Sir Shadi Lal Enterprises Ltd Auditor Reports

TO

THE MEMBERS OF

SIR SHADI LAL ENTERPRISES LIMITED

Report on the Standalone Ind AS Financial Statements

Opinion

We have audited the accompanying standalone financial statements of Sir Shadi Lal Enterprises Limited ("the Company") which comprises the Balance Sheet as at March 31, 2024, the Statement of Profit and Loss (including Other Comprehensive Income), the Statement of Changes in Equity and the statement of cash flows for the year then ended, and notes to the financial statements, including a summary of significant accounting policies and other explanatory information (here in after referred to as "the 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") 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, 2024, and the loss, and total comprehensive income, changes in equity and its cash flows for the year ended on that date.

Basis for Opinion

We conducted our audit of the standalone financial statements 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 ethical requirements that are relevant to our audit of the standalone financial statements under the provisions of the Companies Act, 2013 and the Rules there under, 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.

Material Uncertainty relating to Going Concern:

Attention is invited to note no-55 of the financial statement wherein it is explained that the company has significant losses which has resulted in erosion of net worth of the company as on 31.03.2024. The reason for improvement explained by the company in the said note -55 that it will continue as a going concern and it will likely to pay its liabilities from expected generation of cash flow, are in our opinion uncertain, due to further increase in negative net worth in current year, which may cast significant doubt about the Companys ability to continue as a going concern.

Key Audit Matters

Key Audit Matters are those matters that, in our professional judgment, were of most significance in our audit of the financial statements of the current period. These matters were addressed in the context of our audit of the financial statements as a whole, and informing our opinion thereon, and we do not provide a separate opinion on these matters. We have determined the matters described below to be the key audit matters to be communicated in our audit report.

Revaluation of Land as described in Note 3.1.1 of the Standalone Ind as Financial Statements.

Key Audit Matters	Auditors Response
- During the year ended 31.03.2024, the company has appointed an independent registered valuer who has relevant valuation experience for valuation of property in India for more then ten years, to determine the fair value of freehold and leasehold Land. As an outcome of this process company recognised increase in gross block of Land for Rs. 37781.55 Lakhs. The said increase of Rs. 37781.55 Lakhs includes the valuation of leasehold Land, the Title deed of which is not in favour of Company; however the same is in the possession of Company. The said surplus due to revaluation of Land consist of freehold Land for Rs. 29393.07 Lakhs and leasehold Land for Rs. 8388.48 Lakhs. The company has recognised this increase in the revaluation reserve and in the statement of other comprehensive income.	- Our Audit procedures included the following:
- Revaluation of land is a Key Audit matter due to its financial magnitude & judgments involved in the assessment of the fair value of land. The judgments relate to the valuation methodologies used and the assumption included in each of those methodologies.	- Read and assessed the companys accounting policies with respect to freehold and leasehold Land (PPE) for compliance with relevant accounting standards.
	- We obtained from Company management the report on valuation of Land performed by an external expert appointed by the Company.
	- We assessed the impact of changes in Key assumption on the valuation analysis prepared by the Company.
	- We obtained details of physical verification of Land from independent valuer and compared the results of physical verification of Land with the listing of land as per the Fixed Assets on test check basis.
	- We assessed whether the change in valution was accounted for by the company within the revaluation reserve and other comprehensive income as applicable.
	- We have placed reliance on the valuation report dated 15.01.2024 of Land produced to us.
	- We assessed the disclosures in the financial statement for compliance with the requirement of Ind AS.
	- The said Revaluation Gain of Rs.37781.55 Lacs on account of revaluation of land includes Rs. 8388.48 Lacs pertaining to leasehold land, the Title Deed of which is not in favour of the company, the said leasehold land has not got revalued during financial year ending on March 31, 2021

Emphasis of Matter

1. The Company has not maintained accounts on "Accrual Basis" to the extent:

i) of 19042.96 Lacs in respect of interest on late payment of cane price, which have not been provided as Stated by the Company in Note No. 35 of the aforesaid Standalone Financial Statements.

ii) As stated in Note No. 36 of the aforesaid Standalone Financial Statements in respect of liability, not determined by the Company, towards bonus relating to financial year 2014-15 in accordance with revised Bonus Notification dated 1st January, 2016

2. As Stated in Note No. 37 to the Standalone Financial Statements, the management has decided not to make any further provision this year for Deferred Tax Assets. The management in view of current year loss and accumulated losses and in absence of virtual certainty about future profitability, has decided not to account for the effect of Deferred Taxation for this year, and continuing to carry forward the Deferred Tax Assets Rs.6881.11 lakhs already accounted for in earlier years.

