Steel Authority of India Ltd Auditor Reports

To the Members of Steel Authority of India Limited

Report on the Audit of the Standalone Financial Statements Quali_ed Opinion

1. We have audited the accompanying standalone _nancial statements of Steel Authority of India Limited (‘the Company), which comprise the Balance Sheet as at 31 March 2025, the Statement of Pro_t and Loss (including Other Comprehensive Income), the Statement of Cash Flow and the Statement of Changes in Equity for the year then ended, and notes to the standalone _nancial statements, including material accounting policy information and other explanatory information, in which are included the returns for the year ended on that date audited by the branch auditors of the Companys branches/units/marketing regions as listed in Appendix 1.

2. In our opinion and to the best of our information and according to the explanations given to us, and based on the consideration of the reports of the branch auditors as referred to in paragraph 17 below, except for the effects of the matters described in the Basis for Quali_ed Opinion section of our report, the aforesaid standalone _nancial 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 (‘Ind AS) speci_ed under section 133 of the Act read with the Companies (Indian Accounting Standards) Rules, 2015 and other accounting principles generally accepted in India, of the state of a_airs of the Company as at 31 March 2025, and its pro_t (including other comprehensive income), its cash _ows and the changes in equity for the year ended on that date.

Basis for Quali_ed Opinion

3 a) As referred in note 47.2 (a) to the accompanying standalone _nancial statements, the constitutional validity of the Entry Tax Act has been upheld by the Honble Supreme Court and the matters relating to levy of entry tax are now pending before Regular Benches of the High Court. Pending decision by the Honble High Court of Jharkhand, the management is of the view that no adjustment is required in the accompanying standalone _nancial statements of the Company for the disputed entry tax demand in Jharkhand state amounting to _ 105.13 crore as on 31 March 2025. However, in the absence of su_cient appropriate evidence to support the managements view, we are of the opinion that a provision for entry tax liability should be recognised in the standalone _nancial statements.

The Nine Judge Bench of the Honble Supreme court, vide its order dated_ 11th November, 2016, upheld the Constitutional validity of the Entry Tax legislations passed by the various States. However, the Bench directed that certain other matters raised by the Petitioner, such as matter relating to Entry Tax amounting to _105.13 crore on goods entering into the local area of Jharkhand from other States, etc. may be determined by regular benches hearing the matters. However, pending decision by the Courts, the disputed Entry Tax liabilities of _105.13 crore have been treated by the Company as Contingent Liability.

3 b) As referred in Note 47.2 (b) to the accompanying standalone _nancial statements, the Company has accounted for _344.75 crore refundable by Damodar Valley Corporation (DVC) pursuant to the tari_ order of Jharkhand State Electricity Regulatory Commission (JSERC) dated 10th December, 2024, which follows the directions of the Appellate Tribunal for Electricity (APTEL). The refund which is to be adjusted in 24 equal monthly instalments in the power bills has commenced from January 2025. As per the communication from DVC, the total refund amount of _344.75 crore includes _175.82 crore towards principal and _168.93 crore towards interest. Management is of the view that APTEL has still not issued _nal orders, as such JSERC tari_ orders may still be subject to change due to the outcome of ongoing legal case pending before APTEL. However, the Company has adjusted the entire refund amount, including interest, against the total advance amount appearing in the books. This is not in compliance with the requirements of Ind AS 109, which require application of the E_ective Interest Method and recognition of interest income separately in the Standalone Statement of Pro_t and Loss.

The Company continues to carry an amount of _448.03 crore (_216.87 crore shown in Other Current Asset, _132.09 crore shown in Other Current Financial Asset and _99.07 crore shown in Other Non-Current Financial Asset) as advance paid to DVC for the period from FY 2012–13 to FY 2016–17. The said amount is not under any legal or regulatory dispute, and management has not provided su_cient appropriate audit evidence demonstrating the basis for its continued recoverability. In our opinion, the amount should have been provided for in the standalone _nancial statements for the year ended 31st March, 2025. Had the aforesaid matters been appropriately accounted for, the interest component embedded in the refund instalments would have been recognized as income as per Ind AS 109, resulting in a lower loss and higher equity for the year. Further, advances aggregating _448.03 crore should have been provided for, which would have resulted in a decrease in current assets, an increase in the loss, and a corresponding reduction in equity as at 31st March, 2025.

