Gujarat Mineral Development Corporation Ltd Auditor Reports

TO THE MEMBERS OF

GUJARAT MINERAL DEVELOPMENT CORPORATION LIMITED

Report on the Audit of the Standalone Financial Statements

Opinion

We have audited the accompanying Standalone Financial Statements of Gujarat Mineral Development Corporation Limited (“the Company”), which comprise the Balance Sheet as at 31st March, 2026, 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 Financial Statements, including Material Accounting Policies and other explanatory information (hereinafter referred to as “Standalone Financial Statements”).

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 (“the Act”) in the manner so required and give a true and fair view in conformity with the Indian Accounting Standards prescribed under section 133 of the Act read with the Companies (Indian Accounting Standards) Rules, 2015, as amended, (“Ind AS”) and other accounting principles generally accepted in India, of the state of affairs of the Company as at 31st March, 2026 and its profit and total comprehensive income, changes in equity and its cash flows for the year ended on that date.

Basis for Opinion

We conducted our audit of the Standalone Financial Statements in accordance with the Standards on Auditing (“SAs”) specified under section 143(10) of the Act. Our responsibilities under those Standards are further described in the Auditors Responsibilities for the Audit of the Standalone 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 Financial Statements under the provisions of the Act and the Rules made thereunder, and we have fulfilled our other ethical responsibilities in accordance with these requirements and the ICAIs Code of Ethics. We believe that the audit evidence obtained by us is sufficient and appropriate to provide a basis for our audit opinion on the Standalone Financial Statements.

Emphasis of Matter

I. We draw attention to Note 2.35.01 and 2.35.02 of the Standalone Financial Statements describing the nature of the exceptional items. Pursuant to the revision in GST rates on lignite from 5% to 18% effective 22.09.2025, along with removal of compensation cess, the Company is now eligible to utilise previously unutilised input tax credit (ITC). Accordingly, ITC of H492.63 crore, earlier expensed due to limited utilisation under the inverted duty structure, has been recognised as an asset in the current financial year, with a corresponding credit disclosed as an exceptional item in the Statement of Profit and Loss. This reversal has also impacted Capital Work-in-Progress (CWIP) and Intangible Assets under Development amounting to H12.76 crore and H5.12 crore respectively.

Further, ITC pertaining to earlier years which were under litigation and were written off in the books of accounts, have now been restored following withdrawal of appeal approved by the Joint Commissioner of State Tax. Accordingly, H30.02 crore has been recognised as ITC asset with a corresponding exceptional item in the Statement of Profit and Loss.

ii. We draw kind attention to Note 2.52(b)(i) of the Standalone Financial Statements whereby the company has adopted its accounting policy for Exploration and Evaluation Assets (E & E Assets). Up to 31 March 2025, the Companys Exploration and Evaluation activities were insignificant and hence, the related expenditure was recognised in the Statement of Profit and Loss as and when incurred. From current financial year, considering significance and materiality of exploration activities of ongoing and upcoming projects, the Company has adopted an accounting policy to recognise the E & E assets separately (refer Note 1 (d)). The said change has been made to reflect the E & E assets accurately and also to align the policy with the industry practices. The effect of said change has been given retrospectively w.e.f. 1st April 2024 and accordingly comparative year i.e. FY 2024-25 has also been restated. This change has resulted in addition to E & E Assets under non - current assets amounting to H6.88 crore & H0.12 crore during current and previous financial year respectively with consequential credit to the respective expenses head under Statement of Profit and Loss.

iii. We draw attention to Note No. 2.10.02 of the Standalone Financial Statements regarding trade receivables from Gujarat Urja Vikas Nigam Limited (GUVNL) and Gujarat State Electricity Corporation Limited (GSECL). The Company sells lignite/power to GSECL/GUVNL, with lignite pricing based on a formula using 13% interest on project PPE up to March 31, 2022. However, since July 1, 2017, GSECL/GUVNL has applied only 8.50% interest on payments, resulting in receivables of H10.17 crore (March 31, 2025: H10.17 crore). The matter is under correspondence, and necessary adjustments will be recorded upon nal resolution.

iv. We draw kind attention to Note 2.29.01 of the Standalone Financial Statements, whereby the company earns on the xed deposit held in the escrow accounts for mine closure expenses and recognised such interest as income in the Statement of Profit and Loss. The interest income so earned is a part of escrow account over which the company has no hold until the provisions of mine closure plan are complied.

v. We draw kind attention to Note 2.49 B(i) of the Standalone Financial Statements, regarding valuation of investments in Gujarat Informatics Limited as per latest audited/ management approved Financial Statements. Since the Company has not received Fair Valuation report of Gujarat Informatics Limited as per the Financial Statements for the FY 2025-26, financial impact of the same has been considered based on latest available records i.e. provisional/the management approved financial statements for FY 2021-22. Reduction or increase in the value of investments, if any, will be considered as and when the relevant information is available.

vi. We draw kind attention to Note 2.52 (a) of the Standalone Financial Statements, whereby the company has accounted for material prior period errors discovered during the current period, retrospectively by restating the comparative amounts to which the same relate.

