Impex Ferro Tech Ltd Auditor Reports

The Members of

IMPEX FERRO TECH LIMITED

(A Company under Corporate Insolvency Resolution Process vide NCLT order) Report on the Audit of 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 31st March ,2025, and the Statement of Profit and Loss, the Statement of Changes in Equity and Statement of Cash Flows for the year ended together with notes to the financial statements, including a summary of significant accounting policies and other explanatory information.

The Honble National Company Law Tribunal ("NCLT"), Kolkata Bench, admitted the Corporate Insolvency Resolution Process ("CIRP") application filed by a Financial Creditor of Impex Ferro Tech Limited (the Company) and appointed Mr. Rajiv Kumar Agarwala as Interim Resolution Professional (RP), in terms of the Insolvency and Bankruptcy Code, 2016 (The code) vide order dated 2nd May, 2024.Subsequently Mr. Ashok Kumar Sarawagi was appointed as Resolution Professional (RP) by the Committee of Creditors (CoC) its 2nd CoC meeting held on 14th June,2024 as approved by virtue of e- voting by the CoC members and further vide order dated 12 July, 2024 by the Honble court of NCLT, Kolkata. In view of pendency of CIRP, the management of the affairs of the company and power of the Board of Directors are now vested with RP. These financial results have been prepared by the management of the company and approved by RP.

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 generally accepted in India, of the state of affairs of the Company as at 31 March 2025, the loss and total comprehensive loss, changes in equity and its cash flows for the year ended on that date.

Basis for Qualified Opinion

i. We draw your attention to Note 37 of the accompanying Financial Results regarding non provision of Cumulative interest expense of Rs. 63,020.22 on the borrowings of the company which is not in accordance with the requirements of ₍₁, Ind As 109: Financial Instruments. Had the aforesaid Cumulative interest expense been recognized, Other Equity as on 31.03.25 would have been Rs. (103334.21 Lakhs) instead of reported amount of Rs. (40313.99 lakhs) and current financial liability as on 31st March,2025 would have been Rs. 63076.15 lakhs instead of reported amount of Rs. 55.93 lakhs.

The aforesaid Cumulative interest amount had been admitted by RP in the submitted list of claims dated 08.04.2025, for the CIRP initiated on 02.05.2024, however no bifurcation is available for 30.04.2024, hence finance cost taken as nil, and recorded amount in books is 0.79 lakhs.

ii. With reference to Note 43 Other Expenses includes provisioning of expected credit loss (ECL) of Rs. 313.60 lakhs on Trade Receivable & Rs. 393.53 lakhs on Advance to parties as considered prudent by the management, in view of nonrealisation for long time, to change the ECL policy of the company which has resulted in excess provision. In the absence of other corroborative evidence, we are unable to comment on carrying amount of such receivable on which ECL has been provided for the FY 23-24.

iii. As referred in Note 45 of the Financial Statements, "Trade Receivables", "Trade payables", Advances from Customer", Advances Recoverable in Cash or Kind and " Advance to Suppliers and Other Parties" etc includes balances remaining outstanding for a substantial period. The balances are subject to confirmation/reconciliation. In the absence of above and other corroborative evidence, we unable to comment on the extent to which such balances are recoverable. The reported Financials might have consequential impact which remains unascertained.

Refer Note 37, for list of claims for liabilities (including statutory dues) which were admitted by RP (dated 08.04.2025).

iv. As referred in Note 38 of the Financial Statements, as a part of CIRP, creditors were called upon to submit their claims. In aggregate the claim submitted by the financial creditors as well as operational creditors exceeded the amount as appearing in the books of account/financials.

List of creditors (published on 08.04.2025), Includes admitted claims and also claims under verification and reconciliation by RP with amount as appearing in books. No accounting impact in the books of account has been made in respect of excess, shortage, non-receipt of claims from operational and financial creditors. Hence, consequential impact if any on the reported Financial Statements is currently not considered.

However, the CIRP is going on and the Resolution Plan has already been submitted and one of the Resolution Applicants has been declared as HI bidder.

v. We have been informed that certain information including minutes of CoC meeting and the outcome of certain procedures earned out as part of CIRP process are confidential in nature and could not be shared with anyone other than

N Committee of Creditors and NCLT. Accordingly, we are unable to comment on , / ? y the possible financial impact, presentation and disclosures, if any on aforesaid information not provided to us.

