National Aluminium Company Ltd Auditor Reports

To the Members of

National Aluminium Company Limited

Report on the Audit of the Standalone Financial Statements Opinion

We have audited the accompanying standalone financial statements of National Aluminium Company Limited ("the Company"), which comprise the Balance Sheet as at March 31, 2026, the Statement of Profit and Loss (including Other Comprehensive Income), the Statement of Changes in Equity and the Statement of Cash Flows for the year ended and notes to the standalone financial statements including a summary of material accounting policies and other explanatory information (hereinafter referred to as the "Standalone Financial Statements").

In our opinion and to the best of our information and according to the explanations given to us, the aforesaid standalone financial statements give the information required by the Companies Act, 2013 (the "Act") in the manner so required and give a true and fair view in conformity with Indian Accounting Standards specified under section 133 of the Act read with the Companies (Indian Accounting Standards) Rules 2015, as amended and other accounting principles generally accepted in India, of the state of affairs of the Company as at March 31, 2026, and total comprehensive income (comprising of profit and other comprehensive income), changes in equity and its cash flows for the year ended on that date.

Basis for Opinion

We conducted our audit of the standalone financial statements 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 standalone financial statements section of our report. We are independent of the Company in accordance with the Code of Ethics issued by the Institute of Chartered Accountants of India ("ICAI"), together with the ethical requirements that are relevant to our audit of the standalone 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 ICAIs Code of Ethics. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion on the standalone financial statements.

Emphasis of Matter

We draw attention to

i. Note no. 28.3 and 5.3.1 regarding non-recognition of revenue and impairment assessment of related assets respectively from/of two wind power plants located in the state of Rajasthan since 01.04.2019 in view of no fresh Power Purchase Agreement having been signed.

ii. Note no. 22.3 to the financial statements regarding Provisional assessment and recognition of financial impact arising due to promulgation of the new labour codes, effective from 21^st November, 2025.

Our opinion on the Standalone Financial Statements is not modified in respect of the above matter.

Key Audit Matters

Key audit matters are those matters that, in our professional judgement, were of most significance in our audit of the Standalone Financial Statements of the current period. ese matters were addressed in the context of our audit of the Standalone Financial Statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters. e key audit matters that we have identified in the current year are as follows:

Key Audit Matter	Response of the Auditors in dealing with the matters
1. Carrying value of Property, Plant and Equipment, Capital work-in-progress, Intangible assets and Intangible Assets under Development
Property, plant and equipment, capital work-in-progress, intangible assets and Intangible assets under development represent significant balances recorded in the statement of financial position. e evaluation of the recoverable amount of these assets requires significant judgement in determining the key assumptions supporting the expected future cash flows of the business and the utilisation of the relevant assets including impairment provisions related to the assets. ere are a number of areas where Management judgement impacts the carrying value of property, plant and equipment, intangible assets and their respective depreciation profiles. ese include the decision to capitalise or expense costs; the asset life review including the impact of changes in the Companys strategy; and the timeliness of capitalisation, determination or the measurement and recognition criteria for assets retired from active use.	Our audit procedures included the following:
	We evaluated the assumptions made by Management in the determination of carrying values and useful lives to ensure that these are consistent with the principles of Indian
	Accounting Standards (Ind AS) 16 Property, Plant and Equipment and Ind AS 38 Intangible Assets.
	We assessed whether the carrying values and the useful lives were reasonable by challenging Managements judgements through comparing the useful lives prescribed in Schedule II to the Companies Act, 2013 and the useful lives of certain assets as per the technical assessment of the Management.
	We compared the useful lives of each class of asset in the current year to the previous year to determine whether there were any significant changes in the useful lives of assets, and considered the reasonableness of changes based on our knowledge of the business and the industry.
	We assessed whether indicators of impairment existed as at 31st March 2026 based on our knowledge of the business and the industry and wherever required the provision of impairment of assets/CWIP were reviewed.
	We tested the controls in place over the property, plant and equipment and intangible assets, evaluated the appropriateness of capitalisation policies, performed tests of details on costs capitalised and assessed the timeliness of capitalisation including decapitalisation of assets retired from active use and the application of the asset life.
	In performing these substantive procedures, we assessed the judgements made by Management including the nature of underlying costs capitalised; the appropriateness of asset lives applied in the calculation of depreciation and amortisation; and in assessing the need for accelerated depreciation/amortisation, if required, in the context of impairment.

