Reliance Capital Ltd Directors Report.

on the Standalone financial statements

To

The Members,

Reliance Capital Limited

Report on the audit of the Standalone financial statements Opinion

We have audited the standalone financial statements of Reliance Capital Limited ("the Company"), which comprise the Standalone Balance Sheet as at March 31, 2021, the Standalone Statement of Profit and Loss (including other comprehensive income), Standalone Statement of Changes in Equity and Standalone Statement of Cash Flows for the year then ended, and summary of significant accounting policies and other explanatory information (hereinafter referred to as the "standalone financial statements").

In our opinion and to the best of our information and according to the explanations given to us, the aforesaid standalone financial statements give the information required by the Companies Act, 2013 ("the Act") in the manner so required and give a true and fair view in conformity with the accounting principles generally accepted in India, of the state of affairs of the Company as at March 31, 2021, its loss and other comprehensive income / (loss), its changes in equity and its cash flows for the year ended on that date.

Basis for opinion

We conducted our audit in accordance with the Standards on Auditing ("SAs") 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 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 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 opinion.

Material Uncertainty related to Going Concern

We draw attention to Note No. 40(g) of the standalone financial statements wherein the Company has defaulted in repayment of the obligations to its lenders and debenture holders which is outstanding as on March 31, 2021 and the Company also has incurred losses during the current year and previous year, which indicate material uncertainty exists that may cast a significant doubt on the Companys ability to continue as a Going Concern. The Company is in the process of meeting its obligations by way of time bound monetization of its assets, and accordingly the standalone financial statements of the Company have been prepared on a "Going Concern" basis.

Our opinion is not modified in respect of this matter.

Emphasis of Matter

We draw attention to Note No. 40(f) of the standalone financial statements referring, to filing under Section 143(12) of the Companies Act, 2013 to Ministry of Corporate Affairs by one of the previous auditors for the financial year 2018-19. Based on the facts fully described in the aforesaid note, views of the Company, in-depth examination carried out by the independent legal experts of the relevant records, there were no matters attracting the said Section.

Our opinion is not modified in respect of the above matter.

Key Audit Matters

Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the standalone financial statements of the current year. 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. For each matter below, our description of how our audit addressed the matter is provided in that context.

In addition to the matters described in the Material Uncertainty related to Going Concern section, we have determined the matters described below to be the key audit matters to be communicated in our report. We have fulfilled the responsibilities described in the Auditors responsibilities for the audit of the standalone financial statements section of our report, including in relation to these matters. Accordingly, our audit included the performance of procedures designed to respond to our assessment of the risks of material misstatement of the standalone financial statements. The results of our audit procedures, including the procedures performed to address the matters below, provide the basis for our audit opinion on the accompanying standalone financial statements.

