Saurashtra Cement Ltd Auditor Reports

ON STANDALONE FINANCIAL STATEMENTS

To

The Members of Saurashtra Cement Limited

Report on the Audit of Standalone Financial Statements

Opinion

We have audited the accompanying standalone Financial statements of Saurashtra Cement Limited ("the Company"), which comprise the Balance Sheet as at March 31,2024, the Statement of Profit and Loss (including Other Comprehensive Income), the Statement of Changes in Equity and the Statement of Cash Flows For the year then ended on that date, and Notes to the standalone Financial statements, including a summary of the material accounting policies and other explanatory information (herein after 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 (herein after referred to as "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, (herein after reFerred to as "Ind AS") and other accounting principles generally accepted in India, of the state of affairs of the Company as at March 31,2024, and its Profit, total comprehensive income, changes in equity and its cash Flows For the year ended on that date.

Basis For Opinion

We conducted our audit of the standalone Financial statements in accordance with the Standards on Auditing (hereinafter referred to as Sas), as specified under section 143(10) of the Act. Our responsibilities under those Standards are Further described in the Auditors Responsibilities For the Audit of the standalone 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 (hereinafter referred to as "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 made thereunder, and we have Fulfilied 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.

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 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.

Key Audit Matter	How was the matter addressed in our audit
Revenue recognition - Estimation of incentives to customers	Our audit procedures include the following substantive procedures:
Revenue from sale of products is measured net of discounts, incentives, rebates etc. given to the customers on the Companys sales.	- Obtained an understanding from the management regarding controls relating to recording of incentives and period end outstanding value of performance obligations and tested the operating effectiveness of such controls.
The Company sells its products through various channels such as dealers and commission agents (customers) and provides incentives to them in the form of discount, incentives, rebate etc. under various marketing schemes.	- Performing substantive testing by selecting samples using statistical sampling for discounts and rebates transactions recorded during the year as well as period end discounts and rebates accruals and matching the parameters used in the computation with the relevant source documents.
Certain discounts, incentives and rebates for goods sold during the year are only finalised when the precise amounts are known, and revenue therefore includes an estimate of variable consideration.
The variable consideration represents the portion of discounts. incentives and rebates that are not directly deducted on the invoice and involves estimation by the Company.	- Verifiied the authorisation for schemes for incentives.
	- Evaluated the inputs used in the estimation of revenue in context of incentives.
In addition, the value and timing of promotions for products varies from period to period, and the activity can span beyond the year end. The unsettled portion of the variable consideration results in discounts, incentives, and rebates due to customers as at year end.	- Ensured the completeness of liabilities recognised by evaluating the parameters for the schemes.
This requires an estimation of the revenue taking into consideration these incentives. Therefore, there is a risk of revenue being misstated as a result of variations in the assessment of discounts, incentives and rebates.	- Checking completeness of accrual by subsequent settlement (i.e. payments and credit notes) made after year end which relates financial year 2023-24 and accuracy of the data used by the Company for accrual of discounts and rebates using underlying agreements and debit notes received from customers.
The matter has been determined to be key audit matter in view of volume and complexities in working as well as the involvement of significant estimates by the management.	- Verifiied that accounting treatment is in accordance with Ind AS 115 "Revenue from Contracts with Customers".
Refer Note Nos 22 and 25 to the standalone financial statements.

Information Other than the standalone financial statements and Auditors Report Thereon

The Companys Management and Board of Directors are responsible for the preparation of the other information. The other information comprises the information included in the annual report but does not include the standalone and consolidated financial statements and our auditors reports thereon. The annual report is expected to be made available to us after the date of this auditors report.

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 during the course of our 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.

