Impex Ferro Tech Ltd Auditors Report.

To

THE MEMBERS OF IMPEX FERRO TECH LIMITED

Report on the Financial Statements Qualified Opinion

We have audited the accompanying Financial Statements of IMPEX FERRO TECH LIMITED ("the Company"), which comprise the Balance Sheet as at March 31, 2019, 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 significant accounting policies and other explanatory information (hereinafter referred to as "the Financial Statements").

In our opinion and to the best of our information and according to the explanations given to us, except for the possible effect of the matter described in the basis for qualified opinion section of our report, the aforesaid 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 accepted in India, of the state of affairs of the Company as at 31st March, 2019, the loss and total comprehensive loss, changes in equity and its cash flows for the year ended on that date. Basis for Qualified Opinion

We draw your attention to Note No. 12(iii) of the accompanying Financial Statements regarding non provision of interest expense on the borrowings of the Company amounting to Rs 3,685.53 lakhs for the year ended 31st March, 2019 (Cumulative Non Provisioning of Rs 10,125.11 lakhs till 31.03.2019) and penal interest and charges thereof (amount remaining unascertained) which is not in accordance with the requirements of Ind AS 23: Borrowing Costs read with Ind AS 109: Financial Instruments. Had the aforesaid interest expense been recognized, the finance cost for the year ended 31st March, 2019 would have been Rs 3,804.23 lakhs instead of reported amount of Rs 118.70 lakhs. The total expenses for the year ended 31st March, 2019 would have been Rs 15,370.01 lakhs instead of Rs 11,684.48 lakhs. The Net Loss after tax for the year ended 31st March, 2019 would have been Rs 5,360.16 lakhs instead of reported amount of Rs 1,674.63 lakhs. Total comprehensive Loss for the year ended 31st March, 2019 would have been Rs 5,318.13 lakhs instead of reported amount of Rs 1,632.60 lakhs. Other equity as on 31st March, 2019 would have been Rs 38,301.19 Lakhs instead of reported amount of Rs 28,176.08 Lakhs and Other Current Financial Liability as on 31st March, 2019 would have been Rs 18,466.15 Lakhs instead of reported amount of Rs 8,341.04 Lakhs.

We conducted our audit of the Financial Statements in accordance with the Standards on Auditing (SAs) specified under section 143(10) of the Companies Act, 2013. Our responsibilities under those Standards are further described in the Auditors Responsibilities for the Audit of the Financial Statements section of our report. We are independent of the Company in accordance with the Code of Ethics issued by the Institute of Chartered Accountants of India together with the ethical requirements that are relevant to our audit of the financial statements under the provisions of the Companies Act, 2013 and the Rules there under, and we have fulfilled our other ethical responsibilities in accordance with these requirements. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our qualified opinion.

Material Uncertainty Relating To Going Concern

We draw your attention to Note No. 34 of the financial statements regarding preparation of the financial statements on going concern basis, for the reason mentioned therein. The company has accumulated losses during year ended 31.03.2019. As on date the companys current liabilities are substantially higher than its current assets and net worth has also been fully eroded. These conditions indicate the existence of a material uncertainty that may cast significant doubt on the companys ability to continue as going concern. The appropriateness of assumption of going concern is critically dependent upon the debt resolution of the company which is under process, the companys ability to raise requisite finance, generation of cash flows in future to meet its obligation and to earn profit in future.

Key audit matters

Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the financial statements of the current period. These matters were addressed in the context of our audit of the financial statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters. We have determined the matters described below to be the key audit matters to be communicated in our report.

