setubandhan infrastructure ltd share price Auditors report

To the Members of

M/s Setubandhan Infrastructure Limited (Formerly Known as Prakash Constrowell Limited)

(A Company Under Corporate Insolvency Resolution Process vide NCLT, Mumbai Bench order dated 28.11.2022 )

Report on the Audit of Standalone Financial Statements Opinion

We have audited the accompanying Standalone financial statements of SETUBANDHAN INFRASTRUCTURE LIMITED (Formerly Known as Prakash Constrowell Limited) which comprise the Balance Sheet as at March 31, 2023, the Statement of Profit and Loss (including Statement of Other Comprehensive Income), Statement of changes in equity and Statement of cash flows for the financial year 1^st April 2022 to 31^st March 2023, and notes to the financial statements, including a summary of significant accounting policies and other explanatory information.

In our opinion and to the best of our information and according to the explanations given to us, except for the effect of the matters described in the Basis for Qualified Opinion below, the aforesaid Ind AS 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 Indian Accounting Standards prescribed under section 133 of the act read with Companies (Indian Accounting Standard Rules, 2015, as amended (Ind AS) and other accounting principles generally accepted in India, of the state of affairs of the Company as at 28^th November 2022, and its profit total comprehensive income, its cash flows and changes in equity for the period ended on that date.

Basis for Qualified opinion

We conducted our audit in accordance with the Standards on Auditing (SAs) specified under section 143(10) of the Companies Act, 2013. Our responsibilities under those Standards are further described in the Auditors Responsibilities for the Audit of the 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 financial statements under the provisions of the Companies Act, 2013 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 Qualified opinion on the standalone financial statements.

Qualified Opinion: -

i. We have been appointed as statutory auditor for the period 29^th November 2022 to 31^st March, 2023, however, we have audited financial statement for this period and we have also authenticated combined financial statements for the year 2022-23 relying on the audited figures of previous auditors for the period ended 28.11.2022. Further we have also incorporated the audit report of erstwhile auditor while forming the audit report for the year ended 31^st March, 2023.

ii. Balance Confirmation of Assets and liabilities along with other documentary evidence has not been made available to us and also the liabilities and assets has not been restated according to claim received and accepted during the CIRP period and the balance of various assets and liabilities has been taken solely on the basis of audited financial statement as on 28.11.2022. The same has also been mentioned in the Significant accounting policies by Resolution professional while preparing the financial statement.

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 dont have any key audit matters which is required to be reported except the key audit matters reported by erstwhile auditor in the report dated 28^th November 2022, we are incorporating the same in our audit report as below:-

