To the members of Kwality Limited
(A Company under Corporate Insolvency resolution process vide NCLT order)
REPORT ON AUDIT OF THE STANDALONE FINANCIAL STATEMENTS
1. Qualified Opinion
We have audited the accompanying standalone financial statements of Kwality Limited
(the Company), which comprise the Balance Sheet as at 31 March 2020, the Statement of
Profit and Loss (including Other Comprehensive Income), the Statement of Cash Flow and the
Statement of Changes in Equity for the year ended 31.03.2020, notes to the financial
statements, and a summary of significant accounting policies and other explanatory
information. (Hereinafter referred to as "the Standalone Financial Statements")
In our opinion and to the best of our information and according to explanations given
to us, except for the effects of the matters described in the Basis of Qualified Opinion
paragraph 2 below, the aforesaid financial statements give a true and fair view in
conformity with the accounting principles generally accepted in India of the state of
affairs of the company as at 31 March 2020 and its loss, changes in equity and its cash
flows for the year ended on that date.
2. Basis for Qualified Opinion:
a. The Company has incurred a Net loss of INR 12,874.40 lakhs resulting into net
accumulated losses of INR 1,96,888.91 lakhs and erosion of its Net worth as at 31 March
2020. The company has obligations towards lenders, creditors and other agencies. The
process of filing, verification and acceptance of claims has been completed by the RP
pursuant to ongoing Corporate Insolvency Resolution Process (CIRP). No accounting impact
in the books of accounts has been made in respect of excess, short, non-receipt of claims
or liabilities earlier not recorded in the books of accounts but now quantified and
accepted by RP for operational and financial Creditors hence consequential impact, if any,
is not ascertainable and we are unable to comment on the possible financial impacts of the
same.
b. The company has a number of pending litigations w.r.t various legal and tax matters
pending with various authorities but the company has not made any provision for any future
loss arising to the company in the scenario of negative outcome of such cases. It includes
income tax demand (along with interest) of INR 8,97,440.28 lakhs (including income tax
claim of INR 17798.69 lakhs, which has already been accepted earlier & is recognized
in the books and the balance amount is under appeal) beginning from AY 2011—12 till
AY 2018-19. Income Tax authorities has belatedly filed claim in Form B dated 31.12.2019
for INR 8,97,440.28 lakhs (which also included claim of INR 17798.69 lakhs filed &
admitted earlier and the amounts under appeals) on 20.01.2020 with the Resolution
Professional. As statutory period of completion of CIRP u/s 12 of the Code has come to an
end on November 5, 2019, and the matter is subjudice before the Honble NCLT for
appropriate orders either under Section 31 or Section 33 of the Code ,the Resolution
Professional has not collated and verified the additional claim submitted by income tax
authorities.
We have conducted our audit 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
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
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 thereunder, and
we have fulfilled our other ethical responsibilities in accordance with these requirements
and the Code of ethics. We believe that the audit evidence we have obtained is sufficient
and appropriate to provide a basis for our qualified opinion.
3. EMPHASIS OF MATTER
We draw attention to the following matters in the financial statements:
a. Attention is drawn to Note no. 47 of the standalone financial statements; The
Company continues not to assess impairment of carrying value of tangible assets, capital
work in progress and intangible assets in accordance with requirements of Ind AS - 36 on
"Impairment of Assets". We are unable to obtain sufficient appropriate audit
evidence about the recoverable amount of the Companys tangible assets, capital work in
progress and intangible assets. Consequently, we are unable to determine whether any
adjustments to carrying value are necessary and consequential impacts on the standalone
financial statements.
b. Attention is drawn to Note no. 31 of the Standalone Financial Statements regarding
non-recognition of interest on borrowing from banks and, financial institutions and bank
charges on borrowing from banks and financial institutions subsequent to insolvency
commencement date i.e. 11th December 2018. The company has not recognized any interest on
these amounts. The same is not in compliance with requirements of Ind AS. Had provision
for interest, bank charges and exchange difference been recognized, finance cost and total
expenses, would have been higher and loss and total comprehensive loss for year ended
would also have been higher, having consequential impact on other current financial
liability and other equity.