Key Audit Matter How our audit addressed the key Audit Matter
1 Accuracy of recognition, measurement, presentation and disclosures of revenues and other related balances in view of adoption of Ind AS 115 "Revenue from Contracts with Customers" (new revenue accounting (standard) w.e.f 01.04..2018 Our audit procedures included the following:
The application of the new revenue accounting standard involves certain key judgements relating to identification of distinct performance obligations, determination of transaction price of the identified performance obligations, the appropriateness of the basis used to measure revenue recognized over a period. We have assessed the Companys process to identify the impact of adoption of the new revenue accounting standard. Our audit approach consisted testing of the design and operating effectiveness of the internal controls and substantive testing as follows :
Additionally, new revenue accounting standard contains disclosures which involves collation of information in • Evaluated the design of internal controls relating to recording of efforts incurred and estimation of efforts required to complete the performance obligations.
respect of disaggregated revenue and periods over which the remaining performance obligations will be satisfied subsequent to the balance sheet date. • Selected a sample of contracts and through inspection of evidence of performance of these controls, tested the operating effectiveness of the internal controls relating to efforts incurred and estimated.
Claim and exposure relating to taxation and litigation Our audit procedures included the following:
The Company has material uncertain tax positions including matters in respect of disputed claims /levies under various taxes and legal matters. Our audit procedures include the following substantive procedures:
• Obtained understanding of key uncertain tax positions;
The taxes and litigation exposures have been identified as key audit matter due to: • We have reviewed and analysed key correspondences relating to dispute;
i. Litigation cases require significant judgement due to complexity of the case and involvement of various authorities. • We have discussed the matter for key uncertain tax positions with appropriate senior management;
ii. These involve significant management judgment to determine the possible outcome of the uncertain tax positions. • We have evaluated managements underlying key assumptions in estimating the tax provisions; and Assessed managements estimate of the possible outcome of the disputed cases;

Emphasis of Matter

(i) As referred to Note No. 28 of the Financial Statements, no provision has been made in the books in respect of the fire occurred in the Captive Power Plant. The reported financials might have consequential impact which remains unascertained and unprovided for.

(ii) As referred in Note No. 29 of the Financial Statements, the balance of Sundry Debtors, Advances, Creditors etc. includes balances remaining outstanding for a substantial period. The balances are subject to confirmations and reconciliation. The reported Financials might have consequential impact which remains unascertained.

Our report is not modified in these matters.

Information other than the Financial Statements and Auditors Report Thereon

The Companys Board of Directors is responsible for other information. The other information comprises the information included in the Companys Annual Return but does not include the Financial Statements and our Auditors report thereon.

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

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

If, based on the work we have performed, we conclude that there is a material misstatement of this other information; we are required to report that fact. We have nothing to report in this regard.

Responsibility of the Management for the Financial Statements

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

In preparing the financial statements, management is responsible for assessing the Companys ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless management either intends to liquidate the Company or to cease operations, or has no realistic alternative but to do so.

The Board of Directors is also responsible for overseeing the Companys financial reporting process.

Auditors Responsibilities for the Audit of the Financial Statements

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

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

• Identify and assess the risks of the material misstatement of the financial statement, whether due to fraud or error, design and perform audit procedures responsive to those risks, and obtain audit evidence that is sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control.

• Obtain an understanding of internal financial controls relevant to the audit in order to design audit procedures that are appropriate in the circumstances. Under section 143(3)(i) of the 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 the management.

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

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

Materiality is the magnitude of misstatements in the standalone financial statements that, individually or in aggregate, makes it probable that the economic decisions of a reasonably knowledgeable user of the financial statements may be influenced. We consider quantitative materiality and qualitative factors in (i) planning the scope of our audit work and in evaluating the results of our work; and (ii) to evaluate the effect of any identified misstatements in the financial statements.

We communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit and significant audit findings, including any significant deficiencies in internal control that we identify during our audit. We also provide those charged with governance with a statement that we have complied with relevant ethical requirements regarding independence, and to communicate with them all relationships and other matters that may reasonably be thought to bear on our independence, and where applicable, related safeguards.

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

Report on Other Legal and Regulatory Requirements

I. As required by the Companies (Auditors Report) Order, 2016 ("the Order"), issued by the Central Government Of India in terms of sub-section(ll) 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.

