Nitin Fire Protection Industries Ltd Auditor Reports

To the Liquidator of Nitin Fire Protection Industries Limited

Report on the Audit of the Standalone Ind AS Financial Statements

Disclaimer of Opinion

We were engaged to audit the accompanying Standalone Ind AS Financial Statements of Nitin Fire Protection Industries Limited ("the Company"), which comprise the Balance Sheet as at March 31, 2024, 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 then ended and notes to the Standalone Ind AS Financial Statements including a summary of significant accounting policies and other explanatory Information (hereinafter referred to as "Standalone Ind AS Financial Statements").

We do not express an opinion on the accompanying Standalone Ind AS Financial Statements of the Company. Because of the significance of the matters described in the Basis for Disclaimer of Opinion section of our report and material uncertainty related to going concern section of our report, we have not been able to obtain sufficient appropriate audit evidence to provide a basis for an audit opinion on these Standalone Ind AS Financial Statements.

Basis for Disclaimer of Opinion

(a) The company is in Liquidation vide order dated 18-Jan-2022 and accordingly the Financials should reflect the net realizable value of the assets. As informed, in March 2024, the ex-promoter - Mr. Nitin Shah, withdrew his revival plan and the matter was heard and his withdrawal of the plan was accepted and the auction in favour of M/S Silver Stallion Limited (Consortium with Vikasa India EIF I Fund and AIG Direct LLC) was approved vide NCLT order dated 4th April 2024. However, Certif?cate of Sale/ Sale deed to transfer the company as a going concern is yet to happen. Certif?cate of Sale will be completed only on receipt of full consideration from the successful bidder, hence all the figures in the Financial statement are presented at historical cost. In absence of Valuation reports, no effect with respect to diminution, if any, in the value of assets have been provided by the company, as per the requirements of Ind AS 36 - Impairment of assets.

(b) As explained in Note no. 41 to the Standalone Ind AS Financial Statements, the Company has an investment in Worthington Nitin Cylinders Private Limited aggregating Rs. 4,195.04 lakhs as at March 31, 2024. During the previous years, the Company has made an estimated provision aggregating Rs. 3,772.17 lakhs towards impairment in the value of investments as at that date. In the absence of the fair value of the investment by an independent valuer as required under Ind AS 28 Investment in Associates and Joint Ventures, we are unable to comment

on the extent of provisi?n required towards impairment, if any, in this regard and the resultant impact on loss, other equity and investment.

(c) As explained in Note no. 42 to the Standalone Ind AS Financial Statements, in relation to exposure in trade receivables aggregating Rs. 29,429.75 lakhs which are outstanding for a long period of time, payments for which are not forthcoming and are subject to independent confirmation and intimation to Reserve Bank of India on account of delayed recoveries in respect of balance receivable in foreign currencies. The Company has, in this regard, made provision of Rs. 29,002.46 lakhs as at March 31, 2024 by way of expected credit loss. In the absence of independent confirmations from the trade receivables and non-availability of other alternate audit evidence , we are unable to comment on the recoverability of the amount, adequacy or otherwise of provision made and consequential impact, if any in this regard and the resultant impact on loss, other equity and trade receivable.

(d) As explained in Note no. 43 to the Standalone Ind AS Financial Statements, the trade payables aggregating Rs. 6,710.55 lakhs, advance to trade payable aggregating Rs. 1.73 lakhs, advance from customers aggregating Rs 1.11 lakh and security deposit given aggregating Rs 2.47 lakhs are subject to independent confirmations. In the absence of independent confirmations and any other alternate audit evidences, we are unable to comment on the consequential impact, if any in this regard and the resultant impact on loss, other equity, trade payable and other current assets.

(e) As explained in Note no. 44 to the Standalone Ind AS Financial Statements, due to expiry and non-renewal of Loss Prevention Certification Board (LPCB) Licence by the Company during previous year, the traded goods consisting of firefighting equipment and other components, in the opinion of the management, would fetch its carrying value as at March 31, 2024. The Company has made an estimated provision towards non-moving inventories amounting Rs 5,004.23 Lakh (Including provision of Rs 486.90 Lakhs based on the independent valuation reports) as at March 31, 2020 and no further provision has been made during the financial year ended March 31, 2024. The Company has carried out physical verification of inventories on February 8, 2022 but physical verification report has not been provided to us. Further, as at the year ended March 31, 2024, a physical stock count was undertaken by internal employees of the company itself and was not verified by any independent third party, to verify the inventory on hand. The inventory report generated from this count includes only the quantity of the items and does not reflect their monetary value. The records maintained by the Company are under updation and hence, for us to perform roll back procedure to ascertain the existence of inventories was not possible. Since inventories enter into the determination of the results of operations and cash flows, we are unable to determine whether any adjustments is required in respect of the loss for the year reported in the Statement of Profit and Loss and the net cash flows from operating activities reported in the Cash Flow Statement. We are unable to comment on the existence of inventory and adequacy of such provision made by

the Company and its consequential impact, if any and the resultant impact on loss, other equity and inventories.

