Raj Oil Mills Ltd Directors Report.

TO THE MEMBERS OF RAJ OIL MILLS LIMITED

REPORT ON STANDALONE FINANCIAL STATEMENTS

Opinion

We have audited the accompanying Standalone financial statements of M/s. Raj Oil Mills Limited ("the Company") which comprises the Balance Sheet as at March 31, 2019, the Statement of Profit and Loss, statement of Changes in Equity and Statement of Cash Flows for the year ended on that date, and notes to the financial statements, including a summary of significant accounting policies and other explanatory information (herein after referred to as "standalone Ind AS financial statements").

Basis of Qualified Opinion

We conducted our audit of the standalone Ind AS financial statements in accordance with the Standards on Auditing (SAs) specified under Section 143(10) of the Companies Act (‘the Act). Our responsibilities under those Standards are further described in the Auditors responsibility for the Audit of the standalone Financial Statements section of our report. We are independent of the Company in accordance with the Code of Ethics issued by the Institute of Chartered Accountants of India (ICAI) together with the independence requirements that are relevant to the audit of the standalone financial statements under the provisions of the Act and the Rules made thereunder, and we have fulfilled our other ethical responsibilities in accordance with these requirements and the ICAIs 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 financial statements except for the matters stated hereunder:

1) A petition has been filed against Dipti Veg Oil Limited for recovery of INR 1.75 crorebefore National Company Law Tribunal, Mumbai Bench and the same is disclosed under ‘Trade Receivables in the books of accounts of the Company. In this regard, no provision has been made in the books of accounts of the Company.

2) As per section 148 of the Companies Act, 2013, read with Rule 3 (B)-20 - "Non-Regulated Sector –Edible Oil" and Rule 5 – of Companies (Cost Records and Audit) Rules, 2014, the company is required to maintain the cost record for the manufacturing process. However, the Company is in the process of maintaining records of cost of materials consumed on actual consumption basis. Further, as per Rule 6 of Companies (Cost Records and Audit) Rules, 2014, no cost audit has been carried out by the company during the year under audit.

3) We planned our audit so as to obtain all the information and explanations which we considered necessary in order to provide us with sufficient evidence to give reasonable assurance that the financial statements are free from material misstatement except for the impact on the aforementioned qualifications in the Ind AS Financial Statement of the Company.

Qualified opinion

In our opinion and to the best of our information and according to the explanations given to us, except for the matter described in the Basis of Qualified Opinion paragraph above, the aforesaid standalone Ind AS financial statements give the information required by 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 the Companies (Indian Accounting Standards) Rules, 2015, as amended accounting principles generally accepted in India, of the state of affairs of the Company as at March 31, 2019, and loss(including other comprehensive income),changes in equityand its cash flows for the year ended on that date.

Key Audit Matters

Key audit matters are those matters that, in our professional judgement, were of most significant in our audit of standalone financial statements of the current period. These matters were addressed in the context of our audit of the standalone financial statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters. We have determined the matters described below to be the key audit matters to be communicated in our report.

No Key Audit Matters

1 Implementation of Approved Resolution Plan passed by the Honble NCLT

The Honble NCLT, Mumbai Bench vide its order dated April 19, 2018 had approved the Resolution Plan submitted by the New Promoters, i.e. Rubberwala Housing and Infrastructure Limited and Mukhi Industries Limited in- charge and taken over the Management from May 04, 2018. The Ind AS financial statements have been prepared considering the settlement payments stated under the Approved Resolution Plan.

Auditors Response:

As at March 31, 2019, the effect of adjustments taking into account the settlement payments to the secured and unsecured financial liabilities, loans amounting to INR 81.00 crores and INR 71.19 crores by way of reduction in Equity Share Capital and the same has been recognised under ‘Other Equity. Further, the impact of adjustments on account of settlement payments to operational creditors/trade payables, workmen dues, statutory liabilitieshave been recognised under ‘Statement of Profit and Loss amounting to INR 28.57 crores(net) Refer Note 2A of the standalone Ind AS financial statement for the financial impact of the said NCLT order.

2 Recoverability of uncertain trade receivables and Long-Term Loans

The Company has trade receivables (considered doubtful and more than 3 years) amounting to INR 8.83 crores and receivables by way of loan amounting to INR 52.45 crores, total aggregating to INR 61.28 crores.

Auditors Response:

As at March 31, 2019,the Company has made a provision in the books of accounts basis the information available, considering the nature of the amounts recoverable, sustainability and the likelihood of the recovery from the such receivables.