Other Information

The Companys Board of Directors is responsible for the other information. This Comprises the information included in the Directors report, but does not include the financial statements and our 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 and, in doing so, consider whether the other information is materially inconsistent with the financial statements or our knowledge obtained during the course of our audit or otherwise appears to be materially misstated if based on the work we have performed, we conclude that there is a material misstatement of this other information, we are required to report that fact.

We have nothing to report in this regard.

Responsibilities of Management and those charged with governance for the standalone financial statements

The Companys Board of Directors is responsible for the matters stated in section 134(5) of the Companies Act, 2013 ("the Act") with respect to the preparation of these 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 Ind AS and other accounting principles generally accepted in India, specified under section 133 of the Act read with the Companies(Indian Accounting Standards) Rules,2015,as amended. This responsibility also includes maintenance of adequate accounting records in accordance with the provisions of the Act for safeguarding of the assets of the Company and for preventing and detecting frauds and other irregularities; selection and application of appropriate accounting policies; making judgments and estimates that are reasonable and prudent; and design, implementation and maintenance of accounting policies; 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 standalone financial statement that give a true and fair view and are free from material misstatement, whether due to fraud or error.

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

Those Board of Directors are also responsible for overseeing the companys financial reporting process.

Auditors Responsibilities for the Audit of standalone financial statement

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

As part of an audit in accordance with SAs, we exercise professional judgment and maintain professional skepticism throughout the audit. We also:

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

• 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 Companies Act, 2013, 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 standalone financial statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based on the audit evidence obtained up to the date of our auditors report. However, future events or conditions may cause the Company to cease to continue as a going concern.

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

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

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

From the matters communicated with those charged with governance, we determine those matters that were of most significance in the audit of the standalone financial statements of the current period and are therefore the key audit matters. We describe these matters in our auditors report unless law or regulation precludes public disclosure about the matter or when, in extremely rare circumstances, we determine that a matter should not be communicated in our report because the adverse consequences of doing so would reasonably be expected to outweigh the public interest benefits of such communication.

Report on Other Legal and Regulatory Requirements

1) As required by the Companies (Auditors Report) Order,2020 ("the Order"), issued by the Central Government of India in terms of sub-section(ll) of section 143 of the companies Act, we give in the "Annexure A" a Statement on the matters specified in paragraphs 3 and 4 of the Order.

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 except for the matters stated in the paragraph 2(h)(v) below on reporting under rule 11(g) of the Companies (Audit Auditors) Rules, 2014

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 Indian Accounting Standards specified under Section 133 of the Act,

e) On the basis of the written representations received from the directors as on 31st March, 2024 taken on record by the Board of Directors, none of the directors is disqualified as on 31st March, 2024 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 Control over financial reporting 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) as amended

In our opinion and to the best of our information and according to the explanations given to us , the remuneration paid by the Company to its directors during the year is in accordance with the 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. 34 of the Standalone financial statements);

ii) The Company did not have any long term contracts including derivative contracts for which there were any foreseeable losses; and

iii) There has been no delay in transferring amounts, required to be transferred, to the Investor Education and Protection Fund by the Company.

iv) (a) The Management has represented to us that, to the best of its knowledge and belief, no funds have been advanced or loaned or invested (either from borrowed funds or share premium or any other, sources or kind of funds) by the company to or in any other persons or entities, including foreign entities ("Intermediaries"), with the understanding, whether recorded in writing or otherwise, that the intermediary shall, whether, directly or indirectly lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the company ("Ultimate Beneficiaries") or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries;

(b) The Management has represented to us that, to the best of its knowledge and belief, no funds (which are material either individually or in aggregate) have been received by the company from any person (s) or entities, including foreign entities ("Funding Parties"), with the understanding, whether recorded in writing or otherwise, that the company shall, whether, directly or indirectly, lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the Funding Party ("Ultimate Beneficiaries") or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries;

(c) Based on our audit procedure conducted that are considered reasonable and appropriate in the circumstances, nothing has come to our attention that cause us to believe that the representation under sub-clause (i) and (ii) of Rule 11 (e) as provided under paragraph (2) (h) (iv) (a) & (b) above, contain any material misstatement.

v) The reporting under Rule 11(g) of the Companies (Audit and Auditors) Rules, 2014 is applicable from 1 April 2023.

