To,
The Members of,
OCL Iron and Steel Limited
Report on the Audit of the Standalone Ind AS Financial Statements
Opinion
We have audited the accompanying standalone Ind AS financial statements of OCL Iron and
Steel Limited ("the Company"), which comprise the Balance sheet as at March 31
2019, the Statement of Profit and Loss, including the Statement of Other Comprehensive
Income, the Statement of Changes in Equity and the Statement of Cash Flow for the year
then ended, and Notes to the Financial Statements, including a Summary of Significant
Accounting Policies and other explanatory information (hereinafter referred to as
"the Ind AS standalone financial statements).
In our opinion and to the best of our information and according to the explanations
given to us, the aforesaid Ind AS financial statements give the information required by
the Companies Act, 2013, as amended ("the Act") in the manner so required and
give a true and fair view in conformity with the Indian Accounting Standards prescribed
under section 133 of the Act read with Companies (Indian Accounting Standard) Rules, 2015
and other accounting principles generally accepted in India, of the state of affairs of
the Company as at March 31,2019, its loss including other comprehensive income the changes
in equity and its cash flows for the year ended on that date.
Basis for Opinion
We conducted our audit of the standalone Ind AS financial statements in accordance with
the Standards on Auditing (SAs), as specified under section 143(10) of the Act. Our
responsibilities under those Standards are further described in the ‘Auditors
Responsibilities for the Audit of the Standalone Ind AS 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 standalone Ind AS financial statements
under the provisions of the Act and the Rules thereunder, and we have fulfilled our other
ethical responsibilities in accordance with these requirements and the Code of Ethics. We
believe that the audit evidence we have obtained is sufficient and appropriate to provide
a basis for our audit opinion on the standalone Ind AS financial statements.
Emphasis of Matter
We draw attention to the following matters in the notes to accounts to standalone Ind
AS financial statements of the company:-
a) The Companys accumulated losses as on 31/03/2019 have resulted in complete erosion
of its net worth. Further as on that date, the Companys current liabilities substantially
exceeded the current assets. These factors raise a substantial doubt about the Companys
ability to continue as a going concern in the foreseeable future. However, the Companys
standalone financial statements have been prepared on going concern basis as per the
management opinion disclosed in the said note.
b) The Company has classified all its borrowings from banks as current liabilities, as
the lenders of the Company have classified the Company as Non Performing Assets (NPA).
c) In the absence of pending confirmation of balances from Trade Payable, Trade
Receivable and from parties to/from whom loan and advances are given/ taken and
outstanding as on 31/03/2019, provisions for any adverse variation in the balances is not
quantified.
d) The Company has not carried out evaluation of impairment of assets and no provisions
for impairment has been recorded, as required by Ind- AS - 36.
e) The Company is holding 100% shares in Oriental Iron Casting Limited which company
was struck off by the Registrar of Companies, Delhi and Haryana. The Company had made an
investment of Rs. 19850.00 Lakhs in the equity capital of the Oriental Iron Casting
Limited and also given a loan of Rs. 17203.01 Lakhs to the said company. We have been
informed that Oriental Iron Casting Limited has moved an application in National Company
Law Tribunal on 08/01/2019 for revival of the status.
Our opinion is not modified in respect of the above matters.
Key Audit Matters
Key audit matters are those matters that, in our professional judgment, were of most
significance in our audit of the standalone Ind AS financial statements for the financial
year ended March 31,2019. These matters were addressed in the context of our audit of the
standalone Ind AS 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 that there are no key audit matters to communicate in our report.
"Information Other than the Standalone Ind AS Financial Statements and Auditors
Report Thereon"
The Companys Board of Directors is responsible for the other information. The other
information comprises the information included in the Management Discussion and Analysis,
Boards Report including Annexures to Boards Report, Business Responsibility Report,
Corporate Governance and shareholders information but does not include the standalone Ind
AS financial statements and our auditors report thereon.
Our opinion on the standalone Ind AS financial statements does not cover the other
information and we do not express any form of assurance conclusion thereon.