Impact of all the above quali_cations on the accompanying standalone _nancial statements for the year ended 31 March 2025 is as under:

Our audit report on the standalone _nancial statements of the company for the year ended 31 March 2024 was also modi_ed in respect of above matters.

4 We conducted our audit in accordance with the Standards on Auditing speci_ed under section 143(10) of the Act. Our responsibilities under those standards are further described in the Auditors Responsibilities for the Audit of the Standalone 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 _nancial statements under the provisions of the Act and the rules thereunder, and we have ful_lled our other ethical responsibilities in accordance with these requirements and the Code of Ethics. We believe that the audit evidence we have obtained together with the audit evidence obtained by the branch auditors, in terms of their reports referred to in paragraph 17 of the Other Matter section below is su_cient and appropriate to provide a basis for our quali_ed opinion.

On the basis of this order, DVC has communicated to BSL regarding refund of total amount of _344.75 Crore. DVC started refunding the amount through adjustment in the power bill from January 2025 onward to be completed in 24 equal monthly instalments.

The amount of _ 587.72 crores paid to DVC retained as advance in the books of accounts has now been adjusted with the refundable amount of _ 344.75 Crores. The monthly instalment of _ 12.82 crores received for the period Jan 2025 to Mar 2025 has been accounted as deduction to the total receivable amount. Further, _ 50 crore advance, and liability of _ 76.10 crore kept in books of accounts related to that period has also been adjusted with the total advance amount of _587.72 crore. After consideration of the above amounts, the net advance with M/s DVC of _216.87 crore has been treated as contingent liability. In addition, the claims receivable from M/s DVC is _306.29 crore. The above disputed demands stated at (3a) and (3b), contested on valid and bona_de grounds, have been treated as contingent liabilities as these are not probable that present obligations exist as on 31st March, 2025. Therefore, there is no adverse impact on Pro_t for the year.

Emphasis of Matters

5. We draw attention to the following: a) Note 47.4 to the accompanying standalone _nancial statements, wherein the Company has disclosed a demand of _1905.52 crores raised by the Water Resources Department, Government of Jharkhand (including interest and penalty) towards revised water charges for industrial use from Tenu Ghat dam, as a contingent liability. The said demand arises pursuant to Noti_cation No. 272 & 275 dated April 1, 2011, and a subsequent Noti_cation No. 2/PMC/Jalapurti-175/2007-30 dated January 17, 2023. Although the Company had initially obtained interim relief through a writ petition which has been disposed of and the challenge to the noti_cation has been dismissed by the Single Bench of Honble Jharkhand High Court. The Company has preferred an appeal before the Division Bench, which is pending as on the reporting date. Further, the Company has commenced payment of the entire amount as billed by the Water Resources Department from February 2025 onwards. This matter has been considered as a contingent liability by plant as on March 31, 2025. b) Note 49.2 to the accompanying standalone _nancial statements, which describes that the revenue from operations include sales to government agencies aggregating to _ 9,496.05 crore for the year ended 31st March 2025 (cumulative upto 31st March 2025 of _ 18,143.43 crore) which is recognized on the basis of provisional prices as per the terms if sales with such Government agencies. c) Note 49.10 to the accompanying standalone _nancial statements, wherein the Company has recognised sub-grade iron ore _nes inventory amounting to _ 3,867.41 crores (40.22 Million Tonnes) as at 31st March, 2025, of which inventory amounting to _ 1,195.05 crores (12.34 Million Tonnes) is lying at the Topailore lease as per the latest drone survey report. The Company continues to carry such inventory at net realisable value, based on the average selling price of similar grade _nes declared by Indian Bureau of Mines (IBM), adjusted for estimated selling expenses. However, the Company is yet to receive the necessary dispatch permission from the relevant authority for the Topailore lease, and no alternate arrangements for disposal or internal consumption are presently available. d) Note 49.14 to the accompanying standalone _nancial statement, regarding suspension of certain o_cers and employees of the Company in the previous year and its subsequent revocation basis directions from the Ministry of Steel, Government of India. The matter is pending investigation by external investigative agencies on aspects relating to policy/pricing decisions of the Company as per directions of the Lokpal of India vide its order dated 10 January 2024. In view of the management, basis their internal assessment, the matter is not likely to have a material impact on the operations of the Company and/or these _nancial results. e) Note 49.15 of the accompanying standalone _nancial statements, which describes that a claim of _3.60 crores has been recognized in the books of accounts in relation to irregular transactions. Out of this, an amount of _0.45 crores has been recovered, and e_orts are ongoing to recover the balance of _3.15 crores. Pending recovery, a provision of _3.15 crores has been made in the books of accounts. Our opinion is not modi_ed in respect of these matters.

