Steel Exchange India Ltd Auditor Reports

To

The Members of

STEEL EXCHANGE INDIA LIMITED

Report on the Audit of the Standalone Financial Statements Opini?n

We have audited the accompanying standalone financial statements of M/s.Steel Exchange India Limited ("the Company"), which comprise 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 ended on that date, and a summary of significant accounting policies and other explanatory information (hereinafter 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 except the effect of matter referred to in Basis for qualified opinion 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, the profit 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 in accordance with the Standards on Auditing (SAs) specified 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 together with the ethical 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 Code of Ethics. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.

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. We have determined the matters described below to be the key audit matters to be communicated in our report.

S.No Key Audit matter

1. Conversi?n of converatable equity warrants to Equity shares

During the year, the Company has converted 5,82,21,500 convertible equity shares warrants issued to Umashiv garments private limited to equity shares upon receipt of balance 75% payment for warrants . The company issued 5,82,21,500 equity shares of FV Rs 1/each at a premium of Rs 6.25/shares to Umashiv garments private limited.

This presents a significant audit matter due to the complexity of the transaction and the materiality of the balances involved.

Auditors Response

Principal Audit Procedure

Our audit procedures includes the following:

• Examined the terms and conditions of the share warrants to ensure that the conversion process adheres to the provisions outlined in the relevant agreements and applicable accounting standards.

• Examined the relevant supporting documentation, such as board resolutions, shareholders resolutions, share issuance documents, and any other relevant contracts or agreements. This helps ensure that the conversion process has been authorized and executed appropriately.

• Confirmed the receipt of consideration for the issuance of shares warrants through examination of bank statements, cash receipts, or other relevant financial records.

• Determined the appropriateness of the disclosures in the financial statement in respect of the conversion.

2 Issue of share warrants

During the year ,the company has issued 8,27,27,272 convertible equity warrants of face value Re 1/-(rupees one only) each, at an issue price of Re 11/- per warrant( including a premium of Re 10 per warrant ) for an aggregate consideration of Re 90,99,99,992 by way of preferential allotment to the parties as mentioned in below table.

 

S. No. Name of the company	No.of Warrants
1 KGR RESOURCES LLP	1,81,81,818
2 KOLLURI IMPEX PRIVATE LIMITED	1,81,81,818
3 NEO SPECIAL CREDIT OPPERTUNITIES FUND	1,32,23,636
4 SAHI TRADING PRIVATE LIMITED	1,00,00,000
5 SHAKTHI INTERNATIONAL LLP	1,81,81,818
6 TRUE NORTH CREDIT OPPERTUNITIES FUND	49,58,182

The company has received 25% i.e., Re 22,75,00,000 on 30.01.2024 upon allotment of Convertible equity warrants .

Issue of convertible Equity warrants draw attention due to its potential impact on the companys financial position and shareholder equity. Share warrants are financial instruments that entitle the holder to subscribe to the companys shares at a predetermined price within a specified period.

Audit Procedures:

• Obtained and reviewed the issuance of shares warrants focusing on the terms and conditions, exercise price, expiration date, and any other relevant provisions

• Obtained valuation report from company secretary to assess the fair value of the shares warrants issued, ensuring compliance with relevant accounting standards Evaluate the valuation methodology, assumptions, and inputs used in determining the fair value.

• Confirmed the receipt of consideration for the issuance of shares warrants through examination of bank statements, cash receipts, or other relevant financial records.

• Assessed the potential dilution effect of the issuance of shares warrants on existing shareholders equity interests. Consider the impact on earnings per share (EPS) and other key financial metrics.

• Determined the appropriateness of the disclosures in the financial statement in respect of the conversion.

3. Issue of equity shares on preferential allotment

During the year , the company has made an preferential allotment of 1,30,00,000 and 1,10,00,000 equity shares to Dhatree Udyog Limited and Money Seed respectively, at rates of Re 15.75 and Re 16.6 per share (including premiums of Re 14.75 and Re 15.6 respectively), represents a significant transaction due to its materiality and potential impact on the financial statements of the company. This transaction warrants special audit attention due to its complexities in valuation, compliance, and financial statement presentation.

• Obtained and reviewed the board resolutions, shareholders approvals, and legal agreements related to the preferential allotment of equity shares to Dhatree Udyog Limited and Money Seed. Ensure compliance with the Companies Act, SEBI regulations, and other applicable laws.

