shree precoated steels ltd Management discussions


To,

The Members,

Shree Precoated Steels Limited

Your Directors are pleased to present the 11th Annual Report on the business and operations of the Company, together with the Audited Financial Statement for the year ended 31 March, 2019.

FINANCIAL HIGHLIGHTS:

(Rs in lakhs)

Key Financial Indicators 2018-2019 2017-2018
Revenue from Operations - -
Other Income 113.90 58.91
Total Income 113.90 58.91
Total Expenditure 126.52 93.89
(Loss)/Profit before Tax (12.62) (34.98)
Tax Expenses - -
(Loss)/Profit after Tax (12.62) (34.98)
Other Comprehensive Income/(Loss) (1.21) 4.10
(Loss) for the year after Comprehensive Income/(Loss) (13.83) (30.88)
Opening balance in Statement of Reserves and Surplus (14574.34) (14543.46)
Amount available for appropriation - -
Less: reduction of share capital and reserves as per NCLT order dated 28th August, 2019 14199.32 -
Closing Balance in the Statement of Reserves & Surplus (388.85) (14574.34)

OPERATIONAL REVIEW:

Your Company posted Net Revenues of 113.90 Lakhs and Net Loss of Rs 13.83 Lakhs for F.Y 201819. The Net Revenues and Net Loss for F.Y 201718 was 58.91 Lakhs and 30.88 Lakhs respectively. Since the Company has incurred a loss, no amount is available for appropriation.

SHARE CAPITAL OF THE COMPANY:

During the year under review, the Company has not issued any shares with differential voting rights nor granted any stock options neither sweat equity.

The Order of Reduction and consolidation of Equity share capital of the company was passed by Honble NCLTMumbai bench on 28th August, 2019. Its appointed date is 1st April,2018 and effective date is 17th October,2019..The shareholders holding 20 Equity shares of 10/-each shall be allotted 1 Equity share of 10/- each and any shareholder entitled to fractional shares shall be distributed the sale proceeds. The Total Paid up Share Capital of the Company is reduce from Rs 82,79,80,420/- to Rs 4,13,99,020 divided into 4139902 Equity shares of Rs 10/- each fully paid.

DIVIDEND:

Your Directors regret their inability to recommend any dividend since the Company has suffered loss during the current financial year.

SUBSIDIARIES & ASSOCIATE COMPANIES:

The Company does not have any Subsidiary or Associate Company.

TRANSFER TO RESERVES:

No amount was transferred to the reserves during the financial year ended 31st March, 2019.

NATURE OF BUSINESS:

The Company is engaged in the activities of Real Estate and trading. During the year under review, there was no change in the nature of business of the Company.

COMPANY’S STATE OF AFFAIRS:

The Companys operations and financial performance is more elaborately covered in the Management Discussion Analysis forming part of this Annual Report.

DEPOSITS:

In terms of Sections 73 and 74 of the Companies Act, 2013 read with the Companies (Acceptance of Deposit) Rules, 2014 during the financial year 201819, your Company has not accepted any deposits from public and as such, no amount on account of principal or interest on public deposits was outstanding as on the date of the Balance Sheet.

FRAUD REPORTING:

During the year under review, no instances of fraud were reported by the Statutory Auditor of the Company under section 143 (12) of the Companies Act, 2013.

RELATED PARTY TRANSACTION:

During the year under review the Company has not entered into any contracts/arrangements/ transactions which would qualify as material in accordance with policy of the Company on materiality of related party transactions or as per the provision of SEBI (Listing Obligation and Disclosure Requirement) Regulations 2015.

The details of transactions with related parties in ordinary business routine as per Indian Accounting Standard (IND AS-24) is set out in Note No.30 to the Financial Statements of the Company.

Your Company has formulated a policy for dealing with related party transactions which is also available on website of the Company at http://www.spsl.com/ downloads/polices/RPT_POLICY-spsl.pdf

DISCLOSURE OF ORDERS PASSED BY REGULATORS OR COURTS OR TRIBUNAL:

Pursuant to order passed by Honble NCLT Mumbai, the Paid up Equity Capital of the Company is reduced from Rs 82,79,80,420/- to 4,13,99,020/- comprising of 41,39,902 no. of shares of 10/- each.

No other significant and material orders have been passed by any Regulator or Court or Tribunal which can have impact on the going concern status and the Companys operations in future.

