Bharat Petroleum Corporation Ltd Auditor Reports

TO THE MEMBERS OF BHARAT PETROLEUM CORPORATION LIMITED Report on the Audit of the Standalone Ind AS Financial Statements

Opinion

1. We have audited the accompanying Standalone Indian Accounting Standards ("Ind AS") Financial Statements of Bharat Petroleum Corporation Limited ("the Corporation"), which comprise the Balance Sheet as at March 31, 2024, the Statement of Profit and Loss (including Other Comprehensive Income), the Statement of Cash Flows and the Statement of Changes in Equity 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 Ind AS Financial Statements").

2. In our opinion and to the best of our information and according to the explanations given to us, the aforesaid Standalone Ind AS 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 Corporation as at March 31, 2024, the profit and total comprehensive income, its cash flows and changes in equity for the year ended on that date.

Basis for Opinion

3. We conducted our audit of the Standalone Ind AS Financial Statements in accordance with the Standards on Auditing ("SAs") specified under Section 143(10) of the Act. Our responsibilities under those Standards are further described in the Auditors Responsibilities for the Audit of the Standalone Ind AS Financial Statements section of our report. We are independent of the Corporation 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 Ind AS Financial Statements under the provisions of the Act and the Rules made 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 obtained by us is sufficient and appropriate to provide a basis for our audit opinion on the Standalone Ind AS Financial Statements.

Key Audit Matters

4. Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the Standalone Ind AS 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:

