Mideast Integrated Steels Ltd Auditor Reports

To The Members of Mideast Integrated Steel Limited Report on the audit of standalone Financial Statements Qualified Opinion

1. We have audited the accompanying standalone financial statements of M/s Mideast Integrated Steel (" the Company") which comprises the Balance Sheet as at March 31, 2025, the Statement of Profit and Loss (Including other Comprehensive Income), the Statement of Changes in Equity and the Statement of Cash Flows for the year ended on that date, and the summary of the significant accounting policies and other explanatory information (hereinafter referred to as "the standalone financial statements").

2. In our opinion and to the best of our information and according to the explanations given to us, except for the effects of the matter described in the Basis for Qualified Opinion section of our report, the aforesaid standalone financial statements give the information required by the Companies Act, 2013 (*the Act) in the manner so required and give a true and fair view, in conformity with the Indian Accounting Standards prescribed under section 133 of the Act read with the Companies (Indian Accounting Standards) Rules, 2015, as amended, ("Ind AS") and other accounting principles generally accepted in India, of the state of affairs of the Company as at March 31, 2025, and total comprehensive loss (comprising of the loss and other comprehensive loss), changes in equity and its cash flows for the year ended on that date.

Basis for Qualified Opinion

3. We conducted our audit of the standalone financial statements in accordance with the Standards on Auditing specified under section 143(10) of the Act (SAs). Our responsibilities under those Standards are further described in the Auditors Responsibilities for the Audit of the Standalone Financial Statements section of our report. We are independent of the Company in accordance with the Code of Ethics issued by the Institute of Chartered Accountants of India (ICAI) together with the independence requirements that are relevant to our audit of the standalone financial statements under the provisions of the Act and the Rules made thereunder, and we have fulfilled our other ethical responsibilities in accordance with these requirements and the ICAls Code of Ethics. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our qualified audit opinion on the standalone financial statements.

Qualifications in the Audit Report

1) The Company is carrying Fixed Assets worth Rs. 1562.01 Cr as on 31^st March 2025 being the Gross acquisition value. However, no insurance cover is taken by the company during the F.Y. 2024-25 and as a result the assets of the company are exposed to high risk of fire/burglary/earthquake/natural calamities etc.

2) The balances receivable of Rs. 81.55 Crores as on 31^st March 2025 out of which RP Receivable is Rs. 17.92 Crores of Maithan Ispat Limited as compared to Rs. 44.98 Cr as on 31.03.2024. However, the company has for the remaining non-moving debtors neither made any provision nor initiated any litigation. Also, the impairment testing has not been performed for the non-moving debtors, hence we cannot comment upon the actual recoverability from the reported trade receivable. Further, the balance confirmation from related parties has been received, however balance confirmation from non-related parties is not received.

3) Physical copies of deposits have not been provided to us by the company. Hence, we cannot comment upon the genuineness of the deposits. We have found that few Fixed deposits are in the name of Individuals but the same are recorded in the assets of the company. Further, we have not received direct bank confirmations from the Banks for the current accounts and fixed deposits and interest on fixed deposits. However, the company has provided us duly certified bank statements in majority of the cases except mentioned below: -

S.No Bank Name	Type	Account No.	Balance as per books 31.03.2025 (Rs)
1. UCO BANK	CA-RWA	20990210000038	4,657.43
2. ICICI BANK LIMITED	CA-Dividend	0011050247S9	2,50,01,091.75

4) The company has Tax & Regulatory due payable amounting to Rs. 71.83 crores as on 31st March, 2025.Out of total dues Rs. 71.34 Cr is disputed Dues as per the Management Representation letter given by the Company. Disputed dues are in respect of Central Excise, Service Tax, Sales Tax, VAT, Welfare Cess, Work Contract Tax, Professional Tax, TDS, TCS District Mineral Fund, National Mineral Fund, Provident Fund, Royalty, User Fee & GST have not been deposited with appropriate authorities.

Further The Goods & Service Tax (GST) returns have not been filed by the Company since November 2020 and GST of Delhi (ISD Return) and Odissa also got suspended during the year by the department and company is also not able to pay its GST liability on RCM which is Rs.0 .42 Cr of current year which includes to total dues mentioned above.

