cmm infraprojects ltd share price Auditors report

To,

The Members,

CMM Infraprojects Ltd.

Indore(Madhya Pradesh)

(CIN No.: L45201MP2006PLC018506)

Report on the Financial Statements

We have audited the accompanying financial statements of CMM Infraprojects Ltd.("A Company") Registered Address Shalimar Corporate, 108, 86, South Tukoganj, Indore, (Madhya Pradesh) 452001, which comprise the Balance Sheet as at March 31, 2022, and the Statement of Profit and Loss and Cash Flow Statement for the year ended March 31,2022 and a summary of significant accounting policies and other explanatory information of the company.

Qualified Opinion

In our opinion and to the best of our information and according to the explanations given to us, the financial statements give the information required by the Act in the manner so required and give a true and fairview in conformity with the accounting principles generally accepted in India except points mentioned in qualified opinion para:

(a) In the case of the Balance Sheet, of the state of affairs of the company as at 31^st March, 2022;

(b) In the case of the Statement of Profit and Loss of the profit, for the year ended on that date; and

(c) In the case of the Cash flow Statement, for the year ended on that date.

Basis for Qualified Opinion

(a) Regarding non confirmation of term Borrowing Rs. 146.62/- Lacs, Trade Creditors Rs. 264.03/- Lacs, Advance to Supplier Rs. 140.92/- Lacs, Long term loans & advances of Rs. 244.35/- Lacs, and Current Liabilities of Rs. 341.75/- Lacs and any consequential adjustment thereof in books of accounts and their monetary impact on the respective Assets, Liabilities and Profit/Loss for the year, which is presently unascertainable;

(b) Regarding non-provision of towards doubtful Trade Receivables aggregating to Rs. 448.86/- Lacs. However, the Company is hopeful of their complete recovery and hence no provision is necessary. Due to the above nonprovision, Profit for the year has been overstated by Rs. 448.86/- Lacs with an overstatement in Trade Receivables to the same extent.

(c) Interest on secured loan to Bankers/Institutions has not been provided in the financial statements. This is in contravention to the provisions to the Accounting Standard (AS) 29 regarding the "Provisions, Contingent Liabilities and Contingent Assets". The Company has earned a net profit after tax of Rs. 51.44/- lacs during the period ended 31st March 2022 without providing for interest of Rs. 94.15/ - lacs for the period ended 31st March 2022. The accumulated interest of Rs. 94.15/ -Lacs till 31st March 2022. Hence, liabilities has been understated and profit has been over stated by Rs. 94.15/- lacs.

(d) The provisions contained in section 135 of the Act as applicable which is related to CSR activities has not been complied by the company. Unspent accumulated CSR amount is Rs. 17.83 Lacs till 31st March 2022.

Key Audit Matters

Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the financial statements of the current period. These matters were addressed in the context of our audit of the financial statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters. There is no key audit matter to be communicated in our report.

Other Matters

We do not audit the two branches, Nagpur and Bhubaneswar. These financial statements have been audited by other auditors whose reports have been furnished to us by the management, and our opinion on the financial statement of the company for the year ended to the extent they relate to the financial statement not audited by us stated in this paragraph is solely based on the audit report of other auditor. Our opinion is not qualified in respect of this matter.

Information Other than the Financial Statements and Auditors Report Thereon

The Companys 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 Annexuxe to Boards Report and Business Responsibility Report, but does not include the financial statements and our auditors report thereon.

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

In connection with our audit of the financial statements, our responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent with the financial 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 Financial Statements

The Companys Board of Directors is responsible for the matters stated in Section 134(5) of the Companies Act, 2013 ("the Act") with respect to the preparation and presentation of these financial statements that give a true and fair view of the financial position, financial performance, total comprehensive income, changes in equity and cash flows of the Company in accordance with the accounting principles generally accepted in India, prescribed under Section 133 of the Act. This responsibility also includes maintenance of adequate accounting records in accordance with the provisions of the Act for safeguarding of the assets of the Company and for preventing and detecting frauds and other irregularities; selection and application of appropriate accounting policies; making judgments and estimates that are reasonable and prudent; and design, implementation and maintenance of adequate internal financial controls, that were operating effectively for ensuring the accuracy and completeness of the accounting records, relevant to the preparation and presentation of the financial statements that give a true and fair view and are free from material misstatements, whether due to fraud or error.