When we read the annual report, if we 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 standalone financial statements

The Companys Management and Board of Directors are responsible For the matters stated in section 134(5) of the Act with reFerence to the preparation of these standalone Financial statements that give a true and Fair view of the Financial position, Financial perFormance, total comprehensive income, changes in equity and cash Flows of the Company in accordance with the Ind AS and other accounting principles generally accepted in India. This responsibility also includes maintenance of adequate accounting records in accordance with the provisions of the Act For saFeguarding of the assets of the Company and For preventing and detecting Frauds and other irregularities; selection and application of appropriate accounting policies; making judgements 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 and Board of Directors are responsible For assessing the Companys ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless management either intends to liquidate the Company or to cease operations, or has no realistic alternative but to do so.

The Companys Management and Board of Directors are 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 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 control relevant to the audit in order to design audit procedures that are appropriate in the circumstances. Under section 143(3)(i) of the Act, we are also responsible For expressing our opinion on whether the Company has an adequate internal Financial controls system in place and the operating effectiveness of such controls.

• Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and related disclosures made by management.

• Conclude on the appropriateness of managements use of the going concern basis of accounting and, based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Companys ability to continue as a going concern. IF we conclude that a material uncertainty exists, we are required to draw attention in our auditors report to the related disclosures in the standalone 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.

Other Matters

The standalone financial statements for the year ended March 31, 2023, include the financial information of erstwhile Gujarat Sidhee Cement Limited (GSCL) pursuant to the scheme of amalgamation of GSCL with the Company approved by National Company Law Tribunal vide its order dated March 16, 2023 with January 1, 2022 as appointed date and effective from March 30,2023. This financial information were audited by the auditors of erstwhile GSCL, whose report was furnished to us and was relied upon by us. We had audited the adjustments made by the management consequent to the amalgamation of GSCL with the Company.

Our opinion on the standalone financial statements, and our Report on other legal and regulatory requirements below, is not modified in respect of the above matter and our reliance on the work done by and the report of the other auditors.

Report on Other Legal and Regulatory Requirements

1. As required by Section 143(3) of the Act, based on our audit 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, except for certain matters in respect of audit trail as stated in the paragraph 1 (i)(vi) below on reporting under Rule 11 (g) of the Companies (Audit and Auditors) Rules, 2014.

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 in 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 read with the Companies (Indian Accounting Standards) Rules, 2015, as amended.

e) On the basis of the written representations received from the directors as on March 31,2024, taken on record by the Board of Directors, none of the directors is disqualified as on March 31, 2024, from being appointed as a director in terms of Section 164(2) of the Act.

f) With respect to the adequacy of the internal financial controls with reference to the standalone financial statement of the Company and the operating effectiveness of such controls, refer to our separate report in Annexure A. Our report expresses an unmodified opinion on the adequacy and operating effectiveness of the Companys internal financial controls with reference to the standalone financial statements.

g) 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, we report that, in our opinion and to the best of our information and according to the explanations given to us, the remuneration paid by the Company to its Managing Director and Executive Vice Chairman during the year is in accordance with the provisions of section 197 of the Act.

h) The reservation relating to the maintenance of accounts and other matters connected therewith are as stated in paragraph (b) above on reporting under Section 143(3)(b) and paragraph 1(i)(vi) below on reporting under Rule 11 (g).

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 - Refer Note 34 to the standalone financial statements.

(ii) The Company did not have any long-term contracts including derivative contracts for which there were any material foreseeable losses.

(iii) There has been no delay in transferring amounts which were required to be transferred, to the Investor Education and Protection Fund by the Company.

(iv)(a) The management has represented that, to the best of its knowledge and belief, no funds (which are material either individually or in the aggregate) have been advanced or loaned or invested (either from borrowed funds or share premium or any other sources or kind of funds) by the Company to or in any other person or entity, including foreign entity ("Intermediaries"), with the understanding, whether recorded in writing orotherwise, that the Intermediary shall, whether, directly or indirectly lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the Company ("Ultimate Beneficiaries") or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries;

(b) The management has represented, that, to the best of its knowledge and belief, no funds (which are material either individually or in the aggregate) have been received by the Company from any person or entity, including foreign entity ("Funding Parties"), with the understanding, whether recorded in writing or otherwise, that the Company shall, whether, directly or indirectly, lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the Funding Party ("Ultimate Beneficiaries") or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries;

(c) Based on the audit procedures that have been considered reasonable and appropriate in the circumstances, nothing has come to our notice that has caused us to believe that the representations under sub-clause (i) and (ii) of Rule 11 (e), as provided under (a) and (b) above, contain any material misstatement.