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 attention to the Note 35 to the financial statements regarding preparation of the financial statements on going concern basis which states that the company has incurred cash losses, its liabilities exceeded its total assets and its net worth has been fully eroded as on 31.03.2025. Since, the CIRP is currently under process as per the IBC Code, it is required that the company be managed as going concern during the CIRP. The financial statements is continued to be prepared on going concern basis. However there exists material uncertainly about the companys ability to continue as a going concern since the same is dependent upon the resolution plan to be formulated and approved by NCLT. The appropriateness of preparation of the financial statements on going concern basis is critically dependent upon CIRP as specified in the IBC Code.

Key Audit Matters

Key audit matters are those matters that in our professional judgement were of most significance in our audit of the financial statement of the current period. These matters were addressed in the context of our audit of financial statements as a whole, and informing 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.

"ARADHANA", P-2, New C. I. T Road, Unit# 210, Kolkata-700073, 0:40050480, M:9831054180, E: info@vktulsyan.com, web: www.vktulsvan.com

Key Audit Matter	How our audit addressed the key audit matter
Claims and exposures relating to taxation and litigation	Our audit procedure included the following:
1. 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

We draw attention to Note 52 of the accompanying financial statements, which describes the following matters relating to the Companys bank balances and fixed deposits:

i) A Fixed Deposit of ?10 lakhs, the status and detailed documentation of which are under verification, and the amount has been temporarily classified under advances from others.

ii) Two fixed deposits provided as bank guarantees in favour of the West Bengal Pollution Control Board, with the guarantee validity having expired on 19.6.24.

We draw attention to Note 53 of the accompanying financial statements, which describes the following matters relating to the Companys Axis Bank account marked under lien:

An amount of ?50 lakhs in the Companys Axis Bank account marked under lien, following a NCRP complaint lodged with the Law-and-Order Police Station, Telangana, which remains frozen and is not available for use.

We draw attention to Note 36 of the accompanying financial statements, which describes the following matters relating to the attachment of the Property by Enforcement Directorate:

The assets of the corporate debtors had been attached by Enforcement Directorate vide Provisional Attachment order no 07/2021 dated 31/03/2021 under sub-section 1 of Section 5 of the Prevention of Money Laundering Act, 2002 to the extent to the value of Rs.660.45 lakhs.

The said Provisional Attachment order got confirmed by Ld. Adjudicating Authority vide order dated 09.11.2021. An appeal was filed by the corporate debtor against the said order before Appellate Tribunal of PMLAon 23.12.2021 vide FPA-PMLA- 4373/KOL/2021. The said appeal was dismissed on 03/10/23 for non-appearance.

We draw attention to Note 51 of the accompanying financial statements, which describes that surplus inventory, not previously recorded in the books of accounts, was identified and sold during the current financial year.

As informed to us, the identification of this inventoxy was caiTied out during the year, and the related sale proceeds have been accounted for accordingly.

As stated in Note 29 of the accompanying financial statements, no actuarial valuation for gratuity has been carried out during the financial year ended 31st March 2025. Consequently, the gratuity-related disclosures and the amounts reported in the financial statements are based on the figures from the previous year.

In the absence of an updated actuarial valuation, we are unable to determine the potential impact, if any, on the Companys employee benefit obligations, expenses, and related disclosures for the current year. Accordingly, the current years financial statements are impacted to that extent.

We draw attention to Note No. 40 of the financial statements, which describes the ongoing proceedings initiated by the Directorate of Enforcement (ED) under the Prevention of Money Laundering Act, 2002 (PMLA), involving provisional attachment of immovable properties of the Company valued at ?6.60 Crores. The proceedings pertain to allegations of the propeity being value equivalent proceeds of crime, arising from transactions with SPS Steel Rolling Mills Ltd. The management has contested the attachment and the matter is currently sub judice before the competent authorities.

We draw attention to Note 54 of the accompanying financial statements, which describes the outcome of the Transaction Audit conducted puisuant to the ongoing Corporate Insolvency Resolution Process (CIRP) initiated against the Company under the Insolvency and Bankruptcy Code, 2016.

