iifl-logo

MMTC Ltd Auditor Reports

Add as a Preferred Source on Google
62.32
(0.35%)
Sep 3, 2026|03:59:43 PM

MMTC Ltd Share Price Auditors Report

TO THE MEMBERS OF MMTC LIMITED

Report on the Audit of the Standalone Financial Statements

Quali ed Opinion

We have audited the accompanying standalone nancial statements of MMTC Limited ("the Company"), which comprise the Balance Sheet as at March 31, 2026, the Statement of Pro t 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 notes to the nancial statements including a summary of the material accounting policies and other explanatory information (hereinafter referred to as "Standalone nancial statements"), in which are incorporated the nancial statements for the year ended on that date audited by the Branch Auditors of the Companys Regional O ces (Camp O ces) at Mumbai, Vizag, Chennai and Hyderabad.

In our opinion and to the best of our information and according to the explanations given to us, except for the e ects of the matter described in the Basis for Quali ed Opinion Section of our Report, the aforesaid standalone nancial 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 ("Ind AS") and other accounting principles generally accepted in India, of the state of a airs of the Company as at March 31, 2026, its Pro t and total comprehensive income (Comprising of net pro t and other comprehensive income), changes in equity and its cash ows for the year ended on that date.

Basis for Quali ed Opinion

1. As disclosed in Note no. 11 (Footnote- i) to the nancial statements, in respect of the Anglo Coal case, an amount of Rs. 1088.62 crore (comprising Rs.1087.76 crore deposited with the court and Rs.0.86 crore attached from the companys bank account) had been deposited with the Honble Delhi High Court. The nal determination of the amount is subject to the judgement/clari cation of the Honble Court.

The Honble Delhi High Court, vide its order dated 09.05.2025, directed that "the decree holder [Anglo] shall be entitled to withdraw the said amount along with up-to-date accrued interest after the expiry of two weeks from today". The SLP led by the company before the Honble Supreme Court was dismissed by order dated 03.11.2025.

Thereafter, the Company led an application before the Honble Delhi High Court on 03.11.2025 admitting a total liability of Rs.1169.14 crore, including interest calculated up-to 01.11.2025.

Subsequently, pursuant to the order of the Honble Delhi High Court dated 10.11.2025, an amount of Rs.1000 crore was released to Anglo on 17.11.2025.

Based on the managements calculations, the estimated remaining liability of the company towards Anglo coal as on 17.11.2025 amounts to Rs.170.58 crore, including interest calculated up to 17.11.2025.

Accordingly, the estimated present obligation of the company in respect of the aforesaid matter amounts to Rs. 170.58 crore, against which the company has recognised a provision of Rs. 87.76 crore only. This has resulted in non-recognition of provision to the extent of Rs. 82.82 crore. The company, instead of making a provision of Rs.82.82 crore, has included this amount in its contingent liabilities due to which provision has been understated and contingent liabilities have been overstated by Rs.82.82 crores.

The non-recognition of provision to the extent of Rs.82.82 crore constitutes a departure from the accounting standards as prescribed under section 133 of the Act. Had the amount of Rs.82.82 crore been provided by the company, the provisions would have been increased by Rs.82.82 crore and the net pro t and shareholders funds would have been reduced by the said amount.

We conducted our audit of the Standalone nancial statements in accordance with the Standards on Auditing ("Sas") speci ed under section 143(10) of the Act. Our responsibilities under those Standards are further described in the

Auditors Responsibilities for the Audit of the Standalone nancial statements section of our report. We are independent of the Company in accordance with the Code of Ethics issued by the Institute of Chartered Accountants of India ("ICAI") together with the ethical requirements that are relevant to our audit of the standalone nancial statements under the provisions of the Act and the Rules made thereunder, and we have ful lled our other ethical responsibilities in accordance with these requirements and the ICAIs Code of Ethics. We believe that the audit evidence obtained by us is su cient and appropriate to provide a basis for our quali ed opinion.

Material Uncertainty Related to Going Concern

We draw attention to Note No. 36(k) to the accompanying nancial statements, which states that, MMTC has been directed by administrative ministry to prepare a road map for scaling down of manpower including exit from various JVs. Also direction has been given for exit from business operation. However, wind mill business is still in operation. Government is yet to decide the exit route for MMTC. As there is no communication from Ministry for closure etc., status quo of going concern is being maintained and the accounts have been prepared on going concern basis.

Our opinion is not modi ed in respect of this matter.

Key Audit Matters

Key audit matters are those matters that, in our professional judgment, were of most signi cance in our audit of the Standalone nancial statements of the current period. These matters were addressed in the context of our audit of the Standalone nancial statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters. In addition to the matter described in the Basis for Quali ed Opinion section and Material Uncertainty Related to Going Concern section, we have determined the matters described below to be the key audit matters to be communicated in our report.

Key Audit Matter

Auditors Response

Assessment of Significant Contingent Liabilities (other than the matter described in the Basis for Qualified Opinion section)

We have obtained an understanding of the Companys internal instructions and procedures in respect of estimation and disclosure of contingent liabilities and adopted the following audit procedures:
There are a number of litigations pending before various forums against the Company and the managements judgement is required for estimating the amount to be disclosed as contingent liability. We obtained list of all the pending legal cases handled at Corporate officelegal division as on 31st March 2026 with a note from management on the changes in the status of the cases from that of last year.
We identified this as a key audit matter because the estimates on which these amounts are based involve a signi cant degree of management judgement in interpreting the cases and to determine the possible outcome of those disputes and independent legal assessment to pursue the cases and it may be subject to management bias. understood and tested the design and operating effectiveness of controls as established by the management for obtaining all relevant information for pending litigation cases;
(Refer Note No. 34 to the standalone financial statements read with Accounting Policy No. 2.14) discussed with the management regarding any material developments thereto and latest status of legal matters;
read various correspondences and related documents pertaining to litigation cases and relevant external legal opinions obtained by the management and performed substantive procedures on calculations supporting the disclosure of contingent liabilities;
examined managements judgements and assessments in respect of whether provisions are required;
considered the management assessments of those matters that are not disclosed as contingent liability since the probability of material out flow is considered to be remote;
reviewed the adequacy and completeness of disclosures;
Based on the audit procedures performed, except for the matter described in the Basis for Qualified Opinion Section of our Report, we did not identify any material exception in managements assessment and the related disclosures of significant contingent liabilities.

Emphasis of Matters

1. We draw attention to Footnote to Note No. 10 to the accompanying nancial statements, which states that, the Company has not recognized Deferred Tax Assets in respect of carry forward losses and timing di erences during the current period, in view of the uncertainties involved. Further, the balance of Deferred Tax Asset already appearing in the books amounting to Rs. 163.79 crore has been adjusted/derecognized during the year in accordance with Ind AS 12 - "Income Taxes".

2. We draw attention to Note No. 11 read with Note No. 32(ii)(a) to the accompanying nancial statements, which states that, Gold/Silver/Jewellery/Dust/Solder held against Litigation Settlement and appearing under Other Current Assets and exceptional items amounting to Rs. 13.21 crore represents value of 12503.700 gms of con scated gold jewellery/dust/ solder etc received from Customs Department on 19.01.2026 as per Honble Supreme Court order dated 24.04.2025. This pertains to a legal case led by the company against supply of gold by MMTC to one of its associates for export under Exim Policy during FY 1991-92. The same has been certi ed by the BIS approved hallmarking centre and valued by the management based on rates published by the India Bullion and Jewellers Association (IBJA) as on 19 January 2026, considering certi ed quantity and purity. The valuation has not been carried out by an independent registered valuer as company believes that valuation so determined of above gold items based on certi ed purity and rates declared by IBJA is reasonable and appropriate.

3. We draw attention to Note No. 32(I) to the accompanying nancial statements, which states that, Neelachal Ispat Nigam Ltd (NINL)-Joint Venture company divestment has been completed on 4.7.2022;

- As per the clause of Share Purchase Agreement (SPA) for divestment of NINL, any unforeseen liability on NINL post divestment shall be borne by Sellers/ Promoters as per the warranty clause of SPA until the period of 3 years from date of completion. The aggregate liability of the Sellers and Promoters cannot exceed 20% of the amount received by the sellers from Bid amount, by way of sale consideration and discharge of their respective Seller Debt. MMTCs maximum liability in this regard, if any, works out to Rs. 1067 crore. The period of 3 years has expired on 04.07.2025 and until that date, no Liability has accrued.