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

a) Except for the possible effect of the matter described in the basis for qualified opinion section of our report, 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.

b) Except for the possible effect of the matter described in the basis for qualified opinion section of our report, in our opinion, proper books of account as required by law have been kept by the Company so far as it appears from our examination of those books.

c) The Balance Sheet, the Statement of Profit and Loss including other comprehensive income, the cash flow statement and the statement of changes in equity dealt with by this Report are in agreement with the books of accounts.

d) Except for the possible effect of the matter described in the basis for qualified opinion section of our report, in our opinion, the aforesaid financial statements comply with the Accounting Standards specified under Section 133 of the Act, read with Rule 7 of the Companies (Accounts) Rules, 2014.

e) The matter described in the basis for qualified opinion section of our report, may have adverse effect on the functioning of the company.

f) On the basis of the written representations received from the directors as on 31st March, 2019 taken on record by the Board of Directors, none of the directors is disqualified as on 31st March, 2019 from being appointed as a director in terms of Section 164 (2) of the Act.

g) With respect to the adequacy of the internal financial controls over financial reporting of the Company and the operating effectiveness of such controls, refer to our separate Report in "Annexure B".

h) 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 :

In our opinion and to the best of our information and according to the explanations given to us, the remuneration paid by the

Company to its directors during the year is in accordance with the provisions of section 197 of the Act.

i) 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:

a) The Company has disclosed the impact of pending litigations on the financial position in the Financial Statements. Refer Note 27 to its financial statements.

b) The Company did not have any long term contracts including derivative contracts for which there were any material foreseeable losses;

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

For R. Kothari & Company
Chartered Accountants
Firm Reg. No.:-307069E
CA. Manoj Kumar Sethia
Place: Kolkata Partner
Date: 27th May, 2019 Membership No.:- 064308

"Annexure A" to Independent Auditors Report

The Annexure A referred to in paragraph I under the heading Report on Other Legal & Regulatory Requirements of our report of even date to the financial statements of the Company for the year ended 31st March, 2019, we report that:

(i) (a) The Company is maintaining proper records showing full particulars, including quantitative details and situation, of property, plant and equipment.

(b) The Property, plant and equipment of the Company have been physically verified by the management during the year and no material discrepancies were noticed on such verification. In our opinion, the periodicity of physical verification is reasonable having regard to the size of the company and nature of its assets.

(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 are held in the name of the Company.

(ii) The inventory has been physically verified by the management during the year at reasonable intervals. In our opinion the frequency of such verification is reasonable. The discrepancies noticed on verification between the physical stocks and the book records were not material having regard to the size of the operation of the Company and the same have been properly dealt with in the books of account.

(iii) The company has not granted any loans, secured or unsecured, to companies, firms, or other parties covered in the register maintained under section 189 of the Companies Act 2013. Therefore the reporting under Paragraph 3(iii) is not applicable to the company.

(iv) In our opinion and according to the information and explanation given to us, the Company has complied with the provisions of section 185 and 186 of the Companies Act, 2013 in respect of grant of loans, making investments and providing guarantees and securities, as applicable.

(v) The Company has not accepted any deposits from the public and consequently, the directives issued by Reserve Bank of India and provisions of Section 73 to Section 76 or any other relevant provisions of the Companies Act 2013 and the Companies (Acceptance of Deposit) Rules, 2015 with regard to the deposits accepted from the public are not applicable to the company.

(vi) We have broadly reviewed the books of account maintained by the Company in respect of manufacture of Iron & steel product & Power Generation unit pursuant to the Rules made by the Central Government for the maintenance of cost records under Section 148(1) of the Companies Act, 2013, and we are of the opinion that prima facie, the records have been maintained. We have however not made a detailed examination of the records with a view to determining whether they are accurate and complete.

