Swastik Pipe Ltd Auditor Reports

To the Members of Swastik Pipe Limited

Report on Audit of Standalone Financial Statements

Opinion

We have audited the standalone financial statements of Swastik Pipe Limited ("the Company”) which comprise the Balance Sheet as at March 31, 2024, the Statement of Profit and Loss, Cash Flow Statement for the year then ended, and notes to the financial statements, including 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 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, 2024, and profit, and its cash flows for the year ended on that date.

Basis for Opinion

We conducted our audit in accordance with Standards on Auditing (SAs) specified under section 143(10) of the Companies Act, 2013. Our responsibilities under those Standards are further described in the Auditors Responsibilities for the Audit of the Financial Statements section of our report. We are independent of the Company in accordance with the Code of Ethics issued by the Institute of Chartered Accountants of India together with the ethical requirements that are relevant to our audit of the financial statements under the provisions of the Companies Act, 2013 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.

Emphasis of Matter

We draw attention to Note No. 31 (a) to the Financial Statements, in respect of LADT (Entry Tax) of Rs. 1949.76 Lakhs (without Interest) considered as contingent liabilities the matter is pending with Honble High Court of Punjab & Haryana at Chandigarh, Punjab. The matter is currently sub- judice.

We draw attention to note no. 35 to the financial statements, the value on realization of Current assets, Loans and Advances in the ordinary course of the business shall not be less than the amount at which they are stated, except the provision made by the company for disputed receivables and other current assets in the Balance Sheet which are subject to confirmation/reconciliation.

Our opinion is not modified in respect of the above matters.

Responsibility of Management 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, and cash flows of the Company in accordance with the accounting principles generally accepted in India, including the Accounting Standards specified under Section 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 financial statements that give a true and fair view and are free from material misstatement, whether due to fraud or error.

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

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

Auditors Responsibility for the Audit of Financial Statements

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

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

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

• Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances. Under section 143(3)(i) of the 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.

Report on Other Legal and Regulatory Requirements

1. As required by the Companies (Auditors Report) order,2020 ("the Order”), issued by the Central Government of India in terms of sub-section (11) of section 143 of the Companies Act, 2013, we give in the "Annexure A” statement on the matters specified in 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 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 accounts as required by law have been kept by the Company so far as it appears from our examinations of those books.

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

(d) In our opinion, the aforesaid Standalone Financial statements comply with the Accounting Standards specified under Section 133 of the Act, read with Rule 7 of the Companies (Accounts) Rules, 2014.

(e) On the basis of the written representations received from the directors as on 31st March, 2024 taken on the record by the Board of Directors, none of the directors is disqualified as on 31st March, 2024 from being appointed as a director in terms of Section 164 (2) of the Act.

(f) With respect to the adequacy of the internal financial controls over financial reporting of the Company and the operating effectiveness of such controls, refer to our separate Report in “Annexure B”.

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

I. The Company has disclosed the impact of pending litigations on its financial position in its financial statements as referred in note no 32 to 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 were no amounts which were required to be transferred to the Investor Education and Protection Fund by the Company.

IV. (i) In our opinion no funds have been advanced or loaned or invested (either from borrowed funds or share premium or any other sources or kind of funds) by the company to or in any other person(s) or entity(ies), including foreign entities (“Intermediaries”), with the understanding, whether recorded in writing or otherwise, that the Intermediary shall,

• 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;

(ii) In our opinion no funds have been received by the company from any person(s) or entity(ies), including foreign entities (“Funding Parties”), with the understanding, whether recorded in writing or otherwise, that the company shall,

• Whether, directly or indirectly, lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the Funding Party (Ultimate Beneficiaries”) or,

• Provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries; and

Based on such audit procedures that the auditor has considered reasonable and appropriate in the circumstances, nothing has come to their notice that has caused them to believe that the representations under sub -clause (iv)(i) and (iv)(ii) contain any material mis-statement.

