NEL Holdings Ltd Auditors Report.

To

The Members of

NEL Holdings Limited. (Formerly known as Nitesh Estates Limited)

Report on the Audit of the Ind-AS Standalone Financial Statements

Opinion

We have audited the Ind-AS standalone financial statements of NEL Holdings Limited. (Formerly known as Nitesh Estates Limited and herein after referred as "the Company"), which comprise the Balance Sheet as at 31st March 2019, 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 Ind-AS standalone financial statements give the information required by the Companies Act, 2013 ("the Act") in the manner so required and give a true and fair view in conformity with the Indian Accounting Standards (Ind-AS) prescribed 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, 2019, and its loss, 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 Companies Act, 2013. Our responsibilities under those Standards are further described in the Auditor s Responsibilities for the Audit of the Ind-AS 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 together with the ethical requirements that are relevant to our audit of the Ind-AS standalone financial statements under the provisions of the Companies Act, 2013 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 Ind-AS standalone financial statements of the current year. These matters were addressed in the context of our audit of the Ind-AS standalone financial statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters. We have determined the matters described below to be the key audit matters to be communicated in our report.

Key Audit Matter Response to Key Audit Matter
1. Accuracy of recognition, measurement, presentation and disclosures of revenues and other related balances in view of adoption of Ind-AS 115 gRevenue from contracts with Customersh (Revenue Accounting Standard) applicable from 1st April, 2018. Principal Audit Procedure:
The application of the new revenue accounting standard from current financial year involves certain key judgments relating to identification of distinct performance obligations, determination of transaction price of identified performance obligation and disclosures including presentations of balances in the Ind-AS standalone financial statements. We assessed the CompanyRss internal process to identify the impact of adoption of the new revenue accounting standard. Our audit approach consisted testing of the design and operating effectiveness of internal controls and procedures as follows:
a) Evaluated the design of internal controls relating to implementation of the new revenue accounting standard.
b) Selected a sample of existing continuing contracts and new contracts and tested the operating effectiveness of the internal control, relating to identification of the distinct performance obligations and determination of transaction price.
Refer Notes 23 and 43 to the Ind-AS standalone financial statements. c) Tested the relevant information, accounting systems and change relating to contracts and related information used in recording and disclosing revenue in accordance with the new revenue accounting standard.
d) Performed analytical procedures and test of details for reasonableness and other related material items.
Conclusion:
Our procedures did not identify any material exceptions.
2. Impairment of Investments in Subsidiaries-Impairment Test Principal Audit Procedure:
Due to deterioration in operating performance Besides obtaining an understanding of Management s processes and control with
of the group subsidiaries, the company has incurred significant losses over the years resulted the erosion of net worth significantly. This has triggered impairment assessment of carrying value of investments in subsidiaries amounting to Rs. 11,866/- Lakhs in the Ind-AS standalone financial statement of the Company. regard to testing the investments for impairment our procedures included the following:-
The Company has not engaged any valuation expert to evaluate the fair value of the investments and considered the impairment based on the net worth of individual company as per Balance Sheet valuation. a) Obtained an understanding of management s process and evaluated design and tested operating effectiveness of controls around identification of indicators of impairment under Ind-AS, and around valuation of the business of the subsidiary companies to determine recoverable value of the said investment;
This matter has been identified as a key audit matter for the current year audit. (Refer Note 6 (iii)& 28 to the Ind-AS standalone financial statements) b) Assessed the appropriateness of judgement of the management to estimate the recoverable value of investment in the subsidiary companies;
c) Assessed the reasonableness of assumptions relating to revenue growth rate, gross margins, discount rates etc. based on historical results, current developments and future plans of the business estimated by management ;
d) Assessed cash flows to ensure consistency with current operations of the Companies and performed sensitivity analysis on key assumptions used in management s calculated recoverable value.
e) Based on our procedures, we also considered the adequacy of disclosures in respect of investment in the said subsidiary companies in the notes to the Ind-AS standalone financial statements.
Conclusion:
Our procedures did not identify any exceptions.
3. Contingent Liabilities Principal Audit Procedure:
Assessment of provisions and contingent liabilities in respect of certain litigations including direct and indirect taxes, various claims filed by other parties not acknowledged as debt. Our audit was focused on analysing the facts of subject matter under consideration and judgements/ interpretation of relevant law.
Our Audit approach involved:
There is high level of judgements required to estimate the level of provisioning. a) Examining recent orders and/or communication received from various Tax authorities/ judicial forums and follow up action thereon.
The Company s assessment is supporte d by the facts of matter, their own judgement, past experience, and advice from legal and independent tax consultant wherever considered necessary. Accordingly, unexpected adverse outcomes may significantly impact the company s reported profit and net assets. Associated uncertainty relating to the outcome requires application of judgement in interpretation of law. b) Understanding the current status of the litigation/tax assessments.
c) Evaluating the merit of the subject matter under consideration with reference to the grounds presented therein and available independent legal / tax advice.
Refer Note 34 to the Ind-AS standalone Financial Statements. d) Review and analysis of the contentions of the company through discussion, collection of details of the subject matter under consideration, the likely outcome and consequent potential outflows on those issues.
Conclusion:
Our procedures did not identify any material exceptions.
Principal Audit Procedure:
4. Evaluation of Uncertain Tax Position
The Company is subject to periodic challenges by local tax authorities on a range of tax matters during the normal course of business including direct and indirect tax matters. These involve significant Our audit procedures include the following substantive procedures:
a) Obtained understanding of key uncertain tax positions; and
management judgement to determine the possible outcome of the uncertain tax positions, consequently having an impact on related accounting and disclosures in the Ind- AS standalone financial statements. b) We along with our internal tax experts Read and analysed select key correspondences, external legal opinions / consultations by management for key uncertain tax positions;
Discussed with appropriate senior management and evaluated management s underlying key assumptions in estimating the tax provisions; and
Assessed management s estimate of the possible outcome of the disputed cases.
Conclusion:
Our procedures did not identify any material exceptions.