Key Audit Matters How our audit addressed the Key Audit Matter
1. Impairment of financial assets and Corporate Guarantee (CG) Issued (expected credit losses)
(as described in Note No. 7 and 18 of the standalone financial statements)
Ind AS 109 "Financial Instruments" requires the Company to recognise impairment loss allowance towards its financial assets (designated at amortised cost and corporate guarantee issued) using the expected credit loss (ECL) approach. Such ECL allowance is required to be measured considering the guiding principles of Ind AS 109 including: • We read and assessed the Companys accounting policies for impairment of financial assets and their compliance with Ind AS 109.
• unbiased, probability weighted outcome under various scenarios; • We tested the criteria for staging of loans/CG based on their past-due status to check compliance with requirement of Ind AS 109. Tested a sample of performing (stage 1) loans to assess whether any loss indicators were present requiring them to be classified under stage 2 or 3 and vice versa.
• time value of money; • We evaluated the reasonableness of the Management estimates by understanding the process of ECL estimation and tested the controls around data extraction and validation.
• impact arising from forward looking macro-economic factors and; • Tested the ECL model, including assumptions and underlying computation.
• availability of reasonable and supportable information without undue costs.
Applying these principles involves significant estimation in various aspects, such as:
• grouping of borrowers based on homogeneity by using appropriate statistical techniques;
• staging of loans and estimation of behavioural life;
• determining macro-economic factors impacting credit quality of receivables;
• estimation of losses for loan products / corporate guarantee with no / minimal historical defaults.
Considering the significance of such allowance to the overall standalone financial statements and the degree of estimation involved in computation of expected credit losses, this area is considered as a key audit matter.
2. Impairment assessment for Investments in subsidiaries and associates
(as described in Note No. 8 of the standalone financial statements)
As detailed in Note No. 8, the Company has equity and preference share investments (net of provision for impairment) in subsidiary companies amounting to Rs 10,831 Crore and associate companies amounting to Rs 136 Crore. Our audit procedures, in respect of testing impairment assessment for investments in subsidiaries and associates, included the following:
Such investments are carried at cost as per Ind AS 27 "Separate Financial Statements" and are individually assessed for impairment as per Ind AS 36 "Impairment of Assets". • Obtained understanding of the process, evaluated the design and tested operating effectiveness of controls in respect of impairment assessment of investments in subsidiaries and associates.
Such impairment assessment commences with managements evaluation on whether there is an indication of impairment loss. • held discussions with management regarding appropriate implementation of policy on impairment.
As part of such evaluation, management considers financial information, liquidity and solvency position of investments in subsidiaries and associates. • reconciled financial information mentioned in impairment assessment to underlying source details. Also, assessed of managements estimates considered in such assessment.
Management also considers other factors such as assessment of Companys operations, business performance and modifications, if any, by the auditors of such subsidiaries and associates. • obtained and read latest audited financial statements of subsidiaries and associates. Noted key financial attributes.
Based on such evaluation the Company has made impairment provisions against the above investment. • We evaluated the impairment assessment performed by management.
We focused on this area due to magnitude of the carrying value of investments in subsidiaries and associates, which comprise 80% of the total assets as at March 31, 2021 and are subject to annual impairment assessment.
3. Valuation of Market Linked Debentures
(as described in Note No. 15 of the standalone financial statements)
The Company has issued Market Linked Debentures (MLD). The outstanding balance of MLD as on March 31, 2021 is Rs 496 Crore. These MLDs are economically hedged with Exchange instruments like Nifty, Bank Nifty & Stock Options. • Audit procedures included an assessment of internal controls over valuation methodologies, inputs, judgments made and assumptions used by management in determining fair valuation of MLD.
The Company has done an internal valuation of the outstanding MLD using internal valuation techniques. • Assessed and reviewed the fair valuation of MLD by the Company for compliance with Ind AS.
Considering that internal valuation of MLD is significant to overall standalone financial statements and the degree of managements judgement involved in the estimate, any error in the estimate could lead to material misstatement in the standalone financial statements. Therefore, it is considered as a key audit matter. • Compared resulted valuations against independent sources and externally available market valuation data for sample cases.

Other Information

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

Our opinion on the standalone 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 financial statements, our responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent with the standalone 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.

Management Responsibilities for the standalone 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 financial statements that give a true and fair view of the financial position, financial performance, changes in equity and cash flows of the Company in accordance with the accounting principles generally accepted in India, including the Accounting Standards specified 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 of the assets of the Company and for preventing and detecting frauds and other irregularities; selection and application of appropriate implementation and maintenance of 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 financial statement that give a true and fair view and are free from material misstatement, whether due to fraud or error.

In preparing the standalone 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. Those Board of Directors are also responsible for overseeing the Companys financial reporting process.

Auditors responsibilities for the audit of the standalone financial statements

Our objectives are to obtain reasonable assurance about whether the standalone 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 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 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.

• 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 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 financial statements, including the disclosures, and whether the standalone 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 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

As required by the Companies (Auditors Report) Order, 2016 ("the Order"), issued by the Central Government of India in terms of subsection (11) of section 143 of the Act, we give in "Annexure B" a statement on the matters specified in paragraphs 3 and 4 of the Order, to the extent applicable.

