Silver Oak (India) Ltd Directors Report.


Dear Members,

The Directors present the 36th Annual Report of SILVER OAK (INDIA) LIMITED(the Company) along with the audited financial statements for the financial year ended March 31, 2020. The consolidated performance of the Company has been referred to wherever required.

1. Financial results

a) Standalone figures:

Particulars 2019-20 2018-19

(Rs. in Lacs)

Sales and other Income 2.88 46.20
Profit/(Loss) before Depreciation (74.35) (143.60)
Interest 56.43 42.66
Depreciation 6.66 8.82
Profit/(Loss) before Tax (137.44) (195.08)
Less: Exceptional Item 212.43 0
Less: Provision for Tax 0 0
Net Profit/(loss) for the year (349.88) (195.08)
Profit/(Loss) brought forward from previous year (460.47) (265.39)
Balance carried to Balance Sheet (810.35) (460.47)

b) Consolidated figures:

Particulars 2019-20 2018-19
Sales and other Income 112.58 714.33
Profit/(Loss) before Depreciation (295.94) (164.96)
Interest 58.52 42.88
Depreciation 17.06 11.36
Profit/(Loss) before Tax (371.52) (219.20)
Less: Provision for Tax 2.97 14.42
Net Profit/(loss) for the year (374.49) (233.62)

2. COVID-19

In the last month of FY 2020, the COVID-19 pandemic developed rapidly into a global crisis, forcing governments to enforce lock-downs of all economic activity. For the Company, the focus immediately shifted to ensuring the health and well-being of all employees, and on minimizing disruption to services for all our customers.

Although there are uncertainties due to the pandemic and reversal of the positive momentum gained in the last quarter of FY 2020, the strong balance sheet position, best-in-class profitability and inherent resilience of the business model position the Company well to navigate the challenges ahead and gain market share.

3. Dividend

The Company has incurred a Net loss of Rs 374.49 Lacs during the financial year 2019-20 and further in view of the future expansion plan and other business activities your directors have decided not to recommend any dividend for the year ended 31st March, 2020.

4. Going Concern Status

During the year under review, there were no significant or material orders passed by any regulators or court or tribunal, which can impact the going concern status of the company and /or its future operations.

5. Share Capital

The paid up equity share capital of the Company as on 31st March, 2020 stood at Rs. 3,79,02,000/- (Three Crore Seventy Nine Lac Two Thousand Only). During the year under review, the Company has neither issued shares with differential voting rights nor granted any stock options / sweat equity. Mrs. Leela Kalyani, Director of the Company holds 4.88% of shares of the Company as on the date of this report.

During the year under review, no Stock Options were granted, vested or exercised. No Stock Options are in force as on date. Hence, there are no disclosures required to be made pursuant to the applicable requirements of the Securities and Exchange Board of India (Share Based Employee Benefits) Regulations, 2014.

6. Insurance

Your company has taken all the necessary steps to insure its properties and insurable interests, as deemed appropriateand also as required under the various legislative enactments.

7. Transfer to reserves

The Company has not created any reserves during the financial year 2019-20.

8. Companys performance

Your Company has incurred a net loss of Rs. 349.88 Lacs on standalone basis, during the Financial Year 2019-20 as against the loss of Rs. 195.08 Lacs on standalone basis during the Financial Year 2018-19, after taking into account interest, depreciation, prior period adjustments and exceptional items.

9. Human resource development

Attracting, enabling and retaining talent have been the cornerstone of the Human Resource function and the results underscore the important role that human capital plays in critical strategic activities such as growth.

10. Borrowings

The Total term Loan amount of the company on standalone basis as on 31.03.2020 is 7,15,09,393 (Seven Crores Fifteen Lacs Nine Thousand Three hundred Ninety Three Only) as against 4,17,00,977 (Four Crores Seventeen lacs Nine hundred Seventy Seven Only) loan amount as on 31.03.2019.

11. Industry Overview

India is one of the fastest-growing alcohol markets in the world. Rapid increase in urban population, a sizable middle-class population with increasing spending power, and a sound economy are certain significant reasons behind the increase in alcohol consumption in India. The

Indian alcohol industry is segmented into IMFL (Indian made foreign liquor), IMIL (Indian made Indian liquor), wine, beer and imported alcohol. Imported alcohol accounts for a meager share of around 0.8% of the Indian market.