PARTICULARS OF LOANS, GUARANTEES OR INVESTMENTS:

The company has complied with the provisions of section 185 & 186 of the Act to the extent applicable, with respect to the loans and investments made.

CORPORATE GOVERNANCE:

Our corporate governance practices area reflection of our value system encompassing our culture, policies and relationships with our stakeholders, integrity and transparency are integral to our Corporate Governance practices to ensure that we gain and retain trust of our stakeholders at all times. In compliance with Regulation 34 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, a separate report on Corporate Governance along with a certificate from the Auditors on its compliance forms an integral part of this Annual Report.

SECRETARIAL STANDARDS:

The Secretarial Standards i.e SS1 & SS2 relating to the Meetings of the Board of Directors and General Meetings, respectively have been duly followed by the Company.

BOARD OF DIRECTORS:

The composition of the Board as on 31st March, 2019 consist of 1 (one) Executive Director, 2 (two) NonExecutive Independent Directors and 1 (one) NonExecutive Professional Director.

Change in Composition of Board of Directors:

During the year Mr. Jagdish J. Doshi, ceased to be Non-Executive Independent Director of the Company on 14th August, 2018.

Directors and Key Managerial Personnel:

Mr. Nilesh H. Sarvaiya, Director retires by rotation at the forthcoming Annual General Meeting and being eligible has offered himself for reappointment. Approval of the members is being sought at the ensuing Annual General Meeting for his re-appointment and the requisite details in this connection is contained in the Notice convening the meeting.

The first term of office of Mr. Ambalal C Patel as an Independent Director (Category: Non Executive) expires on 12th May 2019. Pursuant to the recommendation of Nomination and Remuneration

Committee and the approval of Board of Directors in their respective meeting held on 27th March 2019 and 17th May 2019, the Board has recommended re-appointment of Mr. Ambalal C Patel for a second term up to 12th May 2024 (being the age limit of 75 years) as an Independent Director (Category: Non Executive) of the Company.

Further Pursuant to the recommendation of Nomination and Remuneration Committee and the approval of Board of Directors in their respective meeting held on 27th March 2019 and 17th May 2019, the Board has recommended re-appointment of Mrs. Aarti M Ramani for a second term up to 11th August 2024 as an Independent Director (Category: Non Executive) of the Company.

The disclosures required pursuant to Regulation 36 of the SEBI Listing Regulations, and the Secretarial Standard are given in the Notice of AGM, forming part of the Annual Report and Schedule V of the SEBI Listing Regulations are given in the Corporate Governance Report, forming part of the Annual Report. Attention of the Members is also invited to the relevant items in the Notice of the AGM.

Mr. Harsh L. Mehta, Managing Director, Mr. Akshay R. Sharma, Company Secretary contuned to function as Key Mangerial Personnel.

During the year Mr. Harish G. Taparia, Chief Financial Officer (Key Managerial Personnel) of the Company has resigned w.e.f 5th July, 2019 & Mr. Suresh N. Pitale has appointed as a Chief Financial Officer (Key Managerial Personnel) w.e.f 9th August, 2019.

Independent Director’s Declaration:

Pursuant to the provisions of sub-section (7) of Section 149 of the Companies Act, 2013, the Company has received individual declarations from all the Independent Directors confirming that they fulfil the criteria of independence as specified in Section 149(6) of the Companies Act, 2013 read with the Schedules and Rules issued there under as well as Regulation 16 of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015.

Familiarization Program for Independent Director:

In compliance with the requirements of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, the Independent Directors have been familiarized on the Board of the Company by the functional heads of various departments of the Company which includes detailed presentations on the vision and mission of the Company, its operations, business plans, technologies and also future outlook of the entire industry.

Of the familiarization programs extended to the Non-executive & Independent Directors are also disclosed on the Company website from time to time at: (http://www.spsl.com/downloads/familiarisation- of-ID-of-SPSL.pdf)

Pecuniary Relations:

The Company does not pay any remuneration to its Non-Executive / Independent Directors except sitting fees and reimbursement of expenses for attending Meetings of the Board and of its Committees. No commission on the net profit of the Company is paid to any Director. There are no pecuniary relationships or transactions of the Non- Executive Directors vis-avis the Company.

