Lords Chemicals Ltd Auditor Reports

Independent Auditors Report

To the Members of

LORDS CHEMICALS LIMITED

Report on the Audit of the Standalone Financial Statements

Qualified Opinion

We have audited the accompanying standalone financial statement of LORDS CHEMICALS LIMITED ("The Company"), which comprises the Balance Sheet as at March 31, 2025, and the Statement of Profit and Loss and the statement of cash flows for the year ended on that date, 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 possible effects of the matters described in the Basis for Qualified Opinion section of our report, the aforesaid standalone financial statements, give the information required by the Company 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 of the state of affairs of the Company as at March 31, 2025; and of the loss, its cash flows for the year ended on that date;

Basis for Qualified opinion

• In the Ind AS financial statements where in management has considered outstanding trade receivables for Rs 88,17,653/-, advance to Related Party for Rs 85,23,55,181/- and advance to suppliers for Rs 7,50,000/- as good and fully recoverable as at the balance sheet date. No provision has been made against these overdue amounts, and no sufficient audit evidence has been provided to demonstrate their recoverability Due to confirmations being not available and pending reconciliation adjustments of most of the party we are unable to comment on their recoverability of these receivable advance and its consequential effect on these financial statements.

• We draw attention to Note no 15 to the Ind AS financial statements regarding substantial amount of statutory due related to income tax, Excise duty, dividend tax, amounting to Rs 1,60,69,319/- which were outstanding as at the balance sheet date for a significant period. In our opinion, non-payment of these statutory dues may attract penal interest and penalties, the impact of which has not been quantified by the Company. The Companys non- compliance with applicable tax laws in this respect is not in accordance with the requirements ofthe Companies Act, 2013. Had such impact been appropriately provided for, the loss for the year and the liabilities as at the balance sheet date would have been higher to the extent of such interest and penalties.

• We draw attention to note no 8 to the Ind AS Financial Statements regarding the non-realization of Other Current Assets Totaling to Rs.5,99,86,923/-. In the absence of adequate supporting documentation and evidence of subsequent realization, we are unable to comment on the recoverability of these balances. Further, no provision for potential impairment has been recognized by the Company in accordance with the requirements of Ind AS 109. Had adequate provision been made, the loss for the year and the liabilities would have been higher and the Other Current Assets would have been lower to the extent of the impairment required.

• We draw attention to Note no. 19 to the Ind AS Financial statements regarding opening stock for Rs. 455127.78/- (Kyanite ore) are carried in the balance sheet. The Company has not provided any documentary evidence or certification to substantiate its physical existence as on 1st April 2024. Further, while therejias been a change in the stock position during the year, no detailed reconciliation or stock movement record were furnished to us for verification

As informed to us, physical verification of inventories was carried out by the mining department from time to time as and when required, but not specifically with reference to the balance sheet date. The management has not independently conducted or supervised the physical verification.

• We draw attention to Note 36 to the financial statements, which indicates that the Company has been substantially closing its operations since last four years. There is material uncertainty regarding Companys ability to continue as a going concern. The management has not provided a comprehensive assessment of the companys ability to continue as a going concern, nor presented any definitive plans to address such uncertainty. These conditions indicate that the existence of material uncertainty that may cast significant doubt about Companys ability to continue as going concern.

• No provision has been made for short term and long term benefits payable to employees. Quantification of the impact of the same in not possible in the absence of actuarial valuation of the same as on 31.03.2025.

• We draw attention to Note no. 52 to the financial statements, which describes that the Company has continued to make rental payments for a branch office premises despite the lease agreement having expired on 31st March 2022. As stated in the note, the premises is not currently occupied or used by the Company, and no formal agreement or documented business purpose has been made available to support the continued rental payments.

• As per Ind AS-1 "Presentation of Financial Statements" wherein it has been explained by the management that the financial statements have been prepared on Going Concern Basis. Notwithstanding the fact that the company has eroded its net worth and has substantial amount of accumulated loss of past years and huge outstanding of Statutory Dues and on the basis of financial ratios, expected dates of realization of assets and payment of financial liabilities, other information accompanying the financial statements which raises significant concern over the Going Concern ability of the Company.