The Transaction Audit covered the period from 1st April 2022 to 2nd May 2024, and while no transactions were classified as Preferential, Undervalued, Extortionate, or Fraudulent under Sections 43, 45, 50, and 66 of the IBC, certain irregularities were noted outside the scope of the IBC provisions. These include:

Unpaid capital and repair expenditure with concerns over vendors credentials. Subcontracting arrangements and service income involving entities with suspended GST registrations.

Income Tax proceedings related to unexplained credits and alleged dealings with shell entities amounting to ?485 crores, contested by the Company.

Our opinion is not modified in respect of this matter.

Information other than the financial statements and Auditors report thereon

The Companys management and Board of Directors/RP are responsible for the other information. The other information comprises the information included in the Managements/ Directors report, Management Discussion & Analysis etc., but does not include the financial statements and our auditors report thereon. Such other Information are expected to be made available to us after the date of this auditors report. Our opinion on the financial statements does not cover the other information and we will not express any form of assurance conclusion thereon.

In connection with our audit of the financial statements, our responsibility is to read the other information identified above when it becomes available and, in doing so, consider whether the other information is materially inconsistent with the financial statements or our knowledge obtained in the 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 & Resolution Professional 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 lias no realistic alternative but to do so.

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

As the Corporate Insolvency Resolution Process has been initiated in respect of the company under by the Resolution Professional appointed by the NCLT by the said order under the provisions the provision of the Insolvency and Bankruptcy Code, 2016 (The Code) by the National Company Law Tribunal (NCLT) Kolkata Bench, vide its order dated 2nd May, 2024, the powers of the Board of Directors stand suspended as per section 17 of the Code and such power is being exercise of the Code

This statement which is the responsibility of the companys management and has been signed by and taken on record by the Resolution Professional.

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 material misstatement of the financial statements, whether due to fraud or error, design and perform audit procedures responsive to those risks, and obtain audit evidence that is sufficient and appropriate to provide a basis for our opinion. The risk of detecting a material misstatement resulting from fraud is higher than one resulting from error, fraud may involve collusion, forgery, Intentional omissions, misrepresentation, or the override of internal control.

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

vV Chartered Accountants

"ARADHANA", P-2, New C. I. T Road, Unit# 210, Kolkata-700073, 0:40050480, M:9831054180, E: info@vktulsyan.com, web: www.vktulsvan.com

• 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 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 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 effects 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 financial statement of the current period and therefore the key audit matters. We describe these matters in our auditor report unless law or regulation precludes public disclosure about the matters on when, in extremely rare circumstances, we determine that a matter should not be communicated in our report because the adverse consequence 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, 2020 (" the Order") 1 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.

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 losses, 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) Based on the written representations received from the directors as on 31st March, 2025 taken on record by the Board of Directors, none of the directors is disqualified as on 31st March, 2025 from being appointed as a director, However the power of board has been formally suspended due to commencement of the CIRP and all authority to manage the affairs of the company solely vested with RP.

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/ provided 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.

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

c) The company is not required to transfer any amount to Investor Education and Protection Fund pertaining to unpaid dividend.

d) i. The management has represented that, to the best of its knowledge and belief, other than as disclosed in the notes to the accounts, no funds 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 person(s) or entity(ies), including foreign entities ("Intermediaries"), with the understanding, whether recorded in writing or otherwise, that the Intermediary shall, whether, directly or indirectly, lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the Company ("Ultimate Beneficiaries") or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries.

ii. The management has represented, that, to the best of its knowledge and belief, as disclosed in the notes to the accounts, no funds have been received by the company from any person or entity, 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 Fundillg Party ("Ultimate Beneficiaries") or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries.

iii. Based on such audit procedures that we 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) contain any material misstatement.

e) The company has neither declared nor paid dividend during the year. Hence, compliance of provision of section 123 of the Companies Act 2013 does not arise. _;

f) Based on our examination which included test checks, the company has used an accounting software for maintaining its books of account which has a feature of recording audit trail (edit log) facility and the same has not been operated throughout the year for all relevant transactions recorded in the software.

Accordingly, audit trail has not been preserved by the company as per the statutory requirements for record retention for the financial year ended March 31,2025.

For V.K. TULSYAN & Co. LLP.