5) In pursuance to the judgement dated 2nd August, 2017 of Honorable Supreme Court of India, in the matter of Writ Petition (Civil) No. 114 of 2014 between Common Cause v/s Union of India & Others, there is a compensation imposed of Rs 924.75 crores along with interest on the company for excess production of Iron Ore during 2000-01 to 2010-11. The Company was supposed to make the payment of this compensation along with the interest on or before 31st December 2017, failing which the mines of the Company are closed down w. e. f 1st January 2018. The Company has filed a Curative petition (Civil) on 28th March 2018, before the Honorable Supreme Court of India challenging the Judgement and which we have been informed is still pending. Hence, the company has not made provision for the same in the books of accounts. However, in our opinion since this compensation has been crystalized and accordingly, a provision for this liability should have been made in the books. Management has confirmed over mail that Rs. 415.79 crores have been deposited against the order.

Further Hon?ble Supreme Court through its order dated 10.07.2023 has ordered State Government to takeover and sell the iron ore in question and give credit of the sale amounts to the SPV. After this order OMC (appointed by State Govt.) took over Materials of 2, 45,958 MT and during the year under72 review, OMC has sold 1,12,128 MT amounting to Rs. 53,85,72,720

Further, based on the financials company is not having any business activity to generate the revenue in future and also after considering the provision for the above liability the net worth of the company would be negative, considering the same company may not be a going concern.

6) MISL has advances received from customers amounting to Rs. 335.58 Crores as on 31st March, 2025. Out of which no movement in the major proportion of advances for more than 365 days. Since, the advances has not been appropriated against supply of goods or provision of services within a period of three hundred and sixty-five days (365 days) from the date of acceptance of such advance. Hence, the same will be treated as deposit as per the as per the rule 2 (c) (xii) (a) of companies Act and should be disclosed while filling the DPT-3.

7) Hon?ble Supreme Court through its order dated 10.07.2023 has ordered State Government to takeover and sell the iron ore in question and give credit of the sale amounts to the SPV. After this order OMC (appointed by State Govt.) has taken over Materials of 2, 45,958 MT. Further during the year under review, out of total stocks OMC sold 1,12,128 MT amounting to Rs. 53,85,72,720 up to 31.03.2025. The Company has booked an income of Rs. 53.86 crores and book OMC as debtor for the same amount because no supporting documents/Invoices has been received by from the OMC.

Emphasis of Matter in the Audit Report of the Holding Company-Mideast Integrated Steels Limited

1) An application under Section 9 of the Arbitration and Conciliation Act, 1996 (as amended) has been filed by SREI Equipment Finance Limited, in August 2021, in relation to a Loan-Cum- Hypothecation Agreement dated 8 September 2016, whereby the Company had taken a loan for purchase of a Mesco Crusher 600 TPH Engine amounting to Rs.7.92 crores. The petitioner has claimed an outstanding sum of Rs.4.40 crores in the said application. The Company?s books of accounts show a liability of Rs 3.67 crores as at 31^st March, 2023. The matter was pending before Sole Arbitrator and by an order dated 11^th August, 2023 the Learned National Company Law Tribunal (Kolkata Bench) has allow a Resolution Plan filed by one NARCL (National Asset Reconstruction Company Limited). As per the proceedings of Sole arbitrator, order dated 19^th June 2024 Mesco Crusher 600 TPH Engine auctioned for Rs. 2.96 Cr and now Company?s books of accounts show a liability of Rs 0.71 crores as at 31^st March, 2025.

2) We draw attention to Note 30 of the financials, which describe Rs 718 crores plus interest, due to a party in respect of unreconciled amounts as per an arbitration award. The Company is disputing most of such claims and has filed an appeal against the arbitration award before the Bombay High Court. The same has been admitted by the High Court in December 2019. The matter is subjudice.

3) We have relied on the list of legal cases and the contingent liability, as given to us by the management. We are not aware of, nor have been informed of any other matter filed against the company.

4) Bank has deducted TDS on Fixed -Deposit @ 20% because of non-submission of PAN in Central Bank of India resultant Company is unable to claim TDS of the same.

5) As on 31st March, 2025 the company has Balances 73with government authorities amounting to Rs. 14.02 crores on account of deposit under Excise Act, VAT and Service Tax. In this regard, we have not been provided supporting document. Hence, we cannot comment on the deposits and its recoverability.

6) Company has not been able to provide the details of Creditors registered under MSME. Since, as per Company the Creditors have not provided the details w.r.t whether they are MSME registered or not. Further, as per the Company the majority of the Creditors are more than 3 years old, hence there is no interaction with these Creditors. Hence, we are unable to comment upon whether company is following the provision of MSME Act.