• We draw attention to Note 38 of the financial statements, which describes the basis on which the Company has not recognized any Expected Credit Loss (ECL) on trade receivables, as the bad debts have already been written off in the year 2022-23 and the remaining receivables are considered fully recoverable.

• We draw attention to Note 39 the fact that the Company has not carried out 17 testing of its Property, Plant and Equipment (PPE) in accordance with the requirements of Ind AS 36-Impairment of Assets, despite indicators of impairment being present. The Company has incurred significant losses in the past, has faced continued financial stress.

• We draw attention to note no 40 to the Ind AS Non-Current Investment for Rs. 3,22,00,000.00. Irrespective of having Associates Company viz. Mahabir Coke Industries Private Limited the holding company does not prepare a consolidated financial statement. Also management has not conducted any impairment assessment for such investment despite of strong indicators existing for impairment assessment, as required by the Ind As 36, ‘Impairment of Assets. However, when asked about the proper document of the investment party fails to provide the same also there is no management certification of the existence or value of the Investment.

• The final dividend declared for FY 2011-12 of Rs.62,65,000.00/-, FY 2010-11 of Rs. 1,34,117.60/- and FY 2009-10 of Rs.66,808.50/- has not yet been transferred to Investors Education Protection Fund Account as per the requirement of section 124(5) of the Company Act, 2013. Further the Company has not yet transferred the interest to Special Dividend account as per requirement of section 124(5) of the Companies Act, 2013.

• We draw attention to Note No 42 to the Ind AS financial where company carrying bank balance but no documents received in support of this as below:

Bank Name	Closing Balance (As on 31/03/2025)
1. BANK OF INDIA	11,000.00
2. BANK OF INDIA	4382.16
(Amount has been transferred to Dormant Account)
3. BANK OF INDIA	10000.00
(Amount has been transferred to Dormant Account)
4. HDFC BANK	15.85
5. HDFC BANK (DIVIDEND A/C)	66,808.50
6. HDFC BANK (DIVIDEND A/C)	1,34,117.60
7. SOUTH INDIAN BANK	410.18
8. THE FEDERAL BANK LTD	5,792.06
9. HDFC Bank-Burrabazar	936.45

We have sent every respective bank a letter to confirm the balance of each account mentioned above but we havent received any confirmation from the bank.

• We draw attention to Note No 43 of the Statements, wherein the Company has not complied with the rules and regulations of Bombay Stock Exchange, Calcutta Stock Exchange and Jaipur Stock Exchange, which may, in future, levy heavy penalties on the Company.

• The Company received a public notice from Bombay Stock Exchange regarding delisting of its securities from the stock exchange on 25^th September, 2024. In reply the company has started filing the pending Annual Returns, Audit Reports and Limited Review reports from May 2025. The Bombay Stock Exchange has also halted trading of the companies securities since 2013.

• The Company has changed its primary line of business operations during the year-initially from mining and trading in Kyanite to grocery trading-without obtaining any specific board or shareholder resolution or documented policy approval supporting such change. Further, no intimation or disclosure regarding this change in business activity has been made to the Stock Exchange as required under Regulation 30 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015.

Additionally, the Company has ceased its mining operations during the year pursuant to the cancellation of its mining license, but no disclosure regarding this development has been placed on record or reported to the Stock Exchange.

• We draw attention to Note no. 44 wherein the company had reclassified certain items from Consumable Stock to Finished Goods in the financial year 2022-23; however, no formal accounting policy or Board approved documentation supporting this change was provided to us for review.

Also, company has changed its business to trading of grocery and farm produce items, so it can be expected that in future company will keep stock of farm produces only.

• We draw attention to Note no. 45 wherein the company has not complied with various regulatory requirements, including certain provisions of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, the Income Tax Act, 1961, and the filing requirements under the Companies Act, 2013 as the ROC Filings are pending.