(v) The interim dividend declared and paid by the Company during the year and until the date of this audit report is in compliance with Section 123 of the Act.

As stated in Note 14.6 to the standalone financial statements, the Board of Directors of the Company has proposed final dividend for the year which is subject to the approval of the members at the ensuing Annual General Meeting. The dividend declared is in accordance with Section 123 of the Act to the extent it applies to declaration of dividend.

(vi) Based on our examination which included test checks, except for the instances mentioned below, the Company has used accounting softwares for maintaining its books of account, which have a feature of recording audit trail (edit log) facility and the same has operated throughout the year for all relevant transactions recorded in the respective software:

i. The feature of recording audit trail (edit log) facility was not enabled at the database level to log any direct data changes for the accounting software used for maintaining the books of accounts.

ii. The feature of recording audit trail (edit log) facility was not enabled, for a portion of the year in one of the accounting software used for maintaining books of accounts; the audit trail feature was enabled from June 15, 2023 for the tables related to financial information.

Further, where audit trail (edit log) facility was enabled and operated throughout the year, we did not come across any instance of audit trail feature being tampered with during the course of our audit.

As provision to Rule 3(1) of the Companies (Accounts) Rules, 2014 is applicable from April 1, 2023, reporting under Rule 11 (g) of the Companies (Audit and Auditors) Rules, 2014 on preservation of audit trail as per the statutory requirements for record retention is not applicable for the financial year ended March 31, 2024.

2. As required by the Companies (Auditors Report) Order, 2020 ("the Order") issued by the Central Government of India in terms of sub-section 11 of section 143 of the Act, we give in Annexure B, a statement on the matters specified in the paragraph 3 and 4 of the order.

	For, Manubhai & Shah LLP
	Chartered Accountants
	Firm Registration No. 106041W/W100136
	(KC Patel)
	Partner
Place: Mumbai	Membership No. 030083
Date: May28, 2024	UDIN: 24030083BKBENC5851

ANNEXURE-A

TO THE INDEPENDENT AUDITORS REPORT

(Referred to in paragraph 1(f) under "Report on Other Legal and Regulatory Requirements" section of our report to the members of Saurashtra Cement Limited of even date)

Report on the Internal Financial Controls with reference to aforesaid Standalone Financial Statements under Clause (i) of Sub-section 3 of Section 143 of the Act.

In conjunction with our audit of the standalone financial statements of Saurashtra Cement Limited (the Company¹) as of and For the year ended March 31, 2024, we have also audited the internal Financial controls with reference to standalone financial statements of the Company.

Managements Responsibility for Internal Financial Controls

The Companys Management and the Board of Directors are responsible For establishing and maintaining internal financial controls based on the internal financial controls with reference to 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 ICAI (the "Guidance Note"). 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

Our responsibility is to express an opinion on the Companys internal financial controls with reference to the financial statements based on our audit. We conducted our audit in accordance with the Guidance Note and the Standard on Auditing (SAs) prescribed under section 143(10) of the Act, 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 with reference to financial statements were 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 with reference to financial statements and their operating effectiveness. Our audit of internal financial controls with reference to financial statements included obtaining an understanding of internal financial controls with reference to financial statements, assessing the risk that a material weakness exists, and testing and evaluating the design and operating effectiveness of internal control based on the assessed risk. The procedures selected depend on the auditors judgment, including the assessment of the risks of material misstatement of the financial statements, whether due to fraud or error.

