Pioneer Agro Extracts Ltd Auditor Reports

Annexure Ah to the Independent Auditorsf Report

Referred to in paragraph 1 under the heading ‘Report on Other Legal & Regulatory Requirement of our report of even date to the financial statements of the Company for the year ended March 31, 2024:

1. In respect of Companys fixed assets: a) The Company has one car as its fixed assets and has maintained the requisite record. b) The Company has disposed off most of the assets i.e. land, building etc. during previous years.

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 movable property is held in the name of the Company. d) The company has not revalued any Property during the year.

2. As per the information and explanations given to us:

a) The Company has no inventory during the year and there is no requirement of any such procedures for such valuation of the same by management.

b) The company has no working capital or any sanction letter for the same as on 31.03.2024 in excess of Rs 5 Crore.

b) The advances made to the companies or firms is with the agreements made in this behalf and the same is not prejudicial to the companys interest.

c) The Schedule of repayment of Principal and Interest on the same has been stipulated and the repayment of the same is regular and there is no outstanding of more than 90 days of any element of such loan.

4. In respect of loans, investments, guarantees, and security all mandatory provisions of section 185 and 186 of the Companies Act, 2013 have been compiled with.

5. In our opinion and according to the information and explanations given to us, the Company has not accepted deposits during the year and do not have any unclaimed deposits. Therefore, the provisions of the clause 3 (v) of the Order are not applicable to the Company.

6. The maintenance of cost records has been prescribed by the Central Government under sub-section (1) of section 148 of the Companies Act, 2013 and the same is not applicable to the company.

7. In respect of statutory dues: a) According to information and explanations given to us and the records examined by us, the Company has been regular in depositing with appropriate authorities undisputed statutory dues including provident fund, employees state insurance, income tax, value added tax, custom duty, excise duty, cess and other statutory dues wherever applicable.

b) According to information and explanations given to us, no undisputed arrears of statutory dues were outstanding as at March 31, 2023, for a period of more than six months from the date they became payable, except the following: -

As per the VAT Assessment Order dated 22.11.2021 passed for the FY 2014-2015 by Department of Excise & Taxation, demand (including penalty and interest) under Punjab VAT Act 2005 was raised of Rs.1,26,76,398/-. The Company had approached Sales Tax Appellate Tribunal for adjudication on account of grave errors contained in the Assessment Order. Provision towards VAT shall be made, if any, after the decision of the Appellate Tribunal.

8. The Company has not borrowed from Banks and thus has not defaulted in repayment of dues to Banks. The Company has no borrowings from financial institutions by way of debentures.

9. The Company did not raise any money by way of initial public offer or further public offer (including debt instruments) during the year.

10. According to the information and explanations given to us, no material fraud by the Company or on the Company by its officers or employees has been noticed or reported during the course of our audit.

11. According to the information and explanations give to us and based on our examination of the records of the Company, the Company has paid/provided for managerial remuneration in accordance with the requisite approvals mandated by the provisions of section 197 read with Schedule V to the Act.

12. Clause (xiii) of the order is not applicable to the Company as the Company is not a Chit fund company or Nidhi/ Mutual Benefit Fund/ Society.

13. According to the information and explanations given to us and based on our examination of the records of the Company, transactions with the related parties are in compliance with sections 177 and 188 of the Act where applicable and details of such transactions have been disclosed in the financial statements as required by the applicable accounting standards.

14. The company has appropriate and adequate Internal Control System as required as compared to the nature and size of the company.

15. The Internal Audit Report of the Company for the period of Audit is considered by the Statutory Auditor at the time of preparing Independent Audit Report.

16. According to the information and explanations give to us and based on our examination of the records of the Company, the Company has not made any preferential allotment or private placement of shares or fully or partly convertible debentures during the year.

17. According to the information and explanations given to us and based on our examination of the records of the Company, the Company has not entered into non-cash transactions with directors or persons connected with him. Accordingly, paragraph 3(xv) of the Order is not applicable.

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

19. As per the financial ratios and ageing schedule being given in the Balance Sheet, in our opinion there is no material uncertainty exist on the date of issuing Audit report and the company is being able to meet its liabilities as on the Balance Sheet date as and when the same falls within the one year from the balance sheet date.

OF SECTION 143 OF THE COMPANIES ACT, 2013 (gTHE ACTh)

We have audited the internal financial controls over financial reporting of Pioneer Agro Extracts Limited ("the Company") as of 31 March, 2024 in conjunction with our audit of the financial statements of the Company for the year ended on that date

MANAGEMENTfS 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 (‘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 Companies Act, 2013.

AUDITORSf 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 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. 59

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, 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