In preparing 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.

The Board of directors are also responsible for overseeing the Companys financial reporting process.

Auditors Responsibilities for the Audit of the Financial Statements

Our objectives are to obtain reasonable assurance about whether the financial statements, as a whole, are free from material misstatements, 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 it 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 financial statements.

As part of an audit in accordance with SAs, we exercised professional judgment and maintain professional skepticism throughout the audit. We also:

• Identify and assess the risks of material misstatement of the 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 alsoresponsible for expressing our opinion on whether the Company has adequate internal financial controls system in place and the operating effectiveness of such controls.

• Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and related disclosures made by management.

• Conclude on the appropriateness of managements use of the going concern basis of accounting and, based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Companys ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditors report to the related disclosures in the financial statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based on the audit evidence obtained up to the date of our auditors report. However, future events or conditions may cause the Company to cease to continue as a going concern.

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

Materiality is the magnitude of misstatements in the 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 financial statements.

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

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

From the matters communicated with those charged with governance, we determine those matters that were of most significance in the audit of the financial statements of the current period and are therefore the key audit matters. We describe these matters in our auditors report unless law or regulation precludes public disclosure about the matter or when, in extremely rare circumstances, we determine that a matter should not be communicated in our report because the adverse consequences of doing so would reasonably be expected to outweigh the public interest benefits of such communication.

Report on Other Legal and Regulatory Requirements

1. As required by the Companies (Auditor⁷s Report) Order, 2020 ("the Order") issued by the Central Government of India in terms of sub-section (11) of section 143 of the Act, we give in the "Annexure A" statement on the matters specified in the paragraph 3 and 4 of the Order, to the extent applicable.

2. As required by section 143(3) of the Act, we report that:

a. we have sought obtained all the information and explanations which to the best of our knowledge and belief were necessary for the purpose of our audit;

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

c. In our opinion the Balance Sheet, Statement of Profit and Loss and cash flow statement, dealt with by this Report are in agreement with the books of account;

d. In our opinion, the aforesaid financial statements comply with the Accounting Standards specified under Section 133 of the Act, with the rule of the Companies (Accounts)Rules, 2014;

e. On the basis of written representations received from the directors as on 31^st March, 2022, taken on record by the Board of Directors, none of the directors is disqualified as on 31^st March,2022, from being appointed as a director in terms of Section 164(2) of the Act.

f. With respect to the adequacy of the internal financial controls over financial reporting of the company and the operating effectiveness of such controls, refer to our separate report in Annexure B. Our Report expresses disclaimer of opinion on the companys internal financial controls over financial reporting for the reason stated therein.

g. 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, in our opinion and to the best of our information and according to the explanations given to us.

i. The company has some pending litigation which would impact its position as on March 31, 2022. Details are given in Note 28.

ii. The company does not have any long-term contracts including derivative contracts for which there were any material foreseeable losses,

iii. There were no amounts which were required to be transferred to the Investor Education and Protection Fund by the company.

h. With respect to the matter to be included in the Auditors Report under section 197(6) of the Act, as amended.

i. In our opinion and according to the information and explanations given to us, the remuneration paid by the company to its managing director during the year is in accordance with the provision of section 197 of the Act.

Unique Document Identification Number (UDIN) for this document is 22436593AJXZTS9845.

For S P A R K & Associates Chartered Accountants LLP

Chartered Accountant

Firm Registration No. 005313C/ C400311

CA Chandresh Singhvi

Partner

Membership No. 436593

Place: Indore

Dated 30^th May, 2022

Annexure "A" To The Independent Auditors Report On The Financial Statement Of CMM Infraprojects Limited.

Report on the Order issued under Section 143(11) of the Companies Act 2013

I. a) i. The said Company has generally maintained proper records showing full particulars, including quantitative details and situation of Property, Plant and Equipment.

ii. The company does not have any intangible assets hence, reporting under this clause is not applicable.

b) The Property, Plant and Equipment referred to in Note no. 11 of financial statements have been physically verified by the management at reasonable intervals (covering all the assets in a period of three years), which in our opinion is reasonable, having regard to the size of the said Company and nature of its assets. As informed to us, no material discrepancy was noticed on such physical verification.

c) According to the information and explanation given to us and on the basis of our examination of the records of the corporation, the title deeds of immovable property disclosed in the financial statement are held in the name of the Company.