V. The company has not declared or paid dividend during the year under audit, Hence, compliance of section 123 of the Companies Act, 2013 is not applicable in the case of the company.

VI. According to information and explanation provided by management, the company has used an accounting software Navision having provision for Audit Log and the audit log is configured in the Navision system. But the company has not produced before us documentary evidence in respect of the edit log report, hence we are unable to comment upon whether the audit trail feature in the software was enabled and operated throughout the year for all the transactions recorded in the software or whether there were any instances of the audit trail feature been tampered with and audit trail has been preserved by the company as the statutory requirement for record retention.

3. With respect to the matter to be included in the Auditors Report under section 197(16) of the Act: In our opinion and according to the information and explanations given to us, the remuneration paid by the Company to its directors during the current year is in accordance with the provisions of section 197 of the Act. The remuneration paid to any director is not in excess of the limit laid down under section 197 of the Act. The Ministry of Corporate Affairs has not prescribed other details under Section 197(16) of the Act which are required to be commented upon by us.

For O. Aggarwal & Co.

Chartered Accountants FRN: 005755N

Sd/-

CA SHUBHAM GUPTA Partner

Membership no.: 539733 UDIN- 24539733BKENJZ3940 Place: New Delhi Date: 29-05-2024

“Annexure A” to the Independent Auditors Report of Swastik Pipe Limited

Referred to in paragraph 1 under ‘Report on Other Legal and Regulatory Requirements of our

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

(i) (a) (A) The company has maintained proper records showing full particulars

including quantitative details and situation of Property, Plant and Equipment;

(B) The company has maintained proper records showing full particulars of intangible assets;

(b) The Property, Plant and Equipment have been physically verified by the management in a phased manner, designed to cover all the items over a period of three years, which in our opinion, is reasonable having regard to the size of the company and nature of its business. Pursuant to the program, a portion of the property, plant and equipment has been physically verified by the management during the year and no material discrepancies between the books records and the physical fixed assets have been noticed.

(c) The title deeds of immovable properties are held in the name of the company.

(d) The Company has not revalued any of its property, plant and equipment (including Right of Use assets) or intangible assets or both during the year.

(e) No proceedings have been initiated during the year or are pending against the Company as at 31st March, 2024 for holding any Benami Property under the Benami Transactions (Prohibition) Act, 1988 (45 of 1988) as amended in 2016 and rules made thereunder.

(ii) (a) The inventories were physically verified during the year by the Management at reasonable intervals. In our opinion and according to the information and explanations given to us, the coverage and procedure of such verification by the Management is appropriate having regard to the size of the Company and the nature of its operations. No discrepancies of 10% or more in the aggregate for each class of inventories were noticed on such physical verification of inventories when compared with books of account.

(b) According to the information and explanations given to us, the Company has been sanctioned working capital limits in excess of Rs. 5 crores, in aggregate, at points of time during the year, from banks or financial institutions on the basis of security of current assets. In our opinion and according to the information and explanations given to us, the quarterly returns or statements comprising (stock statements or book debt statements) filed by the Company with such banks or financial institutions are materially in agreement with the unaudited books of account of the Company.

(iii) As per information and explanation provided to us, during the year, the company has not made any investments in or provided any guarantee or security or granted any loans or advances in the nature of loans, secured or unsecured, to any companies, firms, Limited Liability Partnerships or other parties. Hence, para (a), (b), (c), (d), (e) and (f) of the said CARO are not applicable to the company.

(iv) As per information and explanations provided to us, during the year, the company has not given loans, investment, guarantees, and security as per the provision of section 185 and 186 of the Companies Act

2013. However, company has complied with provisions of section 186 in respect of opening investment outstanding in books.

(v) In our opinion and according to the information and explanations given to us, the Company has complied with the directives issued by the Reserve Bank of India and the provisions of Sections 73 to 76 or any other relevant provisions of the Companies Act, 2013 and the Companies (Acceptance of Deposits) Rules, 2015 as amended, with regard to the deposits or deemed deposits accepted by the company.