Our opinion on the Standalone Financial Statements, and our Report on Other Legal and Regulatory Requirements, is not modified in respect of matters described above.

Key Audit Matter

Key audit matters are those matters that, in our professional judgement, 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 Standalone Financial Statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters. We have determined the matters described below to be the key audit matters to be communicated in our report.

S. No. Key Audit Matter	Auditors Response
1. Stripping Cost (Refer Note No. 2.14 and Note No. 1 (s))	Our audit approach was a combination of test of internal controls and substantive procedures which included the following:
Expenditure incurred on removal of mine waste materials (overburden) necessary to extract the lignite reserve is referred to as Stripping cost.	Evaluated the Overburden Removal (OB) and lignite reserve estimate and discussed with the geologist about geologist model, estimation tools and sampling method
Cost of stripping is charged on technical evaluated average stripping ratio at each plot of mine after due adjustment for stripping activity.
	(As per SA-620 “Using the Work of an Auditors Expert”).
Refer Note 1(s) of the Material Accounting Policies	Tested ‘Average stripping ratio by recalculating the Lignite to overburden.
	Selected a sample of contracts and through inspection of evidence tested the operating effectiveness of the internal controls relating to stripping activity.
	Carried out a combination of procedures involving enquiry, observation and inspection of evidence in respect of operation of these controls.
	Performed analytical procedures and test of details for reasonableness of expenditure incurred.
2. Mine Closure Obligation	Our Audit procedure included the following:
(Refer Note No. 2.07.01, 2.07.02,2.20.01)
The company estimates its obligation for Mine Closure, Site Restoration and Decommissioning based upon detailed calculation and technical assessment. Mine Closure expenditure is provided as per approved Mine Closure Plan. As the provision for mine closure involves estimate and Management judgement, the same is considered as a Key Audit Matter.	Identi cation and understanding of the reasonableness of the principal assumption used by the management to judge the need for its basis of estimate as it has been explained to us that the provision made is in accordance with the technical evaluation.
	We have verified the arithmetical accuracy of the mine closure obligation provision.
	Based on the above procedures performed, we did not identify any significant exceptions in the managements assessment in Mine closure obligation provision.
S. No. Key Audit Matter	Auditors Response
3. Contingent liabilities relating to Income tax (as described in Note 2.40(i) of the financial statements)	Our audit procedures included the following:
The company has uncertain tax position including matters under dispute which involve significant judgement relating to the possible outcome of these disputes in estimation of the provision of income tax. In view of this, the area has been considered as a Key Audit Matter.	As part of our audit procedures, we have assessed managements processes to identify new possible obligations and changes in existing obligations for compliance with Companys policy and Ind AS 37 requirements.
	We have analysed significant changes from prior periods and obtain a detailed understanding of these items and assumptions applied.
	We have obtained details of completed tax assessments and outstanding demands as at the year ended 31st March, 2026 from management. We involved our internal experts to discuss with the management regarding estimates used to ascertain the tax provision of disputed cases.
	We have held regular meetings with management and legal counsels.
	We have assessed the appropriateness of presentation of the most significant contingent liabilities in the Standalone Financial Statements.

 

4. Carrying value of Property, Plant and Equipment, Right of use assets, Other Intangible assets (including Capital work-in-progress and Intangible Assets under Development, Exploration & Evaluation Assets)

(Refer Note No. 2.01A, 2.01B, 2.01C, 2.03A, 2.03B, 2.03C)

Property, plant and equipment, right of use assets, capital work-in-progress (CWIP), other intangible assets and Intangible assets under development represent significant balances recorded in the statements of financial position in the Standalone Financial Statements.

The evaluation of the recoverable amount of these assets requires significant judgement in determining the key assumptions supporting the expected future cash flows of the business and the utilisation of the relevant assets including impairment provisions related to the assets.

There are a number of areas where management judgement impacts the carrying value of property, plant and equipment, intangible assets and their respective depreciation pro les. These include the decision to capitalise or expense costs; the asset life review including the impact of changes in the Companys strategy; and the timeliness of capitalisation, determination or the measurement and recognition criteria for assets retired from active use.

Our audit procedures relating to the carrying value of property, plant and equipment, right of use assets, other intangible assets (including and capital work-in-progress and intangible assets under development) included the following:

We evaluated the assumptions made by management in the determination of carrying values and useful lives to ensure that these are consistent with the principles of Indian Accounting Standards (Ind AS) 16 Property, Plant and Equipment and Ind AS 38 Intangible Assets.

We compared the useful lives of each class of asset in the current year to the previous year to determine whether there were any significant changes in the useful lives of assets, and considered the reasonableness of changes based on our knowledge of the business and the industry.