Key Audit Matters

6. Key audit matters are those matters that, in our professional judgment, and based on the consideration of the reports of the branch auditors as referred to paragraph 17 below, were of most signi_cance in our audit of the standalone _nancial statements of the current period. These matters were addressed in the context of our audit of the standalone _nancial statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters.

7 In addition to the matters described in the Basis for Quali_ed Opinion, we have determined the matters described below to be the key audit matters to be communicated in our report.

Information other than the Standalone Financial Statements and Auditors Report thereon

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

Our opinion on the standalone _nancial statements does not cover the other information and we will not express any form of assurance conclusion thereon. In connection with our audit of the standalone _nancial statements, our responsibility is to read the other information identi_ed above when it becomes available and, in doing so, consider whether the other information is materially inconsistent with the standalone _nancial statements or our knowledge obtained in the audit or otherwise appears to be materially misstated.

When we read the Annual Report, if we conclude that there is a material misstatement therein, we are required to communicate the matter to those charged with governance.

Responsibilities of Management and Those Charged with Governance for the Standalone Financial Statements

9 The accompanying standalone _nancial statements have been approved by the Companys Board of Directors. The Companys Board of Directors are responsible for the matters stated in section 134(5) of the Act with respect to the preparation and presentation of these standalone _nancial statements that give a true and fair view of the _nancial position, _nancial performance including other comprehensive income, changes in equity and cash _ows of the Company in accordance with the Ind AS speci_ed under section 133 of the Act and other 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 _nancial controls, that were operating e_ectively for ensuring the accuracy and completeness of the accounting records, relevant to the preparation and presentation of the standalone _nancial statements that give a true and fair view and are free from material misstatement, whether due to fraud or error.

10 In preparing the standalone _nancial statements, the Board of Directors 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 the Board of Directors either intends to liquidate the Company or to cease operations, or has no realistic alternative but to do so.

11 The Board of Directors are also responsible for overseeing the Companys _nancial reporting process.

Auditors Responsibilities for the Audit of the Standalone Financial Statements

12 Our objectives are to obtain reasonable assurance about whether the standalone _nancial 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 Standards on Auditing 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 in_uence the economic decisions of users taken on the basis of these standalone _nancial statements.

13 As part of an audit in accordance with Standards on Auditing, speci_ed under section 143(10) of the Act we exercise professional judgment and maintain professional skepticism throughout the audit. We also: Identify and assess the risks of material misstatement of the standalone _nancial statements, whether due to fraud or error, design and perform audit procedures responsive to those risks, and obtain audit evidence that is su_cient 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 _nancial controls with reference to standalone _nancial statements in place and the operating e_ectiveness 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 Board of Directors 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 signi_cant 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 _nancial 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 _nancial statements, including the disclosures, and whether the standalone _nancial statements represent the underlying transactions and events in a manner that achieves fair presentation; and Obtain su_cient appropriate audit evidence regarding the _nancial statements/ _nancial information of the Company and its branches/units/marketing regions or the business activities within the Company to express an opinion on the standalone _nancial statements. We are responsible for the direction, supervision and performance of the audit of standalone _nancial statements of the Company and such branches/units/marketing regions included in the standalone _nancial statements, of which we are the independent auditors. For the other branches/ units/marketing regions included in the standalone _nancial statements, which have been audited by the branch auditors, such branch auditors remain responsible for the direction, supervision and performance of the audits carried out by them. We remain solely responsible for our audit opinion.

