Ahluwalia Contracts (India) Ltd Auditor Reports

TO THE MEMBERS OF

AHLUWALIA CONTRACTS (INDIA) LIMITED

REPORT ON THE AUDIT OF STANDALONE FINANCIAL STATEMENTS

Opinion

We have audited the accompanying standalone financial Statements of Ahluwalia Contracts (India) Limited (‘the Company), which comprise the Balance Sheet as at March 31, 2024, the Statement of Profit and Loss (including other comprehensive income), the Statement of Cash Flow, the Statement of Changes in Equity, Notes to the Financial Statements for the year ended on that date, and a summary of the material accounting policies and other explanatory information (hereinafter referred to as the standalone financial statements).

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 ("the Act") in the manner so required and give a true and fair view in conformity with the Companies (Indian Accounting Standards) Rules, 2015, as amended, ("IND AS") and other accounting principles generally accepted in India, of the state of affairs of the Company as at March 31, 2024, the profit and total comprehensive income, changes in equity and its cash flows for the year 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 Companies Act, 2013. Our responsibilities under those Standards are further described in the Auditors Responsibilities for 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 (ICAI) together with the ethical requirements that are relevant to our audit of the standalone financial statements under the provisions of the Companies Act, 2013 and the Rules 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 evidence we have obtained is sufficient and appropriate to provide a basis for our opinion on the standalone 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 standalone financial statements of the current period. These matters were addressed in the context of our audit of the standalone Ind AS 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.

S. No.	Key Audit Matters	Auditors Response
1	Revenue recognition for long term construction contracts	Our audit procedures include the following:
	The Companys significant portion of business is undertaken through long term construction contracts. Revenue from these contracts is recognized over a period of time in accordance with the requirements of Ind AS 115, Revenue from Contracts with Customers. Due to the nature of the contracts, revenue recognition involves usage of percentage of completion method which is determined based on output method such as surveys of performance completed to date, appraisal of results achieved, milestones reached, units produced or units delivered which involves significant judgements, identification of contractual obligations and the Companys rights to receive payments for performance completed till date, changes in scope and consequential revised contract price and recognition of the liability for loss making contracts. (Note No. 2.3)	• Reading the companys revenue recognition accounting policies and assessing compliance with the policies in terms of Ind AS 115.
		• We performed test of controls over revenue recognition with specific focus on determination of progress of completion and recording of costs incurred.
		• We performed tests of details, on a sample basis, and read the underlying customer contracts and its amendments, if any, key contract terms and milestones etc. for verifying estimation of contract revenue and cost and /or any change in such estimation.
		• We reviewed the managements evaluation process to recognize revenue over a period of time, status of completion for projects and total cost estimates.
		• We tested contracts with exceptions including contracts with low or negative margins, contracts with significant changes in planned cost estimates, contracts with significant contract assets and liabilities, and significant overdue net receivable positions for contracts and tested these exceptions with its correlation with the underlying contracts, documents for the triggers during the period.
		• We tested that the contractual positions and revenue for the year are presented and disclosed in compliance of Ind AS 115 in the Standalone financial statements.

 

S. No.	Key Audit Matters	Auditors Response
2	Trade Receivables and Contract Assets	Our Audit procedures amongst other included the following:
	Trade receivables and Contract Assets amounting to 78107.74 lakhs and 71744.84 lakhs respectively represent approximately 46.88 % of the total assets of the Company as at March 31, 2024. In assessing the recoverability of the aforesaid balance managements judgement involves consideration of aging status, evaluation of litigations and the likelihood of collection based on the terms of the contract. Management estimation is required in the measurement of work completed during the period for recognition of unbilled revenue. We considered this as key audit matter due to the materiality of the amounts and significant estimates and judgements as stated above.	• We understood and tested on a sample basis the design and operating effectiveness of management control over the recognition and the recoverability of the trade receivables and contract assets.
		• We performed test of details and tested relevant contracts, documents and subsequent settlements for material trade receivable balances and amounts included in contract assets that are due on performance of future obligations.
		• We tested the aging of trade receivables at year end.
		• We performed test of details and tested relevant contracts and documents with specific focus on measurement of work completed during the period for material unbilled revenue balances included in contract asset.
		• We performed additional procedures, in respect of material over- due trade receivables and long outstanding contract assets, i.e. tested historical payment records and legal advice obtained by the management on litigations from legal experts.
		• We assessed the allowance for impairment made by management.