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

e) There are no proceedings initiated or pending against the company for holding any benami property under the Benami Transactions (Prohibition) Act, 1988 (45 of 1988) and rules made thereunder as details provided by management.

II. a) As explained to us the physical verification of certain inventory has been conducted at reasonable intervals by the management and no material discrepancies were notice on such verification. As explained by the management that the company is involved in construction activities and there are so many items spread out at the site so it is very difficult to maintain the quantitative records of each and every item.

b) As explained to us, and information provided to us, the company has been sanctioned working capital limits in excess of 5 crore rupees in previous years, in aggregate, from banks or financial institution on the basis of security of current asset, and the monthly statement filled by the company with such bank of financial institute are in agreement with the books of account, the details are given below:

(Amount in Lakhs)

Month	Name of bank	Particulars of security	Balance as per Books	Balance as per Statement	Difference		Reason for material discrepancies
Apr-21	Bank Of Baroda	Stock	5185.00	5185.00	-
May-21	Bank Of Baroda	Stock	5342.00	5342.00	-
Jun-21	Bank Of Baroda	Stock	4773.60	4773.60	-
Jul-21	Bank Of Baroda	Stock	4719.98	4719.98	-
Aug-21	Bank Of Baroda	Stock	4611.52	4611.52	-
Sep-21	Bank Of Baroda	Stock	5040.50	5040.50	-
Oct-21	Bank Of Baroda	Stock	5086.15	5086.15	-
Nov-21	Bank Of Baroda	Stock	5076.23	5076.23	-
Dec-21	Bank Of Baroda	Stock	5258.20	5258.20	-
Jan-22	Bank Of Baroda	Stock	4971.20	4971.20	-
Feb-22	Bank Of Baroda	Stock	4967.04	4967.04	-
Mar-22	Bank Of Baroda	Stock	4429.35	4429.35	-

III. According to the information and explanations given to us, the company has not made investment in, provided any guarantee or security or granted any loan or advances in the nature of loans, secured or unsecured, to companies, firms, Limited Liability Partnerships or any other parties, accordingly this clause is not applicable to the said Company.

IV. In our opinion and according to the information and explanations given to us, the Company has not complied with the provisions of Section 185 and 186 of the Act, with respect to the loans and investments made;

(Amount in Lakhs)

Information of Sec. 186

Particulars	Name of Company/Party	Amount Involved	Balance as at 31/03/2022	Remark
The company shouldpass the board resolution as prescribed and obtained the prior approval, wherever required, from the public financial institution concerned where any term loan is subsisting.	l.Kami Singh Ranawat	-	14.15	Company has not passed any board resolution and has not obtained prior approval from public financial institution regarding such loans and advances.
	2.Sam Pavri	-	36.75
	3.Shreya Sojatiya	-	5.00
	4.Devguru Dhanom Buildcon LLP	0.71	13.82
	5.Nageshwar Infra Build LLP	11.80	-
	6.Samyak Resources Pvt. Ltd.	1.00	-
Loan given at rate of interest lower than prescribed	l.Ashwini Gupta HUF		49.00	No interest has been charged by the company on these parties.
	2.Basupujys Devbuild Pvt. Ltd.	6.63	-
	3.Coral Infrastructure	-	9.85
	4.Hemant Soni	-	35.09
	5.1magine Space LLP	0.30	13.06
	6.Kami Singh Ranawat	-	14.15
	7.Krishnakripa Holdings Pvt. Ltd.	-	2.33
	8.Laxmi Logistics	-	5.00
	9,Opel Developers	-	7.44
	10.Sam Pavri	-	36.75
	11.Shiv Jyoti Estate	-	12.47
	12.Shreya Sojatiya	-	5.00
	13.Shree Sai developers Pvt. Ltd	-	7.56
	14.Shubhash Agarwal HUF	-	43.85
	15.Surendra Kumar Patwa HUF	-	18.56
	16.Zircon Infrastructure Pvt. Ltd	-	6.14

V. The Company has not accepted any deposits from the public as governed by the provision of section 73 to 76 or any other relevant provision of the Companies Act, 2013 and rules framed their under.