Chartered Accountants F.R. No.- 326740E/E300015

Place: Kolkata

Date: 23.07.2025

UDIN: 25061953BMOVDH2921

Vishnu Kumar Tulsyan Partner

M. No.-061953

"ANNEXURE A"TO THE INDEPENDENT AUDITORS REPORT

The Annexure A referred to in paragraph 1 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, 2025, we report that:

i) (a) (A) The Company has maintained proper records showing ftill particulars, including quantitative details and situation, of property, plant, and equipment.

(B) The Company has maintained proper records showing full particulars of intangible assets.

(b) The property, plant and equipment of the Company have been physically verified by the management at reasonable intervals and no material discrepancies were noticed on such verification.

(c) The title deeds of all the immovable properties (other than properties where the Company is the lessee and the lease agreements are duly executed in favour of the lessee), as disclosed in the financial statements are held in the name of the Company.

(d) The Company has not revalued any of its Properly, Plant and Equipment (including Right of Use assets) or intangible assets or both during the year.

Hence, reporting of other information under clause 3 (i) (d) of the said order is not required.

(e) Based on the information and explanations furnished to us, no proceedings have been initiated on or are pending against the Company for holding any benami property under the Benami Transactions (Prohibition) Act, 1988 and Rules made thereunder.

ii) (a) The company does not have any inventory during the year. Accordingly reporting

under clause 3(ii)(a) of the Order is not applicable.

(b) According to the information and explanation given to us, at any point of time of the year, the Company had been sanctioned working capital limit in excess of Rs. 5 crores in aggregate of Bank or financial institutions on the basis of security of current assets and the Company is not submitting periodical returns or statement to the respective Banks/ financial institutions for the reason disclosed in Note 37 of financial statement.

iii) In our opinion and according to the information and explanation given to us, the

Company during the year has not made investments in, provided any guarantee or

? security or granted any loans/ advances in nature of loans, secured or unsecured

ARADHANA", P-2, New C. 1. T. Road, Unit # 210, Kolkata-700073,0 :4005 0480, M : 9831054180, E : info(5)vktulsvan.com, Web www.vktulsvan.com

to companies, firms, limited liability partnerships or any other parties. Hence reporting of other information under clause 3 (iii)(a) to (f) of the said Order is not required.

iv) According to the information and explanations given to us and on the basis of our examination of the records of the Company, the Company has not given any loans, or provided any guarantee or security as specified under Section 185 and 186 of the Companies Act, 2013.

v) According to the information and explanations given to us and on the basis of our examination of the books of account, the company has not accepted any deposits from the public and there is no amounts which are deemed to be deposits and consequently, the directives issued by the Reserve Bank of India and provisions of Section 73 to 76 or any other relevant provisions to the Companies Act 2013 and rules made there under the Companies (Acceptance of Deposit) Rules, 2015] with regard to the deposits are not applicable to the company.

vi) Pursuant to the rules made by the Central Government of India, the provisions of maintenance of cost records under sub-section (1) of the Companies Act,2013 are not applicable to the company. Accordingly, reporting under clause 3(vi) of the Order is not applicable.

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 Tax deducted at source, Employees State Insurance (ESI), Professional Tax, Service Tax, GST, 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, 2025 for a period of more than six months from the date on when they become payable except the following:

SI. No.	Nature of Dues	Amount (Rs. in lakhs)
1	Service Tax Payable	105.42
2	GST Payable	123.62
3	TDS Payable	62.36
4	ESI Payable	1.45
5	Professional tax Payable	0.61
	Total	292.92

Interest, penalty if any on the above remain unascertained and not provided for in the financial statement for the year ended 31st March, 2025.

(b) According to the information and explanations given to us and records of the company examined, and the particulars or statutory dues referred to in sub clause (a) above as on 31st March, 2024 which have not been deposited on account of dispute are as follows,

