K S Oils Ltd Auditor Reports

The Members of K.S. OILS LIMITED

Report on the Audit of the Financial Statements Disclaimer of Opinion

We were engaged to audit the accompanying financial statements of K.S OILS Limited, which comprise the Balance Sheet as at March 31, 2023, and the Statement of Profit and Loss (including other comprehensive income), the Statement of cash flows and the statement of changes in equity for the year then ended, and notes to accounts, including a summary of significant accounting policies and other explanatory information (herein after referred to as “Financial Statements”).

We do not express an opinion on the Financial Statements. Because of the significance of the matters described in the Basis for Disclaimer of Opinion paragraph, we have not been able to obtain sufficient appropriate audit evidence to provide a basis for an audit opinion.

Basis for Disclaimer of Opinion

1. That on a Petition filed by SREI Infrastructure Finance Limited under Section 7 of IBC, 2016, the Adjudicating Authority vide order dated 21.07.2017 admitted the Insolvency Petition filed in respect of M/s K.S. Oils Limited and the Corporate Insolvency Resolution Process (“CIRP”) commenced for the said Corporate Debtor and Mr. Kuldeep Verma (Registration No.: IBBI/IPA-001/IP-P00014/2016- 17/10038) was appointed as Interim Resolution Professional. Thereafter, the Committee of Creditors (COC) confirmed the appointment of Mr. Kuldeep Verma as Resolution Professional.

2. The company has not paid interest on secured Loans from Banks of Rs 1,51,583 Lakhs. The company is not able to quantify the shortfall in interest and financial charges to be provided in books of accounts. During the year, the Corporate Insolvency Resolution Process (CIRP) was initiated against the Company under the provisions of the Insolvency and Bankruptcy Code, 2016. Pursuant to the admission of the application by the Honble National Company Law Tribunal (NCLT), a moratorium was declared under Section 14 of the IBC, effective from 21.7.2017.

In view of the moratorium, the Company has not provided for or recognized interest expenses on borrowings and other financial liabilities covered under the CIRP for the period commencing from the moratorium date.

3. On perusal of financial records of the corporate debtor, RP observed various questionable transactions by corporate debtor falling under the purview of section 43,45,49,50 & 66 of IBC. On 22- Aug-2017 COC discussed and decided to conduct the forensic audit for a period of 24 months in meeting dated 21.12.2017. The forensic auditors endeavored to submit the final transaction audit report on 8.3.2018 after comprehensive analysis of various transactions based on information available. The Forensic report shows that the erstwhile Management of the Company have carried out the business of the Company out with a clear intent to syphon away monies and defraud the creditors of the Corporate Debtor. Kindly Refer Note No 27 of the financial statements for details.

4. The Resolution Professional (RP) was not in receipt of any cash and cash equivalents from the erstwhile management and that amount has been accordingly treated for in the books of Accounts for which RP had filed an application under Section 19 of IBC, 2016 before Honble NCLT, Indore Bench being IA 164 of 2018 and the same is pending adjudication. All existing Bank accounts, the details of which was provided by the erstwhile management, which were existing as on the date of CIRP Proceedings were closed and only 1 Bank account with SBI being A/c No.: 00000010395465279 was kept for receipts and payments during the CIRP.

5. Referring to the approved Sale Certificate after E- Auction issued to Soy- Sar edible Private Limited on 22.3.24 read with corrigendum dated 06.04.24; according to Schedule I under regulation 33 of the insolvency and Bankruptcy Board of India(Liquidation Process) Regulations , 2016 the Liquidator, in consultation with the stakeholder consultation committee of the corporate Debtor, undertook to sell the assets of the Corporate Debtor through an auction on a Going Concern basis (excluding certain assets) herein after referred to as the “acquisition plan by the NCLT order dated 3^rd February received on 5^th February, 2025.

“Upon approval of the reliefs and concessions allowed by the Honble NCLT, Indore Bench in Inv 7 of 2024 filed by the auction purchaser after acquisition of the company as a going concern; all non compliances, breaches and defaults of K.S. OILS Limited for the period prior to the Effective Date (including but not limited to those relating to tax), shall be deemed to be waived by the concerned Governmental Authorities. Immunity shall be deemed to have been granted to K.S OILS from all proceedings and penalties under all Applicable Laws for any non-compliance for the period prior to the Effective Date and no interest/penal implications shall arise due to such non-compliance /default /breach prior to the Effective Date or even accruing after the Effective Date, but arising out of matters or actions arising prior to the Effective Date”.