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion on the Companys internal financial controls with reference to standalone financial statements.

Meaning of Internal Financial Controls with reference to Financial Statements

A companys internal financial controls with reference to financial statements 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 controls with reference to financial statements include those policies and procedures that:

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

2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the Company are being made only in accordance with authorizations of management and directors of the Company; and

3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the Companys assets that could have a material effect on the financial statements.

Inherent Limitations of Internal Financial Controls with reference to Financial Statements

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

Opinion

In our opinion, the Company has, in all material respects, an adequate internal financial control with reference to financial statements and such internal financial controls with reference to financial statements were operating effectively as at March 31, 2024, based on the internal control with reference to financial statements criteria established by the Company considering the essential components of internal control stated in the Guidance Note.

	For, Manubhai &Shah LLP
	Chartered Accountants
	Firm Registration No. 106041W/W100136
	(K C Patel)
	Partner
Place: Mumbai	Membership No. 030083
Date: May 28, 2024	UDIN: 24030083BKBENC5851

ANNEXURE-B

TO THE INDEPENDENT AUDITORS REPORT

(Referred to in paragraph 2 under "Report on Other Legal and Regulatory Requirements" section of our report the members of Saurashtra Cement Limited of even date)

Report on the Companies (Auditor Report) Order, 2020, issued in terms of section 143 (11) of the Companies Act, 2013(the Act) of Saurashtra Cement Limited, (the Company)

In terms of the information and explanations sought by us and given by the Company and the books of account and records examined by us in the normal course of audit and to the best of our knowledge and belief, we state that:

(i) (a) (i) The Company has maintained proper records showing full particulars, including quantitative details and situation of Property, Plant and Equipment, capital work in progress and relevant details of right of use Assets.

(ii) The Company has maintained proper records showing full particulars of Intangible Assets.

(b) The Property, Plant and Equipment have been physically Verifiied 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 program, certain property, plant and equipment have been physically Verifiied by the Management during the year and no material discrepancies have been 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 provided to us, we report that, the title in respect of self-constructed buildings and title deeds of all other immovable properties (other than properties where the Company is the lessee and the lease agreements are duly executed in favour of the lessee), disclosed in the financial statements are held in the name of the Company as at the balance sheet date except in respect of the following immovable properties:

					Rs.in lakhs
Description of properties	Cross carrying value as at Balance Sheet date	Held in name of	Whether promoter, director or their relative or employee	Period held	Reason for not being held in name of Company
Freehold Land, Buildings at Sidheegram Plant	31,156.62	Erstwhile Gujarat			The Title deeds are held in the name of GSCL which has amalgamated with the Company with effect from March 30, 2023 (Appointed date
Leasehold Land at Sidheegram Plant	322.89	Sidhee Cement Limited (GSCL)	No	January 1 ( 2022	being January 1,2022). The change of name on the title deeds from GSCL to Saurashtra Cement Limited is under process.
Commercial office in Daman	1.71
Leasehold Land at Sidheegram Plant	4,104.04	Bharat Chemical Industries	No	February 26, 2024	Deed for Transfer of Mining Lease between the Company, Bharat Chemical Industries and the State Government has been executed. Change of name in the Land Revenue Records is under process.

(d) The Company has not revalued any of its Property, Plant and Equipment (including right of use assets) and intangible assets during the year ended March 31,2024.

(e) According to the information and explanations given to us and on the basis of our examination of the records of the Company, no proceedings have been initiated during the year or are pending against the Company as at March 31, 2024 For holding any benami property under the Benami Transactions (Prohibition) Act, 1988 (as amended in 2016) and rules made thereunder.

(ii) (a) The inventories have been physically Verifiied by the Management at reasonable intervals. In our opinion and according to the information and explanations given to us, the coverage and procedure of such veriFication by the Management are appropriate having regard to the size of the Company and the nature of its operations. No material discrepancies were noticed on such physical veriFication.