(f) As explained in Note no. 45 to the Standalone Ind AS Financial Statements, as per the audited financial statements ended March 31, 2020, during the earlier years, the company, had adjusted balances under Trade Payable and Trade Receivable aggregating Rs. 5,500.74 lakhs. These adjustments are subject to confirmation from respective counter parties and approval from Reserve Bank of India in case of the balances receivable/ payable in foreign currency. Pending such confirmations and approval, we are unable to comment on the consequential impact, if any and the resultant impact on loss, other equity and investment.

(g) As explained in Note no. 46 to the Standalone Ind AS Financial Statements, loans to subsidiaries aggregating Rs. 24,366.07 lakhs (including arising out of devolvement of stand by letter of undertaking issued in favor of subsidiaries in earlier period) and advance for purchase of materials to subsidiary company of Rs. 348.09 Lakhs, are outstanding for a long period of time. The Company has made provision for the entire amount of Rs. 24,714.16 lakhs, which includes provision amounting to Rs. 24,366.07 lakhs on loan to foreign subsidiaries, and for which we have not been provided sufficient appropriate audit evidence. The provision on loan to foreign subsidiary is subject to confirmation from counter party and intimation to Reserve Bank of India on account of delayed recoveries of balance receivable in foreign currency.

In the absence of independent confirmations from the subsidiaries, including foreign subsidiaries and other body corporates, any other alternate audit evidences and non-recovery of any amount during the year and till date, we are unable to comment on the recoverability of the amount, adequacy or otherwise of the provision made and consequential impact, if any and the resultant impact on loss, other equity and investment.

(h) As explained in Note no. 47 to the Standalone Ind AS Financial Statements, the Company has made provision for interest accrued in respect of its borrowings from banks and financial institutions aggregating Rs. 43,479.20 lakhs. As informed the provision has been made based on claim admitted during the liquidation process. In the absence of independent confirmations in this regards, we are unable to comment on the interest provision made by the Company and its consequential impact, if any and the resultant impact on loss, other equity and investment.

(i) We have been informed by the Liquidator/ Resolution professional that certain information and procedures as part of the Corporate Insolvency Resolution Process ("CIRP") and liquidation are of confidential nature and could not be shared with anyone other than the committee of creditors and National Company Law Tribunal. Pending receipt of information, we are unable to comment on the consequential impact, if any and the resultant impact on loss, other equity and investment.

(j) As explained in Note no. 18 the Standalone Financial Statements, the current maturities of long-term borrowings aggregating to Rs. 957.87 lakhs (PY Rs 805.56 lakhs) and short-term borrowing aggregating to Rs 58,915.70 lakhs (PY Rs 59,184.39 lakhs) are subject to independent confirmations. In the absence of independent confirmations and any other alternate audit evidences, we are unable to comment on the consequential impact, if any in this regard and the resultant impact on loss, equity, current maturity of long term borrowing and short term borrowing.

(k) As explained in Note 51 & 52, balances appearing in the financial statements are subject to reconciliation with the returns and submissions made with statutory authorities. Hence, the effect thereof, on Profit/ Loss, Assets and Liabilities, if any, is not ascertainable. Non provision for Deferred Tax Assets/Liability. Further Revenue recognized in books of accounts has not been reconciled with form 26AS. In the absence of such non compliances, we are unable to comment on the consequential impact, if any and the resultant impact on profit & loss, other equity and liabilities.

(l) The financial statements which describes that the Balance of Debtors, Creditors, Loans & Advances, Investments, Advance to Suppliers, balance with government authorities & Others and Advance from Customers & Others are subject to confirmation and reconciliation, if any. Hence, the effect thereof, on Profit/ Loss, Assets and Liabilities, if any, is not ascertainable.

