Noble Explochem Ltd Auditor Reports

TO THE MEMBERS OF NOBLE EXPLOCHEM LIMITED

Report on the Audit of Standalone Financial Statements

Opinion

1. We have audited the accompanying standalone financial statements of Noble Explochem Limited (the ‘Company), which comprise the Balance Sheet as at 31 March 2019, the Statement of Profit and Loss (including Other Comprehensive Income), the Cash Flow Statement and the Statement of Changes in Equity for the year then ended, and a summary of the significant accounting policies and other explanatory information.

2. In our opinion and to the best of our information and according to the explanations given to us, the aforesaid standalone financial statements do not give the information required by the Companies Act, 2013 (the ‘Act) in the manner so required and do not give a true and fair view in conformity with the accounting principles generally accepted in India including Indian Accounting Standards (‘Ind AS) specified under Section 133 of the Act, of the state of affairs (financial position) of the Company as at 31 March 2019, and its profit (financial performance including other comprehensive income), its cash flows and the changes in equity for the year ended on that date. We hereby give an adverse opinion.

Basis for Adverse Opinion

3. We conducted our audit in accordance with the Standards on Auditing specified under Section 143(10) of the Act. Our responsibilities under those standards are further described in the Auditors Responsibilities for the Audit of the Financial Statements section of our report. We are independent of the Company in accordance with the Code of Ethics issued by the Institute of Chartered Accountants of India (‘ICAI) together with the ethical requirements that are relevant to our audit of the financial statements under the provisions of the Act and the rules there under, 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. The following are the basis for us to form an adverse opinion;

a. The company is under insolvency proceedings from 14.05.2018. The status of insolvency proceedings as on the date of audit is that RP has put a newspaper advertisement on 18.05.2019 in local & national newspapers inviting EOI for resolution plan. The last date for receipt of such EOI is 17.06.2019. As per Regulation 35 of the Insolvency and Bankruptcy Board of India (Insolvency Resolution Process for Corporate Persons) Regulations, 2016, the fixed assets cant be reported at fair value as the company is under insolvency proceedings. Hence, the fixed assets are considered at carried forward book value only.

The Companys operations have been suspended since December, 2006. The Company has incurred losses during the current year and past several years and the companys net worth has been completely eroded. The Company Current Liabilities exceeds its Current assets as on the Balance Sheet Date.

In view of all this, we are of the opinion that the company cannot be considered as a "Going Concern" and we are unable to comment on whether its assets would be adequate to meet its liabilities.

b. The Company has been declared as Sick Unit by the erstwhile Board for Industrial and Financial Reconstructions(BIFR) via their order dated 22nd July, 2011 and the Company has not received Draft Rehabilitation Scheme from IDBI Bank (i.e., Operating Agency erstwhile BIFR), However vide Notification No. S.O. 3569(E) issued by the Ministry of Finance, Central Government doted November 25, 2016, Sick Industrial Companies (Special Provisions) Act,1985 (SICA) stand repealed with effect from 1^stDecember. 2016. The Additional Liability, if any on account of such repeal of SICA Act not ascertainable

c. As explained in Note No. 20 of Notes to Accounts the expenses aggregating Rs. 4.61 lacs for the Year 2018-19 have not been provided due to which current year loss is under slated by Rs 4.61 lacs.

d. Calls in arrears are unreconciled to the extent of Rs 2.25 lacs.

e. No provision has been made for loans and advances amounting to Rs. 110.51 lacs, which are prima facie doubtful of recovery and in our opinion current years loss and accumulated losses of the company are under stated by provision of such doubtful advances.

f. Depreciation on tangible and intangible assets (as per Schedule 11 of Companies Act, 2013) has not been provided due to discontinuing operation of the company since December 2006 as the relevant assets are not in use.

g. Deferred Tax Assets (Net) as per IND AS - 12 (previously as per Accounting Standard 22 regarding "Accounting for Taxes on Income) has not been recognized in view of consistent losses in the past and of uncertainty regarding estimation of future profit with reasonable certainty.

h. As explained in Note No 21 the liability on account of non-fulfillment of export obligation has not been considered, since the same has remained ascertained and unaccounted for.

i. The Company is not regular in depositing statutory dues with appropriate authorities and substantial amount of statutory dues has become overdue and remain unpaid. Total statutory dues outstanding are Rs. 96.86 Lacs.

j. As explained, companys production activity is closed, most of the provisions of applicable laws like, Gratuity Act, Labor laws, Environment Lows Specific Industry related laws etc., are not complied with.

k. Internal auditor for the financial year under review has not been appointed by the company as required under section 138 of the Companies Act, 2013 and also the company has not appointed Key Managerial Person (KMP) in form of Company Secretary in whole time in employment and Chief Financial Officer. However, as explained to us by the management that company production activity has been fully stopped from the year 2006-2007. There is no sale or purchase activity since then. Only Administrative activity is continued at Registered Office of the company. The Present size of the working is limited only up to administrative work and necessary staff is maintained by the Company.

