Sintex Industries Ltd Directors Report.

To the Members of Sintex Industries Limited

Report on the Audit of the Standalone Financial Statements

Auditors Opinion

We have audited the accompanying standalone financial statements of Sintex Industries Limited ("the Company"), which comprise the balance sheet as at 31st March 2021, and the statement of Profit and Loss (including Other Comprehensive income), statement of changes in equity and statement of cash flows for the year then ended, on that date and notes to the financial statements, including a summary of significant accounting policies and other explanatory information (hereinafter referred to as "standalone financial statements").

In our opinion and to the best of our information and according to the explanations given to us, the aforesaid standalone financial statements give the information required by the Companies Act, 2013 ("the Act") Act in the manner so required and give a true and fair view in conformity with the Indian Accounting Standards prescribed under section 133 of the Act read with the Companies (Indian Accounting Standards) Rules, 2015, as amended, ("Ind As") and other accounting principles generally accepted in India, of the state of affairs of the Company as at March 31, 2021, Loss, total comprehensive loss, changes in equity and its cash flows for the year ended on that date.

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 (ICAI) together with the independence requirements that are relevant to our audit of the standalone financial statements under the provisions of the Act and the Rules thereunder, and we have fulfilled our other ethical responsibilities in accordance with these requirements and the ICAIs Code of Ethics. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion on the standalone financial statements.

Emphasis of Matter

i. We draw attention to Note 19(i) to the standalone financial statement, with respect to continuing default in payment of dues, most of the lenders have sent notices / letters recalling their loans given and called upon the Company to pay entire dues and other liabilities. Hence in view of the said facts & considering the matter of prudence, whole of the long-term borrowing outstanding as on 31st March 2021 has been classified as current borrowings.

ii. We draw attention to Note 35 to the standalone financial statement, which states that the companys credit rating has been downgraded (Companys credit rating is "BWR D" from Brickwork Ratings India Pvt. Ltd. for Non-Convertible Debentures), which may substantially impair its ability to raise or generate funds to repay its obligations. As mentioned in the same note, The company has defaulted in debt obligation of debentures aggregating to ^ 500.00 Crores for the period April,19 to 6th April,2021 (date of admission in Corporate Insolvency Resolution Process) apart from other credit facilities. However, Company has made provision for interest for the period April,2019 to March,2021.Petition for initiation of Corporate Insolvency Resolution Process under Section 7 of the Insolvency and Bankruptcy Code 2016 filed against the Company by Invesco Asset Management (India) Private Limited (Financial Creditor) for default amount of Rs 15,00,00,000/- (Principal amount) has been admitted against the Company vide Honourable National Company Law Tribunal, Ahmedabad Bench order dated 06.04.2021. Mr. Pinakin Shah (having registration no. IBBI/IPA-002/IP-N00106/2017-18/10248) has been appointed as Interim Resolution Professional by the Honourable National Company Law Tribunal, Ahmedabad Bench under Section 13(1)(c) of the Insolvency and Bankruptcy Code 2016 and moratorium period under Section 14 of the Insolvency and Bankruptcy Code 2016 is declared.

iii. We draw attention to Note 36 to the standalone financial statement, with respect to impairment of assets. As described in the said note, the company has discontinued the manufacturing operations of structured fabrics ( except bleaching facility) at Kalol effective from 1st July, 2019 on account of high cost of operations. The management of the company has assessed that any provision needs to be recognised on account of the impairment of assets in respect of property , plant and equipment of its Textile Division. The higher of Textile Division assets fair value (less cost of disposal) and its value in use as per valuation report obtained from approved valuer as on 30th September,2020 and is found lower than its carrying amount as per books of accounts of the company and hence the Company has recognised impairment loss of Rs 426.64 crores for the year. Therefore, the impairment loss has been shown under "Exceptional Item".

