Reliance Naval & Engineering Ltd Auditors Report.
TO THE MEMBERS OF RELIANCE NAVAL AND ENGINEERING LIMITED
(FORMERLY KNOWN AS RELIANCE DEFENCE AND ENGINEERING LIMITED)
Report on the Audit of the Standalone Financial Statements
We have audited the accompanying Standalone Financial Statements of RELIANCE NAVAL AND ENGINEERING LIMITED (FORMERLY KNOWN AS RELIANCE DEFENCE AND ENGINEERING LIMITED) ("the Company"), which comprise the Standalone Balance sheet as at March 31, 2019, and the Statement of Standalone Profit and Loss (including Other Comprehensive Income), the Statement of Standalone Changes in Equity and the Standalone Cash Flow Statement for the year then ended, and notes to the Standalone Financial Statements, including a 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, 2019 and its loss including other comprehensive income, the changes in equity and its cash flows for the year ended on that date.
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 (ICAI) 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 ICAIs 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
Note no. 36 to the Standalone Financial Statements regarding preparation of standalone financial statements of the Company on going concern basis, notwithstanding the fact that the Company continue to incur cash losses, its net worth has been fully eroded, defaulted in repayment of principal and interest to its lenders, loans have been called back by secured lenders, non-current assets are significantly impaired, current liabilities exceeded the total assets of the Company, etc. for the reasons stated in the said note. These conditions indicate the existence of a material uncertainty that may cast significant doubt on the Companys ability to continue as going concern. The appropriateness of assumption of going concern is critically dependent upon the Companys ability to raise requisite finance / generate cash flows in future to meet its obligations.
Our opinion is not modified in respect of this matter.
Key Audit Matters (KAM)
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 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.
|Key Audit Matter||How our audit addressed the key audit matter|
|1) Impairment of Property, Plant and Equipment (PPE) and Capital Work in Progress (CWIP):|
|Annually Management reviews whether there are any indicators of impairment on the PPE and CWIP of the Company (Refer Note 1 (g) (XIV) to the Standalone Financial Statements) by reference to the requirements under Ind AS 36 "Impairment of Assets". Accordingly, Management has identified impairment indicators (operating losses, negative net-worth, low value order book, Industry overlook etc.) in the Company. As a result, an impairment assessment was required to be performed by the Company by comparing the carrying value of the PPE and CWIP to their recoverable amount to determine whether impairment was required to be recognised.||Our audit procedures included, among others:|
| Updating our understanding of managements annual impairment testing process.|
| Ensuring the methodology of the impairment exercise continues to comply with the requirements of Indian Accounting Standards (Ind AS) as adopted, including evaluating managements assessment of indicators of impairment against indicators of impairment specified within Ind AS 36.|
|For the purpose of above impairment testing the Management has determined the recoverable value based on valuation reports.|| Evaluating the independent external valuers competence, capabilities and objectivity.|
|These conclusions are dependent upon significant management judgments, including in respect of:|| Understanding the methodologies used by the external valuer to estimate resale values.|
| Verifying the completeness of disclosure in the Standalone Financial Statements as per Ind AS 36.|
| Estimated utilization, cash flows, time line for getting new sales orders, political environment etc. During the year ended March 31, 2019 the Company has recorded an impairment provision of Rs. 783,304 Lakhs to reduce the aggregate carrying value of PPE to Rs. 144,600 Lakhs and CWIP to Rs. 10,277 Lakhs, to their estimated recoverable values, as per the valuation report. Refer Note no. 2 to the Standalone Financial Statements.|
|We considered this area as key matter due to the significance of the carrying value of the assets being assessed and due to the level of management judgments impacting the impairment assessment.|
|2) Deferred Tax Assets (DTA) and Credit balance of Minimum Alternate Tax (MAT)|
|As disclosed in Note no. 5 and 6 to the Standalone Financial Statements, the Company has not recognised the DTA of 1,23,420.02 Lakhs (including MAT credit entitlement of Rs. 3,338.18 Lakhs). Rs.||Our audit procedures included, among others:|
|The Management of the Company has forecasted the future taxable profit and concluded not to recognise the DTA in the books of accounts.|| Evaluating the recognition and measurement of the current and deferred tax assets and liabilities by analyzing the current and deferred tax calculations for the compliance with the tax law.|
|We considered this area as key matter due to the:|| Assessing the managements judgments relating to the forecasts of future taxable profit and evaluating the reasonableness of the assumptions underlying the preparation of these forecasts including the consistency of the assumptions used with those used to evaluate the recoverable amount of Companys cash generating units where relevant.|