Sr. No. Key Audit Matters	Auditors Response
1 Accuracy of recognition, measurement, presentation and disclosures of revenues and other related balances in view of adoption of Ind AS 115 "Revenue from Contracts with Customers " (new revenue Accounting standard)	Principal Audit Procedures We assessed the Companys process to identify the impact of adoption of the new revenue accounting standard. Our audit approach consisted testing of the design and operating effectiveness of the internal controls and substantive testing as follows:
The application of the new revenue accounting standard involves certain key judgments relating to identification of distinct performance obligations, determination of transaction price of the identified performance obligations, the appropriateness of the basis used to measure revenue recognized overall period.	• Evaluated the design of internal controls relating to implementation of the new revenue accounting standard.
Additionally, new revenue accounting Standard contains disclosures which involves collation of information in respect of disaggregated revenue and periods over which the remaining performance obligations will be satisfied subsequent to the balance sheet date.	• Selected a sample of continuing and new contracts, and tested the operating effectiveness of the internal control, relating to identification of the distinct performance obligations and determination of transaction price. We carried out a combination of procedures involving enquiry and observation, re-performance and inspection of evidence in respect of operation of these controls.
2. Accuracy of revenues and onerous obligations in respect of fixed price contracts involves critical estimates. Estimated effort is a critical estimate to determine revenues and liability for onerous obligations. This estimate has a high inherent uncertainty as it requires consideration of progress of the contracts, efforts incurred till date and efforts required to complete the remaining contract performance obligations.	• Tested the relevant information technology systems access and change management controls relating to contracts and related information used in recording and disclosing revenue in accordance with the new revenue accounting standard.
3 Evaluation of Uncertain Tax Position - The Group has material uncertain tax positions including matters under dispute which involves significant judgment to determine the possible outcome of these disputes.	• Selected a sample of continuing and new contracts and performed the following procedures:
	• Read, analyzed and identified the distinct performance obligations in these contracts.
	• Compared these performance obligations with that identified and recorded by the Group.
	• Considered the terms of the contracts to determine the transaction price including any variable consideration to verify the transaction price used to compute revenue and to test the basis of estimation of the variable consideration.
	• Samples in respect of revenue recorded for time and material contracts were tested using a combination of approved time sheets including customer acceptances, subsequent invoicing and historical trend of collections and dispute.
	• In respect of samples relating to fixed price contracts, progress towards satisfaction of performance obligation used to compute recorded revenue was verified with actual and estimated efforts from the time recording and budgeting systems. We also tested the access and change management controls relating to these systems.
	• Sample of revenues disaggregated by type and service offerings was tested with the performance obligations specified in the underlying contracts.
	• Performed analytical procedures for reasonableness of revenues disclosed by type and service offerings.
	• We reviewed the collation of information and the logic of the report generated from the budgeting system used to prepare the disclosure relating to the periods over which the remaining performance obligations will be satisfied subsequent to the balance sheet date.
	Principal Audit Procedures Our audit approach was a combination of test of internal controls and substantive procedures which included the following:
	• Evaluated the design of internal controls relating to recording of efforts incurred and estimation of efforts required to complete the performance obligations.
	• Tested the access and application controls pertaining to time recording, allocation and budgeting systems which prevents unauthorized changes to recording of efforts incurred.
	• Selected a sample of contracts and through inspection of evidence of performance of these controls, tested the operating effectiveness of the internal controls relating to efforts incurred and estimated.
	• Selected a sample of contracts and performed a retrospective review of efforts incurred with estimated efforts to identify significant variations and verify whether those variations have been considered in estimating the remaining efforts to complete the contract.
	• Reviewed a sample of contracts with unbilled revenues to identify possible delays in achieving milestones, which require change in estimated efforts to complete the remaining performance obligations.
	• Performed analytical procedures and test of details for reasonableness of incurred and estimated efforts.
	Principal Audit Procedures Obtained details of completed tax assessments and demands for the period ended November 28th, 2022 from management. We involved our internal experts to challenge the managements underlying assumptions in estimating the tax provision and the possible outcome of the disputes. Our internal experts also considered legal precedence and other rulings in evaluating managements position on these uncertain tax positions. Additionally, we considered the effect of new information in respect of uncertain tax positions as at April 1st, 2022 to evaluate whether any change was required to managements position on these uncertainties.

Information other than the Financial Statements and Auditor report thereon.

I. The Companys Management is responsible for the preparation of other information. The other information comprises the information included in the management discussion and analysis, Boards report including Annexures to Boards report but does not include the standalone financial statements and our auditors report thereon.

2. Our opinion on the standalone financial statements does not cover the other information and we do not express any form of assurance conclusion thereon.

3. 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.

4. Based on the work we have performed, if we conclude that there is material misstatement of this other information; we are required to report that fact. We have nothing to report in this regard.

Responsibility of Management for the Standalone Financial Statements

The Companys Management is responsible for the matters stated in section 134(5) of the Companies Act, 2013 ("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 including other comprehensive income , 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, and Companies (Indian Accounting Standards) Rules, 2015, as amended.

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 financial statement that give a true and fair view and are free from material misstatement, whether due to fraud or error.

In preparing the financial statements, management is responsible for assessing the Companys ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless management either intends to liquidate the Company or to cease operations, or bas no realistic alternative but to do so.

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.

• 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 Group 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 Group 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.

• Obtain sufficient appropriate audit evidence regarding the financial information of the entities or business activities within the Group t express an opinion on the standalone financial statements. We are responsible for the direction, supervision and performance of the audit of the financial statements of such entities included in the standalone financial statements.

• Materiality is the magnitude of misstatements in the standalone financial statements that, individually or in aggregate, makes it probable that the economic decisions of a reasonably knowledgeable user of the financial statements may be influenced. We consider quantitative materiality and qualitative factors in (i) planning the scope of our audit work and in evaluating the results of our work; and (ii) to evaluate the effect of any identified misstatements in the financial statements.

We communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit and significant audit findings, including any significant deficiencies in internal control that we identify during our audit.

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

From the matters communicated with those charged with governance, we determine those matters that were of most significance in the audit of the 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 the Companies (Auditors Report) Order, 2016 ("the Order"), issued by the Central Government of India in terms of sub-section (11) of section 143 of the Companies Act, 2013, we give in the Annexure- A statement on the matters specified in paragraphs 3 and 4 of the Order, to the extent applicable.