Sr. No. Key Audit Matter	Auditors Response
1. Valuation of Investment in E&P Subsidiary (Refer Note 7 and Note 56):	The following procedures were carried out in this regard:
The Corporation has an investment of I 10,926.37 crore in 100% subsidiary Bharat Petro Resources Ltd. (BPRL). This subsidiary along with its stepdown subsidiaries, JVs & Associates holds participating interest in various oil/ gas blocks for exploration & evaluation, development, and production activities (E&P).	• We evaluated the design, implementation and operating effectiveness of key controls in relation to the annual impairment testing activity carried out by the Corporation for its investments in Subsidiary.
The Corporations realization from these E&P investments is dependent on the continued successful operations/ development of reserves resulting in expected earnings and revenue growth of the respective companies. BPRL has relinquished or impaired certain oil and gas blocks on account of changes in circumstances and prospects of the blocks.	• We reviewed the audited consolidated Ind AS Financial Statements of BPRL for FY 2023-24 and the independent auditors report thereon.
The above factors have impacted the value in use of BPRLs assets and consequently the Corporations impairment analysis in respect of its Investment in BPRL. Accordingly, we considered this as a Key Audit Matter.	• We assessed the Managements explanation regarding key factors which have led to significant diminution in value of BPRLs assets vis-a-vis the previous year and consequent trigger for impairment of the Corporations investment in the same.
	• We evaluated the impairment analysis carried out during the year by the Corporation, which included an independent comparison of externally and internally assessed value in use of BPRLs Net Assets with carrying cost of investment in BPRL in the Corporations Books of Account.
2. Computation of Expected Credit Loss (ECL):	Our audit approach consisted testing of the design implementation and operating effectiveness of the internal controls and substantive testing as follows:
Trade receivables and loans granted under the Pradhan Mantri Ujwala Yojana (PMUY) scheme constitute a significant component of the total current assets of the Corporation. At each reporting date, the Corporation recognizes Lifetime ECL on Trade Receivables using a ‘simplified approach and 6 months ECL on loans are granted under the PMUY scheme wherein we relied on Managements estimates regarding probability of default rates linked to age-wise bucketing of the corresponding asset. Since, this is a technical matter based on probable outcome of default, we considered this as a Key Audit Matter.	• In respect of loans granted under PMUY, the Corporation has adopted a methodology for calculating ECL in terms of Ind AS 109 (Financial Instruments), based on the broad category of active and inactive consumers and last refill date with expected loan recovery period. We checked the working of the same and it is in line with the common methodology document shared with us.
	• We have evaluated the methodology for age-wise bucketing of trade receivables and key assumptions underlying the probability of default estimates on the same, to ascertain that the same were broadly in-line with the Corporations historical default rates and have considered available information regarding the current economic scenario.
	We selected a few samples outstanding receivable cases having different overdue periods and checked that the computation of ECL has been appropriately carried out in line with the Corporations policy.
3. Evaluation of Contingent Liabilities:	The following audit procedures were carried out in this regard:
Contingent liabilities disclosed are in respect of items which in each case are above the threshold limit. The Corporation has material uncertain positions including matters under dispute which involves significant judgment to determine the possible outcome of these disputes. Contingent liabilities are not recognized in the Standalone Ind AS Financial Statements but are disclosed unless the possibility of an outflow of economic resources is considered remote. In view of significant management estimate and judgement involved, we considered this as a Key Audit Matter.	• We examined sample items above the threshold limit for determination of contingent liabilities and obtained details of completed Excise, VAT/ Sales Tax/ Goods and Service Tax (GST), Entry Tax assessments, demands as well as other disputed claims against the Corporation as on March 31, 2024. The Corporation has obtained opinion from external experts / consultants in various disputed matters. We have relied upon such opinions and litigation history where the Corporation has concluded that possibility of cash outflow is remote while preparing its Standalone Ind AS Financial Statements.
	• We have assessed the Managements underlying assumptions in estimating the possible outcome of such disputed claims/ cases against the Corporation, based on records and judicial precedents made available.
4. Inventories:
Verification and valuation of Inventories and related write down, if any, is a significant area requiring Managements judgment of estimates and application of accounting policies that have significant effect on the amounts recognized in the Standalone Ind AS Financial Statements. Accordingly, we considered this as a Key Audit Matter.	Our audit approach involved the following combination of test of control design, implementations, operating effectiveness and substantive testing in respect of verification and valuation of inventories:
	• We evaluated the system of inventory monitoring and control. It was observed that inventory has been physically verified by the Management during the year at reasonable intervals.
	• Our audit teams have also physically verified on sample basis, the Inventories at various locations and compliance with cut off procedures. However, since physical verification at certain locations was not possible for us, in such cases we have relied on the physical verification of inventory carried out by the Management.
	• In respect of inventory lying with third parties, we have ascertained that these have substantially been confirmed by them. We also examined the system of records maintenance for stocks lying at third party locations.
	• We have also tested the values considered in respect of Net realisable value, cost of products and verified these on sample basis with the inventory valuation and accounting entries posted in this regard.
5. Property, Plant & Equipment:
Estimates of useful lives and residual value of Property, Plant and Equipment is a significant area requiring Management judgment of estimates and application of accounting policies that have significant effect on the amounts recognized in the Standalone Ind AS Financial Statements. Accordingly, we considered this as a Key Audit Matter.	Our audit approach involved the following combination of test of control design, implementations and operating effectiveness and substantive testing in respect of verification and recording of Property, Plant & Equipment:
	• We examined whether the Corporation has maintained proper records showing full particulars, including quantitative details and situation of fixed assets.
	• The physical verification of Property, Plant and Equipment (except LPG Cylinders and pressure regulators with customers) has been carried out by the Management in accordance with the phased program of verification of all assets and necessary accounting entries based on such physical verification have been appropriately posted which were verified by us.
	• Changes in the useful life and residual value of class of assets were adopted based on internal evaluation and was also comparable with other entities in the same industry.
	• We have tested the computation of depreciation on sample basis.
6. Goodwill:
The Corporation tests for impairment of Goodwill at the reporting date, or whenever events or circumstances indicate that the implied fair value of goodwill is less than its carrying amount. Accordingly, we considered this as a Key Audit Matter.	Our Audit Procedures included Test of Details in respect of the following:
	a) Obtained an understanding from the management with respect to process and controls followed by the Corporation to perform annual impairment test related to goodwill.
	b) Obtained the impairment analysis model from the management and reviewed their conclusions.
	c) We assessed the reasonableness of the assumptions used and appropriateness of the valuation methodology applied.
	d) Tested the discount rate and long-term growth rates used in the forecast including comparison to economic and industry forecasts where appropriate.
	e) Assessed and validated the adequacy and appropriateness of the disclosures made by the management in the standalone financial statements.
7. Information Technology	Our procedures included:
A significant part of the Corporations financial reporting process is heavily reliant on IT systems with automated processes and controls over the capture, storage and extraction of information. A fundamental component of these processes and controls is ensuring appropriate user access and change management protocols exist and being adhered to.	We focused our audit on those IT systems and controls that are relevant to preparation of financial statements for financial year ended March 31,2024.
These protocols are important because they ensure that access and changes to IT systems and related data are made and authorized in an appropriate manner. As our audit sought to place a high level of reliance on IT systems and application controls related to financial reporting, high proportion of the overall audit effort was in Information Technology (IT) Systems and Controls.	As audit procedures over IT Systems and controls require specific expertise, we involved our IT specialist.
	Our review of the IT Controls covers the following areas:
	• Physical and Logical Security;
	• Change Management;
	• Backup, Business Continuity and
	• IT Operations.
We focused our audit on those IT systems and controls that are significant to the Corporations financial reporting process.	Our assessment of the IT Controls is performed according to the following approach:
Accordingly, we considered this as a Key Audit Matter.	• Understanding the IT environment.
	• Information gathering about the control framework surrounding the IT environment.
	• Evidence gathering with respect to Control testing.
	• Review of Implementation of controls testing.
	• Review of limited cases to identify whether there had been unauthorized or inappropriate access or changes made to critical IT systems and related data.

