Shree Narmada Aluminium Industries Ltd Directors Report.

To the Members Of

Shree Narmada Aluminium Industries Limited Report on the Financial Statements

We have audited the accompanying financial statements of Shree Narmada Aluminium Industries Limited ("the Company"), which comprise the Balance

Sheet as at March 31, 2020, the Statement of Profit and Loss, statement of changes in equity and Cash Flow Statement for the year then ended, and including asummaryofsignificant accounting policies and other explanatory information.

Basis of Qualified Opinion

The Company is a sick Company under Sick Industrial Companies Act, 1985. The order of the Honorable High Court of Gujarat dated May 16, 2008 for rehabilitation is under the process of implementation. Meanwhile, a secured creditor filed an application before Debt recovery Tribunal-IIl (DRT-III} and the court receiver now having the possession of property. Despite net worth of the Company fully eroded, the Management is of the opinion that the

Going Concern Assumption is sustainable and accordingly the accounts of the Company have been prepared on going concern basis. (Refer Note 18 of financial statements).

In our opinion and to the best of our information and according to the explanations given to us, except in respect of consequential possible impacts of the matters mentioned under para ‘Basis of Qualified Opinion the aforesaid financial statements give the information required by the Act in the manner so required and give a true and fair view in conformity with the accounting principles generally accepted in India, of the state of affairs of the Company as at March 31, 2020, and profit/loss, changes in equity its cash flows for the year ended on that date.

and

Basis for 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 our opinion.

Key Audit Matters

Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the financial statements of the current

period. These matters were addressed in the context of our audit ofthe financial statements as a whole, and in forming our opinion thereon, and we do

not provide a separate opinion on these matters.

Managements Responsibility for the Financial Statements

The Companys Board of Directors is responsible for the matters stated in Section 134(5) of the Companies Act, 2013 ("the Act") with respect to the preparation of these financial statements that give a true and fair view ofthe financial position, financial performance, changes in equity and cash flows

of the Company in accordance with the accounting principles generally accepted in India, including the Accounting Standards specified under Section 133 of the Act. This responsibility also includes maintenance of adequate accounting records in accordance with the provisions of the Act for safeguarding of the assets of the Company and for preventing and detecting frauds and other irregularities; selection and application of appropriate 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 presentationofthe financial statements that give a true and fair view and are free from material misstatement, whether due to fraud or error.

In preparing the financial statements, management is responsible for assessing the Companys ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless management either intends to liquidate the

Company orto 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

Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditors report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with SAs will always detect a material misstatementwhen it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these financial statements.

Report on Other Legal and Regulatory Requirements

As required by the Companies (Auditors Report) Order, 2016 ("the Order") issued by the Central Government of India in terms of sub-section (11) of section 143 of the Act, we give in the Annexure "A" a statement on the matters specified in paragraphs 3 and

4 of the Order, to the extent applicable.

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

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; a) 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. b) The Balance Sheet, Statement of Profit and Loss, and the Cash Flow Statement dealt with by this Report are in agreement with the books of account; c) Inouropinion, the aforesaid financial statements comply with the Accounting Standards specified under Section 133 of the Act, read with Rule 7 of the Companies (Accounts) Rules, 2014. d) Onthe basis of the written representations received from the directors as on 31st March, 2020 taken on record by the Board of Directors, none ofthe directors is disqualified as on 31st March, 2020 from being appointed as a director in terms of Section 164 (2) of the Act e) 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". f) 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 ourinformation and according to the explanations given to us:

The Company has disclosed the impact of pending litigations on its financial position-Refer Note No. 16and 17 of the financial statement.

Il.

Il. The Company did not have any long-term contracts including derivative contracts for which there were any material foreseeable losses; Ill. There were no amountswhich were required to be transferred to the Investor Education and Protection Fund by the Company.

For KM Swadia & Company Chartered Accountants

(Firm Registration No. (110740w)

Sd/-

CAR K Rajput

Partner

Membership No. 125333

Place : Vadodara

Date: 30thJune, 2020

UDIN :20125333AAAADH4708

Annexure A to Independent Auditors Report

(Referred to paragraph 1 of "Report on Other Legal and Regulatory Requirements" section of our report of even date}

Inrespect of Companys fixed assets:

(a) According to the information and explanations given to us, the Company is maintaining records showing full particulars, including quantitative details and situations ofall the fixedassets.

(b) According to the information and explanations given to us, the all the fixed assets are in possession of the court receiver. Hence during the year physical verification was not conducted by the Management. (Refer note 18 of financial statement) (c) According to the information and explanations given to us, the title deed of immovable property is in the name of the Company.

The company is a trading company; it does not hold any inventories. Thus, clause 3(ii) (a), (b), & (c) of the order regarding physical verification of inventories and maintenance of records is not applicable.

According to the information and explanations given to us, the Company has not granted any loans, secured or unsecured, to companies, Limited Liability Partnerships firms or other parties covered in the register maintained under Section 189 of the Companies Act, 2013. Accordingly, clause

3(iii)(a) to 3(iii)(c) are not applicable to the Company.

According to the information and explanations given to us, the Company has not given/made any loans, investments, guarantees, and security accordingly provisions of section 185 and 186 of the Companies Act, 2013 are not applicable.

The Company has not accepted any public deposits within the meaning of sections 73 to 76 of Companies Act, 2013 and rules framed thereunder; vi. As the Company is not a manufacturing concern, the clause 3(vi) of the Order regarding maintenance of cost records under sub-section (1) of section 148 of the Companies Act, 2013 is not applicable to the Company. vii. (a) In our opinion and according to the information and explanations given to us, Company is generally regular in depositing applicable undisputed statutory dues, including provident fund, employees state insurance, income tax, Goods and Service tax, sales tax, wealth tax, service tax, custom duty, duty of excise, value added tax, cess and any other statutory dues with the appropriate authorities during the year and no such dues are outstanding for more than six months from the date they became payable as on March 31, 2020.