• The company has not completed its limited review for the quarters ended on 30^th June 2024,30^th September 2024 and 31^s December 2024 within the timelines prescribed under the Listing Regulations. The Company approached us only in May 2025 to undertake this statutory audit along with pending limited revjewe to this delay, certain records and key personnel were not available, further limiting our ability to/bbt^ji2i^^^nt appropriate audit evidence.

• We draw attention to Note no. 48 wherein the company has not provided the Secretarial Audit Report and Corporate Governance Report for the year ended 31^st March 2025, which are mandatory for a listed entity under applicable provisions of the Companies Act, 2013 and SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 and related rules.

• The GST registration of Kolkata office of the company was suspended by the GST department with effect from 13/08/2024 vide notice no. ZA190824027295A dated 13/08/2024 for non-filing of returns over a period of 6 months. However the GST department revoked the suspension order on 21/10/2024 as the company filed all the pending returns.

• In certain cases, we observed that Tax deducted at Source (TDS) has not been deducted by the company under section 194J for payment of professional fees and Legal and Professional fees. Same is in contravention of the provisions of chapter XVII of Income -tax Act, 1961 which mandates deduction of tax at source at earlier of booking or payment.

• The Company has delayed in filling of its quarterly and annual/year to date results with Security and Exchange Board of India "SEBI". The Company has not taken any provision related to penalty on account of such delay and management is now planning to seek relief against such penalty from SEBI.

• The tenure of Nishita Shah, an Independent Director, expired on 31st January 2024. Consequently, from 1st February 2024, the Board of Directors was not constituted in accordance with the provisions of Section 149 of the Companies Act, 2013 and SEBI (LODR) Regulations, as the Company did not have a woman director and the composition of the Board did not include at least 50% Independent Directors, as required.

• We draw attention to Note no. 51 of the Standalone Financial Statements, Lords Chemicals Limited ("the Company") did not held its annual general meetings for last 2 years. The company had not applied for any extension for these annual general meeting to the Registrar of Companies and Regional Director of West Bengal and has not taken any provision related to penalty and other implications due to delay in holding of annual general meeting. The annual general meeting of financial year 2024-25 has also not been held, although the due date has not expired yet.

Further, the Company also delayed in filling of its quarterly and annual/year to date results with Security and Exchange Board of India "SEBI". The Company has not taken any provision related to penalty on account of such delay and management is now planning to seek relief against such penalty from SEBI.

• The accompanying financial statements for the year ended 31^st March 2025 have been approved by the Board of Directors but have not been adopted by the shareholders in the Annual General Meeting, as the Company has not held the AGM for the said year as required under section 96 of the Companies Act, 2013. Our Audit report is issued on the financial statements as approved by the Board of Directors.

• We draw attention to the point, wherein the position of the whole time Company Secretary were vacant in the company and such vacancy has only been filled by the management in May 2025.

• We draw attention to Note no. 50 wherein the Company has not implemented or maintained the Edit Log feature in its accounting software as mandated under Rule 3(1) of the Companies (Accounts) Rules, 2014, as amended vide Notification dated 24^th March 2021 and 31^s* March 2022. No trail of user-wise changes was made available for our verification.

The impact of above matters on the accompanying Standalone Financial Statements is presently not ascertainable.

We conducted our audit of the Standalone Financial Statements in accordance with the Standards on Auditing (SAs), as specified under section 143(10) of the Companies Act, 2013, as amended ("the Act"). Our responsibilities under those Standards are further described in the "Auditors Responsibilities for the Audit of the Standalone Finandafpf^ Statements" section of our report. We are independent of the Company in accordance with the Code of EthicsjsSuecT by the Institute of Chartered Accountants of India together with the ethical requirements that are re levant to our, audit of the Standalone Financial Statements under the provisions of the Act and the Rules there under, and wellbave "qp fulfilled our other ethical responsibilities in accordance with these requirements and the Code of Ethics. w^Qlieve\

that the audit evidence obtained by us is sufficient and appropriate to provide a basis for our qualified audit opinion on the Standalone Financial Statements.