In connection with our audit of the standalone Ind AS financial statements, our
responsibility is to read the other information and, in doing so, consider whether such
other information is materially inconsistent with the standalone Ind AS financial
statements or our knowledge obtained during the course of 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 for the Standalone Ind AS Financial Statements
The Companys Board of Directors is responsible for the matters stated in section
134(5) of the Act with respect to the preparation of these 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 Ind AS 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 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 the 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, 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.
The Board of Directors are also responsible for overseeing the Companys financial
reporting process.
Auditors Responsibilities for the Audit of the Standalone Ind AS Financial Statements
Our objectives are to obtain reasonable assurance about whether the standalone Ind AS
financial statements as a whole are free from material misstatement, whether due to fraud
or error, and to issue an auditors report that includes our opinion. Reasonable assurance
is a high level of assurance, but is not a guarantee that an audit conducted in accordance
with SAs will always detect a material misstatement when it exists. Misstatements can
arise from fraud or error and are considered material if, individually or in the
aggregate, they could reasonably be expected to influence the economic decisions of users
taken on the basis of these standalone Ind AS financial statements.
As part of an audit in accordance with SAs, we exercise professional judgment and
maintain professional skepticism throughout the audit. We also:
• Identify and assess the risks of material misstatement of the standalone Ind AS
financial statements, whether due to fraud or error, design and perform audit procedures
responsive to those risks, and obtain audit evidence that is sufficient and appropriate to
provide a basis for our opinion. The risk of not detecting a material misstatement
resulting from fraud is higher than for one resulting from error, as fraud may involve
collusion, forgery, intentional omissions, misrepresentations, or the override of internal
control.
• Obtain an understanding of internal control relevant to the audit in order to
design audit procedures that are appropriate in the circumstances. Under section 143(3)(i)
of the Act, we are also responsible for expressing our opinion on whether the Company has
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 standalone Ind AS financial statements or, if such disclosures are inadequate, to
modify our opinion. Our conclusions are based on the audit evidence obtained up to the
date of our auditors report. However, future events or conditions may cause the Company
to cease to continue as a going concern.
• Evaluate the overall presentation, structure and content of the standalone Ind
AS financial statements, including the disclosures, and whether the standalone Ind AS
financial statements represent the underlying transactions and events in a manner that
achieves fair presentation.
We communicate with those charged with governance regarding, among other matters, the
planned scope and timing of the audit and significant audit findings, including any
significant deficiencies in internal control that we identify during our audit.
We also provide those charged with governance with a statement that we have complied
with relevant ethical requirements regarding independence, and to communicate with them
all relationships and other matters that may reasonably be thought to bear on our
independence, and where applicable, related safeguards.
From the matters communicated with those charged with governance, we determine those
matters that were of most significance in the audit of the standalone Ind AS financial
statements for the financial year ended March 31, 2019 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.
Other Matter
The standalone Ind AS financial statements of the Company for the year ended March 31,
2018, included in these standalone Ind AS financial statements, have been audited by the
predecessor auditor who expressed an unmodified opinion on those statements on May 30th,
2018.
Our opinion is not modified in respect of aforesaid matters.
Report on Other Legal and Regulatory Requirements
1. As required by Section 143(3) of the Act, we report that:
(a) We have sought and obtained all the information and explanations which to the best
of our knowledge and belief were necessary for the purposes of our audit;
(b) In our opinion, proper books of account as required by law have been kept by the
Company so far as it appears from our examination of those books
(c) The Balance Sheet, the Statement of Profit and Loss including the Other
Comprehensive Income, Statement of Changes in Equity and the Statement of Cash Flow dealt
with by this Report are in agreement with the books of account
(d) In our opinion, the aforesaid standalone Ind AS financial statements comply with
the Ind AS specified under Section 133 of the Act, read with relevant rules read there
under;
(e) The matter described in Emphasis of Matter paragraph above, in our opinion, may
have an adverse effect on the functioning of the Company;
(f) On the basis of the written representations received from the directors as on March
31,2019 taken on record by the Board of Directors, none of the directors is disqualified
as on March 31,2019 from being appointed as a director in terms of Section 164(2) of the
Act;
(g) With respect to matters to be included in the Auditors Report in accordance with
requirements of section-197(16) of the Act, as amended:
In our opinion and to the best our information and according to the information and
according to the explanations given to us, the remuneration has been paid by the Company.