• Obtained valuation report from company secretary to assess the fair value of the equity shares issued on preferential allotment basis

• Confirmed the receipt of consideration for the preferential allotment of equity shares from Dhatree Udyog Limited and Money Seed. Verify the adequacy of funds transferred through bank statements, cash receipts, or other financial records

• Verified the share register to ensure accurate recording of the allotment of equity shares to Dhatree Udyog Limited and Money Seed, including details such as the number of shares allotted, date of allotment, and consideration received.

• Reviewed the adequacy of disclosure in the financial statements regarding the preferential allotment of equity shares, including details of the parties involved, number of shares allotted, issue price, premium, and any other relevant information. Ensure compliance with applicable accounting standards and regulatory requirements.

4. Evaluation of uncertain tax positions

The Company has material uncertain tax positions including matters under dispute which involves significant judgment to determine the possible outcome of these disputes.

Refer note no 3.28 to the Standalone Financial Statements

Auditors Response

Principal audit procedure

Obtained details of completed tax assessments and demands for the year ended March 31, 2024 from management . Discussed with the managements underlying assumptions in estimating the tax provision and the possible outcome of the disputes. Additionally, we considered the effect of new information in respect of uncertain tax positions as at March 31, 2024 to evaluate whether any change was required to managements position on these uncertainties.

5. Recoverability of Indirect tax receivables and other receivables

1. As at March 31, 2024, other non current assets include Indirect tax balance receivable amounting to Rs 1710.37 lakhs and other receivables Rs 467.80 lakhs out of which amount of Rs 796.93 lakhs and Rs 467.74 lakhs in indirect tax balances and other receivables respectively are pending adjudication Refer Note 3.2 to the Standalone Financial Statements.

Auditors Response

Principal audit procedure

We have verified the relavent documents and records, the sustainability and likelihood of recoverability upon final resolution.

Information Other than the Standalone Financial Statements and Auditors Report Thereon

The Companys Board of Directors are responsible for the preparation of the other information. The other information comprises the information included in the Management Discussion and Analysis, Boards Report including Annexures to Boards Report, Business Responsibility Report, Corporate Governance and Shareholders Information, but does not include the standalone financial statements and our auditors report thereon.

Our opinion on the standalone 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 standalone financial statements, our responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent with the standalone 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.

Managements Responsibility 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 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 including The Indian Accounting Standard specified under sec. 133 of the act. This responsibility also includes maintenance of adequate accounting records in accordance with the provisions of the Act for safeguarding the assets of the Company and for preventing and detecting 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 standalone financial statements that give a true and fair view and are free from material misstatement, whether due to fraud or error.

In preparing the standalone 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.

The Board of Directors are responsible for overseeing the Companys financial reporting process.

Auditors Responsibilities for the Audit of the Standalone Financial Statements

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 standalone 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 financial controls 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 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.

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 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 Section 143(3) of the Act, based on our audit 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, Statement of Changes in Equity and the Statement of Cash Flow dealt with by this Report are in agreement with the relevant books of account.

d. In our opinion, the aforesaid standalone financial statements comply with the Ind AS 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 March 31,2024 taken on record by the Board of Directors, none of the directors is disqualified as on March 31,2024 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 controls over financial reporting of the Company and the operating effectiveness of such controls, refer to our separate Report in "Annexure A". Our report expresses an unmodified opinion on the adequacy and operating effectiveness of the Companys internal financial controls over financial reporting.

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, 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 standalone financial statements.(Refer Note: 3.28 ).

ii. The Company did not have any long-term contracts including derivative contracts for which there were any material foreseeable losses.

iii. There were no amounts which were required to be transferred to the Investor Education and Protection Fund by the Company.

iv. (a) The Management has represented that, to the best of its knowledge and belief, no funds (which

are material either individually or in the aggregate) 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 person or entity, including foreign entity ("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, that, to the best of its knowledge and belief, no funds (which are material either individually or in the aggregate) have been received by the Company from any person or entity, including foreign entity ("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 ("Ult?mate Beneficiaries") or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries;

(c) Based on the audit procedures that have been considered reasonable and appropriate in the circumstances, nothing has come to our notice that has caused us to believe that the representations under sub-clause (i) and (ii) of Rule 11(e), as provided under (a) and (b) above, contain any material misstatement.

v Based on our examination which included test checks, the company has used an accounting software for maintaining its books of account which has a feature of recording audit trail (edit log) facility and the same has 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.

