Beryl Drugs Ltd Directors Report.

To,

The Members, Beryl Drugs Limited, Indore.

Your Directors are pleased to present Twenty Seventh Annual Report on the business and operations of the Company together with the Audited Financial Statements for the year ended March 31, 2020.

1. FINANCIAL RESULTS AND OPERATION:

The Companys financial results have been summarized as follows:

(Rs. In Lakhs)
Year ended 31.03.2020 Year ended 31.03.2019
Total Revenue
(Including other operating revenues) 1304.82 1320.36
Profit before tax (PBT) 15.79 79.63
Less: (a) Current Tax (Net) (3.55) 25.61
(b) Deferred Tax 14.55 (5.06)
Net Profit/Loss for the Period 4.79 59.07
Total Comprehensive Income 9.73 86.09
Basic & Diluted EPS per Equity Share of 0.09 1.16
Face value Rs. 10 each (Rs.)

2.PERFORMANCE OF THE COMPANY:

During the year under review the company earns profit of of Rs. 4.79 Lacs in comparison to last year profit of Rs. 59.07 Lacs. Your directors are putting their best effort to turn the company into more profit making company. The directors are putting their best efforts to increase the income with reducing the cost incurred. Your management is very hopeful to achieve better results in forthcoming period and expects to achieve better financial results as per the perception of the Shareholders of the Company.

The outbreak of COVID-19 pandemic has led to an unprecedented disruption in the economic activities across the globe. Due to the stringent nationwide lockdown imposed by the Government of India with effect from March 25, 2020 the manufacturing activities of the Company were severely affected due to severe supply-side disruptions. The Company has resumed its operations in a phased manner. However, the health and safety of our employees continues to be the foremost priority.

3. DIVIDEND:

In order to further strengthen the Company to expand its business activities and to conserve the financial resources, your Directors regret for their inability to recommend any dividend for the financial year 2019-2020.

4. SHARE CAPITAL

The paid up Equity Share Capital as at March 31, 2020 stood at 5.71 Crores. During the year under review, the Company has not issued shares or convertible securities or shares with differential voting rights nor has granted any stock options or sweat equity or warrants.

5. PUBLIC DEPOSITS

The Company has neither invited nor accepted any deposit from the public during the year, pursuant to the provisions of Section 73 of the Companies Act, 2013 & the Deposit Rules made there under.

6. DIRECTORS AND KEY MANAGERIAL PERSONNEL:

The Board made the following appointments/ re-appointments based on the recommendations of the nomination and remuneration committee:

APPOINTMENTS & RE- APPOINTMENTS: v As per the provisions of the Companies Act, 2013, Mr. Sudhir Sethi (DIN: 00090172) retires by rotation at the ensuing Annual General Meeting and being eligible, seeks re- appointment. The Board recommends his re- appointment. v Re- Appointment of Mr. Sanjay Sethi (DIN: 00090277) as Managing Director of the Company for the period of Five Years.

All Independent Directors of the Company have given declarations that they meet the criteria of independence as laid down under Section 149(6) of the Act and Regulation 16(1)(b) of the Listing Regulations. In the opinion of the Board, the Independent Directors, fulfill the conditions of independence specified in Section 149(6) of the Act and Regulation 16(1) (b) of the Listing Regulations. The Independent Directors have also confirmed that they have complied with the Companys Code of Business Conduct & Ethics.

Particulars of the directors seeking appointment/re-appointment are provided in the notes forming part of the notice for the ensuing Annual General Meeting, as required under Regulation 36(3) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015.