 

3	Litigation and Claims & other Contingent Liabilities-	Our audit procedures amongst others included the following:
	The Company is involved in direct, indirect tax and other litigations that are pending with different statutory authorities. (Refer note 40(i)(a) to the Standalone Financial Statements).	• Obtained list of pending litigations as at March 31, 2024 from management.
	The level of management judgement associated with determining the need for, and the quantum of, provisions for any liabilities is dependent on a number of significant assumptions and assessments which involves interpreting the various applicable rules, regulations, practices and considering precedents in the various jurisdictions.	• We analysed the completed assessments for pending cases of similar nature.
	This matter is considered as a key matter, in view of the uncertainty regarding the outcome of these litigations, the significance of the amounts involved and the subjectivity involved in managements judgement as to whether the amount should be recognized as a provision or only disclosed as contingent liability in the standalone financial statements.	• Discussed the matters with the management to understand the possible outcome of these disputes.
		• We have also considered legal precedence and other rulings in evaluating management position on these uncertain tax & other litigations.
		• Obtained experts opinion in major cases to review the managements assessment of the possible outcome of the disputes relating to direct, indirect tax and other litigations.
		• Assessed contingent liability disclosure in note 40(i)(a) to the accompanying Standalone financial statements.

Other Information

The Companys Board of Director is responsible for the other information. The other information comprises the information included in the Management Discussion and Analysis, Boards Report including Annexures to Boards Report, Business Responsibility and Sustainability Report, Corporate Governance and Shareholders Information, but does not include the standalone financial statements and our auditors

report thereon. The above-mentioned 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 financial statements, 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.

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.

Responsibilities of Management and Those Charged with Governance for the Standalone Financial Statements

The Companys Board of Director is responsible for the matters stated in Section 134(5) of the Companies Act, 2013 (‘the Act) with respect to the preparation of these standalone 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 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 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, 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 also responsible for overseeing the Companys financial reporting process.

Auditors Responsibility 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 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 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 to cease to continue as a going concern.
• 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.

Materiality is the magnitude of misstatements in the standalone financial statements that, individually or in aggregate, makes it probable that the economic decisions of a reasonably knowledgeable user of the standalone 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 standalone financial statements.

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

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

From the matters communicated with those charged with governance, we determine those matters that were of most significance in the audit of the standalone 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, based on our audit we report that:
1. 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.
2. 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, except for keeping backup on daily basis of Payroll module and the matter stated in paragraph h(vi) below, on reporting under rule 11(g) of the companies (Audit and Auditors) Rule, 2014.
3. The Standalone Balance Sheet, the Standalone Statement of Profit and Loss including Other Comprehensive Income, Standalone Statement of

Changes in Equity and the Standalone Statement of Cash Flow dealt with by this Report are in agreement with the relevant books of account.

4. In our opinion, the aforesaid standalone financial statements comply with the Ind AS specified under Section 133 of the Act, read with Rule 7 of the Companies (Accounts) Rules, 2014.
5. On the basis of the written representations received from the directors as on 31st March 2024 and taken on record by the Board of Directors, none of the directors is disqualified as on March 31, 2024 from being appointed as a director in terms of Section 164 (2) of the Act.
6. 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 A". Our report expresses an unmodified opinion on the adequacy and operating effectiveness of the Companys internal financial controls over financial reporting.
7. 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, the remuneration paid by the Company to its directors during the year is in accordance with the provisions of section 197 of the Act.