As provision to Rule 3(1) of the Companies (Accounts) Rules, 2014 is applicable from April 1, 2023, reporting under Rule 11 (g) of the Companies (Audit and Auditors) Rules, 2014 on preservation of audit trail as per the statutory requirements for record retention is not applicable for the financial year ended March 31,2024.

2. As required by the Companies (Auditors Report) Order, 2020 ("the Order") issued by the Central Government in terms of Section 143(11) of the Act, we give in "Annexure B" a statement on the matters specified in paragraphs 3 and 4 of the Order.

	For BHAVANI &Co.
	Chartered Accountants
	Firm Reg. No:012139S
Place : Hyderabad	(CA S KAVITHA PADMINI)
Date : 03-05-2024	PARTNER
	M.No : 229966
	UDIN: 24229966BKBLVX1527

ANNEXURE "A" TO THE INDEPENDENT AUDITORS REPORT

(Referred to in paragraph 1(f) under Report on Other Legal and Regulatory Requirements section of our report to the Members of Steel Exchange india Limited of even date)

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 M/s. Steel Exchange India limited ("the Company") as of March 31,2024 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 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, including adherence to respective 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 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 internal financial control system over financial reporting of the Company.

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 unauthorized 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 BHAVANI &Co.
	Chartered Accountants
	Firm Reg. No:012139S
Place : Hyderabad	(CA S KAVITHA PADMINI)
Date : 03-05-2024	PARTNER
	M.No : 229966
	UDIN: 24229966BKBLVX1527

"ANNEXURE B" TO THE INDEPENDENT AUDITORS REPORT

RReferred to in paragraph 1 under the heading Report on Other Legal & Regulatory Requirement of our report of even date

to the financial statements of the Company for the year ended March 31,2024:

i. In respect of the Companys Property, Plant and Equipment and Intangible Assets:

(a) (A) The Company has maintained proper records showing full particulars, including quantitative details and situation of Property, Plant and Equipment and relevant details of right-of-use assets.

(B) The Company does not have intangible assets, hence order I (a)(B) not applicable.

(b) The Company has a program of physical verification of Property, Plant and Equipment to cover all the assets once every three years which, in our opinion, is reasonable having regard to the size of the Company and the nature of its assets. Pursuant to the program, certain Property, Plant and Equipment were due for verification during the year and 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) Based on our examination of the property tax receipts and lease agreement for land on which building is constructed, registered sale deed / transfer deed / conveyance deed provided to us, we report that, the title in respect of self-constructed buildings and title deeds of all other 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 included under Property, Plant and Equipment are held in the name of the Company as at the balance sheet date.

(d) The Company has not revalued any of its Property, Plant and Equipment assets during the year.

(e) No proceedings have been initiated during the year or are pending against the Company as at March 31,2024 for holding any benami property under the Benami Transactions (Prohibition) Act, 1988 (as amended in 2016) and rules made thereunder.

ii. (a) The management has conducted the physical verification of inventory at reasonable intervals. The discrepancies

noticed on physical verification of the inventory as compared to books records which has been properly dealt with in the books of account were immaterial.

(b) During the year, the company has been sanctioned working capital limits in excess of five crore rupees, in aggregate, from banks or financial institutions on the basis of security of current assets; the quarterly returns or statements filed by the company with such banks or financial institutions are in agreement with the books of account of the Company.

iii. The Company has not granted any loans, secured or unsecured to companies, firms, Limited Liability partnerships or other parties covered in the Register maintained under Section 189 of the Act. Accordingly, paragraph 3 (iii) (a) to (C) of the Order are not applicable.

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 186 of the Companies Act, 2013 In respect of loans, investments, guarantees, and security.

v. The Company has not accepted any deposits from the public and hence the directives issued by the Reserve Bank of India and the provisions of Sections 73 to 76 or any other relevant provisions of the Act and the Companies (Acceptance of Deposit) Rules, 2015 with regard to the deposits accepted from the public are not applicable.

vi. As informed to us, the maintenance of Cost Records has been specified by the Central Government under sub-section (1) of Section 148 of the Act, in respect of the activities carried on by the company. We have broadly reviewed the Cost Records maintained by the Company pursuant to the Companys (Cost Records and Audit) Rules, 2014 prescribed by the Central Government and are of the opinion that prima facie the prescribed cost records have been maintained.

vii. (a) According to the information and explanations given to us and the records of the company examined by us, the

company is regular in depositing undisputed statutory dues including Provident fund, Employee State Insurance, Income tax, sales tax, customs duty, goods and service tax and any other statutory dues as applicable with appropriate authorities. There were no arrears of outstanding statutory dues as on last day of the financial year concerned for a period of more than six months from the date on which they become payable.

