Jai Balaji Industries Ltd Directors Report.

To The Members of

JAI BALAJI INDUSTRIES LIMITED

Report on the Audit of the Standalone Financial Statements Opinion We have audited the accompanying standalone financial statements of JAI BALAJI INDUSTRIES LIMITED ("the Company"), which comprise the balance sheet as at 31st March 2019, and the statement of Profit and Loss (including other comprehensive income) statement of cash flows and statement of changes in equity for the year then ended, and a summary of significant accounting policies and other explanatory information.

In our opinion and to the best of our information and according to the explanations given to us, "except for the effects of the matter described in the Basis for Qualified Opinion section" of our report, the aforesaid standalone financial statements give the information required by the Companies Act ,2013 ("the Act") in the manner so required and give a true and fair view in conformity with the Indian Accounting Standards prescribed under section 133 of the Act read with the Companies (Indian Accounting Standards) Rules 2015, as amended ("Ind AS") and other accounting principles generally accepted in India, of the state of affairs of the Company as at March 31, 2019, and its loss, total comprehensive income , its cash flows and the changes in equity for the year ended on that date.

Basis for Qualified Opinion

We conducted our audit of the standalone financial statements in accordance with the Standards on Auditing specified under section 143(10) of the Act (SAs). Our responsibilities under those Standards are further described in the Auditor’s Responsibility 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 ICAI’s Code of Ethics. We believe that the audit evidence obtained by us is sufficient and appropriate to provide a basis for our opinion on the standalone financial statements.

The Company has not provided for interest amounting to Rs. 125,381.29 Lacs of which Rs. 42,092.48 Lacs pertains to the current financial year on various loans and credit facilities availed from banks and financial institution on the ground that same is being treated as Non-Performing Assets by the lenders. Due to this reason, loss for the current financial year has been understated by Rs. 42,092.48 Lacs and accordingly loss for the year ended 31st March, 2019 would’ve been Rs. 57,460.19 Lacs instead of Rs.15,367.71 Lacs.

Key Audit Matters

Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the standalone financial statements of the current period. These matters were addressed in the context of our audit of the 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. THE KEY AUDIT MATTERS HOW THE MATTER WAS ADRESSED IN OUR AUDIT
1 LOAN CLASSIFIED AS Non Performing Assets (NPA), TRANSFERRED TO ASSET RECONSTRUCTIONCOMPANIES (ARC) OUR AUDIT PROCEDURES INCLUDE THE FOLLOWING:
(Refer Note 20 to the Standalone Financial Statements)
a) Rupee Loan from Banks and financial institutions had been classified as NPA and the lenders have served a call up notice for their exposure. Entire exposure of the lenders has fallen due on immediate demand basis. 1. We obtained the understanding of these asset reconstruction schemes through meetings with management and review of the minutes of the Board of Directors.
b) Axis Bank, UCO Bank, Allahabad Bank and Union Bank of India have already assigned their entire exposure to the Assets Reconstruction Companies in previous years. During the current financial year, the following banks have also assigned their entire exposure in favour of Assets Reconstruction Companies: 2. We reviewed the correspondence of the company with the relevant Asset reconstruction companies and we have examined the agreement made with them.
i. Bank of India has assigned its debts due by the Company in favour of Edelweiss Asset Reconstruction Company on 25th Jan,2019. The Company had made payments of Rs.1082 lacs to the said ARC upto the balance sheet date which has not been adjusted against theliability and is shown as advances to the ARC.
ii. United Bank of India and State Bank of India has assigned their debts due by the Company in favour of M/s Omkara Assets Reconstruction Private Limited on 29th Dec,2018 and 28th Mar,2019 respectively. An amount of Rs.140 lacs paid to the said ARC has been considered as an advance to the said ARC .same as above
iii. The WBIDFCL also assigned its debts due by the Company in favour of M/s Omkara Assets Reconstruction Private Limited on 25th April, 2019.
c) The Company is in active negotiation with Canara Bank, Corporation Bank, IDBI Bank, Indian Overseas Bank, Oriental Bank of Commerce, Punjab National Bank, The Federal Bank Limited and Vijaya Bank to restructure its debts. The finalisation of any corrective plan is still pending.
2 THE COMPANY’S EXPOSURE TO LITIGATION RISK OUR AUDIT PROCEDURES INCLUDE THE FOLLOWING:
(Refer Note 35A to the Standalone Financial Statements) 1. We obtained details of completed tax assessments and demands for the year ended March 31, 2019 from management.
The Company is exposed to different laws, regulations and interpretations thereof and hence, there is a litigation risk. 2. We examined the assumptions used in estimating the tax provision and the possible outcome of the disputes.
Consequently, the Company has significant litigation cases pending with Custom Authorities, Excise Authorities, Service tax Authorities and Income tax Authorities. 3. We considered legal precedence and other rulings in evaluating management’s position on these tax positions.
Given the nature and amounts involved in such cases and the appellate forums at which these are pending, the ultimate outcome and the resultant accounting in the financial statements is subject to significant judgement, which can change over time as new facts emerge and each legal case progresses, and therefore, we have identified this as key audit matter.