India is the largest consumer of whiskey in the world and constitutes about 60% of the IMFL market. Though India is one of the largest consumers of alcohol in the world owing to its huge population, the per capita alcohol consumption of India is low compared to Western countries. The most popular channel of alcohol sale in India is the liquor store; alcohol consumption is primarily an outdoor activity and supermarkets and malls are present only in Tier I and Tier II cities of India. The trends and patterns of alcohol consumption are changing in the country. With the increasing acceptance of women consuming alcohol, growing popularity of wine and high demand for expensive liquor, the market scenario seems to be optimistic.

12. Business Outlook/ Future Projects

Your company is making continous endeavour to enter into new area of market. The high standard and development will ensure cost reduction and cost control which preliminary affect the bottom line of the company.

13. Directors responsibility statement

Pursuant to Section 134(5) of the Act, the Board of Directors, to the best of its knowledge and ability, confirm that:

i. in the preparation of the annual accounts, the applicable accounting standards have beenfollowed and there are no material departures;

ii. they 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 at the end of the financial year and of the profit of the Company for that period;

iii. they have taken proper and sufficient care for the maintenance of adequate accounting records in accordance with the provisions of the Act for safeguarding the assets of the Company and for preventing and detecting fraud and other irregularities;

iv. they have prepared the annual accounts on a going concern basis;

v. they have laid down internal financial controls to be followed by the Company and such internal financial controls are adequate and operating effectively;

vi. they have devised proper systems to ensure compliance with the provisions of all applicable laws and that such systems are adequate and operating effectively.

Based on the framework of internal financial controls and compliance systems established and maintained by the Company, the work performed by the internal, statutory and secretarial auditors and external consultants, including the audit of internal financialcontrols over financial reporting by the statutory auditors and the reviews performed by management and the relevant board committees, including the audit committee, the Board is of the opinion that the Companys internal financial controls were adequate and effective during FY 2020.

14. Directors and key managerial personnel

Each of the Independent Directors have furnished their declarations of independence, as required pursuant to the provisions of section 149(6) of the Act, stating that he\she meet, the criteria of independence as provided in section 149(6) of the Companies Act, 2013.

Mr. Vivek Chibba (DIN: 06466844) was appointed as an Additional Executive Director and Chief Executive Officer of the Company in the Board Meeting held on 14th August,2020.

Mr. Shirish Jaltare retires by rotation and being eligible, offers himself for re-appointment. A resolution seeking shareholders approval for his re-appointment forms part of the Notice.

Pursuant to the provisions of Section 149 of the Act, the independent directors have submitted declarations that each of them meet the criteria of independence as provided in Section 149(6) of the Act along with Rules framed thereunder and Regulation 16(1)(b) of the SEBI Listing Regulations. There has been no change in the circumstances affecting their status as independent directors of the Company.

During the year under review, the non-executive directors of the Company had no pecuniary relationship or transactions with the Company, other than sitting fees, commission, if any and reimbursement of expenses incurred by them for the purpose of attending meetings of the Board / Committee of the Company.

Pursuant to the provisions of Section 203 of the Act,the Key Managerial Personnel of the Company as on March 31, 2020 are:

1. Mr. Shirish Jaltare (Whole Time Director),

2. Mr. Sunil Khandelwal (Chief Financial Officer),

3. Mr. Vivek Chibba (Chief Executive Officer),

4. Mr. Deepak Meena (Company Secretary and compliance officer) .

15. Profile Of The Directors Seeking Appointment / Reappointment:

As required underSEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, following Directors are liable to retire by rotation and seeking appointment / reappointment at the ensuing Annual General Meeting is annexed to the notice convening 36th Annual General Meeting. Mr. Shirish Jaltare (Whole Time Director) is liable to retire/reappoint in ensuing Annual General Meeting.

16. Number of meetings of the Board

Four meetings of the Board were held during the year under review. For details of meetings of the Board, please refer to the Corporate Governance Report, which is a part of this report.

17. Managerial Remuneration:

Disclosures of the ratio of Remuneration of each director to the median employees remuneration and other details asrequire with respect to Section 197(12) of the Companies Act, 2013 read with Rule 5 (1) of the Companies (Appointmentand remuneration of Managerial Personnel) Rules 2014 are given in the Annexure of the Director Report.