- An amount of Rs. 774.95 crore (MMTCs share: Rs. 411.76 crore), kept in an interest-bearing escrow account with SBI, Bhubaneswar, matured on 04.07.2025. As the limitation period of three years concluded on the same date, the amount available in the escrow account as on 04.07.2025 along with the accrued interest was distributed among the promoters of NINL. Accordingly, MMTC received Rs. 411.76 crore towards principal and Rs. 25.75 crore towards interest (net of TDS and bank charges) on 04.07.2025. The aforesaid sum of Rs. 411.76 crore has been booked as income for the year under exceptional items.

In view of expiry of limitation period of 3 years on 04.07.2025, nothing is payable/ receivable from NINL as on date.

4. We draw attention to Footnote to Note No. 31 to the accompanying nancial statements, which states that, during the year, Trade Receivables of Rs. 75.49 crore has been written o as bad debts by Camp O ce Chennai and corresponding provisions there against has been written back under exceptional items.

5. We draw attention to Note No. 36(d) to the accompanying nancial statements, which states that, the Company has led a recovery suit of Rs. 31.40 crore against M/s. Aaryavart Impex Pvt Ltd. (AIPL) in respect of Mint sale transaction (P.Y. Rs. 31.40 crore) which included overdue interest of Rs. 2.95 crore (P.Y. Rs. 2.95 crore) which has been decreed in favour of the Company. MMTC led execution petition and matter will be heard on 08.06.2026. The company has written o the amount of Rs. 28.45 crore in the year 2015-16 due to non-realization of the same. M/s AIPL have also led a suit against Government Mint/MMTC for damages of Rs. 167.20 crore (P.Y. Rs. 167.20 crore) which is not tenable as per legal opinion and is being contested. Besides this, the same has not been considered as a contingent liability because the management is of the view that there is no present or possible liability on the company in this case.

Our opinion is not modi ed in respect of above matters.

Other Matter

1. We did not audit the nancial statements/ nancial information of 4 Regional O ces (Camp O ces) included in the standalone nancial statements of the Company whose nancial statements/ nancial information re ect total assets of Rs.141.16 crores as at March 31, 2026 and total revenues of Rs.10.89 crores for the year ended on that date, as considered in the standalone nancial statements. The nancial statements/ nancial information of these branches have been audited by the branch auditors whose reports have been furnished to us, and our opinion in so far as it relates to the amounts and disclosures included in respect of these branches, is based solely on the report of such branch auditors.

2. Other Financial Assets (Non-Current) includes Advances to Other companies of Rs.33.68 crores which includes an amount of Rs. 33.20 crores in respect of investment against capital commitment in Kandla Free Trade Warehousing Pvt Ltd (KFTWPL) and Haldia Free Trade Warehousing Pvt Ltd (HFTWPL). Out of Rs. 33.20 crores, Rs. 9.11 crores pertains to KFTWPL against which a provision of Rs. 9.06 crores has been held in the books of accounts and Rs. 24.09 crores pertains to HFTWPL against which a provision of Rs.7.25 crores has been held in the books of accounts. Out of remaining dues from HFTWPL of Rs.16.84 crores, Rs. 16.74 crores are outstanding for more than 8 years with status quo against which no provision has been created and the company is considering the same as good and recoverable, as HFTWL has lodged claim in Haldia Development Authority after surrender of land.

3. Other Current Assets includes an amount of Rs. 7.45 crores under GST ITC credit as at 31.03.2026, pertaining to GST Input Tax Credit of DRO cell aggregating to Rs.7.45 crores which has remained unutilized and has shown a continuous increase over the past 3 years. Considering the absence of ongoing business operations of the Company, uncertainty exists regarding the future utilization/recoverability of such input tax credit.

4. In case of Corporate o ce of company, Advance received from Customers includes an amount of Rs. 7.30 crores in respect of credit balance of DOCA (Pulses-PSF) and (Onion 2015-16) which is outstanding for more than 3 years as on 31.03.2026 and is subject to reconciliation.

5. Many old outstanding balances are getting carried forward as it is year after year. These balances need to be meticulously reviewed by the company with respect to its current position and settlement thereof.

6. In case of DRO Cell (erstwhile Delhi Regional O ce), Out of total advance received from customers amounting to Rs. 6.48 crores outstanding as on 31.03.2026, a sum totaling to Rs. 6.45 crores approx. are outstanding for more than 3 years, which has not been settled till date.

7. In case of Regional O ce of Vishakhapatnam:

(I) Trade Receivables of Rs. 4.02 crore is classi ed as "Considered Good-Secured", however the same is not backed up by any security and hence cannot be considered as "Considered Good-Secured". As per the management these transactions have arisen out of back-to-back contracts wherein the payment is done to the supplier after receipt of amount from the buyer and these are long pending due to pending reconciliation arising out of quantity and quality analysis variance.

(II) In respect of Recovery of old advance with Paradeep Port Trust of Rs. 1.17 crore, No provision in the books of accounts has been made and there is no con rmation of the said balance from the Paradeep Port Trust. As per the management, e orts are being made to recover the amount. As per the policy of the Company recoveries from Govt. and PSUs are considered ‘Good and Recoverable and hence no provision has been made.

8. In case of Regional O ce of Hyderabad:

(I) Trade receivables from MBS Groups amounting to Rs.226.82 crore were fully provided for by the company. The Honble Court vide its order passed in March 2025, ruled in favor of MMTC and directed MBS Groups to pay Rs.228.32 crores along with interest at the rate of 13.25% per annum from 30.09.2013 and litigation cost amounting to Rs.11.90 crore. As informed by the management, since the limitation period for ling further appeal by the counterparty has not yet expired, no e ect of the said order has been given in the books of account. The company has not recognized any income in respect of the aforesaid decree, including interest and litigation cost, as the matter is subject to further legal proceedings and the realization of the amount is not reasonably certain as at the reporting date.

Our opinion is not modi ed in respect of these matters.

Information Other than the Financial Statements and Auditors Report Thereon

The Companys Board of Directors is responsible for the other information. The Other information comprises the information included in the Boards Report, Chairmans statement, Management discussion and analysis and other company related information (hereinafter referred to as ‘other reports), but does not include the nancial statements and our auditors report thereon.

The Other reports are expected to be made available to us after the date of this auditors report.

Our opinion on the Standalone nancial statements does not cover the other information and we do not express any form of assurance conclusion thereon.

In connection with our audit of the Standalone nancial statements, our responsibility is to read the other information identi ed above when it becomes available and, in doing so, consider whether the other information is materially inconsistent with the standalone nancial statements or our knowledge obtained in the audit, or otherwise appears to be materially misstated.

When we read the ‘Other reports, if we conclude that there is a material misstatement therein, we are required to communicate the matter to those charged with governance.

Responsibilities of Management and Those Charged with Governance for the Standalone Financial Statements

The Companys Board of Directors is responsible for the matters stated in section 134(5) of the Act with respect to these standalone nancial statements that give a true and fair view of the nancial position, nancial performance, total comprehensive income, changes in equity and cash ows of the Company in accordance with the accounting principles generally accepted in India, including the accounting Standards speci ed 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 accounting policies; making judgments and estimates that are reasonable and prudent; and design, implementation and maintenance of adequate internal nancial controls, that were operating e ectively for ensuring the accuracy and completeness of the accounting records, relevant to the preparation and presentation of the Standalone nancial statements that give a true and fair view and are free from material misstatement, whether due to fraud or error.

In preparing the Standalone nancial 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.

The Board of Directors are responsible for overseeing the Companys nancial reporting process.

Auditors Responsibilities for the Audit of the Standalone Financial Statements

Our objectives are to obtain reasonable assurance about whether the standalone nancial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditors report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that 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 in uence the economic decisions of users taken on the basis of these Standalone nancial statements.

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 nancial statements, whether due to fraud or error, design and perform audit procedures responsive to those risks, and obtain audit evidence that is su cient 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 nancial 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 on whether the Company has adequate internal nancial controls system in place and the operating e ectiveness of such controls.

Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and related disclosures made by the 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 signi cant 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 Standalone nancial 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 Standalone nancial statements, including the disclosures, and whether the Standalone nancial statements represent the underlying transactions and events in a manner that achieves fair presentation.

Materiality is the magnitude of misstatements in the Standalone nancial statements that, individually or in aggregate, makes it probable that the economic decisions of a reasonably knowledgeable user of the Standalone nancial statements may be in uenced. 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 e ect of any identi ed misstatements in the Standalone nancial statements.

We communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit and signi cant audit ndings, including any signi cant de ciencies 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 signi cance in the audit of the Standalone nancial statements of the current period and are therefore the key audit matters. We describe these matters in our auditors report unless law or regulation precludes public disclosure about the matter or when, in extremely rare circumstances, we determine that a matter should not be communicated in our report because the adverse consequences of doing so would reasonably be expected to outweigh the public interest bene ts of such communication.