Based on our examination which included test checks, except for the instances mentioned below, the Company has used accounting softwares for maintaining its books of account, which have a feature of recording audit trail (edit log) facility and the same has operated throughout the year for all relevant transactions recorded in the respective software:

The feature of recording audit trail (edit log) facility was not enabled at the database level to log any direct data changes for the accounting softwares used for maintaining the books of account relating to payroll.

Further, where audit trail (edit log) facility was enabled and operated throughout the year for the respective accounting software, we did not come across any instance of the audit trail feature being tampered with.

	For BASANT RAM & SONS
	Chartered Accountants
	(Firms Registration No. 000569N)
	(R.K. NAYAR)
Place: New Delhi	Partner
Date: 28.05.2024	(Membership No. 087112)
	UDIN: 24087112BKHHOB4865

ANNEXURE ‘A TO THE INDEPENDENT AUDITORS REPORT

Annexure "A" To The Independent Auditors Report of even date of the Standalone Ind AS Financial Statements of Sir Shadi Lal Enterprises Limited for the year ended on 31st March, 2024.

(Referred to in paragraph 1 of the Independent Auditors Report of even date under the heading "Report on Other Legal and Regulatory Requirements" to the members of Sir Shadi Lal Enterprises Limited on the standalone Ind AS financial statements as of and for the year ended March 31, 2024.)

i) In respect of the Companys Property, Plant and Equipment:

a) The Company has maintained proper records showing full particulars, including quantitative details and situation of property, plant and equipment on the basis of available information.

b) The Companys programme of physical verification of all its property, plant and equipment once in three years, is in our opinion, reasonable having regard to the size of the Company and the nature of its property, plant and equipment. Pursuant to such programme, a physical verification of property, plant and equipment has not been carried out during the year.

c) According to the information and explanations given to us and on the basis of our examination of the records of the Company, the title deeds of immovable properties (other than properties where the company is the lessee and the lease agreements are duly executed in favour of the lessee) disclosed in the financial statements are stated to be held in the name of the company, except in the following cases. The original Title Deeds were not produced to us for our verification and we were told that the same are deposited as security with the Bank.

Title Deeds of Immovable property not held in name of the Company.

Relevant line item in the Balance Sheet	Area (in Sqm)	Reason for not being held in the name of the company
Land	2050 & 6150	Lease agreement with Shivalya Thakur -dwara jasanwala on 10.04.1943 for 58 years. Matter is pending in the court.
Land	820	Lease agreement with puran chand & others with company on 25.08.1944 till 30.06.2002.
Land	20707.25	Lease Agreement with SS Light Railway Co. Court order in the companys favour.

Remark: - The cost of above land has been taken nil in the books of the company, however during the year a revalued amount of Rs.8388.48 Lacs has been shown against leasehold land in Fixed Asset.

d) As disclosed in NoteNo. 3.1.1 The company has revalued its Freehold & Leasehold land during the year ended 31st, March, 2024. The revaluation is based on the valuation by a Registered Valuer and the amount of change is more than 10% of the aggregate of the net carrying value of Land.

e) As explained to us that the company does not have any Benami Property, therefore no proceedings have been initiated or are pending against the company for holding any benami property under the Benami Transactions (Prohibition) Act, 1988 (45 of 1988) and rules made there under;

ii). a) During the year, the inventories have been physically verified by the internal auditor on a random basis except material sent for job work and lying with third parties. No discrepancies of 10% or more in the aggregate for each class of inventory were noticed. In our opinion, the frequency of verification is reasonable. The discrepancies noticed on physical verification between the physical stocks and the book records were not material, however, the discrepancies noticed have been properly accounted for in the books of account.

b) Reconciliation of stock statements with stock details submitted to banks were produced to us by the management and were relied upon by us. No material discrepancies were noticed. Refer note no. 41 of the Standalone Annual Financial statements of the company.

iii) The Company has not made investment in, provided any guarantee or security or granted any loans and advances in the nature of loans, secured or unsecured to companies, firms, Limited Liability Partnership or any other parties. Accordingly, the provisions of clause 3 (iii) (a) to (c) of the Order are not applicable to the Company and hence not commented upon.