Information Other than the Financial Statements and Auditorsf Report Thereon

The Company s Board of Directors is responsible for the preparation of the other information.

The other information comprises the information included in BoardRss Report including Annexures to BoardRss Report, Management Discussion and Analysis and Corporate Governance, but does not include the Ind-AS standalone financial statements and our auditorRss report thereon.

Our opinion on the Ind-AS 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 Ind-AS standalone financial statements, our responsibility is to read the other information identified above, and in doing so, consider whether the other information is materially inconsistent with the financial statements or our knowledge obtained during the course of our audit or otherwise appears to be materially misstated.

If, based on the work we have performed, we conclude that there is no material misstatement of this other information, required to report on that fact.

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

The Company s Board of Directors is responsible for the matters stated in section 134(5) of the Companies Act, 2013 ("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, 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 judgements 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 Ind-AS standalone financial statement that give a true and fair view and are free from material misstatement, whether due to fraud or error.

In preparing the Ind-AS standalone financial statements, management is responsible for assessing the Company s 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.

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

Auditorfs Responsibilities for the Audit of the financial statements

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

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

•  Identify and assess the risks of material misstatement of the Ind-AS 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. 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 financial 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 system in place and the operating effectiveness of such controls.

•  Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and related disclosures made by the management.

•  Conclude on the appropriateness of management s 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 Company s ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditors report to the related disclosures in the Ind-AS 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 Ind-AS standalone financial statements, including the disclosures, and whether the financial statements represent the underlying transactions and events in a manner that achieves fair presentation.

Materiality is the magnitude of misstatements in the Ind-AS standalone financial statements that, individually or in aggregate, makes it probable that the economic decisions of a reasonably knowledgeable user of the financial statements may be influenced. We consider quantitative materiality and qualitative factors in (i) planning the scope of our audit work and in evaluating the results of our work; and (ii) to evaluate the effect of any identified misstatements in the financial statements.

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

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

From the matters communicated with those charged with governance, we determine those matters that were of most significance in the audit of the Ind-AS 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.

Emphasis of Matter

1. The Company has given advances to various parties for acquiring land and immovable property. Based on the life time expected credit loss, allowance for such advances has been accounted for without initiating any visible steps to recover the same (Refer Note no.12 of the Ind-AS Standalone financial statements).

2. The Company has accounted certain Income /expenses directly to retained earnings instead of routing through the Statement of Profit & Loss during the year (Refer Note no. 16 (ii) to the Ind-AS Standalone financial statements).

3. The Company is working on item wise calculation/reconciliation of Deferred Tax assets and liabilities as on 31st March, 2019. Accounting entries resulting from such reconciliation is still pending. (Refer Note no. 19 (a) to the Ind-AS Standalone financial statements).

Our opinion is not modified in respect of these matters.

