Federal-Mogul Goetze (India) Ltd Directors Report.

To the Members of Federal Mogul Goetze (India) Limited

Report on the Audit of the Standalone Financial Statements

Opinion

1. We have audited the accompanying standalone financial statements of Federal Mogul Goetze (India) Limited (‘the Company’), which comprise the Balance Sheet as at 31 March 2021, the Statement of Profit and Loss (including Other Comprehensive Income), the Cash Flow Statement and the Statement of Changes in Equity for the year then ended, and a summary of the significant accounting p o l i c i e s a n d o t h e r e x p l a n a t o r y information.

2. In our opinion and to the best of our information and according to the explanations given to us, the aforesaid standalone financial statements give the information required by the Companies Act, 2013 (‘Act’) in the manner so required and give a true and fair view in conformity with the accounting principles generally accepted in India including Indian Accounting Standards (‘Ind AS’) specified under section 133 of the Act, of the state of affairs of the Company as at 31 March 2021, and its profit (including other comprehensive income), its cash flows and the changes in equity for the year ended on that date.

Basis for Opinion

3. We conducted our audit in accordance with the Standards on Auditing specified under section 143(10) of the Act. Our responsibilities under those standards are further described in the Auditor’s Responsibilities for the Audit of the 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 financial statements under the provisions of the Act and the rules thereunder, 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 opinion.

Key Audit Matter

4. Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the standalone 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.

5. We have determined the matter described below to be the key audit matters to be communicated in our report.

Key audit matter How our audit addressed the key audit matter
Provisions and contingent liabilities relating to litigations Our audit procedures in relation to the provisions and contingent liabilities relating to litigations, included, but were not limited to, the following:
As disclosed in note 37 to the standalone financial statements, the Company is involved in various direct taxes, indirect taxes, labour laws and other litigations (‘litigations’) that are pending with various tax authorities and courts. The Company has recognised provisions aggregating to Rs. 5,793.33 lacs and disclosed contingent liabilities of Rs. 6,079.63 lacs related to these litigations. . • Obtained an understanding of the management process for:
Whether a liability is recognised as a provision or disclosed as a contingent liability in the financial statements is inherently judgmental dependent on a number of significant assumptions and assessments. - identification of legal and tax matters initiated against the Company,
These include assumptions relating to the likelihood and/or timing of the cash outflows from the business and the interpretation of local laws and pending assessments at various levels of the statute. We placed specific focus on the judgements in respect to these demands against the Company. - assessment of accounting treatment for each such litigation identified under accounting principles of Ind AS 37 - Provisions, Contingent Liabilities and Contingent Assets, and
The amounts involved are potentially significant and due to the range of possible outcomes and considerable uncertainty around the various litigations the determination of the need for creating a provision in the financial statements is inherently subjective/judgmental and therefore is considered to be a key audit matter in the current year. - measurement of amounts involved.
• Evaluated the design and tested the operating effectiveness of key controls around above process.
Test of details included, but were not limited to, the following-
• Obtained an understanding of the nature of litigations pending against the company and discussed the key developments during the year for key litigations with the management and respective legal counsels handling such cases on behalf of the Company.
• Assessed the Company’s assumptions and estimates in respect of litigations, including the liabilities or provisions recognised or contingent liabilities disclosed in the financial statements. This involved assessing the probability of an unfavorable outcome of a given proceeding and the reliability of estimates of related amounts;
• Assessed management’s conclusions through discussions held with the in house legal counsel and understanding precedents set in similar cases;
• Obtained and evaluated the responses in the independent confirmations obtained from the consultants representing the Company before the various authorities;
• For cases represented by consultants, reviewed each attorney’s response obtained as above to ensure that the conclusions reached by the management are supported by sufficient legal rationale and adequate information is included for the management to determine the appropriate accounting treatment of such cases in the financial statements;
• Involved auditor’s experts to assess the Company’s interpretation and application of relevant tax laws to evaluate the appropriateness of key assumptions used and the reasonableness of estimates in relation to uncertain tax positions, taking into account past precedents;
• Evaluated the disclosures made relating to provisions and contingent liabilities for their appropriateness.

We have determined that there are no other key audit matters to communicate in our report.