Information other than the Standalone 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 Annual Report but does not include the standalone financial statements and our auditors report thereon. Our opinion on the financial statements does not cover the other information and we will 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 identified above 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.

When we read the report, ifwe conclude that there is a material misstatement therein, we are required to communicate the matter to those charged with governance.

Responsibilities of Management and Those Charged with Governance for the Financial Statements

The Companys Board of Directors is responsible for the matters stated in Section 134 (5) of the Companies Act, 2013 with respect to the preparation of these standalone Ind AS financial statements that give a true and fair view of the state of affairs, profit/loss and other total comprehensive income, changes in equity and cash flows of the Company in accordance with the accounting principles generally accepted in India, including the Indian Accounting Standards ("Ind AS") prescribed under Section 133 of the Act.

This responsibility also includes maintenance of adequate accounting records in accordance with the provisions of the Act for safeguarding 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 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.

Auditors Responsibility for the Audit of Standalone Financial Statements

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 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 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 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 Companies Act, 2013, 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 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.

Materiality is the magnitude of misstatements in the standalone financial statements that, individually or in aggregate, makes it probable that the economic decisions of a reasonably knowledgeable user of the financial statements may be influenced. We consider quantitative materiality and qualitative factors in (i) planning the scope of our audit work and in evaluating the results of our work; and (ii) to evaluate the effect of any identified misstatements in the financial statements. We communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit and significant audit findings, including any significant deficiencies in internal control that we identify during our audit.

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

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

1) 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 Companies Act, 2013, we give in "Annexure A" a statement on the matters specified in paragraphs 3 and 4 of the Order to the extent applicable.

2) As required by Section 143 (3) of the Act, we report that:

a) We have sought and except for the possible effect of the matter described in the Basis of Qualified Opinion paragraph above, obtained all the information and explanations which to the best of our knowledge and belief were necessary for the purposes of our audit.

b) Except for the possible effect of the matter described in the Basis of Qualified Opinion paragraph above, in our opinion, proper books of account as required by law have been kept by the Company so far as it appears from our examination of those books.

c) The Balance Sheet, the Statement of Profit and Loss (including other comprehensive income), the Statement of Changes in Equity and the Statement of Cash Flows dealt with by this Report are in agreement with the books of accounts.

d) Except for the possible effect of the matter described in the Basis of Qualified Opinion paragraph above, in our opinion, the aforesaid standalone Ind AS financial statements comply with the Indian Accounting Standards prescribed under Section 133 of the Act read with Rule 7 of the Companies (Accounts) Rules, 2014.

e) The matters described in the ‘Basis of Qualified Opinion paragraphs above, in our opinion may have an adverse effect on the functioning of the Company;

f) The erstwhile Board of Directors has been suspended as on the balance sheet date 31st March, 2019, as regard to Section 17(1) (b) of "The Insolvency and Bankruptcy Code, 2016". The Honble NCLT vide its order dated April 19, 2018 appointed Mr Sufyan Abdul Razak Maknojia as the Managing Director of the Company authorising him to reconstitute the Board of Directors.On the basis of the written representations received from the Management as on 31st March, 2019 taken on record by the reconstituted Board of Directors, none of the directors is disqualified as on 31st March, 2019 from being appointed as a director in terms of Section 164 (2) of the Act.

g) With respect to the adequacy of the internal financial controls with reference to financial statements of the Company and the operating effectiveness of such controls, refer to our separate report in "Annexure B". h) 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:

1. The Company has disclosed the impact of pending litigations on its financial position in its standalone Ind AS financial statements.

2. The Company does not have any long-term contracts including derivatives contracts for which there were any material foreseeable losses; and

3. There are no amounts required to be transferred to the Investor Education and Protection Fund by the Company.

For Kailash Chand Jain & Co.

Chartered Accountants

Firm Registration No.: 112318W

Saurabh Chouhan

Partner

Membership No.: 167453

Place: Mumbai

Date: May 24, 2019

Annexure - A to the Independent Auditors Report to the members of the company on the financial statements for the year ended March 31, 2019.

Referred to in Paragraph 1 under ‘Report on other legal and regulatory requirements Section of our report of even date.

(i) (a) The Company has maintained records showing full particular including quantitative detail and situation of Fixed Assets.

(b) The Company has program of verification to cover all the items in a phased manner which in our opinion, is reasonable having regard to the size of the Company and the nature of its assets. Pursuant to the program, certain fixed assets have been physically verified by the Management during the year. According to the information and explanations given to us, no material discrepancies were noticed on such verification.