We assessed whether indicators of impairment existed as at 31st March, 2026 based on our knowledge of the business and the industry and wherever required the provision of impairment of assets/ CWIP were reviewed.

We tested the controls in place over the property, plant and equipment and intangible assets, evaluated the appropriateness of capitalisation policies, performed tests of details on costs capitalised and assessed the timeliness of capitalisation including de-capitalisation of assets retired from active use and the application of the asset life.

Based on the above procedures, we found managements assessment in determining the carrying value of the property, plant and equipment and intangible assets are to be reasonable.

Information Other than the Standalone 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 Annexure to Boards Report, Business Responsibility and Sustainability Report, Report on CSR Activities, Corporate Governance and Shareholders Information, but does not include the Standalone Financial Statements and our auditors report thereon.

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

When we read the other information, if we conclude that there is material misstatement therein, we are required to communicate the matter to those charged with governance and take appropriate action, if required. We have nothing to report in this regard.

Responsibilities of Management and Those Charged with Governance for the Standalone 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 of these Standalone 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 Indian Accounting Standards (Ind AS) prescribed under section 133 of the Act read with relevant rules issued thereunder and accounting principles generally accepted in India.

This responsibility also includes maintenance of adequate accounting records in accordance with the provisions of the Act for safeguarding the assets of the Company and for preventing and detecting frauds and other irregularities; selection and application of appropriate accounting policies; making judgements 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 Financial Statements that give a true and fair view and are free from material misstatement, whether due to fraud or error.

In preparing the Standalone Financial Statements, the Board of Directors 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 the Board of Directors 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 Standalone Financial Statements

Our objectives are to obtain reasonable assurance about whether the Standalone Financial Statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditors report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with SAs will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these Standalone Financial Statements.

As part of an audit in accordance with Standards on Auditing (“SAs”), we exercise professional judgement and maintain professional skepticism throughout the audit. We also:

Identify and assess the risks of material misstatement of the Standalone 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 controls relevant to the audit in order to design audit procedures that are appropriate in the circumstances. Under section143(3)(I) of the Companies Act, 2013, we are also responsible 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 Standalone 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 Standalone Financial Statements, including the disclosures, and whether the Standalone Financial Statements represent the underlying transactions and events in a manner that achieves fair presentation.

Materiality is the magnitude of misstatements in the Standalone Financial Statements that, individually or in aggregate, makes it probable that the economic decisions of a reasonably knowledgeable user of the Standalone Financial Statements may be in uenced. 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 Standalone Financial Statements.

We communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit and significant audit ndings, 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 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 (Auditors Report) Order, 2020 (“the Order”), issued by the Central Government of India in terms of sub-section (11) of section 143 of the Companies Act, 2013, we give in the Annexure ‘A, a statement on the matters specified in paragraphs 3 and 4 of the Order, to the extent applicable.

2. In terms of Section 143(5) of the Companies Act, 2013, we give in Annexure ‘B a statement on the directions issued under the aforesaid section by the Comptroller and Auditor General of India.

3. As required by Section 143 (3) of the Companies Act, 2013 we report that:

a) We have sought and obtained all the information and explanations which to the best of our knowledge and belief were necessary for the purposes of our audit of the aforesaid Standalone Financial Statements;

b) In our opinion, proper books of account as required by law relating to preparation of the aforesaid Standalone Financial Statements have been kept by the Company so far as it appears from our examination of those books;

c) The Balance Sheet, the Statement of Profit and Loss (including Other Comprehensive Income), the Statement of Changes in Equity and the Cash Flow Statement dealt with by this Report are in agreement with the relevant books of account maintained for the purpose of the Standalone Financial Statements; d) In our opinion, the aforesaid Standalone Financial Statements comply with the Indian Accounting Standards specified under Section 133 of the Act, read with the Companies (Indian Accounting Standards) Rules, 2015, as amended;

e) Being a Government Company, pursuant to the Noti cation No. G.S.R. 463(E) dated 5th June, 2015 issued by Ministry of Corporate Affairs, Government of India, provisions of sub-section (2) of Section 164 of the Companies Act, 2013, are not applicable to the Company.

f) With respect to the adequacy of the internal financial controls with reference to Standalone Financial Statements of the Company and the operating effectiveness of such controls, refer to our separate Report in Annexure ‘C. Our report expresses an unmodi ed opinion on the adequacy and operating effectiveness of the Companys internal financial controls with reference to Standalone Financial Statements.

g) With respect to the other matters to be included in the Auditors Report in accordance with the requirements of section 197(16) of the Act, as amended:

The provision of Section 197 read with Schedule V of the Act, relating to managerial remuneration is not applicable to the Company by virtue of Noti cation No. G.S.R. 463(E) dated 5th June, 2015 issued by the Ministry of Corporate Affairs, Government of India; and

h) With respect to the other matters to be included in the Auditors Report in accordance with Rule 11 of the Companies (Audit and Auditors) Rules, 2014, in our opinion and to the best of our information and according to the explanations given to us:

i. The Company has disclosed the impact of pending litigations on its financial position in its Standalone Financial Statements - Refer Note 2.40 (i) to the Standalone Financial Statements.

ii. As explained to us, the Company did not have any long-term contracts including derivative contracts for which there were any material foreseeable losses.

iii. There has been no instance of delay in transferring amounts, required to be transferred, to the Investor Education and Protection Fund by the Company during the year.

iv. [a] The management has represented that, to the best of its knowledge and belief, no funds (which are material either individually or in the aggregate) have been advanced or loaned or invested (either from borrowed funds or share premium or any other sources or kind of funds) by the 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 Bene ciaries”) or

- provide any guarantee, security or the like to or

on behalf of the Ultimate Bene ciaries.

[b] The management has represented, that, to the best of its knowledge and belief, no funds (which are material either individually or in the aggregate) have been received by the Company from any persons or entities, including foreign entities (“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 entities identified in any manner whatsoever by or on behalf of the Funding Party (“Ultimate Bene ciaries”) or

- provide any guarantee, security or the like from or

on behalf of the Ultimate Bene ciaries; and

[c] Based on such audit procedures as considered reasonable and appropriate in the circumstances, nothing has come to our notice that has caused us to believe that the representations under sub clause (i) and (ii) of Rule 11(e), as provided under (a) and (b) above, contain any material misstatement.

v. The dividend declared / paid during the year by the company is in compliance with Section 123 of the Companies Act, 2013.

vi. The reporting under Rule 11(g) of the Companies

(Audit and Auditors) Rules, 2014 is as under:

Based on our examination which included test checks, the Company has used accounting software for maintaining its books of account, which have a feature of recording audit trail (edit log) facility and the same has operated throughout the year for all relevant transactions recorded in the respective software. Further, for the periods where audit trail (edit log) facility was enabled and operated throughout the year for the respective accounting software, we did not come across any instance of the audit trail feature being tampered with.

The audit trail has been preserved by the Company as per the statutory requirements for record retention.

	For Dhirubhai Shah & Co LLP
	Chartered Accountants
	FRN: 102511W/W100298
	Parth S. Dadawala
	Partner
Place: Ahmedabad	M. No. 134475
Date: 14 May, 2026	UDIN: 26134475HGHUFC7642

ANNEXURE ‘A TO THE

INDEPENDENT AUDITORS REPORT

(Referred to in Para 1 under ‘Report on Other Legal and Regulatory Requirements section of our report to the Members of Gujarat Mineral Development Corporation Limited of even date) To the best of our information and according to the explanations provided to us by the Company and the books of account and records examined by us in the normal course of audit, we state that: i. In respect of the Companys property, plant and equipment (PPE), right-of-use (ROU) assets and intangible assets: a. (A) The company has maintained proper records showing full particulars, including quantitative details and situation of its PPE and relevant details of ROU assets.

(B) The company has maintained proper records showing full particulars of its intangible assets. b. The Company has a program of physical verification of its PPE by which PPE are verified once every three years, the frequency of 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, PPE verification has been undertaken during the year ended 31st March, 2024 for all the projects except for PPE pertaining to Akrimota Thermal Power Project. The company has carried out physical verification of PPE of Akrimota Thermal Power Project during FY 2025-26 and the discrepancies noticed on such verification have been properly dealt with in the books of accounts. c. According to the information and explanations given to us and on the basis of our examination of the records of the Company, the title deeds of immovable properties (other than properties where the company is the lessee and the lease agreements are duly executed in favour of the lessee), disclosed in the financial statements included under PPE are held in the name of the Company as at the balance sheet date. d. According to the information and explanations given to us and on the basis of our examination of the record of the Company, the Company has not revalued its PPE (including ROU assets) or intangible assets or both during the year. e. According to the information and explanations given to us and on the basis of our examination of the record of Company, no proceedings have been initiated or are pending against the Company for holding any benami property under the Benami Transactions (Prohibition) Act, 1988 (as amended in 2016) and rules made thereunder. ii. In respect of Inventory and Working Capital Limits a. (I) The physical verification of inventory has been conducted at reasonable intervals by the Management.

(ii) The coverage and procedure of physical verification of inventory followed by the management is reasonable, adequate and appropriate in relation to the size of company and the nature of its business.