 

3 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" OUR AUDIT PROCEDURES INCLUDE THE FOLLOWING:
(Refer to Note 25 to the Standalone Financial Statements) 1. We assessed the procedures applied by management for the identification of the changes required in the financial statements due to application new IND AS 115
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. Additionally, new revenue accounting standard contains disclosures which involves collation of information in respect of disaggregated revenue and periods over which the remaining performance obligations will be satisfied subsequent to the balance sheet date. 2. We considered the adequacy and appropriateness of the additional disclosures and changes to the previous disclosures based on the new requirements.

Emphasis of Matter

1. We draw attention to Note - 36 of the financial statements, the Company has been incurring losses and its net worth has completely eroded, also its current liability exceeds current assets by Rs.1,77,311.44 Lacs. However, the financial statements of the Company have been prepared on a going concern basis because the management is confident that the improvement in market scenario will help in improving the financial health of the company and accordingly Deferred Tax Assets amounting to Rs.29,085.14 Lacs created up to 31st March 2015 have been carried forward.

2. We also draw attention to Note No.20 of the accompanying Standalone Financial Statements in respect of treatment in the books of accounts of the assignment / settlement of Debts of various Banks and the Financial Institutions.

3. We draw attention to Note No.58 to the financial statements in relation to outstanding balances of trade receivables, trade payables and loans and advances which are subject to confirmation and subsequent adjustments, if any.

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

The Company’s Board of Directors is responsible for the other information. The other information comprises Board’s Report, Report on Corporate Governance and Business Responsibility Report but does not include the consolidated financial statement, standalone financial statements and our auditor’s 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 standalone 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.

Management’s Responsibility for the Standalone Ind AS Financial Statements

The Company’s 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 Ind AS financial statements that give a true and fair view of the financial position, financial performance, including other comprehensive income ,cash flows and changes in equity of the Company in accordance with the 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 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 Company’s ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless management either intends to liquidate the Company or to cease operations, or has no realistic alternative but to do so.

The Board of Directors are also responsible for overseeing the Company’s financial reporting process.

Auditor’s Responsibility for the Audit of the Standalone Ind AS Financial Statements

Our objectives are to obtain reasonable assurance about whether the Ind AS financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with 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 judgement and maintain professional scepticism throughout the audit. We also:

• Identify and assess the risks of material misstatement of the Ind AS 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 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 management.

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

• Evaluate the overall presentation, structure and content of the Ind AS 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 Ind AS 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 standalone financial statements of the current period and are therefore the key audit matters. We describe these matters in our auditor’ 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 Section 143(3) of the Act, based on our audit, 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.

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

(c) The Balance Sheet, the Statement of Profit and Loss including Other Comprehensive Income, the Cash Flow Statement and Statement of Changes in Equity dealt with by this Report are in agreement with the books of account.

(d) In our opinion, the aforesaid Ind AS financial statements comply with the Indian Accounting Standards specified under Section 133 of the Act read with relevant rules issued thereunder.

(e) 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.

(f) 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 A". Our report expresses an unmodified opinion on the adequacy and operating effectiveness of the Company’s internal financial controls over financial reporting.

(g) With respect to the other matters to be included in the Auditor’s 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.