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 standalone balance sheet, the standalone statement of profit and loss (including other comprehensive income, the standalone statement of changes in equity and the standalone statement of cash flow dealt with by this Report are in agreement with the books of account.

d) In our opinion, the aforesaid standalone financial statements comply with the Ind AS specified under Section 133 of the Act.

e) The Company has defaulted in repayment of the obligations to its lenders and debenture holders which is outstanding as on March 31, 2021. Based on the legal opinion obtained by the Company and based on the written representations received from the directors as on March 31, 2021 taken on record by the Board of Directors, none of the directors is disqualified as on March 31, 2021 from being appointed as a director in terms of Section 164 (2) of the Act.

f) The going concern matter described in Material Uncertainty Related to Going Concern section above, in our opinion, may have an adverse effect on the functioning of the Company.

g) With respect to the adequacy of the internal financial controls with reference to standalone financial statements of the Company and the operating effectiveness of such controls, refer to our separate Report in "Annexure A".

h) In our opinion and according to the information and explanation given to us, the Company has not paid / provided for any managerial remuneration as per section 197(16) of the Act.

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, in our opinion and to the best of our information and according to the explanations given to us:

a. The Company has disclosed the impact of pending litigations on its financial position in its standalone financial statements - Refer Note No. 38 to the standalone financial statements;

b. The Company has made provision, as required under the applicable law or Ind AS, for material foreseeable losses, if any, on long-term contracts including derivative contracts - Refer Note No. 51 to the standalone financial statements;

c. Other than for dividend amounting to Rs 0.1 7 Crore pertaining to financial year 201 0-11 to financial year 2012-13 which could not be transferred on account of pendency of various investor legal cases, there has been no delay in transferring amounts, required to be transferred, to the Investor Education and Protection Fund by the Company.

Annexure A to the Independent Auditors Report on the Standalone financial statements

Annexure to the Independent Auditors Report referred to in paragraph under the heading "Report on other legal and regulatory requirements" of our report of even date on the standalone financial statements of Reliance Capital Limited for year ended March 31, 2021.

Report on the Internal Financial Controls with reference to standalone financial statements under Clause (i) of Subsection 3 of Section 143 of the Companies Act, 2013 ("the Act")

1. We have audited the internal financial controls with reference to standalone financial statements of Reliance Capital Limited (the Company) as of March 31, 2021 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

2. The Companys management is responsible for establishing and maintaining internal financial controls based on the internal control with reference to standalone financial statements criteria established by the Company considering the essential components of internal control stated in the Guidance Note on Audit of Internal Financial Controls over Financial Reporting issued by the Institute of Chartered Accountants of India (ICAI). These responsibilities include the design, implementation and maintenance of adequate internal financial controls that were operating effectively for ensuring the orderly and efficient conduct of its business, including adherence to companys policies, the safeguarding of its assets, the prevention and detection of frauds and errors, the accuracy and completeness of the accounting records, and the timely preparation of reliable financial information, as required under the Act.

Auditors Responsibility

3. Our responsibility is to express an opinion on the Companys internal financial controls with reference to standalone financial statements 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 Act, 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 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 internal financial controls with reference to standalone financial statements was 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 internal financial controls system with reference to standalone financial statements and their operating effectiveness. Our audit of internal financial controls with reference to standalone financial statements included obtaining an understanding of internal financial controls with reference to financial reporting, assessing the risk that 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 standalone 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 qualified audit opinion on the Companys internal financial controls system with reference to standalone financial statements.

Meaning of Internal Financial Controls with reference to standalone financial statements

6. A companys internal financial control with reference to standalone financial statements is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of the standalone financial statements for external purposes in accordance with generally accepted accounting principles. A companys internal financial control with reference to standalone financial statements includes those policies and procedures that

(1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the Company;

(2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of the standalone 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 standalone financial statements.

Inherent Limitations of Internal Financial Controls with reference to standalone financial statements

7. Because of the inherent limitations of internal financial controls with reference to standalone financial statements, 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 with reference to standalone financial statements to future periods are subject to the risk that the internal financial controls with reference to standalone financial statements may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

Basis for Qualified Opinion

8. During the previous year, based on our audit, information and explanation provided by the management, following weakness were observed by us with regard to internal financial control.