iv) In our opinion and according to the information and explanations given to us, the company has complied with the provisions of section 185 and I86 of the Companies Act, 2013 with respect to loans, investments, guarantees, and securities.

v) According to the information and explanations given to us, the Company has not accepted any deposit or seemed to be deposit from the public during the year, therefore, the provisions of clause (v) of paragraph 3 of the Order, is not applicable to the Company.

vi) We have broadly reviewed the cost records maintained by the Company pursuant to the Companies (Cost Records and Audit) Rules 2014 prescribed by the Central Government under Section 148 (1) (d) of the Companies Act, 2013 and are of the opinion that, prima facie, the prescribed accounts and cost records have been 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) a) According to the information & explanations given to us and on the basis of our examination of the records of the Company, Except Provident Fund dues amounting to Rs.134.96 lacs there were no undisputed amounts payable in respect of employees State insurance, income-tax, value added tax, wealth-tax, Goods and service-tax, customs duty, excise duty, cess and other material statutory dues were outstanding, at the year end, for a period of more than six months from the date of becoming payable.

b) According to the records of the Company and the information and explanations given to us, there are no amounts in respect of income-tax, value added tax, sales tax, wealth-tax, Goods and service-tax, customs duty, excise duty and cess, which have not been deposited with the appropriate authorities on account of any dispute, other than mentioned in ‘Annexure-1 to this report.

c) Except Provident Fund and Income Tax (TDS), the Company has generally been regular in depositing undisputed statutory dues, including Employees State Insurance, Excise Duty, Cess and other material statutory dues applicable to it with the appropriate authorities.

viii) There were no transactions relating to previously unrecorded income that have been surrendered are disclosed as income during the year in the tax assessments under the Income Tax Act 1961 (143 of 1961).

ix) a) Based on our audit procedure and according to the information and explanation given to us, we are of the opinion that the company has not defaulted in repayment of dues to banks/lenders during the year.

b) The company has not been declared willful defaulter by any bank or financial institution or Government or any government authority.

c) The company has not taken term loan during the year.

d) On and overall examination of the financial statement of the company funds raised on short term basis have prime facie, not been used during the year for long term purposes by the company.

e) The company does not have any subsidiaries/Joint ventures. Hence reporting under clause-3 (ix) (e) of the order is not applicable.

f) The company does not have any subsidiaries/Joint ventures or associate companies, hence reporting under clause-3(ix) (f) of the order is not applicable.

x a) The Company has not raised money by way of initial public offer or further public offer (including debt instrument) during the year, and hence reporting under clause-3(x)(a) of the order is not applicable.

b) During the year the company has not made any preferential allotment or private placement of shares or convertible debentures (fully, partially or optionally convertible) and hence reporting under clause-3(x)(b) of the order is not applicable.

xi a) According to the information and explanation given to us no fraud by the company and no material fraud on the company has been noticed or reported during the year.

b) According to the information and explanation given to us, no report under sub-section (12) of section 143 of the Companies Act has been filed in Form ADT-4 as prescribed under rule 13 of Companies (Audit and Auditors) Rules, 2014 with the Central Government during the year and up to the date of this report.

c) According to the information and explanations given to us, no whistle -blower complaints have been received by the company, therefore not produced to us for consideration.

xii In our opinion and according to the information and explanations given to us, the Company is not a nidhi company and hence reporting under clause (xii) of the order is not applicable

xiii According to the information and explanations given to us and based on our examination of the records of the Company, transactions with the related parties are in compliance with sections 177 and 188 of the Act, 2013 where applicable and details of such transactions have been disclosed in the financial Statements as required by the applicable Accounting Standards.

xiv a) In our opinion, the company has an adequate internal control system commensurate with the size and nature of its business. However, it needs to be further strengthened. b) We have considered the internal audit report for the year under audit, issued to the company during the year, in determining the nature, timing and extent of our audit procedures.