Information Other than the Standalone Ind AS Financial Statements and Auditors Report Thereon

5. The Corporations Board of Directors is responsible for the preparation of 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 Standalone Ind AS Financial Statements and our audit report thereon.

Our opinion on the Standalone Ind AS Financial Statements does not cover the other information and we do not express any form of assurance thereon.

6. In connection with our audit of the Standalone Ind AS Financial Statements, our responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent with the Standalone Ind AS Financial Statements or our knowledge obtained during the course of our audit or otherwise appears to be materially misstated.

7. 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 to those charged with governance.

The Other information is expected to be made available to us after the date of this auditors report and if we conclude that there is a material misstatement therein, we are required to communicate the matter to those charged with governance.

Board of Directors /Managements Responsibility for the Standalone Ind AS Financial Statements

8. The Corporations Board of Directors is responsible for the matters stated in Section 134(5) of the Act with respect to the preparation of these Standalone Ind AS Financial Statements that give a true and fair view of the financial position, financial performance including the other comprehensive income, cash flows and changes in equity of the Corporation in accordance with the Ind AS and other accounting principles generally accepted in India. This responsibility also includes maintenance of adequate accounting records in accordance with the provisions of the Act for safeguarding the assets of the Corporation 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 Ind AS Financial Statements that give a true and fair view and are free from material misstatement, whether due to fraud or error.

9. In preparing the Standalone Ind AS Financial Statements, management is responsible for assessing the Corporations 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 Corporation or to cease operations, or has no realistic alternative but to do so.

10. The Corporations Board of Directors /Management is responsible for overseeing the Corporations financial reporting process.

Auditors Responsibilities for the Audit of the Standalone Ind AS Financial Statements

11. Our objectives are to obtain reasonable assurance about whether the Standalone Ind AS 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 Ind AS Financial Statements.

12. 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 Ind AS 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 Corporation 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 Corporations 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 Ind AS 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 Corporation to cease to continue as a going concern.

• Evaluate the overall presentation, structure and content of the Standalone Ind AS Financial Statements, including the disclosures, and whether the Standalone Ind AS Financial Statements represent the underlying transactions and events in a manner that achieves fair presentation.

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

14. 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.

15. 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.

16. From the matters communicated with those charged with governance, we determine those matters that were of most significance in the audit of the Standalone Ind AS 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.

Other Matter

17. The Corporation is having six independent directors, five executive directors (including the Chairman and Managing director) and two government nominee directors on its Board of Directors. Accordingly, the Board of the Corporation does not have an optimum combination of executive and non-executive directors, as per Regulation 17(1) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 as amended.

Our Opinion is not modified in respect of the above matter.

Report on Other Legal and Regulatory Requirements

18. 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, and on the basis of verification of the books and records of the Corporation, as we considered appropriate and according to the information and explanations given to us, we give in "Annexure A" a statement on the matters specified in paragraphs 3 and 4 of the Order to the extent applicable.

19. As required by Section 143(5) of the Act, we give in "Annexure B", a statement on the matters specified by the Comptroller and Auditor General of India for the Corporation.

20. As required by Section 143(3) of the Act, based on our audit we report that:

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

b) In our opinion, proper books of account as required by law have been kept by the Corporation so far as it appears from our examination of those books.

c) The Balance Sheet, the Statement of Profit and Loss including Other Comprehensive Income, the Statement of Cash Flow and Statement of Changes in Equity dealt with by this Report are in agreement with the relevant books of account.

d) In our opinion, the aforesaid Standalone Ind AS Financial Statements comply with the Ind AS specified under Section 133 of the Act.

e) In view of exemption given vide notification no. G.S.R. 463(E) dated June 5, 2015, issued by Ministry of Corporate Affairs, provisions of Section 164(2) of the Act regarding disqualification of directors, are not applicable to the Corporation.

f) With respect to the adequacy of the internal financial controls over financial reporting of the Corporation and the operating effectiveness of such controls, refer to our separate Report in "Annexure C".

g) Being a Government Corporation, pursuant to the notification number GSR 463(E) dated June 5, 2015 issued by the Government of India, the provisions of Section 197 of the Act are not applicable to the Corporation.

h) 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:

i. The Corporation has disclosed the impact, if any, of pending litigations on its financial position in its Standalone Ind AS Financial Statements. (Refer Note 63 of the Standalone Ind AS Financial Statements;)

ii. The Corporation has made provision, as required under the applicable law or accounting standards, for material foreseeable losses, if any, on long-term contracts including derivative contracts.