(m) According to the information given to us the Company is required to prepare Consolidated Financial Statement but Company has not prepared the same so we are unable to comment upon the same.

(n) As the Company has not documented internal control framework which includes standard operating process for various areas of operations, risk control matrices, etc. and also due to the inability of the management to substantiate that there are adequate internal controls that exist and operate effectively, we are unable to comment on the presence and effectiveness of internal controls that are designed to prevent and detect any material misstatement, fraud, errors and omissions. Further CIRP process have been started form October 2018 and since then the internal audit has been discontinued. We have also issued a disclaimer of opinion in our report on the internal financial controls with reference to the financial statements under Section 143 (3) (i) of the Act of even date annexed to this report.

(o) We have not been provided with any documented framework to ascertain completeness and timely compliance with the provisions of various applicable statutes. Therefore, we are not able to comment on the completeness of compliances under applicable statutes. Further, during the course of audit, we have observed few instances of non-compliances with provisions of SEBI Listing

Obligations and Disclosure Requirements and The Companies Act, 2013. Major non-compliances observed are -

I. The Company has not prepared and presented Consolidated Ind AS Financial Statements for the year ended March 31, 2024 as required under Section 129(3) of the Companies Act, 2013;

II. The Company has not appointed internal Auditors as required by Section 138 of the Companies Act, 2013;

III. As required by Section 203 of the Companies Act, 2013, the Company has not appointed full time Company Secretary;

IV. As required by Section 148 of the Companies Act, 2013 read with Companies (Cost Records and Audit) Rules, 2014, the cost audit is not applicable to the Company;

V. The Company has not prepared and presented quarterly unaudited financial results (standalone and Consolidated) basis as required under the requirements of Regulation 33 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 for all the quarter of the financial year.

VI. The Company did not have a Chief Financial Officer (CFO) since financial year 2018-19 as required under section 203 of the Act.

In the absence of ascertainment of impact arising on account of such non-compliance of laws and regulations on the Ind AS standalone Financial Statements of the company, we are unable to comment on the said consequential impact.

Material Uncertainty Related to Going Concern

We draw attention to Note no. 49 to the Standalone Ind AS Financial Statements, regarding preparation of Standalone Ind AS Financial Statements on a going concern basis. The Company has incurred a net loss of Rs. 685.96 lakhs during the year ended March 31, 2024, the net worth of the Company as of date is fully eroded and it is negative Rs. 1,09,003.24 lakhs as of that date, and further, the Companys current liabilities exceeded its total assets by Rs. 1,08,812.87 lakhs as on March 31, 2024. Further, capacity utilization of the manufacturing facilities is very low. In view of the same and given the fact that liquidation is in progress, as per the Insolvency and Bankruptcy Code 2016 ("IBC"), it is required that the Company be managed as a going concern during CIRP and liquidation.

There exists material uncertainty on the Companys ability to continue as a going concern since the same is dependent upon the sale of the Company on going concern basis based on liquidation Order dated January 18, 2022 passed by National Company Law Tribunal. Accordingly, we are unable to comment on the appropriateness of the going concern assumption used in the preparation of Standalone Ind AS Financial Statements, as it is critically dependent upon liquidation as specified in the IBC.

Responsibilities of Board of Directors / RP/ Liquidator and Those Charged with Governance for the Standalone Ind AS Financial Statements

The Honble National Company Law Tribunal ("NCLT"), Mumbai Bench admitted a petition for initiation of CIRP under section 7 of the IBC filed by one of the financial creditors of the Company dated June 4, 2018 and appointed an Interim Resolution Professional ("IRP") to manage the affairs of the Company in accordance with the provisions of the IBC vide order dated October 22, 2018. The Committee of Creditors ("COC") in its meeting held on November 20, 2018 passed a resolution confirming the appointment of the IRP as the Resolution Professional ("RP"). In view of the CIRP/Liquidation, the powers of the Board of Directors have been suspended and the said power of adoption of the Standalone Ind AS Financial Statements of the Company for the year ended March 31, 2024 vests with the RP/Liquidator in terms of the IBC. (Refer Note no. 1 to the Standalone Ind AS Financial Statements). Further vide order dated January 18, 2022 the RP is now appointed as Liquidator of the Company.