(iii) The Company has maintained proper records of inventory. The discrepancies noticed on such verification between the physical stocks and book stocks were not material for each class of inventory and the same have been properly dealt with in the books of accounts. b. The Company has been sanctioned working capital limits in excess of ve crore rupees, in aggregate, from banks or financial institutions, but the company has not availed the said limit during the year,. Further, sanction letter of the said working capital has not stipulated condition to submit quarterly returns or statements to banks or Financial Institutions. iii. According to the information and explanations given to us and on the basis of our examination of the record of the Company during the year, the Company has not made investment in, provided any guarantee or security or granted any loans or advances in the nature of loans, secured or unsecured to companies, rms, limited liability partnership or other parties covered in the register maintained under section 189 of the Companies Act, 2013. Therefore, requirement of paragraph 3 (iii) of the order is not applicable to the company. iv. In respect of loans, investments, guarantees, and security, provisions of section 185 and 186 of the Companies Act, 2013 have been complied with as applicable. v. The Company has not accepted any deposits or amounts which are deemed to be deposits during the year as per the directives issued by the Reserve Bank of India and within the meaning of the provisions of sections 73 to 76 and other relevant provisions of the Companies Act, 2013 and the rules framed there under, where applicable. Thus, paragraph 3(v) of the order is not applicable to the Company. vi. In pursuance to the order made by the Central Government for the maintenance of cost records under sub section (1) of section 148 of the Companies Act, 2013, the Company has made and maintained the prescribed accounts and records. However, we have not made a detailed examination of the cost records with a view to determine whether they are accurate or complete. vii. In respect of statutory dues a. According to the information and explanations given to us, and on the basis of our examination, the company is generally regular in depositing undisputed statutory dues including Provident Fund, Employees State Insurance, Income Tax, Goods and Services Tax, Sales Tax/ Central Sales Tax, Service Tax, Duty of Excise, Duty of Customs, Value Added Tax, Cess and any other statutory dues with appropriate authorities during the year. Further, no undisputed amounts payable in respect of statutory dues is outstanding for more than six months from the date they become due as on

balance sheet date. b. The details of excise duty, service tax, income tax and Central Sales Tax/VAT not deposited on account of dispute are as under:

Name of Statute	Nature of the Dues	Period to which the amount related	Amount (J in Crore)	Forum where dispute is pending
Commercial Tax	Sales Tax/VAT	1995-96	0.99	Decided by Appellate Tribunal, effect giving order pending
Commercial Tax	Sales Tax/VAT	1997-98	0.02	Decided by Appellate Tribunal, effect giving order pending
Commercial Tax	Sales Tax/VAT	1997-98	0.04	Decided by Appellate Tribunal, effect giving order pending
Commercial Tax	Sales Tax/VAT	1993-94	0.22	Honble Gujarat High Court
Service Tax	Service Tax	Oct-12 to Jun-17	6.21	CESTAT
Service Tax	Service Tax	Feb-12 to Nov-15	0.41	CESTAT
Service Tax	Service Tax	Dec-15 to Mar-16	3.03	CESTAT
Service Tax	Service Tax	Apr-16 to Jun-17	1.66	CESTAT
Service Tax	Service Tax	Dec-15 to Aug-16	-*	CESTAT
Income tax Act,1961	Income Tax	A.Y. 1998-99	0.72	Decided by Honble Gujarat High Court but appeal effect order is pending.
Income tax Act,1961	Income Tax	A.Y. 2002-03	6.62	Honble Gujarat High Court
Income tax Act,1961	Income Tax	A.Y. 2003-04	0.08	Decided by Honble Gujarat High Court but appeal effect order is pending.
Income tax Act,1961	Income Tax	A.Y. 2004-05	0.03	Decided by Honble Gujarat High Court but appeal effect order is pending.
Income tax Act,1961	Income Tax	A.Y. 2010-11	11.51	Honble Gujarat High Court
Income tax Act,1961	Income Tax	A.Y. 2012-13	1.97	ITAT
Income tax Act,1961	Income Tax	A.Y. 2013-14	0.18	Honble Gujarat High Court
Income tax Act,1961	Income Tax	A.Y. 2015-16	0.01	Honble Gujarat High Court

*Amount involved - H32,087/-.

viii. According to the information and explanations given to us, and on the basis of our examination of the records of the Company, no transactions were recorded in the books of accounts that have been surrendered or disclosed as income during the year in the tax assessments under the Income Tax Act, 1961. There is no previously unrecorded income which has been properly recorded in the books of account during the year.

ix. According to the information and explanations given to us and on the basis of our examination of the records of the company, we state as under:

a. The Company has not defaulted in repayment of loan

and payment of interest thereon to the lender.

b. The Company has not been declared wilful defaulter by any bank or financial institution or other lender.

c. The Company has utilised the money obtained by way of term loans during the year for the purposes for which they were obtained.

d. No funds were raised by the Company on short-term basis and therefore reporting under Clause ix(d) is not applicable.

e. 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 and therefore

reporting under Clause ix(e) is not applicable.

f. The Company has not raised any loans by way of pledge of securities held in subsidiaries, associates or joint ventures and therefore reporting under Clause ix(f) is not applicable.

x. a. The Company has not raised moneys by way of initial public offer or further public offer (including debt instruments) during the year and hence reporting under paragraph 3(x)(a) of the Order is not applicable.

