bartronics india ltd Auditors report


To

The Members of BARTRONICS INDIA LIMITED

Corporate Insolvency Proceedings as per Insolvency and Bankruptcy Code, 2016:

The company has been under the corporate insolvency resolution process under the provisions of the Insolvency and Bankruptcy Code, 2016 ("the Code") National Company Law Tribunal order dated December 02, 2019. The powers of the Board of Directors stand suspended as per Section 17 of the Code and such powers were exercised by the Resolution professional appointed by the honourable National Company Law Tribunal (Hyderabad bench) by the said order under the provisions of the code. Thereafter, honourable NCLT has passed an order dated March 10th 2022 approving the Resolution Plan submitted by the Resolution applicant. Consequently, new Board of Directors have been appointed by the company on 28.03.2023

REPORT ON THE AUDIT OF THE STANDALONE FINANCIAL STATEMENTS

We have audited the accompanying Standalone Financial Statements of BARTRONICS INDIA LIMITED("the

Company"), which comprise the Standalone Balance Sheet as at March 31, 2023 and the Standalone Profit and Loss(including Other Comprehensive Income),, the Statement of Changes in Equity and the Standalone Cash flow statement f the year then ended, and notes to the Standalone financial statements, including a summary o the s or ignifi cant accounting policies and other explanatory information(herein after 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 Indian Accounting Standards prescribed under section 133 of the Act read 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, 2023, its Loss, total comprehensive income, changes in equity and its cash flows for the year ended on that date.

Basis for opinion

We c onducted our audit of the standalone financials statements in accordance with the standards on auditing specified under section 143 (10) of the Companies Act, 2013. Our responsibilities under those Standards are further described in the a uditors 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 together with t e fi he requirements that are relevant to our audit o the thical nancial statements under the provisions of the Act fulfi and the rules there under, and we have our other ethical responsibilities in accordance with these requirements and the code of ethics. uffi cient We b elieve t the audit evidence we have obtained s s hat and appropriate to provide a basis for our audit opinion on the Standalone financial statements.

Emphasis of Matter

We Draw attention to the following

(i) No te 2.45 forming part of the Statement regarding Exceptional Item as on 31st March 2023 represents difference between write back of liabilities/ provisions and write off of assets of the Company pursuant to the resolution plan approved by the Honourable National Company Law Tribunal, Hyderabad vide order dated 10 th March 2022. Pursuant to implementation of the Resolution Plan, the Company has written off/derecognized or provided for impairment of its assets, based on managements estimate, to the extent not receivable /recoverable and written back/ derecognized its liabilities, based on managements estimate, to the extent not payable extinguished/waived /cancelled to the Statement of Profit and Loss amounting to INR 15,752.20 Lakhs (net).

Key audit matters

Key a matters are those matters that, in our professional judgment, were o most s udit ignifi cance 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 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 there are no key audit matters to be communicated in our report

Information other than the financial statements and auditors report thereon

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

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

In c onnection with our audit of the standalone financial statements, our responsibility is to read the other information and, i d n so, consider whether the other information is materially inconsistent with the standalone financial oing statements or our knowledge obtained during the course of our audit or otherwise appears to be materially misstated. If, based on the work we have performed, we conclude that there is a material misstatement of this other information, we are required to report that fact. We have nothing to report in this regard.

Managements Responsibility for the Standalone Financial Statements

The Companys Board of Directors is responsible for the matters stated in Section 134(5) of the Companies Act, 2013

("the A with respect to the preparation and presentation of these standalone financial statements that give a true ct") and f vair of the financial position, fi iew nancial 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 I ndian Accounting Standards specified under Section 133 of the Act, read with relevant Rules issued there under.

This responsibility also includes maintenance of adequate accounting records in accordance with the provisions of the Act for safeguarding 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 d esign, implementation and maintenance of adequate internal financial controls, that were operating effectively for ensuring the accuracy and completeness of the accounting records, relevant to the preparation and presentation of the financial s that give a true and fair view and are free from material misstatement, whether due to fraud or error. tatements In p reparing the financial statements, management is responsible for assessing the Companys ability to continue as a going concern, disclosing, as applicable, matters, related to going concern and using the going concern basis of accounting unless management either intends to liquidate the company or to cease operations, or has no realistic alternative but to do so.

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

Auditors Responsibility for the audit of the financial statements

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

v 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 Companies Act, 2013, we are also responsible for expressing o opinion on whether the company has adequate internal financial controls system in place and the ur operating effectiveness of such controls v Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and related disclosures made by management. v 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 s ignificant doubt on the Companys ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditors report to the related disclosures in the financial s or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based on tatements 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. v Evaluate t overall presentation, structure and content of the financial statements, including the disclosures, and he whether t financial statements represent the underlying transactions and events in a manner that achieves fair he presentation.

