Educomp Solutions Ltd Auditor Reports

To the Members of Educomp Solutions Limited

Report on the Audit of the Standalone Ind AS Financial Statements Adverse Opinion

We have audited the accompanying Standalone Ind AS Financial Statements of Educomp Solutions Limited ("the Company"), which comprise the Balance Sheet as at March 31, 2024, the Statement of Profit and Loss (including Other Comprehensive Income), the Statement of Changes in Equity and the Statement of Cash Flows for the year then ended and notes to the Standalone Ind AS Financial Statements including a summary of significant accounting policies and other explanatory information (hereinafter referred to as "Standalone Ind AS Financial Statements"). In our opinion and to the best of our information and according to the explanations given to us, because of the significance of the matters discussed in the Basis for Adverse Opinion section of our report, the aforesaid Standalone Ind AS Financial Statements do not give the information required by the Companies Act, 2013 ("the Act") in the manner so required and also do not give a true and fair view in conformity with the accounting principles generally accepted in India including the Indian Accounting Standards ("Ind AS") prescribed under section 133 of the Act, of the state of affairs of the Company as at March 31, 2024, its loss (including other comprehensive income), changes in equity and its cash flows for the year ended on that date.

Basis for Adverse Opinion

1. As mentioned in Note 3.1 to the Standalone Ind AS Financial Statements, the Management did not conduct physicalverificationof Property, plant and equipment during the year ended March 31, 2024.In absence of the same, we are unable to comment over existence, valuation, and the extent of the adjustment, if any, required in respect of these assets as at March 31, 2024 and the resultant possible impact of the same on the loss for the year ended on that date and on the equity as on that date.

2. As regards trade receivable amounting Rs. 1,072.99 million (net of accumulated million) as on March 31, 2024, the management is of the view that the same are good and fully recoverable in due course and hence no further loss allowance is required. In absence of appropriate audit evidences including balance confirmations, correspondences from parties and details of subsequent realization post March 31, 2024, we are unable to comment on the recoverability of the outstanding trade receivables of Rs. 1,072.99 million and the possible impact of the same on the loss for the year ended March 31, 2024, and on the equity as on that date.

3. As mentioned in Note 12.4 to the Standalone Ind AS Financial Statements, the Company has not accrued interest on borrowing post May 30, 2017, being Corporate Insolvency Resolution Process ("CIRP") commencement date. The amount of such interest not accrued is estimated to be Rs. 4,424.75 million for the reporting financial year and Rs. 23,429.93 million till March 31, 2024. This has resulted in understatement of financial liabilities by Rs. 23,429.93 million as at March 31, 2024; understatement of loss 4,424.75 million and overstatement of equity by Rs. 23,429.93 million as on that date.

4. As disclosed in Note 14 to the Standalone Ind AS Financial Statements, the advance from customers includes amount received from non-corporate entitiesof Rs. 80.44 million which is deemed to be deposit u/s 73 of the Companies Act, 2013 read with Companies (Acceptance of Deposit) Rules 2014 and thereby in violation of section 73 to 76 of the Companies Act, 2013. The impact of the non-compliance on the accompanying Standalone Ind AS Financial Statements is presently not ascertainable.

5. As mentioned in Note 24.2 to the Standalone Ind AS Financial Statements, the Company follows Expected Credit Loss (ECL) model for measuring impairment loss allowance of its trade receivables. The ECL allowance or loss rate is computed based on a provision matrix which takes into account historical credit loss experience.

However, for the computed loss rate as mentioned in Note 24.2 to the Standalone Ind AS Financial Statements, we have not been provided with any underlying workings of such loss rate computed by the Company.

Further, the Company has not taken effect of aforesaid loss rate in computation of impairment loss allowance, if any on trade receivables over and above the existing provision in the books of account. In absence of relevant workings and other details, we are unable to comment on the appropriateness of the loss rate and the possible impact of not considering the effect of the loss rate in impairment loss allowance on the trade receivables balance as at March 31, 2024 and the loss for the year ended on that date and on the equity as on that date.

