasonable having regard to the size of the Company and the nature of its assets. No material discrepancies were noticed on such verification.

(i) (c) According to the information and explanations given to us and on the basis of our examination of the records of the Company, the title deeds of immovable properties (other than immovable properties where the Company is the lessee agreements are duly executed in favour of the lessee) disclosed in the standalone financial statements are held in the name of the Company, except for the following which are not held in the name of the Company:

description of property

Gross carrying value (Amounts in INr Lakhs Held in the name of Whether promoter director or their relative or employee period held from reason for not being held in the name of the company. also indicate if in dispute

Building at Jasola, New Delhi

293.49 Bright ways Housing & Land De- velopment Limited No 7 August 2007 The possession and Original buyers agree- ment, of the property, is in the name of the company. Further, the company is taking adequate legal steps to get the title deeds registered with appropriate authority.

Building at Faridabad, Haryana

2030.39 Godavari Shilpkala Limited No 31 March 2012 The possession and Original buyers agree- ment, of the property, is in the name of the company. Further, the company is taking adequate legal steps to get the title deeds registered with appropriate authority.

Building at Sarita Vihar, New Delhi

36.24 K.K. Enter- prises No 3 November 2000 The possession and Original buyers agree- ment, of the Property, is in the name of Company. Further, the Company is taking adequate legal steps to get the title deeds registered with appropriate authority.

Building at Kolkata, West Bengal

388.80 Mr. Vijay Agarwal Promoter and Director 12 February 2021 The possession and Original buyers agree- ment, of the Property, is in the name of Company. Further, the Company is taking adequate legal steps to get the title registered with appropriate authority.

Building at Faridabad, Haryana

300.00 Mr. Vijay Agarwal, Mrs. Mona Agarwal Promoter and Director 30 March 2021 The possession and Original buyers agree- ment, of the Property, is in the name of Company. Further, the Company is taking adequate legal steps to get the title registered with appropriate authority.

 

Building at Gurugram, Haryana

6,888.90 DLF Limited No 01 September 2019 The possession and Original buyers agreement, of the Property, is in the name of Company. Further, the Company is taking adequate legal steps to get the title deeds registered with appropriate authority.

Building at Prithla, Haryana

101.34 Steelfab Pri- vate Limited No 13 August 1997 The Company has received this property by way of merger of M/s Steelfab Private Limited with the Company. Company is legal owner of the property by way of order of the court however the name is still not changed in the title deed.

(d) According to the information and explanations given to us and on the basis of the Company has not revalued its Property, Plant and Equipment (including Right of Use assets) or intangible assets or both during the year.

(e) According to the information and explanations given to us and on the basis of our examination of the records of the Company, there are no proceedings initiated or pending against the Company for holding any benami Benami Property Transactions Act, 1988 and rules made thereunder. (ii) (a) The inventory, except goods-in-transit has been physically verified by the management during the year.For goods-in-transit, subsequent evidence of receipts has been linked with inventory records. In our opinion, the frequency of such is reasonable and procedures and coverage as followed by management were appropriate. No discrepancies were noticed on between the physical stocks and the book records that were more than 10% in the aggregate of each class of inventory.

(b) According to the information and explanations given to us and on the basis of our examination of the records of the Company, the Company has been sanctioned working capital limits in excess of five crore rupees, in aggregate, from banks or financial institutions on the basis of security of current assets. In our opinion, the quarterly returns or statements filed with the books of account of the Company except as follows: withsuchbanksorfinancialinstitutions

Quarter

Name of bank Particulars

Amoun t as per books of account (In INr Lakhs)

Amount as reported in the quarterly re- turn/ statement (In INr Lakhs) Amount of difference Whether return/ statement subsequently rectified