iv. We draw attention to Note 37 to the standalone financial statement, with respect to conversion of Foreign Currency Convertible Bond (FCCB) into equity shares. As mentioned in the said note during the year 31st March, 2021, FCCBs aggregating to USD 7 Million have been converted into 5122874 equity shares resulting in increase in equity share capital by ^ 0.51 crores and security premium by ^ 46.70 crores. There are USD 6.5 Million FCCBs outstanding for conversion as on 31st March, 2021. Further, the company has defaulted in payment of interest amounting to USD 0.46 Million for the period 25th May, 2019 to 25th Nov, 2020.

v. We draw attention to Note 42 to the standalone financial statement, with respect to recognition of deferred tax assets. As stated in the said Note, deferred tax asset has not been recognized in view of losses during the year.

vi. We draw attention to Note 49 to the standalone financial statement, with respect to realization of subsidies aggregating to Rs 210.96 Crores. As per the information and explanations furnished to us, the management is taking necessary actions for realization of these subsidies and as stated in the said Note, management is perusing for recovery of this amount of subsidy.

vii. We draw attention to Note 52 to the standalone financial statement, with respect to confirmation of balances. As stated in the said note Confirmation of balances (other than related party) in respect of amounts due from trade receivables, capital advances given and loans and advances granted as well as for the amounts due to/payables to trade payables have not been obtained and/or received by the company and, therefore, these balances remained unconfirmed. The process of obtaining confirmation from these parties could not be undertaken due to Covid 19, and will be now initiated by the management of the company and adjustments, if any required on reconciliation of balances on receipt of confirmations, shall be made subsequently. However, the management believes that the effect of such adjustments/discrepancies shall not be material.

viii. We draw attention to Note 54 to the standalone financial statement with respect to forensic audit. Further, South Indian Bank Limited, Axis Bank, Karnataka Bank and Punjab & Sind Bank ("Banks") purportedly report NPA account of the Company as Fraud to Reserve Bank of India on the basis of forensic audit report issued by forensic auditor appointed by lead consortium bank.

The Company has clarified that it had not received prior intimation from PNB as to conclusion of fraud in its NPA account and also the Company has not received forensic audit report including basis for declaring the account of the Company as Fraud. The Company is in the process of adopting pro-active steps for enquiry with PNB. Against the reporting by Banks purporting to declare fraud to the Reserve Bank of India, the Honble Delhi High Court on application of the Company granted relief of stay in relation to the impugned action of lenders declaring fraud in the account of the Company to the Reserve Bank of India or any further steps pursuant thereto.

We are not made available with forensic audit report of the forensic auditor and are not aware about the any processes adopted by the company with banks for any enquiry. Further Management is of the view that classification of fraud by forensic auditor is unjust and unfair. We are not affirming the same.

ix. We draw attention to Note 55 to the standalone financial statement regarding nation wide lockdown by the Government of India in view of COVID-19, a pandemic caused by the novel Coronavirus. It is stated in the said note that The Companys operations were impacted in the month of March 2020 due to shutdown of Lunsapur plant following nationwide lockdown by the Government of India in view of COVID-19, a pandemic caused by the novel Coronavirus. The Company is monitoring the situation closely. From 12th April 2020, operations have commenced in a phased manner with enforcement of strict working restrictions. The Company stabilises its operations in spite of COVID-19 challenges. The Company scale up its operations and have been working at 90% capacity comprising of more than 6 lakhs spindles during the end of the financial year. The scale up of operations is subject to substantial volatility in market and risk averseness due to 2nd and 3rd wave of Covid 19 for which company will keep updated.

x. We draw attention to Note 56 to the standalone financial statement, wherein it is mentioned that the Company has outstanding advances of Rs 531.91 crores receivables from Sintex Prefab & Infra Limited. Petition for initiation of Corporate Insolvency Resolution Process under Section 7 of the Insolvency and Bankruptcy Code 2016 filed against Sintex Prefab & Infra Limited by Bank of Baroda (Financial Creditor) has been admitted vide Honourable National Company Law Tribunal, Ahmedabad Bench order dated 24.02.2021. The Company has submitted claims of Rs 531.91 crores to Mr. Chandra Prakash Jain (IRP of Sintex Prefab & Infra Limited) on 16.03.2021.