Report on Other Legal and Regulatory Requirements

1. As required by the Companies (Auditors Report) Order, 2020 ("the Order") issued by the Central Government in terms of Section 143(11) of the Act, we give in "Annexure A" a statement on the matters speci ed in paragraphs 3 and 4 of the Order.

2. As required by Section 143(3) of the Act, based on our audit we report that:

a) We have sought and obtained all the information and explanations which to the best of our knowledge and belief were necessary for the purposes of our audit of the aforesaid standalone nancial statements.

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 Pro t and Loss including Other comprehensive income, the Statement of Cash Flows and Statement of Changes in Equity dealt with by this report are in agreement with the books of account;

d) In our opinion, the aforesaid standalone nancial statements comply with the Ind AS speci ed under Section 133 of the Act, read with the Companies (Indian Accounting Standards) Rules, 2015 as amended;

e) Being a Government Company pursuant to the Noti cation No. GSR 463(E) dated 5thJune 2015 issued by the Ministry of Corporate A airs, Government of India, provisions of sub-section (2) of Section 164 of the Act, are not applicable to the Company; f) With respect to the adequacy of the internal nancial controls over nancial reporting of the Company and the operating e ectiveness of such controls, refer to our separate Report in "Annexure B".

g) As per Noti cation number G.S.R. 463 (E)dated 5th June, 2015 issued by Ministry of Corporate A airs, section 197 of the Act regarding remuneration to director is not applicable to the Company, since it is a Government Company.

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, as amended in our opinion and to the best of our information and according to the explanations given to us:

i. There are pending litigation including matters relating to sales tax, service tax, custom duty and excise duty which are disclosed as contingent liability refer to Note 34 and 36 to the standalone nancial statements, the impact of the same is unascertainable as the matters are sub-judice.

ii. The Company is not having any long-term contracts including derivative contracts for which there were any material foreseeable losses; and

iii. There has been delay in transferring amounts, required to be transferred, to the Investor Education and Protection Fund by the Company except nominal amounts of Rs.93.75 pertaining to FY 2010-11 and Rs.33.45 pertaining to FY 2013-14 which are appearing under Unpaid Dividend as on 31.03.2026

iv. (a) The Management has represented that, to the best of its knowledge and belief, no funds (which are material either individually or in the aggregate) 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 person or entity, including foreign entity ("Intermediaries"), with the understanding, whether recorded in writing or otherwise, that the Intermediary shall, whether, directly or indirectly lend or invest in other persons or entities identi ed in any manner whatsoever by or on behalf of the Company ("Ultimate Bene ciaries") or provide any guarantee, security or the like on behalf of the Ultimate Bene ciaries (Refer note 49(e)).

(b) The Management has represented, that, to the best of its knowledge and belief, no funds (which are material either individually or in the aggregate) have been received by the Company from any person or entity, including foreign entity ("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 identi ed in any manner whatsoever by or on behalf of the Funding Party ("Ultimate Bene ciaries") or provide any guarantee, security or the like on behalf of the Ultimate Bene ciaries (Refer note 49(f))

(c) Based on the audit procedures that have been considered reasonable and appropriate in the circumstances, nothing has come to our notice that has caused us to believe that the representations under sub-clause (i) and (ii) of Rule 11(e), as provided under (a) and (b) above, contain any material misstatement.

v. The Company has not declared or paid any dividend during the year ended 31st March 2026.

vi. Based on our examination, which included test checks, the Company has used an accounting software for maintaining its books of accounts for the nancial year ended 31st March 2026 which has a feature of recording audit trail (edit log) facility and the same has operated throughout the year for all relevant transactions recorded in the software. Further, during the course of our audit, we did not come across any instance of audit trail feature being tampered with and the audit trail has been preserved by the Company as per the statutory requirements for record retention.

3. As required by CAG of India through directions, issued under Section143(5) of the Act, 2013 we give our report in the attached "Annexure C".

Annexure-A To the Independent Auditors Report on the Standalone Financial Statements of The MMTC LIMITED

Refer to in Paragraph 1 under "Other Legal and Regulatory Requirement" we further report that: i. a.

i. The Company has generally maintained proper records showing full particulars, including quantitative details and situation of Property, Plant and Equipment. However, in some cases records of Property, plant and equipment are not properly updated with complete details.

ii. The Company has maintained proper records showing full particulars of intangible assets.

b. As per the explanations and information given to us and the records examined by us, the company has a regular programme of physical veri cation of its Property, Plant and Equipment at reasonable intervals which is once in a year except xed assets provided to o cials of Ministry of Corporate A airs. In our opinion, this periodicity of physical veri cation is reasonable having regard to the size of the Company and the nature of its assets. In accordance with this programme, Property, plant and equipment were veri ed during the year. As represented by the management, no material discrepancies were noticed on such veri cation.

c. Based on our examination of the property tax receipts and lease agreement for land on which building is constructed, registered sale deed / transfer deed / conveyance deed provided to us, we report that, the title in respect of self-constructed buildings and title deeds of all other 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 Standalone nancial statements included under Property, Plant and Equipment are held in the name of the Company as at the balance sheet date.

Title deeds of immovable property are held in the name of the company except in the cases mentioned below:

Region/O ce

Description of property Gross carrying value (In Rs.) Held in the name of Whether promoter, director or their relative or employee Period held Remarks
Corporate O ce Leasehold Land (Scope) 0.81 Crore Scope Complex No 99 Years Scope is yet to sign Lease agreement with L&DO.
O ce Building (Scope) 1.69 Crore
Corporate O ce Leasehold Land (Sta Quarters) 0.06 Crore Delhi Development No 99 Years Perpetual Lease
Building (Sta Quarters) 0.02 Crore Authority

Further, 36 title deeds has been deposited with Honble High Court in respect of dispute with Anglo American Metallurgical Coal Pte Limited.

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, 2026 for holding any benami property under the Benami Transactions (Prohibition) Act, 1988 (as amended in 2016) and rules made thereunder.

ii.

a. The inventory has been physically veri ed at reasonable intervals by the management and in our opinion, the coverage and procedure of such veri cation by the management is appropriate. According to the information and explanations given to us by the company, value of discrepancies noticed on such physical veri cation does not account for 10% or more in the aggregate for each class of inventory.

b. The Company has not been sanctioned working capital limits by banks or nancial institutions on the basis of security of current assets during any point of time of the year except loan against FDR taken by the company from Punjab & Sind bank in two tranches i.e. Rs.28 crore on 15-09-2025 and Rs.4 crore on 29-09-2025 to pay advance tax and monthly expenses, which was repaid back on 10-10-2025. According to the information and explanation given to us, since loan was taken against FDR,

ling of quarterly returns or statements by the company with such bank is not applicable to the Company.

iii. The Company has not made any investments in, provided any guarantee or security or granted any loans or advances in nature of loans, secured or unsecured, to companies, rms, Limited liability partnerships or any other parties during the year except Advances in nature of loans given to other parties in respect of which-

a. The company has provided advances in the nature of loans during the year and details of which is given below:

Name of Party

Aggregate amount of Advances in the nature of loans provided during the year (Rs.) Balance outstanding as on 31.03.2026 (Rs.)

Haldia Free Trade Warehousing Pvt Ltd (HFTWPL)

Rs. 5,00,000/- Rs. 24,09,04,809/-

The company has not granted any advance in the nature of loan to subsidiary, joint venture and associate.

b. The terms and conditions of the grant of advances in the nature of loans, in our opinion, prima facie, are not prejudicial to the companys interest.

c. In respect of advances in the nature of loans granted by the company, the schedule of repayment of principal and payment of interest has not been stipulated.

d. According to the information and explanations given to us and based on audit procedure performed, in respect of advances in the nature of loans granted by the company, there is no overdue amount remaining outstanding as at the balance sheet date.

e. No advance in the nature of loan granted by the company which has fallen due during the year, has been renewed or extended or fresh loans granted to settle the overdues of existing loans given to the same parties.

f. According to the information and explanations given to us and based on audit procedures performed by us, the company has not granted any loans or advances in the nature of loans either repayable on demand or without specifying any terms or period of repayment during the year except an advance in the nature of loan of Rs.5 lakh granted by the company during the year to M/s. Haldia Free Trade Warehousing Pvt Ltd. comprising 0.15% of total advance to other companies, without specifying any terms or period of repayment. No loan was granted to Promoters, related parties as de ned in clause (76) of section 2 of the Companies Act, 2013 during the year.