June 2022

ICICI/HDFC/SBI/Indusind/ Citi/HDFC Bank

Inventories

36,238.34 36,238.36 (0.02) No

June 2022

ICICI/HDFC/SBI/Indusind/ Citi/HDFC Bank

Trade receivables

19,029.24 19059.23 (29.99) No

June 2022

ICICI/HDFC/SBI/Indusind/ Citi/HDFC Bank

Trade Payables

34,349.28 34,538.16 (188.88) No

September 2022

ICICI/HDFC/SBI /Indusind/ Citi/HDFC Bank

Inventories

41,211.00 41,305.04 (94.04) No

September 2022

ICICI/HDFC/SBI/Indusind/ Citi/HDFC Bank

Trade receivables

20,455.00 20,257.24 197.76 No

December 2022

ICICI/ HDFC/SBI/Indusind/ Citi/HDFC Bank

Inventories

38,663.36 38,599.70 63.66 No

(iii) According to the information and explanations given to us and on the basis of examination of records of the Company, the Company has not provided guarantee or security or granted any advance in nature of loans, secured or unsecured, to companies, firms, limited liability partnerships or any other parties during the year. The Company has made investment in company, limited liability partnership and other partiesand also granted loans to other parties during the year, details of the loan is stated in subclause

(a) below. The Company has not made investment in firms during the year and also the Company has not granted any loans, secured or unsecured, to companies, firms, limited liability partnerships during the year.

(a) Based on the audit procedures carried on by us and as per the information and explanations given to us, the Company has provided loans to other parties as below:

Particulars

Loans (In INr Lakhs)
Aggregate amount during the year - Others (Employees) 207.29
Balance outstanding as at balance sheet date - Others 65.57
(Employees)

(b) According to the information and explanations given to us and based on the audit opinion the investments made during the year and the terms and conditions of the grant of loans during the year are, prima facie, not prejudicial to the interest of the Company. Further, the Company have not provided guarantees, given security and granted any advances in nature of loans during the year.

(c) According to the information and explanations given to us and on the basis of our examination of the records of the Company, in the case of loans given, in our opinion the repayment of principal has been stipulated and the repayments have been regular. However, payment of interest has not been stipulated on account of loans being interest free. Further, the Company has not given any advance in the nature of loan to any party during the year.

(d) According to the information and explanations given to us and on the basis of our examination there is no overdue amount for more than ninety days in respect of loans given. Further, the Company has not given any advances in the nature of loans to any party during the year.

(e) According to the information and explanations given to us and on the basis of our examination of the records of the Company, there is no loan or advance in the nature of loan granted falling due during the year, which has been renewed or extended or fresh loans granted to settle the overdues of existing loans given to same parties.

(f) According to the information and explanations given to us and on the basis of our examination of the records of the Company, 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.

(iv) According to the information and explanations given to us and on the basis of our examination of the records of the Company, the Company has not given any loans, or provided any guarantee or security as specified under Section 185 and 186 of the Companies Act, 2013 ("the Act"). In respect of the investments made by the Company, in our opinion the provisions of Section 186 of the Act have been complied with.

(v) The Company has not accepted any deposits or amounts which are deemed to be deposits from the public. Accordingly, clause 3

(v) of the Order is not applicable.

(vi) We have broadly reviewed the books of accounts maintained by the Company pursuant to the rules prescribed by the Central Government for maintenance of cost records under Section 148

(1) of the Act in respect of its manufactured goods and are of the opinion that prima facie, the prescribed accounts and records have been made and maintained. However, we have not carried out a detailed examination of the records with a view to determine whether these are accurate or complete.

(vii)

(a) The Company does not have liability in respect of Service tax, Duty of excise, Sales tax and Value added tax during the year since effective 1 July 2017, these statutory dues has been subsumed into GST. According to the information and explanations given to us and on the basis of our examination of the records of the Company, in our opinion amounts deducted / accrued in the books of account in respect of undisputed statutory dues including Goods and Service Tax, Provident Fund, Employees State Insurance, Income-Tax, Duty of Customs or Cess or other statutory dues have been regularly deposited by the Company with the appropriate authorities.

According to the information and explanations given to us and on the basis of our examination of the records of the Company, no undisputed amounts payable in respect of Goods and Service Tax, Provident Fund, Employees State Insurance, Income-Tax, Duty of Customs or Cess or other statutory dues were in arrears as at 31 March 2023 for a period of more than six months from the date they became payable.