xi. We draw attention to Note 57 to the standalone financial statement, with respect to insurance claim receivable. The insurance claim receivable includes insurance claim of Rs 23.11 crores of F.Y. 2016-17 is outstanding as on 31st March,2021. The insurance company has repudiated claim pertaining to FY 2016-17. Management of company has filed reply against the same and is hopeful of settling the claims in full. The Company has initiated legal proceedings against the same.

xii. We draw attention to Note 58 to the standalone financial statement, with respect to defaulted in repayment of principal and interest payments. The period and amount of continuing default as on the Balance sheet date are as under:

in Crores)

Name of lenders Principal Interest Period to which it relates
Banks / NBFCS
Punjab National Bank (Including Oriental Bank of Commerce & United Bank of India) 827.07 151.09
Punjab Sind Bank 211.72 39.71
Bank of India 264.73 101.41
Bank of Baroda (Including Dena Bank & Vijaya Bank) 318.18 188.37

May19 to Mar21

Canara Bank (Including Syndicate Bank) 294.39 70.21
Union Bank of India (Including Andra Bank) 53.44 119.33
South Indian Bank 19.83 56.89
Karnataka Bank 7.92 19.73
Central Bank of India 24.90 59.35
IDBI Bank 50.00 16.06
Axis Bank Ltd 82.41 14.51

June19 to Mar21

Canbank Factors Limited 5.54 0.97
The Federal Bank Limited 13.28 2.16
UCO Bank Limited 0.42 0.07
State Bank of India 16.49 47.10 Aug19 to Mar21
Abu Dhabi Commercial Bank - 10.97

Oct19 to Mar21

DZ Bank AG 47.59 7.30
Financial Institution
Export Import Bank of India 169.38 107.54 Jun19 to Mar21
Non Convertible Debentures 483.33 98.60 Jun19 to Mar21

xiii. We draw attention to Note 60 to the standalone financial statement, with respect to events occurring after balance sheet date. As per that note the factory plant situated at Taluka Jafarabad, Lunsapur, Amreli, Gujarat is severely damage due to Cyclone Tauktae on 17th May, 2021 and 18th May, 2021. The expected quantum of loss / damage due to Cyclone Tauktae and estimated impact on the production / operations is under process of determination. The loss / damage is covered by the Insurance and the Company has intimated about the incident of severe damage due to Cyclone Tauktae to the Insurance Company.

Our Opinion is not modified in respect of this matter.

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.

Information Other than the Financial Statements and Auditors Report Thereon

The Companys Board of Directors and IRP are responsible for the other information. The other information comprises the information included in the Boards Report and Annexure to Boards Report, but does not include the financial statements and our auditors report thereon. The other information is expected to be made available to us after the date of this auditors report thereon.

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

In connection with our audit of the financial statements, our responsibility is to read the other information identified above when it becomes available and, in doing so, consider whether the other information is materially inconsistent with the financial statements or our knowledge obtained in the audit, or otherwise appears to be materially misstated.

Managements and Interim Resolution Professionals Responsibility for the Standalone Financial Statement

The Companys Board of Directors and Interim Resolution Professional are responsible for the matters stated in section 134(5) of 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, total comprehensive income, changes in equity and cash flows of the Company in accordance with the accounting principles generally accepted in India. This responsibility also includes maintenance of adequate accounting records in accordance with the provisions of the Act for safeguarding of the assets of the Company and for preventing and detecting frauds and other irregularities; selection and application of appropriate accounting policies; making 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 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 and Interim Resolution Professional are responsible for assessing the Companys ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless management either intends to liquidate the Company or to cease operations, or has no realistic alternative but to do so.