8. 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, as amended in our opinion and to the best of our information and according to the explanations given to us:
1. The Company has disclosed the impact of pending litigations on its financial position in its standalone financial statements- Refer Note- 40(i)(a) to the standalone financial statement.
2. The Company has made provision, as required under the applicable law or accounting standards, for material foreseeable losses, if any, on long-term contracts. The Company has no derivative contracts.
3. There has been no delay in transferring amounts, required to be transferred, to the Investor Education and Protection Fund by the Company.
4. (a) The Management has represented that, to the best of its knowledge and belief, no funds (which are material either individually or in the aggregate) have been advanced or loaned or invested (either from borrowed funds or share premium or any other sources or kind of funds) by the Company to or in any other person or entity, including foreign entity ("Intermediaries"), with the understanding, whether recorded in writing or otherwise, that the Intermediary shall, whether, directly or indirectly lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the Company ("Ultimate Beneficiaries") or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries;

1. The Management has represented, that, to the best of its knowledge and belief, no funds (which are material either individually or in the aggregate) have been received by the Company from any person or entity, including foreign entity ("Funding Parties"), with the understanding, whether recorded in writing or otherwise, that the 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 any guarantee, security or the like on behalf of the Ultimate Beneficiaries;
2. Based on the audit procedures 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 (a) and (b) above, contain any material misstatement.

2. The Board of Directors of the Company have proposed dividend for the year which is subject to the approval of the members at the ensuing Annual General Meeting. The amount of dividend proposed is in accordance with section 123 of the Act, as applicable.
3. Based on our examination, which included test checks, the Company has used accounting software for maintaining its books of account for the financial year ended March 31, 2024 which has a feature of recording audit trail (edit log) facility w.e.f 03.04.2023 and the same has operated accordingly during the year for all relevant transactions recorded in the software except for the software used for payroll which did not have audit trail.

Further, during the course of our audit we did not come across any instance of the audit trail feature being tampered with.

As proviso to Rule 3(1) of the Companies (Accounts) Rules, 2014 is applicable from April 1, 2023, reporting under Rule 11(g) of the Companies (Audit and Auditors) Rules, 2014 on preservation of audit trail as per the statutory requirements for record retention is not applicable for the financial year ended March 31, 2024.

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

For Amod Agrawal & Associates

Chartered Accountants Firm Registration No. 005780N

AMOD AGRAWAL

Partner

Place: New Delhi Membership No.- 084175 Dated: 29-05-2024 UDIN: 24084175BKHZUV9121

ANNEXURE-A TO THE INDEPENDENT AUDITORS REPORT

(Referred to in paragraph 1 (f) under "Report on Other Legal and Regulatory Requirements" section of our report to the Members of Ahluwalia Contracts (India) Limited of even date)

REPORT ON THE INTERNAL FINANCIAL CONTROLS OVER FINANCIAL REPORTING 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 Ahluwalia Contracts (India) Limited ("the Company") as of March 31, 2024 in conjunction with our audit of the standalone 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 issued by the Institute of Chartered Accountants of India. 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 the 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.

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 on Audit of Internal Financial Controls Over Financial Reporting (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 in all material respects.

Our audit involves performing procedures to obtain audit evidence about the adequacy of the internal financial controls system over financial reporting and their operating effectiveness. Our audit of internal financial controls over

financial reporting included obtaining an understanding of internal financial controls over financial reporting, assessing the risk that a material weakness exists, and testing and evaluating the design and operating effectiveness of internal control based on the assessed risk. The procedures selected depend on the auditors 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 system over financial reporting.

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 standalone 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 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 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 standalone 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.

Opinion

In our opinion, the Company has, in all material respects, an adequate internal financial controls system over financial reporting and such internal financial controls over financial reporting were operating effectively as at March 31, 2024, based on the internal control over financial reporting criteria established by the Company considering the essential components of internal control stated in the Guidance Note on Audit of Internal Financial Controls Over Financial

Reporting issued by the Institute of Chartered Accountants of India.