(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 immovable properties are held in the name of the Company.

(ii) As explained to us, the inventories were physically verified during the year by the Management and the discrepancies noticed on physical verification have been properly dealt with in the books of accounts.

(iii) In our opinion and according to the information and explanations given by the management, the Company has not granted any loan, secured or unsecured, to companies, firms, Limited Liability Partnerships (LLPs) or other parties covered in the register maintained under Section 189 of the Act. Accordingly, the provisions of clauses 3(iii)(a), 3(iii) (b) and 3(iii)(c) of the Order are not applicable.

(iv) The Company has not granted any loans or made any investments, or provided any guarantees or security to the parties covered under Section 185 and 186. Therefore, the provisions of Clause 3(iv) of the said Order are not applicable to the Company.

(v) During the year, the National Company Law Tribunal (‘NCLT) vide its order dated April 19, 2018, had approved the Resolution Plan (‘NCLT Order) submitted by the Resolution Professional in accordance with the Insolvency and Bankruptcy Code, 2016. In view of the NCLT order, liability with respect to the Public Fixed Deposit Holders which are in the books of the Company, verified and accepted, will be settled and paid at 100% of the principal amount not exceeding INR 5.36 Crore. The said amount shall be paid in eight quarterly instalments and the Company is complying with the same as provided in the NCLT order.

Further, the Company during the year has not accepted any deposits from the public within the meaning of Sections 73, 74, 75 and 76 of the Act and the Rules framed there under to the extent notified.

(vi) The Central Government has prescribed the maintenance of cost records under Section 148 (1) of the Act. However, as per information and explanation given by the management, the prescribed accounts and records have not been made and maintained by the company.

(vii) According to the information & explanation given to us, in respect of statutory dues:

a) The Company has generally been regular in depositing the undisputed statutory dues including Provident Fund, Employees State Insurance, Income Tax, Goods and Services Tax, Customs duty, Cess and any other material statutory dues as applicable to it with the appropriate authorities though there has been a slight delay in a few cases.

Further, in accordance with the NCLT order, the statutory liabilities (i.e. income tax and Sales/VAT and employees related dues) will be settled at the amounts crystallised in the table below:

Nature of dues Amounts settled
(INR in crores)
Income Tax, Tax Deducted at Source 2.58
Sales tax/VAT/Service Tax 0.89
Employee related dues (including Provident Fund, Employee State Insurance, Profession Tax) 0.51
Total 3.98

Accordingly, the un-disputed amounts payable as on date in respect thereof, which were outstanding at the year-end for a period of more than six months from the date they became payable have been provided in the books and the payments are been settled as stated in the table above as prescribed under the aforementioned Order of the NCLT.

b) According to the information and explanations given to us by the management, the detail of statutory dues of sales tax / VAT and income tax which have not been deposited on account of dispute is as under:

Name of the statute Nature of dues Amount (INR in Crores) Period to which the amount relates Forum where dispute is pending
Sales Tax VAT & CST 2.70 F.Y. 2005-06 Sales Tax Appeal
Sales Tax VAT & CST 7.15 F.Y. 2008-09 Sales Tax Appeal
Sales Tax VAT & CST 8.29 F.Y. 2006-07 Sales Tax Appeal
Sales Tax VAT & CST 15.85 F.Y. 2009-10 Sales Tax Appeal
Sales Tax VAT & CST 11.89 F.Y. 2007-08 Sales Tax Appeal
Sales Tax VAT & CST 10.48 F.Y. 2010-11 Sales Tax Appeal
Sales Tax VAT & CST 32.26 F.Y. 2011-12 Order dated 04.10.2017 received on 31.10.2017. Appeal is yet to be filed.
Sales Tax VAT & CST 11.93 F.Y. 2012-13 Order dated 22.02.2018 received on 28.02.2018. Appeal is yet to be filed.
Sales Tax VAT & CST 5.57 F.Y. 2013-14 Order dated 16.02.2018 received on 28.02.2018. Appeal is yet to be filed.
Income Tax Act, 1961 Income Tax 0.05 F.Y. 2004-05 CIT Appeal
Income Tax Act, 1961 Income Tax 76.90 F.Y. 2007-08 CIT Appeal
Income Tax Act, 1961 Income Tax 49.73 F.Y. 2008-09 CIT Appeal
Income Tax Act, 1961 Income Tax 85.94 F.Y. 2009-10 CIT Appeal
Income Tax Act, 1961 Income Tax 1.77 F.Y. 2005-06 ITAT
Income Tax Act, 1961 Income Tax 10.82 F.Y. 2006-07 ITAT
Income Tax Act, 1961 Income Tax 8.86 F.Y. 2010-11 ITAT

The above Income tax and Sales Tax/VAT dues will be settled for a settlement amount of 1% of the crystallised demand for a maximum of INR 2.58 crores in case of Income Tax and INR 0.89 crores in case of Sales Tax/VAT which shall be paid in four quarterly equal installments in accordance with the Approved NCLT Order.

