Gujarat Mineral Development Corporation Ltd Auditor Reports

To

The Members of

Gujarat Mineral Development Corporation Limited

Report on 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, 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 ended on that date and a summary of the 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 a airs of the Company as at 31st March, 2024 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 kind attention to Note 2.27.01 of the Standalone Financial Statements, whereby the company earned an interest of Rs. 4,974.52 Lakh on the xed deposit of Rs. 82,596.80 Lakh 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.

ii. We draw kind attention to Note 2.48 (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.

iii. We draw kind attention to Note 2.48 (b) and (c) of the Standalone Financial Statements whereby certain modi cations in accounting estimates and rephrasing in the existing accounting policies made during the year in case of Intangible Assets and Trade Receivables. As explained by the management, there is no material financial impact due to aforesaid modi cations and rephrasing.

iv. We draw kind attention to Note 2.45 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 Financial Statement for the FY 2023-24, financial impact of the same has been considered based on latest available records i.e. provisional financials 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.

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)	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 (As per SA-620 “Using the Work of an Auditors Expert”).
Cost of stripping is charged on technical evaluated average stripping ratio at each plot of mine after due adjustment for stripping activity.	Tested ‘Average stripping ratio by recalculating the Lignite to overburden.
Refer Note 1(r) of the Material Accounting Policies	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 (Refer Note No. 2.07.01, 2.07.02,2.19)	Our Audit procedure included the following:
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.	Identification 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.
3. Contingent liabilities relating to Income tax (as described in Note 2.37 of the Consolidated 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 procedures, we have assessed audit managements processes to identify new possible obligations and changes in existing obligations for compliance with the 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, 2024 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) (Refer Note No. 2.01A, 2.01B, 2.01C, 2.03)	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:
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 statement of financial position in the Standalone Financial Statements.	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.
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.	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.
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.	We assessed whether indicators of impairment existed as at 31st March, 2024 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 section 143(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 influenced. We consider quantitative materiality and qualitative factors in (i) planning the scope of our audit work and in evaluating the results of our work; and (ii) to evaluate the effect of any identified misstatements in the 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 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 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. GSR 463(E) dated 5th June, 2015 issued by Ministry of Corporate A airs, 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 05.06.2015 issued by the Ministry of Corporate A airs, Govt. 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 Statement - Refer Note 2.37 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 an instance of delay in transferring amounts, required to be transferred, to the Investor Education and Protection Fund by the Company during the year with respect to Unpaid Dividend for the year 2015-16 amounting to Rs. 20.38 Lakh.

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 Beneficiaries”) or - provide any guarantee, security or the like to or on behalf of the Ultimate Beneficiaries.

[b] The management has represented, that, to the best of its knowledge and belief, no funds (which are material either individually or in the aggregate) have been received by the 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 Beneficiaries”) or - provide any guarantee, security or the like from or on behalf of the Ultimate Beneficiaries; 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 applicable from 1st April, 2023.

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.

	For Dhirubhai Shah & Co LLP
	Chartered Accountants
	FRN: 102511W/W100298
	CA Parth S. Dadawala
	Partner
Place: Ahmedabad	M. No. 134475
Date: 27/05/2024	UDIN: 24134475BKANKT7559

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 programme of physical verification of its PPE by which PPE are veri ed 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 programme, PPE verification has been undertaken during the year ended 31st March, 2024 for all the assets except for assets pertaining to Akrimota Thermal Power Project, for which the verification exercise was conducted in FY 2022-23. 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 veri cation of inventory has been conducted at reasonable intervals by the Management.

(ii) The coverage and procedure of physical veri cation 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 veri cation 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 five crore rupees but the company has not availed the said limit during the year, in aggregate, from banks or financial institutions on the basis of security of current assets. 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, firms, 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 thereunder, where applicable. Thus, of paragraph 3(v) of the order is not applicable to the Company.