|- significance of the carrying amount of DTA and MAT and|
|- significant judgment is required in forecasting the future taxable profit including growth rate, etc.|| Assessing the appropriateness of the disclosures included in the Standalone Financial Statements in respect of current and deferred tax balances as per Ind AS 12 "Income Taxes".|
|3) Litigation Matters and Contingent Liabilities|
|The Company is subject to number of significant litigations. Major risks identified by the Company in that area related to stamp duty, winding-up petitions, applications filed by certain lenders / creditors to NCLT under IBC for the recovery of outstanding dues, Arbitration with the customer / vendors / service providers, invocations of corporate guarantees by the lenders of a subsidiary and bank guarantees by the customers, etc. The amount of litigation may be significant and estimates of the amounts of provisions or contingent liabilities are subject to significant Management judgment. (Refer Note No. 33 to the Standalone Financial Statements)||Our audit procedures included, among others:|
| Assessing the procedures implemented by the Company to identify and gather the risks it is exposed to.|
| Obtaining an understanding of the risk analyses performed by the Company, with relating supporting documentation, and studying written statements from internal and external legal experts, where applicable.|
| Discussion with the management on the development in these litigations during the year ended March 31, 2019.|
|Due to complexity involved in these litigation matters, managements judgment regarding recognition and measurement of provisions for these legal proceedings is inherently uncertain and might change over time as the outcomes of the legal cases are determined. Accordingly, it has been considered as a key matter.|| Enquiring from the companys legal counsel (internal) and study the responses as received from them.|
| Verification that the accounting and / or disclosure as the case may be in the Standalone Financial Statements made by the Company is in accordance with the assessment of legal counsel / management.|
| Obtaining representation letter from the management on the assessment of these matters as per SA 580 (revised) Written representations.|
The Companys Board of Directors is responsible for the other information. The other information comprises the management discussion & analysis and directors report included in the 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.
Responsibilities of Management and Those Charged with Governance 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 state of affairs (financial position), loss (financial performance including other comprehensive income), cash flows and the statement of changes in equity of the Company in accordance with the accounting principles generally accepted in India, including Indian Accounting Standards (Ind AS) prescribed under Section 133 of the Act read with relevant rules issued thereunder.
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 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 Statements 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 Responsibility 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 financial controls 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 ability of the Company 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
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 Standalone Balance Sheet, the Statement of Standalone Profit and Loss (Including other comprehensive income), the Statement of Standalone Changes in Equity and the Standalone Cash Flow Statement 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 prescribed under Section 133 of the Act.
e. The matter described under Material Uncertainty Related to Going Concern 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 and taken on record by the Board of Directors and also based on legal opinion obtained by the Company, with reference to the cancellation of the NCDs issued by the Company to its lenders and principal and interest thereon not payable and its consequential impact on the disqualification of directors under section 164(2) of the Act as mentioned in note no. 16.2 to the Standalone Financial Statements, 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 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".
h. With respect to the other matters to be included in the Auditors Report in accordance with the requirements of section 197(16) of the Act, as amended: In our opinion and to the best of our information and according to the explanations given to us, the Company has paid managerial remuneration of Rs. 74.28 Lakhs to its whole time director as approved by the shareholders of the Company but without obtaining prior approval from the secured lenders as required under the third proviso of the Section 197(1) 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, 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 Financial Statements as referred to in Note No. 33.1 to the Standalone Financial Statements;
ii. The Company has made provisions, as required under the applicable law or Ind AS, for material foreseeable losses, if any, on long term contracts including derivative contracts;
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 ("CARO 2016") issued by the Central Government in terms of Section 143(11) of the Act, we give in "Annexure B" a statement on the matters specified in paragraphs 3 and 4 of CARO 2016.