VI. According to the information and explanations provided to us, the Companies (Cost Accounting Record) Rules 2011 have been applicable to the companies for its construction operations. The Company has appointed Sudeep Saxena & Associates, Cost Accountant (FRN: 100980) to reviewed books of accounts maintained by the company and pursuant to the rules made by the Central Government for maintenance of Cost Records under sub section (I) of section 148 of the Act in respect of construction activity. The Cost Audit is pending since FY 2015-16 and final audit report of the Independent Cost Auditor is not provided by the company, hence we are not able to give any comment on cost records maintained by the company.

VII. (a) According to the information and explanations given to us and on the basis of our examination of records of the company, it is irregular in depositing undisputed statutory dues including Goods and Services Tax, Provident fund, Employees state insurance, Income tax, Sales tax, Duty of customs, Duty of Excise, Value added tax, Cess and any other statutory dues to the appropriate authorities. According the Information and explanation given to us, arrears of outstanding statutory dues as at the last day of the financial year for a period of more than six months from the date they became payable are mentioned below:

(Amount in Lakhs)

S.No. Type of the Dues	Period to which the amount relates	Amount (Rs.)
1 Provident Fund	2020-21	2.87
	2021-22	2.44
2 TDS	2017-18	0.27
	2018-19	0.70
	2019-20	60.36
	2020-21	19.73
	2021-22	0.30
3 Professional Tax	2019-20	0.08
	2020-21	0.08
	2021-22	0.13
4 E.S.I.C	2021-22	0.16
5 Income Tax	2017-18	53.41

(b) According to the information and explanations given to us, there are no dues of GST, Provident fund, Employees State Insurance, Income-tax, Sales tax, Service tax, Duty of Customs, Value added tax, Cess or other statutory dues which have not been deposited by the Company on account of disputes:

Name of the Statute	Nature of the Dues	Amount Pending (Rs.in lakhs)	Period to which the amount relates	Forum where dispute is pending	Remarks
Service Tax	Service Tax Demand	308.97	January 2013 to March 2016	AppellateTribunal
Service Tax	Service Tax Demand	384.78	April 2016 to June 2017	Appellate Tribunal

VIII. According to the information and explanations given to us, there are no transaction that are not recorded in books of accounts have been surrendered or disclosed as income during the year in the tax assessment under income tax act,1961(43 of 1961). Hence, this clause is not applicable.

IX. (a) According to the records of the Company examined by us and the information and explanations given to us, the Company has defaulted in repayment of loans or borrowings fromlender during the year and the details of defaults are as follows:-

(Amount in lakhs

S.No. Nature of Borrowings	Particulars of B antyFinancial Institution	Amount of Default		Period of Default (in Days)
		Principal	Interest
1 Long Term Loans	ICICI BANK (CE-10)	5.92	1.14	1332
2 Long Term Loans	ICICI BANK (CE-123)	26.84	5.11	1301
3 Long Term Loans	ICICI BANK (CE-4,5,6,7,8)	29.96	4.53	1332
4 Long Term Loans	ICICI BANK (LOADER)	24.47	2.47	1240
5 Long Term Loans	ICICI BANK (DUMPER 1)	4.98	0.63	1082
6 Long Term Loans	ICICI BANK (TANDAM ROLLER)	24.97	2.24	1317
7 Long Term Loans	HDFC BANK (FINE ROCK BRAKER)	5.99	0.76	1503
8 Long Term Loans	HDFC BANK (MOTOR GRADER)	76.03	9.66	1503
9 Long Term Loans	HDFC BANK (POCLAIN- HYUNDAI)	21.68	2.76	1503
10 Long Term Loans	HDFC BANK (POCLAIN- KOMATSU)	25.25	3.21	1576
11 Long Term Loans	HDFC BANK (SOIL COMPACTOR)	44.03	5.60	1503
12 Long Term Loans	HDFC BANK (TEREX CRUSHER)	218.42	28.57	1612
13 Long Term Loans	HDFC BANK (MAHENDRA DUMPER)	129.64	16.38	1489
14 Long Term Loans	HDFC BANK (NEW BOLERO)	7.71	1.03	1395
15 Long Term Loans	HDFC BANK (POCLAIN-2)	23.95	3.04	1514
16 Long Term Loans	HDFC BANK (VSI-1000)	9.99	1.31	1416
17 Long Term Loans	TATA CAPITAL*	1.46	0.31	1403
TOTAL		681.27	88.75

‘During the year, full and final settlement has been done for TATA Capital.