(b) According to the information and explanations given to us and on the basis of our examination statutory dues relating to Income-Tax, Duty of Excise, Service Tax and Value Added Tax which have not been deposited on account of any dispute are as follows:

Name of statute

Nature of the dues Amount (in INr Lakhs) period to which the amount relates (financial year) forum where dispute is pending

Income Tax Act, 1961

Income Tax 730.44 2014-15 to 2016-17 and 2019-20 and 2020-21 Commissioner of Income Tax (Appeals)

Income-Tax Act 1961

Income Tax 119.34 2012-13 Deputy Commissioner of Income Tax

Income-Tax Act 1961

Income Tax 18.90 2020-21 Commissioner of Income Tax (Appeals)

Central Excise Act, 1944

Duty of Excise 607.44 2006-07 to 2009-2010 Customs Excise & Service Tax Appellate Tribunal (CESTAT)

Central Excise Act 1994

Duty of Excise 829.60 2008-09 to 2013-14 Customs Excise and Service Tax

Appellate Tribunal (CESTAT)

Central Excise Act 1994 Duty of Excise 2.39 2009-10 Commissioner (Appeals)
Finance Act, 1994 (Service Tax) Service Tax 8.11 2010-11 Additional Commissioner

West Bengal Value Added Tax Act, 2003

Value Added Tax 1262.31 2006-07 to 2013-14 Additional Commissioner Review Board (West Bengal)

(viii) According to the information and explanations given to us and on the basis of our examination of the records of the Company, the previously unrecorded as income in the books of account, in the tax Companyhasnotsurrenderedordisclosedanytransactions, assessments under the Income Tax Act, 1961 as income during the year.

(ix) (a) According to the information and explanations given to us and on the basis of our examination of the records of the Company, the Company has not defaulted in repayment of loans and borrowing or in the payment of interest thereon to any lender. (b) According to the information and explanations given to us and on the basis of our examination of the records of the Company, the Company has not been declared a wilful defaulter by any bank or financial institution or government or government authority.

(c) According to the information and explanations given to us by the management, the Company has not obtained any term loans during the year. Accordingly, clause 3(ix)(c) of the Order is not applicable.

(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 raised on short-term basis have been used for long-term purposes by the Company.

(e) According to the information and explanations given to us and on an overall examination of the standalone financial statements of the Company, we report that the Company has not taken any funds from any entityor person on account of or to meet the obligations of its subsidiaries as defined under the Act.

(f) According to the information and explanations given to us and procedures performed by us, we report that the Company has not raised loans during the year on the pledge of securities held in its subsidiaries (as defined under the Act). (x) (a) The Company has not raised any moneys by way of initial public offer or further public offer (including debt instruments). Accordingly, clause 3(x)(a) of the Order is not applicable.

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

(xi) (a) Based on examination of the books and records of the Company and according to the information and explanations given to us, no fraud by the Company or on the Company has been noticed or reported during the course of the audit..

(b) According to the information andexplanations section(12) of Section 143 of the Act has giventous,noreportundersub-been filed by the auditors in Form ADT-4 as prescribed under Rule 13 of the Companies (Audit and Auditors) Rules, 2014 with the Central Government.

(c) As represented to us by the management, there are no whistle blower complaints received by the Company during the year.

(xii) According to the information and explanations given to us, the Company is not a Nidhi Company. Accordingly, clause 3(xii) of the Order is not applicable.

(xiii) In our opinion and according to the information and explanations given to us, the transactions with related parties are in compliance with Section 177 and 188 of the Act, where applicable, and the details of the related party transactions have been disclosed in the standalone financial statements as required by the applicable accounting standards.

(xiv) (a) Based on information and explanations provided to us and our audit procedures, in our opinion, the Company audit system commensurate with the size and nature of its business.

(b) We have considered the internal auditreportsoftheCompanyissuedtilldate for the period under audit. (xv) In our opinion and accordingtotheinformationandexplanationsgiven to us, 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 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. Accordingly, clause 3(xvi)(a) of the Order is not applicable.

(b) The Company is not required to be registered under Section 45-IA of the Reserve Bank of India Act, 1934. Accordingly, clause 3(xvi)(b) of the Order is not applicable.

(c) The Company is not a Core Investment Company (CIC) as defined in the regulations made by the Reserve Bank of India. Accordingly, clause 3(xvi)(c) of the Order is not applicable.