(h) 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 "Annexure A" to this report;
Our report expresses an unmodified opinion on the adequacy and operating effectiveness
of the Companys internal financial controls over financial reporting.
(i) 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 disclosed the impact of pending litigations on its financial
position in its standalone Ind AS financial statements - Refer Note 37 to the standalone
Ind AS financial statements;
ii. The Company has made provision, as required under the applicable law or accounting
standards, for material foreseeable losses, if any, on long-term contracts including
derivative contracts - Refer Note 23 to the standalone Ind AS financial statements;
iii. There were no amounts which were required to be transferred to the Investor
Education and Protection Fund by the Company.
2. As required by the Companies (Auditors Report) Order, 2016 ("the Order"),
issued by the Central Government of India in terms of sub-section (11) of section 143 of
the Act, we give in the "Annexure B" a statement on the matters specified in
paragraphs 3 and 4 of the Order.
For Arora & Choudhary Associates
Chartered Accountants
Firm Registration Number: 003870N
(Vijay K Choudhary)
Partner
Membership Number: [081843]
Place: New Delhi
Date : 14th June 2019
"ANNEXURE A TO THE INDEPENDENT AUDITORS REPORT"
Report on the Internal Financial Controls under Clause (i) of Sub-section 3 of Section
143 of the Companies Act, 2013 ("the Act").
We have audited the internal financial controls over financial reporting of OCL Iron
and Steel Limited ("the Company") as of March 31, 2019 in conjunction with our
audit of the standalone Ind AS financial statements of the Company for the year ended on
that date.
Managements Responsibility for Internal Financial Controls
The Companys management is responsible for establishing and maintaining internal
financial controls based on the internal control 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". 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 Companies Act, 2013.
Auditors Responsibility
Our responsibility is to express an opinion on the Companys internal financial
controls over financial reporting based on our audit. We conducted our audit in accordance
with the Guidance Note on Audit of Internal Financial Controls over Financial Reporting
(the "Guidance Note") and the Standards on Auditing, issued by ICAI and deemed
to be prescribed under section 143(10) of the Companies Act, 2013, to the extent
applicable to an audit of internal financial controls, both applicable to an audit of
Internal Financial Controls and, both issued by the Institute of Chartered Accountants of
India. Those Standards and the Guidance Note require that we comply with ethical
requirements and plan and perform the audit to obtain reasonable assurance about whether
adequate internal financial controls over financial reporting was established and
maintained and if such controls operated effectively in all material respects.
Our audit involves performing procedures to obtain audit evidence about the adequacy of
the internal financial controls system over financial reporting and their operating
effectiveness.
Our audit of internal financial controls over financial reporting included obtaining an
understanding of internal financial controls over financial reporting, assessing the risk
that a material weakness exists, and testing and evaluating the design and operating
effectiveness of internal control based on the assessed risk. The procedures selected
depend on the auditors judgment, including the assessment of the risks of material
misstatement of the Ind AS financial statements, whether due to fraud or error.
We believe that the audit evidence we have obtained, is sufficient and appropriate to
provide a basis for our audit opinion on the Companys internal financial controls system
over financial reporting.
Meaning of Internal Financial Controls Over Financial Reporting
A companys internal financial control over financial reporting is a process designed
to provide reasonable assurance regarding the reliability of financial reporting and the
preparation of financial statements for external purposes in accordance with generally
accepted accounting principles. A companys internal financial control over financial
reporting includes those policies and procedures that (1) pertain to the maintenance of
records that, in reasonable detail, accurately and fairly reflect the transactions and
dispositions of the assets of the company; (2) provide reasonable assurance that
transactions are recorded as necessary to permit preparation of 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
Because of the inherent limitations of internal financial controls over financial
reporting, including the possibility of collusion or improper management override of
controls, material misstatements due to error or fraud may occur and not be detected.