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

xvi In our opinion the Company is not required to be registered under section 45-IA of the Reserve Bank of India Act 1934. Therefore reporting under clause -3(xvi)(a), (b), (c) & (d) of the order is not applicable

xvii The company has incurred cash profits amounting to Rs.212.02 Lakhs during the financial year ending on 31st march 2024 and cash losses Rs. 1823.33 Lakhs in the immediately preceding financial year.

xviii There has been no resignation of statutory auditors during the year.

xix On the basis of the financial ratios, ageing and expected dates of realization of financial assets and payment of financial liabilities, other information accompanying the financial statements, our knowledge of the board of the directors and management plans and based on our examination of the evidence, supporting the assumption and also negative net worth of the company as on 31st March 2024, we are unable to comment on any material uncertainty exists as on the date of the audit report. We cannot comment and give any guarantee or assurance that the company is capable of meeting its liabilities existing at the date of balance sheet as and when they fall due within a period of one year from the balance sheet date.

xx The companys net worth is negative and it has incurred losses during the year , therefore section 135 of the companies act, 2013 is not applicable. Hence reporting under clause-3(xx)(a) & (b) of the order is not applicable.

xxi This clause is not applicable to the company.

	For BASANT RAM & SONS
	Chartered Accountants
	(Firms Registration No. 000569N)
	(R.K. NAYAR)
Place: New Delhi	Partner
Date: 28.05.2024	(Membership No. 087112)

(Annexure-1 as referred to in Para vii (b) of Annexure ‘A to the Auditors Report of even date to the members of Sir Shadi Lal Enterprises Limited on the accounts for the year ended 31st March, 2024).

Following are the particulars of disputed dues (provided/considered contingent liability, as appropriate) as on 31.03.2024 on account of Income-Tax, Sales-Tax, and Excise matters that have not been deposited on account of dispute:-

Name of the Statute	Nature of the Dues	Amount (Rs. In Lacs)	Period to which the Amounts relates	Forum where dispute is pending
Central Excise Act	Duty/Penalty	0.68	2005-2006	Commissioner Appeal, Muzaffarnagar
U.P. Excise Act	Penalty for Low Recovery duty/Penalty	1.85	1991-1992	Excise Commissioner, Allahabad
		55.42	1988-1989	Weight & Measurement Department Saharanpur, High Court, Allahabad Competition Commis- sion of India.
National Company Law Tribunal	Security Deposit for Appeal	37.46	2011-2012
			2012-2013
			2013-2014

We have been informed that apart from above; there are no dues in respect of Wealth-tax, Goods and Service-tax, and Custom Duty which have not been deposited on account of any dispute.

	For BASANT RAM & SONS
	Chartered Accountants
	(Firms Registration No. 000569N)
	(R.K. NAYAR)
Place: New Delhi	Partner
Date: 28.05.2024	(Membership No. 087112)

ANNEXURE ‘B TO THE INDEPENDENT AUDITORS REPORT

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

We have audited the internal financial controls over financial reporting of SIR SHADI LAL ENTERPRISES LIMITED ("the Company") as of March 31, 2024 in conjunction with our audit of the Standalone Ind AS Financial Statements of the Company for the year ended on that date.

Managements Responsibility for Internal Financial Controls

The Board of Directors of the Company is responsible for establishing and maintaining internal financial controls based on the internal control over financial reporting 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, 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 internal financial controls over financial reporting of the Company 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") issued by the Institute of Chartered Accountants of India and the Standards on Auditing prescribed under Section 143(10) of the Companies Act, 2013, to the extent applicable to an audit of internal financial controls. 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 over financial reporting was established and maintained and if such controls operated effectively in all material respects.

Our audit involves performing procedures to obtain audit evidence about the adequacy of the internal financial controls system over financial reporting and their operating effectiveness. Our audit of internal financial controls over financial reporting included obtaining an understanding of internal financial controls over financial reporting, 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 judgment, 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 system over financial reporting.

Meaning of Internal Financial Controls over Financial Reporting

A companys internal financial control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles. A companys internal financial control over financial reporting includes those policies and procedures that:

(1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the company;

(2) provide reasonable assurance that transactions are recorded as necessary to permit preparation 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 unauthorised acquisition, use, or disposition of the companys assets that could have a material effect on the financial statements.

Limitations of Internal Financial Controls Over Financial Reporting

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

Opinion

In our opinion, to the best of our information and according to the explanations given to us, the Company has, in all material respects, an adequate internal financial controls system over financial reporting and such internal financial controls over financial reporting were operating effectively as at March 31, 2024, based on the internal control over financial reporting 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 BASANT RAM & SONS
	Chartered Accountants
	(Firms Registration No. 000569N)
	(R.K. NAYAR)
Place: New Delhi	Partner
Date: 28.05.2024	(Membership No. 087112)