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 matter described below to be the key audit matter to be communicated in our report.

Related party transactions

See note 24 to the standalone financial statements

The key audit matter	How the matter was addressed in our audit
We identified the accuracy and completeness of disclosure of related party transactions as set out in respective notes to the standalone Ind AS financial statements as a key audit matter due to:	Our procedures in relation to the disclosure of related party transactions included:
The significance of transactions with related parties during the year ended March 31,2025.	Obtaining an understanding of the Companys policies and procedures in respect of the capturing of related party transactions and how management ensures all transactions and balances with related parties have been disclosed in the standalone Ind AS financial statements.
	1. Obtaining an understanding of the Companys policies and procedures in respect of evaluating arms-Length pricing and approval process by the audit committee and the board of directors.
	2. Agreeing the amounts disclosed to underlying documentation and reading relevant agreements, evaluation of arms-length, on as ample basis, as part of our evaluation of the disclosure.

Tax litigations-provisions and contingencies

See note 25 to the standalone financial statements

The key audit matter	How the matter was addressed in our audit
The Company is involved in several ongoing direct and indirect tax litigations sufficient appropriate audit evidence:	We have applied the following audit procedures in this area, among others to obtain
A disclosure for contingent liabilities is made where there is a possible obligation or a present obligation that may probably not require an outflow of resources. When there is a possible or a present obligation where the likelihood of outflow of resources is remote, no provision or disclosure is made.	1. We tested the effectiveness of key controls around the recording and assessment of tax provisions and contingent liabilities.
We have identified tax litigations, provisions and contingencies as a key audit matter because it requires the management to make judgments and estimates in relation to the exposure arising out of litigations. The key judgment lies in the estimation of provisions where they may differ from the future obligations. The Company operates under several tax laws and some of these have a significant impact on the financial statements of the Company.	2. We assessed the value of the provisions and nature of the exposures, applicable regulations and related correspondences with the authorities.
	3. We assessed the relevant historical and recent judgments passed by the court authorities.
	4. Obtained Managements assessment of the open cases and compared to assess the reasonableness of the provision or contingency.
	5. Considered the adequacy of the Companys disclosures made in relation to taxation related provisions and contingencies in the financial statements.

Information other than the financial statements and auditors report thereon

The Companys board of directors is responsible for the preparation of the other information. The other information comprises the information included in the Boards Report including Annexures to Boards Report, Business Responsibility Report but does not include the IND AS financial statements and our auditors report thereon.

Our opinion on the IND AS financial statement does not cover the other information and we do not express any form of assurance conclusion thereon.

In connection with our audit of the IND AS financial statement, 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.

As the Company did not provide us with the Directors report (including the annexure to Directors report), we are unable to perform Corporate Governance and management Discussion and analysis, and conclude that there is a material misstatement therein or not, we are required to communicate the matter to those charged with governance as required under SA720.

Managements Responsibility and Those charged with Governance for the Financial Statement

The Companys Board of Directors is responsible for the matters in section 134(5) of the Companies Atsf^Tl 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 Rule 7 of the Companies (Accounts) Rules, 2014. This responsibility also includes the maintenance of adequate accounting records in accordance with the provision of the Act for safeguarding of the assets of the Company and for preventing and detecting the 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 internal financial control, that were operating effectively for ensuring the 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 IND AS financial statement, management is responsible for assessing the Companys ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless management either intends to liquidate the Company or to cease operations, or has no realistic alternative but to do so.

The board of directors are also responsible for overseeing the Companys financial reporting process.

Auditors Responsibility for the Audit of the Financial Statements

Our objectives are to obtain reasonable assurance about whether the IND AS financial statement as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditors report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with SAs will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these IND AS financial statement.

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

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

• Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances. Under section 143(3)(i) of the Companies Act, 2013, we are also responsible for expressing our opinion on whether the company has adequate internal financial controls system in place and the operating effectiveness of such controls.