Status	Nature of Dues	Period to which the amount relates	Amount involved (Rs. In lakhs)	Forum in which dispute is pending
Central Excise Act 1994	Excise Duty	2006-07	12.36	Commissioner of Central Excise (Appeals)
		2008-09	15.55	Cestat, Kolkata Branch
		2014-15	6.05	Excise, Asansal Division (show cause notice received and reply will be submitted)
		2014-15	7.96	Excise, Asansal Division (show cause notice received and reply will be submitted)
		2012-13tol6-17	1778.07	Write Petition filed and pending under Honble High Court of Calcutta
Total			1819.99	Duty Paid under protest 12,69 lacs
Income Tax Act 1961	Income Tax	2010-11	4306.41	Under Appeal pending with CIT Appeal 21, kolkata
		2012-13	7102.96	Pending under ITAT
		2014-15	18.95	Pending under ITAT
		2015-16	4696.98	Under Appeal pending with CIT Appeal 21, kolkata
		2016-17	1.77	Under Appeal pending with CIT Appeal 21, kolkata
		2017-18	3410.31	Under Appeal pending with CIT Appeal 21, kolkata
		2022-23	1622.03	Under Appeal pending with CIT Appeal 21, kolkata
Total			21159.41
Central Sales Tax & local Sales Tax	Sales Tax	2005-06	293.87	WBCT, Appellate and Revisional Board
		2006-07	479.91	WBCT, Appellate and Revisional Board
		2008-09	711.16	WBCT, Appellate and Revisional Board
		2009-10	211.18	Sr. Joint Commissioner of Commercial Taxes
Total			1696.12
WB Entry Tax Act	Entry Tax	2012-13 to 17-18	504.91	Honble High Court of Calcutta
Total			504.91

Additional to the above, the information and explanations given to us on 08.04.2025, regarding list of creditors, which have not been deposited on account of dispute and admitted by RP in the process of CIRP are as follows,

Name of the Statute	Nature of Dues	Amount involved (Rs. In lakhs)
Deputy Commissioner of Income Tax Central Circle- 3(2), Kolkata	Income Tax	21,372.62
Commissioner of commercial taxes Government of west Bengal	State Govt (West Bengal)	3,483.28
Employees State Insurance Corporation	Central Government	0.14
The GOI through the Assistant commissioner. Customs Division	Central Government	206.79
Income Tax Officer Ward- 2(1) TDS Kolkata Department of Income Tax ministry of revenue	Central Government	6.26

viii) According to the information and explanations given to us and based on our examination of the books of accounts and other records, there were no transactions unrecorded in the books of account and which were surrendered or disclosed as income in the tax assessments under the Income Tax Act, 1961 during the year.

ix) (a) With reference to Note 37 to the financial statements, various credit facilities availed from United Bank of India (UBI), Bank of Baroda (BOB) and State Bank of India (SBI) have been assigned in favour of Rare Asset Reconstruction Ltd (RARE).

K

The lenders (RARE) have submitted their claim and as admitted by RP amounting to Rs.91068.97 lacs which includes principal of Rs.28048.75 lacs and cumulative interest of Rs. 63020.22 lacs. The principal amount lying in the books is Rs.26124.99 lacs. The interest and penal interest as mentioned above remain in unprovided for in the books. The same may have consequential impact on the reported financial for the quarter and year ended 31st March, 2025 as well as earlier periods.

(b) According to the information and explanations given to us and based on our examination of the other records, the company has not been declared as a willful defaulter by any bank or financial institutions or other lender.

(c) According to the information and explanations given to us and based on our examination of the financial statements of the Company, we report that the company has not taken term loan during the year. Hence reporting of information under clause 3 (ix)(c) of the said Order is not applicable.

(d) As mentioned above, the company has not taken any loans or other borrowings from lenders during the year. Hence, reporting of information whether funds raised on short term basis have been utilized for long term purposes under clause 3 (ix)(d) of the said Order is not applicable.

(e) According to the information and explanations given to us and based on our examination of the other records, the company does not have any subsidiaries, associates or joint ventures. Hence reporting of information under clause 3 (ix)(e) & (f) of the said Order is not applicable.

x) (a) Based upon the audit procedures performed and the information and explanations given to us, the company has not raised any money by way of initial public offer or further public offer (including debt instruments) during the year. Hence., reporting of information under clause 3 (x) (a) of the said Order is not applicable.

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

xi) (a) According to the information and explanations given to us by the management, no fraud by the Company or on the company has been noticed or reported during the year.

(b) According to the information and explanations given by the management, no report under sub-section (12) of section 143 of the Companies Act has been filed in Form ADT- 4 as prescribed under rule 13 of Companies (Audit and Auditors) Rules, 2014 with the Central Government, during the year and upto the date of this report.