7. DIRECTORS RESPONSIBILITY STATEMENT:

To the best of knowledge and belief and according to the information and explanations obtained by them, your Directors make the following statement in terms of Section 134[3(c)] of the Act:

1. In the preparation of the annual accounts for the financial period ended on 31st March, 2020 the applicable accounting standards subject to notes to the accounts in Auditors Report had been followed, along with proper explanation relating to material departures;

2. The Director have selected such accounting policies and applied them consistently and made judgments and estimates that are reasonable and prudent, so as to give a true and fair view of the state of affairs of the Company at the end of the financial period ended and profit of the Company for the period under review;

3. The Directors have taken proper and sufficient care for the maintenance of adequate accounting records, in accordance with the provisions of The Companies Act, 2013 for safeguarding the assets of the Company and for preventing and detecting fraud and other irregularities;

4. The Directors have prepared the annual accounts on a going concern basis.

5. They have devised proper systems to ensure compliance with the provisions of all applicable laws and that such systems were adequate and operating effectively.

6. They have laid down internal financial controls, which are adequate and are operating effectively.

8. AUDITORS:

STATUTORY AUDITORS:

The Company had appointed M/s. Prateek Jain & Co. having registration No. 009494C allotted by the Institute of Chartered Accountants of India as Statutory Auditors of the Company for carrying out the Statutory Audit of the Company for the Term of 5 years commencing from the conclusion of 24thAnnual General Meeting to the conclusion of 29th Annual General Meeting of the Company, which will be subject to ratification by shareholders (every year) in ensuing Annual General Meeting. Pursuant to the amendments made to Section 139 of the Companies Act, 2013 by the Companies (Amendment) Act, 2017 effective from May 7, 2018, the requirement of seeking ratification of the Members for the appointment of the Statutory Auditors has been withdrawn from the Statute. Hence the resolution seeking ratification of the Members for continuance of their appointment at this AGM is not being sought.

There have been no instances of fraud reported by the Statutory Auditors under Section 143(12) of the Act and Rules framed there under, either to the Company or to the Central Government. The notes on accounts referred to and the Auditors Report are self explanatory and therefore do not call for any explanatory note

SECRETARIAL AUDITOR:

Ashish Karodia & Co, Practicing Company Secretaries, was appointed to conduct the Secretarial audit of the Company for the fiscal 2020, as required under Section 204 of the Companies Act, 2013 and rules there under. The Secretarial Report for the fiscal 2020 forms part of this Annual report as Annexure- 3 to the Boards Report. The Secretarial Audit Report does not contain any qualification, reservation and adverse remark.

The Board has appointed Ashish Karodia & Co, Practicing Company Secretaries as Secretarial Auditor of the Company for fiscal 2021.

Auditors Certificate on Corporate Governance:

As required by SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, the Auditor certificate on Corporate Governance is enclosed as Annexure to the Boards Report. The Auditors Certificate for fiscal 2020 does not contain any qualification, reservation or any adverse remark.

9. COMPOSITION OF AUDIT COMMITTEE:

As per the requirement of Regulation 18 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 read with Section 177 of the Companies Act, 2013. The present strength of the Audit Committee comprises of Mr. Abhinav Naik, Mrs. Shreya Saraf and Mr. Sudhir Sethi. Mr. Abhinav Naik is the Chairman of the Audit Committee of the Company. All the members of the Audit Committee are independent and non-executive directors. The recommendations of audit committee were duly accepted by the Board of Directors.

There are no recommendations of the audit committee which have not been accepted by the board during the year under review.

10. INSURANCE:

The Companys plant, property, equipment, machinery and stocks are adequately insured against various mis-happenings.

11. PARTICULARS OF EMPLOYEES:

There are no employees as on date on the rolls of the Company who are in receipt of remuneration which requires disclosures under Section 197(12) of the Companies Act, 2013 read with rule 5(1) of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014 i.e. Company does not have any employee receiving Remuneration exceeding the limit specified therein or part thereof. During the year under review, relationship with the employees is cordial.

12 DISCLOSURE OF CONSERVATION OF ENERGY, TECHNOLOGY, ABSORPTION AND FOREIGN EXCHANGE EARNING AND OUTGO. :

Information as per Section 134(3)(m) read with Rule 8 of the Companies (Accounts) Rules, 2014 are enclosed as Annexure- 4 to the Boards Report for the year ended 31st March, 2020.