Number of Meetings of the Board:

The Board of Directors of the Company met Four times during the financial year 2018-19. The details of various Board Meetings are provided in the Corporate Governance Report. The gap intervening between two meetings of the board is as prescribed in the Companies Act, 2013, SEBI (Listing obligation and Disclosure Requirement) Regulations, 2015.

Board Committees:

The Company had the following three Committees of the Board during the year 2018-19:

1. Audit Committee;

2. Nomination and Remuneration Committee;

3. Stakeholders Relationship Committee; and

4. Committee of Independent Directors

The composition of each of the above Committees, their respective role and responsibility is as detailed in the Report of Corporate Governance.

Remuneration of Directors, Key Managerial Personnel and particulars of Employees:

The remuneration paid to Directors is in accordance with Nomination and Remuneration Policy formulated in accordance with Section 178 of the Companies Act, 2013 and Regulation 19 of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (including any statutory modification(s) or re- enactment(s) thereof for the time being in force).

The information required under section 197 of the Companies Act,2013 read with Companies (Appointment and Remuneration of Managerial Personnel )Rules, 2014 (including any statutory modification(s) or re-enactment(s) thereof for the time being in force ) in respect of Directors /employees of the Company is set out in the "Annexure I" to this report .

Further information as required as per the provisions of Section 197 of the Companies Act, 2013 read with Rule 5(2) and Rule 5(3) of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014, is appended to this report as "Annexure II".

Nomination and Remuneration Policy:

The Company has formulated and adopted Nomination and Remuneration Policy in accordance with the provisions of Companies Act, 2013 read with Rules issued there under and SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015.

The said Policy of the Company ,inter alia, provides that the Nomination and Remuneration Committee shall formulate the criteria for appointment of Executive, Non-Executive Director, and Independent Directors on the Board of Directors of the Company and persons in Senior Management of the Company, their remuneration including determination of qualifications, positive attributes, independence of Directors and other matters as provided under subsection (3) of section 178 of Companies Act,2013 (including any statutory modification(s) or reenactment (s) thereof for time being in force).

The salient feature of the Policy is set out in the Corporate Governance Report which forms part of this Annual Report. The Policy is also available on the website of the Company at www.spsl.com.

BOARD EVALUATION:

The Company has devised criteria for performance evaluation of Independent Directors, Board/ Committees, and other individual Directors which includes criteria for performance evaluation of Non Executive Director and Executive Director. Performance evaluation has been carried out as per the Nomination & Remuneration Policy.

At the meeting of the Board all the relevant factors that are material for evaluating the performance of

individual Directors, the Board/ Committees were discussed in detail. A structured questionnaire each for evaluation was prepared and recommended to the Board by Nomination & Remuneration Committee for doing the required evaluation after taking into consideration the input received from the Directors covering various aspects of the Boards functioning such as adequacy of the composition of the Board and its Committees, execution and performance of specific duties, obligations and governance etc.

The performance evaluation of the Independent Directors was also carried by the entire Board. The performance evaluation of the Managing Director & Non-Executive Directors was carried out by the independent Directors at its separate meeting held on 19th March, 2019. The Directors expressed their satisfaction with the evaluation process.

DIRECTORS RESPONSIBILITY STATEMENT:

Pursuant to the requirement of clause (c) of subsection (3) of Section 134 of the Companies Act, 2013, your Directors confirm that:

(a) in the preparation of the annual accounts for the year ended March 31, 2019, the applicable accounting standards read with requirements set out under Schedule III to the Companies Act, 2013, have been followed along with proper explanations relating to material departures, wherever applicable.

(b) the Directors have selected such accounting policies and applied them consistently and made judgments and estimates that are reasonable and prudent so as to give a true and fair view of the state of affairs of the Company as at March 31,2019 and of the profit of the Company for the year ended on that date;

(c) the Directors have taken proper and sufficient care for the maintenance of adequate accounting records in accordance with the provisions of the Companies Act, 2013 for safeguarding the assets of the Company and for preventing and detecting fraud and other irregularities;

(d) the Directors have prepared the annual accounts on a ‘going concern basis;

(e) the Directors have laid down internal financial controls to be followed by the Company and that such internal financial controls are adequate and are operating effectively; and

(f) the Directors have devised proper systems to ensure compliance with the provisions of all applicable laws and that such systems are adequate and operating effectively.