(b) The Company has been sanctioned working capital limits in excess of Rs. 5 crores, in aggregate, during the year, From the bank on the basis of security of current assets. The Company has Filed quarterly returns or statements with such banks, which are in agreement with the books of account other than those as set out below:

						Rs.in lakhs
Quarter ended	Name of bank	Particulars of Securities provided	Amount as per books of account (Excluding Paint Division)	Amount as reported in the quarter end statement	Amount of difference	Reason For differences, as explained by the management
June 30, 2023	HDFC Bank Limited	Inventories and Trade Receivables	29,346.12	25,543.98	(3,802.14)	-Stock under letter of credit, amounting to Rs. 4,433.31 lakhs are not considered by the bank For drawing power calculation and hence not reported in the statement submitted to the bank For quarter ended on June
September 30, 2023	HDFC Bank Limited	Inventories and Trade Receivables	26,100.40	26,327.99	227.59	30, 2023. -Change in value after completion of limited
December 31,2023	HDFC Bank Limited	Inventories and Trade Receivables	28,566.27	28,911.84	345.57	review For respective quarters, aftersubmission of statement to the bank.

ReFer Note No. 19.2 of the Financial statements.

(iii) During the year, the Company has not made any investment in, provided any guarantee or security to companies, Firms, limited liability partnerships or any other parties. During the year, the Company has granted interest Free unsecured loans to employees in respect of which:

a) (i) Aggregate amount of loan provided to subsidiary is Rs. Nil and balance outstanding at the balance sheet date is Rs. Nil.

(ii) During the year, aggregate amount of loan provided to employees is Rs. 54.33 Lakhs and balance outstanding at the balance sheet date is Rs. 48.11 Lakhs.

b) The investments made and the terms of the grant of all loans are not prejudicial to the Companys interest. The Company has not provided any guarantee or given security.

c) In respect of loans granted by the Company, the schedule of repayment of principal have been stipulated and the repayments thereofhave been regular as per stipulation.

d) In respect of loans granted by the Company, there is no overdue amount remaining outstanding as at the balance sheet date.

e) No loan granted by the Company which has Fallen due during the year, has been renewed or extended or Fresh loans granted to settle the overdue of existing loans given to the same parties.

f) The Company has not granted any loans or advances in the nature of loans either repayable on demand or without speciFying any terms or period of repayment to Firms, limited liability partnerships or any other parties during the year. Hence, reporting under clause 3(iii)(f) of the order is not applicable.

(iv) In our opinion and according to the information and explanations given to us, the Company has complied with the provisions of sections 185 and 186 of the Act, with respect to the loans and investments made. The Company has not given any guarantee or provided any security in connection with the loan to any person or other body corporate and accordingly, the question of commenting on compliance with the provisions in respect thereofdoes not arise.

(v) The Company has not accepted deposits or amounts which are deemed to be deposits during the year and does not have any unclaimed deposits as at March 31, 2024. ThereFore, the reporting requirement under clause 3(v) of the Order is not applicable.

(vi) We have broadly reviewed the books of account maintained by the Company in respect of its products where, pursuant to the rules made by the Central Government of India, the maintenance of cost records has been prescribed under sub-section (1) of Section 148 of the Act, and are of the opinion that, prima Facie, the prescribed accounts and records have been made and maintained. We have not, however, made a detailed examination of the records with a view to determine whether they are accurate or complete.

(vii) (a) According to the information and explanations given to us and based on records of the Company examined

by us, the Company has been regular in depositing undisputed statutory dues, including Provident Fund, Employees State Insurance, Income Tax, Customs Duty, Income Tax deducted at source, Goods and Service Tax and other material statutory dues, as applicable.