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

15 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.

16 From the matters communicated with those charged with governance, we determine those matters that were of most signi_cance in the audit of the standalone _nancial 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 bene_ts of such communication.

Other Matter

17 We did not audit the annual _nancial statements/_nancial information of 09 branches/units/marketing regions included in the standalone _nancial statements of the Company whose annual _nancial statements/_nancial information re_ects total assets of _ 52,214.50 crore as at 31 March 2025, and the total revenues of

_ 38,643.44 crore, total net loss after tax of _ 34.62 crore, total comprehensive loss of _ 13.22 crore, and cash out_ow (net) of _ 6.15 crore, respectively, for the year ended on that date, as considered in the standalone _nancial statements. These annual _nancial statements/_nancial information have been audited by the branch auditors whose reports have been furnished to us by the management, and our opinion on the standalone _nancial statements, in so far as it relates to the amounts and disclosures included in respect of branches/units/marketing regions, and our report in terms of sub-section (3) of section 143 of the Act in so far as it relates to the aforesaid branches, is based solely on the report of such branch auditors.

18 We draw attention to the fact that during the year ended 31st March 2025, the Company was not in compliance with the requirements of Section 149, 177, and 178 of the Companies Act, 2013, read with Regulations 17, 18, and 19 read with Schedule II of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, relating to the composition of the Board of Directors and its committees. The Board of Directors consisted of 11 members, of which only 3 are independent directors, which is less than the prescribed minimum of one-third as per Section 149(4) of The Companies Act, 2013. During the year, the Company did not had a woman director as well as 3 other independent directors on the Board but until April 2025. Consequently, the Audit Committee and the Nomination and Remuneration Committee were also not constituted in accordance with the above-mentioned applicable provisions during the _nancial year. The standalone _nancial results for the year ended 31st March 2025, as stated in Note 1, were approved by the Board on the recommendation of the Audit Committee.

Our opinion above on the standalone _nancial statements, and our report on other legal and regulatory requirements below, are not modi_ed in respect of the above matters with respect to our reliance on the work done by and the reports of the branch auditors.

19 The standalone _nancial statements of the Company for the year ended 31 March 2024 were audited jointly by the predecessor auditors, M/s Walker Chandiok & Co. LLP, M/s J N Gupta & Co. LLP, M/s SPARK & Associates Chartered Accountants LLP and M/s Vinod Singhal & Co. LLP, who have expressed a quali_ed opinion on those standalone _nancial statements vide their audit report dated 20 May 2024.

Steel Authority of India Limited (SAIL) being a Government Company, Directors (including Independent Directors) are appointed based on the nomination by Government of India. The status of the vacancies in various positions in the Board and the consequence of the same for non –compliance with request for _lling up the vacancies in the positions of the Executive Directors and Independent Directors was pursued by the Company with the Administrative Ministry vide our letter dated 21.03.2025, 30.10.2024, 08.04.2024 and 22.03.2024. The same was also taken-up with the Administrative Ministry and DPE earlier also. The Board has been regularly kept informed in this regard.

Report on Other Legal and Regulatory Requirements

20 Based on our audit, and on the consideration of the reports of the branch auditors as referred to in paragraph 17 above, we report that the provisions of section 197 read with Schedule V to the Act are not applicable to the Company since the Company is a Government company as de_ned under section 2(45) of the Act. Accordingly, reporting under section 197(16) is not applicable.

21 As required by the Companies (Auditors Report) Order, 2020 (‘the Order) issued by the Central Government of India in terms of section 143(11) of the Act we give in the Annexure I, a statement on the matters speci_ed in paragraphs 3 and 4 of the Order, to the extent applicable.