For Amod Agrawal & Associates

Chartered Accountants Firm Registration No. 005780N

AMOD AGRAWAL

Partner

Place: New Delhi Membership No.- 084175 Dated: 29-05-2024 UDIN: 24084175BKHZUV9121

ANNEXURE-B TO INDEPENDENT AUDITORS REPORT

(Referred to in paragraph 2 under "Report on Other Legal and Regulatory Requirements" section of our report to the Members of Ahluwalia Contracts (India) Limited of even date)

1. (a) In respect of the Companys Property, Plant and Equipment, Right of Use Assets and Intangible Assets:
1. The Company is maintaining proper records showing full particulars, including quantitative details of Property, Plant and Equipment except for shuttering material & scaffolding. As the unit value of shuttering material and scaffoldings is very small and volumes are very large, it is not technically feasible to maintain unit records and movement of the same between various projects/sites. A separate record for movement of Property, Plant and Equipment showing situation is maintained.
2. The Company has maintained proper records showing full particulars of intangible assets.

2. There is a regular programme of verification of Property, Plant and Equipment which is in our opinion, is reasonable having regard to the size

of the Company and the nature of its assets. In accordance with the said programme part of the Property, Plant and Equipment have been physically verified by the management during the year. As informed, no material discrepancies were noticed on such verification.

3. According to the information and explanations given to us, the records examined by us and based on the examination of the conveyance deeds / registered sale deed provided to us, we report that, the title deeds, comprising all the immovable properties (other than immovable properties where the Company is the lessee and the leases agreements are duly executed in favour of the lessee) disclosed in the financial statements are held in the name of the Company except mentioned in table below. In respect of immovable properties of land and building that have been taken on lease and disclosed as Right of Use Assets in the financial statements, the lease agreements are in the name of the Company.

Description of property	Gross carrying value ( In Lakhs)	Held in the name of	Whether promoter, director or their relative or employee	Period held- indicate range, where appropriate	Reason for not being held in the name of the company Also indicate if in dispute
Building 5th & 8th Floor, KB-25, Sector III Bidhurnagar Kolkata	337.63	Lok Nayak Jaiprakash Memorial Committee	No	2007-2010	The possession and original agreement to sale of the property is in the name of the Company. The Company is in process of to get the title deeds registered with appropriate authority. No dispute.

4. 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 revalued its Property, Plant and Equipment (including Right of Use assets) or intangible assets or both during the year.
5. According to the information and explanations given to us no proceedings have been initiated during the year or are pending against the Company as at March 31, 2024 for holding any benami property under the Benami Transactions (Prohibition) Act, 1988 (as amended in 2016) and rules made thereunder.

1. (a) The inventory except goods in transit has been physically verified by the management during the year.

In our opinion, the frequency of such verification is reasonable and procedures and coverage as followed by management were appropriate. No discrepancies were noticed on verification between the physical stocks and the book records that were more than 10% in the aggregate of each class of inventory.

2. 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. Quarterly returns or statements filed by the Company with such banks are in agreement with the books of account of the Company.

1. According to the information and explanation provided to us, during the year Company has not made any investments in, provided any guarantee or security, or granted any loans or advances in the nature of loans, secured or unsecured, to companies, firms, Limited Liability Partnerships, or any other parties. Hence, the requirements under paragraph 3(iii) of the Order are not applicable to the Company.
2. In our opinion and according to the information and explanations given to us, provisions of section 186 of the Companies Act 2013 in respect of investments made have been complied by the Company. There are no other loans, guarantees and securities granted in respect of which provisions of section 185 & 186 of the Companies Act, 2013 are applicable.
3. The Company has not accepted any deposits from the public within the meaning of Section 73 to 76 of the Act and the Companies (Acceptance of Deposits) Rules, 2014 (as amended). Accordingly, the provisions of clause 3(v) of the Order are not applicable.
4. We have broadly reviewed the books of account maintained by the Company pursuant to the rules made by the Central Government for the maintenance

of cost records under section 148(1) of the Companies Act, 2013, and are of the opinion that prima facie, the prescribed accounts and records have been made and maintained. However, we have not carried out detailed examination of such accounts and records with a view to determining whether they are accurate or complete.