There were no undisputed amounts payable in respect of Goods and Service Tax, Provident Fund, Employees State Insurance, Income Tax, Sales Tax, Service Tax, duty of Customs, duty of Excise, Value Added Tax, Cess and other material statutory dues as at March 31, 2024, 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, the details of disputed statutory dues of Income Tax, Service tax, Sales Tax, Value Added Tax, Excise Duty and other material statutory dues which have not been deposited on account of a dispute as of 31^st March 2024 are as Follows:

Name of statute	Nature of dues	Amount (Rs. in Lakhs)	Year to which the amount relates	Forum where the dispute is pending
		174.05	2006-07 and 2007-08	High Court of Gujarat
		36.72*	1992-93	Customs Excise & Service Tax Appellate Tribunal (CESTAT)
		970.07	2007-08 to 2016-17	CESTAT
Central Excise Act, 1944	Excise Duty	3,234.41*	2008-09 to 2011-12 and 2013-14 to 2017-18	CESTAT
		405.57	2019-10 to 2013-14	CESTAT
		495.34*	2009-10,2010-11 and 2012-13	Commissioner/ Add. Commissioner, Central Excise
		5.85*	2013-14	Joint Commissioner, Central Excise
Customs Act,	Custom	35.85*	1995-96	CESTAT
1962	Duty	524.48	2011-12 and 2012-13	CESTAT
		420.59*	2012-13	CESTAT
Central Excise/ CENVAT Credit Rules, 2004	Service Tax	138.36*	2012-13 and 2013-14	CESTAT
Gujarat Sales Tax Act, 1961	Sales Tax	121.21*	2002-03 to 2004-05	Joint Commissioner (A), Rajkot
Gujarat Value Added Tax Act, 2003	VAT	321.88*	2006-07 and 2007-08	Joint Commissioner (A), Rajkot
Income-tax Act, 1961	Income Tax	302.30*	2017-18	CIT (A), National Faceless Appeal Centre (NFAC)
Income-tax Act, 1961	Income Tax	4.35*	2015-16	CIT (A) 3, Mumbai
Income-tax Act, 1961	Income Tax	4,131.09	2019-20 and 2020-21	CIT (A), National Faceless Appeal Centre (NFAC)
The Gujarat Panchayats Act, 1993	House Tax	42.88*	1993-94 to 2023-24	High Court of Gujarat
Mines and Minerals (Development and Regulation) Act, 1957	Royalty	15.12	2004-05 to 2006-07	Commissioner, Geology and Mining Department, Gandhinagar
		355.83	2003-04 to 2014-15	High Court of Gujarat
		546.10*	2003-04 to 2014-15	High Court of Gujarat
Gujarat Stamp Act, 1958	Stamp Duty	28.02	2013-14	High Court of Gujarat
Goods and Services Tax Act, 2017	GST	19.71	2017-18	Joint Commissioner of SGST(A), Rajkot
		34.97*	2017-18

* Disputed statutory dues in the name of erstwhile GSCL.

(viii) The Company has not surrendered or disclosed any transaction, previously unrecorded in the books of account, in the tax assessments under the Income Tax Act, 1961(43 of 1961) as income during the financial year ended March 31,2024. Accordingly, the requirement to report on clause 3(viii) of the Order is not applicable to the Company.

(ix) (a) In our opinion, the Company has not defaulted in repayment of loans or other borrowings or in the payment of interest thereon to any lender during the year.

(b) The Company has not been declared wilful defaulter by any bank or financial institution or government or any government authority.

(c) To the best of our knowledge and belief, in our opinion, term loans availed by the Company during the year were applied for the purposes for which the loans were obtained.

(d) On an overall examination of the financial statements of the Company, no funds raised on short-term basis have been used for long-term purposes by the Company.

(e) On an overall examination of the financial statements of the Company, the Company has not taken any funds from any entity or person on account of or to meet the obligations of its subsidiary, associates or joint ventures.

(f) The Company has not raised loans during the financial year ended March 31,2024 on the pledge of securities held in its subsidiaries, joint ventures or associate companies. Hence, the requirement to report on clause 3(ix)(f) of the Order is not applicable to the Company.