The Detail of remuneration paid to the directors including executive directors of the Company are given in Form MGT9 available on the website of the company at .

18. Board evaluation

The Board of Directors has carried out an annual evaluation of its own performance, board committees and individual directors pursuant to the provisions of the Act and SEBI Listing Regulations. The performance of the Board was evaluated by the Board after seeking inputs from all the directors on the basis of criteria such as the board composition and structure, effectiveness of board processes, information and functioning, etc. The performance of the committees was evaluated by the board after seeking inputs from the committee members on the basis of criteria such as the composition of committees, effectiveness of committee meetings, etc. The above criteria are broadly based on the Guidance Note on Board Evaluation issued by the Securities and Exchange Board of India on January 5, 2017.

In a separate meeting of independent directors, performance of non-independent directors, the Board as a whole and the Chairman of the Company was evaluated, taking into account the views of executive directors and non-executive directors.

The Board and the Nomination and Remuneration Committee reviewed the performance of individual directors on the basis of criteria such as the contribution of the individual director to the board and committee meetings like preparedness on the issues to be discussed, meaningful and constructive contribution and inputs in meetings, etc. At the board meeting that followed the meeting of the independent directors and meeting of Nomination and Remuneration Committee, the performance of the Board, its Committees, and individual directors was also discussed. Performance evaluation of Independent Directors was done by the entire Board, excluding the independent director being evaluated.

19. Policy on directors appointment and remuneration and other details

The contents of Nomination and Remuneration Policy of the Company prepared in accordance with the provisions of Section 178 of the Companies Act, 2013 and Regulation 19 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 are provided in the Corporate Governance Report. The Policy may be referred to at the Companys website at (

20. Audit committee

The details pertaining to the composition of the Audit Committee are included in the Corporate Governance Report, which is a part of this report.

21. StatutoryAuditors

M/s Mahendra Badjatya And Company, Chartered Accountants, Indore, have been appointed as Auditors of the company, to hold office from the conclusion of 33 rd Annual General Meeting till the conclusion of Thirty Eighth Annual General Meeting of the Company.

As reported earlier, in terms of the Companies Amendment Act, 2017 read with Notification S.O. 1833(E) dated7th May 2018 read with The Companies (Audit and Auditors) 2nd Amendment Rules, 2018 alongwith its corrigendumdated 17th May, 2018 delete rules and provisions relating to annual ratification of the appointment of auditor.Now during a single term of 5 years, there are no requirement for ratification of the appointment of auditor.They will be continue as statutory auditors of the company.

22. Secretarial Auditor

According to the provision of section 204 of the Companies Act, 2013 read with Rule 9 of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014, Mr. Varun Bhomia, Company Secretary in Practice, Indore has been appointed by the Board of Directors to conduct the audit of the secretarial records of the company for the year ended 2019-20.

23. Auditors report and Secretarial audit report

The Auditors Report does not contain any qualification. Notes to Accounts and Auditors remarks in their report are self-explanatory and do not call for any further comments.

1. Secretarial Audit Report

In terms of Section 204 of the Act and Rules made there under, Mr. Varun Bhomia, Company Secretary in Practice, Indore has been appointed Secretarial Auditors of the Company. The report of the Secretarial Auditors is enclosed as Annexure VII to this report. The report is selfexplanatory and do not call for any further comments.

2. Secretarial Compliance Report

In terms of SEBI (LODR) 2015 the company have appointed Mr. Varun Bhomia, to issue a compliance report in respect of complaince of various rules, notices, circulars, notification etc. issued by BSE SEBI from time totime.

During the year a company have complied all the circulars, notices, notification issued under various SEBI Act and Regulations, which are applicable for the company. The report is selfexplanatory and do not call for any further comments.

3. Internal Audit & Controls

The Company continues to engage M/s A.B. Doshi & Co., Chartered Accountants, Indore as its Internal Auditor for the Financial year 2019-20. During the year, the Company continued to implement their suggestions and recommendations to improve the control environment. Pursuant to provision of section 138 of the Companiesact, 2013 The Audit Committee of the Board of Directors in consultation with the Internal Auditor formulates the scope, functioning, periodicity and methodologies for conducting the Internal Audit subject to terms and conditions as decided by the Audit Committee.Your company wish to continue to engage M/s A.B. Doshi & Co., Chartered Accountants, Indore, as its Internal Auditor for the financial year 2020-21.