7) There are fixed assets shown under capital work in progress in the books of the Company Rs. 24.46 Cr, since more than 5 years. In our opinion, the Company needs to ascertain the completion date of the same and accordingly capitalize the assets where applicable.

8) During the financial year the company has had transactions with its related parties, and has a net inter-company receivables being loans and advances given amounting to Rs.201.67 Cr as at 31st March 2025 while the amount as on 31st March 2024 was Rs. 222.34 Cr. The Company has received back an amount of Rs.20.67Crores from the related parties during this period ended as on 31st March 2025. The management has not carried out the impairment assessment as required by Ind AS 36.

Hence, we cannot comment on the carrying value of these receivables, along with the related impairment, if any, and consequential impact thereof on the profit/loss for the year, had the Company performed such impairment assessment.

9) Balances of Debtors, Creditors, advances received from customers, advances given to supplier and deposits received & given are subject to confirmations and reconciliations except related party. We could not verify the reported numbers due to non-availability of sufficient information and records. Hence, we cannot comment upon the correctness of the reported numbers.

10) There is an unpaid dividend amount of Rs 2.5 crores which pertains to financial year 2013-14. The same should have been transferred into Investor Education and Protection Fund, however, has not been done by the Company. This amount is yet kept in the Unpaid Dividend account with the bank.

11) The Company have Property, Plant and Equipment (PPE) amounting to Rs. 781.07 crores as on 31st March 2025. We have not verified the assets physically. Company has provided Physical Verification report conducted by third party but Quantity mentioned in Physical Verification report does not align with Fixed Asset Register shared with us.

12) As per Rule 3(1) of the Companies (Accounts) Rules, 2014 with respect to audit trail and edit log, the Company has not used accounting software which has a feature of recording audit trail of each and every transaction, creating an edit log of each change made in the books of account along with the date when such changes were made and ensuring that the audit trail cannot be disabled.

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 74the current period. These matters were addressed in the context of our audit of the standalone financial statements, and in forming our opinion thereon, and we do not provide a separate opinion on these matters. There are no matters determined to be the key audit matters to be communicated in our report.

Information Other than the Standalone 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 Management Discussion and Analysis, Boards Report including Annexures to Boards Report. Business Responsibility Report, Corporate Governance and Shareholders Information, but does not include m standalone financial statements and our auditors report thereon. Our opinion on the standalone 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 standalone financial statements, our responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent with the standalone financial statements or our knowledge obtained during the course of our audit or otherwise appears to be materially misstated. If, based on the work we have performed, we conclude that there is a material misstatement of this other information, we are required to report that fact. Since we have not been provided with the other information, we will not be able to report on the same.

Responsibility of Management and Board of Director for the standalone annual financial results

These standalone annual financial results have been prepared on the basis of the standalone Ind AS financial statements.

The Companys Management and the Board of Directors are responsible for the preparation and presentation of these standalone annual financial results that give a true and fair view of the net profit/(loss) and other comprehensive income and other financial information in accordance with the recognition and measurement principles laid down in Indian Accounting Standards prescribed under Section 133 of the Act and other accounting principles generally accepted in India and in compliance with Regulation 33 of the Listing Regulations. 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 accounting policies; making judgments and estimates that are reasonable and prudent; and the design, implementation and maintenance of adequate internal financial controls, that were operating effectively for ensuring accuracy and completeness of the accounting records, relevant to the preparation and presentation of the standalone annual financial results that give a true and fair view and are free from material misstatement, whether due to fraud or error.

In preparing the standalone annual financial results, the Management and the Board of Directors are 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 the Board of Directors either intends to liquidate the Company or to cease operations, or has no realistic alternative but to do so.

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

Auditors Responsibilities for the Audit of the Standalone Annual Financial

Results

Our objectives are to obtain reasonable assurance about whether the standalone annual financial results 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 standalone annual financial results.

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 standalone annual financial results, 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 expressing our opinion whether the Company has adequate internal financial controls with reference to standalone annual Ind AS financial statements 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 in the standalone annual financial results made by the Management and Board of Directors.

Conclude on the appropriateness of the Management and Board of Directors 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 ability of the Company 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 standalone annual financial results 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 standalone annual financial results, including the disclosures, and whether the standalone annual financial results represent the underlying transactions and events in a manner that achieves fair presentation.