(b) According to the information and explanation given to us, the following dues of the service tax, customs duty, excise duty , value added tax , GST , Central sales tax, Cess and other statutory dues which have not been deposited with appropriate authorities on account of any dispute.

?ame of the Statute	Nature of Dues	Period to which the amount relates	Amount in	Deposlts/ Pald in (?¦)	Forum where the dispute is pending with
CSTAct	Sales Tax	2004-05	28,27,172/-	3,53,397/-	CTO.Gajuwaka, Visakhapatnam
CSTAct	Sales Tax	2005-06	47,85,829/-	23,92,914/-	STAT, Visakhapatnam
APVAT	Sales Tax	2019-20	2,74,70,664	1,37,83,617/-	STAT, Visakhapatnam
APVATAct	Sales Tax	2013-14	11,85,519/-	11,85,519/-	JC legal,Vijayawada
APVAT Act	Sales Tax	2012-13	23,21,766/-	11,60,883/-	ADC APPEAL,Vijayawada
APVATAct	Sales Tax	2013-14	1,18,189/-	1,18,189/-	STAT, Visakhapatnam
APVATAct	Sales Tax	2014-15	8,68,360/-	8,68,360/-	Appellate Deputy Commissloner, Visakhapatnam
APVATAct	Sales tax	2014-15	51,856/-	3,37,690/-	Appellate Deputy Commissioner (CT), Vijayawada
APVATACT	Sales tax	2015-16	31,41,694/-	7,85,424/-	Honble High Court of Telangana & AP
APVATACT	Sales tax	2016-17	82,70,573/-	20,67,643/-	Honble High Court of Telangana & AP
APVATACT	Sales tax	2017-18	13,19,062/-	3,29,765/-	Appellate Deputy Commissioner (CT), Vijayawada
APVATACT	Sales tax	2014-15	57,375/-	57375/-	STAT, Visakhapatnam
APVATACT	Sales tax	2015-16	2,63,227/-	1,31,614/-	Appellate Deputy Commissioner (CT), Vijayawada
APVATACT	Sales tax	2016-17	5,17,834/-	2,58,917	Appellate Deputy Commissioner (CT), Vijayawada
APVATACT	Sales tax	2015-16	44,10,896/-	nil	Appellate Deputy Commissioner (CT), Vijayawada
APVATACT	Sales tax	1991-92	10,99,007	nil	Commercial Tax Officer, Punjagutta Divisi?n, Hyderabad
Customs Act	Customs Duty	2003-04	54,35,648/-	NIL	Honble High Court of Telangana & AP
Customs Act	Customs Duty	2012-13	67,38,452/-	NIL	CESTAT, Bangalore
Central Excise Act	Excise Duty 2009-10	2010-1142011-12	61,18,776/-	50,00,000/-	Commissioner of Central Excise, Visakhapatnam
Central Excise Act	Excise Duty	2014-15	8,23,38,648/-	Nil	Commissioner of Central Excise, Visakhapatnam.
Customs Act	Customs duty	2012-13	2,18,06,647/-	NIL	Honble Customs, Central Excise & Service Tax-Appellate Tribunal, Telangana
Excise Act	Excise duty	2012-13	8,58,585/-	NIL	Assistant Commissioner of Customs & Central Excise, Visakhapatnam
Excise Act	Excise duty	2014-151D 2017-18	87,30,013/-	NIL	Commissioner of Central Tax & Customs, (Appeals), Guntur
Excise Act	Excise duty	2015-16	6,90,69,600/-	Nil	Principie Commissioner of Central Excise, Visakhapatnam
Excise Act	Excise duty	2009-10	14,35,189	Nil	AP HIGH COURT
Excise Act	Excise Duty	2015-16	92,58,242	10,00,000	CESTAT

 