Our opinion is not modified in respect of above matters
4. Material Uncertainty Related to Going Concern
The Company has incurred cash losses, its liabilities exceeded total assets and its net
worth has been fully eroded as on 31st March 2020. Capacity utilization of manufacturing
processing facilities is very low and Corporate Insolvency Process against the Company is
in process. Since the CIRP is currently in progress, as per the Code, it is required that
the Company be managed as a going concern during the CIRP. The standalone financial
statements is continued to be prepared on going concern basis. However there exists
material uncertainty about the Companys ability to continue as going concern since the
application filed by the resolution applicant seeking a direction against the CoC to
approve the resolution plan is sub-judice before the Honble NCLT. Hence the application
for liquidation of the Company filed by
RP with NCLT is in abeyance until the said application filled by the resolution
applicant is decided by the NCLT. The appropriateness of preparation of standalone
financial statements on going concern basis is critically dependent upon CIRP as specified
in the Code. Our opinion is not modified in respect of this matter.
5. Information other than the Financial Statements and Auditors Report Thereon
The Companys Board of Directors / Resolution Professional are responsible for the
other information. The other information comprises the information included in the Annual
Report (but does not include the standalone financial statements and our auditors report
thereon), which is expected to be made available to us after that date. Our opinion on the
standalone financial statements does not cover the other information and we do not and
will not express any form of assurance conclusion thereon. In connection with our audit of
the standalone financial statements, our responsibility is to read the other information
identified above and, in doing so, consider whether the other information is materially
inconsistent with the standalone financial statements or our knowledge obtained in the
audit, or otherwise appears to be materially misstated.
When we read the other information identified above, if we conclude that there is a
material misstatement therein, we are required to communicate the matter to those charged
with governance.
6. Responsibilities of Management/ Board of Directors/ Resolution Professional for the
Standalone Financial Statements
The Companys Board of Directors/Resolution Professional / Management is responsible
for the matters stated in section 134(5) of the Companies Act, 2013 ("the Act")
with respect to the preparation of these standalone financial statements that give a true
and fair view of the financial position, financial performance, changes in equity 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. This
responsibility also includes maintenance of adequate accounting records in accordance with
the provisions of the Act for safeguarding of the assets of the Company and for preventing
and detecting frauds and other irregularities; selection and application of appropriate
implementation and maintenance of accounting policies; making judgments and estimates that
are reasonable and prudent; and design, implementation and maintenance of adequate
internal financial controls, that were operating effectively for ensuring the accuracy and
completeness of the accounting records, relevant to the preparation and presentation of
the financial statement that give a true and fair view and are free from material
misstatement, whether due to fraud or error.
In preparing the financial statements, management is responsible for assessing the
Companys ability to continue as a going concern, disclosing, as applicable, matters
related to going concern and using the going concern basis of accounting unless management
either intends to liquidate the Company or to cease operations, or has no realistic
alternative but to do so.
Those Board of Directors / Resolution Professional /Management are also responsible for
overseeing the Companys financial reporting process.
Pursuant to ongoing Corporate Insolvency Resolution Process (CIRP) powers of the Board
of Directors have been suspended and these powers are now vested with Resolution
Professional (RP).
7. Auditors Responsibility 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 misstatements, 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 our 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 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 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 Companies Act, 2013 we are also responsible for expressing an opinion on whether
the company has adequate internal financial control system in place and the operating
effectiveness of such controls.
• Evaluate the appropriateness of the accounting policies used and the
reasonableness of the accounting estimates and related disclosures made by the
management/directors/ RP.
• Conclude on the appropriateness of the managements use of 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 a 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.
We communicate with those charged with governance regarding, amongst 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 reasonable be thought to bear on our
independence, and where applicable, related safeguards.
8. Report on Other Legal and Regulatory Requirements:
(1) As required by The Companies (Auditors 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 "A" a statement on the matters
specified in paragraphs 3 and 4 of the Order, to the extent applicable.
(2) Further to our comment in the Annexure A, as required by Section 143(3) of the Act,
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 books.
(c) There are no branch offices of the company having separate branch auditors.
(d) The Balance Sheet, the Statement of Profit and Loss (including other comprehensive
income), the Cash Flow Statement and the Statement of Changes in Equity dealt with by this
Report are in agreement with the books of account.