Report on Other Legal and Regulatory Requirements

1. As required by the Companies (Auditor s Report) Order, 2016 ("the Order"), issued by the Central Government of India in terms of sub-section (11) of section 143 of the Companies Act, 2013, we give in the "Annexure Ah, 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 except information related to deferred tax and actuarial valuation as on 31.03.2019 as stated in Note no. 19(a) and 32(c) to the Ind-AS standalone Ind-AS financial statements, which to the best of our knowledge and belief were necessary for the purposes of our audit.

b) In our opinion, proper books of account as required by law have been kept by the Company so far as it appears from our examination of those books.

c) The Balance Sheet, the Statement of Profit and Loss including other comprehensive income, statement of changes in equity and statement of cash flows dealt with by this Report are in agreement with the books of account.

d) In our opinion, the aforesaid Ind-AS standalone financial statements comply with the Indian Accounting Standards specified under Section 133 of the Act, read with relevant rules issued thereunder.

e) On the basis of written representations received from the directors as on 31st March, 2019 taken on record by the Board of Directors, none of directors is disqualified as on 31st March, 2019 from being appointed as director in terms of Section 164(2) of the Act .

f) With respect to the adequacy of the internal financial controls over financial reporting of the Company and the operating effectiveness of such controls, refer to our separate Report in gAnnexure Bh.

g) With respect to the other matters to be included in the Auditor s Report in accordance with Rule 11 of the Companies (Audit and Auditors) Rules, 2014, as amended, 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 Ind-AS standalone financial statements Refer Note 34 ;

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.

For RAY & RAY
Chartered Accountants
(Firm s Registration No. 301072E)
Sd/-
(Bidyut Prakas Bhattacharya)
Place: Bangalore Partner
Date: 30th May 2019 Membership No.053906

ANNEXURE TO THE INDEPENDENT AUDITORS REPORT

Annexure A referred to in our report to the members of NEL Holdings Limited. (Formerly known as NITESH ESTATES LIMITED) under the heading Report on Other Legal and Regulatory Requirements of our report at even date.

We report that:

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

b) According to the information and explanation given to us, some of the fixed assets have been physically verified by the Management during the year in a phased program and no material discrepancies were noticed on such verification. In our opinion, the frequency of such verification is reasonable having regard to the size of the company and the nature of its assets.

c) According to information and explanation given to us no immovable properties are held in the name of the company.

ii. The Company is engaged in the business of real estate development and related services and holds inventories in the form of land, developed and under development of properties. In our opinion and according to the information and explanations given to us, having regard to the nature of inventories, the procedures and frequency of the physical verification by way of title deeds, site visits by the management and certification of work completion are reasonable and adequate having regard to the size of the Company and the nature of its business.

iii. According to the information and explanation given to us, the Company has granted unsecured loans to companies, firms, or other parties as listed in the register maintained under section 189 of the Companies Act, 2013 (Refer to Note 38 to the financial statements).In our opinion and according to the information and explanations given to us, the terms and conditions of the loans are not prejudicial to the interest of the Company.

iv. According to the information and explanation given to us, the Company has complied with the provisions of Section 185 and 186 of the Act, with respect to loans and investments made.

v. The Company has not accepted any deposits during the year. However, the Company has collected Rs 897 Lakhs amount as advance against their proposed residential projects in the earlier year, which have now been abandoned and such receipts, now are in the nature of deemed deposits under rule 2(c ) (xii) (b) Companies Acceptance of deposit (Rules) 2014 and which are also attracted by sections 73 to 76 of the Companies Act, 2013. Out of the said amount the company has subsequently refunded Rs 763 Lakhs and is in the process of refunding the remaining amount Rs 134 Lakhs. The amount and disclosure requirements of deemed deposits which are required by the relevant act and directives issued by the Reserve Bank of India have not yet been ascertained. (Refer Note no. 44 to the Ind-AS Standalone financial statements). vi. The Central Government has prescribed for the maintenance of the cost records under section 148(1) of the Companies Act, 2013 in respect of the products of the Company. Accordingly, the management has appointed a cost auditor whose report is still awaited and could not be produced to us.

vii. (a) According to the information and explanations given to us, the Company is generally regular in depositing with appropriate authorities undisputed statutory dues including Provident fund, Employees State Insurance, Sales Tax, Wealth Tax, Cess, Custom Duty, Goods and GST and other statutory dues applicable to it.

There are no undisputed amounts payables in respect of provident fund, employees state insurance, sales tax, duty of customs, duty of excise, value added tax, cess and any other statutory dues to the appropriate authorities except Goods and Services Tax Rs. 33 Lakhs and Income Tax Rs 765 Lakhs as at 31st March, 2019 for a period more than six months from the date they became due.