(b) As at March 31, 2020, according to the records of the Company and the information and explanations given to us, disputed dues payable by the Company on account Tax / Sales Wealth Tax/Service Tax / Duty of Custom/Duty of Excise are as under:

ofIncome Tax /

Nature of Dues we Name of Statute dene, en 31,2019 Period Forum
1 The Bombay Sales Tax Act Sales Tax, Interest and Penalty 114,000 1991-92 Before Honorable Tribunal Filed by Company
2 The Bombay Sales Tax Act Sales Tax, Interest and Penalty 2,217,000 1992-93 Before Honorable Tribunal Filed by Company
3 The Bombay Sales Tax Act Sales Tax, Interest and Penalty 2,618,000 1993-94 Before Honorable Tribunal Filed by Company
4 The Bombay Sales Tax Act Sales Tax, Interest and Penalty 918,000 1994-95 Before Honorable Tribunal Filed by Company
5 The Bombay Sales Tax Act Sales Tax, Interest and Penalty 200,000 1995-96 Before Honorable Tribunal Filed by Company
6 The Bombay Sales Tax Act Sales Tax, Interest and Penalty 8,000 1999-00 Before Honorable Tribunal Filed by Company

viii. According to the information and explanationsgiven to us and on the basis of our examinationofthe books of accounts, in our opinion, the Company has not defaulted in repayment of dues to banks, government and any financial institutions. The Company did not have any debentures outstanding as the year end. ix. According to the information and explanations given to us by the management, the Company has not raised any fund by way of public issue orfrom term loan. x. According to the information and explanation given to us, we have not come across any instance of fraud by the Company or any fraud on the its officers or employees, either noticed or reported duringyear, on or by the Company.

Companyby the

xi. To the best of our knowledge and according to the information and explanations given to us, the Company has neither paid nor provided for any managerial remuneration during the year and hence reporting under clause (xi) of the Order is not applicable. xii. According to the information and explanation given to us, in our opinion the Company is not a Nidhi Company as prescribed under section 406 the Act. xiii. According to the information and explanations given to us, all 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 innoteno-: 21 of the financial Statements as required by the applicable accounting standards; xiv. The Company has not made any preferential allotment or private placement ofsharesor fully or partly convertible debentures during the year. xv. According to the information and explanations given to us, the company has not entered into any non-cash transactions with directors or persons connected with him and hence clause 3(xv) of the Order is not applicable to the Company. xvi. The Company is not required to be registered under section 45-IA ofthe Reserve Bank of India Act,1934.

For K M Swadia & Company
Chartered Accountants
(Firm Registration No.110740w)
Sd/-
CAR K Rajput
Partner
Membership No. 125333

Place: Vadodara

Date: 30th June, 2020

UDIN: 20125333AAAADH4708

Annexure B to The Independent Auditors Report of Even Date on The Financial Statements of Shree Narmada Aluminium Industries Limited. Report on the Internal Financial Controlsunder 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 Shree Narmada Aluminium Industries Limited. ("the Company") as of March 31, 2020 in conjunction with the financial statements of the Company for the on that date. our audit of year ended

Managements Responsibility for Internal Financial Controls

The Companys management is responsible for establishing and maintaining internal financial controls based on the criteria established by the Company considering the size of Company and essential components of internal control stated in the Guidance Note on Audit of Internal Financial Controls Over

Financial Reporting issued by the Institute of Chartered Accountants of India ("ICAI"). These responsibilities include the design, implementation and maintenance of adequate internal financial controls that were operating effectively for ensuring the orderly and efficient conduct of its business, including adherence to Companys policies, the safeguarding of its assets, the prevention and detection of frauds and errors, the accuracy and completeness of the accounting records, and the timely preparation of reliable financial information, as required under the Companies Act,2013.

Auditors Responsibility

Our responsibility is to express an opinion on the Companys internal financial controls over financial reporting based on our audit. We conducted our audit in accordance with the Guidance Note on Audit of Internal Financial Controls Over Financial Reporting (the "Guidance Note") and the Standards on Auditing, issued by ICAl and deemed to be prescribed under section 143(10) of the Companies Act, 2013, to the extent applicable to an audit of internal financial controls, both applicable to an audit of Internal Financial Controls and, both issued by the Institute of Chartered Accountants of India. Those

Standards and the Guidance Note require that we comply with ethical requirements and plan and perform the audit to obtain reasonable assurance about whether adequate internal financial controls overfinancial 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 adequacyofthe internal financial controls system over financial reporting and their operating effectiveness.

Our audit of internal financial financial reporting included obtaining an understanding of internal financial controls over financial reporting, controls over

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 judgment, including the assessment auditors ofthe risks of material misstatement ofthe financial statements, whether due to fraud orerror.

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

ACompanys 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 offinancial 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 FinancialControls over Financial Reporting

Becauseofthe inherent limitations of internal financial controls overfinancial 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 becauseofchanges 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 controls system over financial reporting and such internal financial controls were operating effectively as at March 31, 2020, based on the assessment of essential components of internal controls over financial reporting stated in the Guidance Note carried out by the Company and representation to that effect is made availableto us by the Company.

For KM Swadia & Company

Chartered Accountants

FRN (110740W)

Sd/-

CAR K Rajput

Partner

M.No.125333

Place: Vadodara

Date: 30th June, 2020

UDIN: 20125333AAAADH4708