(h) With respect to the other matters to be included in the Auditor’s Report in accordance with Rule 11 of the Companies (Audit and Auditors) Rules, 2014, 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 financial statements – Refer Note 35A

ii. The Company did not have any long-term contracts including derivative contracts for which there were any material foreseeable losses.

iii. There has been no such sum which needs to be transferred to the Investor Education and Protection Fund by the Company.

2. As required by the Companies (Auditor’s Report) Order, 2016 ("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 "B" a statement on the matters specified in paragraphs 3 and 4 of the Order, to the extent applicable.

For, S. K. AGRAWAL & CO.
Chartered Accountants
Firm’s Registration No-306033E
(J. K. CHOUDHURY)
Place : Kolkata Partner
Dated : May 30, 2019 Membership No: 009367

ANNEXURE "A" TO THE INDEPENDENT AUDITOR’S REPORT

Report on the Internal Financial Controls Over Financial Reporting 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 JAI BALAJI INDUSTRIES LIMITED ("the Company") as of March 31, 2019 to the extent of records available with us in conjunction with our audit of the Ind AS financial statements of the Company for the year ended on that date.

Management’s Responsibility for Internal Financial Controls

The Board of Directors of the Company 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. 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, 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.

Auditor’s Responsibility

Our responsibility is to express an opinion on the internal financial controls over financial reporting of the Company 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 prescribed under Section 143(10) of the Companies Act, 2013, to the extent applicable to an audit of internal financial controls. 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 auditor’s judgement, 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 Company’s internal financial controls system over financial reporting.

Meaning of Internal Financial Controls over Financial Reporting

A Company’s 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 Company’s 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 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 company’s assets that could have a material effect on the financial statements.

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, to the best of our information and according to the explanations given to us, 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 March 31, 2019, based on the internal control over financial reporting criteria established by the Company.

For, S. K. AGRAWAL & CO.
Chartered Accountants
Firm’s Registration No-306033E
(J. K. CHOUDHURY)
Place : Kolkata Partner
Dated : May 30, 2019 Membership No: 009367

Annexure -B to the Independent Auditors’ Report

The Annexure referred to in our Independent Auditors Report to the members of JAI BALAJI INDUSTRIES LIMITED (‘the Company’) on the standalone financial statements for the year ended on 31st March 2019. We report that:

i. (a) The Company has maintained proper records showing full particulars, including quantitative details and situation of fixed assets

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

(c) According to information and explanation 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 inventories have been physically verified during the year by the management at regular intervals. In our opinion and according to the information and explanations given to us, no material discrepancies were noticed on physical verification.

iii. According to information and explanation given to us and on the basis of our examination of the records of the Company, the Company has granted unsecured loans to one company covered in the register maintained under section 189 of the Companies Act, 2013 (‘the Act’).

Accordingly, we report that: -

a) The terms and conditions of such loans are prima facie not prejudicial to the company’s interest.

b) The above loans are re-payable on demand

iv. In our opinion and according to the information and explanations given to us, the Company has complied with the provisions of sections 185 and 186 of the Companies Act, 2013 in respect of loans, investments, guarantees and securities made.

v. The Company has not accepted any deposits from the public. Accordingly, paragraph 3(v) of the Order is not applicable.

vi. We have broadly reviewed the books of account maintained by the Company pursuant to the rules prescribed by the Central Government for maintenance of cost records under section 148 (1) of the Act, and are of the opinion that prima facie the prescribed accounts and records have been made and maintained.

vii. According to the information and explanations given to us in respect of statutory dues:

(a) The Company has not been regular in depositing undisputed statutory dues, including Provident Fund, Employees State Insurance, Income Tax, Service Tax, Value Added Tax, duty of Excise, Cess and other statutory dues with the appropriate authorities during the year.