(vii) (a) According to the information and explanation given to us and on the basis of our examination of the books of account, the Company has generally delayed in depositing undisputed statutory dues including Provident Fund, Income tax, sales tax, Service Tax, Duty of customs, value added tax, GST, cess and other statutory dues during the year with appropriate authorities.

According to the information and explanation given to us, no undisputed amounts payable in respect of the above were in arrears as at 31st March, 2019 for a period of more than six months from the date on when they become payable except the following :

Sl. No. Nature of Dues Amount (Rs in lakhs)
1 Service Tax 148.39
2 P.F.Payable 4.67
3 IGST Payable 1.71
4 CGST Payable 4.38
5 SGST Payable 38.52
Total 197.67

(b) According to the information and explanations given to us and records of the company examined, there were no dues in respect of provident fund, employees state insurance, income taxes, sales taxes/ value added taxes, service taxes, duty of customs, excise duties, GST, cess etc. which have not been deposited with the appropriate authorities on account of any dispute except the followings:

Name of the Statute

Nature of Dues

Financial Year

Amount (Rs in lakhs)

Forum where dispute is pending
Central Exise Act 1994

Excise Duty

2005-06

12.36

Commissioner of Central Excise (Appeals) (III)
2007-08

15.55

Cestat, Kolkata Branch

2013-14

6.05 Excise, Asansol Division

2013-14

7.96 Excise, Asansol Division
Sub- Total (a) 41.92
Central Sales

2005-06

304.13 Sr.Joint Commissioner of Commercial Taxes,
Tax and Local

2006-07

479.91 Sr.Joint Commissioner of Commercial Taxes,
Sales Tax

2008-09

748.45 Sr.Joint Commissioner of Commercial Taxes,
Vat & Cst

2009-10

211.16 Sr.Joint Commissioner of Commercial Taxes,

2014-15

83.64 Sr.Joint Commissioner of Commercial Taxes,

2015-16

38.41 Sr.Joint Commissioner of Commercial Taxes,
Sub- Total (b) 1865.7
W. B. Entry Tax Act Entry Tax

2012-13 & 2013-14

504.91 Honble high court of Calcutta
Sub- Total (c) 504.91
Income Tax Act

2009-10

4306.41 Commissioner of Income Tax (Appeals),Kolkata
1961 Income Tax

2011-12

1606.46 Commissioner of Income Tax (Appeals),Kolkata

2014-15

3134.64 Commissioner of Income Tax (Appeals),Kolkata
Sub- Total (d) 9047.51
Total(a+b+c+d) 11460.04

(viii) Based upon the audit procedures performed and according to the records of the Company examined by us and the information and explanation given to us, the Company has defaulted in payment of interest and repayment of principal on borrowings to banks as follows:

Amount of default of Principal portion as on the Balance Sheet Date

(Rs Lacs)
Name of Bank Funded Interest Term Loan Restructured Term Loan Working Capital Term Loan Total Period of Default
State Bank of India 626.93 300.39 2,251.60 3,178.92 February, 2016 to March, 2019
Bank of Baroda 153.40 48.45 594.10 795.95 February, 2016 to March, 2019
Punjab National Bank 121.23 100.32 360.43 581.98 January, 2016 to March, 2019
United Bank of India 180.05 - 799.50 979.55 April, 2016 to March, 2019
Grand Total 1,081.61 449.16 4,005.63 5,536.40

Amount of default of Interest portion as on the Balance Sheet Date :

Name of Bank Funded Interest Term Loan Restructured Term Loan Working Capital Term Loan Total Period of Default
State Bank of India 643.08 607.89 2,565.99 3,816.96 February, 2016 to March, 2019
Bank of Baroda 98.74 106.16 720.32 925.22 February, 2016 to March, 2019
Punjab National Bank 99.13 226.84 450.94 776.91 January, 2016 to March, 2019
United Bank of India 220.68 - 866.71 1,087.39 April, 2016 to March, 2019
Grand Total 1,061.63 940.89 4,603.96 6,606.48

Since the SBT has been merged with SBI , SBTs Bank interest default has been merged with SBI.