22 Further to our comments in Annexure I, as required by section 143(3) of the Act based on our audit, and on the consideration of the reports of the branch auditors as referred to in paragraph 17 above, we report, to the extent applicable, that: a) We have sought and except for the matters described in the Basis for Quali_ed Opinion section, obtained all the information and explanations which to the best of our knowledge and belief were necessary for the purpose of our audit of the accompanying standalone _nancial statements; 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 and proper returns adequate for the purposes of our audit have been received from the branches not visited by us, except for the e_ects of the matters described in the Basis for Quali_ed Opinion section and except for the matters stated in paragraph 21(i)(vi) below on reporting under Rule 11(g) of the Companies (Audit and Auditors) Rules, 2014 (as amended). c) The reports on the accounts of the branch o_ces of the Company audited under section 143(8) of the Act by the branch auditors have been sent to us and have been properly dealt with by us in preparing this report; d) The standalone _nancial statements dealt with by this report are in agreement with the books of account and with the returns received from the branches not visited by us; e) Except for the effects of the matters described in the Basis for Qualified Opinion section, in our opinion, the aforesaid standalone _nancial statements comply with Ind AS speci_ed under section 133 of the Act; f) The provisions of section 164(2) of the Act are not applicable to the Company since the Company is a Government company as de_ned under section 2(45) of the Act; g) The quali_cation/modi_cation relating to the maintenance of accounts and other matters connected therewith are as stated in paragraph 3 of the Basis for Quali_ed Opinion section, paragraph 21(b) above on reporting under section 143(3)(b) of the Act and paragraph 21(i)(vi) below on reporting under Rule 11(g) of the Companies (Audit and Auditors) Rules, 2014 (as amended); h) With respect to the adequacy of the internal _nancial controls with reference to standalone _nancial statements of the Company as on 31 March 2025 and the operating e_ectiveness of such controls, refer to our separate report in Annexure II wherein we have expressed an unmodi_ed opinion; and i) 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 and based on the consideration of the reports of the branch auditors as referred to in paragraph 17 above: i. Except for the e_ects of the matters described in paragraph 3 of the Basis for Quali_ed Opinion section, the Company, as detailed in note 47.1 to the standalone _nancial statements, has disclosed the impact of pending litigations on its _nancial position as at 31 March 2025; ii. The Company did not have any long-term contracts including derivative contracts for which there were any material foreseeable losses as at 31 March 2025; iii. There were no amounts which were required to be transferred to the Investor Education and Protection Fund by the Company during the year ended 31 March 2025 except _ 1.00 crore pertaining to unclaimed matured deposits which was required to be deposited in the Investor Education and Protection Fund during the year ended 31st March 2018 and which has not been deposited till 31st March 2025;

iv. a. The management has represented that, to the best of its knowledge and belief, as disclosed in note 51.7(a) to the standalone _nancial statements, no funds have been advanced or loaned or invested (either from borrowed funds or securities premium or any other sources or kind of funds) by the Company to or in any person(s) or entity(ies), including foreign entities (‘the 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 identi_ed in any manner whatsoever by or on behalf of the Company (‘the Ultimate Bene_ciaries) or provide any guarantee, security or the like on behalf the Ultimate Bene_ciaries; b. The management has represented that, to the best of its knowledge and belief, as disclosed in note 51.7(b) to the standalone _nancial statements, no funds have been received by the Company from any person(s) or entity(ies), including foreign entities (‘the 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 identi_ed in any manner whatsoever by or on behalf of the Funding Party (‘Ultimate Bene_ciaries) or provide any guarantee, security or the like on behalf of the Ultimate Bene_ciaries; and c. Based on such audit procedures performed as considered reasonable and appropriate in the circumstances, nothing has come to our notice that has caused us to believe that the management representations under sub-clauses (a) and (b) above contain any material misstatement. v. The interim/_nal dividend paid by the Company during the year ended 31 March 2025 in respect of such dividend declared for the previous year is in accordance with section 123 of the Act to the extent it applies to payment of dividend As stated in note 49.16 to the accompanying standalone _nancial statements, the Board of Directors of the Company have proposed _nal dividend for the year ended 31 March 2025 which is subject to the approval of the members at the ensuing Annual General Meeting. The dividend declared is in accordance with section 123 of the Act to the extent it applies to declaration of dividend. vi. Based on our examination which included test checks except for the instance mentioned below, the Company, in respect of _nancial year commencing on 1 April 2024, have used accounting software for maintaining its books of account which have a feature of recording audit trail (edit log) facility and the same have been operated throughout the year for all relevant transactions recorded in the software. Further, during the course of our audit we did not come across any instance of audit trail feature being tampered with, other than the consequential impact of the exception given below.