The Companys Board of Directors/ Liquidator/RP 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 Ind AS Financial Statements that give a true and fair view of the financial position, financial performance (including other comprehensive income), changes in equity and cash flows of the Company in accordance with the accounting principles generally accepted in India, including Ind AS specified under section 133 of the Act, read with relevant rules issued thereunder. 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 Standalone Ind AS 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 Ind AS Financial Statements, the Board of Directors/ RP/ Liquidator 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 Board of Directors/ RP/ Liquidator either intends to liquidate the Company or to cease operations, or has no realistic alternative but to do so.

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

Auditors Responsibilities for the Audit of the Standalone Ind AS Financial Statements

Our responsibility is to conduct an audit of the Companys Standalone Ind AS Financial Statements in accordance with Standards on Auditing issued by the Institute of Chartered Accountants of India ("ICAI") and to issue an auditors report. However, because of the matters described in the Basis for Disclaimer of Opinion and material uncertainty related to going concern sections of our report, we were not able to obtain

sufficient appropriate audit evidence to provide a basis for an audit opinion on these Standalone Ind AS Financial Statements.

We are independent of the Company in accordance with the Code of Ethics and provisions of the Act that are relevant to our audit of the Standalone Ind AS Financial Statements and we have fulfilled our ethical requirements in accordance with the Code of Ethics issued by ICAI and the requirements under the Act.

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 section 143(11) of the Act, we give in

"Annexure 1" 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. As described in the Basis for Disclaimer of Opinion section, we sought but were unable to obtain all the information and explanations which to the best of our knowledge and belief were necessary for the purpose of our audit;

b. Due to the possible effects of the matters described in the Basis for Disclaimer of Opinion section above and clause (vi) of Annexure 1 to the Independent Auditors Report, we are unable to state whether 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. Due to the possible effects of the matters described in the Basis for Disclaimer of Opinion section, we are unable to state whether the Balance Sheet, the Statement of Profit and Loss (including Other Comprehensive Income), the 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. Due to the possible effects of the matters described in the Basis for Disclaimer of Opinion section, we are unable to state whether the aforesaid Standalone Ind AS Financial Statements comply with the Indian Accounting Standards referred to in section 133 of the Act read with relevant rules issued thereunder;

e. After initiation of CIRP/ Liquidation process, Board of Directors the Company are suspended as on March 31, 2024, and accordingly we are unable to comment on the disqualification 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 the financial statements of the Company and the operating effectiveness of such controls, we give our separate report in "Annexure 2";

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 Standalone Ind AS Financial Statements - Refer Note no. 37 Contingent Liabilities to the Standalone Ind AS Financial Statements;

(ii) Except for the possible effects of the matters described in the Basis of Disclaimer of Opinion section above, the Company has made provision, as required under the applicable law or accounting standards, for material foreseeable losses, on long-term contracts including derivative contracts.

(iii) There has been delay in transferring amounts, required to be transferred, to the Investor Education and Protection Fund by the Company. Details are as follows-

Year Ended	Date of Declaration	Unpaid Dividend Rs in Lakhs	Due date for Transfer to IEPF
31-Mar-13	31-Aug-13	0.26	14-Sep-20
31-Mar-15	21-Sep-15	1.22	23-Oct-22

(iv) (a) The management has represented that, to the best of its knowledge and belief, no funds (which are material either individually or in the aggregate) have been advanced or loaned or invested (either from borrowed funds or share premium or any other sources or kind of funds) by the company to or in any other person(s) or entity(ies), including foreign entities ("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 ("Ult?mate Beneficiaries") or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries;

(b) The management has represented that, to the best of its knowledge and belief, no funds (which are material either individually or in the aggregate) have been received by the company from any person(s) or entity(ies), including foreign entities ("Funding Parties"), with the understanding, whether recorded in writing or otherwise, that the company shall, whether, directly or indirectly, lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the Funding Party ("Ultimate Beneficiaries") or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries; and

(c) Based on audit procedures that have been considered reasonable and appropriate in the circumstances, we are unable to comment that the representations under sub-clause (i) and (ii) of Rule 11 ( e) as provided under

(a) and (b) above contain any material mis-statement.

(v) The company has not declared nor proposed or paid any dividend during the year and therefore compliance under section 123 of the Companies Act, 2013 is not applicable to the company.

(vi) Based on our examination which included test checks, the company has used accounting software for maintaining its books of account which has a feature of recording audit trail (edit log) facility but the same has not been operated throughout the year for all relevant transactions recorded in the software. The feature of recording audit trail (edit log) facility was enabled during the mid of the financial year under consideration.