Information other than the Financial Statements and Auditor’s Report thereon

6. The Company’s Board of Directors is responsible for the other information. The other information comprises the information included in the Annual Report, but does not include the standalone financial statements and our auditor’s report thereon. The Annual Report is expected to be made available to us after the date of this auditors report. Our opinion on the standalone financial statements does not cover the other information and we will not express any form of assurance conclusion thereon. In connection with our audit of the standalone financial statements, our responsibility is to read the other information identified above when it becomes available and, in doing so, consider whether the other information is materially inconsistent with the standalone financial statements or our knowledge obtained in the audit or otherwise appears to be materially misstated.

When we read the Annual Report, if we conclude that there is a material misstatement therein, we are required to communicate the matter to those charged with governance.

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

7. The accompanying standalone financial statements have been approved by the Company’s Board of Directors. The Company’s Board of Directors is responsible for the matters stated in section 134(5) of the Act with respect to the preparation of these standalone financial statements that give a true and fair view of the financial position, financial p e r f o r m a n c e i n c l u d i n g o t h e r comprehensive income, changes in equity and cash flows of the Company in accordance with the accounting principles generally accepted in India, including the Ind AS specified 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 misstatement, whether due to fraud or error.

8. In preparing the financial statements, management is responsible for assessing the Company’s 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.

9. Those Board of Directors is also r e s p o n s i b l e f o r o v e r s e e i n g t h e Company’s financial reporting process.

Auditor’s Responsibilities for the

Audit of the Financial Statements

10. Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s 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 Standards on Auditing 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.

11. As part of an audit in accordance with Standards on Auditing, we exercise 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 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 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 management;

• Conclude on the appropriateness of management’s 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 Company’s ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditor’s 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 auditor’s 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; 12. 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.

13. We also provide those charged with governance with a statement that we have c o m p l i e d w i t h r e l e v a n t e t h i c a l 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.

14. 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 auditor’s 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

15. As required by section 197(16) of the Act, based on our audit, we report that the Company has paid remuneration to its directors during the year in accordance with the provisions of and limits laid down under section 197 read with Schedule V to the Act.

16. As required by the Companies (Auditor’s Report) Order, 2016 (‘the O r d e r ‘ ) i s s u e d b y t h e C e n t r a l Government of India in terms of section 143(11) of the Act, we give in the Annexure A, a statement on the matters specified in paragraphs 3 and 4 of the Order.

17. Further to our comments in Annexure A, as required by section 143(3) of the Act, based on our audit, we report, to the extent applicable, 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 purpose of our audit of the accompanying standalone financial statements;

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

c) the standalone financial statements dealt with by this report are in agreement with the books of account;

d) in our opinion, the aforesaid standalone financial statements comply with Ind AS specified under section 133 of the Act;

e) on the basis of the written representations received from the directors and taken on record by the Board of Directors, none of the directors is disqualified as on 31 March 2021 from being appointed as a director in terms of section 164(2) of the Act;

f) we have also audited the internal financial controls with reference to financial statements of the Company as on 31 March 2021 in conjunction with our audit of the standalone financial statements of the Company for the year ended on that date and our report dated 28 June 2021 as p e r A n n e x u r e B e x p r e s s e d unmodified opinion; and

g) with respect to the other matters to be included in the Auditor’s 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 Company, as detailed in note 37 to the standalone financial statements, has disclosed the impact of pending litigation(s) on its financial position as at 31 March 2021;

ii. the Company did not have any long-term contracts including derivative contracts for which there were any material foreseeable losses as at 31 March 2021.;

iii. there were no amounts which were required to be transferred to the Investor Education and Pr o t e c t i o n Fu n d b y t h e Company during the year ended 31 March 2021; and

iv. the disclosure requirements relating to holdings as well as dealings in specified bank notes were applicable for the period from 8 November 2016 to 30 December 2016, which are not relevant to these standalone financial statements. Hence, reporting under this clause is not applicable.

For Walker Chandiok & Co. LLP

Chartered Accountants

Firm’s Registration No.:

001076N/N500013

Anamitra Das

Partner

Membership No.: 062191

UDIN: 21062191AAAAIX8165

Place: Gurugram

Date: 28 June 2021

Annexure A to the Independent Auditor’s report of even date to the members of Federal-Mogul Goetze (India) Limited, on the standalone financial statements for the year ended 31 March 2021

Annexure A

Based on the audit procedures performed for the purpose of reporting a true and fair view on the financial statements of the Company and taking into consideration the information and explanations given to us and the books of account and other records examined by us in the normal course of audit, and to the best of our knowledge and belief, we report that:

(i) (a) The Company has maintained proper records showing full particulars, including quantitative details and situation of property, plant and equipment, intangible assets and right-of-use assets.