The matured deposit have already been claimed by the successors/ relatives of the individuals but is pending for submission of document of proof of legal heir by the claimants. Appropriate procedure is being followed for refunding the matured deposits to the legal heirs.

Audit trail facility is being implemented shortly.

The matter is under review for necessary action.

23 As required by section 143(5) of the Act, we give in ‘Annexure III, a statement on the matters speci_ed in the directions issued by the Comptroller and Auditor General of India in respect of the Company.

Comments

In terms of the information and explanations sought by us and given by the Company and the books of account and records examined by us in the normal course of audit and based on the consideration of the reports of the branch auditors, and to the best of our knowledge and belief, we report that: (i) (a) (A) The Company has maintained proper records showing particulars of plant and equipment, capital work-in-progress, investment property and relevant details of right-of-use assets. However, we have observed that the records of location and identity of certain _xed assets need strengthening in the Fixed Asset Register (FAR) to ensure accurate tracking and veri_cation. Further, the area in respect of certain lands need to be reconciled with the records of the authorities in the respective States and wherein, as informed to us by the management, the delay is due to procedural matters involved.

(B) The Company has maintained proper records showing full particulars of intangible assets.

(b) The Company has a regular programme of physical veri_cation of its property, plant and equipment, capital work-in-progress, investment property and relevant details of right-of-use assets under which the assets are physically veri_ed in a phased manner over a period of three years, which in our opinion, is reasonable having regard to the size of the Company and the nature of its assets. In accordance with this programme, certain property, plant and equipment, investment property and relevant details of right-of-use assets were veri_ed during the year and no material discrepancies were noticed on such veri_cation/ material discrepancies were noticed on such veri_cation which have been properly dealt with in the books of account. However, there are certain land and buildings which are under encroachment / unauthorised occupation and hence, were not subjected to physical veri_cation.

(c) The title deeds of all the immovable properties (including investment properties) held by the Company (other than properties where the Company is the lessee and the lease agreements are duly executed in favour of the lessee), disclosed in Note 4,4a and 48.1(B) to the standalone _nancial statements, are held in the name of the Company, except for the following properties, for which the Companys management is in the process of getting the registration in the name of the Company: For properties where the Company is a lessee, the lease arrangements have been duly executed in favour of the Company except in following cases:

(_ in crore)

Necessary action is being taken to update location and extent of area in respective plants in _xed asset register. This is a continuous process.

Necessary action is being taken to evict the occupants from land and building under encroachment/unauthorized occupation.

For properties where the Company is a lessee, the lease arrangements have been duly executed in favour of the Company except in following cases:

(_ in crore)

(d) The Company has not revalued its property, plant and equipment (including right-of-use assets) or intangible assets during the year.

(e) No proceedings have been initiated or are pending against the Company for holding any benami property under the Prohibition of Benami Property Transactions Act, 1988 (as amended) and rules made thereunder. (ii) (a) In our opinion, the management has conducted physical veri_cation of inventories at reasonable intervals during the year except for goods-in-transit and inventories lying with third parties and, in our opinion, the coverage and procedure of such veri_cation by the management is appropriate and in certain cases, the bulk inventories have been veri_ed on the basis of visual surveys /estimates. The discrepancies noticed on physical veri_cation of inventory as compared to book records were not 10% or more in aggregate for each class of inventory. For stocks lying with third parties at the year-end, written con_rmations have been obtained by the management; (b) As disclosed in Note 51.5 to the standalone _nancial statements, the Company has been sanctioned a working capital limit in excess of _ 5 crores by banks based on the security of current assets. The quarterly statements, in respect of the working capital limits have been _led by the Company with such banks and such statements are in agreement with the books of account of the Company for the respective periods which were subject to review, except for the following:

(_ in crore)

The Company has not made any investment in, provided any guarantee or security or granted any loans or advances in the nature of loans, secured or unsecured to companies, _rms, Limited Liability Partnerships (LLPs) or any other parties during the year. Accordingly, reporting under clause 3(iii) of the Order is not applicable to the Company. (iv) In our opinion, and according to the information and explanations given to us, the Company has complied with the provisions of section 186 of the Act in respect of investments made and guarantees and security provided by it, as applicable. Further, the Company has not entered into any transaction covered under section 185 of the Act. (v) In our opinion, and according to the information and explanations given to us, the Company has not accepted any deposits or there are no amounts which have been deemed to be deposits within the meaning of sections 73 to 76 of the Act and the Companies (Acceptance of Deposits) Rules, 2014 (as amended). Accordingly, reporting under clause 3(v) of the Order is not applicable to the Company.

(vi) The Central Government has speci_ed maintenance of cost records under sub-section (1) of section 148 of the Act in respect of the products of the Company. We have broadly reviewed the books of account maintained by the Company pursuant to the rules made by the Central Government for the maintenance of cost records and are of the opinion that, prima facie, the prescribed accounts and records have been made and maintained. However, we have not made a detailed examination of the cost records with a view to determine whether they are accurate or complete.

(vii) (a) In our opinion, and according to the information and explanations given to us, undisputed statutory dues including goods and services tax, provident fund, employees state insurance, income-tax, sales-tax, service tax, duty of customs, duty of excise, value added tax, cess and other material statutory dues, as applicable, have generally been regularly deposited with the appropriate authorities by the Company, though there have been slight delays in a few cases. Further, no undisputed amounts payable in respect thereof were outstanding at the year-end for a period of more than six months from the date they became payable.

(b) According to the information and explanations given to us, there are no statutory dues referred in sub-clause (a) which have not been deposited with the appropriate authorities on account of any dispute except for the following:

(viii) According to the information and explanations given to us, no transactions were surrendered or disclosed as income during the year in the tax assessments under the Income Tax Act, 1961 (43 of 1961) which have not been previously recorded in the books of accounts.

(ix) (a) According to the information and explanations given to us, the Company has not defaulted in repayment of its loans or borrowings or in the payment of interest thereon to any lender.

(b) According to the information and explanations given to us including con_rmations received from banks/ _nancial institution and other lenders and representation received from the management of the Company, and on the basis of our audit procedures, we report that the Company has not been declared a willful defaulter by any bank or _nancial institution or government or any government authority. (c) In our opinion and according to the information and explanations given to us, money raised by way of term loans were applied for the purposes for which these were obtained.

(d) In our opinion and according to the information and explanations given to us, and on an overall examination of the _nancial statements of the Company, funds raised by the Company on short term basis have, prima facie, not been utilised for long term purposes.

(e) According to the information and explanations given to us and on an overall examination of the standalone _nancial statements of the Company, the Company has not taken any funds from any entity or person on account of or to meet the obligations of its subsidiaries, associates or joint ventures. (f) According to the information and explanations given to us, the Company has not raised any loans during the year on the pledge of securities held in its subsidiaries, joint ventures or associate companies.

(x) (a) The Company has not raised any money by way of initial public o_er or further public o_er (including debt instruments), during the year. Accordingly, reporting under clause 3(x)(a) of the Order is not applicable to the Company.

(b) According to the information and explanations given to us and on the basis of our examination of the records of the Company, the Company has not made any preferential allotment or private placement of shares or (fully, partially or optionally) convertible debentures during the year. Accordingly, reporting under clause 3(x)(b) of the Order is not applicable to the Company.

(xi) (a) According to the information and explanations given to us and on the basis of our examination of the records of the company, a fraud by employees on the Durgapur Steel Plant has been noticed and reported during the year by the management. The fraud pertains to a series of unauthorized transactions carried out by executives in the Pension Cell under the guise of pension refunds and salary payments, involving diversion of funds to unauthorized bene_ciaries and use of non-bona _de bank accounts. The identi_ed fraudulent transactions amounted to _3.60 crore.