13 MANAGEMENT DISCUSSION AND ANALYSIS REPORT:

In terms of the provisions of Regulation 34 of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015, the Managements discussion and analysis forms an integral part of this report and gives detail of the overview, industry structure and developments.

14 CORPORATE GOVERNANCE:

Your Company has always strived to maintain appropriate standards of good corporate governance. The report on corporate governance as stipulated under Schedule V (C) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 forms part of this Report. The requisite certificate confirming compliance with the conditions of corporate governance as stipulated under the said clause is also attached to this report.

15 LISTING WITH STOCK EXCHANGES :

The Equity Shares of the Company are listed with the Bombay Stock Exchange Ltd and Ahmedabad Stock Exchange Limited.

The Company has delisted its securities from Madhya Pradesh Stock Exchanges w.e.f. 30th May, 2015.

16 INTERNAL CONTROL SYSTEM :

The Board has adopted policies and procedures 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 disclosures.

17 TRANSACTIONS WITH RELATED PARTIES

Details of the transactions with related partys falls under the scope of Section 188(1) of the Act. Information on transactions with related parties pursuant to Section 134(3)(h) of the Act read with rule 8(2) of the Companies (Accounts) Rules, 2014 are given in Annexure 1in Form AOC-2 and the same forms part of this report.

18 INDEPENDENT DIRECTORS DECLARATION

The Independent Directors have confirmed and declared that they are not disqualified to act as an Independent Director in compliance with the provisions of Section 149 of the Companies Act, 2013 read with Regulation 16(B) of the SEBI (Listing Obligations and Disclosure Requirements)

Regulations,2015 and the Board is also of the opinion that the Independent Directors fulfill all the conditions specified in the Companies Act, 2013 making them eligible to act as Independent Directors.

19 CORPORATE SOCIAL RESPONSIBILITY:

The policy of the Corporate Social Responsibility is not applicable to the Company.

20 EXTRACT OF ANNUAL RETURN:

The details forming part of the extract of the Annual Return in Form MGT- 9 is annexed herewith as Annexure- 2.

21 NUMBER OF BOARD MEETINGS:

6 Board Meetings were held during the financial year from 1st April, 2019 to 31st March, 2020. The maximum interval between any two meetings did not exceed 120 days, as prescribed in the Companies Act, 2013.

22 VIGIL MECHANISM:

A "Vigil Mechanism Policy" for directors and employees of the Company is constituted, to provide a mechanism which ensures adequate safeguards to employees and Directors from any victimization on rising concerns of any violation of legal or regulatory requirements, incorrect or misrepresentation of any, financial statements and reports, etc.

The details pertaining to establishment of vigil mechanism for employees and directors are included in the Corporate Governance Report which forms part of this report.

23 FINANCIAL YEAR:

Pursuant to Section 2(41) of the Companies Act, 2013, the Company adopted April- March as its Financial Year. The Financial Year of the Company shall be for a period of 12 months i.e. 1st April to 31st March.

24 COMMITTEES OF THE BOARD:

Currently, the Board has Three Committees: the Audit Committee, the Nomination and Remuneration Committee, The Stakeholders Relationship Committee. A detailed note on the composition of the Board and its committees is provided in the Corporate Governance Report section of this Annual Report.

25 MATERIAL CHANGES AND COMMITMENT AFFECTING FINANCIAL POSITION OF THE COMPANY:

There are no material changes or commitments occurring after 31st March, 2020, which may affect the financial position of the Company or may require disclosure.

26 MEETING OF INDEPENDENT DIRECTORS:

During the year under review, a separate meeting of Independent Directors was held on 20th March, 2020

• Evaluation of the performance of Non- Independent Directors and Board of Directors as a whole.

• Evaluation of the performance of the Chairman of the Company, taking into account the views of the Executive Directors.