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

i) (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 Corporation 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 Corporation ("Ultimate Beneficiaries") or provide any 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 (which are material either individually or in the aggregate) have been received by the Corporation from any person or entity, including foreign entity ("Funding Parties"), with the understanding, whether recorded in writing or otherwise, that the Corporation 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;

(c) 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) of the Companies (Auditor and Auditors) Rules, 2014, as provided under (a) and (b) above, contain any material misstatement.

j) As stated in Note 24 to the standalone Ind AS financial statements, the Board of Directors of the Corporation have proposed final dividend for the year which is in accordance with Section 123 of the Act to the extent it applies to declaration of dividend. Final dividend paid during the year in respect of the previous year is in accordance with Section 123 of the Act.

k) Based on our examination which included test checks, the Corporation has used an accounting software for maintaining its books of account which has a feature of recording audit trail (edit log) facility and the same has operated throughout the year for all relevant transactions recorded in the software. Further, during the course of our audit we did not come across any instance of 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 year ended March 31, 2024.

ANNEXURE A TO INDEPENDENT AUDITORS REPORT

[Referred to in paragraph 18 under Report on Other Legal and Regulatory Requirements in the Independent Auditors

Report of even date to the members of Bharat Petroleum Corporation Limited ("the Corporation") on the Standalone Ind AS

Financial Statements as of and for the year ended March 31, 2024]

To the best of our information and according to the explanations provided to us by the management of the Corporation and the books of account and records examined by us in the normal course of audit we state that:

(i) (a) A. The Corporation is maintaining proper records showing full particulars, including quantitative details and situation of Property, Plant and Equipment;

B. The Corporation is maintaining proper records showing full particulars of Intangible assets;

(b) As per information and explanations given to us, physical verification of Property, Plant and Equipment (except LPG Cylinders and pressure regulators with customers) has been carried out by the Management during the year in accordance with the phased program of verification of all assets over three years. As informed, no material discrepancies were noticed on such verification;

(c) According to the information and explanations given to us and on the basis of our examination of the records of the Corporation, the title deeds of all the immovable properties (other than properties where the Corporation is a lessee and the lease agreements are duly executed in favor of the lessee) disclosed in the Standalone Ind AS Financial statements are held in the name of the Corporation, except in cases given in Statement 1 and title deeds held in the name of the subsidiaries Bharat Gas Resources Limited (BGRL) and Bharat Oman Refineries Limited (BORL) are in the process of getting transferred in the name of the Corporation). These subsidiaries have been amalgamated with the Corporation as per the Ministry of Corporate Affairs (MCA) orders approving the scheme of amalgamation; (Refer Note 45 to the standalone financial statements)

(d) As per the information obtained and explanations given to us, the Corporation has not revalued its Property, Plant and Equipment (including Right-of-Use assets) or intangible assets or both during the year;

(e) As per the information obtained and explanations given to us, no proceedings have been initiated or are pending against the Corporation for holding any benami property under the Benami Transactions (Prohibition) Act, 1988 (45 of 1988) and rules made thereunder.

(ii) (a) The inventory (excluding stocks with third parties and goods in transit) has been physically verified by the Management during the year at reasonable intervals. In respect of inventory lying with third parties, these have substantially been confirmed by them. In our opinion, the coverage and procedure of such verification is appropriate considering the size and nature of the business of the Corporation. As per the information and explanations given to us, no material discrepancies of 10% or more in the aggregate for each class of inventory were noticed on the said physical verification carried out by the Management;

(b) The Corporation 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. As per the information obtained and explanations given to us and as disclosed/ demonstrated by the records/ reconciliations produced to us for our verification, the quarterly returns or statements filed by the Corporation with such banks and financial institutions are in agreement with the books of account of the Corporation.

(iii) (a) During the year if the Corporation has made 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, accordingly, we have to report as under:

(Rs in crore)

Particular	Guarantees	Security	Loans	Advances in nature of loans
Aggregate amount granted/ provided during the year
- Subsidiary	5,467.43		-
- Joint Venture	-		-
- Associate	159.00
- Others	-		39.86
Balance outstanding as at balance sheet date
- Subsidiary	20,040.68		-
- Joint Venture	753.50		7.50
- Associate	159.00		-
- Others	-		1,253.91

(b) As per the information obtained and explanations given to us, the investments made, guarantees provided, security given and the terms and conditions of the grant of all loans and advances in the nature of loans and guarantees provided are not prejudicial to the Corporations interest;