(b) As required under sub-section (12) of Section 143 of the Companies Act, 2013, we have reported the matter to the Central Government in Form ADT-4 as prescribed under Rule 13 of the Companies (Audit and Auditors) Rules, 2014 in respect of the Durgapur Steel Plant during the year.

(c) According to the information and explanations given to us and based on the records of the Company, one case was received during the year under the ‘VIGIL / Whistle Blower Mechanism of SAIL by the Vigilance department. The said case is currently kept on hold as the Central Bureau of Investigation (CBI) is conducting an investigation into a similar matter.

(xii) The Company is not a Nidhi Company and the Nidhi Rules, 2014 are not applicable to it. Accordingly, reporting under clause 3(xii) of the Order is not applicable to the Company.

(xiii) In our opinion and according to the information and explanations given to us, all transactions entered into by the Company with the related parties are in compliance with sections 177 and 188 of the Act, where applicable. Further, the details of such related party transactions have been disclosed in the standalone _nancial statements, as required under Indian Accounting Standard (Ind AS) 24, Related Party Disclosures speci_ed in Companies (Indian Accounting Standards) Rules 2015 as prescribed under section 133 of the Act. xiv) (a) In our opinion and according to the information and explanations given to us, the Company has an internal audit system commensurate with the size and nature of its business. However, the internal audit function is being performed by the employees of the Internal Audit Department of the Company. It is recommended that the overall internal audit process needs to be strengthened specially, identifying key control areas and addressing key risk areas in order to achieve comprehensive audit coverage and implementation of corrective actions.

The Company has taken appropriate action for reporting and avoid recurrence of such fraud.

The investigation in the similar matter is still in progress.

Appropriate actions are being taken to strengthen overall Internal Audit Process including identifying key control and addressing key risk areas.

(b) We have considered, the internal audit reports for the year under audit, issued to the Plant during the year and till date, in determining the nature, timing and extent of our audit procedures.

(xv) According to the information and explanation given to us, the Company has not entered into any non-cash transactions with its directors or persons connected with its directors and accordingly, reporting under clause 3(xv) of the Order with respect to compliance with the provisions of section 192 of the Act are not applicable to the Company.

(xvi) The Company is not required to be registered under section 45-IA of the Reserve Bank of India Act, 1934. Accordingly, reporting under clauses 3(xvi)(a), (b) and (c) of the Order are not applicable to the Company.

(xvii) The Company has not incurred any cash losses in the current _nancial year as well as the immediately preceding _nancial year.

(xviii) There has been no resignation of the Statutory Auditors during the year and accordingly the reporting under clause 3(xviii) is not applicable to the company. (xix) According to the information and explanations given to us and on the basis of the _nancial ratios, ageing and expected dates of realisation of _nancial assets and payment of _nancial liabilities, other information in the standalone _nancial statements, our knowledge of the plans of the Board of Directors and management and based on our examination of the evidence supporting the assumptions, nothing has come to our attention, which causes us to believe that any material uncertainty exists as on the date of the audit report indicating that Company is not 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. We, however, state that this is not an assurance as to the future viability of the company. We further state that our reporting is based on the facts up to the date of the audit report and we neither give any guarantee nor any assurance that all liabilities falling due within a period of one year from the balance sheet date, will get discharged by the company as and when they fall due.

(xx) (a) According to the information and explanations given to us, there are no unspent amounts towards Corporate Social Responsibility pertaining to other than ongoing projects as at end of the current _nancial year. Accordingly, reporting under clause 3(xx)(a) of the Order is not applicable to the Company.

(b) According to the information and explanations given to us, the Company has transferred the remaining unspent amounts towards Corporate Social Responsibility (CSR) under sub-section (5) of section 135 of the Act, in respect of ongoing project, within a period of 30 days from the end of _nancial year to a special account in compliance with the provision of sub-section (6) of section 135 of the Act, (xxi) The reporting under clause 3(xxi) of the Order is not applicable in respect of audit of standalone _nancial statements of the Company. Accordingly, no comment has been included in respect of said clause under this report.