(e) Except for the possible effects of matters described in the Basis for Qualified
Opinion paragraph above, 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.
(f) On the basis of the written representations received from the management/RP as on
31 March 2020, none of the directors is disqualified as on 31 March 2020 from being
appointed as a director in terms of Section 164 (2) of the Act.
(g) The matters described in the Basis for Qualified Opinion paragraph above, and the
matters described in the Material uncertainty relating to Going Concern may have an
adverse impact on the functioning of the company.
(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".
(i) The qualifications to maintenance of accounts and other matters connected therewith
are as stated in the Basis for Qualified Opinion paragraph above.
(j) With respect to the other matters to be included in the Auditors Report in
accordance with Rule 11 of the Companies (Audit and Auditors) Rules, 2014, in our opinion
and to the best of our information and according to the explanations given to us:
(i) The company has a lot of pending litigations and as detailed in Note No 38 to the
standalone financial statements has disclosed the impact of pending litigations on its
financial position.
(ii) The company has no foreseeable losses on long-term contracts including derivative
contracts.
(iii) There has been no delay in transferring amounts, required to be transferred, to
the Investor Education and Protection Fund by the Company.
For B. RATTAN & ASSOCIATES
Chartered Accountants Firms Registration No: 011798N
Sd/-
Bishamver Kumar Karn
Membership No: 094790 Partner
UDIN: 20094790AAAAAQ5977
Place: New Delhi
Date: 29 July 2020
ANNEXURE "A" TO INDEPENDENT AUDITORS REPORT
REPORT AS PER THE COMPANIES (AUDITORS REPORT) ORDER, 2016
Referred to in Point No . 1 of "Report on Other Legal and Regulatory
Requirements" of the Independent Auditors Report of even date to the financial
statements of Kwality Limited for the year ended 31 March 2020.
i. (a) The company has maintained proper records showing full particulars, including
quantitative details and situation of fixed assets on the basis of available information
except assets were not tagged with any unique identification number.
(b) As explained to us, the fixed assets have been physically verified by management at
periodical intervals and no material discrepancies were noticed
ii. As explained by management, there is a system of physical verification of inventory
at periodic intervals, which is adequate to the size of the company and the nature of its
business . No material discrepancies were noticed on physical verification between
physical stock and books of accounts .
iii. As per the information and explanations provided to us, the company has not
granted any loans, secured or unsecured to companies, firms, limited liability
partnerships or other parties covered in the register maintained under section 189 of the
Companies Act, 2013 .
iv As per the information and explanations provided to us, compliance with Section 185
and 186 of the Companies Act, 2013 in respect of the loans, investments, guarantees and
security are not applicable.
v. As per the information and explanations given to us the company has not accepted any
deposits under the directives issued by the Reserve Bank of India and the provisions of
section 73 to 76 or any other relevant provisions of the Companies Act, 2013 and the rules
framed thereunder
vi. As per information and explanations received from the management, the company has
maintained the cost records as prescribed by the Central Government under Section 148(1)
of the Companies Act, 2013.
vii. (a) The company is generally regular in depositing undisputed statutory dues
including customs duty, and any other statutory dues with the appropriate authorities
except Income tax, provident fund, employees state insurance and Tax Deducted at Source .
According to the information and explanations given to us undisputed amounts payable for
above statutory dues are outstanding as on the last day of the financial year for a period
of six months from the date they became payable .