2. (A) 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 Balance Sheet, the Statement of Profit and Loss including Other Comprehensive income and the Cash Flow Statement dealt with by this Report are in agreement with the books of account.

d. In our opinion, the aforesaid Standalone Ind AS financial statements comply with the Accounting Standards specified under Section 133 of the Act, read with Rule 7 of the Companies (Accounts) Rules, 2014.

e. No written representations received from the directors hence we cannot comment on the qualification/disqualification of directors in terms of Section 164 (2) of the Act.

f. 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 B". Our report expresses an unmodified opinion on the adequacy and operating effectiveness of the Companys internal financial controls over financial reporting; and

(B) 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:

• The Company has not disclosed the impact of pending litigations on its financial position in its financial statements, No such details are available.

• The Company does not have any long-term Contract. The Company was not required to make any provisions for material foreseeable losses.

• There has been no delay in transferring amounts, required to be transferred, to the Investor Education and Protection Fund by the Company during the reporting period.

• i. We have not received any representation from the management regarding loans or advance or guarantee through intermediaries, however on the basis of audit report of erstwhile auditor dated 28.11.2022 we report that management has represented that, to the best of its knowledge and belief, no funds 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 persons or entities, including foreign entities ("Intermediaries") with the understanding, whether recorded in writing or otherwise, that the Intermediary shall:

> Directly or indirectly lend or invest in other persons or entities identified in any manner whatsoever ("Ultimate Beneficiaries") by or on behalf of the Company; or

> Provide any guarantee, security or the like to or on behalf of the Ultimate Beneficiaries.

ii. The management has represented that, to the best of its knowledge and belief, no funds have been received by the Company from any persons or entities, including foreign entities ("Fund Parties") with the understanding, whether recorded in writing or otherwise that the Company shall:

> Directly or indirectly lend or invest in other persons or entities identified in any manner whatsoever ("Ultimate Beneficiaries") by or on behalf of the Funding Party; or

> Provide any guarantee, security or the like from or on behalf of the Ultimate Beneficiaries; and

iii. Based on such audit procedures as considered reasonable and appropriate in the circumstances, nothing has come to our notice that has caused us to believe that the representations under subclause d (i) and d (ii) contain any material misstatement.

• During the reporting period, the Company has not declared or paid any dividend.

• Corporate Insolvency Resolution Process (herein referred as "CIRP") has been initiated against the company i.e. SETUBANDHAN INFRASTRUCTURE LIMITED w.e.f. 28th November 2022 vide order of the National Company Law Tribunal, Mumbai Bench under

Section 7 of the Insolvency and Bankruptcy Code, 2016 ( herein referred as "IBC, 2016") and Mr. Sandeep Devdas Maheshwari (herein referred as "IRP") (Reg No.:- IBBI/IPA-001/IP-P00640/2017- 18/110 has been appointed as Interim Resolution professional of the Corporate Debtor(the company). Consequently, Powers of Board of Directors has been suspended and company is under supervision and management of IRP under the Provision of Insolvency and Bankruptcy Code, 2016. The Honble NCLT, Mumbai has also declared moratorium vide "clause d" of CIRP order prohibiting initiation/continuation of any proceedings against the company during CIRP Period.

(C) With respect to the matter to be included in the Auditors Report under Section 197(16) of the Act: In our opinion and according to the information and explanations given to us, the remuneration paid by the Company to its directors during the current reporting period is in accordance with the provisions of Section 197 of the Act. The remuneration paid to any director is not in excess of the limit laid down under Section 197 of the Act.

The Ministry of Corporate Affairs has not prescribed other details under Section 197(16) of the Act which are required to be commented upon by us.

For J A M P R S & Co.

Chartered Accountants

FRN:019026C

CA Sandeep Kumar

Partner

M. No. 514470

Place: Delhi

Date: 02/08/2023

UDIN: 23514470BGWGBZ4879

Annexure - A to the Auditors Report

The Annexure referred to in our Independent Auditors Report to the members of Setubandhan Infrastructure Limited on standalone Ind-AS financial statements for the period Ended on 31/03/2023. We report that:

1) In respect of fixed assets:

a) (A) The Company is maintaining proper record to show full particulars including, quantitative details and situation of all property, plant and equipment assets on the basis of available information.