Those Board of Directors and IRP are also responsible for overseeing the Companys financial reporting process.

Auditors Responsibilities for the Audit of the Financial Statements

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 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 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 financial statements, whether due to fraud or error, design and perform audit procedures responsive to those risks, and obtain audit evidence that is sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control.

• Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances. Under section 143(3)(i) of the Act, we are also responsible for expressing our opinion on whether the company has adequate internal financial controls system in place and the operating effectiveness of such controls.

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

• Conclude on the appropriateness of managements use of the going concern basis of accounting and, based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Companys ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditors report to the related disclosures in the financial statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based on the audit evidence obtained up to the date of our auditors report. However, future events or conditions may cause the Company to cease to continue as a going concern.

• Evaluate the overall presentation, structure and content of the financial statements, including the disclosures, and whether the financial statements represent the underlying transactions and events in a manner that achieves fair presentation.

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 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 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.

2. 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, the statement of changes in equity 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 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) On the basis of the written representations received from the directors as on 31st March, 2021 taken on record by the Board of Directors, none of the directors is disqualified as on 31st March, 2021 from being appointed as a director in terms of Section 164 (2) of the Act.

(f) With respect to the adequacy of the internal financial controls with reference to financial statements of the Company and the operating effectiveness of such controls, refer to our separate Report in "Annexure B".

(g) With respect to the other matters to be included in the Auditors Report in accordance with the requirements of section 197(16) of the Act, as amended:

In our opinion and to the best of our information and according to the explanations given to us, no managerial remuneration has been paid by the company to its directors during the year is in accordance with provisions of Section 197 of the Act.

(h) With respect to the other matters to be included in the Auditors Report in accordance with Rule 11 of the Companies (Audit and Auditors) Rules, 2014, as amended in our opinion and to the best of our information and according to the explanations given to us:

i. The Company has disclosed the impact of pending litigations on its financial position in its financial statements - Refer Note no 51 to the standalone financial statements;

ii. Provision has been made in the financial statements, as required under the applicable law or accounting standards, for material foreseeable losses, if any, on long-term contracts including derivative contracts.

iii. There were no amounts which were required to be transferred to the investors education and protection fund by the company.

For, R Choudhary & Associates
Chartered Accountants
Firm Regn. No: 101928W
Place : Ahmedabad K M Chaudhary
Date : 29th June, 2021 (Partner)
UDIN : 21133388AAAAMH9887 M. No.: 133388

ANNEXURE A - to the Independent Auditors Report

Annexure to Independent Auditors Report for the period ended March 2021

(Referred to in Paragraph 1 under the Heading of "Report on Other Legal and Regulatory Requirements" section of our Report of even date)

(i) Fixed Assets

a) The Company has maintained proper records showing full particulars including quantitative details and situation of fixed assets.

b) The Company has a program of physical verification of its property, plant and equipment to cover all the items of property, plant and equipment in a phased manner, which, in our opinion, is reasonable having regard to the size of the Company and the nature of its property, plant and equipment. Pursuant to the program, certain property, plant and equipment were physically verified by the Management during the year. According to the information and explanations given to us, no material discrepancies were noticed on such verification.

c) According to the information and explanations given to us and the title deeds and other records examined by us, we report that the title deeds in respect of all the immovable properties comprising of freehold land and buildings are held in the name of the Company except in respect of freehold lands having aggregate cost of ^ 436.81 Crores, for which documents in favor of the Company are not executed as at end of the year.( Refer Note - 53 to Standalone financial statements)

(ii) Inventories

As explained to us, the inventories, were physically verified during the year by the Management at reasonable intervals and no material discrepancies were noticed on physical verification.

(iii) Loans given

According to Information and explanations given to us, the Company has not granted any Secured or unsecured loan to companies, firms, Limited Liability Partnerships or other parties covered in the register maintained under Section 189 of the Companies Act, 2013. Hence reporting under clause 3 (iii) (a), (b) and (c) does not arise.

