Sturdy Industries Ltd Directors Report.

To the Members of Sturdy Industries Limited.

Report on the Financial Statements as per Ind AS

We have audited the accompanying standalone financial statements of Sturdy Industries Limited ("the Company"), which comprise the Balance Sheet as at March 31, 2019, and the Statement of Profit and Loss, Statement of change in Equity and Cash Flow Statement for the year then ended, and a summary of significant accounting policies and other explanatory information.

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 in the manner so required and give a true and fair view in conformity with the accounting principles generally accepted in India, of the state of affairs of the Company as at March 31, 2019, andits loss, and its cash flows for the year ended on that date.

Basis of Qualified Opinion

a). Attention is invited to Note No 2 of the financial statements in respect ofProperty, Plant and Machinery and Equipments and depreciation on assets thereon. The company has already booked depreciation amounting to Rs. 4.51 Crupto 31/12/2018. During the current quarter the company has re-accessed the life of plant and machinery through Chartered Engineer, as per his certificate dated 09/03/2019 the management of the company has taken the accessed useful lifeof plant and machinery to 35 Years against 25 Years as specified in part ‘C of ScheduleII of the companies Act 2013, as result of which depreciation for the current Quarter ending 31st March 2019 isNegative to the extent of Rs 1.26 Crs and as a result of this readjustment in useful life of plant and machinery, depreciation and Net Block has been adjustedaccordingly which has resulted in increase in the net profit to the extent 1.26 Cr for the year.

b.) Attention is invited to Note No.9 of the financial statements in respect of Short Term Loan and Advances amounting to Rs. 1243.77 Lacsshown as recoverable in respect of Claims to be received on account of subsidy/incentives/other Govt. claims, out of which Rs. 1019.67 Lacshas been considered as income during the year (Refer note 22 of financial statements),although the same has not been acknowledged by the concerned departments and right to receive has not been established. Hence profit to that extent has been overstated in financial statements.

Our opinion is not modified in respect of these matters.

Opinion

In our opinion and to the best of our information and according to the explanations given to us, except for the effects of the matter described in basis for Qualified opinion paragraph above, the aforesaid standalone financial statements give the information required by the Act in the manner so required and give a true and fair view in conformity with the accounting principles generally accepted in India, of the state of affairs of the Company as at March 31, 2019 and itsloss and its Cash Flow for the year ended on that date.

Key Audit Matters

Key audit matters are those matters that in our professional judgment were of the most significant in our audit of the standalone financial statements of the current period. These matters addressed in the contest of our audit of the 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.

Key Audit Matter How our report addressed the Key audit matter.
1.Change in useful life and residualvalue of Plant and machinery. Our Audit Procedure include the following:-
As at March 31, 2019, the company has a gross block of Rs. 8372.30 Lacs in plant and machinery which constitute 69.36% of the property, plant and equipments ( Refer Note 2 of the financial statements) • Assessment of useful life of plant and machinery determined by external expert i:e Chartered Engineer and has relied upon his certificate.
In the current year, the company has revised the useful life of the plant and machinery. Assessment of the useful life of plant and machinery in an integrated and complex plants involves management judgment, consideration of historical experience, anticipated technological changes. • Examining the useful economic life and residual value with reference to companies historical experience, technical evaluation by third party and our understanding of future utilization of assets by the company.
Accordingly, it has been determined as Key Audit matter. • Review of disclosure made by the company in the financial statements in this regard.
• Assessing whether the impact on account of changes has been appropriately recognized in the financial statements.
2.Evaluation of Uncertain tax positions Our audit procedure include the following substantive procedures;-
The Company is having tax jurisdiction in Delhi region and is subject to periodic challenges by the local tax authorities on the rage of tax matters during the normal course of business. These involve significant management judgment to determine the possible outcome of the uncertain tax positions, consequently having impact on related accounting and disclosures in the standalone financial statements. • Obtained understanding of key uncertain tax positions; and
Refer Para 7 ( c) of CARO. • We along with company tax experts:-
a) Read and analyzed select key correspondences, consultation by the management with the external tax professionals working on key uncertain tax positions.
b) Discussed with the appropriate senior management and evaluated managements underlying key assumptions in estimating the tax provisions if any to be made; and
c) Assessed managements estimate of the possible outcome of the disputed cases;

Emphasis of Matter

a)Attention is invited to Note No. 4 of the financial statements in which the company has outstanding from Govt. Departments in shape of various claims amounting to Rs. 1139.37 Lakhs and advance to other parties amounting to Rs. 704.35 Lakhs which are outstanding since long for which the company has not madc any provision as the management considers it as good as recoverable.

Managements Responsibility for the 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 including other comprehensive income, cash flows and change in equityof the Company in accordance with the Accounting principles generally accepted in India, including theIndian Accounting Standard Ind AS specified under Section 133 of the Act, read with the provision of the Companies ( Indian accounting Standards) Rules, 2015 as amended . This responsibility includes the maintenance of adequate accounting records in accordance with the provision of the Act for safeguarding of the assets of the Company and for preventing and detecting the 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 ofadequate internal financial control, that were operating effectively for ensuring the accuracy and completeness of the accounting records, relevant to the preparation and presentations of the financial statements that give a true and fair view and free from material misstatement, whether due to fraud or error.