5. (a) In our opinion, the Company has generally been regular in depositing undisputed statutory dues, including Goods and Services tax, Provident Fund, Employees State Insurance, Income Tax, Sales Tax, Service Tax, duty of Custom, duty of Excise, Value Added Tax, Cess and other material statutory dues applicable to it with the appropriate authorities except there have been slight delays in few cases in depositing Provident Fund, ESI, & Income Tax.

2. There were no undisputed amounts payable in respect of Goods and Service tax, Provident Fund, Employees State Insurance, Income Tax, Sales Tax, Service Tax, duty of Custom, duty of Excise, Value Added Tax, Cess and other material statutory dues in arrears as at March 31, 2024 for a period of more than six months from the date they became payable.
3. According to the records of the Company, the dues outstanding of sales-tax, income-tax, duty of custom, duty of excise, service tax, value added tax, goods & service tax and cess on account of any dispute, are as follows:

Name of the Statute	Nature of Dues	Amount ( in lakhs)	Period to which the amount relates	Forum where dispute is pending
Central Excise Act, 1944	Demand for Excise duty	319.70	Mar.11 to Nov.12	Commissioner (Appeals) Central Excise, Bangalore
Central Excise Act, 1944	Demand for Excise duty	364.31	April-12 to Feb.- 2016	CESTAT, Allahabad
Central Excise Act, 1944	Demand for Excise duty	236.86	April-12 to Feb.- 2016	CESTAT, Allahabad
Commercial Taxes, Jharsuguda	VAT Demand	61.25	19.02.08 to 31.03.12	Additional Commissioner, SGST-Jharsuguda (Orissa)
Goods & Services Tax, Act	GST Demand	13.15	2017-18	Appellate Tribunal, Delhi
Goods & Services Tax, Act	GST Demand	41.40	2018-19	DETC, Gurgaon
Goods & Services Tax, Act	GST Demand	33.03	2020-21	Appellate Authority, Mumbai
Goods & Services Tax, Act	GST Demand	89.37	2021-22	Appellate Authority, Mumbai
Goods & Services Tax, Act	GST Demand	59.65	2022-23	Appellate Authority, Mumbai
Name of the Statute	Nature of Dues	Amount ( in lakhs)	Period to which the amount relates	Forum where dispute is pending
Goods & Services Tax, Act	GST Demand	431.97	2017-18	Appellate Authority, Kolkata
Goods & Services Tax, Act	GST Demand	78.22	2018-19	Jt. Commissioner, LTU, WB
Haryana Value Added Tax	VAT Demand	239.42	2011-12	PHHC, Chandigarh
The Finance Act, 2004 and the Service Tax Rules	Service Tax Demand	521.37	2007-08 TO 2011- 12	CESTAT, DELHI
The Finance Act, 2004 and the Service Tax Rules	Service Tax Demand	64.82	2009-10 to 2011-12	CESTAT, DELHI
The Finance Act, 2004 and the Service Tax Rules	Service Tax Demand	721.00	2011-12	CESTAT, DELHI
The Finance Act, 2004 and the Service Tax Rules	Service Tax Demand	207.55	2014-15 TO 30.06.17	Appellate Tribunal, Delhi
The Finance Act, 2004 and the Service Tax Rules	Service Tax Demand	1,201.14	April-12 to March-13	CESTAT, DELHI
The Finance Act, 2004 and the Service Tax Rules	Service Tax Demand	36.49	2006-09	Asst. Commissioner, Jamnagar
The Finance Act, 2004 and the Service Tax Rules	Service Tax Demand	8.71	Apr.07 to Feb.08	Asst. Commissioner, Jamnagar
The Finance Act, 2004 and the Service Tax Rules	Service Tax Demand	3,309.91	2010-11	CESTAT, CHANDIGARH
The Finance Act, 2004 and the Service Tax Rules	Service Tax Demand	870.41	2005-06/2008-09	Appellate Tribunal, Mumbai