l. Attention is also invited in respect of the share application money received of Rs. 622.50 Lacs by the Company which is pending for allotment, in terms of Section 73 read with Companies (Acceptance of Deposits) Amendment Rules, 2015.

m. In absence of documents/ details are not made available to us, we are unable to comment whether any sums require to be transfer to the Investor Education and Protection Fund or not and period of delay thereon.

n. The balance of other current assets, trade payables, unsecured loans and other current liabilities includes balance remaining outstanding for a substantial period. The balances are subject to confirmation and reconciliation. The reported financials might have consequential impact which remains unascertained.

o. As informed to us by the Board of Director, Company has neither provided nor paid any interest on outstanding dues to MSME Creditors in the past years and current year Refer Note No. 13 Trade payables - disclosure in accordance with section 22 of Micro, Small and Medium Enterprises Development Act, 2006.

p. Rental expense for the office premises is not provided as per the rent agreement. There is shortage in booking of rent by Rs. 55,352.

Key Audit Matters

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

5. Except for the matter described in the ‘Basis for Adverse Opinion section, we have determined that there are no other Key Audit Matters to communicate in our report.

Information other than the Financial Statements and Auditors Report thereon

6. The Companys Board of Directors is responsible for the other information. The other information comprises the information included in the Annual Report, but does not include the financial statements and our auditors report thereon.

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

In connection with our audit of the financial statements, our responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent with the financial statements or our knowledge obtained in the audit or otherwise appears to be materially misstated. If, based on the work we have performed, we conclude that there is a material misstatement of this other information; we are required to report that fact. We have nothing to report in this regard.

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

7. The Companys 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 including other comprehensive income, Cash Flow and changes in equity of the Company in accordance with the Indian Accounting Standards (INDAS) 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.

This responsibility also includes maintenance of adequate accounting records in accordance with the provisions of the Act for safeguarding the assets of the Company and for preventing and detecting raids and other irregularities selection and application of appropriate accounting policies; making judgments and estimates that are reasonable and prudent; design, implementation and maintenance of adequate internal financial controls, that are 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.

8. In preparing the financial statements, management is responsible for assessing the Companys ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless management either intends to liquidate the Company or to cease operations, or has no realistic alternative but to do so.

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

Auditors Responsibilities for the Audit of the Financial Statements

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

11. As part of an audit in accordance with Standards on Auditing, we exercise professional judgment and maintain professional skepticism throughout the audit. We also:

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

• Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances. Under Section 143(3) (i) of the Act, we are also responsible for explaining 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 management.

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

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

12. 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.

13. 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.

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

Report on Other Legal and Regulatory Requirements

15. As required by the Companies (Auditors Report) Order,2016 (the ‘Order) issued by the Central Government of India in terms of Section 143(11) of the Act, we give in the Annexure A, a statement on the matters specified in paragraphs 3 and 4 of the Order.

16. Further to our comments in Annexure A, 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 purpose of our audit; except for those mentioned in the Basis for Adverse Opinion Section

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; except for those mentioned in the Basis for Adverse Opinion Section

c) the standalone financial statements dealt with by this report are in agreement with the books of account;

d) In our opinion, the aforesaid standalone financial statements comply with Ind AS specified under Section 133of the Act; Except for the following accounting standards:

IND AS 16 - Property Plant and Equipment

IND AS 12 - Income Taxes

IND AS 19 - Employees Benefits

lND AS 36 - Impairment of Assets.

IND AS 37 - Provisions, Contingent Liabilities and Contingent Assets

e) on the basis of the written representations received from the directors and taken on record by the Board of Directors, none of the directors is disqualified as on 31 March 2019 from being appointed as a director in terms of Section164(2) of the Act; company under IBC, board dissolved.

f) we have also audited the internal financial controls over financial reporting (IFCoFR) of the Company as on 31March 2019 in conjunction with our audit of the financial statements of the Company for the year ended on that date and our report as per Annexure B expressed an qualified opinion;

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

i. the Company has not disclosed the impact of pending litigations on its financial position in the financial statements;

ii. The Company did not have any long-term contracts including derivative contracts; as such the question of commenting on any material foreseeable losses thereon does not arise;

iii. there has been delay in transferring amounts, required to be transferred, to the Investor Education and Protection Fund by the Company during the year ended 31 March 2019; cant be commented upon due to non-availability of required data.

iv. the disclosure requirements relating to holdings as well as dealings in specified bank notes were applicable for the period from 8 November 2016 to30 December 2016, which are not relevant to these financial statements. Hence, reporting under this clause is not applicable.