Materiality is the magnitude of misstatements in the standalone annual financial results that, individually or in aggregate, makes it probable that the economic decisions of a reasonably knowledgeable user of the standalone annual76 financial results 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 standalone annual financial results.

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.

Report on Other Legal and Regulatory Requirements

1. As required by the Companies (Auditor?s Report) Order, 2020 ("the Order") issued by Central

Government of India in term of sub-section (11) of Section 143 of the Companies Act, 2013, we enclose in "Annexure A" a statement on the matter specified in paragraphs 3 and 4 of the order.

2. As required by Section 143(3) of the Act, based on our audit, subject to the qualified opinion give above, 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) The Balance Sheet, the Statement of Profit and Loss including other comprehensive income, Statement of change in Equity and Cash Flow Statement dealt with by this Report are in agreement with the books of account.

d) In our opinion, the aforesaid standalone financial statements comply with the Ind AS specified under section 133 of the Act, read with Rule 7 of the Company (Accounts) Rule, 2014.

e) On the basis of written representations received from the directors as on 31 March, 2023 taken on record by the Board of Directors, none of the directors is disqualified as on 31 March, 2023, 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 operating effectiveness of such controls, refer to our separate report in "Annexure B".

g) With respect to the other matters to be included in the Auditor?s Report in accordance with the requirements of section 197(16) of the Act, as amended:-

In our opinion and to the best of our information and according to the explanations given to us, we report as under with respect to other matters to be included in the Auditor?s Report in accordance with the provision of section 197 of the Act.

h) With respect to the other matters to be included in the Auditor?s Report in accordance with Rule 11 of the Companies (Audit and Auditors) Rule, 2014, as amended in our opinion and to the best of our information and according to the explanations given to us, subject to the qualified opinion given above:-

i. The Company has disclosed the impact of pending litigations on its financial position in the standalone financial statement.

ii. 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 has been a delay in transferring amounts to the Investor Education and Protection Fund by the Company, of Rs. 2.50 crores pertaining to the unpaid dividends for the financial year 2013-14.

iv. a. The management has represented that, to the best of its knowledge and belief, to the standalone financial statements, no funds have been advanced or loaned or invested (either from borrowed funds or share premium or any other sources or kind of funds) by the Company to or in any other persons or entities, including foreign entities ("Intermediaries"), with the understanding, whether recorded in writing or otherwise, that the Intermediaries shall, whether, directly or indirectly lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the Company ("Ultimate Beneficiaries") or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries; and

b. The management has represented, that, to the best of its knowledge and belief, other than as disclosed in the notes to the accounts, no funds have been received by the Company from any persons or entities, including foreign entities ("Funding Parties"), with the understanding, whether recorded in writing or otherwise, that the Company shall, whether, directly or indirectly, lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the Funding Party ("Ultimate Beneficiaries") or provide any 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 their notice that has caused them to believe that the representations under sub-clause (i) and (ii) contain any material mis-statement.

v. The Company has not declared and paid any dividend during the year. Therefore, reporting in this regard is not applicable to the Company.

vi. As per Rule 3(1) of the Companies (Accounts) Rules, 2014 with respect to audit trail and edit log, based on our examination, the Company has not used accounting software which has a feature of recording audit trail of each and every transaction, creating an edit log of each change made in the books of account along with the date when such changes were made and ensuring that the audit trail cannot be disabled.

Draft Annexure - A to The Independent Auditor?s Report

Referred to in paragraph 1 under the heading ‘Report on Other Legal & Regulatory Requirement? of our report of even date to the financial statements of the Company for the year ended March as on 31^st, 2025:

(i) (a)(A) The company has provided proper records showing full particulars, including quantitative details and situation of Property, Plant and Equipment.

(B) The company does not have any intangible assets.

(b) As per the information and explanation given to us, the property, plant and equipment has been physically verified by the management during the year through a third-party Auditor.

(c) We have not been able to verify the title deeds of all the immovable properties. Further, certain assets are charged against the loans taken by the Company. However, details were not available for our verification.

(d) The company has revalued its Property, Plant and Equipment (including Right of Use assets) or intangible assets, if any, or both during the year.

(e) As per the information and explanation given to us, no proceedings have been initiated or are pending against the company for holding any Benami Property under the Benami Transactions (Prohibition) Act, 1988 (45 of 1988) and rules made thereunder. However, we have not been able to verify the same separately.