(b) The Company has a regular program of physical verification of its property, plant and equipment under which property, plant and equipment are verified in a phased manner over a period of three years, which, in our opinion, is reasonable having regard to the size of the Company and the nature of its assets. In accordance with this program, certain property, plant and equipment were verified during the year and no material discrepancies were noticed on such verification.

(c) The title deeds of all the immovable properties (which are included under the head ‘Property, plant and equipment’ and ‘right-of-use asset’) are held in the name of the Company.

(ii) In our opinion, the management has conducted physical verification of inventory at reasonable intervals during the year, except for goods-in-transit and stocks lying with third parties. For stocks lying with third parties at the year-end, written confirmations have been obtained by the management. No material discrepancies were noticed on the aforesaid verification.

(iii) The Company has not granted any loan, secured or unsecured to companies, firms, Limited Liability Partnerships (LLPs) or other parties covered in the register maintained under Section 189 of the Act. Accordingly, the provisions of clauses 3(iii)(a), 3(iii)(b) and 3(iii)(c) of the Order are not applicable.

(iv) In our opinion, the Company has complied with the provisions of Section 186 in respect of investments. Further, in our opinion, the Company has not entered into any transaction covered under Section 185 and Section 186 of the Act in respect of loans, guarantees and security.

(v) In our opinion, the Company has not accepted any deposits within the meaning of Sections 73 to 76 of the Act and the Companies (Acceptance of Deposits) Rules, 2014 (as amended). Accordingly, the provisions of clause 3(v) of the Order are not applicable.

(vi) We have broadly reviewed the books of account maintained by the Company pursuant to the Rules made by the Central Government for the maintenance of cost records under sub-section (1) of Section 148 of the Act in respect of Company’s products and are of the opinion that, prima facie, the prescribed accounts and records have been made and maintained. However, we have not made a detailed examination of the cost records with a view to determine whether they are accurate or complete.

(vii)(a) The Company is regular in depositing undisputed statutory dues including provident fund, employees’ state insurance, income-tax, sales-tax, goods and services tax service tax, duty of customs, duty of excise, value added tax, cess and other material statutory dues, as applicable, to the appropriate authorities. Further, no undisputed amounts payable in respect thereof were outstanding at the year-end for a period of more than six months from the date they become payable.

(b) The dues outstanding in respect of income-tax, sales-tax, goods and services tax, service-tax, duty of customs, duty of excise and value added tax on account of any dispute, are as follows:

Name of the statute Nature of dues Amount (Rs. in lacs) Amount paid under Protest (Rs. in lacs) Period to which the amount relates Forum where dispute is pending
Income tax Act, 1961 Income tax 16.54 - 1995-1996 and 1996-1997 Honorable High Court, Delhi
Income tax Act, 1961 Income tax 432.49 - 1997-98 Honorable High Court, Delhi
Income tax Act, 1961 Income tax 2.30 - 2007-08 Assessing officer, Delhi
Income tax Act, 1961 Income tax 1,732.22 - 2010-11 Income Tax Appellate Tribunal and Commissioner of Income Tax (Appeals), Delhi
Income tax Act, 1961 Income tax 1.98 - 2011-12 Assessing officer, Delhi
Income tax Act, 1961 Income tax 26.75 - 2013-14 Commissioner of Income Tax (Appeals), Delhi
Income tax Act, 1961 Income tax 79.11 - 2014-15 Commissioner of Income Tax (Appeals), Delhi
Income tax Act, 1961 Income tax 786.95 - 2015-16 Commissioner of Income Tax (Appeals), Delhi
Income tax Act, 1961 Income tax 528.99 142.15 2016-17 Commissioner of Income Tax (Appeals), Delhi
The Central Excise Act,1944 Excise Duty 1.18 - 1995-1996 Joint Commissioner of Central Excise, Patiala, Punjab
The Central Excise Act, 1944 Excise Duty 1.36 - 2003-2004 Joint Commissioner of Central Excise, Patiala, Punjab
The Central Excise Act, 1944 Excise Duty 1.76 - 1997-1999 Assistant Commissioner of Central Excise, Patiala, Punjab
The Central Excise Act, 1944 Excise Duty 1.84 - 1997-98 Joint Commissioner of Central Excise, Patiala, Punjab
The Central Excise Act, 1944 Excise Duty 6.96 - 1998-1999 Joint Commissioner of Central Excise, Patiala, Punjab
The Central Excise Act, 1944 Excise Duty 3.32 - 2001-2002 Additional Commissioner of Central Excise, Patiala, Punjab
The Central Excise Act, 1944 Excise Duty 188.28 - 2014-2017 Joint Commissioner, CGST Commissionerate, Alwar Rajasthan
The Central Excise Act, 1944 Excise Duty 282.45 - Nov-2013 to Jun-2017 Additional Director General- DGGSTI, New Delhi
The Central Excise Act, 1944 Excise Duty 241.00 - 2014-15 Additional Director General- DGGSTI, New Delhi
The Central Excise Act, 1944 Excise Duty 10.84 - 2017 Assistant Commissioner GST, Bhiwadi
Finance Act, 1994 (Service Tax) Service tax 86.44 25.00 2006-2007 Customs, Excise and Service Tax Appellate Tribunal, Bangalore
Finance Act, 1994 (Service Tax) Service tax 3.55 - 2009 Assistant Commissioner, Bhiwadi, Rajasthan
Finance Act, 1994 (Service Tax) Service tax 314.73 327.47 2008-12 Customs, Excise and Service Tax Appellate Tribunal, New Delhi
Finance Act, 1994 (Service Tax) Service tax 16.61 - 2009-10 Joint Commissioner, Jaipur, Rajasthan
Finance Act, 1994 (Service Tax) Service tax 5.81 0.58 2008-2011 Commissioner of Central Excise, Bangalore
Finance Act, 1994 (Service Tax) Service tax 113.70 4.60 May 2005 to July 2005 Customs, Excise and Service Tax Appellate Tribunal, Bangalore
Finance Act, 1994 (Service Tax) Service tax 194.00 14.60 Oct 2008 to March 2013 Customs, Excise and Service Tax Appellate Tribunal, Bangalore
Finance Act, 1994 (Service Tax) Service tax 0.09 - May 2008 To Dece. 2008 Add. Commissioner, Jaipur
Finance Act, 1994 (Service Tax) Service tax 13.02 - 2006-08 Joint. Commissioner, Jaipur
Finance Act, 1994 (Service Tax) Service tax 13.56 - 2010-11 Joint. Commissioner, Jaipur
Finance Act, 1994 (Service Tax) Service tax 28.70 - 2011-12 Joint. Commissioner, Jaipur
West Bengal VAT Act,2003 Value added tax 1.56 - 2001-2002 Kolkata Assistant Commissioner
West Bengal VAT Act,2003 Value added tax 1.87 - 2004-2005 Kolkata Assistant Commissioner
West Bengal VAT Act,2003 Value added tax 1.76 - 2006-2007 Kolkata Assistant Commissioner
West Bengal VAT Act,2003 Value added tax 1.18 - 2006-2007 Kolkata Assistant Commissioner
Karnataka VAT Act, 2003 Value Added tax 1.36 - 2007-2008 Assistant Commissioner, Bangalore
Karnataka VAT Act, 2003 Value added tax 13.38 3.41 2008-09 DCCT Audit Bangalore
Uttaranchal VAT Act,2005 Value Added Tax 33.38 33.38 2010-11 Uttarakhand High Court
Gujarat VAT Demand Act, 2003 Value Added Tax 568.25 56.83 2012-13 Gujarat DC Appeals
Gujarat CST Demand Value Added Tax 39.28 3.93 2012-13 Gujarat DC Appeals
Uttar Pradesh VAT Act, 2008 Value Added Tax 4.03 - 2014-15 Uttar Pradesh, ADC Ghaziabad
Andhra Pradesh VAT Act, 2005 Value added tax 35.07 5.48 2013-14 Telangana, Assessing Officer
Rajasthan VAT Act, 2003 Value Added Tax 85.06 - 2014-17 Assistant Commissioner, Bhiwadi, Rajasthan
Karnataka VAT Act 2003 Value Added Tax 442.42 - 2015-16 DCCT, Audit Bangalore

(viii) The Company has not defaulted in repayment of loans or borrowings to any bank or financial institution or government during the year. The Company did not have any outstanding debentures during the year.

(ix) The Company did not raise moneys by way of initial public offer or further public offer (including debt instruments) and did not have any term loans outstanding during the year. Accordingly, the provisions of clause 3(ix) of the Order are not applicable.