| Name of the Statue |
Name of the dues |
Net amount payable (Amount in INR lakhs) |
Period to which the amount relates (Financial year) |
Due Date |
Date of Payment |
| Income Tax act, 1961 |
Income Tax |
5,444.76* |
2015-16 |
30 Nov 2016 |
Not Paid |
| Income Tax act, 1961 |
Income Tax |
6,195.96* |
2016-17 |
30 Nov2017 |
Not Paid |
| Income Tax act, 1961 |
Income Tax |
7,187.72* |
2017-18 |
30 Nov 2018 |
Not Paid |
| Income Tax act, 1961 |
TDS |
94.95* |
2017-18 |
|
Not Paid |
| Income Tax act, 1961 |
TDS |
377.77* |
2018-19 |
|
Not Paid |
| Employees Provident Fund Organisation |
EPF |
11.21 |
2018-19 |
|
Not Paid |
| Employees State Insurance |
ESIC |
0.94 |
2018-19 |
|
Not Paid |
*Amount has been claimed under the Insolvency and Bankruptcy Code, 2016
(b) According to the explanations and information given to us, there are disputed
amounts in respect of government dues not deposited with appropriate authorities
| Name of the Statue |
Name of the dues |
Net Amount payable (INR in lakhs) |
Period to which the amount relates (Financial year) |
Forum where dispute is pending |
| Uttar Pradesh VAT |
VAT |
7.50 |
2013-14 |
Addl . Comm. (Appeal), Bulandshahr |
| Uttar Pradesh VAT |
VAT |
33.80 |
2014-15 |
Tribunal (2nd Appeal), Aligarh |
| Uttar Pradesh VAT |
VAT |
3.38 |
2014-15 |
Allahabad High Court |
| Uttar Pradesh VAT |
VAT |
17.54* |
2015-16 |
Addl . Comm. (Appeal), Bulandshahr |
| Uttar Pradesh VAT |
VAT &CST |
428.61 |
2016-17 |
Addl . Comm. (Appeal), Bulandshahar |
| Haryana VAT |
VAT |
3.87* |
2012-13 |
DETC Cum Assessing Authority, Palwal |
| Haryana VAT |
VAT |
340.86* |
2013-14 |
DETC (ST) Cum Assessing Authority, Palwal |
| Haryana VAT |
VAT |
1008.57* |
2014-15 |
DETC (ST) Cum Assessing Authority, Palwal |
| Haryana VAT |
VAT |
386.90* |
2015-16 |
ETO cum Assessing Authority, HARYANA |
| Haryana VAT |
VAT |
481.20* |
2016-17 |
ETO Cum Assessing Authority, HARYANA |
| Haryana VAT |
VAT |
210.08* |
2017-18 |
ETO Cum Assessing Authority, HARYANA |
| Haryana GST |
Trans 1 |
921.64* |
2017-18 |
ETO Cum Assessing Authority, HARYANA |
| Haryana VAT |
Service Tax |
6.36 |
2015-16 & 2016-17 |
Superintendent (Audit), Audit Circle-6, Faridabad |
| Rajasthan VAT |
VAT |
18.46 |
2014-15 |
Appellate Authority, Appeals III, Jaipur |
| Delhi VAT |
VAT |
10.87 |
2012-13 |
Commissioner (VAT), Appeals, Delhi |
| Punjab VAT |
VAT |
16.08 |
2012-13 |
DETC(Appeals) cum JD(Appeals) Patiala |
| Punjab VAT |
VAT |
5.96 |
2012-13 |
DETC(Appeals) cum JD(Appeals) Patiala |
| Punjab VAT |
VAT |
7.85 |
2016-17 |
AETC, Mobile Wing, Amritsar |
| Rajasthan VAT |
VAT |
0.02* |
2016-17 |
CTO, Jaipur 1, Special III |
| GST Intelligence, Gurugram |
GST |
15147.63 |
2017-18 & 2018-19 |
Directorate General of GST Intelligence |
| Customs, Excise & Service Tax |
EPCG |
182.52* |
2019-20 |
Commissioner of Customs, Nhava Sheva |
| Customs, Excise & Service Tax |
DEPB Credit |
69.44 |
2012-13 |
Customs and Service Tax Appellate, Mumbai |
| Income Tax act, 1961 |
Income Tax |
8,97,440.27A |
2010-11 to 2017-18 |
Commissioner of Income Tax (Appeal) |
*Amount has been claimed under the Insolvency and Bankruptcy Code, 2016
A Includes INR 18828.44 lakhs covered in Undisputed Statutory Dues more than six months
as for FY 2015-16, 2016-17 and 2017-18 .
(viii) Pursuant to the continuing defaults of the Company, a corporate insolvency
resolution process ("CIRP") under the Insolvency and Bankruptcy Code, 2016 was
initiated against the Company vide an order of the Delhi Bench of the National Company Law
Tribunal ("NCLT"). Owing to the initiation of CIRP, the borrowings are
considered as currently payable . For further details refer note 19 of standalone
financial statements .