6. We have neither got the direct confirmations nor provided with the statements for borrowings from banks and financial institutions amounting to Rs. 14,909.96million (net) as at March 31, 2024. Further, in case of bank borrowings amounting to Rs. 3,425.19 million wherein we have received the confirmations or bank statements, the amount recorded in the Standalone Ind AS Financial Statements is short by Rs. 120.26 million (net) in comparison to amounts reported in the confirmations or bank statements. In the absence of reconciliations and other alternative audit evidence, we are unable to determine any possible impact thereof on the loss for the year ended 31st March 2024 and on balance of borrowings and equity as at March 31, 2024

7. Balance in borrowings other than bank borrowings mentioned in paragraph 6 above, amounting to Rs. 8,088.85 million as at March 31, 2024 are subject to confirmation. Borrowings other than bank borrowings amounting to Rs. 142.58 million wherein we have received the balance confirmation, the amount recorded in the Ind AS Financial Statements is short by Rs. 12.42 million. In the absence of any alternative audit evidence, we are unable to comment on any possible impact thereof on the loss for the year ended 31st March 2024 and on balance of borrowings and equity as at March 31, 2024.

8. As disclosed in Note 28 to the Standalone Ind AS Financial Statements, financial guarantees aggregating Rs. 13,371.97 million were issued to banks on behalf of its erstwhile subsidiaries. As per Ind AS 109 "Financial Instruments", the said financial guarantees are required to be initially measured at fair value and subsequently measured at the higher of (i) the amount of loss allowance in accordance with Expected Credit Loss ("ECL") method and (ii) amount initially recognized less cumulative amount of income recognized in income statement. However, no measurement of financial guarantees at fair value and estimation of loss allowances in accordance with ECL method were performed during the year. In absence of such measurement, we are unable to comment on the resultant impact thereof on the loss for the year ended March 31, 2024 and corresponding liability and equity as on that date.

9. The Company has not determined the provision for penal interest for defaults on borrowings as per the contractual terms of the underlying agreements. In absence of such assessment, we are unable to comment on the possible impact thereof on the loss for the year ended March 31, 2024 and on the balance of borrowings and equity as on that date.

10. As disclosed in Note 6.5 to the Standalone Ind AS Financial Statements, the balance with banks in current account amounting to Rs. 7.52 million is not verifiable as the same is not reflected in the bank statement. As per the bank statements available, the banks have recovered/ transferred these amounts but the Company has not recorded these transactions in its books of accounts. It is informed that the Company has taken up the matter with the concerned banks for refund/reversal of amount debited by banks. In the absence of any evidence to the contrary, the cash and bank balance as on March 31, 2024 is overstated by Rs.7.52 million along with overstatement of equity for the equivalent amount on that date. 11. We have neither got the direct confirmation nor provided with the bank statements for balance with banks in current accounts and margin money with aggregate amount of Rs. 0.1 million. In the absence of any alternative evidence, we are unable to comment on any possible impact thereof on the loss for the year ended March 31, 2024 and on the balance with banks as at March 31, 2024 and on equity as on that date.

12. As mentioned in Note 4(ii) to the Standalone Ind AS Financial Statements, the Company has fully amortized its intangible assets (knowledge-based content) as per its accounting policy but the same continues to generate revenue for the company. In absence of re-assessment of the useful life of the intangible assets, we are unable to comment on the resultant impact of amortization on the loss for the year ended on March 31, 2024, carrying value of intangible assets and on the equity as on that date. 13. The Companys investment in its subsidiary companies viz. Educomp Learning Private Limited, Educomp School Management Limited, and Educomp Professional Education Limited aggregating to Rs. 701.73 million (net of provision for impairment of Rs. 2,581.30 million) has not been evaluated for any further impairment since financial year 2020-21. These subsidiary companies have not furnished their audited financial statements nor latest valuation reports of these companies have been made available. The latest audited financial statements of subsidiary companies are available for the financial year 2018-19. In absence of appropriate audit evidence, we are unable to comment upon appropriateness of carrying amount of investments and possible impact of the same on the loss for the year ended March 31, 2024 and equity as on that date.

14. As disclosed in Note No.6.1.3A, the Company has made 100% provision for impairment on its newly allotted Preference Shares with aggregate amount of Rs.9,772.75 million by Edu Smart Services Private Limited (ESSPL) which was undergoing liquidation process as part of the settlement envisaged in the Revival Plan approved by Honble NCLT. These Preference Shares have been allotted in lieu of earlier investment held in Preference Shares of ESSPL with aggregate amount of Rs. Nil (Rs.515.91 million with 100% provision) and trade receivables of Rs. Nil (Rs.9,784.55 million with 100% provision). The Management has represented that newly allotted preference shares have zero value for the Company and accordingly been fully provided for. In the absence of clarification on the basis of valuation and future recoverability, if any, of these preference shares, we are unable to comment on the possible impact thereof on the loss for the year ended March 31, 2024 and equity as on that date.