24. Cost Auditor

The Ministry of Corporate Affairs (MCA) vides Notification dated 31st December, 2014 made amendment in the Companies (Cost Records and Audit) Rules, 2014, through Companies (Cost Records and Audit) Amendment Rules, 2014. As per the said amendment rules, our Company is exempted from the requirement to conduct Cost Audit. Therefore, the Company did not appointed Cost Auditor for financial year 2018-19.

25. Risk management

The Company has established a well-defined process of risk management, wherein the identification, analysis andassessment of the various risks, measuring of the probable impact of such risks, formulation of risk mitigation strategy and implementation of the same takes place in a structured manner. Though the various risks associated with the business cannot be eliminated completely, all efforts are made to minimize the impact of such risks on theoperations of the Company. Necessary internal control systems are also put in place by the Company on various activities across the board to ensure that business operations are directed towards attaining the stated organizational objectives with optimum utilization of the resources. Apart from these internal control procedures, a well-defined and established system of internal audit is in operation to independently review and strengthen these control measures,which is carried out by a reputed firm of Chartered Accountants. The Audit Committee of the Company regularly reviews the reports of the internal auditors and recommends actions for further improvement of the internal controls.

26. Vigil Mechanism

The Company has a vigil mechanism named Whistle Bowler Policy to deal with instance of fraud and mismanagement, if any. In staying true to our values of Strength, Performance and Passion and the Company is committed to the high standards of Corporate Governance and stakeholder responsibility. The Policy ensures that strict confidentiality is maintained whilst dealing with concerns an Experts Committee has been constituted which looks into the complaints raised. The Committee reports to the Audit Committee and the Board.

The Vigil Mechanism comprises three policies viz.,

i. the Whistle Blower Policy for Directors & Employees,

ii. Whistle Blower Policy for Vendors and

iii. Whistle Blower Reward & Recognition Policy for Employees.

The constitution of the committee during the financial year under review is as follows:

Name of the Director Category
Mr. Suresh Kejriwal Independent Director
Mr. Prakash Kumar Gadia Independent Director
Mr. Shirish Jaltare Executive Director

27. Particulars of loans, guarantees and investments

During the year under review, the Company has not given any loan or provided guarantees or made any investments as prescribed under Section 186 of the Companies Act, 2013.

28. Transactions with related parties

The Company has entered into transaction with the related party during the financial year 201920 with the related parties referred to in sub-section (1) of section 188 of the Companies Act, 2013 and the Statutory auditors of the company has also verified in its through its Auditors Report that the related party transactions are undertaken at Arms Length Price. Details of the transactions are disclosed in Form AOC 2 as Annexure “G”.

29. Corporate Social Responsibility

Corporate Social Responsibility spending not to be applicable to the Company as the turnover/net worth is below the threshold limit.

30. Extract of annual return

The extract of Annual Return in Form MGT 9 as required under Section 92 (2) of the act, (as amended) read with Rule12 of the Companies ( Management and Administration) Rules 2014 (as amended) is available at the website of theCompany at

31. CEO/CFO Certification:

Certificate obtained from Mr. Shirish Jaltare, Whole-time Director and Mr. Sunil Khandelwal, Chief Financial Officer, pursuant to Regulation 33 of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, for the year under review has been duly placed before the board and a copy of the certificate on the financial statements for the year ended March 31, 2020 is annexed as annexure “D” along with this report.

32. Ratio Of The Remuneration Of Each Director To The Median Remuneration Of The Employees Of The Company:

Pursuant to the provisions of Section 197(12) read with Rule 5 of (Appointment and remuneration of managerial Personnel) Rules, 2014, the details is given in Annexure “I”.

33. Particulars of employees

Pursuant to Section 197 of Companies act, 2013 read with the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014 as amended, Remuneration paid to all the Key Managerial Personnel was in accordance with remuneration Policy adopted by the Company.

Particulars of Employee of the company who are covered by the provisions contained in Rule 5(2) and Rule 5 (3) of Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014 are as under.