 

2. Valuation of employees defined benefit obligations and other long-term benefits
Company has recognised long-term employee benefit liabilities and defined benefit obligations (net of plan asset against funded gratuity obligation). e valuation of employee benefit obligations is dependent on market conditions and assumptions made. e key audit matter specifically relates to the following key assumptions like discount rate, inflation expectations and life expectancy assumptions. e setting of these assumptions is complex and requires the exercise of significant Management judgement with the support of third-party actuary.	Our audit procedures relating to the valuation of employees, defined benefit obligations and other long-term benefits included the following:
	In testing the valuation, we have examined the reports of external actuarial specialists to review the key actuarial assumptions used, both financial and demographic, and considered the methodology utilised to derive these assumptions
	We evaluated the assumptions made by Management and the actuary to ensure that these are consistent with the principles of Ind AS 19 Employee Benefits.
	Furthermore, we have examined the sensitivity analysis on the key assumptions in valuing the defined benefit obligations.

 

3. Advances and deposits in respect of tax matters under litigation continuing as assets
Financial Statements disclose other assets, which includes material recoverable claims of direct and indirect tax deposits (net of provision) including VAT and CENVAT credits which are pending adjustment/ adjudication .	Our audit procedures relating to the advance and deposits in respect of tax matters under litigation continuing as assets included the following:
Significant judgement is required in assessing the nature of these exposures and their accounting and disclosure requirements.	We obtained from Management the details of completed tax assessments and demands and appeal orders of the appellate authority.
	We involved our internal experts to challenge the Managements underlying assumptions in estimating the tax liability and the possible outcome of the disputes.
	Our internal experts also considered legal precedence and other rulings in evaluating Managements position on these uncertain tax positions.
	Additionally, we have considered opinions of legal and tax experts, wherever available, to review the nature of the amounts recoverable, the sustainability and the likelihood of recoverability upon final resolution.

 

4. Valuation of deferred tax assets and liabilities
Company has disclosed deferred tax assets/liabilities in the Financial Statements.	Our audit procedures relating to the advance and deposits in respect of tax matters under litigation continuing as assets included the following:
Company operates in activities which involves application of various provisions in income tax. assessment of the valuation of deferred tax assets/liabilities, resulting from temporary differences, and provisions for uncertain tax positions is significant to our audit as the calculations are complex and depend on sensitive and judgemental assumptions. ese include, amongst others, long- term future profitability and local fiscal regulations and developments.	Ascertained the completeness and accuracy of the deferred tax assets/liabilities and recognizing uncertain tax positions.
	We challenged and tested the Managements assessment of the recoverability of the deferred tax assets, and the probability of future cash outflows in respect of deferred tax liabilities identified by the Company.

 

5. Ascertainment, disclosure and provisioning in respect of contingent liabilities
Company has material uncertain tax matters, both direct and indirect, under dispute involving material aggregate demand which require significant judgement to determine the possible outcome of these disputes. Additionally, the Company has other on-going legal matters relating to various claims by the Government of Odisha or other agencies constituted by the State Government and by contractors/suppliers which require application of Management judgement in order to determine the likely outcome.	Our audit procedures relating to the ascertainment, disclosure and provisioning in respect of contingent liabilities included the following:
	We obtained a detailed understanding and evaluated the design and implementation of controls that the Company has established in relation to disclosure and provisioning of contingent liabilities in accordance to Ind AS 37 Provisions, Contingent Liability and Contingent Assets. Regarding direct and indirect tax contingent liabilities, we undertook following principal audit procedures:
	Assessment of the process and relevant controls implemented to identify tax litigations and pending administrative proceedings.
	Reviewing orders and other communication from tax and other regulatory authorities and management responses thereto.
	Discussion with the Management regarding the status of the most significant disputes and inspection of the key relevant documentation.
	Analysis of opinion received from tax experts where available.
	Review of the adequacy of the disclosures in the notes to the financial statements In assessing the potential exposures of the Company in respect of other contingent liabilities, we have:
	Assessed the design and implementation of controls in relation to the monitoring of known exposures;
	Referred Board and other meeting minutes to identify areas subject to Companys consideration;
	Consulted with the Companys internal legal advisors in understanding on-going and potential legal matters impacting the Company;
	Reviewed available legal opinions from experts; and Reviewed the proposed accounting and disclosure of actual and potential legal liabilities.