(x) (a) The Company has not raised moneys by way of initial public offer or further public offer (including debt instruments) during the year. Hence reporting under clause 3(x)(a) of the Order is not applicable.

(b) During the year the Company has not made any preferential allotment or private placement of shares or convertible debentures (fully or partly or optionally). Hence reporting under clause 3(x)(b) of the Order is not applicable to the Company.

(xi) (a) To the best of our knowledge no fraud by the Company or on the Company, is noticed or reported during the year.

(b) To the best of our knowledge, no report under sub-section (12) of section 143 of the Companies Act has been filed in Form ADT-4 as prescribed under rule 13 of Companies (Audit and Auditors) Rules, 2014 with the Central Government, during the year and up to the date of this report.

(c) As represented to us by the Management, there were no whistle blower complaints received by the Company during the year.

(xii) The Company is not a nidhi Com pany as per the provisions of the Companies Act, 2013. Therefore, the requirement to report on clause 3(xii) of the Order is not applicable to the Company.

(xiii) Transactions with the related parties are in compliance with sections 177 and 188 of Companies Act, 2013 where applicable and the details have been disclosed in the notes to the standalone financial statements, as required by the applicable accounting standards.

(xiv) (a) The internal audit during the year was carried out by Internal Audit Department of the Company. Having

regard to the size and volume of the Companys operations the internal audit department did not have adequate staff. In view of this in our opinion the internal audit system was not commensurate with the size and the nature of its business.

(b) We have not considered, the internal audit reports issued to the Company during the year.

(xv) According to the information and explanations given to us and based on our examination of the records of the Company, the Company has not entered into any non-cash transactions with Directors or persons connected to directors and hence provisions of Section 192 of the Companies Act, 2013 and requirement to report on clause 3(xv) of the Order are not applicable to the Company.

(xvi) (a) The Company is not required to be registered under section 45-IA of the Reserve Bank of India Act, 1934.

Hence, reporting under clause (xvi)(a), (b) and (c) of the Order is not applicable.

(b) The Group does not have any CIC as part of the group and accordingly reporting under clause (xvi)(d) of the Order is not applicable.

(xvii) The Company has not incurred cash losses during the Financial year covered by our audit and the immediately preceding Financial year.

(xviii) There has been no resignation of the statutory auditors of the Company during the year and accordingly requirement to report on clause 3(xviii) of the Order is not applicable to the Company.

(xix) On the basis of the Financial ratios, ageing and expected dates of realization of Financial assets and payment of Financial liabilities, (Asset Liability Maturity (ALM) pattern) other information accompanying the Financial statements and our knowledge of the Board of Directors and Management plans and based on our examination of the evidence supporting the assumptions, nothing has come to our attention, which causes us to believe that any material uncertainty exists as on the date of the audit report indicating that Company is not capable of meeting its liabilities existing at the date of balance sheet as and when they Fall due within a period of one year From the balance sheet date. We, however, state that this is not an assurance as to the Future viability of the Company. We Further state that our reporting is based on the Facts up to the date of the audit report and we neither give any guarantee nor any assurance that all liabilities Falling due within a period of one year From the balance sheet date, will get discharged by the Company as and when they Fall due.

(xx) The Company has Fully spent the required amount towards Corporate Social Responsibility (CSR) and there is no unspent CSR amount For the year requiring a transFer to a Fund specified in Schedule VII to the Companies Act or special account in compliance with the provision of sub-section (6) of section 135 of the said Act. Accordingly, reporting under clause (xx) of the Order is not applicable For the year.

	For, Manubhai & Shah LLP
	Chartered Accountants
	Firm Registration No. 106041W/W100136
	(K C Patel)
	Partner
Place: Mumbai	Membership No. 030083
Date: May28, 2024	UDIN: 24030083BKBENC5851