vi. In pursuant 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 Service 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 except for one instance of delay in deposit to Investor Education and Protection Fund (IEPF) 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 (Rs. in Lakh)	Forum where dispute is pending
Commercial Tax	Sales Tax/VAT	1993-94	21.78	Decided by Appellate Tribunal, effect giving order pending
Commercial Tax	Sales Tax/VAT	1995-96	98.92	Decided by Appellate Tribunal, effect giving order pending
Commercial Tax	Sales Tax/VAT	1997-98	2.45	Decided by Appellate Tribunal, effect giving order pending
Commercial Tax	Central Sales Tax	1997-98	4.26	Decided by Appellate Tribunal, effect giving order pending
Service Tax	Service Tax	Dec-15 to Aug-16	0.32	Appellate Tribunal
Service Tax	Service Tax	Oct-12 to Jun-17	621.08	Appellate Authority / Adjudicating Level
Service Tax	Service Tax	Feb-12 to Nov-15	41.32	Appellate Authority / Adjudicating Level
Service Tax	Service Tax	Dec-15 to Mar-16	302.90	Appellate Authority / Adjudicating Level
Service Tax	Service Tax	Apr-16 to Jun-17	165.56	Appellate Authority / Adjudicating Level
Income Tax Act,1961	Income Tax	A.Y. 1998-99	72.16	Honble Gujarat High Court
Income Tax Act,1961	Income Tax	A.Y. 2002-03	661.92	Honble Gujarat High Court
Income Tax Act,1961	Income Tax	A.Y. 2003-04	7.53	Honble Gujarat High Court
Income Tax Act,1961	Income Tax	A.Y. 2004-05	3.27	Honble Gujarat High Court
Income Tax Act,1961	Income Tax	A.Y. 2010-11	1151.46	Honble Gujarat High Court
Income Tax Act,1961	Income Tax	A.Y. 2012-13	189.71	ITAT
Income Tax Act,1961	Income Tax	A.Y. 2013-14	1457.06	Honble Gujarat High Court
Income Tax Act,1961	Income Tax	A.Y. 2015-16	1707.49	ITAT
Income Tax Act,1961	Income Tax	A.Y. 2018-19	1929.03	CIT(A)
Income Tax Act,1961	Income Tax	A.Y. 2020-21	4024.97	CIT(A)

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. The Company does not have any loans or borrowings from any financial institutions, banks, government or debenture holders during the year. Thus, the paragraph 3(ix) of the order is not applicable to the Company.

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 give 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 o 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
	CA Parth S. Dadawala
	Partner
Place: Ahmedabad	M. No. 134475
Date: 27/05/2024	UDIN: 24134475BKANKT7559

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 27th May, 2024, we have reported on the Directions and Sub-directions under section 143(5) of the Companies Act, 2013 applicable for the year 2023-24 as under:

PART - I

Directions under Section 143(5) of Companies Act 2013 Applicable for the year 2023-24

S. No. Directions/Questions u/s 143(5)	Action Taken by Gujarat Mineral Development Corporation Ltd.	Impact on Accounts and Financials
1 Whether the company has system in place to process all the accounting transactions through IT system? If yes, the implications of processing of accounting transactions outside IT system on the integrity of the accounts along with the financial implications, if any, may be stated.	Yes, the Company has Oracle-based composite ERP System covering all the departments of the company from where accounting transactions are processed. We have not come across any case, where accounting transactions are processed outside ERP. Therefore, there is no nancial implication on the integrity of the accounts.	No impact
2 Whether there is any restructuring of an existing loan or cases of waiver/write o of debts/loans/interest etc. made by a lender to the company due to the companys inability to repay the loan? If yes, the financial impact may be stated. Whether such cases are properly accounted for? (In case, lender is a Government Company, then this direction is also applicable for statutory auditor of lender Company).	The Company has no borrowing. Therefore, there is no restructuring of an existing loan or cases of waiver/ write o of debts/loans/interest etc., made by a lender to the company due to Companys inability to repay the loan.	No impact
3 Whether funds (grants/subsidy etc.) received /receivable for specific schemes from Central/State Government or its agencies were properly accounted for/utilised as per its term and conditions? List the cases of deviation.	Yes, funds (grants/subsidy etc.) received/ receivable for specific scheme from Central/ State Government or its agencies were properly accounted for/ utilized as per its terms and conditions.	No impact

 

	For Dhirubhai Shah & Co LLP
	Chartered Accountants
	FRN: 102511W/W100298
	CA Parth S. Dadawala
	Partner
Place: Ahmedabad	M. No. 134475
Date: 27/05/2024	UDIN: 24134475BKANKT7559

PART - II

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

S. No. Sub Directions Issued/Questions u/s 143(5)	Action Taken by Gujarat Mineral Development Corporation Ltd.	Impact on Accounts and Financials
Manufacturing Sector
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 impact
	No Major Displacement/Rehabilitation has been taken at any project of the company for the year 2023-24.
	(Please note that we are not technical expert)
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.	No 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.	No impact
	(Please note that we are not technical expert)
4 Whether the Company has disbanded and discontinued mines, if so, the payment of corresponding dead rent thereagainst may be veri ed.	As informed to us, the Company has discontinued its Panandhro mine due to exhaust of lignite. Dead rent of Rs. 68.76 lakh 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 books of account of the Company, as per the policy adopted on this behalf.	No impact

 

S. No. Sub Directions Issued/Questions u/s 143(5)	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.	No impact
	In respect of utilisation and disposal of ash, generally the Company is using it in back lling of mine in Panandhro project.
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.	No impact
	(Please note that we are not technical experts).
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

 

	For Dhirubhai Shah & Co LLP
	Chartered Accountants
	FRN: 102511W/W100298
	CA Parth S. Dadawala
	Partner
Place: Ahmedabad	M. No. 134475
Date: 27/05/2024	UDIN: 24134475BKANKT7559

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, 2024, 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 was 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, 2024, 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
	CA Parth S. Dadawala
	Partner
Place: Ahmedabad	M. No. 134475
Date: 27/05/2024	UDIN: 24134475BKANKT7559