Service Tax Act	Service Tax	2013-141D 2016-17	17,98,12,034/-	1,34,81,800	Commissioner of Central tax, Visakhapatnam
Service Tax Act	Service tax	2016-17	1,22,63,893/-	Nil	Additional Commissioner Of central Tax, Visakhapatnam
Service Tax Act	Service tax	2017-18	18,76,843	Nil	Additional Commissioner of central tax,Visakhapatnam
Service Tax Act	Service tax	2016-17	52,25,963/-	5,22,595	Principie Commissioner Of central Tax, Visakhapatnam
GSTACT	GST	2017-18	69,21,076	7,72,188/-	Deputy Commissioner of central Tax, Rajamahendravaram
GSTAct	GST	2017-18	20,20,429	NIL	Deputy Commissioner of central Tax, Visakhapatnam
Service Tax Act	Service tax	2016-17	1,22,63,893/-	Nil	Additional Commissioner of central Tax,Visakhapatnam
Service Tax Act	Service tax	2017-18	18,76,843/-	Nil	Additional Commissioner of central tax,Visakhapatnam
Service Tax Act	Service tax	2016-17	52,25,963/-	Nil	Principie Commissioner of central Tax, Visakhapatnam
GSTAct	GST	2017-18	69,21,076/-	NIL	Deputy Commissioner of central Tax, Rajamahendravaram
GSTAct	GST	2017-18	20,20,429/-	NIL	Deputy Commissioner of central Tax, Visakhapatnam

viii. There were no transactions relating to previously unrecorded income that have been surrendered or disclosed as income during the year in the tax assessments under the Income Tax Act, 1961 (43 of 1961),

ix. (a) According to the records of the company examined by us,the information and explanations given to us, the company has not defaulted in repayment of loans or borrowings to any financial institutions or banks as on at the balance sheet date.

(b) The Company has not been declared wilful defaulter by any bank or financial institution or government or any government authority.

(c) The Company has taken term loan during the year and have applied for the purpose it was obtained.

(d) On an overall examination of the financial statements of the Company, funds raised on short-term basis have, prima facie, not been used during the year for long-term purposes by the Company.

(e) On an overall examination of the financial 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.

(f) The Company has not raised any loans during the year on the pledge of securities held in its subsidiaries, joint ventures or associate companies and hence reporting on clause 3(ix)(f) of the Order is not applicable.

x. (a) The Company has not raised moneys by way of initial public offer or further public offer (including debt instruments) during the year and hence reporting under clause 3(x)(a) of the Order is not applicable.

(b) The company has not made any preferential allotment or private placement of shares and convertible debentures (fully convertible) during the year and accordingly order under x(b) is not applicable.

xi. (a) No fraud by the Company and no material fraud on the Company has been noticed or reported during the year.

(b) 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 upto the date of this report.

(c) We have taken into consideration the whistle blower complaints received by the Company during the year (and upto the date of this report), while determining the nature, timing and extent of our audit procedures.

xii. 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 to us and based on our examination of the records of the company transactions with the related parties are in compliance with section 177 and 188 of Companies Act,2013 where applicable and the 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 audit system commensurate with the size and the nature of

its business.

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

xv. In our opinion during the year the Company has not entered into any non-cash transactions with its Directors or persons connected with its directors. and hence provisions of section 192 of the Companies Act, 2013 are not applicable to the Company

xvi. In our opinion, the Company is not required to be registered under section 45-IA of the Reserve Bank of India Act, 1934. Hence, reporting under clause 3(xvi)(a), (b) and (c) of the Order is not applicable. (b) In our opinion, there is no core investment company within the Group (as defined in the Core Investment Companies (Reserve Bank) Directions, 2016) and accordingly reporting under clause 3(xvi)(d) of the Order is not applicable.

xvii. The Company has not incurred cash losses during the financial year covered by our audit and the immediately preceding financial year.

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

xix. On the basis of the financial ratios, ageing and expected dates of realisation of financial assets and payment of financial liabilities, other information accompanying the financial statements and our knowledge of the Board of Directors and Management plans 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) There are no unspent amounts towards Corporate Social Responsibility (CSR) on other than ongoing projects

requiring a transfer to a Fund specified in Schedule VII to the Companies Act in compliance with second proviso to sub-section (5) of Section 135 of the said Act. Accordingly, reporting under clause 3(xx)(a) of the Order is not applicable for the year.

	For BHAVANI &Co.
	Chartered Accountants
	Firm Reg. No:012139S
Place : Hyderabad	(CA S KAVITHA PADMINI)
Date : 03-05-2024	PARTNER
	M.No : 229966
	UDIN: 24229966BKBLVX1527