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

v. According to the information and explanations given to us, the Company has not accepted any deposits or there is no amount which has been considered as deemed deposit within the meaning of sections 73 to 76 of the Act and the Companies (Acceptance of Deposits) Rules, 2014 (as amended). Accordingly, reporting under clause 3(v) of the Order is not applicable to the Company.

vi. According to the information and explanations given to us maintenance of cost records has not been prescribed by the Central government for the Company under section 148(1) of the Act. Accordingly, the provisions of clause 3(vi) of the Order are not applicable.

vii.

a) According to the information and explanations given to us and as per the records veri ed by us, the Company has been regular in depositing undisputed statutory dues including Income Tax, Provident Fund dues, Professional Tax, Value Added Tax, Service Tax and Goods & Service tax with the appropriate authorities. There were no undisputed amount payable in respect of Income Tax, Provident Fund dues, Professional Tax, GST, Value Added Tax and Service Tax and other statutory dues in arrear as at 31st March 2026 for more than six months from the date they became payable.

b) In case of dues of Income Tax or sales tax or service tax or duty of custom or duty of excise or value added tax or cess which have not been deposited on account of any dispute are attached as "Annexure I". viii. There were no transactions relating to previously unrecorded income that have been surrendered or disclosed as income during the year in the tax assessments under the Income Tax Act, 1961 (43 of 1961).

ix.

a. According to the information and explanations given to us and as per the records veri ed by us, the Company has not defaulted in repayment of loans or other borrowings or in the payment of interest thereon to any lender. Further there are no borrowings outstanding as on 31st March 2026.

b. According to the information and explanations given to us including representation received from the management of the Company, and on the basis of our audit procedures, we report that the Company has not been declared a willful defaulter by any bank or nancial institution or other lender.

c. In our opinion and according to the information and explanations given to us, the company has not obtained any term loan during the year. Hence reporting under clause 3(ix)c of the Order is not applicable.

d. In our opinion and according to the information and explanations given to us, the funds raised on short term basis were not utilized for long term purposes.

e. According to the information and explanations given to us and on an overall examination of the Standalone nancial statements of the Company, the Company has not taken any funds from any entity or person on account of or to meet the obligations of its subsidiaries or joint ventures.

f. 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.

x.

a. The Company has not raised any money by way of initial public o er or further public o er (including debt instruments), during the year. Accordingly, reporting under clause 3(x)(a) of the Order is not applicable.

b. According to the information and explanations given to us, the Company has not made any preferential allotment or private placement of shares or (fully, partially or optionally) convertible debentures during the year. Accordingly, reporting under clause 3(x)(b) of the Order is not applicable to the Company.

xi.

a. No fraud by the Company or on the Company has been noticed or reported during the year. According to the information and explanations given to us and based on the audit procedures performed in accordance with the generally accepted auditing practices in India, we have neither come across any instance of fraud on or by the company or its o cers, 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 led in Form ADT-4 as prescribed under rule 13 of Companies (Audit and Auditors) Rules, 2014 with the Central Government, during the year and upto the date of this report.

c. According to the information and explanations given to us including the representation made to us by the management of the Company, there are no whistle-blower complaints received by the Company during the year.

xii. In our opinion and according to the information and explanations given to us, the Company is not a Nidhi Company. Accordingly, the provisions of paragraph 3(xii) of the Order are not applicable to the Company.

xiii. According to the information and explanations given to us, all transactions with the related parties made by the Company are in compliance with section 177 and 188 of the Act, where applicable and the relevant details in respect of such transactions have been appropriately disclosed in the Standalone Financial Statements under Ind AS-24 - "Related Party Disclosures speci ed under Section 133 of the Act read with relevant rules.

xiv.

a. In our opinion the Company has an adequate internal audit system commensurate with the size and the nature of its business.

b. We have considered, the internal audit reports for the year under audit, issued to the Company during the year and till date, in determining the nature, timing and extent of our audit procedures.

xv. 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.

xvi.

a. In our opinion, the Company is not required to be registered under section 45-IA of the Reserve Bank of India Act, 1934. Hence, reporting under clause 3(xvi)(a) & (b) of the Order is not applicable.

b. In our opinion, the Company is not a core investment company (as de ned in the Core Investment Companies (Reserve Bank) Directions, 2016) and accordingly reporting under clause 3(xvi)c & (d) of the Order is not applicable.

xvii. The Company has not incurred any cash losses during the nancial year covered by our audit and in the immediately preceding nancial year.

xviii. There has been no resignation of the statutory auditors of the Company during the year. Accordingly, reporting under clause 3(xviii) of the Order is not applicable.

xix. According to the information and explanations given to us and on the basis of the nancial ratios, ageing and expected dates of realisation of standalone nancial assets and payment of standalone nancial liabilities, other information accompanying the standalone nancial statements, our knowledge of the plans of the Board of Directors and management, we are of the opinion that no material uncertainty exists as on the date of the audit report that the Company is 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.

xx. There are no unspent amounts towards Corporate Social Responsibility (CSR) on other than ongoing projects requiring a transfer to a Fund speci ed in Schedule VII to the Companies Act in compliance with second proviso to sub-section (5) of Section 135 of the said Act. Accordingly, reporting under clause 3(xx)(a) and (b) of the Order is not applicable for the year.

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

Mumbai Region

Nature of Dues Year Amount Involved Forum where dispute is pending
Bombay Sales Tax Act Sales Tax 1989-90 15,01,06,778* Jt. Comm. Of Sale tax (Appeal IV)
Bombay Sales Tax Act Sales Tax 2001-02 45,03,961 Jt. Comm. Of Sale tax (Appeal I)
Maharashtra VAT, 2002 Sales Tax 2016-17 28,75,574 Jt. Comm. Of Sale tax (Appeal VI)
Maharashtra VAT, 2002 Sales Tax 2017-18 5,15,568 Jt. Comm. Of Sale tax (Appeal VI)
Maharashtra VAT, 2002 Sales Tax 2013-14 2,43,593** Jt. Comm. Of Sale tax (Appeal VI)
Goods and Service Tax Act, 2017 GST 2018-19 99,11,638 Additional Commissioner Appeals II Bandra
Goods and Service Tax Act, 2017 GST 2018-19 to 2022-23 59,03,296*** Jt./Addl. Commissioner, Appeals II, BKC, Mumbai

* Out of above demand of Sales tax, an amount of Rs.5,00,000/- has been deposited by the company. ** Out of above demand of Sales tax, an amount of Rs. 72,921/- has been deposited by the company. ***Out of above demand of GST, an amount of Rs. 2,90,489/- has been deposited by the company.

Chennai Region

Nature of Dues Year Amount Forum where dispute is pending
TNGST Act Sales Tax Penalty & Interest (SPANDEX YARN) 2001-02 1,78,566 Assistant Commissioner of Commercial Taxes
TN VAT Act Sales tax 1999-00 78,25,755 High Court
TN VAT Act Sales tax exhibition return penalty and interest 2007-08 14,53,825 JC Appeals
Customs Act, 1962 Customs duty on di erences in the classi cation of items 2012-13 11,56,46,975 CESTAT Chennai
Customs Act, 1962 Customs duty on di erences in the classi cation of items 2013-16 64,09,352 High Court of Telangana
Total 13,15,14,473

Vizag Region

1. Visakhapatnam (RO) (incl. Kolkata camp o ce)

Nature of Statute Nature of Dues Year AmountAuthority
APGST APGST 1968-69 9,28,162 HC HYD
CST CST 2007-08 91,537 ADC
VAT APVAT 2013-14 17,31,799 ADC
CST CST 2013-14 46,07,728 HC Kolkata
WBVAT WBVAT 2013-14 51,46,313 HC Kolkata
GST KOLKATTA GST 2017-18 4,56,85,382 CESTAT, Kolkata
Customs duty Customs duty 2009-10 92,92,463 CESTAT, Hyderabad
Customs duty Customs duty 2008-09 1,64,52,750 APHC
Customs Customs duty 2021-22 1,50,15,449 CESTAT, Hyderabad
Service Tax Service Tax 2014-15 1,91,21,170 CESTAT, Hyderabad
Service Tax Service Tax 2013-14 1,57,63,170 CESTAT, Hyderabad
Interest & Penalty 8,37,92,745
Total 21,76,28,668