Also, projections of any evaluation of the internal financial controls over financial
reporting to future periods are subject to the risk that the internal financial control
over financial reporting may become inadequate because of changes in conditions, or that
the degree of compliance with the policies or procedures may deteriorate.
Opinion
In our opinion, to the best of our information and according to the explanations given
to us, the Company has, in all material respects, an adequate internal financial controls
system over financial reporting and such internal financial controls over financial
reporting were operating effectively as at March 31,2019, based on the internal control
over financial reporting criteria established by the Company considering the essential
components of internal control stated in the Guidance Note on Audit of Internal Financial
Controls Over Financial Reporting issued by the Institute of Chartered Accountants of
India.
For Arora & Choudhary Associates
Chartered Accountants
Firm Registration Number: 003870N
(Vijay K Choudhary)
Partner
Membership Number: [081843]
Place: New Delhi
Date: 14th June 2019.
"Annexure B" to the Independent Auditors Report
Referred to in para 2 under the heading ‘Report on Other Legal & Regulatory
Requirement of our report of even date to the standalone Ind AS financial statements of
the Company for the year ended March 31, 2019:
i. a) The Company has generally maintained proper records showing full particulars,
including quantitative details and situation of property, plant and equipment.
b) As explained to us, the property, plant and equipment, according to the practice of
the Company have been physically verified during the year by the management at reasonable
intervals. In our opinion, the frequency of physical verification of property, plant and
equipment is reasonable having regard to the size of the Company and nature of its assets.
According to the information and explanation given to us, no material discrepancies were
noticed on such physical verification.
c) As per information and explanation provided to us and on the basis of our
examination of the records of the Company, the title deeds of immovable properties are
held in the name of the company.
ii. We have been informed that the inventories have been physically verified during
current financial year by an external firm of Chartered Accountants. The frequency of
physical verification, in our opinion, is reasonable having regard to the size of the
company and nature of its business. No material discrepancies were reported by the firm of
Chartered Accountants who physically verified the inventories, the issues/ discrepancies
stated in the report needs to be addressed/ reconciled/ adjusted immediately by the
Company.
iii. The Company has granted unsecured loans to wholly owned subsidiary company which
is covered in the register maintained under section 189 of the Companies Act, 2013
(‘the Act) during the period under review. Such loan is repayable on demand and as
such there are no irregularities with regards to the amount being overdue as on 31st
March 2019.
iv. 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 Companies Act, 2013
in respect of grant of loans, making of investments, providing guarantees and securities.
v The Company has not accepted any deposits from the public and hence the directives
issued by the Reserve Bank of India and the provisions of Sections 73 to 76 or any other
relevant provisions of the Companies Act, 2013 and the rules framed there under. Thus
paragraph 3(v) of the Order is not applicable to the company.
vi. As informed to us, the cost records has been specified by the Central Government
under sub-section (1) of Section 148 of the Companies Act, 2013 and such accounts and
records have been so made and maintained. However we are neither required to carry out nor
have carried out any detailed examination of such accounts and records.
vii. a) According to information and explanations given to us and on the basis of our
examination of the books of account, and records, the Company is not regular in depositing
undisputed statutory dues including Provident Fund, Employees State Insurance, Income-Tax,
Goods and Services Tax, Sales tax, Service Tax, Duty of Customs, Duty of Excise, Value
added Tax, Cess and any other statutory dues with the appropriate authorities. The
outstanding amount payable as on 31st March 2019 on account of statutory dues
being Rs. 8129.37 Lakhs.