Employee throughout the Year : Nil Employee for part of the year : Nil

34. Details Of Significant And Material Orders Passed By The Regulators Or Courts Or Tribunals:

There are no significant and material orders passed by the regulators or courts or tribunals impacting the going concern status and companys operations in future.

35. Prevention Of Insider Trading:

In terms of SEBI (Prohibition of Insider Trading) Regulation, 2018 The Company has revised its Code of Conduct for Prevention of Insider Trading alongwith adoption of Policy for Legitimate purpose with a view to regulate trading insecurities by the Directors and designated employees of the Company. The Code requires pre-clearance for dealing in the Companys shares and prohibits the purchase or sale of Company shares by the Directors and the designated employees while in possession of unpublished price sensitive information in relation to the Company and during the period when the Trading Window is closed. The Board is responsible for implementation of the Code. All Board Directors and the designated employees have confirmed compliance with the Code.

36. Subsidiary Companies:

During the financial year 2019-20, there is no change in the material subsidiary, the Companys investment in M/s APT Infrastructure Private Limited (CIN: U45400DL2007PTC170319), which is a subsidiary to your company stands at 6,00,000 (Six lacs) Equity shares of Rs. 10 (Rupees ten only) each for Rs. 60,00,000/- (Sixty lacs only) and also 7,000 (Seven thousand) convertible debentures for Rs. 1,50,47,083 (One Crore Fifty lacs forty seven thousand and eighty three only).

Statement containing salient features of the financial statement of subsidiary company pursuant to first proviso to sub-section (3) of Section 129 read with Rule 5 of Companies (Accounts) Rules, 2014) has been annexed with this report as “Annexure “K”.

37. Listing Of Equity Shares On Stock Exchanges:

The Companys shares are listed in Bombay Stock Exchange Limited with Security Code 531635 and ISIN INE870J01019.

38. Deposits from public:

The Company has not accepted any deposits from public.

39. Independent Directors Meeting And Familiarization Programme:

In terms of SEBI Regulation, 2015, a meeting of Independent Directors was held in absence of Non-Independent Directors and members of the Management.The Meeting was held inter-alia, with a view to review the performance of non-independent directors and the Board as a whole, review the performance of the Chairperson of the company, taking into account the views of executivedirectors and non-executive directors; and to assess the quality, quantity and timeliness of flow of informationbetween the company management and the Board.The details of Independent Directors Meeting and familiarization program are stated in the Corporate Governance Report.

40.Adequacy Of Internal Financial Control

The Company has in place adequate internal financial control with reference to financial statements. Periodic audit is undertaken on continuous basis covering all the major operations. Reports of the Internal Auditors are reviewed by the management from time to time and desired actions are initiated to strengthen the control and effectiveness ofthe system. During the year, such control was tested and no reportable material weaknesses were observed in the design or operation.

The Internal financial control with reference to financial statement as designed and implemented by the company are adequate. During the year under review, no material or serious observation has been received from the InternalAuditors of the company for inefficiency of such control.

41.Internal Control System And Their Adequacy

The Internal Control System provides for well documented policies/guidelines, authorization and approval procedures.Considering the nature of its business and size of operation, your company through its internal auditor carried out periodic audit based on the plan approved by the audit committee.

The Summary of the Internal Audit observation and the status of the implementation are submitted to the Audit Committee. The status of implementation of the recommendation is reviewed by the Audit Committee on a regular basis and desired action are initiated to strengthen the control and effectiveness of the system. Concerns, if any,reported to the board.

42. Disclosure As Per The Sexual Harassment Of Women At Workplace (Prevention, Prohibition And Redressal) Act, 2013:

The Company has zero tolerance towards sexual harassment at the workplace and has adopted a policy on prevention prohibition and redressal of sexual harassment at workplace in line with the provisions of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and the Rules thereunder.

43. Policies As Per Sebi (Listing Obligations And Disclosure Requirements) Regulations, 2015

Pursuant to requirements of provisions of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 the Company has adopted the following policies currently which are available on the portal of the company (

• Policy for Preservation of Documents.

• Policy for Determination and Disclosure of Material Events.

• Policy on Remuneration of Directors and Key Managerial personal.

• Archival Policy.

• Policy on Material Related Party T ransactions.

• Internal financial control policy.

• T erms and condition of appointment of Independent Directors

• Policy on Sexual harassment of Women at Workplace.