2. Bhubaneswar (Camp O ce)

Nature of Statute

Nature of Dues Year Amount Authority
OST(INT) OST (Interest) 1978-79 26,50,388.00 High Court of Orissa with Interest
OST OST 1978-79 2,63,57,122.25 High Court of Orissa with Interest
OST OST 1978-79 13,17,856.50 High Court of Orissa with Interest
Orrisa Sales Tax Interest 1978-79 3,57,42,030.00 Revision petition Filed Before Commissioner of CT & GST, disposed and demand stayed till disposal of SLP with Interest.
Orissa Sales Tax Orissa Sales Tax 1992-93 - Tribunal rejected the demand and remanded back for re-assessment, Challenged the other party in High court of Orissa with interest.
Orissa Sales Tax DEPB 2006-09 25,98,58,244.95 Orissa sales tax Tribunal with interest.
Orissa Sales Tax DEPB 2010-12 9,13,36,459.23 High Court of Orissa with interest.
OVAT Sales Tax 2013-14 - Orissa sales tax Tribunal with interest.
CST (Odisha) Sales Tax 2013-14 - Orissa sales tax Tribunal with interest.
ET (Odisha) ET 2013-14 - Orissa sales tax Tribunal with interest.
CST (Odisha) Declaration Form Issue 2011-14 1,00,86,727.51 Orissa sales tax Tribunal with interest.
CGST & SGST ACT GST 2018-19 7,29,54,835.26 Writ petition led before Honble High court on 08.10.2020
CGST & SGST ACT ITC Disallowed 2019-20 - Appelate Authority
CGST & SGST ACT GST 2017-18 14,45,294.61 Filing Writ petition before High court
OST Act (Interest) Sales Tax 1966 9,58,035.00 High Court of Orissa with interest.
CGST & SGST ACT GST 2021-22 25,54,947.45 Appeal Pending before 1st Appellate Authority
Central Excise Act Service Tax 2010-11 7,48,99,571.49 Writ No. 27016/2020 led on 8-10-2020
Central Excise Act Service Tax 2011-12 7,57,83,875.74 Writ No. 27021/2020 led on 8-10-2020
Central Excise Act Service Tax 2009-12 66,45,34,605.13 Writ No. 27027/2020 led on 8-10-2020
Central Excise Act Service Tax 2012-13 75,66,359.91 Writ No. 27023/2020 led on 8-10-2020
Central Excise Act Service Tax 2012-13 9,01,32,186.89 Writ No. 27029/2020 led on 8-10-2020
Central Excise Act Service Tax 2013-14 9,94,263.00 CESTAT APPEAL FILED ON 04.02.2019
Central Excise Act Service Tax 2017-18 27,731.56 CESTAT APPEAL FILED ON 28.05.2019
Central Excise Act Service tax 2013-15 17,71,628.00 CESTAT Appeal led
Customs Act Customs 2012-13 149,02,87,737 Appeal led in CESTAT
Total 2,91,12,59,899.48

Hyderabad Region

Nature of Statute

Nature of Dues Year Amount Authority
CST Central Sales Tax 1989-90 1,49,770 STAT-VIZAG
APGST Sales Tax 1991-92 24,02,576 STAT-VIZAG
APGST Sales Tax 1992-93 13,96,269 STAT-VIZAG
APGST Sales Tax 1993-94 17,62,687 STAT-VIZAG
APGST Sales Tax 1993-94 6,30,615 STAT-VIZAG
CST Central Sales Tax 1993-94 4,41,446 STAT-VIZAG
CST Central Sales Tax 1994-95 2,04,081 AC LTU- VIZAG
CST Central Sales Tax 1997-98 58,43,100 STAT-VIZAG
CST Central Sales Tax 1999-00 39,04,454 STAT-VIZAG
CST Central Sales Tax 2000-01 2,52,926 STAT-VIZAG
VAT VAT 2006-07 6,76,058 AC LTU-STAT-VIZAG
VAT VAT 2007-08 71,000 AC AUDIT-VIZAG
VAT VAT 2008-09 7,84,474 STAT-VIZAG
VAT VAT 2012-13 99,49,808 ADC (CTO)-VIZAG
CST Central Sales Tax 2013-14 4,40,000 STAT-VIZAG
APVAT-JC VAT 2013-14 22,00,000 AP VAT-JC Amaravathi
Customs Of India CUSTOM DUTY-NFM 2021-22 46,47,711 High court of Telangana
Customs Of India CUSTOM DUTY-PMD 2016-17 5,36,12,040 CESTAT- Delhi
Customs Of India CUSTOM DUTY-PMD 2014-17 1,71,54,022 CESTAT- Chennai
Customs Of India CUSTOM DUTY-PMD 2014-17 2,74,37,928 CESTAT- Chennai
GST GST 2017-20 22,89,697 Customs and Central Tax
Appeals-II, Hyderabad

Corporate O ce

Nature of Statute

Nature of Dues Year (AY) Amount Forum
Income Tax Act Income Tax 2023-24 15,07,190 CIT(A)
Income Tax Act Income Tax 2009-10 2,10,00,000 High Court
Income Tax Act Income Tax 2005-06 4,51,65,330 Sup. Court
Income Tax Act Income Tax 2003-04 4,15,00,000 High Court
Income Tax Act Income Tax 2001-02 1,17,77,218 High Court
Income Tax Act Income Tax 1997-98 1,02,93,042 CIT(A)
Sub-Total* 13,12,42,780
Finance Act, 1994 Service Tax 2013-14 to 2016-17 28,49,08,035 CESTAT
Sub-Total** 28,49,08,035
Grand Total 41,61,50,815.00

*As against the above demand of Income Tax, an amount of Rs. 4,26,62,268 has been deposited by the company. **Out of the above demand of Service Tax, an amount of Rs. 59,72,240 has been deposited by the company.

DRO Cell (erstwhile Delhi Regional O ce)

Nature of Statute

Nature of Dues Period to which the amount relates Amount (in Rs) Forum where dispute is pending
UP-VAT LST/CST 1990-91 617,588 Moradabad, Allahabad High Court
UP-VAT LST 1991-92 470,578 Moradabad, Allahabad High Court
UP-VAT LST 1992-93 264,037 Moradabad, Allahabad High Court
UP-VAT LST 1993-94 185,100 Moradabad, Allahabad High Court
UP-VAT LST 1987-88 1,635,160 Joint Commissioner (Appeals), UP-VAT
UP-VAT VAT 1996-97 611,808 Joint Commissioner (Appeals), UP-VAT
UP-VAT VAT+Interest for non- submission of Form -3B (Gold) & Form 3C 1 (Mentha Oil) 2007-08 62,457 Joint Commissioner (Appeals), UP-VAT
Haryana-VAT LST 1992-93 424,587 Faridabad, Punjab & Haryana High Court, Chandigarh
MP-VAT LST 1999-00 150,004 Sale Tax Authority, Indore
MP-VAT LST 1998-99 4,730,692 Assessing Authority, Indore
Custom & Central Excise Custom Duty & Interest on non-export of gold jewellery against Gold Loan by Associates 1999-00 27,267,919 Pending before Honble Delhi high Court as per directions of Honble Supreme Court of India
RST Act ST 2003-04 14,946,540 Rajasthan Kar Board Ajmer (Rs.36.28 lacs have been deposited under protest). Sales Tax Dept. has appealed against the order of DC (Appeals) in Kar Board.
CGST ACT GST 2017-18 to 2021-22 28,560,484 Asst. Commissioner, CGST, Delhi
Haryana VAT LST 2013-14 14,64,75,714 Haryana VAT Tribunal, Chandigarh (Fully covered by Bank Guarantee)
Pending before Honble
Central Excise Act Central Excise 2010-11 & 2011-12 19,35,74,658 Supreme Court of India
Income Tax TDS 2008-09 100 TDS Demand
Income Tax TDS 2010-11 to 2011-12 42,340 TDS Demand
Income Tax TDS 2019-20 47,196 Commissioner of Income Tax (Appeals)

Annexure B To the Independent Auditors Report of even date on the Standalone Financial Statements of MMTC Limited

Report on the Internal nancial Controls under section 143(3)(i) of the Companies Act, 2013 ("the Act")

We have audited the internal nancial controls over nancial reporting of MMTC Limited ("the Company") as of March 31, 2026 in conjunction with our audit of the standalone nancial statements of the Company for the year ended on that date.

Managements Responsibility for Internal Financial Controls

The Board of Directors of the Company is responsible for establishing and maintaining internal nancial controls based on the internal control over nancial 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 nancial controls that were operating e ectively for ensuring the orderly and e cient conduct of its business, including adherence to the 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 nancial information, as required under the Act.

Auditors Responsibility

Our responsibility is to express an opinion on the Companys internal nancial controls over nancial of the company 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, as speci ed under section 143(10) of the Act, to the extent applicable to an audit of internal nancial 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 nancial controls over nancial reporting was established and maintained and if such controls operated e ectively in all material respects.

An audit involves performing procedures to obtain audit evidence about the adequacy of the internal nancial controls system over nancial reporting and their operating e ectiveness.

Our audit of internal nancial controls over nancial reporting included obtaining an understanding of internal nancial controls over nancial reporting, assessing the risk that a material weakness exists, and testing and evaluating the design and operating e ectiveness of internal control based on the assessed risk. The procedures selected depend on the auditors judgement, including the assessment of the risks of material misstatement of the Standalone nancial statements, whether due to fraud or error.

We believe that the audit evidence we have obtained is su cient and appropriate to provide a basis for our audit opinion on the Companys internal nancial controls system over nancial reporting.