• 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 IND AS financial statement 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 IND AS financial statement, including the disclosures, and whether the IND AS financial statement 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 aggregated to probable that the economic decisions of a reasonably knowledgeable user of the financial statements may berinfluenfcef. We consider quantitative materiality and qualitative factors in (i) planning the scope of our audit work and 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 IND AS financial statement 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 the 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 (11) of section 143 of the Companies Act 2013, We give in the Annexure A on the matters specified in paragraph 3 & 4 of the order.

2) 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) Except for the possible effects of the matters described in basis of opinion section above, in our opinion 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) The Balance Sheet and the Statement of Profit and Loss, and the cash flow statement dealt with by this Report are in agreement with the books of account.

d) Except for the possible effects of the matters described in basis of qualified opinion section above, in our opinion, the aforesaid standalone financial statements comply with the Accounting Standards. Specified under Section 133 of the Act, read with Rule 7 of the Companies (Accounts) Rules, 2014.

e) On the basis of written representations received from the directors as on 31 March, 2025, taken on record by the Board of Directors, none of the directors is disqualified as on 31 March, 2025, 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 B". Our report expresses an unmodified opinion on the adequacy and operating effectiveness of the companys internal financial controls over financial reporting.

g) With respect to the other matters to be included in the Auditors Report in accordance with the requirements of section 197(16) of the Act, as amended, in our opinion and to the best of our information and according to the explanations given to us, the remuneration paid by the Company to its directors during the year is not in accordance with the provisions of section 197 of the Act. The Company has not obtained approval from shareholders for payment of remuneration to directors in the year of loss, which is in contravention of section 197 of the act.

h) 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 disclosed the impact of pending litigation on its financial position in itS-Mlftiitfoae financial statement. (Refer Note No 26 to the financial statements)

ii. The Company did not have any long-term contracts including derivative contra^.for whidif$hjae/j were any material foreseeable losses.

iii. The final dividend declared of Rs. 62,65,000.00/- has not yet been transferred, to the Investor Education and Protection Fund by the Company.

i) The matters described in the basis for opinion section above and material uncertainty related to going concern section above , in our opinion, may have an adverse effect on the functioning of the company.

j) Based on our examination which include test checks, except for the instances mentioned below, the company has not used accounting software for maintaining its Books of Accounts, which have a feature of recording Audit trail (Edit Log) facility and the same has operated throughout the year for all relevant transactions are recorded in the respective software.

k) Based on our examinations and information provided to us, the company has not maintained the minutes books as per the provisions of the applicable statute.

l) Based on our examinations and information provided to us, the company has not fulfilled all the BSE compliances including the formation of Sub Committees and appointment of Independent Director as per requirement of LODR Agreement.

m) During the course of Audit, the company has not provided us with the Secretarial Report, with is mandatory for the company to maintain.

	For Rajesh Jalan & Associates
	Chartered Accountants
Place : Kolkata
Date : 16.06.2025
	ESjeshrJalan)
	v j Partner
	(Firm Registration No.: 326370E)
	UDIN-25065792BMJBSC2815

The Annexure A referred to in paragraph 1 of the Our Report of even date to the members of M/s LORDS CHEMICALS LIMITED on the accounts of the company for the year ended 31^st March, 2025.

On the basis of such checks as we considered appropriate and according to the information and explanation given to us during the course of our audit, we report that:

1) (a) (i) The Company has maintained proper records showing full particulars including quantitative details and situation of Property, Plant and Equipment and relevant details of right of use assets.

(ii) The Company has also maintained proper records showing full particulars of its intangible assets, including details of useful life and amortization, as applicable.

(b) As explained to us, and the record of the company examined by us, the property, plant and equipment have been physically verified by the management in periodical manners reasonable intervals; no material discrepancies were noticed on such verification.

(c) According to the information and explanations given to us and on the basis of our examination of the records of the Company, the title deeids of all the immovable properties (other than properties where the Company is the lessee and the lease agreements are duly executed in favour of the lessee) disclosed in the financial statements are held in the name of the Company as at the balance sheet date.