The Company needs to strengthen loan processing documentation including justification for sanctioning the loans / exposures, risk assessment of exposures and its mitigation monitoring of end use of funds, evaluation of borrowers repayment capacity and the policy of sanctioning the loan to entities with weaker credit worthiness.

During the current year the Company has not given any loans / guarantee to any entity.

Qualified Opinion

9. In our opinion and to the best of information and according to explanations given to us, the Company has maintained adequate internal financial controls with reference to standalone financial statements as at March 31, 2021 based on the internal control with reference to standalone financial statements criteria established by the Company considering the essential components of internal control stated in the Guidance Note and except for possible effects of the material weakness described in the Basis of Qualified Opinion paragraph above on the achievement of the objectives of the Control criteria, the Companys internal financial control with reference to standalone financial statements were operating effectively as at March 31, 2021.

A material weakness is a deficiency, or a combination of deficiencies, in internal financial control with reference to standalone financial statements, such that there is a reasonable possibility that a material misstatement of the Companys annual or interim standalone financial statements will not be prevented or detected on a timely basis.

10. We have considered the material weakness identified and reported above in determining the nature and extent of audit tests applied in our audit of the standalone financial statements of the Company for the year ended March 31, 2021 and these material weaknesses do not affect our opinion on the standalone financial statements of the Company.

Annexure B to the Independent Auditors Report on the Standalone financial statements

Referred to in the Independent Auditors Report of even date to the members of Reliance Capital Limited ("the Company) on the standalone financial statements as of and for the year ended

March 31, 2021

i. (a) The Company is maintaining proper records showing full particulars, including quantitative details and situation, of property, plant and equipment.

(b) The property, plant and equipment are physically verified by the Management according to a phased programme designed to cover all the items over a period of three years, which, in our opinion, is reasonable having regard to the size of the Company and the nature of its assets. Pursuant to the programme, a portion of the property plant and equipment has been physically verified by the Management during the year and no material discrepancies have been noticed on such verification.

(c) According to the information and explanation given to us and records examined by us, the title deeds of immovable properties, as disclosed in Note No. 11 and 1 2 on Investment Property and Property Plant and Equipment respectively to the standalone financial statements, are held in the name of the Company.

ii. The Company is in the business of finance and investment activity, and consequently, does not hold any inventory. Therefore, the provisions of clause 3(ii) of the said Order are not applicable to the Company.

iii. In our opinion and according to the information and explanation given to us, the Company has not granted any loans, secured or unsecured, to companies, firms, Limited Liability Partnerships or other parties covered in the register maintained under Section 189 of the Act. Therefore, the provisions of clause 3(iii) of the said Order are not applicable to the Company.

iv. In our opinion and according to the information and explanation given to us, the Company has not granted any loan or provided any guarantee or security in connection with any loan taken by parties covered under section 185 of the Act. Therefore, the provisions of section 185 of the Act are not applicable to the Company.

The Company is registered as Core Investment Company with Reserve Bank of India. Thus, the provision of Section 1 86 except sub-section (1) of the Act is not applicable to the Company. In our opinion and according to the information and explanations given to us, during the year, the Company has not made any investments through more than two layers of investment companies as mentioned in sub section (1) of Section 186 of the Act.

v. In our opinion and according to the information and explanation given to us, the Company has not accepted any deposits from the public within the meaning of directives issued by the Reserve Bank of India and sections 73, 74, 75 and 76 of the Act and the Rules framed there under to the extent notified. Therefore, the provisions of clause 3(v) of the said Order are not applicable to the Company.

vi. In our opinion and according to the information and explanation given to us, the Central Government of India has not specified the maintenance of cost records under sub-section (1) of Section 1 48 of the Act for any of the products of the Company. Therefore, the provisions of clause 3(vi) of the said Order are not applicable to the Company.

vii. (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 generally regular in depositing undisputed statutory dues in respect of provident fund, income tax, profession tax, goods and service tax, cess and other material statutory dues, as applicable, with the appropriate authorities. There are no undisputed amounts payable in respect of such applicable statutory dues as at March 31, 2021 for a period of more than six months from the date they became payable.