Meaning of Internal Financial Controls Over Financial Reporting

A Companys internal nancial control over nancial reporting is a process designed to provide reasonable assurance regarding the reliability of nancial reporting and the preparation of Standalone nancial statements for external purposes in accordance with generally accepted accounting principles. A Companys internal nancial control over nancial reporting includes those policies and procedures that:

a) Pertain to the maintenance of records that, in reasonable detail, accurately and fairly re ect the transactions and dispositions of the assets of the company;

b) Provide reasonable assurance that transactions are recorded as necessary to permit preparation of Standalone nancial 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

c) Provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the companys assets that could have a material e ect on the Standalone nancial statements.

Inherent Limitations of Internal Financial Controls over Financial Reporting

Because of the inherent limitations of internal nancial controls over nancial reporting, including the possibility of collusion or improper management override of controls, material misstatements due to error or fraud may occur and not be detected. Also, projections of any evaluation of the internal nancial controls over nancial reporting to future periods are subject to the risk that the internal nancial control over nancial reporting may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

Opinion

In our opinion, to the best of our information and according to the explanations given to us, the company has, in all material respects, an adequate internal nancial controls system over nancial reporting and such internal nancial controls over nancial reporting were operating e ectively as at March 31, 2026, based on "the internal control over nancial 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"

Annexure C To the Independent Auditors Report of even date on the Financial

Statements of MMTC LIMITED

Report on the Directions issued by C&AG under section 143(5) of the Companies Act, 2013 for the Financial Year 2025-2026

Sr. No Particulars Reply Impact on financial statement
I Assess the fair valuation of all the investments, both quoted and unquoted, made directly by the Company or through Trusts, for Post retirement benefits of the employees. This includes verifying valuation methodologies, ensuring consistency with Ind AS and reviewing supporting documentation. The auditor shall provide a brief note on the valuation approach, its reasonability, and compliance with applicable regulations, reporting any material deviations or misstatements. As per the information and explanations given to us and the records produced before us, all the investments, made directly by the Company or through Trusts, for Post retirement benefits of the employees have been valued appropriately in accordance with the applicable financial reporting framework and applicable regulations. The valuation approach and valuation methodologies applied by the company for these investments is reasonable and appropriate and no material deviation or misstatement was observed therein. Brief note on the valuation approach is given below: Nil
The company has a Post Retirement Medical Benefit (PRMB) Trust for Post retirement benefits of the employees. As per the trust deed of PRMB Trust, funds available with the trust are invested with LIC on floating interest rates. The fair value of investment with LIC as on 31.03.2026 is Rs. 215,28,13,987.43, based on the Certificate of Balance in Fund as on 31/03/2026 provided by LIC.
The company has a Gratuity Trust for maintaining & investing funds relating to Gratuity of employees. As per the Trust Deed of Gratuity Trust, funds available with Trust are invested with LIC only. The investment earns yearly interest as declared by LIC every year. Funds are transferred from MMTC to Trust (which are further transferred by Trust to LIC) based on the Actuarial valuation of Trust done every year and accordingly funds are maintained in Trust. The fair value of investment with LIC as on 31.03.2026 is Rs. 31,45,12,053/- based on the Certificates of Balance in Fund as on 31/03/2026 provided by LIC.
The valuation of investments in case of PRMB Trust and Gratuity Trust as above have been certified by LIC and we have relied on the said certificates for reporting the fair value of investments and have not independently verified the valuation methodologies adopted by LIC and our procedures were limited to verification of the certificates and related records made available by the management.
The company has a CPF Trust which was created for maintaining & investing the PF funds of MMTC employees. Every month, PF deducted from the salary of employees (12% of Basic +DA) and Employer contribution (12% of
Basic +DA) is transferred to Trust. CPF Trust is an exempted trust permitted by EPFO but is governed by the rules & regulations of EPFO. All investments are done as per the EPFO defined pattern for investments. Compliance Audit of the Trust is done by EPFO every year. Any withdrawal from the investments requires the approval of EPFO. The investments are accounted for in the books of Trust at face value.
As represented by the management, CPF trust investments as on 31.03.2026 amounts to Rs.173,14,85,967/- which has been valued at the original cost of investment.
The Superannuation Trust was created by MMTC for maintaining & Investing funds relating to Pension to employees on retirement. Funds were earlier invested with LIC and the investment used to earn yearly interest as declared by LIC every year. Later on, as per the approval of Board and amendment in Trust deed, funds available in LIC were transferred to NPS as governed by Pension Fund Regulatory and Development Authority (PFRDA). Presently, funds are directly transferred from MMTC to individual NPS accounts of employees through HDFC Bank as POP (point of presence).
II Whether the Company has a system in place to process all the accounting transactions through IT system? If yes, whether review of this system and controls that are significant to the Companies financial reporting process as well as cyber security has been done and material discrepancies found, if any, have been suitably reported? The implications of processing of accounting transactions outside IT system on the integrity of the accounts along with the financial implications may also be reported. As per the information and explanations given to us, the company has a system in place to process all the accounting transactions through IT System (Tally accounting software).

Based on audit procedures carried out and as per the information and explanations given to us, no accounting transactions were processed outside IT system (Tally accounting software) except sale of goods in retail business which is done through independent RMS software, valuation of closing inventory and month end expense provisions which are computed manually, depreciation which is computed by FA module and interest on employee loans etc. which are computed manually, and entered through Journal vouchers in Tally accounting software. The same does not have any implications on the integrity of the accounts.

Nil
Based on the audit procedures performed by us, review of this system and controls that are significant to the Companies financial reporting process has been done and no material discrepancies were found.
In respect of review of cyber security, Vulnerability Assessment and Penetration Testing (VAPT) Audits of the IT Infrastructure of the Company including Delhi Head Office and all its camp offices including sub-regional offices were conducted during the year vide reports dated 19-07-2025 by an external agency engaged by MMTC Limited. Material observations identified during the audit have been duly reported to the management for corrective action. Further, as represented by the management, no material weaknesses in such
IT systems and controls, which may result in material misstatement of the financial statements of the company were observed in such audit.
III Whether funds (grants/ subsidy etc.) received/ receivable for specific schemes from Central/State Government or its agencies were properly accounted for as per the applicable accounting standards or norms and whether the received funds were utilised as per its terms and conditions? Whether accounting of interest earned on grants received has been done as per terms and conditions of the Grant. List the cases of deviation. Based on audit procedures carried out and as per the information and explanations given to us, no funds (grants/subsidy etc.) were received/ receivable for specific schemes from Central/ State Government or its agencies. Nil
IV Whether the Company has identified the key Risk areas? If yes, whether the Company has formulated any Risk Management Policy to mitigate these risks? If yes, (a) whether the Risk Management Policy has been formulated considering global best practices? (b) whether the Company has identified its data assets and whether it has been valued appropriately? As per the information and explanations given to us, the Company has identified the key Risk areas and has formulated a Risk Management Policy to mitigate these risks. The said policy is available on companys website and the policy has not been specifically benchmarked against any global framework; however it incorporates principles considered appropriate to the companys operations and risk profile. Nil
As per the information and explanations given to us, the company has not identified any data assets and consequently these have not been subject to valuation.
V Whether the Company is complying with the Securities and Exchange Board of India (SEBI) (Listing Obligation and Disclosure Requirements) Regulations, 2015, and other applicable rules and regulations of SEBI, Department of Investment and Public Asset Management, Ministry of Corporate Affairs, Department of Public Enterprises, Reserve Bank of India, Telecom Regulatory Authority of India, CERT-IN, Ministry of Electronics and Information Technology and National Payments Corporation of India wherever applicable? If not, the cases of deviation may be highlighted. Based on the information and explanations given to us, secretarial audit report of the company, and audit procedures carried out by us, the company is complying with the Securities and Exchange Board of India (SEBI) (Listing Obligation and Disclosure Requirements) Regulations, 2015, and other applicable rules and regulations of SEBI, Department of Investment and Public Asset Management, Ministry of Corporate Affairs, Department of Public Enterprises, Reserve Bank of India, Telecom Regulatory Authority of India, CERT-IN, Ministry of Electronics and Information Technology and National Payments Corporation of India wherever applicable. Nil

COMPLIANCE CERTIFICATE

We have conducted the audit of accounts of MMTC LIMITED for the year ended 31st March 2026 in accordance with the Directions / Sub Directions issued by the C&AG of India under Section 143(5) of the Companies Act, 2013 and certify that we have complied with all the Directions / Sub Directions issued to us.