Further, during the course of our audit we did not come across any instance of audit trail feature being tampered with. Additionally, the audit trail has been preserved by the company as per the statutory requirements for record retention.

ANNEXURE 1 TO THE INDEPENDENT AUDITORS REPORT

[Referred to in paragraph 1 under Report on Other Legal and Regulatory Requirements in the Independent Auditors Report of even date to the members of Nitin Fire Protection Industries Limited on the Standalone Ind AS financial statements for the year ended March 31, 2024]

On the basis of such checks as we considered appropriate and according to the information and explanations given to us during the course of our audit, we report that:

i) In respect of its Property, Plant and Equipment and Intangibles Assets:

(a) A. The Company has not provided records showing full particulars, including quantitative details and situation of Property, Plant and Equipment.

B. The Company has not provided records showing full particulars, including quantitative details and situation of intangibles assets.

(b) As informed to us the Company has a program of physical verification of Property, Plant and Equipment to cover all the items in a phased manner over a period of three years, however not documentary proof has been provided. Further, the Property, Plant and Equipment of the Company have not been physically verified by the Company/ Resolution Professional/Liquidator during the year and as such, we cannot comment on material discrepancies existing, if any.

(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 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 except as per disclosure made in Note 3 to the Financial Statements, as follows:

Land/ Building	Total number cases	of	Leasehold/ Freehold	Gross Block as on March 31, 2024	Net Block as on March 31, 2024
Leasehold Land	1	Leasehold	Rs 12.79 lakhs	Rs 11.42 lakhs

(d) According to the information and explanations given to us and on the basis of our examination of the records of the Company, the Company has not revalued/ provided valuation report of its Property, Plant and Equipment (including Right of use assets) or intangible assets during the year nor they have made any provision as per Ind AS 36- Impairment of Assets.

(e) According to the information and explanations given to us and on the basis of our examination of the records of the Company, there are no proceedings initiated or are pending against the Company for holding any benami property under the Prohibition of Benami Property Transactions Act, 1988 and rules made thereunder.

ii) (a) A physical stock count was undertaken by internal employees of the company itself and was not verified by any independent third party, to verify the quantity of inventory on hand. The inventory report generated from this count includes only the quantity of the items and does not reflect their monetary value accordingly, we cannot comment on material discrepancies existing, if any. Also, the frequency of inventory verification is not reasonable.

(b) As disclosed in note 61.12 to the financial statements and according to the information and explanations given to us and on the basis of our examination of the records of the Company, the Company has been sanctioned working capital limits in excess of five crore rupees, in aggregate, from banks on the basis of security of current assets. As the company is under CIRP/Liquidation hence the company has not filed the quarterly returns or statements with such banks.

iii) (A) The Company has provided loans or advances in the nature of loans, or stood guarantee, or provided security to any subsidiary, joint venture or associate which are repayable on demand is not prejudicial to the interest of company except to the extend interest not being charged.

(B) The Company has provided loans or advances in the nature of loans, or stood guarantee, or provided security to parties other than subsidiaries, joint ventures and associates.

(b) The investment made, guarantee provided, security given and terms and condition of the grant of all loans and advances in the nature of loans and guarantee provided are not prejudicial to the interest of the company.

(c) In respect of loans or advance in the nature of loans, the schedule of repayment of principal and payment of interest has not been stipulated thus we are unable to comment whether the repayments or receipts are regular.

(d) In respect of loans granted, since the Company has granted loans which are payable on demand and during the year the Company has not demanded such loan and interest so we are unable to comment whether, there is no amounts overdue for more than 90 days as at the balance sheet date.

(e) As per information given to us we are unable to comment whether no loan or advances in the nature of loan has fallen due during the year, which, has been renewed or extended or fresh loans granted to settle the overdue of existing loans given to the same parties.