FOR D P Sarda & Co

Chartered Accountants

FRN 117227W

Ankur Agrawal

Partner

MRN 140702

Place; Nagpur

Date; 20^th June, 2019

ANNEXURE TO THE INDEPENDENT AUDITORS REPORT

(Annexure "A" Referred to in Paragraph 1 under the heading "Report on other legal and regulatory requirements "of Our Report of Even Date.)

Reports under The Companies (Auditors Report) Order, 2016 (CARO 2016) for the year ended on 31st March 2019

On the basis of such checks as we considered appropriate and according to the information and explanation given to us during the course of our audit, we state that;

1 In Respect of Fixed Assets

(a) The Company has not maintained proper records showing full particulars including quantitative details and situation of fixed assets.

(b) The Fixed Assets of the Company have not been physically verified by the Management during the year, therefore we are unable to comment on discrepancies in absence of such physical verification.

(c) As informed to us, title deed of immovable properties are held in name of Company, However there are equitable mortgage on the existing freehold land and charge on other fixed assets,

(d) The fair value of assets are not disclosed as mentioned in para 3(a) of the main audit report. Hence, the assets are disclosed at carry forward values.

2 In Respect of Inventories

According to the information and explanations given to us, the companys production activity has been fully stopped from the year 2006-2007. There is no sale or purchase activity since then. Only administrative activity is continued at Registered Office of the company, therefore the company does not have any inventories on hand as on the reporting date.

3 Loans to Parties given to Parties Covered under section 189

According to the information and explanations given to us, the Company has not granted any loan, secured or unsecured to companies, firms or other parties covered under section 189 of the Act. Accordingly paragraph (iii) of the said Order is not applicable.

4 Compliance of Provision of Section 185 and 186 of the Companies Act 2013 in respect of Loans, Guarantees and securities.

In our opinion and according to the information and explanations given to us, the Company has complied with the provisions of section 185 and 186 of the Act, with respect to the loans and investments made.

5 Acceptance of Deposits

According to the information and explanations given to us, the Company has not accepted any deposits from the public. Only an old outstanding of Share Application Money which is pending for allotment, of Rs. 25 Lacs covered under section 73 to 76 of the Companies Act, 2013 and rules framed there under.

6 Maintenance of Cost Record

According to the information and explanations given to us, the companys production activity has been fully stopped from the year 2006-07. There is no sale or purchase activity since then. Only administrative activity is continued at Registered Office of the company and as explained to us, Central Government has not prescribed the maintenance of cost records under sub-section (1) of section 148 of (he Act, for the products of the Company, Therefore, the provisions of Clause 3(vi) of the Order is not applicable to the Company.

7 Undisputed & Disputed Statutory Dues

(a) According to the information and explanations given to us and the records of the Company examined by us, In our opinion, the Company is not regular in depositing the undisputed statutory dues including provident fund, investor education and protection fund employees state insurance, income tax, sales tax, wealth lax, service tax, customs duty, excise duty, value added tax, cess and any other statutory dues, as applicable, with the appropriate authorities .

Name of Statute	Natue of Dues	Amount (Rs.)
Companies Act	Investor Education and Protection Fund (Unpaid Dividend)	1,42,989
Fringe Benefit Tax	Fringe Benefit	13,36,171
Labor Laws	Leave Encashment	47,96,449
Payment of Gratuity Act	Gratuity	65,04,984
Wealth Tax Act	Wealth Tax	1,43,169
Non Agriculture & Gram Panchayat Tax	Non Agriculture & Gram Panchayat Tax	25,22,251
Interest Payable on Government Dues	Government Dues on Various Taxes (As per Standing on Books of Accounts)	38,49,273
BSE Listing Fees	Bombay Stock Exchange (BSE)	2,87,500
Income Tax Act, 1961	Income Tax	17,76,059
Central Excise Act	Excise Duty	7,74,696
Professional Tax Act	Professional Tax	10,91,647
Service Tax	Service Tax	1,35,190
Provident Fund Act	Provident Fund	7,22,664
Sales Tax Act	Sales Tax	57,11,468
Total		2,97,94,510

The additional interest and penalty (if any)in above statutory dues as may be levied by the concerned authorities has not been quantified and provided for. In addition to above, there are demands raised from Central Processing Centre (CPC) TDS aggregating to Rs. 1,76,990/- for various financial years. As informed to us the company is in the process of identifying the nature of such demands and whether any rectification/disputes are required to be taken before jurisdictional authorities .

(b) As informed to us, the dues outstanding of Income- Tax, Sales-tax, Wealth tax, Service Tax, Custom duty, Excise duty and cess on account of any dispute, are as follows:

Nature of Statue	Nature of Dues	Amount (Rs.)	Period to Which Amount Relates	Forum Where Dispute is Pending
Central Excise Tariff Act	Excise Duty	15,90,000	Various Years	CESTAT Mumbai
Income Tax Act, 1961	Income Tax Demand	66,760	A.Y. 2009-10	(CPC, Bengaluru).
Total		16,56,760

8 Loan From Banks/ Financial Institution/ Government/ Debenture

As explained to us, Company has not defaulted in repayment of dues to a financial institution or banks. However there are outstanding dues of 14,32,718/- standing in the Books of Account relating to The Employees Bank Loan for which confirmation is not available with the company.