In preparing the standalone financial statements, management is responsible for assessing the company ability to continue as a going concern disclosing as applicable, matter relating to going concern and using the going concern basis of accounting unless management either intents to liquidate the company or to ceaseoperation, or hasno realistic alternative but to do so.

Those board of directors are responsible for overseeing the companys financial reporting process.

Auditors Responsibility

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

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

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

• Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances. Under section 143(3)(i) of the 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 financial statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based on the audit evidence obtained up to the date of our auditors report. However, future events or conditions may cause the Company to cease to continue as a going concern.

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

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

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

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

Report on Other Legal and Regulatory Requirements

1. As required by the Companies (Auditors Report) Order, 2016 ("the Order") issued by the Central

Government of India in terms of sub-section (11) of section 143 of the Act, we give in the Annexure A, a statement on the matters specified in the paragraph 3 and 4 of the Order, to the extent applicable.

2. As required by section 143(3) of the Act, we report that:-

a) We have sought and obtained allthe information and explanations which to the best of our knowledge and belief were necessary for the purpose of our audit;

b) In our opinion proper books of account as required by law have been kept by the Company so far as appears from our examination of those books.

c) The Balance Sheet, Statement of Profit and Loss, and Cash Flow Statement dealt with by this Report are in agreement with the books of account.

d) Except for the effects of the matter described in the basis for Qualified opinion paragraph above, in our opinion, the aforesaid standalone financial statements comply with the Indian Accounting Standards (Ind As) specified under Section 133 of the Companies Act, 2013, read with Rule 7 of the Companies(Accounts) Rules,2014;

e)The matters described in the basis for Qualified Opinion paragraph and Emphasis of matter paragraph above, in our opinion, can adversely affect the functioning of the company.

f) On the basis of written representations received from the directors as on March 31, 2019, and taken on record by the Board of Directors, none of the directors is disqualified as on March 31, 2019, from being appointed as a director in terms of section 164(2) of the Companies Act, 2013.

(ANNUAL REPORT 2018-19)g)The qualification relating to the maintenance of accounts and other matters connected therewith are as stated in the Basis for Qualified Opinion paragraph above.

h) with respect to the adequacy of the internal financial controls over financial reporting of the company and the operating effectiveness of such control, refer to our separate report in Annexure "B and

i) With respect to the other matters included in the Auditors Reportin accordance with Rule 11 of Companies (Audit and Auditors)Rules, 2014 in our opinion and to thebest of our information and according to explanations given to us:

i. The Company has not disclosed the impact of pending litigations in its financial statements with respect to suits on or by the company in respect of suits filed by the company for acquisition of properties or recovery of advances as referred to in note 5.1 and 5.2 of the financial statements.

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

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

FOR K SINGH &ASSOCIATES
CHARTERED ACCOUNTANTS
Firm No. 012458N
Sd/-
Kultar Singh
Partner
Membership No. 091673
PLACE: Chandigarh
DATED:30/05/2019

Annexure- A to the Independent Auditors Report

Referred to in paragraph 1 under ‘Report on other Legal and Regulatory Requirements section of our report of even date. We report that:

1.(a) The company has maintained proper records showing full particulars including quantitative details and situation of its fixed assets.

(b) As explained to us, fixed assets have been physically verified by the management at reasonable intervals; no material discrepancies were noticed on such verification.

(c) In our opinion and according to the information and explanations given to us, the company immovable properties in its name. the title deeds of immovable properties are held in the name of the company.

2. As explained to us, inventories have been physically verified during the year by the management at reasonable intervals and no material discrepancy was noticed on physical verification of stocks by the management as compared to book records.

3. According to information and explanations given to us, the company has not granted unsecured loan to partiescovered under section 189 of the companies Act. 2013 Accordingly, the provisions of clause 3 (iii) (a) to (C) of the Order are not applicable to the Company and hence not commented upon.

4.The company has not given any loans to directors or to any other persons in whom the director is interested or given any guarantee or provided any security in connection with any loan taken by him or such person as covered under section 185 of the Companies act 2013

5The Company has not accepted deposits. Hence the provisions of Section 73 to 76 or any other relevant provisions of the Act and the rules framed there under are not applicable to the Company.