(f) As information given to us, we are unable to comment, that the company has not given any loans or advances in the nature of loans either repayable on demand or without specifying any terms or period of repayment to promoters, related parties as defined in clause (76) of section 2 of Companies Act, 2013

iv) As the statutory registers has not been provided for our verification, in respect of loans, investments, guarantees and securities, we unable to comment whether, the Company has complied with the provisions of Section 185 and 186 of the Companies Act, 2013 in respect of Loans, Investments made, Guarantees, and Securities provided by it.

v) As per the Information given to us the Company has not accepted any deposits from the public under the provisions of Section 73 to 74 of the Act and the rules framed there under and therefore reporting under clause 3(v) is of order is not applicable.

vi) We have broadly reviewed the books of account maintained by the company in respect of the products where the maintenance of cost records has been specified by the Central Government under sub-section (I) of section 148 of the Act and the rules framed there under and we are of the opinion that prima facie, the prescribed accounts and records has not maintained by the company.

vii) In respect of statutory dues:

a) In our opinion, the company has generally been not in regular in depositing undisputed statutory dues, including Goods and Services tax, Provident Fund, Employees State Insurance, Income Tax, Sales Tax, Service Tax, duty of Excise, Value Added Tax, Cess and other material statutory dues applicable to it with the appropriate authorities.

According to the information and explanations given to us, There were undisputed amounts payable in respect of Goods and Service tax, Provident Fund, Employees State Insurance, Income Tax, Sales Tax, Service Tax, duty of Custom, duty of Excise, Value Added Tax, Cess and other material statutory dues in arrears as at March 31, 2024 for the period of more than six months from the date they become payable are as follows.

Name of the statute	Nature of the dues	Amount Rs. in lakhs	Period to which the amount relates	Due Date	Date of Payment
Maharashtra Labour Welfare Fund	Maharashtra Labour Welfare Fund	0.09	Since June 2019	July 2019	Unpaid
Income Tax Act, 1961	Tax Deducted at Source	15.47	Since June 2019	July 2019	Unpaid

b) According to the information and explanations given to us and records of the Company examined by us, dues outstanding with respect to VAT, Sales Tax and Service Tax, Goods and Service tax & cess, on account of any dispute are as follows.

Name of the statute	Nature of dues	Amount Rs. in lakhs	Period to which the amount relates	Forum where dispute is pending
Income Tax Act, 1961	Income Tax	0.20	A.Y. 2012-13	Demand for late payment of interest UIs
	Income Tax	0.25	A.Y. 2013-14	220(2)
	Income Tax	2848.91	A.Y. 2016-17	Commissioner of Income Tax (Appeal)
The Central Sales Tax Act 1956	Sales Tax	0.93	F.Y. 2013-14	Commissioner of Sales Tax
	Sales Tax	22.81	F.Y. 2014-15
	Sales Tax	96.14	F.Y. 2015-16
	Sales Tax	114.72	F.Y. 2016-17
GST	GST Dues u/s. 73	33.90 15.73	F.Y. 2017-18 F.Y. 2018-19	Asst. Comm of State Tax, Mulund, Mumbai - 80.

viii) There were no transactions relating to previously unrecorded income that have been surrendered or disclosed as income during the year in the tax assessments under the Income Tax Act, 1961 (43 of 1961).

ix) a) The company has not defaulted in repayment of loans or other borrowings or in the payment of interest thereon except for the details given below :-

Sr. No Particulars	Amount of default as at March 31, 2024 (Including Interest due) Rs. In Lakhs	Period of default
1 IFCI Limited	1,223.41	March 2018 - March 2024
2 Bank of Baroda	17,407.25	June 2017- March 2024
3 IDBI Bank	42,845.41	January 2018- March 2024
4 Axis Bank	31,379.16	August 2017- March 2024

b) The Company has not been declared wilful defaulter by any bank or financial institution or government or any government authority.

c) The Company has not taken any term loan during the year and there are outstanding term loans at the beginning of the year and as company has not provided any

information related to this henee we are unable to comment whether the term loan is applied for purpose which was obtained.

d) On examination of the financial statements of the Company has not raised any short- term fund therefore Clause 3 (ix) (d) is not applicable.

e) The Company does not raised any fund from entity or person on account of or to meet the obligation of its subsidiaries, joint ventures or associate Companies therefore the Clause 3 (ix) (e) is not applicable.

f) The Company does not raised loans during the year on the pledge of securities held in its subsidiaries, associates or joint ventures or associate Companies; the Clause 3 (ix)

(f) is not applicable.