15. As explained in Note 36 to the Standalone Ind AS Financial Statements regarding managerial remuneration paid to one of the whole time directors of the Company during the quarter ended June 30, 2015 and during the year ended March 31, 2015 in non-compliance with the requirements of Section 197 and Section 198 read with Schedule V to the Companies Act, 2013, and paid during the year ended March 31, 2014 in non-compliance with the requirements of Section 198, Section 269 and Section 309 read with Schedule XIII to the Companies Act, 1956, for which the Central Governments approval is yet to be obtained.

16. As disclosed in Note 38 to the Standalone Ind AS Financial Statements, as per the Insolvency & Bankruptcy Code and Regulations issued there under, the RP has received, verified, and admitted the claims submitted by the creditors (Operational and Financial), employees and workmen of the Company aggregating to Rs. 30,437.72 million as on May 30, 2017. These claims have been taken into cognizance by Committee of the Creditors (CoC) in its 12th meeting held on February 17, 2018, while approving the Resolution Plan of the Company. The details of such claims have been disclosed in the said note. As represented by the Management/ Caretaker RP, a reconciliation of the admitted claims vis-a-vis liabilities outstanding as at March 31, accounts has not been prepared and any impact thereof has not been considered in the preparation of these Standalone Ind AS Financial Statements as at and for the year ended March 31, 2024.

In absence of the above, we are unable to comment upon appropriateness of carrying value of such liabilities as at March 31, 2024 and any possible impact of the same on the loss for the year ended on that date and equity as at that date.

17. As disclosed in Note 39 to the Standalone Ind AS Financial Statements, the Company is currently subjected to the investigations by Serious Fraud Investigation Office (SFIO) and the Central Bureau of Investigation (CBI). As further explained to us, certain information has been requested by them from the Company and the investigations are currently underway and the Company is yet to get any orders or directions in this respect from the said Authorities till the date of signing this report. In absence of pending investigations, we are unable to comment on the consequential impact of these matters on these Standalone Ind AS Financial Statements as at and for the year ended March 31, 2024.

18. As disclosed in Note 40 to the Standalone Ind AS Financial Statements, the Company did not have any internal audit conducted during the year as required under section 138 of the Act. The impact of the non-compliance on the accompanying Standalone Ind AS Financial Statements is presently not ascertainable. 19. As disclosed in Note 41 to the Standalone Ind AS Financial Statements, these Standalone Ind AS Financial Statements are not authenticated by the Company Secretary of the Company which is not in compliance applicable provisions of the Act. Also, the impact of these non-compliances on the accompanying Standalone Ind AS Financial Statements is presently not ascertainable.

20. As disclosed in Note 42 to the Standalone Ind AS Financial Statements, these Standalone Ind AS Financial Statements are not approved by the Chief Financial Officer of the Company which is not in compliance with section 134 (1) of the Act. The impact of this non?compliance on the accompanying Standalone Ind AS

Financial Statements is presently not ascertainable.

21. As disclosed in Note 43 to the Standalone Ind AS Financial Statements, the Company has not been in compliance with various other provisions of the Companies Act 2013, SEBI LODR Regulations, 2015, Foreign Exchange Management Act, 1999 and Goods and Services Tax Act, 2017. The financial or other impact of these non-compliances on these Standalone Ind AS Financial Statements is presently not ascertainable. We conducted our audit in accordance with Standards on Auditing (SAs) specified under section 143(10) of Standards are further described in the Auditors Responsibilities theAct.Ourresponsibilities for the Audit of the Standalone Ind AS Financial Statements section of our report. We are independent of the Company in accordance with the Code of Ethics issued by the Institute of Chartered Accountants of India ("ICAI") together with the ethical requirements that are relevant to our audit of the Standalone Ind AS

Financial Statements under the provisions of the Act and Rules there under and we have fulfilled our other ethical responsibilities in accordance with these requirements and the Code of Ethics. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our adverse opinion on the Standalone Ind AS Financial Statements.

Material Uncertainty Related to Going Concern

We draw attentionto Note 2A(c) to the Standalone Ind AS Financial Statements, which indicates that the Company has incurred substantial losses during the year, its net worth has been completely eroded, has defaulted in repayment of its loans and related interest, and has negative working capital. The Company has undergone Corporate Insolvency Resolution Process under the IBC, 2016 and the resolution plan approved by Honble NCLT has been challenged by the Successful Resolution Applicant. These conditions indicate that a material uncertainty exists that may cast significant doubt about the Companys ability to continue as a going concern. However, these Standalone Ind AS Financial Statements have been prepared on a going concern basis as the management is of the view that the Company has been able to discharge its operational liabilities from its internal date of this balance sheet and is also confident that the Company would have sufficient fund balance to continue as going concern as stated in the said note.