(c) According to provision of section 177(9) of the Companies Act 2013 read with Rule 7 of the Companies (Meetings of Board and its Powers) Rules, 2014 establishment of Vigil Mechanism or Whistle - Blower Policy under SEBI LODR Regulations is applicable to the

% company. As per information and explanation provided to us by the management, no

Whistle - Blower Complaints received by the company during the year.

xii) As the Company is not a Nidhi Company and the Nidhi Rules,2014 are not applicable to it, the reporting under Clause 3(xii)(a) to (c) of the Order is not applicable to the Company.

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

xiv) (a) In our opinion and according to the information and explanation given to us, the Company has an internal audit system commensurate with the size and nature of its business.

(b) The company has furnished us reports of the Internal Auditors for the period under audit which were considered by us in the course of Audit.

xv) Based upon the audit procedures performed and the information and explanations given by the management, the company has not entered in to any non-cash transactions with directors or persons connected with him. Accordingly, the reporting in respect of compliance of provisions of section 192 of the Companies Act 2013 is not required.

xvi) (a) Based upon the audit procedures performed and the information and explanations given by the management, the company is not required to be registered under section 45 IA of the Reserve Bank of India Act,1934.

(b) Based upon the audit procedures performed and the information and explanations given by the management, the company has not conducted any Non-Banking Financial or Flousing Finance Activities without a valid certificate of registration (CoR) from Reserve Bank of India.

(c) Based upon the audit procedures performed and the information and explanations given by the management, the company is not a Core Investment Company (CIC) as defined in the regulations made by the Reserve bank of India. Therefore, reporting under clause3 (xvi) (c) of the said Order is not applicable.

(d) Based upon the audit procedures performed and the information and explanations given by the management, the Group does not have any Core Investment Company (CIC) as part of Group. Therefore, reporting under clause 3 (xvi) (d) of the said Order is not applicable.

xvii) In our opinion and according to the information and explanations given to us, the Company has incurred cash losses during the financial year and in the immediately preceding financial year. Except for the possible effect of the matter described in the basis for qualified opinion section of our report the cash losses incurred by the company is as follows:

Particulars	2024-25	2023-24
Cash losses	(24.6)	(2331.41)

xviii) According to the information and explanations given to us and based on our examination of the records of the Company, the COC has requested statutory auditor to reduce the fees, as the operation of the Company are closed and the company has been admitted under CIRP. Accordingly, new statutory auditor has been appointed.

xix) According to the information and explanations given to us and on the basis of financial ratios, ageing and expected dates of realizations of financial assets and payment of the financial liabilities, other information accompanying the financial statements, management plans, admission & ongoing Corporate Insolvency Resolution Process ("CIRP") against the company and the Resolution Plan has already been submitted and one of the Resolution Applicants has been declared as HI bidder, and based on our examination of the evidence supporting the assumptions, which causes us to belief that there is material uncertainty exists as on the date of the audit report that company is not 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/inability of the company. We further state that our reporting is based on the facts upto the date of the audit report and we neither give any guarantee nor assurance that all liabilities falling due within a period of one year from the balance sheet date will get discharged/not discharged by the company as and when they fall due.

xx) The section 135 of the Companies Act 2013 is not applicable to the company. Accordingly, reporting under clause 3 (xx) (a) & (b) of the said Order is not applicable.

xxi) The Company is not required to prepare Consolidated Financial Statements. Accordingly, clause 3(xxi) of the Order is not applicable.

For V.K. TULSYAN & Co. LLP.

Chartered Accountants

F.R. No.- 326740E/E300015

Annual Report 2024-25 : 72

Place: Kolkata	Vishnu	Kumar Tulsyan
Date :23.07.2025		Partner
UDIN: 25061953BMOVDH2921	M.	No.- 061953

ANNEXURE B"TO THE 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 M/s. IMPEX FERRO-TECH LIMITED ("the Company") as of 31st March,2024 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 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 V.K. TULSYAN & Co. LLP.

Chartered Accountants

F.R. No.- 326740E/E300015

Place: Kolkata	Vishnu Kumar Tulsyan
Date :23.07.2025	Partner
UDIN: 25061953BMOVDH2921	M. No.- 061953