Annexure "A" to the Independent Auditors Report (Referred to in paragraph 1 (g) under Report on Other Legal and Regulatory Requirements of our report of even date on Standalone Financial Statements of RELIANCE NAVAL AND ENGINEERING LIMITED for the year ended March 31, 2019) Report on the Internal Financial Controls Over Financial Reporting 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 RELIANCE NAVAL AND ENGINEERING LIMITED (FORMERLY KNOWN AS RELIANCE DEFENCE AND ENGINEERING 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 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 (the Guidance Note) issued by the Institute of Chartered Accountants of India (ICAI). These responsibilities include the design, implementation and maintenance of adequate internal financial controls that were operating effectively for ensuring the orderly and efficient conduct of 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.
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 the ICAI and the Standards of Auditing prescribed under Section 143(10) of the Companies Act, 2013, to the extent applicable to an audit of internal financial controls. 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 judgement, including the assessment of the risks of material misstatement of the Standalone 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 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 Standalone 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.
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 issued by the ICAI.
Annexure "B" to the Independent Auditors Report (Referred to in paragraph 2 under the heading "Report on Other Legal and Regulatory Requirements" of our report of even date to the members of RELIANCE NAVAL AND ENGINEERING LIMITED on the Standalone Financial Statements for the year ended March 31, 2019)
i. In respect of its fixed assets:
a. The Company has maintained proper records showing full particulars, including quantitative details and situation of fixed assets on the basis of available information.
b. As explained to us, the Company has physically verified certain assets, in accordance with a phased program of verification, which in our opinion is reasonable, having regard to the size of the Company and the nature of its assets. No material discrepancies were noticed on such physical verification as compared with the available records.
c. According to the information and explanations given to us and on the basis of our examination of the records of the Company, the Company doesnt have any freehold immovable properties. As informed to us, in respect of leasehold immovable properties the original title deeds have been deposited with the lenders, we have been produced the photocopy of the title deeds of these leasehold immovable properties and based on such documents, the title deeds are held in the name of the Company.
ii. As explained to us, inventories have been physically verified during the year by the management and in our opinion the frequency of verification is reasonable. Discrepancies noticed on physical verification of the inventories between the physical inventories and book records were not material, having regard to the size of the operations of the Company and the same have been properly dealt with. iii. In respect of loans, secured or unsecured, granted by the Company to companies, firms, Limited liability partnerships or other parties covered in the register maintained under section 189 of the Act:
a. In the earlier years the Company had granted unsecured loan to its five wholly owned subsidiary Companies and the terms and conditions on which the loan had been granted were not, prima facie, prejudicial to the interest of the Company.
b. The terms of repayment of principal and payment of interest have been stipulated and during the year, the principal and interest were due for payment but due to the financial crisis the parties had not paid the same.
c. The amounts are overdue and the Company has considered the said loan and interest receivables as doubtful and has been written off. 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 Act, in respect of grant of loans, making investments and providing guarantees and securities. v. According to the information and explanations given to us, the Company has not accepted any deposits from the public. Therefore, the provisions of paragraph 3 (v) of the CARO 2016 are not applicable to the Company. vi. According to the information and explanations given to us, the Central Government has not prescribed the cost records to be maintained under sub-Section (1) of Section 148 of the Act in respect of activities carried on by the Company. Therefore the provisions of paragraph 3(vi) of the CARO 2016 are not applicable to the Company.