(b) According to the information and explanations given to us, the following are the disputed statutory dues which have not been deposited by the company as on 31st March, 2019.

Name of Statute Nature of Dues Period to which the amount relates Amount (Rs. in Lakhs) Forum where Disputes is Pending
Income Tax Income tax AY 2009-10 148 CIT- Appeal
Act, 1961 AY 2011-12 9 CIT-Appeal
KAVAT Act VAT AY 2009-10 247 DCCT Appeal
AY 2011-12 327 DCCT-Audit
AY 2014-15 114 DCCT-Audit

viii. According to the information and explanations given to us, the company has defaulted in repayment of loans or borrowing to a financial institution Rs 4,257 Lakhs, bank Rs 693 Lakhs and to the debenture holders Rs 9,328 Lakhs. The borrowing from the Bank Accounts have become Non-Performing Assets (NPA) subsequent to the balance sheet date. Due to non-repayment of debentures, the trustee of the debenture holders has filed the recovery petition with National Company Law Tribunal (NCLT), Bangalore Branch. [Refer note 17(i) and (ii)] and 34 (a) (iii). The Company has not taken any loans or borrowings from the government.

ix. The company has not raised money by way of initial public offer or further public offer (including debt instruments) and term loans were applied for the purposes for which those are raised.

x. According to the information and explanations given to us ,no fraud on or by the company has been noticed or reported during the year. Accordingly, the provision of clause 3(x) of the said order is not applicable.

xi. According to the information and explanations give 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 provisions of section 197 read with Schedule V to the Act.

xii. The Company is not a Nidhi Company. Accordingly, paragraph 3(xii) of the Order is not applicable.

xiii. According to the information and explanations given to us by the management all transactions with the related parties are in compliance with Sections 177 and 188 of Companies Act, 2013 where applicable and the details have been disclosed in the Financial Statements as required by the applicable accounting standards.

xiv. The company has not made any preferential allotment or private placement of shares or fully or partly convertible debentures during the year under review. Accordingly, the provision of clause 3(xiv) of the Order is not applicable.

xv. The company has not entered into any non-cash transactions with directors or persons connected with them. Accordingly, the provision of clause 3(xv) of the Order is not applicable.

xvi. The company is not required to be registered under section 45-IA of the Reserve Bank of India Act, 1934.Accordingly, the provision of clause 3(xvi) of the Order is not applicable.

For RAY& RAY
Chartered Accountants
Firm s Registration No.301072E
Sd/-
(Bidyut Prakash Bhattacharya)
Place: Bangalore Partner
Date: 30th May 2019 Membership No 053906

"Annexure-B" to the Independent Auditorsf Report

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

We have audited the internal financial controls over financial reporting of NEL Holdings Ltd.

(hereinafter referred to as the Company ) as of 31st March, 2019 in conjunction with our audit of the Ind-AS standalone financial statements of the Company for the year ended on that date.

Managements Responsibility for Internal Financial Controls

The Company s 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 ). 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 company s 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 Company s internal financial controls over financial reporting based on our audit. We conducted our audit in accordance with the Guidance Note on Audit of Internal Financial Controls over Financial Reporting (the

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

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

Company s internal financial controls system over financial reporting.

Meaning of Internal Financial Controls over Financial Reporting

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

Inherent Limitations of Internal Financial Controls over Financial Reporting

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

According to the information and explanations given to us and based on our audit, in our opinion, the Company has generally maintained, in all material respects, an adequate internal financial controls over financial reporting and such internal financial controls over financial reporting were generally operating effectively as of 31st March 2019 based on the internal control over financial reporting criteria established by the Company considering the essential components of internal controls stated in the "Guidance Note on Audit of Internal Financial Controls over Financial Reporting" issued by the Institute of Chartered Accountants of India. However certain areas need further improvement in designing the Documentation on Internal Financial Controls of the Company in respect of engagement of channel partners ensuring with RERA registration, issue of handover certificate to customers, IR/GR, incorporating the process flow by which the aforesaid transactions are initiated, authorized, processed, recorded, and reported at departmental level.

Internal audit is concurrently done in the company. Regularity of Internal audit, its reports and follow-up action thereon should be timely ensured.

However, our opinion is not qualified in the above respect.

For RAY & RAY
Chartered Accountants
(Firm s Registration No. 301072E)
Sd/-
(Bidyut Prakas Bhattacharya)
Place: Bangalore Partner
Date: 30th May 2019 Membership No.053906