MANAGEMENTS REPLY TO AUDITORS OBSERVATIONS IN THE AUDIT REPORT ON SATANDALONE FINANCIAL STATEMENTS FOR 2025-26

AUDITORS OBSERVATION MANAGEMENTS REPLY
Basis for Qualified Opinion
As disclosed in Note no. 11 (Footnote- i) to the financial statements, in respect of the Anglo Coal case, an amount of Rs. 1088.62 crore (comprising Rs.1087.76 crore deposited with the court and Rs.0.86 crore attached from the companys bank account) had been deposited with the Honble Delhi High Court. The final determination of the amount is subject to the judgement/clarification of the Honble Court. The Company has provided complete details, supporting documents and management explanations to the Auditors during the course of Audit proceedings. Pursuant to the orders dated 06.05.2022 and 07.07.2022 passed by the Honble Delhi High Court in the Anglo Coal matter, MMTC Limited had deposited an aggregate amount of Rs.1088.62 crore, comprising:
The Honble Delhi High Court, vide its order dated 09.05.2025, directed that "the decree holder [Anglo] shall be entitled to withdraw the said amount along with up-to- date accrued interest after the expiry of two weeks from today". The SLP filed by the company before the Honble Supreme Court was dismissed by order dated 03.11.2025.
• Rs.1087.76 crore through Demand Draft dated 20.07.2022 deposited with the Registrar General of the Honble Delhi High Court; and
• Rs.0.86 crore attached from MMTCs Bhubaneswar bank account.
Thereafter, the Company filed an application before the Honble Delhi High Court on 03.11.2025 admitting a total liability of Rs.1169.14 crore, including interest calculated up-to 01.11.2025. The aforesaid amount of Rs.1088.62 crore had already been fully recognized and provided for in the books of account of the Company.
Subsequently, pursuant to the orders of the Honble Delhi High Court, an amount of Rs.1000 crore was released to Anglo on 17.11.2025 from the deposited amount.
Subsequently, pursuant to the order of the Honble Delhi High Court dated 10.11.2025, an amount of Rs.1000 crore was released to Anglo on 17.11.2025.
Based on the managements calculations, the estimated remaining liability of the company towards Anglo coal as on 17.11.2025 amounts to Rs.170.58 crore, including interest calculated up to 17.11.2025. To file an application in Delhi High Court, Ld. Advocate advised MMTC to provide estimated calculation sheet considering interest calculation up to 01.11.2025.
Accordingly, the estimated present obligation of the company in respect of the aforesaid matter amounts to Rs. 170.58 crore, against which the company has recognised a provision of Rs. 87.76 crore only. This has resulted in non-recognition of provision to the extent of Rs. 82.82 crore. The company, instead of making a provision of Rs.82.82 crore, has included this amount in its contingent liabilities due to which provision has been understated and contingent liabilities have been overstated by Rs.82.82 crores. The aforesaid calculations/workings for Rs. 1170.00 crore were submitted:
• pursuant to judicial directions,
• during the course of proceedings,
• on a provisional and without prejudice basis,
• And, subject to further arguments and adjudication, particularly regarding:
(I) The applicable USD exchange rate.
(ii) The methodology for determination of the final payable amount.
The non-recognition of provision to the extent of Rs.82.82 crore constitutes a departure from the accounting standards as prescribed under section 133 of the Act. Had the amount of Rs.82.82 crore been provided by the company, the provisions would have been increased by Rs.82.82 crore and the net profit and shareholders funds would have been reduced by the said amount.
Accordingly, the Management submits that the said calculations/workings cannot be construed as final crystallization or unconditional acceptance/admission of liability by the Company.
Further, against the original deposit of Rs.1088.62 crore made by MMTC in July 2022, substantial interest accrual amounting to approximately Rs.259.74 crore had accrued up to 01.11.2025 while the amount remained under custody of the Honble Court. The same is disclosed in Notes to Accounts no. 10. The rate of interest payable as decided by court is lesser than the Bank interest rate accruing on the amount deposited with Court.
Such accrued interest was available for adjustment against any additional amount, if any, that may ultimately become payable pursuant to the final judicial determination.
Accordingly, considering the substantial accrued interest available against the deposited amount, the Management assessed that no separate or incremental outflow of resources from the Company is expected in respect of the alleged differential liability of Rs.82.82 crore as referred to in the Audit Qualification.
In accordance with Ind AS 37 - "Provisions, Contingent Liabilities and Contingent Assets", a provision is required to be recognized only when all the following conditions are satisfied:
(a) An entity has a present obligation (legal or constructive) that is a result of a past event;
(b) it is probable that an outflow of resources embodying economic benefits will be required to settle the obligation; and
(c) a reliable estimate can be made of the amount of the obligation.
In reference to the above accounting standard, the condition mentioned at (b) does not satisfy as the chances of probable outflow for Rs. 82.82 crore is NIL, considering the accrued interest available with Court. Company had appropriately recognized the original liability of Rs.1088.62 crore, the incremental amount beyond the said deposit remained subject to:
• Adjudication by the Honble Court,
• Judicial clarification on applicable exchange rate and related methodology, and
• Adjustment against accrued interest lying with the Honble Court.
Considering the above facts and circumstances, the Management respectfully disagrees with the qualification made by Statutory Auditors as the provision of Rs.82.82 crore was not warranted on the reporting date and is appropriately disclosed as contingent Liability.
Key Audit Matters
Assessment of Significant Contingent Liabilities (other than the matter described in the Basis for Qualified Opinion section) There are a number of litigations pending before various forums against the Company and the managements judgement is required for estimating the amount to be disclosed as contingent liability. We identified this as a key audit matter because the estimates on which these amounts are based involve a significant degree of management judgement in interpreting the cases and to determine the possible outcome of those disputes and independent legal assessment to pursue the cases and it may be subject to management bias. Contingent liabilities are not recognized but disclosed in Notes to the Accounts when the company has possible obligation due to past events and existence of the obligation depends upon occurrence or non-occurrence of future events not wholly within the control of the company. Management has reasonably assessed the cases and disclosed contingent liabilities in note no 34 of standalone and consolidated financial statements.
(Refer Note No. 34 to the Standalone financial statements read with Accounting Policy No. 2.14)
Auditors Response:
We have obtained an understanding of the Companys internal instructions and procedures in respect of estimation and disclosure of contingent liabilities and adopted the following audit procedures:
• We obtained list of all the pending legal cases handled at Corporate office legal division as on 31st March 2026 with a note from management on the changes in the status of the cases from that of last year.
• understood and tested the design and operating effectiveness of controls as established by the management for obtaining all relevant information for pending litigation cases;
• discussed with the management regarding any material developments thereto and latest status of legal matters;
• read various correspondences and related documents pertaining to litigation cases and relevant external legal opinions obtained by the management and performed substantive procedures on calculations supporting the disclosure of contingent liabilities;
• examined managements judgements and assessments in respect of whether provisions are required;
• considered the management assessments of those matters that are not disclosed as contingent liability since the probability of material outflow is considered to be remote;
• reviewed the adequacy and completeness of disclosures;
Based on the audit procedures performed, except for the matter described in the Basis for Qualified Opinion Section of our Report, we did not identify any material exception in managements assessment and the related disclosures of significant contingent liabilities.
Material Uncertainty Related to Going Concern
We draw attention to Note No. 36(k) to the accompanying financial statements, which states that, MMTC has been directed by administrative ministry to prepare a road map for scaling down of manpower including exit from various JVs. Also direction has been given for exit from business operation. However, wind mill business is still in operation. Government is yet to decide the exit route for MMTC. As there is no communication from Ministry for closure etc., status quo of going concern is being maintained and the accounts have been prepared on going concern basis. Our opinion is not modified in respect of this matter. The status quo of going concern is being maintained. The company have prepared accounts on going concerned basis as disclosed in Note No 36(k).
Emphasis of Matters
We draw attention to Footnote to Note No. 10 to the accompanying financial statements, which states that, the Company has not recognized Deferred Tax Assets in respect of carry forward losses and timing differences during the current period, in view of the uncertainties involved. Further, the balance of Deferred Tax Asset During FY 2024-25, Statutory Auditor in its report under Other Matter reported that availability of sufficient future taxable income is uncertain for utilization of Deferred Tax Asset Rs. 163.79 crore. In response to audit observation, MMTC has assured to review and
already appearing in the books amounting to Rs. 163.79 crore has been adjusted/derecognized during the year in accordance with Ind AS 12 - "Income Taxes". adjust the DTA as per applicable Ind AS during FY2025-26. As stated above there is no probability of future business taxable income, hence DTA balance lying in the books has been derecognized as per compliance of Ind AS 12 and same has been duly disclosed in note no. 10.
We draw attention to Note No. 11 read with Note No. 32(ii)(a) to the accompanying financial statements, which states that, Gold/Silver/Jewellery/Dust/Solder held against Litigation Settlement and appearing under Other Current Assets and exceptional items amounting to Rs. 13.21 crore represents value of 12503.700 gms of confiscated gold jewellery/dust/ solder etc received from Customs Department on 19.01.2026 as per Honble Supreme Court order dated 24.04.2025. This pertains to a legal case filed by the company against supply of gold by MMTC to one of its associates for export under Exim Policy during FY 1991-92. The same has been certified by the BIS approved hallmarking centre and valued by the management based on rates published by the India Bullion and Jewellers Association (IBJA) as on 19 January 2026, considering certified quantity and purity. The valuation has not been carried out by an independent registered valuer as company believes that valuation so determined of above gold items based on certified purity and rates declared by IBJA is reasonable and appropriate. The Honble Supreme Court of India, vide its Order dated 24.04.2025, directed the Customs Department to hand over the confiscated gold to MMTC.
The matter relates to the supply of gold by MMTC to M/s Ramsons Jewellers during FY 1991-92 for export of jewellery. As per the prevailing policy, the exporter was required to fulfill the export obligation within 120 days from the date of issue of gold. However, M/s Ramsons Jewellers failed to export approximately 19 kg of gold supplied by MMTC within the stipulated period.
Subsequently, in 1997, the Customs Department,NSEz seized 12503.700 gms of gold in various forms, including gold jewellery, gold dust, and gold solder, from the factory premises of M/s Ramsons Jewellers. The seized material remained in Customs-sealed parcels under the custody of MMTC .
Pursuant to the aforesaid order of the Honble Supreme Court, MMTC DRO took possession of the confiscated parcels from the Customs Department on 19.01.2026.
Accordingly, for the purpose of valuation, the gold rate prevailing on 19.01.2026, as published by the India Bullion and Jewellers Association (IBJA), has been considered, since MMTC acquired physical possession of the confiscated gold on that date.
Further, the purity of the gold jewellery, gold dust, and gold solder contained in the confiscated parcels has been determined on the basis of XRF analysis and Fire Assay reports issued by an independent BIS-approved Hallmarking Centre.
The valuation has therefore been arrived at based on the purity established through the aforesaid test reports and the applicable IBJA gold rate as on 19.01.2026.
We draw attention to Note No. 32(I) to the accompanying financial statements, which states that, Neelanchal Ispat Nigam Ltd (NINL)-Joint Venture company divestment has been completed on 4.7.2022; Neelachal Ispat Nigam Ltd (NINL)-Joint Venture company divestment has been completed on 4.7.2022.
According to the Share Purchase Agreement (SPA) for divestment of NINL, the period of limitation of 3 years for any unforeseen liability on NINL post divestment not exceeding 20% of the amount received by the sellers from Bid amount has also completed on 04.07.2025 and no Liability has accrued. Also, an amount of Rs. 774.95 crore (MMTCs share: Rs. 411.76 crore), kept in an interest-
As per the clause of Share Purchase Agreement (SPA) for divestment of NINL, any unforeseen liability on NINL post divestment shall be borne by Sellers/ Promoters as per the warranty clause of SPA until the period of 3 years from date of completion. The aggregate liability of the Sellers and Promoters cannot exceed 20% of the amount received by the sellers from Bid amount, by way of sale consideration and discharge of their respective Seller Debt. MMTCs maximum liability in this regard, if
any, works out to Rs. 1067 crore. The period of 3 years has expired on 04.07.2025 and until that date, no Liability has accrued. bearing escrow account with SBI, Bhubaneswar, matured on 04.07.2025 and as the limitation period of three years also concluded on the same date, the amount available in the escrow account as on 04.07.2025 along with the accrued interest was distributed among the promoters of NINL in their share holding ratio. Accordingly, MMTC received Rs. 411.76 crore towards principal and Rs. 25.75 crore towards interest (net of TDS and bank charges) on 04.07.2025 and was accounted for in the books of MMTC.
An amount of Rs. 774.95 crore (MMTCs share: Rs. 411.76 crore), kept in an interest-bearing escrow account with SBI, Bhubaneswar, matured on 04.07.2025. As the limitation period of three years concluded on the same date, the amount available in the escrow account as on 04.07.2025 along with the accrued interest was distributed among the promoters of NINL. Accordingly, MMTC received Rs. 411.76 crore towards principal and Rs. 25.75 crore towards interest (net of TDS and bank charges) on 04.07.2025. The aforesaid sum of Rs. 411.76 crore has been booked as income for the year under exceptional items.
Further, Escrow account is closed as nothing is payable/ receivable from NINL as on date.
In view of expiry of limitation period of 3 years on 04.07.2025, nothing is payable/ receivable from NINL as on date.
We draw attention to Footnote to Note No. 31 to the accompanying financial statements, which states that, during the year, Trade Receivables of Rs. 75.49 crore has been written off as bad debts by Camp Office Chennai and corresponding provisions there against has been written back under exceptional items. The write off of Trade Receivable and corresponding Provision written back has no impact on profitability of the Company during the FY 2025-26.
We draw attention to Note No. 36(d) to the accompanying financial statements, which states that, the Company has filed a recovery suit of Rs. 31.40 crore against M/s. Aaryavart Impex Pvt Ltd. (AIPL) in respect of Mint sale transaction (PY Rs. 31.40 crore) which included overdue interest of Rs. 2.95 crore (P.Y. Rs. 2.95 crore) which has been decreed in favor of the Company. MMTC filed execution petition and matter will be heard on 08.06.2026. The company has written off the amount of Rs. 28.45 crore in the year 2015-16 due to non-realization of the same. M/s AIPL have also filed a suit against Government Mint/MMTC for damages of Rs. 167.20 crore (P.Y. Rs. 167.20 crore) which is not tenable as per legal opinion and is being contested. Besides this, the same has not been considered as a contingent liability because the management is of the view that there is no present or possible liability on the company in this case. The Company has filed a recovery suit of Rs. 31.40 crore against M/s. Aaryavart Impex Pvt Ltd. (AIPL) now changed to Anmol Tradeline Pvt. Ltd. (ATPL) in respect of Mint sale transaction (P.Y. Rs. 31.40 crore) which included overdue interest of Rs. 2.95 crore (P.Y. Rs. 2.95 crore) which has been decreed in favour of the Company. MMTC filed execution petition and matter was heard on 01.08.2025 and Honble Court has granted last opportunity to file affidavit and admission and denial to ATPL. The company has written off the amount of Rs. 28.45 Crore in the FY 2015-16 due to non-realization of the same. M/s AIPL (now changed to ATPL) have also filed a suit against MMTC for damages of Rs. 167.20 crore which is not tenable as per legal opinion and is being contested. MMTC has filed denial affidavit before the Honble Court in this regards. Besides this, the same has not been considered as a contingent liability because the management is of the view that there is no present or possible liability on the company in this case."
Matter is pending before Commercial Court, Ahmedabad. Matter came up for hearing before newly designated commercial court of Judge Shri Prajapati.
In response to the notices issued to the banks by the Court, Social Co-Operative Bank and Mehsana Co-Operative Bank appeared and filed statement of account. IndusInd bank stated that if they can have PAN of AIPL and ATPL, and will produce bank account details. Matter stands adjourned to 18-08-2026.