(d) The Company has not revalued any of its Property, Plant and Equipment (including right-of-use assets) and intangible assets during the year.

(e) No proceedings have been initiated during the year or are pending against the Company as at March 31, 2025 for holding any benami property under the Benami Transactions (Prohibition)

Act, 1988 and rules made thereunder.

2) (a) As explained to us, inventories were physically verified after the year end by the management, while further discussion with the party about the physical presence of opening stock for Rs.4,55,127/- (Kyanite ore) we did not get proper document and certificate on this.

(b) During any point of time of the year, the company has not been sanctioned any working capital limits, from banks or financial institutions on the basis of security of current assets. Therefore, the provisions of Clause are not applicable to the company.

3) (a) During the year the company has not made any investment and provided any guarantee or security.

However the company has given some Loans, which is interest free and prejudicial to the interest of the company as detai ed hereunder:

Name of the party	Amount Paid (Rs.)	Refund (Rs.)	Closing (Rs.)	Nature
Ajay kumar Jain	51,95,011	17,53,075	30,53,901/-	Advance
AKJ Minerals Ltd	2,07,889	2,98,398	4,02,79,164/-	Advance

(b) The company has granted loans during the year which are interest free and are prejudicial to the interest of the company.

(c) There is no agreement for loans granted/provided and hence we are not able to comment.

(d) The total amount outstanding which is not regular in serving interest is Rs.85,33 Crores.

(e) In absence of agreement we are not able to comment.

4) The company has extended Loan to its Director for Rs. 30,53,901/- during the year has violated the provision of section 185 of the Company Act 2013. Company also violate the provisos of Section 186 on which company has granted loan to related party and other in excess of the permission allowed in the Act as below:

Total share capital Rs. 125300000/- @ 60% = Rs.7,51,80,000/-, total Reserve Rs. 76,70,20,690.31/- @ 100% Rs. 76,70,20,690,31/- higher of them. Eligible amount Rs. 76,70,20,690.31/-.

Total loan outstanding during the year for Rs. 85,32,92,531.00/-

5) The Company has taken advances from customers which were outstanding for more than-ofye veal amounting to Rs. 75,10,600/-, in terms of Section 73 of Companies Act, 2013 reatflHpgether Companies (Acceptance of Deposits) Rules, 2014, (Rule 2(1) (Xii) (a)), such advances liabilities treated as deposits and hence the company is in violation of the same. Except for compliance with the aforesaid amount, 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) We have broadly reviewed the Turnover which is less than 35 Crore hence the provision of the said order about cost records is not applicable.

7) a) According to the information and explanations given to us, the Company is generally regular in depositing undisputed statutory dues, including provident fund, employees state insurance, sales tax, income tax, wealth tax, service tax, duty of customs, duty of excise, value added tax, cess and other statutory dues, as applicable, with the appropriate authorities except as below:

Nature of payment	Amount	Remarks
Sales Tax	3348611.00	Pending
Central Excise Duty Service Tax & Interest	9760564.90	Pending
Dividend Tax	2032680.00	Pending
Entry Tax	210372.00	Pending
Dividend	6465926.10	Pending
Service Tax	719081.00	Pending

b) The particulars of dues of sales tax, income tax, wealth tax, service tax, duty of customs, duty of excise, value added tax and cess as applicable as at 31st March 2025 which have not been deposited on account of a dispute are as follows