(viii) The Company has defaulted in repayment of loans and borrowings to the banks and financial institutions. Pursuant to the continuing defaults of the Company with respect to the loans and borrowings to banks and financial institutions, a Corporate Insolvency Resolution Process under the Insolvency and Bankruptcy Code, 2016 was initiated against the Company on July 10, 2017. The NCLT vide its order dated April 19, 2018 approved the Resolution Plan and crystallized the settlement payments to be made to the said banks and financial institutions pursuant to which debts owed by the Company as at that date have been partially settled through repayments and the balance amounts has subsequently been waived off. Accordingly, the table below provides the relevant information in respect of such debts:

Sr. No. Particulars Amount Outstanding as on March 31, 2019 (INR Crores)
Name of the lenders: Fund Based
1 SVC Bank 13.00
2 Edelweiss Assets Reconstruction Co. Ltd. 9.00
3 Public Deposits (inclusive of interest) 4.83
4 Inter-Corporate Deposit 0.05
5 Citi Bank Equity Home Loan -
6 L &T Home Finance Mortgage Loan -
Name of the lenders: Non-Fund Based
1 SICOM (Bill Discounting) 0.54
2 SIDBI (Bill Discounting) 0.13
3 IFCI Factors (Bill Discounting) 0.54

(ix) The Company has not raised moneys by way of initial public offer or further public offer (including debt instruments) or term loans and hence reporting under Clause 3(ix) of the CARO 2016 Order is not applicable.

(x) According to the information and explanations given by the management, we report that no fraud by the Company or on the Company by its officers and employees has been noticed or reported during the year. We have reported one instance under the Independent Auditors Report Point 1 as stated under the Emphasis of Matter.

(xi) According to the information and explanations given by the management, the company does not pay any managerial remuneration during the year and therefore the provisions of clause 3(xi) of the order are not applicable to the company.

(xii) In our opinion, the Company is not a Nidhi Company. Therefore, the provisions of Clause 3(xii) of the Order are not applicable to the Company.

(xiii) In our opinion and according to the information and explanation given to us, the Company is in compliance with section 177 and 188 of Companies Act, 2013 where applicable, for all transactions with the related parties and the details of related party transactions have been disclosed in the standalone financial Statements as required by the applicable Ind AS.

(xiv) According to the information and explanation given to us, the Company has not made any preferential allotment or private placement of shares or fully or partly convertible debentures during the year under review and hence reporting under the provisions of Clause 3(iv) of the Order are not applicable to the Company. However, as per the NCLT Order, the Company has issued 1,12,41,513 shares of INR 10/- each amounting to INR 11,24,15,130/-

(xv) According to the information and explanations given to us, the Company has not entered into any non cash transactions with its directors or persons connected with the directors and hence, the provisions of Clause 3(xv) of the Order are not applicable to the Company.

(xvi) The Company is not required to be registered under Section 45-IA of the Reserve Bank of India Act, 1934. Accordingly, the provisions of Clause 3(xvi) of the Order are not applicable to the Company.

For Kailash Chand Jain & Co.

Chartered Accountants

Firm Registration No.: 112318W

Saurabh Chouhan

Partner

Membership No.: 167453

Place: Mumbai

Date: May 24, 2019

Annexure - B to the Independent Auditors Report

Referred to in Paragraph 1(g) under Report on Other Legal and Regulatory Requirements section of our report to the Members of Raj Oils Mills Limited of even date

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 Raj Oil Mills Limited ("the Company") as of March 31, 2019 in conjunction with our audit of the standalone financial statements of the Company for the year ended on that date.

Managements Responsibility for Internal Financial Controls

The Board of Director of the Company 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 (‘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 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 issued by ICAI and the Standards on Auditing 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, 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 except which stated in Audit Report.

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 judgement 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 except which stated in Audit Report to provide a basis for 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 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.

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 and 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 ICAI.

Referred to in our report of even date

For Kailash Chand Jain & Co.

Chartered Accountants

Firm Registration No.: 112318W

Saurabh Chouhan

Partner

Membership No.: 167453

Place: Mumbai

Date: May 24, 2019