b. According to the information and explanations given to us and based on our examination of the records of the Company, the Company has not made any preferential allotment or private placement of shares or convertible debentures (fully or partly or optionally) and hence reporting under paragraph 3(x)(b) of the Order is not applicable.

xi. a. According to the information and explanations given to us, no material fraud by the Company or on the Company by its of cers or employees has been noticed or reported during the course of our audit.

b. There is no Audit Report in form ADT-4 as prescribed

under rule 13 of Companies (Audit and Auditors) Rules,

2014 has been led by the auditors with Central Government in terms of provisions of sub section 12 of Section 143 of the Companies Act with the Central Government during the year and up to the date of this report. c. According to the information and explanations given to us, there is no whistle blower complaint has been 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 3 (xii) (a), (b) and (c) of the Order is not applicable to the Company. xiii. According to the information and explanations given to us, all transactions with the related parties are in compliance with sections 177 and 188 of Companies Act, 2013 wherever applicable and the details have been disclosed in the Standalone Financial Statements etc. as required by the applicable Indian Accounting Standards. xiv. a. In our opinion the Company has an Internal Audit system commensurate with the size and nature of its business. b. We have considered, the internal audit reports for the year under audit, issued to the Company during the year and till date, in determining the nature, timing and extent of our audit procedures. xv. According to the information and explanations given to us and based on our examination of the records, the Company has not entered into any non-cash transactions with any director or persons connected with him as specified in Section 192 of the Act. xvi. According to the information and explanation given to us, the Company is not required to be registered u/s 45-IA of Reserve Bank of India Act, 1934. Accordingly, provision of paragraph 3(xvi) of the Order is not applicable to the Company. xvii. According to the information and explanations given to us, the company has not incurred cash losses in the financial year and in the immediately preceding financial year. xviii.There has been no instance of resignation of the statutory auditors during the year.

xix. On the basis of the financial ratios, ageing and expected dates of realisation of financial assets and payment of financial liabilities, other information accompanying the financial statements, Plans of the Board of Directors and management, we are of the opinion that no material uncertainty exists as on the date of the audit report and the company is 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 information and explanation given to us, the company has spent the entire amount hence there is no unspent amount which is required to be transferred 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. Accordingly, reporting under paragraph 3(xx)(a) of the Order is not applicable for the year. b. There is no such amount remaining unspent under subsection (5) of section 135 of the Companies Act, pursuant to any ongoing project, which has been required to be transferred to special account in compliance with the provision of sub-section (6) of section 135 of the said Act;

	For Dhirubhai Shah & Co LLP
	Chartered Accountants
	FRN: 102511W/W100298
	Parth S. Dadawala
	Partner
Place: Ahmedabad	M. No. 134475
Date: 14 May, 2026	UDIN: 26134475HGHUFC7642

ANNEXURE ‘B TO THE

INDEPENDENT AUDITORS REPORT

(Referred to in Para ‘2 under ‘Report on Other Legal and Regulatory Requirements section of our report to the Members of Gujarat Mineral Development Corporation Limited of even date)

In continuation of our Independent Auditors Report on Standalone Financial Statements of Gujarat Mineral Development Corporation Ltd (“The Company”) dated 14th May 2026, we have reported on the Directions and Sub-directions under section 143(5) of the Companies Act, 2013 applicable for the year 2025-26 as under:

PART-I

Directions under Section 143(5) of Companies Act 2013 Applicable for the year 2025-26