According to the information and explanations given to us, arrears of undisputed
amounts payable in respect of the aforesaid statutory dues as at March 31, 2019 for a
period of more than six months from the date they become payable as per books of accounts
is Rs. 8129.37 Lakhs
b) According to the information and explanation given to us, the statutory dues that
have not been deposited on account of matters pending before appropriate authorities are
detailed below:
| S.No. |
Name of the Statute |
Nature of Dues |
Year to which it relates |
Forum where dispute is pending |
Amount (in Lakhs) |
| 1 |
Central Sales Tax |
CST |
2004-05 |
Odisha Sales Tax Tribunal |
79.33 |
| 2 |
Central Sales Tax |
CST |
2006-07 |
Odisha Sales Tax Tribunal, Cuttack |
8.98 |
| 3 |
Central Sales Tax |
CST |
2007-08 |
Odisha Sale Tax TRIBUNAL, Cuttack |
17.18 |
| 4 |
Central Sales Tax |
CST |
2010-11 |
Odisha Sales Tax Tribunal, Cuttack |
20.30 |
| 5 |
Central Sales Tax |
CST |
2010-11 |
STO, Keonjhar |
3.51 |
| 6 |
Central Sales Tax |
CST |
2009-10 |
Joint Commissioner of Central Sales Tax, Jajpur |
14.91 |
| 7 |
Central Sales Tax |
CST |
2011-12 |
Odisha Sales Tax Tribunal, Cuttack |
23.67 |
| 8 |
Central Sales Tax |
CST |
2011-13 |
Odisha Sales Tax Tribunal, Cuttack |
58.25 |
| 9 |
Central Sales Tax |
CST |
2013-14 |
Odisha Sale Tax TRIBUNAL, Cuttack |
2.72 |
| 10 |
Central Sales Tax |
CST |
2014-15 |
Odisha Sale Tax TRIBUNAL, Cuttack |
81.45 |
| 11 |
Central Service Tax |
Service Tax |
2006-12 |
Addl. Commissioner, (Adjn.) Commissionerate Office, Bhubaneswar |
29.99 |
| 12 |
Central Service Tax |
Service Tax |
2011-16 |
Addl. Commissioner (Audit), Rourkela Circle, Bhubaneswar |
75.89 |
| 13 |
Central Service Tax |
Service Tax |
2016-17 |
Addl. Commissioner (Audit), Rourkela Circle, Bhubaneswar |
17.22 |
| 14 |
Central Service Tax |
Service Tax |
2008-10 |
Commissioner, Commissionerate Office, Bhubaneswar |
275.73 |
| 15 |
Central Excise Tax |
Cenvat |
2005-06 |
CESTAT |
23.68 |
| 16 |
Central Excise Tax |
Cenvat |
2012-13 |
Addl. Commissioner (Audit), Rourkela Circle, Bhubaneswar |
14.91 |
| 17 |
Central Excise Tax |
Service Tax |
2013-14 |
Addl. Commissioner (Audit), Rourkela Circle, Bhubaneswar |
48.96 |
| 18 |
Odisha Entry Tax |
State Entry Tax |
2005-06 |
Joint Commissioner of Sales Tax, Sundergarh |
2.66 |
| 19 |
Odisha Entry Tax |
State Entry Tax |
2006-07 |
Addl. Commissioner of Sales Tax, Odisha, Cuttack |
3.05 |
| 20 |
Odisha Entry Tax |
State Entry Tax |
2007-08 |
Commissioner of Sales Tax, Odisha, Cuttack |
23.55 |
| 21 |
Odisha Entry Tax |
State Entry Tax |
2007-10 |
Addl. Commissioner of Sales Tax, North Zone Sambalpur |
4.07 |
| 22 |
Odisha Entry Tax |
State Entry Tax |
2010-12 |
Commissioner of Sales Tax, Odisha, Cuttack |
3.52 |
| 23 |
Odisha Entry Tax |
State Entry Tax |
2011-13 |
Commissioner of Sales Tax, Odisha, Cuttack |
20.58 |
| 24 |
Odisha Entry Tax |
State Entry Tax |
2011-13 |
Odisha High Court |
7.38 |
| 25 |
Odisha Entry Tax |
State Entry Tax |
2011-13 |
Odisha High Court |
51.30 |
| 26 |
Odisha Entry Tax |
CT & GST |
2016-17 |
CT & GST Territorial Range, Rourkela (Non submission of C-Forms) |
241.15 |
| 27 |
Odisha Entry Tax |
CT & GST |
2015-16 |
CT & GST Territorial Range, Rourkela (Non submission of C-Forms) |
123.94 |
| 28 |
Odisha Sales Tax |
VAT |
2005-06 |
Addl. Commissioner of Sales Tax Odisha, Cuttack |
473.68 |
| 29 |
Odisha Sales Tax |
VAT |
2006-07 |
Odisha Sales Tax Tribunal, Cuttack |
36.17 |
| 30 |
Odisha Sales Tax |
VAT |
2007-08 |
