monsanto india ltd Auditors report


To the Members of Monsanto India Limited

Report on the Audit of the Financial Statements Opinion

We have audited the financial statements of Monsanto India Limited ("the Company"), which comprise the balance sheet as at 31st March, 2019, and the statement of profit and loss, statement of changes in equity and statement of cash flows for the year then ended, and notes to the financial statements, including a summary of significant accounting policies and other explanatory information.

In our opinion and to the best of our information and according to the explanations given to us, the aforesaid 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 accounting principles generally accepted in India, of the state of affairs of the Company as at 31st March, 2019, profit, changes in equity and its cash flows for the year ended on that date.

Basis for Opinion

We conducted our audit in accordance with the Standards on Auditing (SAs) specified under section 143(10) of the Act. Our responsibilities under those Standards are further described in the Auditors Responsibilities for the Audit of the 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 ethical requirements that are relevant to our audit of the financial statements under the provisions of the Act and the Rules thereunder, and we have fulfilled our other ethical responsibilities in accordance with these requirements and the Code of Ethics. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.

Key Audit Matters

Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the financial statements of the current period. These matters were addressed in the context of our audit of the financial statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters.

1. Recognition, Valuation and Presentation of Provisions and Contingent Liabilities:

Refer to note 9 and note 35 of the financial statements. The Company has number of significant outstanding income tax litigation with different authorities of Income Tax department.

As of 31st March, 2019, the Company has net tax asset of Rs 166.37 crores. In addition, the Company has disclosed significant contingent liability pertaining to Income tax and other contingent liabilities in Note 35.

Given the complexity and magnitude of potential exposure to the Company, the assessment of the existence of the present legal or constructive obligation, analysis of the probability of the related payment and analysis of a reliable estimate, involves significant judgement by the management. Due to the level of judgement relating to recognition, valuation and presentation of provisions and contingent liabilities, this is considered to be a key audit matter.

Our audit procedures in respect of this matter included:

Evaluated the design and performed testing of the relevant controls to evaluate the operating effectiveness and assessed how the Company monitors legal, tax and regulatory developments and their assessment of the potential impact on the Company.

Involved auditors expert to go through the summary of litigation matters provided by the Companys tax team and discussed each of the material cases noted in the report to determine the Companys assessment of the likelihood and magnitude of any liability that may arise.

Obtained confirmation from managements consultant with respect to ongoing tax litigations and held discussions regarding the material cases with the management.

Reviewed the provisions recorded and assessed the adequacy of disclosures in the financial statements.

Reviewed minutes of board meetings, including the sub-committees.

2. Valuation of biological assets

Refer to note 11 in the financial statements for the related disclosures.

The biological assets of the Company represent the unharvested / standing crops of Corn as on the reporting date. Ind AS 41, Agriculture, requires that biological assets shall be recognized at its fair value less point of sale costs, except when there is inability to measure fair value reliably.

Based on the assessment done by the management of the Company, there are neither observable market prices for these unharvested / standing crops nor are there alternative estimates of fair value that are determined to be clearly reliable that give a fair expression of the fair values. Hence, the unharvested / standing crops of corn are measured at initial recognition and at each financial reporting date at cost.

Management determines the cost of biological assets based on a methodology using the following key estimates:

- Sowing plan

- Crop stage

- expected crop yield/production; - Production report; and - cost incurred as on date;

The resulting estimate is highly sensitive to the inputs and requires management to make several judgemental assumptions and assessments. As at 31st March, 2019, the above methodology was applied to the unharvested / standing crops of corn with the carrying value of Rs 3.15 crores.

Due to the degree of judgement involved in the valuation of biological assets, this is considered as Key Audit Matter.

Our audit procedures in respect of this matter included:

Understanding the policies and procedures applied to recognizing cost of biological asset as well as compliance therewith, including an analysis of the effectiveness of controls.

Reviewed the principles used in the valuation of the standing crop and analysed the key assumptions.

Performed detailed testing on the key inputs into valuation including estimated yields, crop stage and confirm validity, accuracy and completeness of the production report.

Compared the prior year estimated yields to the current year actuals attained to assess the reasonableness and accuracy of management estimates.