(B) The Company has maintained proper records showing full particulars of Intangible Assets;

b) We are informed that the company has a regular programme of physical verification of its property, plant and equipment by which all the property, plant and equipment are verified in a phased manner over a period of three years. However, as per the informations and explanations given to us, the management have not done the verification during the reporting period.

c) As per the erstwhile auditors report, the title deeds of immovable properties (except for, Floors of Pinnacle Mall shown in the buildings are not in the name of the company. The company entered a lease agreement with the Silver Key Developers Pvt. Ltd. for it.) disclosed in the standalone financial statements are held in the name of the Company. The management has not provided any comment on that.

d) According to the information and explanations given to us and on the basis of our examination of the records of the Company, the Company has not revalued its property, plant and equipment (including Right-of- use assets) or Intangible assets or both during the reporting period.

e) According to the information and explanations given to us and on the basis of our examination of the records of the Company, there are no proceedings initiated or pending against the Company for holding any Benami Property under the Prohibition of Benami Property Transactions Act, 1988 and rules made there under.

2) In respect of its inventories:

a) As explained to us, inventories i.e. WIP of construction activity have been physically verified by the management at reasonable intervals during the reporting period. However, we do not find any document to verify the physical verification of the inventories by the management.

b) As per the information given to us, and on the basis of our examination of the records of the Company, the Company has been sanctioned working capital limits in excess of five crore rupees, in aggregate, from banks. However, the limits sanctioned by the banks are already classified by the Banks as NPA hence there are no stock statements being submitted by the company.

c) The company is not maintaining proper records of inventory. Since there are no proper documents to support the physical verification of the inventories by the management, we cannot comment on the adequacy and discrepancy in the stock items.

3) According to the information and explanations given to us and on the basis of our examination of the records of the Company, the Company has not made any investments, provided guarantee or security, or granted any advances in the nature of loans, secured or unsecured, to companies, firms, limited liability partnerships or any other parties during the reporting period.

Based on the audit procedures carried on by us and as per the information and explanations given to us, the Company has not provided any loans/advances in the nature of loans, or stood guarantee, or provided security to any other entity. Further, the company has not made any investments, or provided guarantees or securities during the reporting period, accordingly sub- clause (a), (b), (c), (d), (e), and (f) of this clause of the order is not applicable.

4) 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, with respect to the loans and investments made.

5) According to the information and explanation given to us, the Company has not accepted any deposits from the public and accordingly, paragraph 3(v) of the Order is not applicable.

6) As informed to us, the Central Government has not prescribed maintenance of the cost records under section 148(1) of the Companies Act, 2013, accordingly clause 3 (vi) of the order is not applicable.

7) In respect of Deposit of Statutory Liability:

a) We do not been provided sufficient documents and details regarding depositing of statutory liabilities hence we cannot comment on the depositing with appropriate authorities undisputed statutory dues including Provident Fund, employees state insurance, income tax, service tax, sales tax, tax deducted at source, cess and other material statutory dues applicable.

However as per audit report of erstwhile auditor and our verification and According to the information and explanations given to us and the records of the company examined by us, TDS amounting to Rs. 2, 00, 05,093/- is payable undisputed which were in arrears as at 31^st of March 2023 for a period of more than six months from the date they become payable.

b) We have not been provided the complete details of statutory dues which is pending as on 31^st of march 2023 on account of any disputes, however on the basis of audit report of erstwhile auditor following dues of Statutory

liabilities have not been deposited by the Company on account of disputes:

Name of Statue	Nature of Dues	Amount Rs. (Rs. In Lakh)	Forum where Dispute is Pending
Income Tax Act, 1961	Income Tax Assessment dues under Section 153A of the act	2265.46	Assistant Commissioner of Income Tax (Appeals)
Employees State Insurance Act, 1948	Demandraised by Appellate Authority of Employee State Insurance Corporation (ESIC)	5.37	Industrial Labour Court, Nashik
Goods and Service Tax Act, 2017	OST Demand order for FY 2017-18 to FY 2020-21	547.02	GST Appellate Authority

8) According to the information and explanation given to us and on the basis of our examination of the records of the Company, the Company has not surrendered or disclosed any transactions, previously unrecorded as income in the books of account, in the assessments under the Income Tax Act, 1961 as income during the reporting period.