The approval of the acquisition Plan subsequent to 31 March 2023 has been considered as a non-adjusting event for the purpose of financial statements for the year ended 31 March 2023. Pursuant to such approval of the acquisition Plan, the financial statements for the year ended 31 March 2023 have been prepared on a going concern basis.

6. The management/RP has conveyed that the subsidiary company was also in the process of liquidation and the winding up of the same was done on 28^th April, 2023. Hence, no consolidated financial statements were required to be prepared.

7. In view of facts mentioned in Note 27, during the Corporate Insolvency Resolution Process (CIRP), only those receipts which have been actually realized in the designated bank account operated and maintained by the Resolution Professional (RP) have been recognized as Other Income in these financial statements. It is specifically noted that certain credits may appear in the Corporate Debtors Form 26AS on account of tax deducted at source (TDS), but where the corresponding income has not been actually realized in the said account, such amounts have not been recognized as income in these financial statements. Only incomes which were realized by the RP/ Liquidator during the CIRP has been recognized in books of accounts as specified in IND-AS 115, Revenue Recognition, Revenue is measured at fair value of the consideration received or receivable and revenue is measured at fair value of the consideration received or receivable, after deduction of any trade discounts, volume rebates and any taxes or duties collected on behalf of the government which are levied on sales etc.

8. Under the circumstances mentioned in Note 27 of financial statements and in the absence of documents/information and pending matters for adjudication before Honble NCLT, Indore Bench the accounts has been prepared to the extent feasible based on available alternate evidences/information. Since several of the financial irregularities are sub judice and the various investigations are ongoing, any further adjustments/disclosure, if required would be made in the financial results of the Company as and when the outcome of the above uncertainties is known and the consequential adjustments/disclosures are identified.

Due to the requirements translation at the time of IND AS Rs 25,988 Lakhs of redeemable preference shares have been shown under the Borrowings head. The company has not taken effect of Rs 779.64 Lakhs (Rs 259.88 Lakhs per year interest for 3 years from 2014 to 2017) in Financial Liabilities and Reserves. The company has not booked the Dividend payable on 1% Cumulative Preference shares under Interest expense in the Profit and Loss account of Rs 259.88 each for the year 2018-2021, it should have been booked till the date when the preference shares had to be mandatorily redeemed. At the time of translation to IND AS the company has not taken effect of the same as the company is in CIRP proceedings at this time.

9. We were appointed as auditors of the Company in May 2025 thus-

a) We were not able to observe the counting of physical inventories at the beginning and at the end of the year. We were unable to satisfy ourselves by alternative means concerning the inventory quantities held at March 31, 2023, which are stated in the Balance Sheets at Rs 922 Lakhs as it is the same as last year balance sheet figures.

b) Gross block and net block of fixed assets as per books are what is physically present cannot be verified by us and so we are not able to comment upon the same. We are not able to verify the Capital Work in Progress of Rs 2624 Lakhs.

c) We were unable to confirm or verify by alternative means accounts payables and accounts receivable included in the Balance Sheet shown at a total amount of Rs 15,465 Lakhs and Rs 615 Lakhs respectively as at March 31, 2023.

d) Long term Loan and Advances of Rs. 919 Lakhs includes advances aggregating capital advance of Rs. 384 Lacs given to the suppliers and security Deposit of Rs.427 lacs are shown in the Balance sheet. Major of balance is shown in books for more than three years. In absence of confirmation provision to be made if any for adverse variation in the carrying amount of these balances, the company has shown it at this value.