Knowledge Center
Logo

Logo IIFL Customer Care Number
(Gold/NCD/NBFC/Insurance/NPS)
1860-267-3000 / 7039-050-000

Logo IIFL Capital Services Support WhatsApp Number
+91 9892691696

Download The App Now

appapp
Loading...

Follow us on

facebooktwitterrssyoutubeinstagramlinkedintelegram

2026, IIFL Capital Services Ltd. All Rights Reserved

ATTENTION INVESTORS

RISK DISCLOSURE ON DERIVATIVES

Copyright © IIFL Capital Services Limited (Formerly known as IIFL Securities Ltd). All rights Reserved.

IIFL Capital Services Limited - Stock Broker SEBI Regn. No: INZ000164132 (Member ID - NSE: 10975 BSE: 179 MCX: 55995 NCDEX: 01249), DP SEBI Reg. No. IN-DP-185-2016, PMS SEBI Regn. No: INP000002213, IA SEBI Regn. No: INA000000623, Merchant Banker SEBI Regn. No. INM000010940, RA SEBI Regn. No: INH000000248, BSE Enlistment Number (RA): 5016, AMFI-Registered Mutual Fund Distributor & SIF Distributor
ARN NO : 47791 (Date of initial registration – 17/02/2007; Current validity of ARN – 08/02/2027), PFRDA Reg. No. PoP 20092018, IRDAI Corporate Agent (Composite) : CA1099

ISO certification icon
We are ISO/IEC 27001:2022 Certified.

This Certificate Demonstrates That IIFL As An Organization Has Defined And Put In Place Best-Practice Information Security Processes.