AUDIT COMMITTEE:

The Committee of Audit Committee is in alignment with provisions of Section 177 of the Companies Act, 2013 read with Rules issued there under and Regulation 18 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. The members of the Audit Committee are financially literate and have experience in financial management.

The Audit Committee comprises of Mrs. Aarti M. Ramani, Mr. A.C. Patel and Mr. Nilesh Sarvaiya. Mr. Akshay Sharma acts as a Company Secretary to the Audit Committee. During the year under review Mr. Jagdish J. Doshi who was the chairman of the committee expired and his place was taken by Mrs. Aarti Ramani.

All recommendation made by Audit Committee were accepted by the Board of Directors of the Company.

AUDITOR AND AUDITOR’S REPORT:

Statutory Auditor:

M/s. V Parekh & Associates, Chartered Accountants (Firm Registration No.107488W) were appointed as Statutory Auditors of the Company at the 6th AGM till conclusion of 11th Annual General Meeting.

The Auditors report for the financial year ended 31st March, 2019, on financial statements of the Company forms a part of this Annual Report. The Auditors Report for the financial year ended 31st March, 2019 does not contain any qualification, reservation or adverse remark.

The Board has recommended the appointment of M/s. Manesh Mehta & Associates , Chartered Accountants (Firm No. 115832W) as the Statutory Auditors of the Company in their place, for a term of five consecutive years, from the conclusion of the 11th Annual General Meeting of the Company till the conclusion of the 16th Annual General Meeting of the Company, based on the recommendation of the Audit Committee.

Secretarial Auditor:

The Board of Directors of the Company has appointed Mr. Haresh Sanghvi, Practising Company

Secretary as the Secretarial Auditor to conduct an audit of Secretarial records for the financial year 2018-19.

The Company has received consent from Mr. Haresh Sanghvi to act as the auditor for conducting audit of Secretarial records for the financial year ending 31 st March, 2019.

The Secretarial Audit Report along with the Secretarial Compliance Report for the financial year ended 31 st March, 2019 is set out in Annexure III to this Report. The Secretarial Compliance Report contains one observation for the name of the Company not in line with business activities carried out by the company in terms of Regulation 45 of SEBI (Listing Obligation and Disclosure Requirements) Regulations, 2015.

Internal Auditor

Pursuant to section 138(1) of the Companies Act,2013 read with the Companies (Accounts) Rules, 2014, Mr. Hitesh Panchal, a qualified Chartered Accountant is appointed as Internal Auditor of the Company. The Internal Auditor conducts the internal audit of the functions and operations of the Company and reports to the Audit Committee and Board quarterly.

MANAGEMENT DISCUSSION ANALYSIS:

• Market Review :

India was the worlds third-largest steel producer in 2017. The growth in the Indian steel sector has been driven by domestic availability of raw materials such as iron ore and cost-effective labour. Consequently, the steel sector has been a major contributor to Indias manufacturing output.

The Indian steel industry is very modern with state-of-the-art steel mills. It has always strived for continuous modernization and up-gradation of older plants and higher energy efficiency levels.

Indian steel industries are classified into three categories such as major producers, main producers and secondary producers.

• Company Overview:

The Management has rich experience of over four decades in the Steel related business and Real Estate business and has developed and established excellent business relationships in the Industry which can be helpful to the

Company to form a strategic alliance with them in the future. The goodwill and expertise of the Company and Management is the greatest strength.

The Company has currently traded in Development rights and is exploring opportunities in real estate development and redevelopment projects. The company is focusing on projects related to trading of flats, development rights and investment in real estate, if right opportunity exists.

• Opportunities:

India is expected to overtake Japan to become the worlds second largest steel producer soon, and has envisaged achieving 300 MT of annual steel production capacity by 2030.Steel consumption is expected to grow 5.7 per cent year-on-year to 92.1 MT in 2018.

India is expected to become the second largest steel producer in the world by 2018, based on increased capacity addition in anticipation of upcoming demand, and the new steel policy, that has been approved by the Union Cabinet in May 2017, is expected to boost Indias steel production.Huge scope for growth is offered by Indias comparatively low per capita steel consumption and the expected rise in consumption due to increased infrastructure construction and the thriving automobile and railways sectors.