Emphasis of Matter

We draw attention to the following matters:

1. The Corporate Insolvency Resolution Process has been initiated against the company under the provision of insolvency and bankruptcy Code 2016 by an order of National Company Law Tribunal with effect from 21^st July 2017. Further Mr. Kuldeep Verma was appointed as Liquidator (RP) and confirmed as Liquidator (RP) with approved of Committee of Creditors (COC) at their meeting held on 22^nd Aug 2017. On 16^th March 2021; he was appointed as the Liquidator. The powers of Board of Directors stand suspended and such powers were vested with Mr. Kuldeep Verma appointed as the Liquidator with respect to the company.

2. Note No 30 of the financial statements regarding inventories. Closing stock of inventory has been taken as 922 Lakhs in the Balance sheet but we could not ascertain the value of such inventory.

3. As per the IBC code the RP has to receive, collate and reconcile all the claims submitted by the creditors of the company. The RP has verified and admitted the claims submitted by the creditors against the company as per the Code. Accounting impact in the books of accounts has not been made in respect to excess, short or non-receipts of claim or liabilities for financial and operational creditor as the Resolution plan has been approved during the subsequent year on 21^st July 2017. On 16^th March 2021, the company went into Liquidation.

4. As per “Indian Accounting Standard 36”, “Impairment of Asset”, if the carrying amount of the asset is more than recoverable amount then asset need to be impaired and as per “Indian Accounting Standard 109” on financial assets through expected credit loss method basis these provisions we were required to seek for any impairment obligations from management, since the Company was under the process CIRP the management determined value in use as on 31st March 2023 by and taking depreciation for the intervening period thus the property, plant & equipment has been depreciated by Rs. 3173 Lakhs during the year and the effect of impairment loss will be disclosed when the valuation will be done and the impairment can be calculated accurately.

Key Audit Matters

Key audit matters are those matters that, in our professional judgment, are 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.

Except for the matters described in the Basis for disclaimer of opinion and Material uncertainty related to going concern, we could not determine whether there are other key audit matters or not to be communicate in our report.

Information other than financial statements and Auditors Report thereon

The Management of the company i.e Liquidator is responsible for the preparation of the other information. We have not been provided the other information comprises of the Financial or non-financial information (other than financial statements and the auditors report thereon) included in an entitys annual report.

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 on the other information obtained prior to the date of this auditors report, we conclude that there is a material misstatement of this other information, are required to report that fact. We have nothing to report in this regard.

Management and Those Charged with Governances Responsibility for the Financial Statements

The Management of the company i.e Liquidator is responsible for the matters stated in section 134(5) of the Companies Act 2013 (“the Act”) with respect to the preparation of these financial statements that give a true and fair view of the financial position, financial performance and cash flows of the Company in accordance with the accounting principles generally accepted in India, including the Accounting Standards specified under section 133 of the Act, read with Companies (Accounts) Rules, 2015.

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 for ensuring accuracy and completeness of the accounting records relevant to the preparation and presentation of the financial statements 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 i.e Liquidator is responsible for assessing the Companys ability to continue as going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless management i.e Liquidator either intends to liquidate the company or to cease operations, or has no realistic alternative but to do so.

Auditors Responsibility

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 audit conducted in accordance with Standards on Auditing 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 Standards on Auditing, 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 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 control relevant to the audit in order to design audit procedures that are appropriate in the circumstances. Under Section 143(3) (i) of the Act, we are also responsible for explaining our opinion on whether the Company has adequate internal financial controls system in place and the operating effectiveness of such controls.

? Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and related disclosures made by management.

? Conclude on the appropriateness of managements use of the going concern basis of accounting and, based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Companys ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditors report to the related disclosures in the 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 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

1. As required by the Companies (Auditors Report) Order, 2020 (“the Order”) issued by the Central Government of India in terms of sub-section (1 1) of section 143 of the Act, we give in the Annexure a statement on the matters Specified in paragraphs 3 and 4 of the Order.