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

We also provide those charged with governance with a statement that we have complied with relevant ethical requirements regarding independence, and to communicate with them all relationships and other matters that may reasonably be thought to bear on our independence, and where applicable, related safeguards. From the matters communicated with those charged with governance, we determine those matters that were of most significance in the audit of the financial statements of the current period and are therefore the key audit matters. We describe these matters in our auditors report unless law or regulation precludes public disclosure about the matter or when, in extremely rare circumstances, we determine that a matter should not be communicated in our report because the a dverse 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. A s required by Section 143(3) of the Act, we report that:

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

(b) In o opinion, proper books of account as required by law relating to preparation of the financial statements ur have been kept by the Company so far as it appears from our examination of those books.

(c) The S Balance Sheet, the Standalone Statement of Profit and Loss including Other Comprehensive tandalone

Income, Statement of Changes in equity and the Cash Flow Statement dealt with by this Report are in agreement with the books of account.

(d) In o opinion, the aforesaid Standalone financial statements comply with the Accounting Standards ur specified under Section 133 of the Act, read with rule 7 of the Companies (Accounts) Rules,2014.

(e) O n the basis of the written representations received from the Directors as on March 31, 2023, taken record b t Board of Directors, none of the Directors is disqualified as on March 31, 2023 from being y he appointed as a Director in terms of Section 164 (2) of the Act.

(f) with r to the adequacy of the internal financial controls over financial reporting of the Company espect and the operating effectiveness of such controls, refer to our separate Report in "Annexure A". Our report expresses a unmodified opinion on the adequacy and operating effectiveness of the Companys internal financial controls over reporting.

(g) I n our opinion, the managerial remuneration for the year ended March 31, 2023 has been paid / by the Company to its directors in accordance with the provisions of section 197 read with Schedule V to the Act; (h) W ith respect to the other matters to be included in the Independent Auditors Report in accordance

Rule 11 of the Companies (Audit and Auditors) Rules, 2014, in our opinion and to the best of our information and according to the explanations given to us:

(i) The Company does not have any pending litigations which would impact its position.

(ii) T he Company did not have any long-term contracts including derivative contracts for which were any material foreseeable losses under the applicable law or accounting standards.

(iii) T he Following amount to be transferred to the Investor Education and Protection Fund by Company.

Particulars Amount
Dividend for the year of 2010-11 505,632/-

( a)iv) The management has represented that, to the best of its knowledge and belief, no funds have been advanced or loaned or invested (either from borrowed funds or share premium or any other sources or kind of funds) by the company to or in any other persons or entities, including foreign entities ("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 a m ny whatsoever by or on behalf of the company ("Ultimate Beneficiaries") or provide any anner guarantee, security or the like on behalf of the Ultimate Beneficiaries. b) The management has represented that, to the best of its knowledge and belief, no funds have been received by the company from any persons or entities, including foreign entities ("Funding Parties"), with the understanding, whether recorded in writing or otherwise, that the company shall, whether, directly or i lend or invest in other persons or entities identified in any manner whatsoever ndirectly, by or on b of the Funding Party ("Ultimate Beneficiaries") or provide any guarantee, security or ehalf the like on behalf of the Ultimate Beneficiaries; and c) Based on the audit procedures that were 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 (a) and (b) contain any material misstatement. v Since the Company has not declared or paid any dividend during the year, the question of commenting on) whether dividend declared or paid is in accordance with Section 123 of the Companies Act, 2013 does not arise v As provision to rule 3(1) of the Companies (Accounts) Rules, 2014 is applicable for the Company only withi) effect from 01 April 2023, reporting under Rule 11(g) of the Companies (Audit and Auditors) Rules, 2014 is not applicable

2. A s required by the Companies (Auditors Report) Order, 2020 (‘the Order) issued by the Central Government terms o S f 143(11) of the Act, we give in ‘Annexure B a statement on the matters specified in paragraphs 3 ection and 4 of the Order, to the extent applicable

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 of even date)

Report o t Internal Financial Controls Over Financial Reporting under Clause (i) of Sub-section 3 of Section he 143 of the Companies Act, 2013 (‘the Act)

We h aave the internal financial controls over financial reporting Bartronics India Limited (‘the Company) as of udited March 3 2 in conjunction with our audit of the Standalone Ind AS financial statements of the Company for the year 1, 023 ended and as on that date.

Managements Responsibility for Internal Financial Controls

The C ompanys management is responsible for establishing and maintaining internal financial controls based on the internal c over financial reporting criteria established by the Company considering the essential components of ontrol 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). These responsibilities include the design, implementation and maintenance of adequate internal financial controls that were operating effectively for ensuring the orderly a efficient conduct of its business, including adherence to Companys policies, the safeguarding of its assets, nd 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 Company Act 2013..