Information Other than the Standalone Financial Statements and Auditors Report ereon

e Companys Board of Directors is responsible for the preparation of the other information. e other information comprises the information included in the Financial Performance highlights, Boards Report including Annexure to Boards Report, Management Discussions and Analysis, Business Responsibility and Sustainability Report, Report on Corporate Governance, Shareholders Information and other information in the Integrated Annual Report but does not include the standalone financial statements and our auditors report thereon. Our opinion on the standalone financial 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 financial statements, our responsibility is to read the other information identified above when it becomes available, and in doing so, consider whether the other information is materially inconsistent with the standalone financial statements or our knowledge obtained during the course of our audit, or otherwise appears to be materially misstated.

If, based on the work we have performed on the other information that we obtained prior to the date of auditors report, we conclude that there is a material misstatement of this information, we are required to report that fact. We have nothing to report in this regard.

When we read the other information, which we will obtain after the date of auditors report and 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 ose Charged with Governance for the Standalone Financial Statements

e Companys Board of Directors is responsible for the matters stated in section 134(5) of the Act with respect to the preparation of these Standalone Financial Statements that give a true and fair view of the financial position, financial performance, total comprehensive income, changes in equity and cash flows of the Company in accordance with the accounting principles generally accepted in India, including the Indian Accounting Standards (Ind AS) specified under section 133 of the Act. is 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 standalone financial statements that give a true and fair view and are free from material misstatement, whether due to fraud or error. In preparing the standalone 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 management either intends to liquidate the Company or to cease operations, or has no realistic alternative but to do so. e Board of Directors is also responsible for overseeing the Companys financial reporting process.

Auditors Responsibility for the Audit of the Standalone Financial Statements

Our objectives are to obtain reasonable assurance about whether the standalone 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 standalone 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 standalone 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. e 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 adequate internal financial controls with reference to standalone 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 ability of the Company to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditors report to the related disclosures in the standalone 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 standalone financial statements, including the disclosures, and whether the standalone 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 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 significance in the audit of the standalone 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.

Report on Other Legal and Regulatory Requirements

1. As required by the Companies (Auditors Report) Order, 2020 ("the Order") issued by the Central Government of India in terms of sub- section (11) of Section 143 of the Act, we give in the "Annexure A" a statement on the matters specified in the paragraphs 3 and 4 of the said Order, to the extent applicable.

2. We are enclosing our report in terms of Section 143 (5) of the Act, on the basis of such checks of the books and records of the Company as we considered appropriate and according to the information and explanations given to us, in the "Annexure B" on the directions issued by the Comptroller and Auditor General of India.

3. 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. e Balance Sheet, the Statement of Profit and Loss (including Other Comprehensive Income), Statement of changes in Equity and the Statement of Cash Flows dealt with by this Report are in agreement with the books of account.

d. In our opinion, the aforesaid standalone financial statements comply with the Indian Accounting Standards specified under Section 133 of the Act.

e. We have been informed that the provisions of Section 164(2) of the Act in respect of disqualification of directors are not applicable to the Company, being a Government Company in terms of notification no. G.S.R.463 (E) dated 5^th June 2015 issued by Ministry of Corporate Affairs, Government of India.

f. With respect to the adequacy of the internal financial controls with reference to standalone financial statements of the Company and the operating effectiveness of such controls, refer to our separate report in "Annexure C".

g. We are informed that the provisions of Section 197 read with Schedule V of the Act, relating to managerial remuneration are not applicable to the Company, being a Government Company, in terms of Ministry of Corporate Affairs Notification no. G.S.R. 463 (E) dated 5^th June 2015.