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

a) As described in the Basis for Disclaimer of Opinion paragraph, we sought but were unable to obtain all the information and explanations which to the best of our knowledge and belief were necessary for the purpose of our audit;

b) Due to the possible effects of the matter described in the Basis for Disclaimer of Opinion paragraph, we are unable to state whether proper books of account as required by law have been kept by the Company so far as appears from our examination of those books;

c) Due to the possible effects of the matter described in the Basis for Disclaimer of Opinion paragraph, we are unable to state whether the Balance Sheet, Statement of Profit and Loss and Cash Flow Statement dealt with by this Report are in agreement with the books of account;

d) Due to the possible effects of the matter described in the Basis for Disclaimer of Opinion paragraph, we are unable to state whether the aforesaid financial statements comply with the Accounting Standards under Section 133 of the Act read with the relevant rules issued there under;

e) The matter described in the Basis for Disclaimer of Opinion paragraph above, in our opinion, may have an adverse effect on the functioning of the Company.

f) No written representations has been received or taken on record regarding disqualification of directors as on March 31, 2022 as there are no directors available in the Board for compliance as per section 164(2) of the Act. So we are unable to comment upon this.

g) The reservation relating to the maintenance of accounts and other matters connected therewith are as stated in the Basis for Disclaimer of Opinion paragraph above.

h) 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”. Our report expresses a disclaimer opinion on the adequacy and the operating effectiveness of the companys internal financial controls over financial reporting; and internal audit has also not been taken placed by company.

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:

i. Due to the possible effects of the matter described in the Basis for Disclaimer of Opinion paragraph, we are unable to state whether the Company has disclosed the impact of pending litigations on its financial position in its financial statements; However, as per the informations, explanations and representations received from the Liquidator there are no pending litigations.

ii. Due to the possible effects of the matter described in the Basis for Disclaimer of Opinion paragraph, we are unable to state whether the Company has made provision, as required under the applicable law or accounting standards, for material foreseeable losses, if any, on long term contracts including derivative contracts;

iii. There is no amount required to be transferred, to the Investor Education and Protection Fund by the Company.

iv. As per the management representation we report,

a) No funds have been advanced or loaned or invested by the company to or in any other person(s) or entities, including foreign entities (“Intermediaries”), with the understanding that the intermediary shall whether directly or indirectly lend or invest in other persons or entities identified in any manner by or on behalf of the company (Ultimate Beneficiaries) or provide any guarantee, security or the like on behalf of ultimate beneficiaries.

b) No funds have been received by the company from any person(s) or entities including foreign entities (“Funding Parties”) with the understanding that such company shall whether, directly or indirectly, lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the funding party (ultimate beneficiaries) or provide guarantee, security or the like on behalf of the Ultimate beneficiaries.

c) Based on such audit procedures we have 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( a) and (c) contain any material mis-statement.

v. Proviso to Rule 3(1) of the companies (Accounts) Rules, 2024 for maintaining books of account using accounting software which has a feature of recording audit trail( edit log) facility is applicable to the company with effect from 1April, 2023 and accordingly reporting under Rule 11(g) of companies (Audit and Auditors) Rules, 2014 is not applicable for the financial year ended March 31, 2023.

3. The company has not declared or paid any dividend during the year; hence its compliance with section 123 of the companies Act, 2013 has not been commented upon.

Annexure “A” to the Independent Auditors Report

Annexure referred to in Paragraph 1 of “Report on Legal and regulatory requirements” of our independent auditors report of even date to the members of K.S Oils Limited as on 31^st March 2023.

As required by the Companies (Auditors Report) Order, 2020 (“the Order”) and on the basis of such checks as we considered appropriate and according to the information and explanations given to us during course of our audit, we report that: -

1. In respect of its Property, Plant & Equipment

(a) According to the information and explanation given to us and on the basis of examination of books and records, the company has not maintained the records; so we are not able to comment upon the same.

(b) During the year, no verification of Property, Plant and Equipment has been conducted by management.

(c) 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 immovable properties which are freehold and held in the name of company as at the balance sheet date. In respect of immovable properties taken on lease, Lease hold improvements have been disclosed as fixed assets in the financial statements, the lease agreement are in the name of the company. However, supplement lease agreement as mentioned in lease agreement are not on record.

(d) According to the information and explanations given to us and on the basis of our examination of the records of the Company has not revalued its property plant & equipment or intangible assets during the period under consideration.

(e) According to the information and explanations given to us, no proceedings have been initiated during the year or are pending against the company for holding any benami property under the Benami Transactions (Prohibition) Act, 1988 (45 of 1988) and rules made there under, hence requirement to report on clause (i)(e) of paragraph 3 of the Companies (Auditors Report) Order, 2023 is not applicable.