(d) According to the information and explanations provided to us by the management of the Company, the Group (as per the provisions of the Core Investment Companies(ReserveBank)Directions,2016) does not have any CICs as detailed in Note 45 of the standalone financial statements. We have not, however, separately evaluated whether the information provided by the management is accurate and complete. (xvii) The Company has not incurred cash losses in the current and in the immediately preceding financial year.

(xviii) There has been no resignation of the statutory auditors of the Company during the year. Accordingly, reporting under clause 3(xviii) of the Order is not applicable to the Company (xix) According to the information and explanations given to us and on the basis of the financial ratios, ageing and expected dates of realisation of financial assets and payment of financial liabilities, 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 when they fall due within a period of one year from the balance sheet date.liabilities 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 neithergiveanyguaranteenoranyassurancethat liabilitiesfalling due within a period of one year from the balance sheet date, will get discharged by the Company as and when they fall due.

Also refer to the Other Information paragraph of our main audit report which explains that the other information comprising the information included in annual report is expected to be made available to us after the date of this auditors report. (xx) In our opinion and according to the information and explanationsgiventous,thereisnounspentamountundersub-section(5) of Section 135 of the Act pursuant to any project. Accordingly, clauses 3(xx)(a) and 3(xx)(b) of the Order are not applicable.

For B s r & co. llP
Chartered Accountants
Firm registration no.:101248W/W-100022
Sd/-
kunal kapur
partner

Place : Faridabad

Membership no. 509209

Date : 30 May 2023

icai udin: 23509209BgYgKg4387

annexure B to the independent auditos report

on the standalone Financial statements of action construction equipment limited for the year ended 31 March 2023

report on the internal financial controls with reference to the aforesaid standalone financial statements under clause (i) of sub-section 3 of section 143 of the act (referred to in paragraph 2(a)(f) under report on the other legal and regulatory requirements section of our report of even date)

Opinion

We have audited the internal financial controls with reference to financial statements of Action Construction Equipment Limited ("the Company") as of 31 March 2023 in conjunction with our audit of the standalone financial statements of the Company for the year ended on that date.

In our opinion, the Company has, in all material respects, adequate internal financial controls with reference to financial statements and such internal financial controls were operating effectively as at 31 March 2023, based on the internal financial controls with reference to financial statements 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(the "Guidance Note").

Managements and Board of directors responsibilities for internal Financial controls

The Companys Management and the Board of Directors are responsible for establishing and maintaining internal financial controls based on the internal financial controls with reference to financial statements criteria established by the Company considering the essential components of internal control stated in the GuidanceNote.Theseresponsibilitiesinclude 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 Act.

Auditors responsibility

Our responsibility is to express an opinion on the Companys internal financial controls with reference to financial statements based on our audit. We conducted our audit in accordance with the Guidance Note and the Standards Section143(10) of Auditing,prescribedunder the Act, to the extent applicable to an audit of internal financial controls with reference to financial statements. 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 with reference to financial statements were 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 with reference to financial statements and their operating effectiveness. Our audit of internal financial controls with reference to financial statements included obtaining an understanding of internal financial controls with reference to financial statements, assessing the risk that a material weakness exists, and testing and evaluating the design and operatingeffectiveness of internal control based on the assessed risk. The procedures selected depend on the auditors judgement, including the assessment of the risks of material misstatement of the standalone 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 with reference to financial statements

Meaning of internal Financial controls with reference to Financial statements.

A companys internal financial controls with reference to financial statements is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of standalone with generally accepted accounting principles. A companys internal financial controls with reference to financial statements include those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactionsand dispositions of the assets of the company; (2) provide reasonable assurance that transactionsare recorded as necessary to permit preparation of standalone financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the company are being made only in accordance with authorisationsof management and directors of the company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorised acquisition, use, or disposition companys assets that could have a material effect on the standalone financial statements.companys assets that could have a material effect on the financial statements.

inherent limitations of internal Financial controls with reference to Financial statements

Because of the inherent limitations of internal financial controls with reference to financial statements, 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 with reference to financial statements to future periods are subject to the risk that the internal financial controls with reference to financial statements may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

For B s r & co. llP
Chartered Accountants
Firm registration no.101248W/W-100022
Sd/-
kunal kapur
partner

Place : Faridabad

Membership no. 509209

Date : 30 May 2023

icai udin: 23509209BgYgKg4387