• Challenge:

While the management of your Company is confident of creating and exploiting the opportunities, it also finds the following challenges in Steel and Real Estate Industry as followed:

1. Regulatory Framework :The need to have a regulatory framework Authority in centre arose in 2015 .The RERA Act,is now expected to bring transparency in the sector .This will also help check delay in delayed possessions and unfair practices;

2. Lending Rate: With the rate of interest being high and unchanged for a long period of time and also cost of living increasing, not many buyers were able to take the step ahead and own a house.

3. Slow approvals: Streamlining the approval process is another issue faced by the Authorities.Delayed approval continue to pose lot of challenges for the developer community .Delays cost increase in prices,loss of confidence of investors and more pilation of stock.Single Window Clearance is long awaited and much anticipated for ease of Industry.

4. Land cost : In order to implement affordable housing for all, Government should offer land at subsidized rates. Further, the success of "Housing for ALL by 2022 "requires a close coordination between Government and Private bodies .

5. Increased cost of finance: The overall sentiment remain subdued due to lack of Investment support in the market. Insufficient funds posed a tough challenge for the developers.

EXTRACT OF ANNUAL RETURN:

The details forming part of the extract of the Annual Return in form MGT-9 is annexed herewith as Annexure IV.

CORPORATE SOCIAL RESPONSIBILITY:

The company does not have net profits in any financial year as per Section 135 of the Companies Act, 2013. Hence the Company is not required to undertake any activity under CSR rules. The details are given in Annexure V.

MATERIAL CHANGES AFFECTING THE FINANCIAL POSITION OF COMPANY:

Post conclusion of Financial year, the Honble NCLT, Mumbai Bench passed the Order of Capital Reduction and Consolidation having appointed date as 1st April, 2018 and effective date as 17th October, 2019. On account of capital reduction the Paid up capital of the Company has been reduced to 4,13,99,020/- comprising of 41,39,902 no. of shares of 10/- each. Pursuant to Order of Capital Reduction on every 20 Equity shares of 10/- each ,1 Equity of 10/- each will be allotted. The shareholders who are entitled to Fractional Shares shall be distributed sale proceeds of Fractional shares.

During the year Mr. Harish G. Taparia, Chief Financial Officer (Key Managerial Personnel) of the Company has resigned w.e.f 5th July, 2019 & Mr. Suresh N.

Pitale has appointed as a Chief Financial Officer (Key Managerial Personnel) w.e.f 9th August, 2019.

HUMAN RELATIONS AND INDUSTRIAL RELATIONS:

Your Company firmly believes that employees are most valuable assets and Key players of business success and sustained growth. The Company continued to conduct various employee benefit, recreational and team building programs to enhance employee skills, motivation as also to foster team spirit.

INTERNAL FINANCIAL CONTROL SYSTEMS AND THEIR ADEQUACY:

Internal Financial Controls are an integrated part of the risk Management process, addressing financial and financial reporting risks. The internal financial controls have been documented, digitized and embedded in the business processes.

Assurance on the effectiveness of the internal financial controls is obtained through management reviews, control self-assessment, continuous monitoring by functional expert as well as testing of the internal financial control system by the internal auditors during the course of their audit. We believe that these systems provide reasonable assurance that our internal financial controls are designed effectively and are operating as intended.

VIGIL MECHANISM:

A "Vigil Mechanism Policy" for Directors and employees of the Company is constituted, to provide a mechanism which ensures adequate safeguards to employees and Directors from any victimization on rising of concerns of any violations of legal or regulatory requirements, incorrect or misrepresentation of any, financial statements and reports, etc. The policy for Vigil Mechanism is also placed on the website of the company under http:// www.spsl.com/downloads/polices/Whistle%20 Blower%20Policy.pdf

CONSERVATION OF ENERGY & TECHNOLOGY ABSORPTION:

The information on conservation of energy, technology and foreign exchange earnings and outgo as stipulated in Section 134(3)(m) of the

Companies Act,2013 and rules framed there under is enclosed in Annexure VI.

GREEN INITIATIVE:

Your Company has adopted green initiative to minimize the impact on the environment. The Company has been circulating the copy of the Annual Report in electronic format to all those members whose email addresses are available with the Company. Your Company appeals other Members also to register themselves for receiving Report in electronic form.