6. We have broadly reviewed the cost records maintained by the company pursuant to the companies (Cost Records and Audit) Rules,2014 as amended and prescribed by the central Government under subsection (1) of section 148 of the companies Act,2013 and are of the opinion that, prime facie the prescribed cost records have been made and maintained. We have, however, not made detailed examination of the cost records with view to determining whether they are accurate of complete. 7.(a) Based on our audit procedures and on the information and explanations given by the management, and on the basis of our examination of records of the company amount deducted /accrued in the books of accounts in respect of undisputed statutory dues including Provident Fund, Employees State Insurance,

Income-tax, GST,Custom Duty,and any other statutory dues with the appropriate authorities, b) According to the information and explanation given to us, no undisputed amount payable in respect above were in arrearsas at 31/03/2019for a period of more than six months from the date they become payable. c) Detail of dues of Excise Duty which have not been deposited as on 31/03/2019 on account of dispute are given below:

Name of the Statute ( Nature of Dues) From where Dispute is pending Period to which the amount relates Amount Involved(Rs in Lacs)
Central Excise Act Tribunal 2010-11 13.00
Tribunal 2004-05 to 2013-14 202.28
Commissioner 2014-15 77.71

8. Based upon the audit procedures performed and the information and explanations given by the management. The Company has defaulted in the repayment of dues to banks .The period and amount of default lender wise is appended:

Particulars Amount of default as the balance sheet  date Period of default Remarks, if any
1) Name of lenders: Punjab National Bank 21687.17 Lacs January,18 to 31st March 2019 to 31st Resolution plan has been submitted repayment to the bank for of loan and matter is under consideration.

9. Based upon the audit procedures performed and the information and explanations given by the management, the Company did not raise any money by way of initial public offer or further public offer (including debt instruments) and term loans during the year, therefore, the provisions of para 3(ix) of the Order is not applicable to the Company. 10.According to the information and explanations given to us, no fraud by the Company or on the Company by its officers or employees has been noticed or reported during the year. 11.The Company has paid any managerial remuneration during the financial year ending 31st March 2019 however the company has sought the necessary approval and mandated as per the provisions of section 197read with schedule V of the Companies Act2013.12.In our opinion and according to the information and explanations given to us, the Company is not a Nidhi company, therefore, the provisions of para 3(xii) of the Order is not applicable to the Company. 13.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 where applicable and details of such transactions have been disclosed in the financial statements as required by the applicable accounting standards.

14.According to the information and explanations given to us and based on our examination of the records of the Company, the Company has not made any preferential allotment or private placement of shares or fully or partly convertible debentures during the year.

15.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 directors or persons connected with him, therefore, the provisions of para 3(xv) of the Order is not applicable to the Company. 16.The Company is not required to be registered under section 45-IA of the Reserve Bank of India Act, 1934.

FOR K SINGH & ASSOCIATES
CHARTERED ACCOUNTANTS
Firm No. 012458N
Sd/-
Kultar Singh
Partner
Membership No. 091673
PLACE: Chandigarh
DATED:30/05/2019

Annexure - B to the Auditors Report

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

We have audited the internal financial controls over financial reporting of Sturdy Industries Limited ("the Company") as of 31st March, 2019 in conjunction with our audit of the standalone financial statements of the Company for the year ended on that date.

Managements Responsibility for Internal Financial Controls

The Companys management is responsible for establishing and maintaining internal financial controls based on the internal 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 (‘ICAI). These responsibilities include the design, implementation and maintenance of adequate internal financial controls that were operating effectively for ensuring the orderly and efficient conduct of its business, including adherence to companys policies, the safeguarding of its assets, the prevention and detection of frauds and errors, the accuracy and completeness of the accounting records, and the timely preparation of reliable financial information, as required under the Companies Act, 2013.

Auditors Responsibility

Our responsibility is to express an opinion on the Companys internal financial controls over financial reporting based on our audit. We conducted our audit in accordance with the Guidance Note on Audit of Internal Financial

Controls over Financial Reporting (the "Guidance Note") and the Standards on Auditing, issued by ICAI and deemed to be prescribed under section 143(10) of the Companies Act, 2013, to the extent applicable to an audit of internal financial controls, both applicable to an audit of Internal Financial Controls and, both issued by the Institute of Chartered Accountants of India. Those Standards and the Guidance Note require that we comply with ethical requirements and plan and perform the audit to obtain reasonable assurance about whether adequate internal financial controls 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 authorisations 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.

Inherent 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, 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 31st March, 2019, 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 ICAI.

forK Singh &Associates
Chartered Accountants
Firms Registration Number: 012458N
Sd/-
CA. KultarSingh
Partner
Membership Number: 091673
Place of Signature: New Delhi
Date: 30th May, 2019

15 Lease

The Company has not entered into any fresh operating leasing agreement during the year Current Financial Year.

16 Disclosure under Micro, Small, and Medium Enterprises Development Act,2006

For K.SINGH & ASSOICATES on behalf of the Board of Directors for STURDY INDUSTRIES LTD.
Chartered Accountants, Firm No 012458N
Sd/- Sd/- Sd/- Sd/- Sd/-
(Kultar Singh)

Amit Bhatti

Gurwinder Singh

Ramesh Gupta

Amit Gupta

P A R T N E R

(C.F.O)

(C.S)

(Director)

(Director)

M.No 091673

M.No A52827

DIN-0161363

DIN-0161417

Dated:-30/05/2019
Place:-CHANDIGARH