Our opinion is not modified in respect of this matter.

Key Audit Matters

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. Except for the matters described in the Basis for Adverse Opinion section and Material Uncertainty Related to Going Concern section, we have determined that there are no other key audit matters to communicate in our report.

Emphasis of Matter

We draw attentionto the following matters in the notes to the Standalone Ind AS Financial Statements: (a) Note 2A(a) to the Standalone Ind AS Financial Statements, wherein it is stated that Honble NCLT has approved the resolution plan but the same has not been implemented by the Successful ResolutionApplicant (SRA) and therefore in view of the order dated November 23,.2023 of the NCLT, the above standalone financial statements for the year ended March 31, 2024 have been prepared by the Caretaker ResolutionProfessional and his team. Accordingly, these Standalone Ind AS Financial Statements have been prepared and approved by the Caretaker RP.

(b) Note 28.1 to the Standalone Ind AS Financial Statements, claims aggregating Rs. 1,659.20 million have been admitted by the RP against guarantees issued on behalf of erstwhile subsidiaries companies but the same have not been recorded in the books of accounts and continues to be shown under contingent liabilities. (c) Note 12.2 & 33 on Trade Payable due to MSME where the company has not made further provision of interest for the period after commencement of CIRP i.e. May 30, 2017 on unpaid dues of the MSMEs pertaining to the pre-CIRP period as these dues would be settled in accordance with the Bankruptcy Code, 2016.

Our opinion is not modified in respect of these matters.

Other Information

In view of the current status of the Company, the Caretaker Resolution Professional (RP) is responsible for the preparation of the other information. The other information comprises the information included in the Boards Report, Report on Corporate Governance and Annexures to Boards Report, but does not include the Standalone Ind AS Financial Statements, Consolidated Ind AS Financial Statements and our auditors 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 conclusion thereon.

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 informationis materially inconsistent with the Standalone Ind AS Financial Statements or our knowledge obtained in the audit or otherwise appears to be materially misstated. Boards Report, Report on Corporate Governance and Annexures to Boards Report are not made available to us as at the date of this auditors report. We have nothing to report in this regard.

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

The Erstwhile Resolution Professional of the Company appointed by theCommittee of Creditors ("CoC") pursuant to the order passed by the Honble NationalCompany Law Tribunal ("NCLT"), with whom the management of the affairs of the Company and the powers of the Board of Directors of the Company were vested after the commencement of CIRP w.e.f. May 30, 2017 under the provisions of Insolvency and Bankruptcy Code, 2016 ("InsolvencyCode"),continuesto act in the capacity of a Caretaker Resolution Professional as per directions of the Honble NCLT vide its Order dated 23.11.2023 since the approved resolution plan has not been implemented by the Successful Resolution Applicant. Hence the Caretaker Resolution Professional 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 other comprehensive income), changes in equity and cash flows of the Company in accordance with the accounting principles generally accepted in India, including Ind AS specified under section 133 of the Act, read with relevant rules issued there under. This responsibility also includes maintenance of adequate accounting records in accordance with the provisions of the Act for safeguarding of the assets of the Company and for preventing and detecting frauds and other irregularities; selection and application of appropriate accounting policies; making judgments and estimates that are reasonable and prudent; and design, implementation and maintenance of adequate internal financial controls, that were operating effectively for ensuring the accuracy and completeness of the accounting records, relevant to the preparation and presentation of the Standalone Ind AS Financial Statements that give a true and fair view and are free from material misstatement, whether due to fraud or error.

Financial Statements of a company is required to Further,asperSection be authenticated by the Chairperson of the Board of Directors, where authorized by the Board or at least two Directors, of which one shall be the Managing Director or the CEO (being a Director), the CFO and the Company Secretary where they are appointed. However, in view of the current status of the Company post approval of a resolution plan during CIRP but not implemented by the Successful Resolution Applicant, these Standalone Ind AS Financial Statements are approved by the Caretaker RP [refer note 2A(a) of the Standalone Ind AS Financial Statements and paragraph (a) under Emphasis of Matter].

In preparing the Standalone Ind AS 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.