(c) In respect of loans and advances in the nature of loans, as per the terms of loans, the principal amount is not due during the year. The Corporation has been regular in the receipt of interest towards the same;

(d) There is no amount overdue for more than ninety days so the question of taking reasonable steps to recover principal and interest does not arise;

(e) No loan or advance in the nature of loan granted which has fallen due during the year, has been renewed or extended or fresh loans granted to settle the overdues of existing loans given to the same parties. Therefore, the question of specifying the aggregate amount of such dues renewed or extended or settled by fresh loans and the percentage of the aggregate to the total loans or advances in the nature of loans granted during the year does not arise;

(f) The Corporation has not granted any loans or advances in the nature of loans either repayable on demand or without specifying any terms or period of repayment. Therefore, the question of specifying the aggregate amount, percentage thereof to the total loans granted, aggregate amount of loans granted to Promoters, related parties as defined in clause (76) of Section 2 of the Act, does not arise.

(iv) In our opinion and according to the information obtained and explanations given to us, the Corporation has complied with the provisions of Section 185 and Section 186 of the Act, with respect to the loans, investments, guarantees and securities.

(v) In our opinion and according to the information obtained and explanations given to us, the Corporation has not accepted any deposits from public and it does not have any amounts which are deemed to be deposits within the provisions of Sections 73 to 76 of the Act read with The Companies (Acceptance of Deposits) Rules, 2014 and other relevant provisions of the Act.

(vi) Maintenance of cost records has been specified by the Central Government under Section 148(1) of the Act and the rules framed thereunder for the products manufactured by the Corporation. Such accounts and records as prescribed have been so made and maintained. We have not, however, made a detailed examination of the same with a view to determining whether they are accurate or complete.

(vii) (a) The Corporation is generally regular in depositing with appropriate authorities, undisputed statutory dues including

Goods and Service Tax, Provident Fund, Employees State Insurance, Income-Tax, Sales-Tax, Service Tax, Duty of customs, Duty of Excise, Value Added Tax, Cess and any other statutory dues applicable to it. According to the information and explanations given to us, no undisputed amounts payable in respect of Goods and Service Tax, Provident Fund, Employees State Insurance, Income-Tax, Sales-Tax, Service Tax, Duty of customs, Duty of Excise, Value Added Tax, Cess and any other statutory dues applicable to it, were outstanding, as on the last day of the financial year, for a period of more than six months from the date they became payable.

(b) According to the information obtained and explanation given to us, the statutory dues referred to in (vii)(a) above, which have not been deposited on account of any dispute, are as per Statement 2.

(viii) No transactions have been surrendered or disclosed as income during the year in the tax assessments under Income Tax Act, 1961 (43 of 1961), which were not recorded in the books of account. Therefore, question of recording of the income during the year which was previously unrecorded in the books of account does not arise.

(ix) (a) According to the information obtained and explanations given to us, the Corporation has not defaulted in repayment

of loans or other borrowings or in the payment of interest thereon to any lender. Therefore, the question of reporting on the period and amount of default does not arise;

(b) The Corporation is not a declared wilful defaulter by any bank or financial institution or other lender;

(c) According to the information obtained and explanations given to us, the term loans were applied for the purpose for which the loans were obtained;

(d) On an overall examination of the financial statements of the Corporation, Funds raised on short-term basis have, prima-facie, have not been utilized during the year for long-term purposes. For the purpose of reporting under this clause, LPG Deposits received have not been considered as short-term funds as the amounts to be repaid during next 12 months are expected to be insignificant;

(e) The Corporation 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. Therefore, the question of reporting on details thereof with nature of such transactions and the amount does not arise;

(f) The Corporation has not raised loans during the year on the pledge of securities held in its subsidiaries, joint ventures or associate companies. Therefore, the question of reporting on details thereof and default, if any, in repayment of such loans raised does not arise.

(x) (a) The Corporation did not raise any money by way of initial public offer or further public offer (including debt instruments) during the year. Therefore, the question of reporting of its application, delays or default and subsequent rectification, if any, does not arise;

(b) According to the information and explanations given to us and based on our examination of the books and records, the Corporation has not made any preferential allotment or private placement of shares or convertible debentures (fully, partially or optionally convertible) during the year. Therefore, the question of complying with Section 42 and Section 62 of the Act and reporting on its utilization does not arise.

(xi) (a) During the course of our examination of the books and records of the Corporation, carried out in accordance with the generally accepted auditing practices in India and according to the information obtained and explanations given to us, we did not come across any fraud committed by the Corporation and no material fraud on the Corporation have been noticed or reported during the year;

(b) We, have not filed any report under Sub-Section 12 of Section 143 of the Companies Act, 2013 in Form ADT-4 as prescribed under rule 13 of the Companies (Audit and Auditors) Rules, 2014 with the Central Government;

(c) As per the information obtained and explanation given by the Corporation, no Whistle-blower complaint has been received by the Corporation during the year.