• Evaluation of the quality, content and timelines of flow of information between the management and the Board that is necessary for the Board to effectively and necessarily perform its duties.

All the Independent Directors were present at the said Meeting.

27 INTERNAL AUDITOR

M/s Abhay Bhandari & Associates, Chartered Accountants, Indore is appointed as Internal Auditor of the Company to conduct the internal audit of the Company for the Financial Year 2019-2020, as required under Section 138 of the Act 2013 and the Companies (Accounts) Rules, 2014.

28 DEMATERIALISATION OF SHARES

The shares of your Company are being traded in electronic form and the Company has established connectivity with both the depositories i.e. National Securities Depository Limited (NSDL) and Central Depository Services (India) Limited (CDSL). In view of the numerous advantages offered by the Depository system, Members are requested to avail the facility of dematerialization of shares with either of the Depositories as aforesaid. As on March 31, 2020, 73.94% of the share capital stands dematerialized.

29 SECRETARIAL STANDARDS

The Company has complied with the Secretarial Standards issued by The Institute of Company Secretaries of India (ICSI).

30 DISCLOSURE UNDER THE SEXUAL HARASSMENT OF WOMEN AT WORKPLACE (PREVENTION, PROHIBITION AND REDRESSAL) ACT, 2013

The Company has in place an Anti Sexual Harassment Policy in line with the requirements of The Sexual Harassment of Women at the Workplace (Prevention, Prohibition and Redressal) Act, 2013. Internal Complaints Committee (ICC) has been set up to redress complaints received regarding sexual harassment. All employees (permanent, contractual, temporary, trainees) are covered under this policy.

The following is a summary of sexual harassment complaints received and disposed off during the year 2019-2020 No of complaints received: NIL

No of complaints disposed off: Not Applicable

31 RISK MANAGEMENT

The Company has in place Risk Management Policy as per requirement of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 and Section 134(3)(n) of the Companies Act, 2013, which requires the Company to lay down procedure for risk assessment and risk minimization. The Board of Directors, Audit committee and the Senior Management of the Company should periodically review the policy and monitor its implementation to ensure the optimization of business performance, to promote confidence amongst stake holders in the business processes, plan and meet strategic objectives and evaluate, tackle and resolve various risks associated with the Company. The business of the Company is exposed to various risks, arising out of internal and external factors i.e. Industry, Competition, Input, Geography, Financial, Regulatory, Other Operational, Information Technology related other risks

32 WEB LINK OF THE COMPANY:

The Web link of the Company is Website. www.beryldrugs.com.

33 BOARD EVALUATIONS:

Pursuant to the provisions of section 134 (3)(p) of the Companies Act, 2013 and applicable Regulations of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, the Board adopted a formal mechanism for evaluating its performance and as well as that of its Committees and Individual Directors, including the Chairman of the Board. The exercise was carried out through a structured evaluation process.

Covering various aspects of the Boards functioning such as composition of the Board & committees, experience & competencies, performance of specific duties & obligations, governance issues etc.

The evaluation of the Independent Directors was carried out by the entire Board and that of the Chairman and the Non-Independent Directors were carried out by the Independent Directors. The Directors were satisfied with the evaluation results, which reflected the overall engagement and effectiveness of the Board and its Committees with the Company.

34 RETIRE BY ROTATION:

Pursuant to the provisions of Section 152 of the Companies Act, 2013, Mr. Sudhir Sethi, Chairman & Director of the Company, retires by rotation and being eligible, offers himself for reappointment.

35 PARTICULARS OF JOINT VENTURE, SUBSIDIARY & ASSOCIATE COMPANY

The Company does not have any joint venture, subsidiary or associate company during the year.

36 APPRECIATION AND ACKNOWLEDGEMENT

Your Directors appreciated the trust reposed by the medical fraternity and patients in the Company and look forward to their continued patronage. Your Directors are also grateful and pleased to place on record their appreciation and acknowledgement with gratitude the support and Company-operation extended by clients, customers, vendors, bankers, investors, media and both the State and central Government and their agencies and look forward their continued support.