Auditors Responsibilitiesfor the Audit of the Standalone Ind AS Financial Statements

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 this Standalone Ind AS Financial Statements. As part of an audit in accordance with SAs, we exercise professional judgment and maintain professional skepticism throughout the audit. We also: 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,

Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances. Under section 143(3)(i) of the Act, we are also responsible for expressing our opinion on whether the company has adequate internal financial controls with reference to Standalone Ind AS Financial Statements 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 the Companys Directors/management/Caretaker RP (refer note 2A(a) of the Standalone Ind AS Financial Statements and paragraph "(a)" underEmphasisofMatter paragraph).

Conclude on the appropriateness of managements use of the going concern basis of accounting and, based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Companys ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditors report to the related disclosures in the Standalone 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 Company to cease to continue as a

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.

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

We also provide those charged with governance with a statement that we have complied with relevant ethical requirements regarding independence, and to communicate with them all relationships and other matters that may reasonably be thought to bear on our independence, and where applicable, related safeguards. From the matters communicated with those charged with governance, we determine those matters that were of most significance in the audit of the Standalone 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 expectedtooutweighthepublicinterestbenefits .communication ofsuch

Report on Other Legal and Regulatory Requirements

(1) As required by the Companies (Auditors Report) Order, 2020 ("the Order") issued by the Central Government of India in terms of section 143(11) of the Act, we give in "Annexure 1", a statement on the matters specified in paragraphs 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 and except for the matters described in the Basis for Adverse Opinion section of our report, obtained all the information and explanations necessary for the purposes of our audit; b. Except for the possible effects of the matters described in the Basis for Adverse Opinion section of our report and matters stated in paragraph (j)(vi) below on reporting under Rule 11 (g) of the Companies (Audit and Auditors) Rules, 2014, in our opinion, proper books of account as required by law have been s. book keptbytheCompanysofarasitappearsfromourexamination ofthose c. The Balance Sheet, the Statement of Profitand Loss, the Statement of Changes in Equity and the Statement of Cash Flows dealt with by this report are in agreement with the books of account; d. Except for the possible effects of the matters described in the Basis for Adverse Opinion section report, in our opinion, the aforesaid Standalone Ind AS Financial Statements comply with the Indian Accounting Standards specified under section 133 of the Act read with relevant rules issued thereunder; e. The matters described under the Basis for Adverse Opinion and Material Uncertainty Related to Going Concern section of our report, in our opinion, may have an adverse

Company; f. We have not received written representation from the directors of the company as on March 31, 2024. In the absence of written representation received, we are unable to comment whether the director is disqualified as on March 31, 2024 from being appointed as a director in terms of section 164(2) of the

Act.

g. The qualification/reservation/adverse remarks relating to the maintenance of accounts and other matters connected therewith are as stated in the Basis for Adverse Opinion section of our report. h. With respect to the adequacy of the internal financial controls with reference to Standalone Ind AS

Financial Statements of the Company and the operating effectiveness of such controls, refer to our separate report in "Annexure 2". Our report expresses a Disclaimer of Opinion on the Companys internal financial controls with reference to Standalone Ind AS Financial Statements for the reasons stated therein; i. In accordance with the requirements of section 197(16) of the Act, as amended, in our opinion and to the best of our information and according to the explanations given to us, no remuneration has been paid by the Company to its directors during the year and accordingly the provisions of section 197 of the Act are not applicable.

Also refer our comment in paragraph 15 of the "Independent Auditors Report - Basis of adverse opinion" regarding managerial remuneration paid to one of the whole-time director of the Company during the quarter ended June 30, 2015, year ended March 31, 2015 and year ended March 31, 2014 for which Central Governments approval is yet to be obtained by the Company. j. 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. Except for the matters described in the Basis for Adverse Opinion paragraph above, the Company has disclosed the impact of pending litigations on its financial position in its Standalone Ind AS