Auditors R esponsibility

Our r esponsibility is to express an opinion on the Companys internal nancial controls over fi nancial reporting based on our audit. We conducted our audit in accordance with the Standards on Auditing prescribed under Section 143(10) of t A he a the Guidance Note, to the extent applicable to an audit of internal financial controls. Those Standards ct nd and the Guidance Note require that we comply with the ethical requirements and plan and perform the audit to obtain reasonable a about whether adequate internal financial controls over financial reporting was established and ssurance maintained and if such controls operated effectively in all material respects.

Our a iudit performing procedures to obtain audit evidence about the adequacy of the internal financial controls nvolves system o financial reporting and their operating effectiveness. Our audit of internal financial controls over financial ver reporting i obtaining an understanding of internal ncluded nancial controls over fi nancial 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 elected depend on the auditors judgment, including the assessment of the risks of material misstatement of the standalone financial statements, whether due to fraud or error.

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

Meaning of Internal Financial Controls Over Financial Reporting

A c ompanys internal financial control over financial reporting is a process designed to provide reasonable assurance regarding t liability of financial reporting and the preparation of financial statements for external purposes in heir 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, a ccurately and fairly reflect the transactions and dispositions of the assets of the company; (2) provide reasonable assurance t transactions are recorded as necessary to permit preparation of financial statements in accordance with hat 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 statements.

Inherent Limitations of Internal Financial Controls over Financial Reporting

Because o t inherent limitations of internal f he nancial controls over fi nancial reporting, including the possibility of collusion or improper management override of controls, material misstatements due to error or fraud may occur and not b d e Also, projections of any evaluation of the internal financial controls over financial reporting to future etected. periods a s re to the risk that the internal financial controls over financial reporting may become inadequate because ubject of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

Opinion

In our opinion, to the best of our information and according to the explanations given to us, the Company has, in all material r an adequate internal financial controls system over financial reporting and such internal financial espects, controls o financial reporting were operating effectively as at March 31, 2023, based on the internal control over ver financial r criteria established by the Company considering the essential components of internal control stated eporting in the Guidance Note on Audit of Internal Financial Controls Over Financial Reporting issued by the Institute of Chartered Accountants of India.

ANNEXURE ‘B TO THE INDEPENDENT AUDITORS REPORT

(Referred to in paragraph2 under the heading of "Report on Other Legal and Regulatory Requirements" of our

Independent Auditors Report of even date to the members of Bartronics India Limited on the standalone financial statements for the year ended March 31, 2023

Report on Companies (Auditors Report) Order, 2020 (‘the Order) issued by the Central Government in terms of Section 143(11) of the Companies Act, 2013 (‘the Act) of Bartronics India Limited(‘the Company)

1. I n respect of the Companys Property, Plant and Equipment:

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

(B) The Company has maintained proper records showing full particulars of Intangible assets erified (b) The P Plant and Equipment have not been v roperty, during the year by the Management in accordance with a r program of verification. We are unable to comment on discrepancies that might be arose on egular such p hysical verification of fixed assets that are lying on all locations where physical verification could not be performed..

(c) A ccording to the information and explanation given to us, title deeds of the immovable properties been m ortgaged as security with lenders i.e. banks, financial institutions and others for security of the borrowings raised by the Company. On the basis of our examination of the records of the Company and the copies of the title deeds not available with the Company, (d) T he Company has not revalued its Property, Plant and Equipment (including Right of use intangible assets during the year ended March 31, 2023.

(e) T here are no proceedings initiated or are pending against the Company for holding any benami under the Prohibition of Benami Property Transactions Act, 1988 and rules made there under.

2. (a) The management has conducted physical verification of inventory at reasonable intervals during the year and n m o discrepancies were noticed on such physical verification. Inventories lying with third parties aterial have b c een by them during the year and no material discrepancies were noticed in respect of such onfirmed confirmations.

(b) During the year, the company has not sanctioned any working capital limits from banks or financial institutions on the basis of security of Current assets.

3. A ccording to the information and explanations given to us, the Company has not granted any loans, secured or unsecured t companies, firms, Limited Liability Partnerships or other parties covered in the register maintained under section 189 of the Companies Act, 2013. Accordingly, the provisions of clause 3(iii)(a), (b) and (c) of the Order are not applicable to the Company and hence not commented upon.

4. I n our opinion and according to the information and explanations given to us, the Company has not advanced loans to directors/ to a company in which the Director is interested in, to which the provision of section 185 of the Companies Act, 2013 apply and hence not commented upon. Further, in our opinion and according to the information and explanations given to us, the provisions of section 186 of the Companies Act, 2013 in respect of loans and advances given, investments made, guarantees and securities given have been complied with by the Company.