(iv) Compliance of Sec. 185 & 186

In our opinion and according to the information and explanations given to us, the company has complied with the provisions of sections 185 & 186 of the companies Act, 2013 in respect of grant of loans, making investments and providing guarantees and securities, as applicable.

(v) Public Deposit

According to Information and explanations given to us, the company has not accepted any deposits from the public during the year and in respect of unclaimed deposits, the company has complied with the provision of section 73 to 76 or any other relevant provisions of the companies Act, 2013.

(vi) Cost Records

The company is maintaining the cost records as specified by the Central Government under sub-section (1) of section 148 of the Companies Act in respect of service carried out by the company. We have broadly reviewed the cost records maintained by the Company pursuant to the Companies (Cost Records and Audit) Rules, 2014, as amended prescribed by the Central Government under sub-section (1) of Section 148 of the Companies Act, 2013 and are of the opinion that, prima facie, the prescribed cost records have been made and maintained. We have, however not made a detailed examination of the cost records with a view to determine whether they are accurate or complete.

(vii) Statutory Dues

According to the information and explanations given to us, in respect of statutory dues:

a) The Company has generally been regular in depositing its undisputed statutory dues including Provident Fund, Income-tax, Goods and Service Tax, Customs duty, cess and other material statutory dues applicable to it to the appropriate authorities.

b) No undisputed amounts payable in respect of the aforesaid dues were outstanding as at March 31, 2021 for a period of more than six months from the date they became payable except ^ 0.09 crore of Provident fund which is pending to be paid as the PAN and/or Aadhar of new joinee were not available so their PF(UAN) was not generated.

c) According to the information and explanations given to us, there are no dues of income tax, sales tax, excise duty, and Goods and Service Tax on account of any dispute, which have not been deposited.

(viii) In our opinion and according to the information and explanations given to us, the company has defaulted in repayment of dues to banks, financial institutions and debenture holders. Lender wise details of defaults in repayment of borrowing (Term Loan & Working Capital) and interest are given below.

(Rs in Crores)

Name of lenders

Principal

Interest

Period to which it relates

Banks / NBFCS

Punjab National Bank (Including Oriental Bank of Commerce & United Bank of India)

827.07

151.09

May19 to Mar21
Punjab Sind Bank

211.72

39.71

Bank of India

264.73

101.41

Bank of Baroda (Including Dena Bank & Vijaya Bank)

318.18

188.37

Canara Bank (Including Syndicate Bank)

294.39

70.21

Union Bank of India (Including Andra Bank)

53.44

119.33

South Indian Bank

19.83

56.89

Karnataka Bank

7.92

19.73

Central Bank of India

24.90

59.35

June19 to Mar21
IDBI Bank

50.00

16.06

Axis Bank Ltd

82.41

14.51

Canbank Factors Limited

5.54

0.97

The Federal Bank Limited

13.28

2.16

UCO Bank Limited

0.42

0.07

State Bank of India

16.49

47.10

Aug19 to Mar21
Abu Dhabi Commercial Bank

-

10.97

Oct19 to Mar21
DZ Bank AG

47.59

7.30

Export Import Bank of India

169.38

107.54

Jun19 to Mar21
Non Convertible Debentures

483.33

98.60

Jun19 to Mar21

(ix) The Company has not raised money by way of initial public offer or further public offer (including debt instrument) any term loans during the period under audit therefore, paragraph 3 (ix) of the order is not applicable to the company.

(x) Based upon the audit procedures performed for the purpose of reporting the true and fair view of the financial statements and as per the information and explanations given by the management, we report that no fraud by the Company or any fraud on the company by its officers or employees has been noticed or reported during the year.

(xi) According to information & explanations given to us, no managerial remuneration has been paid by the company to its directors during the year is in accordance with provisions of Section 197 of the Act read with schedule V to the Act.