Financial Statements - Refer Note 28 to the Standalone Ind AS Financial Statements. Also refer paragraph "(b)" under Emphasis of Matter paragraph on Contingent Liabilities; ii. Except for the possible effects of matters described under Basis of Adverse Opinion paragraph, the Company has made provision, as required under the applicable law or accounting standards, for material foreseeable losses, if any, on long-term contracts and derivative contracts if any; iii. The company has not transferred an amount of Rs. 0.31 million on account of unpaid dividend pertaining to FY 2011-12 (declared on 30th May, 2012) which was required to be transferred to Investor Education and Protection Fund by 05th July,2019; iv. (a) The management has represented that to the best of its knowledge and belief as disclosed in Note 53(A), no funds have been advanced or loaned or invested (either from borrowed funds or share premium or any other source or kind of funds) by the company to or in any other persons or entities, including foreign entities (intermediaries), with the understanding, whether recorded in writing or otherwise, that the intermediary shall, whether directly or indirectly lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the company (Ultimate Beneficiaries) or provide any guarantee, security or the like on Beneficiaries; (b) The management has represented that to the best of its knowledge and belief as disclosed in Note 53(B), no funds have been received by the company from any persons or entities including foreign entities (the Funding Parties), with the understanding, whether recorded in writing or otherwise, that the company shall, whether directly or indirectly lend or invest in other persons or entitiesidentified in any manner whatsoever by or on behalf of the Funding Beneficiaries)or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries; and

(c) Based on such audit procedures that were considered reasonable and appropriate in the circumstances, nothing has come to our notice that has caused us to believe that the representation under clause (a) and (b) contain any material mis-statement. v. The Company has not declared or paid any dividend during the year. Accordingly, the provision of section 123 of the Act is not applicable to the company. vi. Based on our examination, which included test checks, the Company has used software for maintaining its books of account for the financial year ended March 31, 2024 and it is observed that some of the required features of audit trail have been kept manually. Hence we are unable to comment on audit trail feature of the said software.

(b) The statutory dues referred to in sub clause (a) which have not been deposited on account of any dispute are disclosed as under:

Name of the statute	Nature of the dues	Amount Disputed	Amount paid under Protest	Period to which the amount Relates	Forum where dispute is pending
BVAT Act 2005	Bihar-VAT	0.34 million	0.07 million	2011-12	Asstt. CommissionerTrade Tax, Patna
DVAT Act 2004	Delhi-VAT	0.07 million	NIL	2013-14	Appeal/objection filedbefore Objection Hearing Authority (SOHO) Delhi (DVAT)
DVAT Act 2004	Delhi-VAT	4.57 million	NIL	2014-15	Appeal/objection filedbefore Objection Hearing Authority (SOHO) Delhi (DVAT)
DVAT Act 2004	Delhi-VAT	1.46 million	NIL	2015-16	Appeal/objection filedbefore Objection Hearing Authority (SOHO) Delhi (DVAT)
DVAT Act 2004	Delhi-VAT	19.56 million	NIL	2016-17	Appeal/objection filedbefore Objection Hearing Authority (SOHO) Delhi (DVAT)
DVAT Act 2004	Delhi-VAT	2.91 million	NIL	2017-18	Appeal/objection filed before Objection Hearing Authority (SOHO) Delhi (DVAT)
MVAT Act 2002	Maharashtra- VAT	8.14 million	NIL	2015-16	Rectification application filed before DC of State Tax (MVAT) Mumbai
MVAT Act 2002	Maharashtra- VAT	0.71 million	NIL	2016-17	Rectification application filed before DC of State Tax (MVAT) Mumbai
PVAT Act, 2005 (UT Chandigarh)	Chandigarh-VAT	0.17 million	NIL	2012-13	Appeal pending before DC Excise, Chandigarh
Finance Act 1994	Ahmedabad (Service Tax)	Service Tax- 209.8 million Penalty-104.94 million (U/s 78) Penalty-0.010 million (U/s 77) Interest u/s 75	NIL	2014-15	Appeal Pending before Gujarat High Court at Ahmedabad. Recovery proceedings stayed by Honble High Court of Gujarat Vide Order dated 06-01-2021
THE EMPLOYEES PROVIDENT FUNDS AND MISCELLANEOUS PROVISIONS ACT, 1952	Provident Fund Contributions & other charges	8.78 million	NIL	March 2008 - February 2014	An Appeal Pending before Central Government Industrial Tribunal Cum Labour Court.
INCOME TAX ACT, 1961 Maharashtra	Penalty u/s 271B	0.06 million	NIL	2021-22	Appeal filed before CIT (Appeals)
Goods & Service Tax	Maharashtra GST	1.50 million	0.80 million	2018-19	Appeal to Appellate Authority Mumbai
West Bengal Goods & Service Tax	West Bengal GST	2.83 million	Nil	2018-19	Appeal to Appellate Authority Kolkata

 

For Kumar Vijay Gupta & Co.

Chartered Accountants

ICAI Firm Registration No.: 007814N

Rajneesh Ghei

Partner

Membership No.: 086329

Place: New Delhi

Date: July 18, 2024

UDIN: 24086329BKFXTB6685