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

i. e Company has disclosed the impact of pending litigations on its financial position in its Standalone Financial Statements – Refer Note 26 to the Standalone Financial Statements;

ii. e Company has made provision, as required under the applicable law or Indian Accounting Standards, for material foreseeable losses, if any, in respect of long-term contracts. As explained to us, there are no derivative contracts entered into by the Company;

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

iv. a) e 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 identified in any manner whatsoever by or on behalf of the Company ("Ultimate Beneficiaries") or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries;

b) e 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 identified in any manner whatsoever by or on behalf of the Funding Party ("Ultimate Beneficiaries") or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries; and

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. As stated in Para 18.3 to the Standalone Financial Statements a) e final dividend proposed in the previous year, declared and paid by the Company during the year is in accordance with Section 123 of the Act, as applicable; and

b) e interim dividend declared and paid by the Company during the year and until the date of this report is in compliance with Section 123 of the Act; and vi. Based on our examination, which included test checks, the Company has used accounting so_ware systems for maintaining its books of account for the financial year ended March 31, 2026 which have the feature of recording audit trail (edit log) facility and the same has operated throughout the year for all relevant transactions recorded in the so_ware systems. Further, during the course of our audit we did not come across any instance of the audit trail feature being tampered with and the audit trail has been preserved by the Company as per the statutory requirements for record retention.

However, e Payroll so_ware used by the Company for maintaining Payroll records did not have an audit trail feature enabled. Consequently, there was no audit trail maintained for transactions recorded within this particular so_ware for the whole year.

ANNEXURE "A" TO THE INDEPENDENT AUDITORS REPORT

ANNEXURE REFERRED TO IN INDEPENDENT AUDITORS REPORT TO THE MEMBERS OF NATIONAL ALUMINIUM COMPANY LIMITED ON THE STANDALONE FINANCIAL STATEMENTS FOR THE YEAR ENDED MARCH 31, 2026

i. (a) (A) e Company is maintaining proper records showing full particulars including quantitative details and situation of Property, Plant and Equipment including Right of Use Assets, except for leasehold lands mentioned under para (c) below pending execution of leasehold deed.

(B) e Company is maintaining proper records showing full particulars of intangible assets.

(b) ere is a regular programme of physical verification of all Property, Plant and Equipments over a period of three years which, in our opinion, is reasonable having regard to the size of the Company and the nature of its Property, Plant and Equipment. In our opinion and as per the information given by the Management, the discrepancies observed were not material and have been appropriately accounted for in the books.

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

e details of exceptions are given below:

Description of the Property	Gross Carrying Value (In Crores)	Title deeds held in the name of	Whether promoter, director or their relative	Period held	Reason for not being held in the name of Company
23.93 Acres of Freehold Land at Koraput District of Odisha	0.1	Govt. of Odisha	No	1982-83	Land is in the possession of the Company. Transfer of land in the name of the Company is in the process.
554.05 Acres of Leasehold Land at Koraput District of Odisha	0.25	Govt. of Odisha	No	1982-83	Sanction and Execution of Lease Agreement is pending
46.90 Acres of Freehold Land at Anugola district of Odisha	0.33	Govt. of Odisha	No	1987-88	Land is in the possession of the Company. Transfer of land in the name of the Company is in the process.
48.27 Acres of Freehold Land at	0.57	Respective Land owners	No	1987-88	Land is in the possession of the Company. Transfer of land in the name of the Company is in the process.
Anugola district of Odisha 56.50 Acres of Freehold Land at					Land is in the possession of the Company.
Anugola district of Odisha	-	Respective Land owners	No	1993-94	Transfer of land in the name of the Company is in the process.
599.69 Acres of Leasehold Land at Anugola district of Odisha	1.38	Govt. of Odisha	No	1987-88	Sanction and Execution of Lease Agreement is pending
1.69 Acres of Leasehold Land at Anugola district of Odisha	-	Industrial Development Corporation of Odisha (IDCO)	No	2018-19	Communal/Gochhar Land
16.60 Acres of Leasehold Land at Anugola district of Odisha	-	Industrial Development Corporation of Odisha (IDCO)	No	2020-21	Communal/Gochhar Land
25.69 Acres of Leasehold Land at Anugola district of Odisha	-	Industrial Development Corporation of Odisha (IDCO)	No	2022-23	Communal/Gochhar Land
4.36 Acres of Leasehold Land at Anugola district of Odisha	-	Industrial Development Corporation of Odisha (IDCO)	No	2022-23	Communal/Gochhar Land
0.66 Acres of Leasehold Land at Dhenkanal district of Odisha	0.09	Govt. of Odisha	No	1987-88	Sanction and Execution of Lease Agreement is pending

(d) e 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) According to the information and explanations given to us, the inventory (excluding material in transit) has been physically verified by the management during the year and in our opinion, the coverage and procedures of such verification by Management is appropriate. As explained to us, no discrepancy of 10% or more in the aggregate for each class of inventory was noticed on physical verification of inventories as compared to the book records.