Amount of Default of Interest portion of Cash Credit Accounts as on Balance Sheet Date:

Particulars Funded Interest Term Loan Period of Default
State Bank of India 2320.76 February, 2016 to March, 2019
Bank of Baroda 614.78 February, 2016 to March, 2019
Punjab National Bank 427.89 January, 2016 to March, 2019
United Bank of India 356.39 April, 2016 to March, 2019
Total 3719.82

The unprovided interest liability amounting to Rs 10,125.11 lakhs as referred in Note No. 12(iii) of the Financial Statements continued to be a default. The company does not have any loans or borrowings from the government and has not issued any Debentures.

(ix) Based upon the audit procedures performed and the information and explanations given by the management, the company has not raised moneys by way of initial public issue/ follow-on offer (including debt instruments) and term loans.

(x) Based upon the audit procedures performed and the information and explanations given by the management, we report that no fraud by the Company or on the company by its officers or employees has been noticed or reported during the year.

(xi) Based upon the audit procedures performed and the information and explanations given by the management, the managerial remuneration has been paid or provided in accordance with the requisite approvals mandated by the provisions of section 197 read with Schedule V to the Companies Act, 2013.

(xii) In our opinion and according to the information and explanations given to us, the Company is not a Nidhi Company. Therefore, the reporting under Paragraph 3 (xii) of the Order is not applicable to the Company.

(xiii) In our opinion and according to the information and explanations given to us, all transactions with the related parties are in compliance with Section 177 and 188 of Companies Act, 2013 where applicable and the details have been disclosed in the Financial Statements as required by the applicable Accounting Standards.

(xiv) According to the information and explanation 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 of fully or partly convertible debentures and hence reporting under paragraph 3(xiv) of the Order is not applicable to the Company.

(xv) Based upon the audit procedures performed and the information and explanations given by the management, the company has not entered into any non-cash transactions with directors or persons connected with them. Accordingly, the reporting under Paragraph 3 (xv) of the Order is not applicable to the Company and hence not commented upon.

(xvi) In our opinion, the company is not required to be registered under section 45 IA of the Reserve Bank of India Act, 1934.

For R. Kothari & Company
Chartered Accountants
Firm Reg. No.:-307069E
CA. Manoj Kumar Sethia
Place: Kolkata Partner
Date: 27th May, 2019 Membership No.:- 064308

"Annexure B" to Independent Auditors Report

Report on the Internal Financial Controls Over Financial Reporting under Clause (i) of Sub-section 3 of Section 143 of the Companies Act, 2013 ("the Act")

We have audited the internal financial controls over financial reporting of IMPEX FERRO TECH LIMITED ("the Company") as of 31st March, 2019 in conjunction with our audit of the 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 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 (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 Companies Act, 2013.

Auditors Responsibility

Our responsibility is to express an opinion on the Companys internal financial controls over financial reporting 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 Institute of Chartered Accountants of India and the Standards on Auditing issued by ICAI and prescribed under section 143(10) of the Companies Act, 2013, to the extent applicable to an audit of internal financial controls, both applicable to an audit of Internal Financial Controls and, both issued by the Institute of Chartered Accountants of India. 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 over financial reporting 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 system over financial reporting and their operating effectiveness. Our audit of internal financial controls over financial reporting included obtaining an understanding of internal financial controls over financial reporting, 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 judgment, including the assessment of the risks of material misstatement of the 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 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 financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the company are being made only in accordance with authorizations of management and directors of the company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized 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 31 March 2019, 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 R. Kothari & Company
Chartered Accountants
Firm Reg. No.:-307069E
CA. Manoj Kumar Sethia
Place: Kolkata Partner
Date: 27th May, 2019 Membership No.:- 064308