The Finance Act, 2004 and the Service Tax Rules	Service Tax Demand	573.60	2007-2011	CESTAT, MUMBAI
The Finance Act, 2004 and the Service Tax Rules	Service Tax Demand	84.53	2006-07 to 2010-11	Commissioner-CGST-GZB.
The Finance Act, 2004 and the Service Tax Rules	Service Tax Demand	13.57	2013-14	CESTAT, Allahabad
The Finance Act, 2004 and the Service Tax Rules	Service Tax Demand	2,804.68	June-07 to Sep-10	CESTAT, Allahabad
Name of the Statute	Nature of Dues	Amount ( in lakhs)	Period to which the amount relates	Forum where dispute is pending
The Finance Act, 2004 and the Service Tax Rules	Service Tax Demand	31.44	Mar.12 to Mar.13	Commissioner Appeal, Noida
The Finance Act, 2004 and the Service Tax Rules	Service Tax Demand	45.35	Oct 10 to Feb 12	CESTAT, Allahabad
The Finance Act, 2004 and the Service Tax Rules	Service Tax Demand	57.10	2016-17	Adjudication Authority, Kolkata
The Finance Act, 2004 and the Service Tax Rules	Service Tax Demand	38.54	2017-18	Adjudication Authority, Kolkata
The Finance Act, 2004 and the Service Tax Rules	Service Tax Demand	103.48	Oct.05 to Jan.08	CESTAT, KOLKATA
Value Added tax Act, Chandigarh	VAT Demand	44.71	2012-13	Dy. Comm. (Appeals), Chandigarh
Value Added Tax Act, DELHI	VAT Demand	69.88	2013-14	Special Commissioner, DVAT
Value Added Tax Act, DELHI	VAT Demand	5.30	2014-15	Special Commissioner, DVAT
Value Added Tax Act, DELHI	VAT Demand	16.77	2015-16	Special Commissioner, DVAT
Value Added Tax Act, DELHI	VAT Demand	7.49	2016-17	Special Commissioner, DVAT
Value Added Tax Act, DELHI	VAT Demand	37.20	2017-18	Special Commissioner, DVAT
Value Added Tax Act, MH	VAT Demand	16.43	2005-06	Dy Commissioner (Audit), Mumbai
Value Added Tax Act, UP	VAT Demand	4.27	2005-06	Appellate Tribunal, Ghaziabad
Value Added Tax Act, UP	VAT Demand	2.67	2006-07	Additional Commissioner (A), Ghaziabad
Value Added Tax Act, UP	VAT Demand	59.36	2008-09	Appellate Tribunal, Ghaziabad
Value Added Tax Act, UP	VAT Demand	6.84	Jan.08 to March-08	Additional Commissioner (A), Ghaziabad
Value Added Tax Act, WB	VAT Demand	1.54	1997-98	appellate Tribunal, Kolkata
Value Added Tax Act, WB	VAT Demand	3.01	1998-99	Sr. Jt. Commissioner, Kolkata
Value Added Tax Act, WB	VAT Demand	0.22	2005-06	Sr. Jt. Commissioner, Kolkata
Income Tax Act, 1961	Income Tax Demand	66.45	AY 2016-17	Commissioner of Income Tax Appeals-New Delhi
Income Tax Act, 1961	Income Tax Demand	70.8	AY 2019-20	Commissioner of Income Tax Appeals-New Delhi
Income Tax Act, 1961	Income Tax Demand	2.86	AY 2020-21	Commissioner of Income Tax Appeals-New Delhi
Income Tax Act, 1961	Income Tax Demand	17.57	AY 2021-22	Commissioner of Income Tax Appeals-New Delhi
Employees Provident Fund & Miscellaneous Provision Act,1952	Provident Fund Demand	5,457.34	2007 to 2009	Employees Provident Fund Appellate Tribunal, New Delhi and High Court, New Delhi
Indian Stamp Act	Stamp Duty on Real Estate Project	57.42	1990-91	Allahabad High Court

1. 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 surrendered or disclosed any transactions, previously unrecorded as income in the books of account, in the tax assessments under the Income Tax Act, 1961 as income during the year.
2. 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 banks or financial institutions during the year.