Reviewed and recalculated the formulae as per the production report for accuracy.

3. Revenue recognition

Refer the disclosures related to revenue recognition in note 2(O), note 23 and note 40 of the financial statements.

Revenue is recognized in accordance with Ind AS 115, net of discounts, incentives and rebates accrued to the customers based on sales and returns from customer. The estimate associated with these discounts, incentives, and rebates involves significant estimates. Consequently, there is a possibility that the contractual terms that give rise to these adjustments to sales are incorrectly recorded and thus, revenue recognized in the financial statements may be incorrectly measured.

We determined this matter to be a key audit issue due to the variety of discounts and incentives offered, as well as the complexity associated with the estimates that management must make to record some of them at year end.

Our audit procedures in respect of this matter included:

Understood the policies and procedures applied to revenue recognition as well as compliance therewith, including performing testing of controls to assess the effectiveness of the same.

Verified and discussed with management significant discount, incentives and rebates schemes rolled by the management including contractual terms and conditions related to discounts and incentives, as well as the assumptions used in the related estimates.

Verified the relevant estimates made and checked approvals in connection with discounts, incentives and rebates at year end.

Enquired if there is any change in the estimation method from the last year.

Verified other adjustments and credit notes issued after the reporting date particularly the true up/true down working and relevant approval for adjustments.

Reviewed disclosures included in the notes to the financial statements.

4. Sales return reserve

Refer the disclosures related to Revenue recognition in Note 2 (O), note 22, note 23 and note 40 of the financial statements.

Revenue is recognized net of actual sales returns and sales return reserve, which is based on management estimates. The Company creates sales return reserve against each sales invoice generated at a predefined rate and does true-up of the sales return reserve based on the inputs received from the sales and commercial team at the year end. The method of creating the sales return reserves requires significant estimate based on complex, highly subjective judgments and hence require special audit consideration due to geographical, environmental factors, market conditions, historical experience and complexity associated with the estimates that management make to record them at year end. Since the said matter is subject to managements judgment, the rationality of the basis is one of the key audit matters.

Our audit procedures in respect of this matter included:

Understood the policies and procedures applied to creation of sales return reserve, including performing testing of controls to assess the effectiveness of the same.

Analysed if the sales return reserve is created for all invoices generated during the year as per the rate approved by the management.

Verified the relevant estimates made and checked approvals in connection with sales return reserve created at year end.

Enquired if there is any change in the estimation method from the last year.

Verified other adjustments and credit notes issued after the reporting date particularly the true up/true down working and relevant approval for adjustments.

Reviewed disclosures included in the notes to the financial statements.

5. Allowance for inventory obsolescence

Refer to note 12 of the financial statements.

The Company holds significant inventories and records allowance for identified and estimated inventory obsolescence. As at 31st March, 2019, the Company had inventories of Rs 277.71 crores. The Company provides for obsolescence for Corn business considering the inventory on hand, expected harvest and expected sales till the end of the crop year. Further the estimates are validated by Laboratory tests and trends of the obsolescence in the past. The obsolescence covers inventory under work-in-progress and finished goods. Given the significant judgment involved in managements assessment, the allowance for inventory obsolescence is identified as a key audit matter.

Our audit procedures in respect of this matter included:

Understood management policy and process for identification of providing of obsolete inventory, including performing testing of controls to assess the effectiveness of the same.

Reviewed the managements judgement applied in calculating the value of inventory obsolescence, taking into consideration laboratory testing reports and management assessment of the present and future condition of the inventory.

Assessed the adequacy of the relevant disclosure in the notes to the financial statements.

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 Management report, Chairmans statement, Directors report etc. but does not include the financial statements and our auditors report thereon

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

In connection with our audit of the financial statements, our responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent with the financial statements or our knowledge obtained in the 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. We have nothing to report in this regard.