Name of the Statute	Nature of Dues	Amount Involved (in thousand)	Period to which The amount relates	Forum where Dispute is Pending
Income Tax Act, 1961	Income Tax	125.93	FY 2007-08	Assessing Officer
Income Tax Act, 1961	Income Tax	885.23	FY 2008-09	Assessing Officer
Income Tax Act, 1961	Income Tax	2542.46	FY 2009-10	Rectification
Income Tax Act, 1961	Income Tax	81.37	FY 2011-12	Assessing Officer
Income Tax Act, 1961	Income Tax	22879.55	FY 2012-13	CIT Appeal, Kolkata
Income Tax Act, 1961	Income Tax	14039.02	FY 2013-14	CIT Appeal, Kolkata
Income Tax Act, 1961	Income Tax	5575.30	FY 2016-17	Assessing Officer
Income Tax Act, 1961	Income Tax	2409.31	FY 2022-23	Assessing Officer
The Central Excise Act, 1944	Central Excise	18968.13	FY 2010-11	Appeal -11, Commissionerate, Kolkata

8) As explained and informed us there was no transactions of unrecorded income that have been surrendered or disclosed as income during the year in the tax assessment under the Income Tax Act, 1961 (43of 1961).

9) a) According to the information and explanations given to us, the company has not taken any loans or advances from any Bank or Financial institutions in the current years.

b) In our opinion and according to the information and explanation given to us, the company has progress money by way of term loans during the year and there has been no utilization during the current years of the term loans obtained by the company during any previous years. Accordingly, reporting under clauses 40&)(d of the order is not applicable to the company.

c) In our opinion and according to the information and explanation given to us, the company has not raised any funds on short term basis during the year or in any previous years. Accordingly, Reporting under clauses 3(ix)(d) of the order is not applicable to the company.

d) According to the information and explanations given to us and on an overall examination of the financial statements of the company, the Company has not taken any funds from any entity or person on account of or to meet the obligation of its subsidiaries.

e) According to the information and explanations given to us, the company has not raised any loans during the year on the pledge of securities held in its subsidiaries.

10) The company have not issued any fresh security by way of Initial public offer or private placement or Further Public offer, and hence clause not applicable.

11) (a) Based upon the audit procedures performed and the information and explanations given to us, no fraud by the Company and no material fraud on the company by its officers or employees has been noticed or reported during the year.

(b) As per clause (a) & (b) is not applicable.

(c) As informed by the management no whistleblower complaints received by the company during the year.

12) In our opinion, the Company is not a Nidhi Company. Therefore, the provisions of clause (12) of the Order are not applicable to the Company.

13) In our opinion, and according to the information and explanation given to us, company has not complied with section 177 of Companies Act, 2013. Disclosure of related party transaction under section 188 of Companies Act, 2013 has been given in financial statement as per the applicable accounting standards.

14) a) In our opinion and according to the information and explanations given to us, the company has an internal audit system as required under section 138 of the Act which is Commensurate with the size and nature of its business.

b) We could not consider the reports issued by the internal auditors of the company till date for the period under audit as we were not provided the Internal Audit Report.

15) In our opinion during the year the Company has not entered into any non-cash transactions with its Directors or persons connected with its directors and hence provisions of section 192 of the Companies Act, 2013 are not applicable to the Company

16) In our opinion, the company is not required to be registered under section 45 LA of the Reserve Bank of India Act, 1934 and accordingly, die provisions of clause (a), (b) & (c) of the Order are not applicable to the Company and hence not commented upon.

d) As informed to us there is no core Investment company within the group, hence provisions of the clause not applicable.

17) The company have incurred cash loss during the year and also in immediately preceeding financial year.

18) On the basis of the financial ratios, ageing and expected dates of realization of financial assets and payment of financial liabilities, other information accompanying the financial statements and our knowledge of the Board of Directors and Management plans and based on our examination of the evidence supporting the assumptions, nothing has come to our attention, which causes us to believe that any material uncertainty exists as on the date of the audit report indicating that Company is not capable of meeting its liabilities existing at the date of balance sheet as and when they fall due within a period of one year from the balance sheet date. We, however, state that this is not an assurance as to the future viability of the Company. We further state that our reporting is based on the facts up to the date of the audit report and we neither give any guarantee nor any assurance that all liabilities falling due within a period of one year from the balance sheet date, will get discharged by the Company as and when they fall due.