2. In respect of its inventories

(a) Inventory records have not been provided to us for verification.

(b) According to the information and explanations given to us and on the basis of our examination of the records of the Company is not availing any working capital limit. Hence requirement to report on clause

(ii)(b) of the Order, 2023 is not applicable.

3. The Company has during the year, not made investments in, provided any guarantee or security or granted any loans or advances in the nature of loans, secured or unsecured, to companies, firms, Limited Liability Partnerships or any other parties. Accordingly, the provisions of clause (iii) of the Order is not applicable.

4. According to the information and explanation given to us, the company has no loans, investments, guarantees or security where provisions of section 185 and 186 of the Companies Act, 2013 are to be complied with.

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

6. The company has not maintained any cost records on account of no business as the company was in liquidation and so we cannot comment on cost records u/s 148(1)(d) of the companies Act , 2013.

7.In respect of the Statutory Dues:

(a) According to the information and explanation given to us and records examined by us, Undisputed statutory dues including provident fund, investor education and protection fund, employees state insurance, income -tax, sales tax, wealth-tax, service tax, customer duty, excise duty, cess and other material statutory dues, if any applicable to it, have not been regularly deposited with appropriate authorities and there have been material delays in numerous numbers of cases. The Arrears of outstanding dues at the last day of financial year concerned for a period of more than six months from the date they became payable are as under:

Name of Statue	Nature of Dues	Amount (Rs. In Lacs)	Period to which amount relates	Due Date	Date of Payment
Employee Provident fund and Miscellaneous Provision Act	ESIC	3.80	Period related to 2012-17	Various Dates
Service Tax	Provident Fund	113.41	Period related to 2012-17	Various Dates	Paid Rs. 8.77 up to 03.07.2017
State Sales Tax	Service Tax	136.07	Period related to 2013-17	Various Dates	Paid Rs. 4.05 up to 01.05.2017
State Sales Tax	VAT	878.29	Period related to 2012-16	Various Dates
State Sales Tax	WCT	7.42	Period related to 2014-16	Various Dates
State Sales Tax	Entry Tax	99.90	Period related to 2012-16	Various Dates

(b) Details of Dues of Income Tax, Wealth Tax, Service Tax, duty of custom & Excise Value Added Tax, Cess which have not been deposited as on March 31, 2023 on account of disputes are given below.

Name of the Statute	Nature of the dues	Amount (Rs. In lakhs)	Period to which amount relate	Forum where dispute is pending
Madhya Pradesh VAT Act	VAT	4560	2007-08
Madhya Pradesh VAT Act	VAT	8	2009-10	Tax Board Bhopal
Madhya Pradesh VAT Act	VAT	12	2007-08	Tax Board Bhopal
Madhya Pradesh VAT Act	VAT	19	2009-10	Tax Board Bhopal
Madhya Pradesh VAT Act	VAT	264	2010-11
Madhya Pradesh VAT Act	VAT	70	2011-12
Madhya Pradesh VAT Act	VAT	81	2012-13
Madhya Pradesh VAT Act	VAT	52	2013-14
Madhya Pradesh VAT Act	VAT	4	2009-10
Madhya Pradesh VAT Act	VAT	8	2010-11
Madhya Pradesh VAT Act	VAT	32	2012-13
Madhya Pradesh VAT Act	VAT	8	2012-13
Madhya Pradesh VAT Act	VAT	202	2010-11
Madhya Pradesh	VAT	413	2011-12	--
VAT Act
Madhya Pradesh VAT Act	VAT	502	2012-13
Madhya Pradesh VAT Act	VAT	10	2013-14
Madhya Pradesh VAT Act	VAT	1	2014-15
Madhya Pradesh VAT Act	VAT	26	2011-12
Madhya Pradesh VAT	VAT	81	2012-13
Madhya Pradesh VAT Act Act	VAT	84	2012-13
Sales Tax Act	Sales Tax/ CST	119	2008-09	--
Sales Tax Act	Sales Tax/ CST	4	2007-08	--
Sales Tax Act	Sales Tax/ CST	52	2010-11	--
Sales Tax Act	Sales Tax/ CST	267	2011-12	--
Sales Tax Act	Sales Tax/ CST	247	2012-13	--
Sales Tax Act	Sales Tax/ CST	4	2013-14	-
Sales Tax Act	Sales Tax/ CST	4	2012-13	-
Sales Tax Act	Sales Tax/ CST	22	2011-12	-
Sales Tax Act	Sales Tax/ CST	18	2012-13	-
Sales Tax Act	Sales Tax/ CST	76	2012-13	-
Entry Tax Act	Entry Tax	1205	2007-08	-
Entry Tax Act	Entry Tax	3	2009-10	--
Entry Tax Act	Entry Tax	10	2007-08	-
Entry Tax Act	Entry Tax	1	2009-10	-
Entry Tax Act	Entry Tax	668	2009-10	-
Entry Tax Act	Entry Tax	196	2010-11	-
Entry Tax Act	Entry Tax	59	2011-12	-
Entry Tax Act	Entry Tax	4	2013-14	-
Entry Tax Act	Entry Tax	2	2009-10	-
Entry Tax Act	Entry Tax	7	2010-11	-
Central Excise Act	Excise Act	24	2001-02	High Court
Central Excise Act	Excise Act	3	2002-03	High Court
Central Excise Act	Excise Act	43.1	2009-2012	Commissioner of Central Excise (Appeals)
Central Excise Act	Excise Act	12.85	2008-09	Appeal Tribunal Delhi
Mandi Tax	Mandi Tax	65.12	2008-09	High Court