9) a) According to the records of the company examined by us and information and explanations given to us, the company has defaulted in repayment of loans or other borrowings to any lender as at the balance sheet date. The details of which has been mentioned below:

Name of bank or Financial Institution	Type of Facility	Outstanding amount as on 31.03.2023 (As per claims received by the RP)
State bank of India	Cash Credit Facility	Rs 10,385.91 Lakhs
Andhra bank	Cash Credit Facility	Rs 1,300.65 Lakhs
Kotak Bank	Car Loan	Rs 228.90 Lakhs
IL&FS Financial Services Limited	Loan	Rs 4,104.71 Lakhs

b)According to the information and explanations given to us and on the basis of our examination of the records of Company, the Company has not been declared as a willful defaulter by any bank or financial institution or other lender.

c) According to the information and explanations given to us and on the basis of our examination of the records of Company, the Company has not obtained any Term loans during the reporting period, accordingly, clause 3(ix)(c) of the Order is not applicable.

d) According to the information and explanations given to us and on the basis of our examination of the records of Company, we report that no funds have been raised on short-term basis during the reporting period by the Company. Accordingly, clause 3(ix)(d) of the Order is not applicable.

e) According to the information and explanations given to us and on the basis of our examination of the records of Company, we report that the Company has not taken any funds from any entity or person on account of or to meet the obligations of its subsidiaries as defined under the Companies Act, 2013. Accordingly, clause 3(ix)(e) of the Order is not applicable.

f) According to the information and explanations given to us and on the basis of our examination of the records of Company, we report that the Company has not raised loans during the reporting period on the pledge of securities held in its subsidiaries as defined under the Companies Act,

2013. Accordingly, clause 3(ix)(f) of the Order is not applicable.

10) a) The Company has not raised any money by way of initial public offer or the further public offer (including debt instruments) during the reporting period. Accordingly, reporting requirements of this clause is not applicable

b) As per explanations given to us; the company has not made any preferential allotment or private placement of shares or convertible debentures (fully, partially, or optionally convertible) during the reporting period. Accordingly, reporting requirement of this clause is not applicable.

11) a) Based on examination of the books and records of the Company and according to the information and explanations given to us, considering the principles of materiality outlined in Standards on Auditing, we report that no fraud by the Company or on the Company has been noticed or reported during the course of the audit.

b) According to the information and explanations given to us, no report under sub- section (12) of Section 143 of the Companies Act, 2013 has been filed by the auditors in Form ADT-4 as prescribed under Rule 13 of Companies (Audit and Auditors) Rules, 2014 with the Central Government.

c) No whistle-blower complaints during were received during the reporting period by the company.

12) In our Opinion and according to the information and explanations given mto us, the Company is not a Nidhi company. Accordingly, paragraph 3(xii) of the Order is not applicable.

13) According to the information and explanations given to us and based on our examination of the records of the Company, transactions with the related parties are in compliance with Sections 177 and 188 of the Act where applicable and details of such transactions have not been disclosed in the financial statements as required by the applicable accounting standards.

14) a) Based on information and explanations provided to us and our audit procedures, in our opinion, the company has no internal audit system commensurate with the size and nature of its business.

b) We were not provided any internal audit reports for the reporting period.

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

16) a) The Company is not required to be registered under section 45-IA of the Reserve Bank of India Act 1934. Accordingly, clause 3(xvi)(a) of the Order is not applicable.

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

c) The Company is not a Core Investment Company (CIC) as defined in the regulations made by the Reserve Bank of India. Accordingly, clause 3(xvi)(c) of the Order is not applicable.

d) According to the information and explanations provided to us during the course of audit, the Group does not have any CIC. Accordingly, the requirements of clause 3(xvi)(d) are not applicable.

17) The company has not incurred cash losses in the current financial reporting period and the immediately preceding financial year

18) There has been no resignation of the statutory auditors during the reporting period. However, after initiation of CIRP w.e.f. 28.11.2022 the Auditor has been changed and J A M P R S & CO has been appointed as Statutory auditor w.e.f 29.11.2022, hence audit for the period April 22 to 28^th of November 2022 has been conducted by erstwhile auditor GRANDMAR & ASSOCIATES and Audit for period 29^th of November 2022 to March 31, 2023 has been conducted by J A M P R S & CO.

19) Since Company is already under CIRP due to default in payment of its dues on time, on the basis of the financial ratios, ageing and expected dates of realization of financial assets and payment of financial liabilities, other information accompanying the financial statements, the auditors knowledge of the Board of Directors and management plans, We have an opinion that there is material uncertainty exists as on the date of the audit report that company is 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;

20) As per the provisions of section 135(5) the company is not mandatorily required to constitute a Corporate Social Responsibility Committee and spend funds for the Corporate Social Responsibility (CSR) activities. Accordingly, reporting requirements of this clause is not applicable.

For J A M P R S & Co.

Chartered Accountants

FRN:019026C

CA Sandeep Kumar

Partner

M. No. 514470

UDIN:-23514470BGWGBZ4879

Place: Delhi

Date: 02/08/2023