(x) No fraud by the Company or on the Company by its officers or employees has been noticed or reported during the period covered by our audit.

(xi) Managerial remuneration has been paid and provided by the Company in accordance with the requisite approvals mandated by the provisions of Section 197 of the Act read with Schedule V to the Act.

(xii) In our opinion, the Company is not a Nidhi Company. Accordingly, provisions of clause 3(xii) of the Order are not applicable.

(xiii) In our opinion all transactions with the related parties are in compliance with Sections 177 and 188 of Act, where applicable, and the requisite details have been disclosed in the financial statements etc., as required by the applicable Ind AS.

(xiv) During the year, the Company has not made any preferential allotment or private placement of shares or fully or partly convertible debentures.

(xv) In our opinion, the Company has not entered into any non-cash transactions with the directors or persons connected with them covered under Section 192 of the Act.

(xvi) The Company is not required to be registered under Section 45-IA of the Reserve Bank of India Act, 1934.

For Walker Chandiok & Co LLP

Chartered Accountants

Firm’s Registration No.: 001076N/N500013

Anamitra Das

Partner

Membership No.: 062191

UDIN: 21062191AAAAIX8165

Place : Gurugram

Date :28 June 2021

Annexure B to the Independent Auditor’s Report of even date to the members of Federal Mogul Goetze (India) Limited on the standalone financial statements for the year ended 31 March 2021

Annexure B

Independent Auditor’s Report on the internal financial controls with reference to the standalone financial statements under Clause (i) of Subsection 3 of Section 143 of the Companies Act, 2013 (‘the Act’)

1. In conjunction with our audit of the standalone financial statements of Federal Mogul Goetze (India) Limited (‘the Company’) as at and for the year ended 31 March 2021, we have audited the internal financial controls with reference to financial statements of the Company as at that date.

Responsibilities of Management and Those Charged with Governance for Internal Financial Controls

2. The Company’s Board of Directors is responsible for establishing and maintaining internal financial controls based on the internal control over financial reporting criteria established by the Company considering the essential components of Internal Control stated in the Guidance note on the Audit of Internal Financial Controls over Financial Reporting (the "Guidance Note") 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 the Company’s business, including adherence to the Company’s policies, the safeguarding of its assets, the prevention and detection of frauds and errors, the accuracy and completeness of the accounting records, and the timely preparation of reliable financial information, as required under the Act.

Auditor’s Responsibility for the Audit of the Internal Financial Controls with Reference to Financial Statements

3. Our responsibility is to express an opinion on the Companys internal financial controls with reference to financial statements based on our audit. We conducted our audit in accordance with the Standards on Auditing issued by the ICAI prescribed under Section 143(10) of the Act, to the extent applicable to an audit of internal financial controls with reference to financial statements, and the Guidance Note 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 with reference to financial statements were established and maintained and if such controls operated effectively in all material respects.

4. Our audit involves performing procedures to obtain audit evidence about the adequacy of the internal financial controls with reference to financial statements and their operating effectiveness. Our audit of internal financial controls with reference to financial statements includes obtaining an understanding of such internal financial controls, 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 auditor’s judgement, including the assessment of the risks of material misstatement of the financial statements, whether due to fraud or error.

5. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion on the Company’s internal financial controls with reference to financial statements.

Meaning of Internal Financial Controls with Reference to Financial Statements

6. A companys internal financial controls with reference to 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 companys internal financial controls with reference to financial statements include 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 company;

(2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the company are being made only in accordance with authorisations of management and directors of the company; and

(3) provide reasonable assurance regarding prevention or timely detection of unauthorised acquisition, use, or disposition of the companys assets that could have a material effect on the financial statements.

Inherent Limitations of Internal Financial Controls with Reference to Financial Statements

7. Because of the inherent limitations of internal financial controls with reference to 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 financial statements to future periods are subject to the risk that the internal financial controls with reference to financial statements may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

Opinion

8. In our opinion, the Company has, in all material respects, adequate internal financial controls with reference to financial statements and such controls were operating effectively as at 31 March 2021, based on the internal control over financial reporting criteria established by the Company considering the essential components of internal control stated in the Guidance note issued by the ICAI.

For Walker Chandiok & Co LLP

Chartered Accountants

Firm’s Registration No.:

001076N/N500013

Anamitra Das

Partner

Membership No.: 062191

UDIN: 21062191AAAAIX8165

Place: Gurugram

Date: 28 June 2021