(ii) (a) As per the management certificate provided to us, Inventories has been physically verified by the management during the year through a third-party auditor.

(b) During the year, the company has not been sanctioned working capital limits in excess of five crore rupees, in aggregate, from banks or financial institutions on the basis of security of current asset.

(iii) As per the information and explanation given to us, during the year, the company has not made investments in, nor has provided guarantee or security, however has granted loans or advances in the nature of loans / advances, secured or unsecured, to companies, firms, Limited Liability Partnerships or any other parties.

The aggregate amount during the year, and balance outstanding at the balance sheet date with respect to such loans or advances to subsidiaries, joint ventures and associates and other parties is as follows:

Particulars	Loans/ Advances (In crores)	Advances in nature of loans/ advances (in crores)
Aggregate amount granted/provided during the year
Subsidiary	Nil	NIL
Other related party	Nil	NIL
Others	Nil	NIL
Balance Outstanding as at balance sheet date in respect of above cases
Subsidiary	Nil	17.91
Other related party	Nil	183.36
Others	Nil	Nil

According to information and explanation given to us, the company has, in respect of loans, investments, guarantees, and security provisions, complied with (iv) section 185 and 186 of the Companies Act, 2013.

(v) There are deposits (advance from customers against which supply of goods or provision of services has not been provided within a period 365 days from the date of receipt of advance) accepted by the company. Hence the provisions of sections 73 to 76 or any other relevant provisions of the Companies Act and the rules are applicable but the same are not complied with.

(vi) Pursuant to the rules made by the Central Government, for the maintenance of Cost Records under section 148(1) of the Companies Act, 2013 in respect of the company?s products. We are of the opinion that prima facie the prescribed accounts and records have not been maintained during the financial year as the

Plant is not in operation. Further, the Plant of the Company has not been in operation for more than 5 years.

(vii) (a) According to information and explanations given to us and on the basis of our examination of the books of account, and records, the Company has been generally regular in depositing undisputed statutory dues including Provident Fund, Employees State Insurance, Income-Tax, Sales tax, Duty of Customs, Duty of Excise, Value added Tax, Cess and any other statutory dues with the appropriate authorities. According to the information and explanations given to us, no undisputed amounts payable in respect of the above were in arrears as at March 31st, 2025 for a period of more than six months from the date on when they become payable.

(b) According to the records of the Company, the disputed dues in respect of Central Excise, Service Tax, Sales Tax, Entry Tax, Income Tax, GST & TDS as at March 31st, 2025 have not been deposited with appropriate authorities and no provision has been made for the same in the financials. Details are as follows:

Particulars	31.03.2025 (in Cr)	31.3.2024 (in Cr)
(i) Central Excise, Customs and Service Tax*	131.908	131.908
(ii) Sales Tax and Entry Tax*	27.800	27.800
(iii) Income Tax	19.39	19.39
(iv) GST*	68.53	68.53
(v) TDS	0.24	0.24
Total	269.568	269.568

*Note: The number reported in the above table has been provided by the company which are not verified by us due to non- availability of complete supporting details.

(viii) In our opinion, according to the information and explanation given to us, there is no any unrecorded income surrendered or disclosed in the income tax assessment during the year. Accordingly, reporting under clause (viii) of paragraph 3 of the Order is not applicable.

(ix) (a) The company has defaulted in repayment of disputed loans or other disputed borrowings or in the payment of disputed interest thereon to any lender. The details are as under: -

Bank/financial institution	Default Amount	Currency	Default made for the period
SREI Equipment Finance Limited	71,00,000	INR	Entire year

(b) In the absence of information, we are unable to comment if the company has been declared a wilful defaulter.

(c) As per the information and explanation given to us, no term loans were raised by the Company during the year. Accordingly, the provision stated in paragraph 3(ix)(c) of the Order is not applicable to the Company

(d) According to the information and explanation provided to us, there are no funds raised by the Company on short term basis. Accordingly, the provision stated in paragraph 3(ix)(d) of the Order is not applicable to the Company

(e) According to the information explanation given to us and on an overall examination of the standalone financial statements of the Company, we report that 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 explanations given to us and procedures performed by us, we report that the Company has not raised loans during the year on the pledge of securities held in its subsidiaries, joint ventures or associate companies.