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

The Companys Board of Directors is responsible for the matters stated in section 134(5) of the Act with respect to the preparation of these financial statements that give a true and fair view of the financial position, financial performance, changes in equity and cash flows of the Company in accordance with the accounting principles generally accepted in India, including the Accounting Standards specified under section 133 of the Act. This responsibility also includes maintenance of adequate accounting records in accordance with the provisions of the Act for safeguarding of the assets of the Company and for preventing and detecting frauds and other irregularities; selection and application of appropriate accounting policies; making judgments and estimates that are reasonable and prudent; and design, implementation and maintenance of adequate internal financial controls, that were operating effectively for ensuring the accuracy and completeness of the accounting records, relevant to the preparation and presentation of the financial statement that give a true and fair view and are free from material misstatement, whether due to fraud or error.

In preparing the financial statements, the Board of Directors 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 the Board of Directors either intends to liquidate the Company or to cease operations, or has no realistic alternative but to do so.

Those Board of Directors are also responsible for overseeing the Companys financial reporting process.

Auditors Responsibilities for the Audit of the Financial Statements

Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material 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 financial statements.

We give in "Annexure A" a detailed description of Auditors responsibilities for Audit of the Financial Statements.

Report on Other Legal and Regulatory Requirements

1. As required by the Companies (Auditors Report) Order, 2016 ("the Order"), issued by the Central Government of India in terms of sub-section (11) of section 143 of the Act, we give in "Annexure B" a statement on the matters specified in paragraphs 3 and 4 of the Order, to the extent applicable.

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

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

(b) 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, the Statement of Changes in Equity and the cash flow statement dealt with by this Report are in agreement with the books of account.

(d) In our opinion, the aforesaid financial statements comply with the Accounting Standards specified under Section 133 of the Act, read with Rule 7 of the Companies (Accounts) Rules, 2014.

(e) On the basis of the written representations received from the directors as on 31st March, 2019 taken on record by the Board of Directors, none of the directors is disqualified as on 31st March, 2019 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 with reference to financial statements of the Company and the operating effectiveness of such controls, refer to our separate Report in "Annexure C".

(g) With respect to the other matters to be included in the Auditors Report in accordance with Rule 11 of the Companies (Audit and Auditors) Rules, 2014, in our opinion and to the best of our information and according to the explanations given to us:

i. The Company has disclosed the impact of pending litigations on its financial position in its financial statements – Refer Note 35 to the financial statements; ii. The Company did not have any long-term contracts including derivative contracts for which there were any material foreseeable losses.

iii. There has been no delay in transferring amounts, required to be transferred, to the Investor Education and Protection Fund by the Company.

3. As required by The Companies (Amendment) Act, 2017, in our opinion, according to information, explanations given to us, the remuneration paid by the Company to its directors is within the limits laid prescribed under Section 197 of the Act and the rules thereunder.

For MSKA & Associates
Chartered Accountants
ICAI Firm Registration No. 105047W
Yogesh Sharma
Date: 30th April, 2019 Partner
Place: Mumbai Membership No. 211102

ANNEXURE A

TO THE INDEPENDENT AUDITORS REPORT ON EVEN DATE ON THE FINANCIAL STATEMENTS OF MONSANTO INDIA LIMITED

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

Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances. Under section 143(3)(i) of the Act, we are also responsible for expressing our opinion on whether the company has internal financial controls with reference to 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 made by management.

Conclude on the appropriateness of managements use of the going concern basis of accounting and, based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Companys ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditors report to the related disclosures in the financial statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based on the audit evidence obtained up to the date of our auditors report. However, future events or conditions may cause the Company to cease to continue as a going concern.

Evaluate the overall presentation, structure and content of the financial statements, including the disclosures, and whether the financial statements represent the underlying transactions and events in a manner that achieves fair presentation.

We communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit and significant audit findings, including any significant deficiencies in internal control that we identify during our audit.

We also provide those charged with governance with a statement that we have complied with relevant ethical requirements regarding independence, and to communicate with them all relationships and other matters that may reasonably be thought to bear on our independence, and where applicable, related safeguards.

From the matters communicated with those charged with governance, we determine those matters that were of most significance in the audit of the financial statements of the current period and are therefore the key audit matters. We describe these matters in our auditors report unless law or regulation precludes public disclosure about the matter or when, in extremely rare circumstances, we determine that a matter should not be communicated in our report because the adverse consequences of doing so would reasonably be expected to outweigh the public interest benefits of such communication.