S. Directions/Questions u/s 143(5) No.	Action Taken by Gujarat Mineral Development Corporation Ltd.	Impact on Accounts and Financials
1 Assess the fair valuation of all the investments, both quoted and unquoted, made directly by the Company or through Trusts, for Post retirement benefits of the employees. This includes verifying valuation methodologies, ensuring consistency with Ind AS and reviewing supporting documentation. The auditor shall provide a brief note on the valuation approach, its reasonability, and compliance with applicable regulations, reporting any material deviations or misstatements.	The Company manages its post-retirement gratuity obligations through GMDC Ltd Employees Gratuity Trust. The trust has invested in fund plan assets with the Life Insurance Corporation of India (LIC) and recognise fair value on the basis of certi cates issued by LIC. The Company has not created any fund or trust for managing leave encashment obligations.	No impact
2 Whether the Company has a system in place to process all the accounting transactions through IT system? If yes, whether review of this system and controls that are significant to the Companies financial reporting process as well as cyber security has been done by Information Security Auditing Organisations empanelled by Cert-In at a minimum frequency of once in a year and material discrepancies found, if any,	Yes, the company has Oracle based composite ERP System covering all the departments of the company from where accounting transactions are processed. During the year, no instances were observed where accounting transactions were processed outside the ERP system. Therefore, there is no financial implication on the integrity of the accounts.	No impact
have been suitably reported? The implications of processing of accounting transactions outside IT system on the integrity of the accounts along with the financial implications may also be reported.	The Company has not carried out the review through Information Security Auditing Organisations empanelled by CERT-In, but has carried out a review of controls over cyber security, through the National Forensic Sciences University (NFSU) during FY 2025-26 and no material discrepancies have been observed therein. NFSU is an autonomous institution of national importance, established under the Ministry of Home Affairs by an Act of Parliament and NFSU functions as an elite academic and training institution and collaborates with CERT-In empaneled partners for security auditing, rather than being an empaneled auditor itself. (Please note that we are not technical expert).
		Impact on
S. Directions/Questions u/s 143(5) No.	Action Taken by Gujarat Mineral Development Corporation Ltd.	Accounts and Financials
3 Whether funds (grants/subsidy etc.) received/ receivable for specific schemes from Central/State Government or its agencies were properly accounted for as per the applicable accounting standards or norms and whether the received funds were utilised as per its terms and conditions? Whether accounting of interest earned on grants received has been done as per terms and conditions of the Grant. List the cases of deviation.	Yes, fund (grant / subsidy etc). received / receivable for specific schemes from Central/State Government or its agencies were properly accounted for/utilised as per its terms and conditions. As informed to us, the company has not earned any interest on Government Grant. Consequently, no accounting treatment is required.	No impact
4 Whether the Company has identified the key Risk areas? If yes, whether the Company has formulated any Risk Management Policy to mitigate these risks? If yes, (a) whether the Risk	Yes, the Company has identified the key Risk areas. The Company has formulated the Risk Management Policy to mitigate these risks.	No impact
Management Policy has been formulated considering global best practices? (b) whether the Company has identified its data assets and whether it has been valued appropriately?	(a) The Risk Management Policy has been formulated in alignment with global standard - ISO 31000:2019 Risk Management Framework.
	(b) As per the information provided by the Company, the company has not been directed or is required by the State Government, to identify the Data Assets and to carry out its valuation. Accordingly, the Company has neither identified its data assets nor performed any valuation thereof.
5 Whether the Company is complying with the Securities and Exchange Board of India (SEBI) (Listing Obligation and Disclosure Requirements) Regulations, 2015, and other applicable rules and regulations of SEBI, Department of Investment and Public Asset Management, Ministry of Corporate Affairs, Department of Public Enterprises, Reserve Bank of India, Telecom Regulatory Authority of India, CERT-IN, Ministry of Electronics and Information Technology and National Payments Corporation of India wherever applicable? If not, the cases of deviation may be highlighted.	The company has generally compiled with Securities and Exchange Board of India (SEBI) (Listing Obligation and Disclosure Requirements) Regulations, 2015, and other applicable rules and regulations of SEBI and Ministry of Corporate Affairs. Further, the company has complied with guidelines and regulations of CERT-IN except matter stated in serial no. 2 above. As informed to us, guidelines and regulations of Department of Investment and Public Asset Management, Department of Public Enterprises, Reserve Bank of India, Telecom Regulatory Authority of India, Ministry of Electronics and Information Technology and National Payment Corporation of India is not applicable to the company.	No impact

For Dhirubhai Shah & Co LLP

	Chartered Accountants
	FRN: 102511W/W100298
	Parth S. Dadawala
	Partner
Place: Ahmedabad	M. No. 134475
Date: 14 May, 2026	UDIN: 26134475HGHUFC7642

PART - II

Sector-Speci c Sub-directions under section 143(5) of Companies Act, 2013

S. Sub-directions issued/Questions u/s 143(5) No. Manufacturing Sector	Action Taken by Gujarat Mineral Development Corporation Ltd.	Impact on Accounts and Financials
	Mining
1 Whether the company has taken adequate measures to reduce the adverse effect on environment as per established norms and taken up adequate measures for the relief and rehabilitation of displaced people.	According to the information and explanation given to us, the Company is obtaining environmental pollution monitoring report periodically from outside agency for each project to reduce/monitor the adverse effect on environment. No Major Displacement/Rehabilitation has been taken up at any project of the company for the year 2025-26. (Please note that we are not technical expert)	No impact
2 Whether the Company had obtained the requisite statutory compliances that was required under mining and environmental rules and regulations?	As per the information and explanation given to us, the Company has obtained necessary consents from GPCB for mining projects.	Not impact
3 Whether overburden removal from mines and back lling of mines are commensurate with the mining activity?	As informed to us, in respect of lignite projects overburden removal from mines and back lling of mines are commensurate with the mining activity as per submitted/approved/prepared mine closure plan. (Please note that we are not technical expert)	No impact
4 Whether the Company has disbanded and discontinued mines, if so, the payment of corresponding dead rent thereagainst may be verified.	As informed to us, the Company has discontinued its Panandhro mine due to exhaust of lignite. Dead rent of H0.69 crore paid during the year for above mine.	No impact
5 Whether the Companys financial statements had properly accounted for the effect of Rehabilitation Activity and Mine Closure Plan?	The expenditure on Rehabilitation Activity and for Mine Closure is properly accounted in the nancial statements of the Company, as per the Material Accounting policy of the Company adopted in this behalf.	No impact