(b) According to the information and explanations given to us and the records of the Company examined by us, there are no dues of sales tax, service-tax, goods and service tax which have not been deposited on account of any dispute. The particulars of dues of income tax and value added tax as at March 31, 2021, which have not been deposited on account of a dispute is as under:

Name of the statute Nature of dues Amount (Rs in crore) Period to which the amount relates Forum where the dispute is pending
Income tax Act, 1961 Income Tax 12 A.Y. 20172018 Commissioner of Income Tax Appeals, Mumbai
Maharashtra Value Added Tax Act, 2002 Value Added Tax 1.38 F.Y 20152016 Joint Commissioner of State Tax, Maharashtra
Maharashtra Value Added Tax Act, 2002 Value Added Tax 0.31 F.Y 20162017 Joint Commissioner of State Tax, Maharashtra

viii. According to the records of the Company examined by us and the information and explanation given to us , the Company has defaulted in repayment of loans and borrowings obtained from financial institutions , banks and debenture holders, details of which are as follows:

Particulars Amount of Default as at the Balance Sheet Date (Rsin crore) Period of Default (Days)
Name of the lenders Principal Interest Principal Interest
1. Loans from Banks and Financial Institutions
Housing Development Finance Corporation Limited 524 79 456 487
Axis Bank Limited 100 13 493 517
2. Debenture Holders 16,260 3,127 365-548 365-548
Your attention is drawn to Note No. 41 of standalone financial statements.

The Company did not have any loans or borrowing from government during the year.

ix. In our opinion, and according to the information and explanations given to us, during the year the Company has not raised any term loans and any moneys by way of initial public offer or further public offer (including debt instruments) accordingly, the provisions of clause 3(xi) of the Order are not applicable to the Company.

x. Attention is invited to Note No. 40(f) of the standalone financial statements and emphasis of matter paragraph of our main audit report, in addition thereto during the course of our examination of the books and records of the Company, carried out in accordance with the generally accepted auditing practices in India, and according to the information and explanations given to us, we have neither come across any instance of material fraud by the Company or on the Company by its officers or employees, noticed or reported during the year, nor have we been informed of any such case by the Management.

xi. In our opinion and according to the information and explanations given to us, the Company has not paid/ provided for managerial remuneration accordingly, the provisions of clause 3(xi) of the Order are not applicable to the Company.

xii. In our opinion and according to the information and explanations given to us, the Company is not a Nidhi Company and the Nidhi Rules, 2014 are not applicable to it, accordingly, the provisions of clause 3(xii) of the Order are not applicable to the Company.

xiii. According to the information and explanations given to us and based on our examination of the records of the Company, in our opinion, transactions entered into by the Company with the related parties are in compliance with Sections 177 and 188 of the Act. The details of related party transactions as required under Ind AS 24 "Related Party Disclosures" specified under Section 133 of the Act have been disclosed in the standalone financial statements. (Refer Note No. 35 of the standalone financial statements)

xiv. During the year, the Company has not made any preferential allotment or private placement of shares or fully or partly convertible debentures during the year. Accordingly, the provisions of clause 3(xiv) of the Order are not applicable to the Company.

xv. In our opinion and according to the information and explanations given to us, during the year, the Company has not entered into any non-cash transactions with its directors or persons connected with him. Accordingly, the provisions of clause 3(xv) of the Order are not applicable to the Company.

xvi. According to the information and explanations given to us the Company is registered as Core Investment Company under section 45-IA of the Reserve Bank of India Act, 1934.

For Pathak H.D. & Associates LLP
Chartered Accountants
Firms Registration No: 107783W/ W100593
Vishal D. Shah
Partner
Membership No: 11 9303
UDIN: 21 11 9303AAAAJY1864
Place : Mumbai
Date : May 8, 2021