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

b) The company has not made any preferential allotment or private placement of shares or convertible debentures (fully, partially or optionally convertible) during the year. Accordingly, the provisions of Clause 3(x) (b) of the Order are not applicable to the Company.

xi) a) During the course of our 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 fraud by the Company or any fraud on the Company by its officers or employees, noticed or reported during the year, nor have we been informed of any such instance by the management/ Resolution Professional/ Liquidator.

b) No report under sub-section (12) of section 143 of the Companies Act has been filed in Form ADT-4 as prescribed under rule 13 of Companies (Audit and Auditors) Rules, 2014 with the Central Government, during the year and upto the date of this report.

c) During the year no whistle-blower complaints have been raised and received by the company;

xii) The Company is not a Nidhi Company and hence reporting under clause (xii) of the Order is not applicable.

xiii) In our opinion, the Company is in compliance with Section 177 and 188 of the Companies Act. 2013 with respect to applicable transactions with the related parties and the details of related party transactions have been disclosed in the financial statements as required by the applicable accounting standards.

xiv) The requirement of internal audit is applicable to the company but company has not appointed internal auditor during the period under review, hence we are unable to comment upon the provisions of clause 3(xiv)(a) to (b) of the order.

xv) In our opinion during the year the Company has not entered into any non-cash transactions with its Directors or persons connected with its directors and henee provisions of section 192 of the Companies Act, 2013 are not applicable to the Company.

xvi) a) The Company is not required to be registered under section 45-IA of the Reserve Bank of India Act, 1934.

b) The company has not conducted any Non-Banking Financial or Housing Finance activities without a valid Certificate of Registration (CoR) from the Reserve Bank of India as per the Reserve Bank of India Act, 1934

c) The company is a not a Core Investment Company (CIC) as defined in the regulations made by the Reserve Bank of India, therefore the Clause 3 (xvi) (c) is not applicable.

d) The company does not have any CIC as part of the Group and hence reporting under

clause 3(xvi) of the order is not applicable.

xvii) The Company has incurred cash losses during the financial year and the immediately preceding financial year.

xviii) There has been no resignation of the statutory auditors of the Company during the year.

xix) On the basis of the financial ratios, ageing and expected dates of realisation 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, it has come to our attention, which causes us to believe that material uncertainty exists as on the date of the audit report indicating that 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 future viability of the Company. We further state that our reporting is based on the facts up to the date of the audit report and we neither give any guarantee nor any assurance that all liabilities falling due within a period of one year from the balance sheet date, will get discharged by the Company as and when they fall due.

xx) According to the Section 135 (1) towards Corporate Social Responsibility is not applicable to the Company, therefore Clause 3 (xx) is not applicable.

ANNEXURE 2 TO THE INDEPENDENT AUDITORS REPORT

[Referred to in paragraph 2 under Report on Other Legal and Regulatory Requirements in the Independent Auditors Report of even date to the members of Nitin Fire Protection Industries Limited on the Standalone Ind AS financial statements for the year ended March 31, 2024]

Report on the Infernal Financial Controls with reference to Financial Statements under clause (i) of sub-section 3 of section 143 of the Companies Act, 2013 ("the Act)

We were engaged to audit the internal financial controls with reference to financial statements of Nitin Fire Protection Industries Limited ("the Company") as of March 31, 2024 in conjunction with our audit of the Standalone Ind AS financial statements of the Company for the year ended on that date.

Managements/ Resolution Professional (RP)/ Liquidators Responsibility for Internal Financial Controls

The Companys Management/ Resolution Professional/ Liquidator 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 (the "Guidance Note") 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 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, to the extent applicable to an audit of internal financial controls, both issued by the ICAI.

Because of the matter described in the Disclaimer of Opinion paragraph below, further no standard operating procedure (SOP) provided for our review, hence we were not able to obtain sufficient appropriate audit evidence to provide a basis for an audit opinion on internal financial controls with reference to financial statements of the Company.

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 authorisations of management and directors of the company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorised acquisition, use, or disposition of the companys assets that could have a material effect on the financial statements.

Disclaimer of Opini?n

The system of internal financial controls with reference to financial statements with regard to the Company were not made available to us to enable us to determine if the Company has established adequate internal financial controls with reference to financial statements and whether such internal financial controls were operating effectively as at March 31, 2024.

We have considered the disclaimer reported above in determining the nature, timing, and extent of audit tests applied in our audit of the Standalone Ind AS Financial Statements of the Company, and the disclaimer has affected our opinion on the Standalone Ind AS Financial Statements of the Company and we have issued a disclaimer of opinion on the Standalone Ind AS Financial Statements.

For Parekh Shah & Lodha

Chartered Accountants

ICAI Firm Registration No. 107487W

Sd/-

CA Pranay Bhutra

Partner

Membership No. 623927

UDIN: 2462327BKEWYY5379

Place: Mumbai

Date: 09th July, 2024