(b) According to the information and explanations given to us, the Company has been sanctioned working capital limits in excess of five crore rupees, in aggregate, from banks and financial institutions on the basis of security of current assets. Also, the quarterly returns/statements filed by the Company with such banks and financial institutions are in agreement with the books of account of the Company.

(iii) (a) In our opinion and according to the information and explanations given to us, the Company has not extended any financial guarantee during the year. However, the same was extended in financial year 2024-25, details of which are given below:

Particulars (in _ Crore)	Guarantees
Aggregate amount granted/provided during the year:
-Joint Ventures	0.00
-Others	0.00
Balance outstanding as at balance sheet date in respect of above cases:
-Joint Ventures	200.00
-Others	0.00

(b) In our opinion and according to the information and explanations given to us, guarantees provided, and the terms and conditions of guarantees provided are not prejudicial to the Companys interest.

(c) According to the information and explanations given to us, the Company has not provided loans or provided advances in the nature of loans or provided security, secured or unsecured to companies, firms, limited liability partnership or any other parties during the year. Consequently, clause (iii) (c), (d), (e), (f) of paragraph 3 of the Order are not applicable.

iv. e Company has complied with the provisions of Section 185 of the Act in relation to Loans to directors, whether made directly or indirectly and Section 186 of the Act with respect to the loans and investments made.

v. According to information and explanations given to us, the Company has not accepted any deposits from the public within the meaning of the directives issued by the Reserve Bank of India and provisions of Sections 73 to 76 of the Act and the Rules framed thereunder.

vi. We have broadly reviewed the books and records maintained by the Company as specified by the Central Government for the maintenance of cost records under Section 148(1) of the Act in respect of manufacturing activities and are of the opinion that prima facie, the prescribed accounts and records have been made and maintained. However, we have not made a detailed examination of the records with a view to determine whether they are accurate and complete.

vii. (a) According to the information and explanations given to us and on the basis of our examination of the records of the Company, in our opinion, the Company is generally regular in depositing undisputed statutory dues including Provident Fund, Employees State Insurance, Income Tax, Goods and Services Tax, Duty of Customs, Cess and other material statutory dues with the appropriate authorities. No undisputed statutory dues are outstanding for a period of more than six months from the date they became payable as at 31^st March, 2026.

(b) According to the information and explanations given to us, the disputed statutory dues that have not been deposited for matters under dispute and pending disposal before various authorities are stated below:

Nature of Statue	Nature of Dues	Period to which it relates	Forum where the dispute is pending	Gross Disputed Amount ( Crores)	Amount Paid under protest ( Crore)
1 Income Tax Act 1961	Income tax/TDS/Interest	2009-10 to 2023-24	Commissioner of Income Tax (Appeals)	173.51	214.95
			Total	173.51	214.95
2 Finance Act, 1994	Service Tax/Penalty	2007-08 to 2016-17	Tribunal	2.23	0.04
			Total	2.23	0.04
3 Custom Act, 1962	Custom Duty/ Penalty	2000-01 to 2012-13	Tribunal	192.21	1.91
			Total	192.21	1.91
4 Orissa VAT Act, 2004	VAT/ Penalty	2005-06 to 2009-10	Tribunal	0.64	0.17
		2016-17 to 2017-18	Appellate Authority	0.05	0.00
			Total	0.69	0.17
		2002-03 to 2002-03	High Court	1.46	0.37
5 Orissa Sales Tax Act, 1947	OST/Penalty	2003-04 to 2004-05	Tribunal	0.86	0.54
		1996-97 to 2002-03	Appellate Authority	1.46	1.80
	Total			3.78	2.71
6 Orissa Entry Tax Act, 1999	ET/ Penalty	2000-01 to 2004-05	High Court	7.30	2.07
		1999-00 to 2014-15	Appellate Authority	32.95	20.77
			Total	40.26	22.84
7 Central Sales Tax Act, 1956	CST/ Penalty	1992-93 to 2008-09	Tribunal	254.92	63.00
		1993-94 to 1994-95	Appellate Authority	16.46	15.02
			Total	271.38	78.02
8 Motor Vehicles Act, 1988	Road Tax	2008-09 to 2020-21	Orissa High Court	2.65	0.00
			Total	2.65	0.00
9 Indian Stamp (Odisha Amendment) Act, 2013	Stamp Duty/Registration	2018-19 to 2018-19	Orissa High Court	0.51	0.00
			Total	0.51	0.00
10 Industrial Policy Resolution 1996, Govt. of Odisha	Land Acquisition and interest thereon	1982-83 to 2023-24	Orissa High Court	127.65	0.00
			Total	127.65	0.00
11 MMDR Act, 1957	Royalty	2011-12 to 2015-16	Orissa High Court	136.32	0.00
			Total	136.32	0.00
12 GST Act, 2017	GST	2017-18 to 2020-21	Tribunal	118.48	6.07
			Appellate Authority	43.08	1.99
			Total	161.56	8.06
			Grand Total	1,112.75	328.70