According to the information and explanations given to us, the following undisputed amounts payable in respect of the aforesaid dues were outstanding as at 31st March, 2019 for a period of more than six months from the date they became payable:

Name of statute Nature of Dues Amount Outstanding (Rs. in Lacs) Period to which amount relates
Income Tax Act, 1961 TDS 381.78 April’17 to September’18
Finance Act, 1994 Service Tax 95.95 December’16 to June’17
The Central Excise Act, 1944 Excise Duty 803.32 June’16 to May’17
Provident Fund Act, 1952 Provident Fund 784.27 May’16 to September’18
Finance Act, 1994 Swachh Bharat Cess 10.22 September’16 to June’17
Finance Act, 1994 Krishi Kalyan Cess 10.16 September’16 to June’17
Punjab Value Added Tax Act Value Added Tax 53.57 September’13 to February’14

(b) According to information and explanations given to us, the following dues of income tax, sales tax, duty of excise, duty of custom, service tax and value added tax have not been deposited by the Company on account of disputes:

Name of the statute Nature of dues Amount under dispute not yet deposited (Rs. in lacs) Financial year to which the amount relates Forum where dispute is pending
The Central Excise Act, 1944 Excise Duty 22,494.80 2007-08 to 2018-19 CESTAT, Commissioner (Appeals)
Finance Act, 1994 Service Tax 936.14 2010-11 to 2018-19 CESTAT, Commissioner (Appeals)
Custom Act, 1962 Custom Duty 917.36 2012-13, 2016-17 2017-18, 2018-19 CESTAT, Commissioner (Appeals)
The West Bengal Sales Tax Act, 1994 Sales Tax 3.59 2004-05 West Bengal Appellate & Revisional Board
The Central Sales Tax Act, 1956 Central Sales Tax 1018.13 2006-07 to 2016-17 West Bengal Appellate & Revisional Board
The West Bengal Value Added Tax Act, 2003 Value Added Tax 1667.58 2005-06 to 2014-15 West Bengal Appellate & Revisional Board
The Uttar Pradesh Value Added Tax Act, 2007 Value Added Tax 6.85 2005-06, 2016-17 West Bengal Appellate Revisional Board
The Income Tax Act, 1961 Income Tax 6.85 2008-09 DCIT/CIT(A)

viii. In our opinion and according to information and explanations given by the management, we are of the opinion that the Company has defaulted in the repayment of dues to banks and financial institution during the year as given below: -

Rs. in lacs

Banks Default of Amount (Principal and Interest)
Canara Bank 3,332.30
Corporation Bank 2,152.78
Federal Bank 403.21
IDBI Bank 1,056.94
Indian Overseas Bank 18,950.01
Oriental Bank of Commerce 26459.60
Punjab National Bank 2,826.42
VIJAYA Bank 8,154.96
Grand Total 54,453.28

 

Financial Institution Default of Principal and Interest
WBIDFC 4950.45

*above figures don’t include interest amounting to Rs. 125,381.29 lacs of which Rs 42,092.48 Lacs pertains to financial year 2018-19, Rs. 43,744.25 lacs pertain to financial year 2017-18 and Rs. 39,544.56 lacs for the financial year 2016-17, as interest has not been provided in the books as mentioned in Note – 20 of the financial statements.

**The lenders have initiated the recovery procedures and have already served the call up notice for their exposure. Therefore, instead of structured repayment schedule, the entire exposure of the banks/ financial institution has fallen due on immediate basis.

To the best of our knowledge and belief and according to the information and explanations given to us, during the year the Company did not avail any term loan facility from bank or financial institution. Also, Company did not raise any money by way of initial public offer or further public offer (including debt instruments) during the year.

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

xi. According to the information and explanation given by the management, the company has not paid remuneration over and above the limits prescribed under section 197, read with Schedule – V of the act to executive director.

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) of the Order is not applicable.

xiii. According to the information and explanations given to us and based on our examination of the records of the Company, transactions with the related parties are in compliance with sections 177 and 188 of the Act where applicable and details of such transactions have been disclosed in the financial statements as required by the applicable Indian Accounting Standards.

xiv. According to the information and explanations give to us and based on our examination of the records, the Company has not made any private placement of shares during the year under review.

xv. According to the information and explanations given to us and based on our examination of the records of the Company, the Company has not entered into non-cash transactions with directors or persons connected with them and hence provisions of section 192 of companies Act, 2013 are not applicable to the company.

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

For, S. K. AGRAWAL & CO.
Chartered Accountants
Firm’s Registration No-306033E
(J. K. CHOUDHURY)
Place : Kolkata Partner
Dated : May 30, 2019 Membership No: 009367