For and on Behalf of the Board Beryl Drugs Ltd.

Sd/-

Sanjay Sethi Managing Director

DIN: 00090277

Place: Indore

Dated: 20th November, 2020

(Pursuant to clause (h) of sub-section (3) of section 134 of the Act and Rule 8(2) of the Companies (Accounts) Rules, 2014)

Form for disclosure of particulars of contracts / arrangements entered into by the company with related parties referred to in sub-section (1) of section 188 of the Companies Act, 2013 including certain arms length transactions under third proviso thereto:

1. Details of contracts or arrangements or transactions not at arms length basis: Beryl Drugs Limited (BDL) has not entered into any contract or arrangement or transaction with its related parties which is not at arms length during financial year 2019-20.

2. Details of material contracts or arrangement or transactions at arms length basis: a. Name(s) of the related party and nature of relationship: Babulal Sethi (Father of Promoter) b. Nature of contracts / arrangements / transactions: Office Rent c. Duration of the contracts / arrangements / transactions: 12 months

d. Salient terms of the contracts or arrangements or transactions including the value, if any: N.A.

On behalf of the Board of Directors,

Sd/-

Sanjay Sethi Managing Director

(DIN 00090277)

Date: 20th November, 2020

Place : Indore

FORM NO. MGT 9 EXTRACT OF ANNUAL RETURN

As on financial year ended on 31.03.2020

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

I. REGISTRATION & OTHER DETAILS:
1 CIN L02423MP1993PLC007840
2 Registration Date 24.08.1993
3 Name of the Company BERYL DRUGS LIMITED
4 Category/Sub-category of the Company MANUFACTURING
5 Address of the Registered office & contact details 133, Kanchan Bagh, Indore (M.P)- 452001
6 Whether listed company YES
7 Name, Address & contact details of the Registrar ADROIT CORPORATE SERVICES PVT LTD
& Transfer Agent, if any. 1st Floor, Makwana Road, Marol Naka,
Andheri (East), Mumbai- 400059

II. PRINCIPAL BUSINESS ACTIVITIES OF THE COMPANY

(All the business activities contributing 10 % or more of the total turnover of the company shall be stated)

S.No. Name and Description of main products / services NIC Code of the Product/service % to total turnover of the company
1 Manufacturing of Allopathic Pharmaceuticals Preparations Group 210, Class 2100, Sub- class 21002 100%

III. PARTICULARS OF HOLDING, SUBSIDIARY AND ASSOCIATE COMPANIES

S.No. Name and address of the Company CIN/GLN Holding/ Subsidiary/ Associate % of shares held Applicable Section
1. NA

IV. SHARE HOLDING PATTERN

(Equity share capital breakup as percentage of total equity) (i) Category-wise Share Holding

Category of Shareholders

No. of Shares held at the beginning of the year [As on 01-April-2019]

No. of Shares held at the end of the year [As on 31-March-2020]