 

S. Sub-directions issued/Questions u/s 143(5) No.	Action Taken by Gujarat Mineral Development Corporation Ltd.	Impact on Accounts and Financials
	Power Sector
	Generation
1 In the cases of Thermal Power Projects, compliance of the various Pollution Control Acts and the impact thereof including utilisation and disposal of ash and the policy of the company in this regard, may be checked and commented upon.	As per the information and explanation provided to us, the Company has made compliance of various Pollution Control Acts. In respect of utilisation and disposal of ash, generally the Company is using it in back lling of mine in Panandhro project.	No impact
2 Has the company entered into revenue-sharing agreements with private parties for extraction of coal at pitheads and it adequately protects the financial interest of the company?	As informed to us, the Company has not entered into revenue sharing agreements with private parties for extraction of coal at pitheads	Not Applicable
3 Does the company have a proper system for reconciliation of quantity/quality of coal ordered and received and whether grade of coal/moisture and demurrage etc., are properly recorded in the books of accounts?	Company does not purchase coal from the outside parties. However, as informed to us, the Company is having a system in ERP for reconciliation of quantity ordered and received and Grade of coal/ moisture and demurrage etc. are recorded in the books of account on the basis of Test Certificate received from the laboratory. (Please note that we are not technical experts).	No impact
4 How much share of free power was due to the State Government and whether the same was calculated as per the agreed terms and depicted in the accounts as per accepted accounting norms?	The power is sold to Government controlled entity and the same is calculated as per terms agreed in Power Purchase Agreement (PPA ).	No impact
5 In the case of Hydroelectric Projects, the water discharge is as per policy /guidelines issued by the State Government to maintain biodiversity. For not maintaining it penalty paid/payable may be reported.	As informed to us, no hydroelectric Project is carried out by Company.	Not Applicable

ANNEXURE ‘C TO THE INDEPENDENT AUDITORS REPORT

(Referred to in Para ‘3(f) under ‘Report on Other Legal and Regulatory Requirements section of our report to the Member of Gujarat Mineral Development Corporation Limited of even date)

Report on the Internal Financial Controls with reference to Standalone Financial Statements under Clause (i) of Subsection 3 of Section 143 of the Companies Act, 2013 (“the Act”)

We have audited the internal financial controls over financial reporting of Gujarat Mineral Development Corporation Limited (“the Company”) as of 31st March, 2026, in conjunction with our audit of the Standalone Financial Statements of the Company for the year ended on that date.

Managements Responsibility for Internal Financial Controls

The Companys Management is responsible for establishing and maintaining internal financial controls with reference to Standalone Financial Statements 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 Audit of Internal Financial Controls Over Financial Reporting issued by the Institute of Chartered Accountants of India (the “ICAI”). These responsibilities include the design, implementation and maintenance of adequate internal financial controls that were operating effectively for ensuring the orderly and efficient conduct of its business, including adherence to companys policies, the safeguarding of its assets, the prevention and detection of frauds and errors, the accuracy and completeness of the accounting records, and the timely preparation of reliable financial information, as required under the Act.

Auditors Responsibility

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

Our audit involves performing procedures to obtain audit evidence about the adequacy of the Internal Financial Controls with reference to Standalone Financial Statements and their operating effectiveness.

Our audit of Internal Financial Controls with reference to Standalone Financial Statements included 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 auditors judgement, including the assessment of the risks of material misstatement of the Standalone Financial Statements, whether due to fraud or error.

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion on the Companys internal financial controls system over financial reporting.

Meaning of Internal Financial Controls Over Financial Reporting

A Companys internal financial control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of Standalone Financial Statements for external purposes in accordance with generally accepted accounting principles. A Companys internal financial control over financial reporting includes those policies and procedures that

1. pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the Company;

2. provide reasonable assurance that transactions are recorded as necessary to permit preparation of Standalone 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 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, material misstatements due to error or fraud may occur and not be detected. Also, projections of any evaluation of the internal financial controls over financial reporting to future periods are subject to the risk that the internal financial control over financial reporting may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

Opinion

In our opinion, the Company has, in all material respects, an adequate internal financial controls system over financial reporting and such internal financial controls over financial reporting were operating effectively as at 31st March, 2026, 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 Audit of Internal Financial Controls Over Financial Reporting issued by the Institute of Chartered Accountants of India.

	For Dhirubhai Shah & Co LLP
	Chartered Accountants
	FRN: 102511W/W100298
	Parth S. Dadawala
	Partner
Place: Ahmedabad	M. No. 134475
Date: 14 May, 2026	UDIN: 26134475HGHUFC7642