19) According to the information and explanations given to us, the Company does not have anwunspeiit-ajpouiU in

respect of any ongoing or other than ongoing project as at the expiry of the financial year. Aj&ormngly, xep(>rang under clause 3(xx) of the Order is not applicable to the Company. jt^ olkatsj^fl

\U\ 7l7yW/

20) The reporting under clause 3(xxi) of the Order is not applicable in respect of audit of standalone financial statements of the Company. Accordingly, no comment has been included in respect of said clause under this report.

	For Rajesh Jalan & Associates
	Chartered Accountants
	Firm Regd. No-3 263 70E
	( RVjeshdapi)
	Partner
	(Firm Registration NST326370E)
	UDIN - 25065792BMJBSC2815
Place : Kolkata
Date : 16.06.2025

"Annexure B" to the Independent Auditors Report of even date on the Financial Statements of M/s LORDS CHEMICALS LIMITED

Report on the Internal Financial Controls 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 LORDS CHEMICALS LIMITED ("the Company") as of March 31, 2023 in conjunction with our audit of the Ind AS financial statements of the Company for the year ended on that date.

Managements Responsibility for Internal Financial Controls

The Companys management is responsible for establishing and maintaining internal financial controls based on the internal control over financial reporting criteria established by the Company considering the essential components of internal control stated in the Guidance Note on Audit of Internal Financial Controls over Financial Reporting issued by the Institute of Chartered Accountants of India". 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 deemed to be prescribed under section 143(10) of the Companies Act, 2013, to the extent applicable to an audit of internal financial controls, both applicable to an audit of Internal Financial Controls and, both issued by the Institute of Chartered Accountants of India. Those Standards and the Guidance Note require that we comply with ethical requirements and plan and perform the audit to obtain reasonable assurance about whether adequate internal financial controls over financial reporting was established and maintained and if such controls operated effectively in all material respects.

Our audit involves performing procedures to obtain audit evidence about the adequacy of the internal financial controls system over financial reporting and their operating effectiveness. Our audit of internal financial controls over financial reporting included obtaining an understanding of internal financial controls over financial reporting, assessing the risk that a material weakness exists, and testing and evaluating the design and operating effectiveness of internal control based on the assessed risk. The procedures selected depend on the auditors judgment, including the assessment of the risks of material misstatement of the financial statements, whether due to fraud or error.

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion on the Companys internal financial controls system over financial reporting except note given in Audit Report in opinion paragraph and emphasis of Matter.

Meaning of Internal Financial Controls over Financial Reporting

A companys internal financial control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles. A companys internal financial control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the company; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the company are being made only in accordance with authorizations of management and directors of the company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the companys assets that could have a material effect on the financial statements.

Basis for Opinion

According to information and explanation given to us and based on our audit, the following material weakness have been identified in the effectiveness of the Companys internal financial controls over financing reporting as at March 31,2025:

a) Refer to Note 5 and 7 of the financial statements, in respect of long outstanding overdue trade receivables and advance, whereby evidences of control over monitoring/assessing recoverability of such over dues, including assessment of provision of provision for doubtful trade receivables and advances were not operation effectively. This could potentially result in the company not recognizing a provision for doubtful/old overdue trade receivables.

b) The Companys internal controls over updating the customers/ vendors master data with present addresses were operating moderately.

c) The Companys internal financial controls over timely recording of journal entries were operating moderately. We have observed delays in recording of the entries which potentially results in delay of preparation of financial statements.

In our opinion, the Company has, in all material respects, an adequate internal financial controls system over financial reporting and such internal financial controls over financial reporting were operating effectively as at March 31, 2025, based on the internal control over financial reporting criteria established by the Company considering the essential components of internal control statedin the Guidance Note on Audit of Internal Financial Controls Over Financial Reporting issued by the Institute of Chartered Accountants of India"

	For Rajesh Jalan& Associates
	Chartered Accountants
	Firm Registration No.: 326370E
	Rajfesh Jalani
	UDIN - 25065792BMJBSC2815
Place : Kolkata
Date : 16.06.2025