% Change during the year
Demat Physical Total % of Total Shares Demat Physical Total % of Total Shares
A. Promoters
(1) Indian
a) Individual/ HUF 0 0 0 0.00 0 0 0 0.00 0.00
b) Central Govt 0 0 0 0.00 0 0 0 0.00 0.00
c) State Govt(s) 0 0 0 0.00 0 0 0 0.00
d) Bodies Corp. 0 0 0 0.00 0 0 0 0.00 0.00
e) Banks / FI 0 0 0 0.00 0 0 0 0.00 0.00
f) Any other
f-1) DIRECTORS RELATIVES 355331 0 355331 7.01 355331 0 355331 7.01 0.00
f-2) DIRECTORS 908700 0 908700 17.92 908700 0 908700 17.92 0.00
Sub Total (A) (1) 1264031 0 1264031 24.92 1264031 0 1264031 24.92 0
(2) Foreign
a) NRI Individuals 0 0 0 0.00 0 0 0 0.00 0.00
b) Other Individuals 0 0 0 0.00 0 0 0 0.00 0.00
c) Bodies Corp. 0 0 0 0.00 0 0 0 0.00 0.00
d) Any other 0 0 0 0.00 0 0 0 0.00 0.00
Sub Total (A) (2) - - - 0.00% - - - 0.00% 0.00%
TOTAL (A) 12,64,031 - 12,64,031 0.00% 12,64,031 - 12,64,031 24.92% 0.00%
B. Public Shareholding
1. Institutions
a) Mutual Funds 0 0 0 0.00 0 0 0 0.00 0.00
b) Banks / FI 0 0 0 0.00 0 0 0 0.00 0.00
c) Central Govt 0 0 0 0.00 0 0 0 0.00 0.00
d) State Govt(s) 0 0 0 0.00 0 0 0 0.00 0.00
e) Venture Capital Funds 0 0 0 0.00 0 0 0 0.00 0.00
f) Insurance Companies 0 0 0 0.00 0 0 0 0.00 0.00
g) FIIs 0 0 0 0.00 0 0 0 0.00 0.00
h) Foreign Venture Capital Funds 0 0 0 0.00 0 0 0 0.00 0.00
i) Others (specify) 0 0 0 0.00 0 0 0 0.00 0.00
Sub-total (B)(1):- 0 0 0 0.00 0 0 0 0.00 0.00
2. Non-Institutions
a) Bodies Corp.
i) Indian 218328 40100 258428 5.10 191075 40100 231175 4.56 -0.54
ii) Overseas 0 0 0 0.00 0 0 0 0.00 0.00
b) Individuals
i) Individual shareholders holding nominal share capital upto Rs. 1 lakh 1347401 1270200 2617601 51.61 1346814 1259100 2605914 51.38 -0.23
ii) Individual shareholders holding nominal share capital in excess of Rs 1 lakh 854445 10100 864545 17.05 891634 10100 901734 17.78 0.73
c) Others (specify)
Non Resident Indians 53595 13300 66895 1.32 53920 12300 66220 1.31 -0.01
Foreign Nationals 0 0 0 0.00 0 0 0 0.00 0.00
Clearing Members 200 0 200 0.00 2626 0 2626 0.05 0.05
Trusts 0 0 0.00 0 0 0 0.00 0.00
Foreign Bodies - D R 0 0 0.00 0 0 0 0.00 0.00
Sub-total (B)(2):- 24,73,969 13,33,700 38,07,669 75.08% 24,86,069 13,21,600 38,07,669 75.08% 0.00%
Total Public (B) 24,73,969 13,33,700 38,07,669 75.08% 24,86,069 13,21,600 38,07,669 75.08% 0.00%
C. Shares held by Custodian for GDRs & ADRs 0 0 0.00 0 0 0 0.00 0.00
Grand Total (A+B+C) 37,38,000 13,33,700 100.00% 37,50,100 13,21,600 50,71,700 100.00% 0.00%

(ii) Shareholding of Promoter

SN Shareholders Name

No. Of Share at the begining of the year

No. Of Shares at the end of the year

% change in shareholding during the year
no. Of Shares % of total Shares of the company % of Shares Pledged/ encumbered to total shares No. of Shares % of total Shares of the company % of Shares Pledged / encumbered to total shares
1 SONIYA SETHI 155896 3.07 0.00 155896 3.07 0.00 0.00
2 SANGITA SETHI 191935 3.78 0.00 191935 3.78 0.00 0.00
3 SUDHIR SETHI 364400 7.18 0.00 364400 7.18 0.00 0.00
4 BABULAL SETHI 7500 0.15 0.00 7500 0.15 0.00 0.00
5 SANJAY SETHI 544300 10.73 0.00 544300 10.73 0.00 0.00
TOTAL 1264031 24.92 0.00 1264031 24.92 0.00 0.00