RISK MANAGEMENT:

Your Company has an elaborate risk Management procedure and adopted a systematic approach to mitigate risk associated with accomplishment of objectives, operations, revenues and regulations. Your Company believes that this would ensure mitigating steps proactively and help to achieve stated objectives.

GENERAL DISCLOSURE

Your Directors state that no disclosure or reporting is required in respect of the following items as there were no transactions on these items during the year under review or the same is not applicable to the company:

1. Issue of equity shares with differential rights as to dividend, voting or otherwise.

2. Issue of shares (sweat equity shares) to employees of the Company under ESOS.

3. Employee stock option scheme or provision of money for the purchase of its own shares by employees/ Directors or by trustees for the benefit of employees/Directors;

4. Buy Back of shares of the Company.

5. Issue of Bonus Shares by the Company.

6. Preferential allotment or qualified institutional placement during the financial year 2018-19.

7. Maintenance of Cost Records as per Rule 8 (5) (ix) of The Companies (Accounts) Rules, 2014 and Section 148(1) of Companies Act, 2013.

8. Your Directors further state that your company has constituted an Internal Complaint Committee

pursuant to provisions of Sexual Harassment of Woman at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and during the year under review, there were no cases filed thereunder.

ACKNOWLEDGEMENT:

The Board of Directors wishes to express its gratitude and record its sincere appreciation for the commitment and dedicated efforts put in by all the employees. Your Directors take this opportunity to express their grateful appreciation for the encouragement, co-operation and support received by the Company from the Central and State Government, local authorities, bankers, customers, suppliers and business associates. The directors are thankful to the shareholders for their continued

support and the confidence reposed in the Company and its management.

By Order of the Board of Directors
For Shree Precoated Steels Limited
Ambalal C Patel
Place : Mumbai Chairman
Date : 24th October, 2019 DIN: 00037870

 

CIN: L70109MH2007PLC174206
Registered Office:
1, Ground Floor, "Citi Mall",
New Link Road, Andheri (W),
Mumbai - 400 053, Maharashtra,
Tel.: +91-7208182677,
Email Id: spsl.investors@gmail.com
Website: www.spsl.com

Annexure I

Details of Remuneration as per Section 197 (12) (1) of Companies Act, 2013:

(I) The ratio of the remuneration of each director to the median remuneration of the employees of the company for the financial year :-

Sr. No. Name of Director Ratio of remuneration to the Median remuneration of the employees
1 Harsh L. Mehta (100)

(II) The percentage increase in remuneration of each director, Chief Financial Officer and Company Secretary, if any, in the financial year 2018-19:-

Sr. No. Name of Director/KMP

% increase over last FY 2018-19

1 Harsh L. Mehta 15%
2 Harish G. Taparia 18%
3 Akshay R. Sharma 18%

(III) The percentage increase in the median remuneration of employees in the financial year 2018-19 :- 15%

(IV) The number of permanent employees on the rolls of company as on 31st March, 2019 :- 4

(V) average percentile increase already made in the salaries of employees other than the managerial personnel in the last financial year and its comparison with the percentile increase in the managerial remuneration and justification thereof and point out if there are any exceptional circumstances for increase in the managerial remuneration :- on an Average between 15% to 18%.

We hereby confirm that the remuneration paid is as per the remuenration policy recommended by the Nomination and Remuneration Committee of the Company and as adopted by the Company.

Mr. Ambalal C. Patel
Place: Mumbai (Chairman)
Date: 24th October, 2019 DIN:00037870

Annexure II

Information as required under Rule 5(2) of the Companies (Appointment and Remuneration of Managerial

Personnel) Rules, 2014:

(I) The names of top ten employees in terms of remuneration drawn for FY 2018-19:- NIL

(a) Name of the employees who were employed throughout the FY 2018-19 and were in receipt of remuneration in FY 2018-19, in the aggregate, was not less than one crore and two lakh rupees :-NIL

(b) Name of the employees who were employed for a part of FY 2018-19 and were in receipt of remuneration in any part of FY 2018-19, in the aggregate, was not less than eight lakh and fifty thousand rupees per month:-NIL

(c) Name of employees who were employed throughout the FY 2018-19 or part thereof, were in receipt of remuneration in excess of remuneration drawn by managing Diretor or Whole-Time Director or Manager and holds by himself or along with his spouse and dependent children, not less than two percent of the equity shares of the company:- NIL