(b) According to the information and explanations given to us, Company is not declared as willful defaulter by bank or financial institution or other lender;

(c) According to the information and explanations given to us by the management, the Company has not obtained any term loans. Accordingly, reporting under the clause is not applicable.

(d) According to the information and explanations given to us and on an overall examination of the balance sheet of the Company, we report that no funds have been raised on short-term basis by the Company. Accordingly, reporting under this clause is not applicable.

(e) In our opinion and according to the information and explanations given to us, the company has not taken any funds from any entity or person on account of or to meet the obligations of its subsidiaries, associates or joint ventures

(f) In our opinion and according to the information and explanations given to us, the company has not raised loans during the year on the pledge of securities held in its subsidiaries, joint ventures or associate companies.

X. (a) The Company did not raise any money by way of initial public offer or further public offer (including debt instruments) during the year. Accordingly, paragraph (x) of the order is not applicable.

(b) The company has made not made any preferential allotment or private placement of shares or convertible debentures (fully, partially or optionally convertible) during the year.

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

b)According to the information and explanations given to us, no report under subsection (12) of Section 143 of the Companies Act, 2013 has been filed by the auditors in Form ADT-4 as prescribed under Rule 13 of Companies (Audit and Auditors) Rules, 2014 with the Central Government.

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

XII. In our opinion and according to the information and explanations given to us, the Company is not a nidhi company. Accordingly, paragraph (xii) of the order is not applicable.

XIII. According to the information and explanations given to us and based on our examination of the records of the Company, transactions 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 financial statements as required by the applicable accounting standards.

XIV a) In our opinion the company does not has an internal audit system commensurate with the size and nature of its business.

b) We have not received the internal audit reports of the Company.

XV On the basis of information and explanation given to us, the Company has not entered into any non-cash transactions with directors or persons connected with him during the financial year.

XVI. a) According to the information and explanations provided to us, the company is not required to be registered under Section 45-IA of the Reserve Bank of India Act, 1934 and hence this clause is not applicable to the Company.

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

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

d) According to the information and explanations provided to us during the course of audit, the Company does not have any CIC. Accordingly, the clause is not applicable.

XVII. Based on our examination the company has not incurred cash losses in the financial year 2021 - 22 and in the immediately preceding financial year, and hence reporting under this clause is not required.

XVIII. There is no resignation of the statutory auditors during the year. Accordingly, the clause is not applicable.

XIX. 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, the auditors knowledge of the Board of Directors and management plans, nothing has come to our attention, which causes us to believe that any material uncertainty found as on the date of the audit report 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.

XX. (a) According to the information and explanations given to us, in respect of other than ongoing projects, and transferred unspent amount to a Fund specified in Schedule VII to the Companies Act within a period of six months of the expiry of the financial year in compliance with second proviso to sub-section (5) of section 135 of the said Act are not applicable to the company.

(b) According to the information and explanations given to us, the company is not required to transfer any amount to special account in compliance with provision of sub-section (6) of section 135 of the said Act.

XXI. According to the information and explanations given to us, the company does not make any consolidation financial statement hence this clause is not applicable Unique Document Identification Number (UDIN) for this document is22436593AJXZTS9845.

For S P A R K & Associates Chartered Accountants LLP

Chartered Accountants

Firm Reg No. 005313C/C400311

CA Chandresh Singhvi

Partner

Membership No. 436593

Indore,

Dated 30^th May, 2022

ANNEXURE "B" TO THE INDEPENDENT AUDITORS REPORT

Report on the Internal Financial Controls under Clause (i) of subsection 3 of the section 143 of the Companies Act, 2013

We have audited the internal financial controls over financial reporting of CMM Infraprojects Ltd. ("the Company") as of March 31, 2022 in conjunction with our audit of thefinancial statements of the Company for the year ended on that date.