(iii) Change in Promoters Shareholding (please specify, if there is no change)

SN Particulars

No. Of Shares at the beginning of the year

Cumulative Shareholding during the year

Name of Promoters No. of shares % of total shares No. of shares % of total shares
1 At the beginning of the year SONIYA SETHI 1,55,896 3.07 1,55,896 3.07%
Changes during the year NIL NIL
At the end of the year 0 0.00% 1,55,896 3.07%
2 At the beginning of the year SANGITA SETHI 191935 3.78 191935 3.78
Changes during the year NIL NIL
At the end of the year 0 0.00 191935 3.78
3 At the beginning of the year BABULAL SETHI 7500 0.15 7500 0.15
Changes during the year NIL NIL
At the end of the year 0 0.00 7500 0.15
4 At the beginning of the year SANJAY SETHI 544300 10.73 544300 10.73
Changes during the year NIL NIL
At the end of the year 0 0.00 544300 10.73
5 At the beginning of the year SUDHIR SETHI 364400 7.18 364400 7.18
Changes during the year NIL NIL
At the end of the year 0 0.00 364400 7.18

(iv) Shareholding Pattern of top ten Shareholders

(Other than Directors, Promoters and Holders of GDRs and ADRs):

Shareholding at the beginning of the year

Cumulative Shareholding during the year

SN For each of the Top 10 shareholders Date No. of shares % of total shares No. of shares % of total shares
1 NAME: ARIHANT CAPITAL MKT. LTD
At the beginning of the year 01/04/2019 47005 0.93 47005 0.93
Changes during the year 12/04/2019 -5500 0.11 41505 0.82
20/09/2019 -30 0.00 41475 0.82
27/09/2019 2000 0.04 43475 0.86
29/11/2019 950 0.02 44425 0.88
06/12/2019 -950 0.02 43475 0.86
27/12/2019 -2000 0.04 41475 0.82
31/01/2020 500 0.01 41975 0.83
07/02/2020 100 0.00 42075 0.83
14/02/2020 -100 0.00 41975 0.83
At the end of the year 31/03/2020 - 0.00% 41,975 0.83%
2 NAME: RASHMI NAVINBHAI MEHTA
At the beginning of the year 01/04/2019 64686 1.28 64689 1.28
Changes during the year 31/05/2019 1000 0.02 65689 1.30
07/06/2019 1000 0.02 66689 1.31
17/01/2020 1000 0.02 67689 1.33
31/01/2020 600 0.01 68289 1.35
07/02/2020 50 0.00 68339 1.35
At the end of the year 31/03/2020 0 0.00 68339 1.35
NAME: JINESH JOSEPH At the beginning of the year 01/04/2019 84796 1.67 84796 1.67
Changes during the year NIL NIL NIL NIL
At the end of the year 31/03/2020 0 0.00 84796 1.67
4NAME: TARA SETHI
At the beginning of the year 01/04/2019 74104 1.46 74104 1.46
Changes during the year NIL NIL NIL NIL
At the end of the year 31/03/2020 0 0.00 74104 1.46
NAME: R. B. VIJAY
At the beginning of the year 01/04/2019 71077 1.40 71077 1.40
Changes during the year 20/12/2019 5000 0.10 76077 1.50
At the end of the year 31/03/2020 0 0.00 71077 1.50
NAME: MAYANK SIYAL
At the beginning of the year 01/04/2019 63990 1.26 63990 1.26
Changes during the year NIL NIL NIL NIL
At the end of the year 31/03/2020 0 0.00 63990 1.26
NAME: SIMIMON
KALLUPURACKAL JOBY
At the beginning of the year 01/04/2019 53335 1.05 53335 1.05
Changes during the year NIL NIL NIL NIL
At the end of the year 31/03/2020 0 0.00 53335 1.05
NAME: SUNIMA STEEL
MARKETING PVT LTD
At the beginning of the year 01/04/2019 41663 0.82 41663 0.82
Changes during the year NIL NIL NIL NIL
At the end of the year 31/03/2020 0 0.00 41663 0.82
NAME: SUDHA BIJAWAT
At the beginning of the year 01/04/2019 34896 0.69 34896 0.69
Changes during the year NIL NIL NIL NIL
At the end of the year 31/03/2020 0 0.00 34896 0.69
NAME: MOHAMMAD ALI
At the beginning of the year 01/04/2019 35016 0.69 35016 0.69
Changes during the year 06/04/2019 2004 0.04 37020 0.73
At the end of the year 31/03/2020 0 0.00 37020 0.73