(xii) In our opinion and according to the information obtained and explanations given to us, the Corporation is not a Nidhi Company. Accordingly, paragraph 3(xii)(a, b and c) of the Order are not applicable to the Corporation.

(xiii) According to the information obtained and explanations given to us and based on our examination of the records of the Corporation, all transactions entered into by the Corporation with the related parties are in compliance with Sections 177 and 188 of the Act where applicable and details of such transactions have been disclosed in the Standalone Ind AS Financial Statements, as required by the applicable Indian Accounting Standards.

(xiv) (a) The Corporation has an internal audit system commensurate with the size and nature of its business;

(b) We have considered, the reports of the internal auditor for the year under audit, issued to the Corporation during the year.

(xv) According to the information obtained and explanations given to us and based on our examination of the records, the Corporation has not entered during the year into non-cash transactions with directors or persons connected with them. Accordingly, paragraph 3(xv) of the Order is not applicable.

(xvi) The Corporation is not required to be registered under Section 45-IA of the Reserve Bank of India Act, 1934. Accordingly, paragraph 3(xvi) (a,b,c and d) of the Order are not applicable.

(xvii) The Corporation has not incurred cash losses in the current financial year and in the immediately preceding financial year.

(xviii) There has not been any resignation of the statutory auditors during the year.

(xix) According to the information obtained and explanations given to us and on the basis of the financial ratios, ageing and expected dates of realization of financial assets and payment of financial liabilities, other information accompanying the financial statements, our knowledge of the Board of Directors and management plans, we are of the opinion that no material uncertainty exists as on the date of the audit report that Corporation is capable of meeting its liabilities existing as 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 Corporation. 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 Corporation as and when they fall due.

(xx) (a) There are no unspent amount towards Corporate Social Responsibility (CSR) on other than ongoing projects, requiring a transfer the unspent amount to a Fund specified in Schedule VII to the 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 respect of on-going projects, the Corporation has transferred amount remaining unspent as at the year end to a special account with in a period of 30 days from the end of the said financial year in compliance with the provisions of sub-section (6) of Section 135 of the said Act.

STATEMENT 1 (REFER CLAUSE i (c) OF ANNEXURE A)

Rs in crore

Description of property	Gross carrying value Kin crore	No. of Cases	Held in name of	Whether promoter, director or their relative or employee	Period held - indicate range, where appropriate	Reason for not being held in name of Corporation*
Land	144.46	14	a) Rajaswa Vibag, Jiladikari, Udhamsingh Nagar,	No	1928-2023	Registration Pending with Authorities (In one of the case, Title Deed is in the name of Joint Owner)
			b) Railways,
			c) Karnataka Industrial Areas Development Board (KIADB),
			d) Hindusthan Petroleum Corporation Limited (HPCL),
			e) Government of Kerala,
			f) Government of Maharashtra,
			g) Deputy Salt Commissioner, Bombay,
			h) Telangana State Industrial Infrastructure Corporation,
			i) Others
Right-of-Use Assets	0.51	01	Karnataka Industrial Area Development Authority (KIADB)	No	01-04-1983	Land Allotment Case
Land	1.23	04	a) British India Company Limited, b) District Magistrate Mathura,	No	1994-2004	Legal Dispute
			c) Railways,
			d) Andhra Pradesh Industrial Infrastructure Company (APIIC),
Land	2.28	02	Andhra Pradesh Industrial Infrastructure Company (APIIC)	No	1985	Land Allotment Case

(Refer Additional information in respect of Notes 2 to 6 (Part S), of the standalone financial statements)

Note: Original 54 Title deeds amounting to Rs 70.31 crore (which includes 21 Title deeds held in the name of erstwhile subsidiary BORL) are not available with the Corporation. However, the same have been verified based on copies made available to us for verification.

STATEMENT 2 (REFER CLAUSE vii (b) OF ANNEXURE A)

AMOUNTS INVOLVED AND FORUM WHERE DISPUTE IS PENDING SHALL BE MENTIONED.