• Marked appeals decided by the authority against us in the absence of appeal advance, hence no further appeals are pending.

• Marked no appeals are submitted against the demand in the absence of appeal advance.

Referring to the approved acquisition plan by the NCLT order dated 3^rd February received by us dated 5^th February 2025 all these disputed statutory dues need not to be deposited

“Upon approval of the reliefs and concessions allowed by the Honble NCLT, Indore Bench in Inv 7 of 2024 filed by the auction purchaser after acquisition of the company as a going concern; all noncompliances, breaches and defaults of K.S OILS Limited for the period prior to the Effective Date (including but not limited to those relating to tax), shall be deemed to be waived by the concerned Governmental Authorities. Immunity shall be deemed to have been granted to K.S OILS from all proceedings and penalties under all Applicable Laws for any non-compliance for the period prior to the Effective Date and no interest/penal implications shall arise due to such non-compliance /default /breach prior to the Effective Date or even accruing after the Effective Date, but arising out of matters or actions arising prior to the Effective Date”.

(c) According to the records of the Company, there are no amount that are due to be transferred to the investor Education and Protection Fund in accordance with the relevant provisions of the Companies Act, 1956 and rules made there.

8. According to the information and explanation given to us, company has no transactions, not recorded in the books of account have been surrendered or disclosed as income during the year in the tax assessments under the Income Tax Act, 1961 (43 of 1961).

9. (a) Based on our audit procedures and according to the information and explanations given to us, the Company has defaulted in repayment of dues to a financial institution or bank or debenture holders.

(Refer Note 29 of the Financial Statements)

b) As per information available in the public domain, the Company has been included in the list of wilful defaulters published by the Reserve Bank of India (RBI). This classification is based on disclosures made by lending institutions and disseminated through RBIs reporting framework.

c) According to the information and explanation given to us and on the basis of disclaimer of opinion we cannot comment if term loans were applied for the purpose for which the loans were obtained;

d) According to the information and explanation given to us, funds raised on short term basis have not been utilized for long term purposes;

e) According to the information and explanation given to us, the company has not taken any funds from any entity or person on account of or to meet the obligations of its subsidiaries, associates or joint ventures;

f) According to the information and explanation given to us, the company has not raised loans during the year on the pledge of securities held in its subsidiaries, joint ventures or associate companies.

10. a) The Company has not raised moneys by way of initial public offer or further public offer (including debt instruments) during the year;

(b) According to the information and explanation given to us, the Company has not made any preferential allotment or private placement of shares or convertible debentures (fully, partially or optionally convertible) during the year.