vii. According to the information and explanations given to us in respect of statutory dues:
a. The company has been generally regular in depositing undisputed statutory dues, including provident fund, Employees State Insurance, duty of customs, cess, Goods and Service Tax and any other statutory dues, as applicable, with the appropriate authorities during the year however delays have been noticed in respect of income tax. According to the information and explanations given to us, no undisputed amounts payable in respect of such statutory dues were outstanding as at March 31, 2019 for a period of more than six months from the date they became payable except income tax amounting to Rs. 118.20 Lakhs.
b. Details of dues of Income tax and dues to Excise Department aggregating to Rs. 3991.20 Lakhs that have not been deposited on account of disputed matters pending before appropriate authorities are as under.
|Name of the Statutes||Nature of the Dues||Period to which it relates||Amounts (Rs. in Lakhs) (*)||Forum where the dispute is pending|
|Income Tax Act,1961||Income Tax||2007-08 to 2017-18||51.28||Commissioner of Income Tax|
|CENVAT Credit Rules, 2004||Penalty under Central Excise Act,1944||2010-11 to 2017-18||3939.92||Commissioner of Central Excise|
* Net of amount deposited under protest viii. Based on our audit procedures and information and explanations given by the management, and considering the recall notices received by the company from lender banks, we are of the opinion that as on March 31, 2019 the Company has defaulted in repayment of loans (including payment of interest on loans and Non Convertible Debentures (NCD)) to banks and financial institutions aggregating to Rs. 6,46,436.32 Lakhs. Lender wise details of such defaults are as under:
|Bank / Financial Institution||Amount of default as at the balance sheet date|
|(Rs. in Lakhs)|
|Less Than 90 Days||More Than 90 Days|
|Union Bank of India||2,415.83||1,06,905.76|
|State Bank of Patiala||786.35||34,781.03|
|Oriental Bank of Commerce||350.97||13,413.06|
|Life Insurance Corporation||237.05||9,226.79|
|Punjab National Bank||651.93||35,518.46|
|United Bank of India||470.74||16,476.09|
|Karur Vyasa Bank||94.32||3,639.97|
|Bank of India||408.06||13,064.80|
|Central Bank of India||1,402.34||54,494.99|
|Jammu & Kashmir Bank||818.08||26,645.58|
|Bank of Maharashtra||261.32||9,103.55|
|Punjab & Sind Bank||74.56||2,417.11|
|State Bank of India||816.42||36,000.28|
|State Bank of Mysore||18.46||814.90|
ix. According to the information and explanations given to us, the term loans raised during the year were, prima facie, been applied for the purpose for which those are raised. The Company has not raised any money by way of initial public offer or further public offer (including debt instruments).
x. Based on our audit procedures performed for the purpose of reporting the true and fair view of the Standalone Financial Statements and on the basis of information and explanations given by the management, no fraud by the Company or on the Company by its officers or employees has been noticed or reported during the year.
xi. In our opinion and according to the information and explanations given to us the Company has paid managerial remuneration without the requisite approvals from the lenders as mandated by the provisions of section 197 read with Schedule V to the Companies Act, 2013.
xii. In our opinion and according to the information and explanations given to us, the Company is not a nidhi company. Therefore, the provisions of paragraph 3 (xii) of the CARO 2016 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, 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 Standalone Financial Statements etc. as required by the applicable accounting standards.
xiv. 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 debentures during the year. Therefore, the provisions of paragraph 3 (xiv) of the CARO 2016 are not applicable to the Company.
xv. According to the information and explanations given to us, the Company has not entered into non-cash transactions with directors or persons connected with him. Therefore, the provisions of paragraph 3 (xv) of the CARO 2016 are not applicable to the Company.
xvi. In our opinion and according to information and explanations provided to us, the Company is not required to be registered under section 45-IA of the Reserve Bank of India Act 1934.
|For Pathak H.D. & Associates|
|Firm Reg. No. 107783W|
|Dated: May 28, 2019|