(v) Shareholding of Directors and Key Managerial Personnel:

SN Shareholding of each Directors and each Key Managerial Personnel Date

Shareholding at the beginning of the year

Cumulative Shareholding during the year

No. of shares % of total shares No. of shares % of total shares
1 Name SUDHIR SETHI
At the beginning of the year 01/04/2019 3,64,400 7.18% 3,64,400 7.18%
Changes during the year NIL 0.00% 0.00%
At the end of the year 31/03/2020 - 0.00% 3,64,400 7.18%
2 Name SANJAY SETHI
At the beginning of the year 01/04/2019 5,44,300 10.73% 5,44,300 10.73%
Changes during the year NIL 0.00% 0.00%
At the end of the year 31/03/2020 - 0.00% 5,44,300 10.73%
B. Remuneration to other Direcors
SN. Particulars of Remuneration Total Amount
MR. YASHESH VASHISTHA MRS MADHU THAKUR MR. ABHINAV NAIK MRS. SHREYA SARAF (Rs/Lac)
1 Independent Directors
Fee for attending board committee meetings 5000/- 5000/- 25,000/- 25,000/- 60,000/-
Commission - -
Others, please specify - -
Total (1) 5000/- 5000/- 25,000/- 25,000/- 60,000/-
2 Other Non-Executive Directors - - -
Fee for attending board committee meetings -
Commission - - -
Others, please specify - - -
Total (2) - -
Total (B)=(1+2) 60,000/-
Total Managerial Remuneration 60,000/-
C. Remuneration to Key Managerial Personnel other than MD/Manager/WTD
SN. Particulars of Remuneration Total Amount
Name Mr. Ashish Baraskar Mrs. Neha Sharma (Rs/Lac)
Designation CFO CS
1 Gross salary 2,23,000/- Per Annum 1, 92,000/- Per Annum 4,15, 000/- Per Annum
(a) Salary as per provisions contained in section 17(1) of the Income-tax Act, 1961 - - -
(b) Value of perquisites u/s 17(2) Income-tax Act, 1961 - - -
(c) Profits in lieu of salary under section 17(3) Income- tax Act, 1961 - - -
2 Stock Option - - -
3 Sweat Equity -
- -
Commission - -
4 - as % of profit - - -
- others, specify - - -
5 Others, please specify - - -
Total 2,23,000/-Per Annum 1, 92,000/- Per Annum

4,15, 000/- Per Annum

VII. PENALTIES / PUNISHMENT/ COMPOUNDING OF OFFENCES:

Type Section of the Companies Act Brief Description Details of Penalty / Punishment/ Compounding fees imposed Authority [RD / NCLT/ COURT] Appeal made, if any (give Details)
A. COMPANY
Penalty NIL NIL NIL NIL NIL
Punishment NIL NIL NIL NIL NIL
Compounding NIL NIL NIL NIL NIL
B. DIRECTORS
Penalty NIL NIL NIL NIL NIL
Punishment NIL NIL NIL NIL NIL
Compounding NIL NIL NIL NIL NIL
C. OTHER OFFICERS IN DEFAULT
Penalty NIL NIL NIL NIL NIL
Punishment NIL NIL NIL NIL NIL
Compounding NIL NIL NIL NIL NIL