(x) (a) The Company did not raise any money by way of initial public offer or further public offer (including debt instruments) during the year. Accordingly, the provisions stated in paragraph 3 (x)(a) of the Order are not applicable to the Company.

(b) According to the information and explanations given to us and based on our examination of the records of the Company, the Company has not made any preferential allotment or private placement of shares or fully, partly or optionally convertible debentures during the year. Accordingly, the provisions stated in paragraph 3 (x)(b) of the Order are not applicable to the Company.

(xi) (a) During the course of our examination of the books of account carried in accordance with the generally accepted auditing standards in India, we have neither come across any instance of fraud on or by the Company, either noticed or reported during the year, nor have we been informed of such case by the Management.

(b) No report under sub-section (12) of section 143 of the Companies Act has been filed by us in Form ADT-4 as prescribed under rule 13 of Companies (Audit and Auditors) Rules, 2014 with the Central Government;

(c) As per the information and explanation given to us by the management, there are no whistleblower complaints received during the year by the company. We have independently not verified the same and have relied on the management representation.

(xii) In our opinion, the Company is not a Nidhi company. Accordingly, reporting under sub clause (a), (b) and (c) of clause (xii) of paragraph 3 of the Order is not applicable.

(xiii) As per the information and explanation given to us, except for the effects of the matter described in the Basis for Qualified Opinion section of our report and in our CARO report, all transactions with the related parties are in compliance with sections 177 and 188 of Companies Act, where applicable, and the details have been disclosed in the financial statements, etc., as required by the applicable accounting standards.

(xiv) (a) As per Section 138 of the Companies Act, read with Rule 13, the Company, for the financial year 2024, is required to have an internal audit system in place. Company has appointed the internal auditor.

(b) We have considered internal audit reports issued by internal auditors during our audit.

(xv) Based upon the audit procedures performed and the information and explanations given by the management, the company has not entered into any non-cash transactions with directors or persons connected with the directors. Accordingly, the provisions of clause 3 (xv) of the Order are not applicable to the Company and hence not commented upon.

(xvi) (a) In our opinion, the Company is not required to be registered under section 45 IA of Reserve Bank of India Act, 1934 and accordingly, the provisions stated in paragraph clause 3 (xvi)(a) of the Order are not applicable to the Company.

(b) In our opinion, the Company has not conducted any Non-Banking Financial or Housing Finance activities without any valid Certificate of Registration from Reserve Bank of India. Hence, the reporting under paragraph clause 3 (xvi)(b) of the Order are not applicable to the Company.

The Company is not a Core investment Company (CIC) as defined in the (c) regulations made by Reserve Bank of India. Hence, the reporting under paragraph clause 3 (xvi)(c) of the Order are not applicable to the Company.

The Company does not have more than one CIC as a part of its group. Hence, the (d) provisions stated in paragraph clause 3 (xvi)(d) of the Order are not applicable to the Company.

(xvii) Based on the overall review of standalone financial statements, the Company has incurred cash losses of Rs.21.18 Cr in the current financial year but not in the immediately preceding financial year.

(xviii) There has been no resignation of the statutory auditors during the year. Hence, the provisions stated in paragraph clause 3 (xviii) of the Order are not applicable to the Company.

(xix) On the basis of the financial ratios, aging and expected dates of realization of financial assets and payment of financial liabilities, other information accompanying the financial statements, in the capacity of the Statutory Auditor, we are of the opinion that there may be material uncertainty which exists as on the date of the audit report that the company may not be capable of meeting its liabilities existing at the date of the balance sheet as and when they fall due within a period of one year from the balance sheet date.

(xx) As per the information and explanation given to us, there is no unspent amount to be transferred to a Fund specified in Schedule VII to the Companies Act within a period of six months of the expiry of the financial year in compliance with second proviso to sub-section (5) of section 135 of the said Act. Hence, the provisions stated in paragraph clause 3 (xx) of the Order are not applicable to the Company.

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

However, according to the information and explanations given to us, the Company holding share of other company are as mentioned below: -

S. No. Company Name	Number of Share	% of holding
1. Maithan Ispat Ltd	32,38,26,010	99.6%

For, ASHOK SHYAM & ASSOCIATES

Chartered Accountants

FRN: -011223N

(Ashok B Gupta)

Partner

Membership No.089858

UDIN: - 25089858BMLAIM7612

Place: -New Delhi

Date: 30.05.2025