viii. According to the information and explanations given to us and on examining the books of accounts, no transactions were recorded in the books of accounts that have been surrendered or disclosed as income during the year in the tax assessments under the Income Tax Act, 1961.

ix. (a) According to the information and explanations given to us, except for bills discounting arrangement with banks, the Company does not have any loans or borrowings from any financial institutions, banks, Government or debentures holders. e Company has not defaulted in repayment of the loans obtained under the bill discounting facility.

(b) e Company has not been declared as wilful defaulter by any bank or financial institution or other lender.

(c) e Company has not taken any term loan during the year and hence reporting under clause (ix)(c) of paragraph 3 of the Order is not applicable.

(d) On an overall examination of the Standalone Financial Statements of the Company, the Company has not raised funds on short term basis and hence reporting under clause (ix)(d) of paragraph 3 of the Order is not applicable.

(e) On an overall examination of the Standalone Financial 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 joint ventures. e Company does not have any subsidiaries or associates.

(f) e Company has not raised any loans on the pledge of securities held in its joint ventures during the year and the company does not have any subsidiaries or associates, and hence reporting under clause (ix)(f) of paragraph 3 of the Order is not applicable.

x. (a) e Company has not raised any moneys by way of initial public offer, further public offer (including debt instruments) during the year. Accordingly, clause (x) (a) of paragraph 3 of the Order is not applicable.

(b) e Company has not made any preferential allotment or private placement of shares or convertible debentures (fully, partially or optionally convertible) during the year. Accordingly, clause (x) (b) of paragraph 3 of the Order is not applicable.

xi. (a) According to the information and explanations given to us, no fraud by the Company or any fraud on the Company has been noticed or reported during the year.

(b) No report has been filed under Sub-section (12) of Section 143 of the Companies Act by the auditors in Form ADT-4 as prescribed under Rule 13 of Companies (Audit and Auditors) Rules, 2014 with the Central Government during the year and up to the date of this report.

(c) According to the information and explanations given to us, there is no whistle blower complaint 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 under section 406 of the Companies Act, 2013 Accordingly, clauses (xii) (a), (b) and (c) of paragraph 3 of the Order are not applicable.

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 the details have been disclosed in the Standalone Financial Statements (Refer Note 39 of the Standalone Financial Statements).

xiv. (a) In our opinion and based on our examination, the Company has an internal audit system commensurate with the size and nature of its business.

(b) We have considered the internal audit reports of the Company issued till date, for the period under.

xv. According to the information and explanations given to us and based on our examination of the records, the Company has not entered into any non-cash transactions with any director or persons connected with him as specified in Section 192 of the Act.

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 and hence reporting under clauses (xvi) (a) and (b) of paragraph 3 of the Order are not applicable.