11(a).During the course of our examination of the records of the Company, carried out in accordance with the generally accepted auditing practices in India, and according to the information and explanations given to us, a forensic audit was done and several instances of fraud were reported by erstwhile management ; following which 2 applications were filed before the Honble NCLT- IA 163/2018 and IA- 164/2018 which is still sub judice before the Honble NCLT, Indore Bench ; also CBI has initiated legal proceedings before the special judge, Rouse Avenue Courts, New Delhi against the erstwhile management (Refer Note No 27 of financial statements); hence we say that there is an instance of fraud on or by the Company,

(b) According to the information and explanation given to us, no report under subsection (12) of section 143 of the Companies Act has been filed by the auditors in Form ADT-4 as prescribed under rule 13 of Companies (Audit and Auditors) Rules, 2014 with the Central Government;

? According to the information and explanation given to us, no whistle-blower complaints, received during the year by the company;

12. Company is not a Nidhi company, accordingly provisions of the Clause (xii) of the Order is not applicable to the company.

13. According to the information and explanations given to us, we are of the opinion that all transactions with 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 etc., as required by the Accounting Standards and the Companies Act, 2013.

14. According to the information and explanations given to us, the company has no internal audit system since it was in the process of CIRP and then Liquidation;

15. According to the information and explanations given to us, we are of the opinion that the company has not entered into any non-cash transactions with directors or persons connected with him and accordingly, the provisions of clause (xv) of the Order is not applicable.

16. According to the information and explanations given to us, we are of the opinion that the company is not required to be registered under section 45-IA of the Reserve Bank of India Act, 1934 and the company is not a Core Investment Company (CIC) as defined in the regulations made by the Reserve Bank of India, accordingly the provisions of clause (xvi) of the Order are not applicable.

17. According to the information and explanations given to us and based on the audit procedures conducted we are of opinion that the company has incurred Nil cash losses in the current financial year and Rs 226 Lakhs in the immediately preceding financial year.

18. There has been no resignation of the statutory auditors during the year and accordingly, the provisions of clause (xviii) of the Order is not applicable; However, the resignation for this period was done in June 2025 by the previous auditor.

19. Since the Company was under CIRP and went into Liquidation on 16^th March 2023.Therefore, existence of any material uncertainty on 31.03.2023 regarding the ageing report, financial ratios and expected dates of realization of financial assets and payment of financial liabilities, any other information accompanying the financial statements, Board of Directors and management plans are covered under Notes to accounts.

20. The provisions of Section 135 towards corporate social responsibility are not applicable on the company. Accordingly, the provisions of clause (xx) of the Order is not applicable.

21.The management has conveyed that the subsidiary company is also in the process of liquidation and its winding up has been done on 28th April, 2023. Hence, no consolidation is required. The reporting under clause (xxi) of the order has not been done.

Annexure B to the Independent Auditors Report

Report on the Internal Financial Control 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 K.S OILS Limited Company under CIRP (“the Company”) as on 31st March 2023 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 i.e Liquidator 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”) 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 Ind AS financial statements, whether due to fraud or error.

We believe that the audit evidence has not been obtained and is not available so as 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 Ind AS 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 Ind AS financial statements in accordance with generally accepted accounting principles, and 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 Ind AS 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.

Qualified Opinion

Due to inadequate staff and unavailability of relevant records, in our opinion, the Company does not have an adequate internal financial controls system over financial reporting and such internal financial controls over financial reporting were not operating effectively as at 31st March, 2023. We have not been provided with 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.

Other matter

The Corporate Insolvency Resolution Process has been initiated against the company under the provision of insolvency and bankruptcy Code 2016 by an order of National Company Law Tribunal with effect from 21^st July 2017. Further Mr. Kuldeep Verma was appointed as Liquidator (RP) and confirmed as Liquidator (RP) with approved of Committee of Creditors (COC) at their meeting held on 22^nd Aug 2017.

The powers of Board of Directors stand suspended and such powers shall be vested with Mr. Kuldeep Verma appointed as the RP with respect to the company. On 16 March 2023, the Honble NCLAT passed order in Company Appeal (AT) (Insolvency) No. 98 of 2023 directing the liquidation of the Corporate Debtor (“Liquidation Order”)