Odisha Sales Tax Tribunal, Cuttack |
6.57 |
| 31 |
Odisha Sales Tax |
VAT |
2009-10 |
Commissioner of Sales Tax, Odisha, Cuttack |
25.02 |
| 32 |
Odisha Sales Tax |
VAT |
2009-10 |
Addl. Commissioner of Commercial Taxes, Jajpur road |
8.64 |
| 33 |
Odisha Sales Tax |
VAT |
2010-11 |
Addl. Commissioner of Commercial Taxes, Orissa |
16.77 |
| 34 |
Odisha Sales Tax |
VAT |
2011-13 |
Commissioner of Sales Tax, Odisha, Cuttack |
37.67 |
| 35 |
Odisha Sales Tax |
VAT |
2011-13 |
Odisha High Court |
35.14 |
| 36 |
Odisha Sales Tax |
VAT |
2011-13 |
Odisha High Court |
76.80 |
| 37 |
Bhiwadi Sales Tax |
ET |
2013-16 |
Revenue department-Bhiwadi |
116.18 |
|
Total (A) |
|
|
|
2,110.52 |
viii. According to the information and explanations given to us and as per our
verification of the records of the Company, there had been delays in payment of
installments and interest of term loans and foreign currency loans to the banks during the
year under audit. In view of the persisting defaults, entire term loans amounting to Rs.
151824.16 Lakhs (including interest due thereon) is under default.
ix. Based upon the audit procedures performed and the information and explanations
given by the management, the company has not raised moneys by way of initial public offer
or further public offer including debt instruments and term loans during the year.
Accordingly, the provisions of clause 3 (ix) of the Order are not applicable to the
Company.
x. According to the information and explanations given to us and represented by the
management and based on our examination of books and records of the Company, we have been
informed that no case of fraud committed by the company or any fraud on the company by its
officers or employees has been noticed or reported during the year.
xi. According to the information and explanations given to us and based on our
examination of the records of the Company, the Company has neither paid nor provided for
managerial remuneration during the year.
xii. According to information and explanations given to us, the Company is not a Nidhi
Company. Therefore, the provisions of clause 3 (xii) of the Order is not applicable to the
Company.
xiii. According to the information and explanations provided to us and based on our
examination of the records of the company, all transactions with related parties are in
compliance with sections 177 and
188 of Companies Act, 2013 where applicable and details of such transactions have been
disclosed in the financial statement as required by applicable Indian Accounting
Standards.
xiv. Based upon the audit procedures performed and the information and explanations
given by the management, 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 provisions of clause 3 (xiv) of the Order are not applicable to
the Company.
xv. Based upon the audit procedures performed and the information and explanations
given by the management, the company has not entered into any non-cash transactions with
directors or persons connected with him. Accordingly, the provisions of clause 3 (xv) of
the Order are not applicable to the Company.
xvi. In our opinion, the company is not required to be registered under section 45 IA
of the Reserve Bank of India Act, 1934 and accordingly, the provisions of clause 3 (xvi)
of the Order are not applicable to the Company.
For Arora & Choudhary Associates
Chartered Accountants
Firm Registration Number: 003870N
(Vijay K Choudhary)
Partner
Membership Number: [081843]
Place: New Delhi
Date: 14th June 2019.
+91-9892691696