5. T he Company has not accepted deposits 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.

6. T he Company does not maintained the cost records pursuant to the Companies (Cost Accounting Records) Rules, 2011 prescribed by the Central Government under Section 148 (1) of the Companies Act, 2013

7. ( In our opinion, the Company has generally been regular in depositing undisputed statutory dues, includinga) 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. 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, 2023 for a period of more than six months from the date they became payable except given below :

Sl.No Particulars Amount
1. Central Sales Tax (2011-12) 590,577/-
2. Dividend Distribution Tax (2010-11) 5,655,516/-
3 Service tax (Reverse Charge) 155,090/-

( Theb) dues of 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 statutory dues have not been deposited on account of any dispute, are as follows :

Natures of dues Disputed Dues Period to which the amount relates Forum where the dispute is pending
Income tax-FBT 58,320,485/- 2008-09 Appellate authority – CIT Appeals
Income tax 198,526,020/- 2008-09 Appellate authority – Income Tax Appellate Tribunal
Income tax 23,857,430/- 2009-10 Appellate authority – Income Tax Appellate Tribunal
Income tax 169,815,780/- 2010-11 Appellate authority – DRP Bangalore
Income tax 64,855,030/- 2011-12 Appellate authority – Income Tax Appellate Tribunal
Income tax 85,183,480/- 2012-13 Appellate authority – Income Tax Appellate Tribunal
Income tax 238,266,090/- 2013-14 Appellate authority – Income Tax Appellate Tribunal
Income tax 496,500,450/- 2014-15 Appellate authority – CIT Appeals
Income tax 237,426,347/- 2015-16 Appellate authority – CIT Appeals
Income tax 30,110,649/- 2021-22 Appellate authority – CIT Appeals

8. T he Company has not surrendered or disclosed any transaction, previously unrecorded in the books of account, the tax assessments under the Income Tax Act, 1961 as income during the year. Accordingly, the requirement to report on clause 3(viii) of the Order is not applicable to the Company

9. ( The Company has not defaulted in repayment of loans or other borrowings or in the payment of interesta) thereon to any lender as at March 31,2023

(b) The Company has been not declared willful defaulter by the bank or financial institution or government or any government authority.

( There are no Term Loans availed during the year and hence the provisions of Clause (9) ( c ) of the Orderc) are not applicable

(d) On an overall examination of the 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.

(e) On an overall examination of the financial statements of the Company, the Company has not taken any funds from any entity or person on account of or to meet the obligations of its subsidiaries.

( The Company has not raised any loans during the year on the pledge of securities held in its subsidiaries,f) Joint ventures or associate companies.

10. ( The Company has not raised moneys by way of initial public offer or further public offer (including debta) instruments) during the year and hence reporting under clause 3(x)(a) of the Order is not applicable.

( During the year, the Company has made preferential allotment to the Resolution Applicant and strategicb) investors in compliance with approved Resolution Plan by Honble NCLT, Hyderabad order dated 10.03.2022 and the funds raised have been used for the purposes for which the funds were raised.

11. ( Based upon the audit procedures performed for the purpose of reporting the true and fair view of thea) standalone fi statements and according to the information and explanations given by the management, nancial no fraud by the Company or no material fraud on the Company has been noticed or reported during the year.

(b) During the year, no report under sub-section (12) of section 143 of the Companies Act, 2013 has been filed by cost auditor/ secretarial auditor or by us in Form ADT – 4 as prescribed under Rule 13 of Companies (Audit and Auditors) Rules, 2014 with the Central Government

( There are no whistle-blower complaints during the year by the company. c)

12. T he Company is not a nidhi Company as per the provisions of the Companies Act, 2013. Therefore, the requirement to report on clause 3(xii)(a),(b) and (c) of the Order is not applicable to the Company.

13. I n our opinion, the Company is incompliance with Section177 and 188 of the CompaniesAct,2013 with respect to applicable transactions with the related parties and the details of related party transactions have been disclosed in the financial statements as required by the applicable accounting standards.

14. ( The Company has an internal audit system commensurate with the size and nature of its business a)

( The internal audit reports of the Company issued till the date of the audit report, for the period under auditb) have been considered by us.

15. I n 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.

16. I n our opinion, the Company is not required to be registered under section 45-IA of the Reserve Bank of

Act, 1934. Hence,reporting under clause 3(xvi)(a), (b), (c) and (d) of the Order are not applicable

17. The c has incurred cash losses of Rs.2365.34 lakhs in the financial year and Rs.4661.19 lakhs in the ompany immediately preceding financial year

18. T here has been no resignation of the statutory auditors during the year and accordingly requirement to

Clause 3(xviii) of the Order is not applicable to the Company

19. On t basis of the financial ratios, ageing and expected dates of realization of financial assets and payment of he financial l other information accompanying the financial statements and our knowledge of the Board iabilities, 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.

19. ( The Company has not any other than ongoing projects, therefore provision of section 135 of Companiesa) Act,2013is not applicable to the company

( This clause is not applicable to the companyb)