(xii) The company is not a Nidhi Company and hence reporting under clause (xii) of the paragraph 3 of the order is not applicable.

(xiii) In our opinion and according to the information and explanations given to us, all the transactions with the related parties are in compliance with section 177 and 188 of the Companies Act, 2013, where applicable, and the details of related party transactions have been disclosed in the standalone financial statements as required by the applicable Indian accounting standards.

(xiv) During the year, company has not made any preferential allotment or private placement of shares or fully or partly convertible debentures. Therefore paragraph 3 (xiv) of the order is not applicable to the company.

(xv) In our opinion and according to the information and explanations given to us, during the year, the company has not entered into any non-cash transactions with its directors or persons connected with him and hence paragraph 3 (xv) of the order is not applicable to the company.

(xvi) In our opinion and according to the information and explanations given to us, company is not required to be registered under section 45-IA of the Reserve Bank of India Act, 1934.

For, R Choudhary & Associates
Chartered Accountants
Firm Regn. No: 101928W
Place : Ahmedabad K M Chaudhary
Date : 29th June, 2021 (Partner)
UDIN : 21133388AAAAMH9887 M. No.: 133388

ANNEXURE B - The Independent Auditors Report

of even date on the Standalone Financial Statements of Sintex Industries Limited.

(Referred to in Paragraph 2(F) under the Heading of "Report on Other Legal and Regulatory Requirements" section of our Report of even date)

Report on the Internal Financial Controls under Clause (i) of Sub-section 3 of Section 143 of the Companies Act, 2013 ("the Act")

We have audited the internal financial controls with reference to Financial Statements of Sintex Industries Limited ("the Company") as of 31 March, 2021 in conjunction with our audit of the standalone financial statements of the Company for the year ended on that date.

Managements Responsibility for Internal Financial Controls

The Companys management is responsible for establishing and maintaining internal financial controls based on, "the internal financial controls with reference to financial statements criteria established by the Company considering the essential components of internal control stated in the Guidance Note on Audit of Internal Financial Controls over Financial Reporting issued by the Institute of Chartered Accountants of India". 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 with reference to financial statements 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 ICAI 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 with reference to financial statements 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 adequacy of the internal financial controls with reference to financial statements and their operating effectiveness. Our audit of internal financial controls with reference to financial statements included obtaining an understanding of internal financial controls with reference to financial statements, assessing the risk that a material weakness exists, and testing and evaluating the design and operating effectiveness of internal control based on the assessed risk. The procedures selected depend on the auditors judgement, including the assessment of the risks of material misstatement of the financial statements, whether due to fraud or error.

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

Meaning of Internal Financial Controls with reference to financial statements

A companys internal financial control with reference to financial statements is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles. A companys internal financial control with reference to financial statements 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 of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the company are being made only in accordance with authorizations of management and directors of the company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the companys assets that could have a material effect on the financial statements.

Inherent Limitations of Internal Financial Controls with reference to Financial Statements

Because of the inherent limitations of internal financial controls with reference to financial statements, including the possibility of collusion or improper management override of controls, material misstatements due to error or fraud may occur and not be detected. Also, projections of any evaluation of the internal financial controls with reference to financial statements to future periods are subject to the risk that the internal financial control with reference to financial statements may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

Opinion

In our opinion, the Company has, in all material respects, an adequate internal financial controls system with reference to financial statements and such internal financial controls with reference to financial statements were operating effectively as at 31 March, 2021, based on, "the internal control with reference to financial statements criteria established by the Company considering the essential components of internal control stated in the Guidance Note on Audit of Internal Financial Controls Over Financial Reporting issued by the Institute of Chartered Accountants of India".

For, R Choudhary & Associates
Chartered Accountants
Firm Regn. No: 101928W
Place : Ahmedabad K M Chaudhary
Date : 29th June, 2021 (Partner)
UDIN : 21133388AAAAMH9887 M. No.: 133388