For MSKA & Associates
Chartered Accountants
ICAI Firm Registration No. 105047W
Yogesh Sharma
Date: 30th April, 2019 Partner
Place: Mumbai Membership No. 211102

ANNEXURE B

TO INDEPENDENT AUDITORS REPORT OF EVEN DATE ON THE FINANCIAL STATEMENTS OF MONSANTO INDIA LIMITED FOR THE YEAR ENDED 31ST MARCH, 2019

[Referred to in paragraph 1 under ‘Report on Other Legal and Regulatory Requirements in the Independent Auditors Report]

i. (a) The Company has maintained proper records showing full particulars including quantitative details and situation of fixed assets.

(b) All the fixed assets (Property, Plant and Equipment) have not been physically verified by the management during the year but there is a regular program of verification which, in our opinion, is reasonable having regard to the size of the Company and the nature of its assets. No material discrepancies were noticed on such verification.

(c) According to the information and explanations given to us and on the basis of our examination of the records of the Company, the title deeds of immovable properties are held in the name of the Company.

ii. The inventory, including stock with third parties, has been physically verified during the year by the management. In our opinion, the frequency of verification is reasonable. No material discrepancies were noticed on verification between the physical stock and the book records.

iii. The Company has not granted any loans, secured or unsecured to Companies, Firms, Limited Liability Partnerships (LLP) or other parties covered in the register maintained under section 189 of the Companies Act, 2013 (‘the Act). Accordingly, the provisions stated in paragraph 3 (iii) (a) to (c) of the Order are not applicable to the Company.

iv. In our opinion and according to the information and explanations given to us, the Company has not either directly or indirectly, granted any loan to any of its directors or to any other person in whom the director is interested, in accordance with the provisions of section 185 of the Act and the Company has not made investments through more than two layers of investment companies in accordance with the provisions of section 186 of the Act. Accordingly, provisions stated in paragraph 3(iv) of the Order are not applicable to the Company.

v. In our opinion and according to the information and explanations given to us, the Company has not accepted any deposits from the public within the meaning of Sections 73, 74, 75 and 76 of the Act and the rules framed there under.

vi. We have broadly reviewed the books of account relating to materials, labour and other items of cost maintained by the Company pursuant as specified by the Central Government for the maintenance of cost records under sub-section (1) of section 148 of the Act and we are of the opinion that prima facie the prescribed accounts and records have been made and maintained. We have not, however, made a detailed examination of the records with a view to determine whether they are accurate or complete.

vii. (a) According to the information and explanations given to us and the records of the Company examined by us, in our opinion, the Company is regular in depositing with appropriate authorities undisputed statutory dues including provident fund, income-tax, goods and service tax, duty of customs, cess and any other statutory dues applicable to it.

There were no undisputed amounts payable in respect of provident fund, income tax, goods and service tax, customs duty, cess and other material statutory dues in arrears as at 31st March, 2019 for a period of more than six months from the date they became payable.

(b) According to the information and explanation given to us and examination of records of the Company, the outstanding dues of income-tax, goods and service tax, cess and any other statutory dues on account of any dispute, are as follows:

Name of the statute Nature of dues Amount Rs in crores Period to which the amount relates Forum where dispute is pending
Income Tax Act, 1961 Income tax demand 35.49# Assessment year 2008-09, 2010-11, 2011-12 and 2016-17 Commissioner of Income Tax, Appeals (CIT(A))
Income Tax Act, 1961 Income tax demand 203.25" Assessment year 2009-10 to 2015-16 Income Tax Appellate Tribunal (ITAT)
Finance Act, 1994 Service Tax 18.36 October 2009- June 2017 Commissioner of GST and Central Excise

 

Name of the statute Nature of dues Amount Rs in crores Period to which the amount relates Forum where dispute is pending
Entry Tax Act, 1976 Entry Tax 0.11 2015-16 Assistant Commissioner, Anti Evasion
Various state Value Added tax Value Added Tax 2.13^ 2002-03, 2009-10 to 2013-14 Deputy Commissioner of Commercial Tax

# 6.04 paid under protest " 158.02 paid under protest ^ 1.28 paid under protest

viii. The Company does not have any loans or borrowings from any financial institution, banks, government or debenture holders during the year. Accordingly, the provision stated in paragraph 3(viii) of the Order is not applicable to the Company.