• Code of Insider T rading.

44. Green Initiative

Your Directors would like to draw your attention to section 20 of the Companies act, 2013 read with the Companies(Management and administration) Rules, 2014 as may be amended from time to time which permit the paperless compliances and also service of notice/documents (including annual report) through electronic mode to its shareholders.

Your Directors hereby once again appeal to all those members who have not registered their e mail address so far are requested to register their email address in respect of electronic holding with their concerned Depository participants and /or with the Company.

45. Health Safety And Environment

Your company recognizes the protection and management of environments as one of the highest priorities and every effort is made to conserve and protect the environment. During the year, your company continued its focus in creatingas aesthetic, environment friendly, Industrial habitant in its factory units, mobilizing support generating interest among staff and labors for maintaining hygienic and green surroundings.

46. Business Responsibility Report

The business responsibility reporting as required by regulation 34(2) (f) of the SEBI (listing obligations and disclosure requirements) regulations, 2015 is not applicable to your company for the financial year ending March 31, 2020.

47. Management Discussion And Analysis Report

A) Industry Structure & Development and Outlook

Indian Made Foreign Liquor (IMFL) is “state subject” and as such every State has its own policies in respect of this industry. Madhya Pradesh, the state in which the company operates, has its own policy, both for manufacture as well as for marketing/distribution. The industry is expected to achieve average annual growth and many new players are expected to be stepping into the industry.

B) Opportunities & Threats, Risks & Concerns

The Companys strength is built around domestic marketing network. The growth of the industry provides the necessary opportunities for the company to grow. However, the industry is under constant pressure due to steep competition from unorganized sector and the industrial scenario in the nearby area.

C) Internal Controls and their adequacy

The company has adequate internal control systems, commensurate with the size and operations of the company. The scope of the internal audit is to ensure the control systems established by the management are correctly implemented and to suggest any additional changes required to strengthen the existing systems. These Systems and procedure are reviewed at regular intervals through internal audits, statutory audits and audit committee.

D) Human Resource and Industrial Relations

Industrial relations continue to remain peacefully at the factory and other offices of the Company and all the employees are working with the company for a common objective. Industrial relations of the company were cordial during the year.

48. Code Of Conduct:

The Board of Directors has approved a Code of Conduct which is applicable to the Members of the Board and all employees in the course of day to day business operations of the company. The Company believes in "Zero Tolerance"against bribery, corruption and unethical dealings / behaviors of any form and the Board has laid down the directives to counter such acts. The code laid down by the Board is known as "code of business conduct" which forms anAppendix to the Code. The Code has been posted on the Companys website The Code

laysdown the standard procedure of business conduct which is expected to be followed by the Directors and the designated employees in their business dealings and in particular on matters relating to integrity in the work place, in business practices and in dealing with stakeholders. The Code gives guidance through examples on the expected behavior from an employee in a given situation and the reporting structure. All the Board Members and the Senior Management personnel have confirmed compliance with the Code. All Management Staff were given appropriate training in this regard.

49. Conservation of energy, technology absorption, foreign exchange earnings and outgo Conservation of energy:

Information in respect of Conservation of Energy, Technology Absorption and Foreign Exchange earnings and outgo pursuant to provisions of Section 134 of the Companies Act, 2013 read with the Companies (Accounts) Rules, 2014, for the financial year ended 31.03.2020, is attached as Annexure” A" which forms part of this Report.

50. Appreciation

Your Directors wish to acknowledge the co-operation and assistance extended to the company by the Companys Banker and state and Central Government agencies. Your directors also acknowledge with gratitude the support of the shareholders customers, dealers, agents and suppliers for their continued faith and support in the company and itsmanagement.

51. General

Your Directors state that no disclosure or reporting is required in respect of the following items as there were no transaction on these items during the year under review:

1. No issue of equity shares with differential right as to dividend, voting or otherwise.

2. There is no Employees Stock Option Scheme (ESOS).

3. The Company has not issued any Sweat Equity Shares.


CIN: L11531MP1984PLC002635

Place: Indore (M.P.) Sd/- Sd/-
Date : 05 th September, 2019 Leela Kalyani Shirish Jaltare
SILVER OAK (INDIA) LTD. Director Director
CIN: L11531MP1984PLC002635 DIN:06625369 DIN:00070935