(b) According to the information and explanations given to us, the Company is not a Core Investment Company (CIC) (as defined in the regulations made by Reserve Bank of India) and there is no CIC within the Group and hence reporting under clauses (xvi) (c) and (d) of paragraph 3 of the Order are not applicable.

xvii. e Company has not incurred cash losses in the financial year and in the immediately preceding financial year.

xviii. ere has been no resignation of the statutory auditors during the year..

xix. Based on the financial ratios, ageing and expected dates of realisation of financial assets and payment of financial liabilities, other information accompanying the financial statements and our knowledge of the Board of Directors and management plans and based on our examination of the evidence supporting the assumptions, nothing has come to our attention, which causes us to believe that any material uncertainty exists as on the date of the audit report indicating that the Company is not capable of meeting its liabilities existing at the date of balance sheet as and when they fall due within a period of one year from the balance sheet date. We, however, state that this is not an assurance as to the future viability of the Company. We further state that our reporting is based on the facts up to the date of this audit report and we neither give any guarantee nor any assurance that all the 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. (a) According to the information and explanations given to us, there is no unspent amount towards Corporate Social Responsibility (CSR) in respect of other than ongoing projects during the year requiring a transfer to a fund specified in Schedule VII to the Act in compliance with second proviso to Sub-section (5) of Section 135 of the Act. Accordingly, reporting under clause (xx)(a) of paragraph 3 of the Order is not applicable.

(b) According to the information and explanations given to us, there has been INR 16.87cr unspent amount of CSR in respect of ongoing projects during the year requiring transfer to a special account as per Section 135 (6) of the Act has been transferred within the stipulated timeline.

ANNEXURE B TO THE INDEPENDENT AUDITORS REPORT

ANNEXURE TO THE INDEPENDENT AUDITORS REPORT ON THESTANDALONE FINANCIAL STATEMENTS FOR THE YEAR ENDED

31 ^ST MARCH, 2026 OF NATIONAL ALUMINIUM COMPANY LIMITED

Statement on the matters specified in the Directions of C&AG as referred in Paragraph 2 of Report on Other Legal and Regulatory Requirements paragraph of our report of even date to the members of NATIONAL ALUMINIUM COMPANY LIMITED on the Standalone Financial Statements for the year ended 31^st March, 2026.

Directions	Action Taken	Impact on standalone financial statements
1. 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. is includes verifying valuation methodologies, ensuring consistency with Ind AS and reviewing supporting documentation. e auditor shall provide a brief note on the valuation approach, its reasonability, and compliance with applicable regulations, reporting any material deviations or misstatements.	Company has created the following post retirement benefit trusts for meeting its obligation towards various post retirement benefit schemes for employees.
	1. Nalco Employees Provident Fund Trust 2. Nalco Employees Group Gratuity Trust
	3. Nalco Employees Leave Rule Benefit Trust
	4. Nalco Employees Post Retirement Medical Benefit Trust In respect of Provident Fund Trust, the investments are made in debt instruments and mutual funds/ETFs as per the investment guidelines notified by Ministry of Employment and Labour, GoI. In respect of other trusts, the investments are made in Group Superannuation Plans of Life Insurance Corporation of India. Investment in mutual funds/ETFs are valued considering the NAV/market price as at the reporting date. e debt instruments and Group Superannuation Plans are valued at cost and interest accrued thereon. e above valuation methodologies are consistently followed.	Nil
2. 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 by Information Security Auditing Organisations empanelled by Cert-In at a minimum frequency of once in a year and material discrepancies found, if any, have been suitably reported? e implications of processing of accounting transactions outside IT system on the integrity of the accounts along with the financial implications may also be reported.	e Company has implemented SAP-ERP to process transactions through Financial Accounting (FI), Controlling (CO), Sales and Distribution (SD), Materials Management (MM), etc. Transactions relating to payroll are processed through Citrix system. IT systems and controls that are significant for financial reporting as well as cyber security are reviewed and no such material discrepancies are found. No accounting transactions have been processed outside the IT system. erefore, there are no implications on the integrity of the accounts. e Company carries out internal review every year. However, appointment of agency for audit of the systems and cyber security threat by a CERT-in empanelled organisation is in process.	Nil
3. 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.	No funds (grants/subsidy etc.) were received or are receivable for specific schemes from the Central/State government or its agencies during the year.	NA
4. 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?	e Company has identified key risk areas and has formulated the Risk Management Policy considering global best practices to mitigate these risks. e company has not identified any data assets and consequently these have not been subject to valuation.	Nil
5. 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 (where applicable), and audit procedures carried out by us, the company is complying with the Securities and Exchange Board of India (SEBI) (Listing Obligations 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, except provisions relating to the composition of the Board of Directors. is non-compliance is due to absence of requisite number of Independent Directors on the Board which is beyond the control of Board as President of India is the appointing authority of Directors.	Nil