(ix) The Company has not raised any money by way of initial public offer or further
public offer (including debt instruments) during the year
(x) During the course of our examination of the books and records of the company,
carried out in accordance with the generally accepted accounting practices in India, and
according to the information and explanations given to us, we have neither come across any
instances of material fraud by the company by its officers and employees noticed or
reported during the year, nor have we been informed of any such case by the management/RP.
(xi) According to the information and explanations given by the management, the
managerial remuneration has been paid / provided within mandated by the provisions of
section 197 read with Schedule V to the Companies Act, 2013.
(xii) As the company is not a Nidhi company the Nidhi Rules 2014 are not applicable to
the company.
(xiii) According to the information and explanations given to us, the company has made
disclosure as regards related party relationship in accordance with the notified
"Indian Accounting Standard -24, Related Party Disclosure".
(xiv) The company has not made any preferential allotment or private placement of
shares or fully or partly convertible debentures during the year under review.
Accordingly, the provisions of Clause 3 of the Order are not applicable to the company.
(xv) According to the information and explanations given to us, the company does not
deal with, if any, non-cash transactions with any of its directors or persons connected
with him .
(xvi) According to the information and explanations given to us, the company is not
required to be registered under Section 45 IA of The Reserve Bank of India Act, 1934.
For B. RATTAN & ASSOCIATES
Chartered Accountants
Firms Registration No: 011798N
Sd/-
Bishamver Kumar Karn
Membership No: 094790
Partner
UDIN: 20094790AAAAAQ5977
Place: New Delhi
Date: 29 July 2020
ANNEXURE "B" TO INDEPENDENT AUDITORS REPORT
(REPORT ON INTERNAL FINANCIAL CONTROLS OVER FINANCIAL REPORTING)
(Referred to paragraph 2(h) of Report on Other Legal and Regulatory Requirements of
the Independent Auditors Report of even date on the financial statements of Kwality
Limited)
Report on the Internal Financial Controls under Clause(i) of Sub Section 3 of Section
143 of the Companies Act, 2013 (The Act).
1. We have audited the internal financial controls over financial reporting of Kwality
Limited as on 31 March 2020 in conjunction with our audit of financial statements of the
company for the year ended on that date .
2. Managements Responsibility for Internal Financial controls
The Board of Directors/Resolution Professional of the Company are 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 companies policies,
the safeguarding of its assets, the prevention and detection of frauds and errors, the
accuracy and completeness of the accounting records, and the timely preparation of
reliable financial information as required under the Act
3. 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 Guidance Note on Audit of Internal Financial Controls over Financial Reporting ( the
" Guidance Note") and the Standards on Auditing as specified under Section 143
(10) of the Act to the extent applicable to an audit of internal financial controls . ,
both applicable to an audit of internal financial controls and both issued by ICAI. Those
Standards and Guidance Notes 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 if such controls operated
effectively in all material respects .
4. 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 include
obtaining an understanding of internal financial controls over financial reporting,
assessing a risk that a material weakness exists, and testing and evaluating the design
and operating effectiveness of internal control based on assessed risk. The procedures
selected depend on the auditors judgement, including the assessment of the risks of
material misstatement of the financial statements, whether due to fraud or error
5. We believe that the audit evidence we have obtained is sufficient and appropriate to
provide a basis for our audit opinion on the internal financial control system over
financial reporting .
6. Meaning of Internal Financial Controls over Financial Reporting
A companys internal financial controls 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 controls 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, directors and RP of the company , and (3) provide reasonable assurance
regarding prevention or timely detection of unauthorised acquisition , use or disposition
of the companys assets that could have a material effect on the financial statements .
7. 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 fraud or error 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 controls
over financial reporting may become inadequate because of changes in conditions, or that
the degree of compliance with the policies or procedures may deteriorate.
8. Opinion
In our opinion, to the best of our information and according to the explanations given
to us ,the Company has, in all material aspects, an adequate internal financial controls
system over financial reporting and such internal financial controls over financial
reporting were operating effectively as on 31 March 2020, 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 issued by ICAI.
For B. RATTAN & ASSOCIATES
Chartered Accountants Firms Registration No: 011798N
Sd/-
Bishamver Kumar Karn
Membership No: 094790 Partner
UDIN: 20094790AAAAAQ5977
Place: New Delhi Date: 29 July 2020
+91-9892691696