9 Proceeds of Public Issue (Including, debt instruments) /Term Loan

According to the records of the company examined by us and as per the information and explanations given to us, Company has not raised any money from any public issue/ follow on offer. However, the Company has received Share Application Money which is pending for allotment.

10 Frauds on or by the Company

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 by the management, we have neither come across any instance of fraud on or by the Company. Noticed or reported during the year, nor have we been informed of such case by the Management of Company.

11 Managerial Remuneration

According to the records of the company examined by us and as per the information and explanations given to us, the managerial remuneration has been paid or provided in accordance with the provisions of sec lion 197 read with schedule V of the Companies Act.

12 Nidhi Companies

In our opinion the Company is not a chit fund or a Nidhi/mutual benefit fund/society Therefore, the provision of clause 3 (xii) of the Order is not applicable to the Company.

13 Related Party Transactions

As per the information and explanations given during the course of our verification. in our opinion, all transactions with the related parties made by the company were in compliance with section 177 and 188 of the Act, to the extent applicable to the company during the year, the relevant details in respect of which have been appropriately disclosed in the financial statements.

14 Preferential Issue of Shares or Debentures

According to the information and explanations given to us, The company has not made any preferential allotment or private placement of shares or partly convertible debentures during the year, However the Company "as received Share Application Money which is pending for allotment.

15 Non-Cash Transactions with Directors etc.

According to the information and explanations given to us, we report that the company has not entered into any non-cash transaction with directors or persons connected with him.

16 Provision or Section 45-1A of the Reserve Bank of India Act, 1934

According to the information and explanations given to us, during the year, the Company is not required to be registered under section 45- lA of the Reserve Bank of India Act,1934.

FOR D P Sarda & Co

Chartered Accountants

FRN 117227W

Ankur Agrawal

Partner

MRN 140702

Place; Nagpur

Date; 20^th June, 2019

Independent Audit Report to the Members of Noble Explochem Limited.

Annexure – "B" to the Auditors Report

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

1. In conjunction with our audit of the standalone financial statements of Noble Explochem Limited (the"Company") as at and for the year ended 31 March 2019, we have audited the internal financial controls over financial reporting (IFCoFR)of the Company as of that date.

Managements Responsibility for Internal Financial Controls

2. The Companys Board of Directors 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 (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 the Companys 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

3. Our responsibility is to express an opinion on the Companys IFCoFR based on our audit. We conducted our audit in accordance with the Standards on Auditing, issued by the ICAI and deemed to be prescribed under Section143(10) of the Act, to the extent applicable to an audit of IFCoFR and the Guidance Note issued by the ICAI. 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 IFCoFR were established and maintained and if such controls operated effectively in all material respects.

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

5. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion on the Companys IFCoFR. Annexure B to the Independent Auditors Report of even date to the members of Noble Explochem Limited, on the standalone financial statements for the year ended 31 March 2019 Meaning of Internal Financial Controls over Financial Reporting

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

Inherent Limitations of Internal Financial Controls over Financial Reporting

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

Qualified Opinion

8. According to the information and explanations given to us and based on our audit, the following material weaknesses have been identified as at 31.03.2019;

The company did not have an appropriate internal control system: a) For recoverable including loans and advances and creditors outstanding balances, obtaining their confirmations and reconciliation of their outstanding balances with the books of accounts. This could potentially affect the balance in the other recoverable, trade payable, income and expenses account balances. b) For payment of statutory dues, which could potentially give rise to liabilities

A ‘material weakness is a deficiency, or a combination of deficiencies, in internal financial control over financial reporting, such that there is a reasonable possibility that a material misstatement of the companys annual or interim financial statements will not be prevented or detected on a timely basis.

Opinion

9. In our opinion, except for the possible effects of the material weakness described above on the achievement of the objectives of the control criteria, the company has maintained, in all material respects, adequate internal financial controls over financial reporting and such internal control over financial reporting criteria established by the company considering the essential components of the internal control stated in the Guidance Note issued by the ICAI.

We have considered the material weakness identified and reported above in determining the nature, timing and extend of audit test applied in our audit of the stand alone financial statements of the company for the year ended 31.03.2019 and these material weakness do not affect our opinion on the standalone financial statements of the Company, other than qualification reported by us in our independent audit report.

FOR D P Sarda & Co

Chartered Accountants

FRN 117227W

Ankur Agrawal

Partner

MRN 140702

Place; Nagpur

Date; 20^th June, 2019