ANNEXURE "C" TO THE INDEPENDENT AUDITORS REPORT

ANNEXURE TO THE INDEPENDENT AUDITORS REPORT OF EVEN DATE ON THE STANDALONE FINANCIAL STATEMENTS FOR THE YEAR ENDED 31ST MARCH, 2026 OF NATIONAL ALUMINIUM COMPANY LIMITED

(Referred in paragraph 3(g) under the head "Report on Other Legal and Regulatory Requirements" of our report of even date) 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 standalone financial statements of National Aluminium Company Limited ("the Company") as of March 31, 2026, in conjunction with our audit of the standalone financial statements of the Company for the year ended on that date.

Managements Responsibility for Internal Financial Controls

Companys management is responsible for establishing and maintaining internal financial controls based on the internal control over financial reporting criteria established by the Company considering the essential components of internal control stated in the Guidance Note on Audit of Internal Financial Controls Over Financial Reporting issued by the Institute of Chartered Accountants of India (ICAI). ese responsibilities include the design, implementation and maintenance of adequate internal financial controls that were operating effectively for ensuring the orderly and efficient conduct of its business, including adherence to companys policies, the safeguarding of its assets, the prevention and detection of frauds and errors, the accuracy and completeness of the accounting records, and the timely preparation of reliable financial information, as required under the Companies Act, 2013.

Auditors Responsibility

Our responsibility is to express an opinion on the Companys internal financial controls over financial reporting based on our audit. We conducted our audit in accordance with the Guidance Note on Audit of Internal Financial Controls Over Financial Reporting (the "Guidance Note") and the Standards on Auditing, issued by ICAI and deemed to be prescribed under section 143(10) of the Companies Act, 2013, to the extent applicable to an audit of internal financial controls, both applicable to an audit of Internal Financial Controls and, both issued by the Institute of Chartered Accountants of India. Those Standards and the Guidance Note require that we comply with ethical requirements and plan and perform the audit to obtain reasonable assurance about whether adequate internal financial controls over financial reporting was established and maintained and if such controls operated effectively in all material respects.

Our audit involves performing procedures to obtain audit evidence about the adequacy of the internal financial controls system over financial reporting and their operating effectiveness. Our audit of internal financial controls over financial reporting included obtaining an understanding of internal financial controls over financial reporting, assessing the risk that a material weakness exists, and testing and evaluating the design and operating effectiveness of internal control based on the assessed risk. e procedures selected depend on the auditors judgment, including the assessment of the risks of material misstatement of financial statements, whether due to fraud or error. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion on the Companys internal financial controls system over financial reporting.

Meaning of Internal Financial Controls with reference to standalone financial statements

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

(1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the company;

(2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of standalone 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 Standalone Financial Statements.

Inherent Limitations of Internal Financial Controls with reference to standalone financial statements

Because of the inherent limitations of internal financial controls over financial reporting, including the possibility of collusion or improper management override of controls, material misstatements due to error or fraud may occur and not be detected. Also, projections of any evaluation of the internal financial controls over financial reporting to future periods are subject to the risk that the internal financial control over financial 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, the Company has, in all material respects, an adequate internal financial controls system over financial reporting and such internal financial controls over financial reporting were operating effectively as at 31^st March, 2026, based on the internal control over financial reporting criteria established by the Company considering the essential components of internal control stated in the Guidance Note on Audit of Internal Financial Controls Over Financial Reporting issued by the Institute of Chartered Accountants of India.

	For B M CHATRATH & CO LLP	For S R B & ASSOCIATES
	Chartered Accountants	Chartered Accountants
	F. Regd. No. 301011E/E300025	F. Regd. No. 310009E
	Sd/-	Sd/-
	(CA Sanjay Sarkar)	(CA Sarat Chandra Bhadra)
	Partner	Partner
Place: Bhubaneswar	M. No. 064305	M. No.: 017054
Date: 30th April 2026	UDIN: 26064305HCGAPV5773	UDIN: 26017054ZYKBYR6710