Sr. No. Name of the Statute	Nature of dues	Forum where dispute is pending	Amount (Kin crore)	Period block to which it relates*
1 Central Excise Act, 1944	Duty, interest and penalty for cases relating to determination of assessable value, Cenvat credit etc.	Supreme Court	2,403.29	2000-2010
		High Court	41.58	2000-2015
		Appellate Tribunal*	2,802.24	1990-2023
		Appellate Authority**	59.43	1995-2022
		Adjudicating Authority***	0.00	2010-2020
		Total	5,306.54
2 Customs Act, 1962	Duty, Interest and Penalty for cases relating to determination of valuation etc.	Appellate Tribunal *	4.58	1995-2015
		Appellate Authority**	6.61	2010-2015
		Total	11.19
3 Income Tax Act, 1961	Tax, Interest and Penalty demands towards various income tax disputes	Appellate Authority**	223.91	2005-2023
		Adjudicating Authority***	0.23	2005-2023
		Total	224.14
4 Sales Tax/ VAT/ GST Legislations	Tax, Interest and Penalty demands towards various Sales Tax/ VAT/ GST disputes	Supreme Court	364.20	1995-2010
		High CourtAA	402.70	1995-2020
		Appellate Tribunal*	3,428.72	1985-2020
		Appellate Authority**	681.43	1985-2020
		Adjudicating Authority***	0.44	2020-2024
		Total	4,877.49
5 Finance Act, 1994 (Service Tax)	Duty, Interest and Penalty for cases relating to Service Tax disputes	Supreme Court	39.32	2005-2015
		High Court	20.26	2000-2005
		Appellate Tribunal*	1,302.45	2005-2020
		Appellate Authority**	5.66	2000-2020
		Total	1,367.69
6 The Environment Protection Act,1986	Compenzation for environmental damage caused by VOX pollutants	Supreme Court	67.50	2020-2022
7 Bombay Provincial Municipal Corp. Act, 1949	Property Tax	High Court	6.29	2010-2020
		Adjudicating Authority	41.74	1995-2013
		Total	48.03
8 Maharashtra Municipal Council/ Nagarpanchayat Industrial Township Act	Manmad Export Fees Case	High Court	22.15	1995-2000
9 National Green Tribunal Act, 2010	Compenzation for Green Belt Development	Supreme Court	2.00	2017-2022
10 The Delhi Municipal Corporation Act, 1957	Property Tax	High Court	59.52	2005-2015
11 The New Delhi Municipal Council Act, 1994	Property Tax	Appellate Authority	3.84	2020-2024
		Adjudicating Authority	1.07	2020-2024
		Total	4.91
12 Indian Stamp Act, 1889	Stamp Duty	Revenue Board of MP	52.74	2020-2024
Grand Total			12,043.90

Remarks:

Dues Include Penalty & Interest, wherever applicable.

* Appellate Tribunal includes Sales Tax Tribunal, CESTAT and ITAT.

** Appellate Authority includes Commissioner Appeals, Assistant Commissioner Appeals, Deputy Commissioner Appeals, Joint Commissioner Appeals and Deputy Commissioner Commercial Taxes Appeals.

*** Adjudicating Authority includes Collector of Sales Tax, Sales Tax Officer and Deputy Commissioner Sales Tax, Joint / Deputy/ Additional Commissioner of Commercial Taxes etc.

a Period block shall indicate the period interval in which all the disputes under that authority have taken place.

AA Does not include Rs 80.14 crore deposited with the Court as per Garnishee Order for which the credit is not yet given by the Sales Tax Department.

ANNEXURE B TO INDEPENDENT AUDITORS REPORT

[Referred to in paragraph 19 under "Report on Other Legal and Regulatory Requirements" in the Independent Auditors Report of even date to the Members of Bharat Petroleum Corporation Limited ("the Corporation") on the Standalone Ind AS Financial Statements as of and for the year ended March 31, 2024]

CAG DIRECTIONS FOR THE YEAR 2023-24

1. Whether the Company has system in place to process all the accounting transactions through IT systemRs If yes, the implications of processing of accounting transactions outside IT system on the integrity of the accounts along with the financial implications, if any, may be stated.

The Corporation has a system in place to process all the accounting transactions through its implemented IT system (SAP). As such, we have not come across any accounting transactions processed outside IT systems which would have an impact on the integrity of the accounts or any financial implications.

2. Whether there is any restructuring of an existing loan or cases of waiver/write off of debts/ loans/ interest etc. made by a lender to the Company due to the Companys inability to repay the loanRs If yes, the financial impact may be stated. Whether such cases are properly accounted forRs (In case, lender is a Government company, then this direction is also applicable for statutory auditor of lender company).

There has been no case of restructuring of an existing loan or cases of waiver/ write off of debts/ loans/ interest etc. made by a lender to BPCL due to the BPCLs inability to repay the loan in FY 2023-24.

3. Whether funds (grants/subsidy etc.) received/ receivable for specific schemes from Central/ State Government of its agencies were property accounted for/ utilized as per its term and conditionsRs List the cases of deviation.