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

x. During the course of our audit, examination of the books and records of the Company, carried out in accordance with the generally accepted auditing practices in India, and according to the information and explanations given to us, we have neither come across any instance of material fraud by the Company or on the Company by its officers or employees.

xi. According to the information and explanations given to us and based on our examination of the records of the Company, the Company has paid/ provided for managerial remuneration in accordance with the requisite approvals mandated by the provisions of section 197 read with Schedule V to the Act.

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

xiii. According to the information and explanations given to us and based on our examination of the records of the Company, transactions with the related parties are in compliance with sections 177 and 188 of the Act where applicable and details of such transactions have been disclosed in the financial statements as required by the applicable accounting standards.

xiv. 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 or partly convertible debentures during the year. Accordingly, the provisions stated in paragraph 3 (xiv) of the Order are not applicable to the Company.

xv. According to the information and explanations given to us and based on our examination of the records of the Company, the Company has not entered into non-cash transactions with directors or persons connected with him. Accordingly, provisions stated in paragraph 3(xv) of the Order are not applicable to the Company.

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

For MSKA & Associates
Chartered Accountants
ICAI Firm Registration No. 105047W
Yogesh Sharma
Date: 30th April, 2019 Partner
Place: Mumbai Membership No. 211102

ANNEXURE C

TO THE INDEPENDENT AUDITORS REPORT OF EVEN DATE ON THE FINANCIAL STATEMENTS OF MONSANTO INDIA LIMITED

[Referred to in paragraph 2(f) under ‘Report on Other Legal and Regulatory Requirements in the Independent Auditors Report]

Report on the Internal Financial Controls under Clause (i) of Sub-section 3 of Section 143 of the Companies Act, 2013 ("the Act")

We have audited the internal financial controls with reference to financial statements of Monsanto India Limited ("the Company") as of 31st March, 2019 in conjunction with our audit of the financial statements of the Company for the year ended on that date.

Managements Responsibility for Internal Financial Controls

The Companys Management is responsible for establishing and maintaining internal financial controls based on the internal control with reference to financial statements criteria established by the Company considering the essential components of internal control stated in the Guidance Note on Audit of Internal Financial Controls Over Financial Reporting issued by the Institute of Chartered Accountants of India (ICAI) (the "Guidance Note"). These responsibilities include the design, implementation and maintenance of adequate internal financial controls that were operating effectively for ensuring the orderly and efficient conduct of its business, including adherence to Companys policies, the safeguarding of its assets, the prevention and detection of frauds and errors, the accuracy and completeness of the accounting records, and the timely preparation of reliable financial information, as required under the Act.

Auditors Responsibility

Our responsibility is to express an opinion on the Companys internal financial controls with reference to financial statements based on our audit. We conducted our audit in accordance with the Guidance Note and the Standards on Auditing, issued by ICAI and deemed to be prescribed under section 143(10) of the Act, to the extent applicable to an audit of internal financial controls. 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 internal financial controls with reference to financial statements was established and maintained and if such controls operated effectively in all material respects.

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

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion on the Companys internal financial controls with reference to financial statements.

Meaning of Internal Financial Controls With Reference to Financial Statements

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

Inherent Limitations of Internal Financial Controls With Reference to Financial Statements

Because of the inherent limitations of internal financial controls with reference to financial statements, including the possibility of collusion or improper management override of controls, material misstatements due to error or fraud may occur and not be detected. Also, projections of any evaluation of the internal financial controls with reference to financial statements to future periods are subject to the risk that the internal financial control with reference to financial statements 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, the Company has, in all material respects, an internal financial controls with reference to financial statements and such internal financial controls with reference to financial statements were operating effectively as at 31st March, 2019, based on the internal control with reference to financial statements criteria established by the Company considering the essential components of internal control stated in the Guidance Note.

For MSKA & Associates
Chartered Accountants
ICAI Firm Registration No. 105047W
Yogesh Sharma
Date: 30th April, 2019 Partner
Place: Mumbai Membership No. 211102