Managements Responsibility for Internal Financial Controls

The Board of Directors of the Company is responsible for establishing and maintainingintemal financial controls based on the internal control over financial reporting criteriaestablished by the Company considering the essential components of internal control statedin the Guidance Note on Audit of Internal Financial Controls over Financial Reporting issuedby the Institute of Chartered Accountants of India. These responsibilities include the design,implementation and maintenance of adequate internal financial controls that were operatingeffectively for ensuring the orderly and efficient conduct of its business, including adherenceto respective companys policies, the safeguarding of its assets, the prevention anddetection of frauds and errors, the accuracy and completeness of the accounting records,and the timely preparation of reliable financial information, as required under the CompaniesAct, 2013.

Auditors Responsibility

Our responsibility is to express an opinion on the internal financial controls over financialreporting of the Company based on our audit. We conducted our audit in accordance withthe Guidance Note on Audit of Internal Financial Controls Over Financial Reporting (the"Guidance Note") issued by the Institute of Chartered Accountants of India and theStandards on Auditing prescribed under Section 143(10) of the Companies Act, 2013, to theextent applicable to an audit of internal financial controls. Those Standards and the GuidanceNote require that we comply with ethical requirements and plan and perform the audit too obtain reasonable assurance about whether adequate internal financial controls overfinancial reporting was established and maintained and if such controls operated effectivelyin all material respects.

Our audit involves performing procedures to obtain audit evidence about the adequacy ofthe internal financial controls system over financial reporting and their operatingeffectiveness. Our audit of internal financial controls over financial reporting includedobtaining an understanding of internal financial controls over financial reporting, assessingthe risk that a material weakness exists, and testing and evaluating the design and operatingeffectiveness of internal control based on the assessed risk. The procedures selected dependon the auditor⁷s judgment, including the assessment of the risks of material misstatementof the financial statements, whether due to fraud or error.

We believe that the audit evidence we have obtained, is sufficient and appropriate to providea basis for our audit opinion on the internal financial controls system over financial reportingof the Company.

Meaning of Internal Financial Controls over Financial Reporting

A companys internal financial control over financial reporting is a process designed toprovide reasonable assurance regarding the reliability of financial reporting and thepreparation of financial statements for external purposes in accordance with generallyaccepted accounting principles. A companys internal financial control over financialreporting includes those policies and procedures that (1) pertain to the maintenance ofrecords that, in reasonable detail, accurately and fairly reflect the transactions anddispositions of the assets of the company; (2) provide reasonable assurance thattransactions are recorded as necessary to permit preparation of financial statements inaccordance with generally accepted accounting principles, and that receipts andexpenditures of the company are being made only in accordance with authorizations ofmanagement and directors of the company; and (3) provide reasonable assurance regardingprevention or timely detection of unauthorized acquisition, use, or disposition of thecompanys assets that could have a material effect on the financial statements.

Inherent Limitations of Internal Financial Controls Over Financial Reporting

Because of the inherent limitations of internal financial controls over financial reporting, including the possibility of collusion or improper management override of controls, materialmisstatements due to error or fraud may occur and not be detected. Also, projections ofany evaluation of the internal financial controls over financial reporting to future periods aresubject to the risk that the internal financial control over financial reporting may becomeinadequate because of changes in conditions, or that the degree of compliance with thepolides or procedures may deteriorate.

Basis for Disclaimer of Opinion

According to the information and explanation given to us, the company has not established its internal financial control over financial reporting in criteria based on or considering the essential components of internal control stated in Guidance note issued by Institute of Chartered Accountant of India.

Disclaimer of Opinion

Because of the significance of the matter described in the Basis of Disclaimer of Opinion paragraph above we are unable to obtain sufficient appropriate audit evidences to provide a basis of our opinion whether company had adequate internal financial control over financial reporting and whether such internal financial control was operating effectively as at March 31,2022.

According, we dont express an opinion on the company internal financial control over financial reporting. We have considered the disclaimer reported above in determining the nature, timing and extent of audit test applied in our audit of financial statement of company for the year ended March 31, 2022, and the disclaimer does not affect our opinion on the said financial statement of the company.

Unique Document Identification Number (UDIN) for this document is22436593AJXZTS9845.

For S P A R K & Associates Chartered Accountants LLP

Chartered Accountants

Firm Reg No. 005313C/C400311

CA Chandresh Singhvi

Partner

Membership No. 436593

Indore,

Dated 30^th May, 2022