2. The Company has not been declared willful defaulter by any bank or financial institution or government or any government authority.
3. In our opinion and according to the information and explanations given to us by the management, term loans were applied for the purpose for which the loans were obtained.
4. On an overall examination of the standalone financial statements of the Company, funds raised on short- term basis have, prima facie, not been used during the year for long-term purposes by the Company.
5. According to the information and explanation 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 entity or person on account of or to meet the obligations of its subsidiaries, associates or joint ventures as defined in the Act.
6. 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, joint ventures or associate companies.

2. 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 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, the clause 3 (x)(b) of the Order is not applicable to the Company.

3. 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 report that no fraud by the Company or on the Company has been noticed or reported during the course of the audit.

2. According to the information and explanations given to us, no report under sub-section (12) of Section 143 of the Companies Act, 2013 has been filed by the auditors in Form ADT-4 as prescribed under rule 13 of Companies (Audit and Auditors) Rules, 2014 with the Central Government.
3. As represented to us by the management, there are no whistle-blower complaints received by the Company during the course of audit. Accordingly, the provisions stated in paragraph (xi)(c) of the Order is not applicable to company.

1. The Company is not a Nidhi Company and hence reporting under clause 3(xii) of the Order is not applicable.
2. According to the records of the Company examined by us and the information and explanation given to us, the Company has complied with section 177 and 188 of the Companies Act 2013 in relation to transaction with

related parties and the details have been disclosed in the standalone financial statements, as required by the applicable accounting standards.

3. (a) In our opinion the Company has an adequate internal audit system commensurate with the size and the nature of its business.

(b) We have considered, the internal audit reports for the year under audit, issued to the Company during the year and till date, in determining the nature, timing and extent of our audit procedures.

4. In our opinion during the year the Company has not entered into any non-cash transactions with its Directors or persons connected with its directors and hence provisions of section 192 of the Companies Act, 2013 are not applicable to the Company
5. (a) In our opinion, the Company is not required to be registered under section 45-IA of the Reserve Bank of India Act, 1934. Hence, reporting under clause 3(xvi)(a) of the Order is not applicable.

2. 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, reporting under clause 3(xvi)(b) of the Order is not applicable.
3. The Company is not a Core Investment Company (CIC) as defined in the regulation made by Reserve Bank of India. Hence, reporting under clause 3(xvi)
3. of the Order is not applicable.
4. According to the information & explanations provided to us, the Company does not have any CIC as part of its group. Hence reporting under clause 3(xvi)(d) of the Order is not applicable.

1. The Company has not incurred cash losses during the financial year covered by our audit and the immediately preceding financial year.
2. There has been no resignation of the statutory auditors of the Company during the year. Accordingly, clause 3(xviii) of the Order is not applicable.
4. On the basis of the financial ratios, ageing and expected dates of realisation of financial assets and payment of financial liabilities, other information accompanying the financial statements and 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 indicating that Company is not capable of meeting its liabilities existing at the date of balance sheet as and when they fall due within a period of one year from the balance sheet date. We, however, state that this is not an assurance as to the future viability of the Company. We further state that our reporting is based on the facts up to the date of the audit report and we neither give any guarantee nor any assurance that all liabilities falling due within a period of one year from the balance sheet date, will get discharged by the Company as and when they fall due.
5. (a) In our opinion no amount is required to be transferred in respect of other than ongoing projects to a Fund specified in Schedule VII to the Companies Act within a period of six months of the expiry of the financial year in compliance with second proviso to sub-section (5) of section 135 of the said Act.

(b) In our opinion no amount is required to transfer in respect of ongoing projects, to a Special Account within thirty days from the end of the financial year as required under the sub-section (6) of section 135 of the Act.

For Amod Agrawal & Associates

Chartered Accountants Firm Registration No. 005780N

AMOD AGRAWAL

Partner

Place: New Delhi Membership No.- 084175 Dated: 29-05-2024 UDIN: 24084175BKHZUV9121