Funds (grants/subsidy etc.) received/ receivable for specific schemes from Central/ State Government of its agencies were properly accounted for/ utilized as per its terms and conditions.

ANNEXURE C TO INDEPENDENT AUDITORS REPORT

[Referred to in paragraph 20(f) under Report on Other Legal and Regulatory Requirements in the Independent Auditors Report of even date to the members of Bharat Petroleum Corporation Limited on the Standalone Ind AS Financial Statements for the year ended March 31, 2024]

REPORT ON THE INTERNAL FINANCIAL CONTROLS WITH REFERENCE TO THE STANDALONE IND AS FINANCIAL STATEMENTS UNDER CLAUSE (i) OF SUB-SECTION 3 OF SECTION 143 OF THE COMPANIES ACT, 2013 ("THE ACT")

We have audited the internal financial controls with reference to the Standalone IndAS financial statements of Bharat Petroleum Corporation Limited ("the Corporation") as of March 31, 2024, in conjunction with our audit of the Standalone Ind AS Financial Statements of the Corporation for the year ended on that date.

MANAGEMENTS RESPONSIBILITY WITH REFERENCE TO THE STANDALONE IND AS FINANCIAL STATEMENTS

The Corporations Management is responsible for establishing and maintaining internal financial controls based on the internal control with reference to the Standalone Ind AS Financial Statements established by the Corporation considering the essential components of internal control stated in the Guidance Note on Audit of Internal Financial Controls with reference to the Standalone Ind AS Financial Statements issued by the Institute of Chartered Accountants of India (the ICAI). 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 Corporations policies, safeguarding of its assets, the prevention and detection of frauds and errors, the accuracy and completeness of the accounting records, and the timely preparation of reliable financial information, as required under the Act.

AUDITORS RESPONSIBILITY

Our responsibility is to express an opinion on the Corporations internal financial controls with reference to the Standalone Ind AS Financial Statements 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") issued by the ICAI and the Standards on Auditing specified under Section 143(10) of the Act, to the extent applicable to an audit of internal financial controls, both issued by the ICAI. 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 were established and maintained and if such controls operated effectively in all material respects.

Our audit involves performing procedures to obtain audit evidence about the adequacy of the internal financial controls system with reference to the Standalone Ind AS Financial Statements and their operating effectiveness. Our audit of internal financial controls with reference to the Standalone Ind AS Financial Statements included obtaining an understanding of internal financial controls with reference to the Standalone Ind AS Financial Statements, 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 judgment, including the assessment of the risks of material misstatement of the 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 Corporations internal financial controls system with reference to the Standalone Ind AS Financial Statements.

MEANING OF INTERNAL FINANCIAL CONTROLS WITH REFERENCE TO THE STANDALONE IND AS FINANCIAL STATEMENTS

A Corporations internal financial control with reference to the Standalone Ind AS Financial Statements is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles. A Corporations internal financial control with reference to the Standalone Ind AS Financial Statements 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 Corporation;

2. Provide reasonable assurance that transactions are recorded as necessary to permit preparation of Standalone Ind AS financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the Corporation are being made only in accordance with authorizations of management and directors of the Corporation; and

3. Provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the Corporations assets that could have a material effect on the financial statements.

INHERENT LIMITATIONS OF INTERNAL FINANCIAL CONTROLS WITH REFERENCE TO THE STANDALONE IND AS FINANCIAL STATEMENTS

Because of the inherent limitations of internal financial controls with reference to the Standalone Ind AS Financial Statements, including the possibility of collusion or improper management override of controls, material misstatements due to error or fraud may occur and not be detected. Also, projections of any evaluation of the internal financial controls with reference to the Standalone Ind AS Financial Statements to future periods are subject to the risk that the internal financial control with reference to the Standalone Ind AS Financial Statements 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, to the best of our information and according to the explanations given to us, the Corporation has, in all material respects, an adequate internal financial controls with reference to standalone financial statements and such internal financial controls were operating effectively as at March 31, 2024, based on the criteria for internal financial control over financial reporting established by the Corporation considering the essential components of internal control stated in the Guidance Note on Audit of Internal Financial Controls Over Financial Reporting issued by the ICAI.

For Kalyaniwalla & Mistry LLP	For K. S. Aiyar & Co
Chartered Accountants	Chartered Accountants
ICAI FRN: 104607W/W100166	ICAI FRN: 100186W
Sd/-	Sd/-
Sai Venkata Ramana Damarla	Rajesh S. Joshi
Partner	Partner
M. No. 107017	M. No.038526
UDIN: 24107017BKERTS3327	UDIN: 24038526BKEKRQ3726
Place: Mumbai	Place: Mumbai
Date: May 9, 2024	Date: May 9, 2024