(vi) We have broadly reviewed the cost records maintained by the company pursuant to the order made by the Central Government for the maintenance of cost records, u/s 148(1) of the Companies Act, 2013 and are of opinion that prima facie the prescribed records and accounts have been maintained by the company. However, we have not made a detailed examination of these records to verify whether they are accurate and complete.

(vii) (a) According to information and explanations given to us and on the basis of our examination of the books of accounts and records, the Company has been generally regular in depositing 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 any other statutory dues with the appropriate authorities. According to the information and explanation given to us, no undisputed amounts payable in respect of the above were in arrears as at march 31, 2024 for a period of more than six months from the date on when they became payable except mentioned below.

Name of the Statute	Nature of Dues	Amount Rs in Lakhs	Period to which the amount relates	Date of payment	Remarks
Income Tax Act, 1961	Tax Deducted at Source	5.99	2023-24	Not paid till date
Income Tax Act, 1961	Tax Deducted at Source	0.46	2022-23	Not paid till date
Income Tax Act, 1961	Tax Deducted at Source	0.21	2017-18	Not paid till date
Income Tax Act, 1961	Tax Deducted at Source	0.84	2016-17	Not paid till date
Income Tax Act, 1961	Tax Deducted at Source	0.04	2012-13	Not paid till date	Demand stands as per portal. However, the same has to be paid after reconciliation.
Income Tax Act, 1961	Tax Deducted at Source	0.01	2011-12	Not paid till date
Income Tax Act, 1961	Tax Deducted at Source	0.59	2010-11	Not paid till date
Income Tax Act, 1961	Tax Deducted at Source	0.07	2009-10	Not paid till date
Income Tax Act, 1961	Tax Deducted at Source	0.63	2008-09	Not paid till date
Income Tax Act, 1961	Tax Deducted at Source	0.79	2007-08	Not paid till date
Income Tax Act, 1961	Income Tax	2.92	2016-17	Not paid till date
Income Tax Act, 1961	Income Tax	0.07	2008-09	Not paid till date	Demand stands as per portal. However, the same has to be paid after reconciliation.
Income Tax Act, 1961	Income Tax	2.07	2017-18	Not paid till date
Income Tax Act, 1961	Income Tax	8.19	2013-14	Not paid till date

(b) The dues of 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 any other statutory dues that have not been deposited on account of any dispute, are as follows:

Name of the Statute	Nature of Dues	Amount Rs in Lakhs	Amount paid under protest Rs in Lakhs	Period to which the amount relates	Forum where dispute is pending
U.P. Sales Tax Department	Entry tax	435.43	435.43	2008-11	Allahabad High court
Haryana Entry tax	LADT Demand	1,949.76	-	Earlier Years	Punjab & Haryana High court

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

(ix) (a) Based on our audit procedure and according to information and explanations given to us, the company has not defaulted in repayment of loans or other borrowings or in the payment of interest thereon to the any lender.

(b) The Company has not been declared willful defaulter by any bank or financial institution or other lender.

(c) The Company has utilized term loans for the purpose for which the loans were obtained.

(d) The Company has not utilized the funds raised on short-term basis for long-term purposes.

(e) The Company does not have any subsidiary or associate or joint venture during the year accordingly reporting under clause (ix)(e) of the Order is not applicable.

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

(x) (a) Based upon the audit procedures performed and the information and explanations given by the management, the company has not raised moneys by way of initial public offer or further public offer (including debt instruments) during the year, hence, reporting under clause (x)(a) of the Order is not applicable.

(b) On the basis of the Examination of records and according to the information and explanation given to us, the company has not made any preferential allotment or private placement of shares or convertible debentures (fully, partially or optionally convertible) during the year. Therefore, clause no. x(b) of the said Order is not applicable.

(xi) (a) Based upon the audit procedures performed and the information and explanations given by the management, we report that no fraud by the company or on the company by its officers or employees has been noticed or reported during the year.

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

(c) According to the information and explanation provided to us, there were no whistle blower complaints received by the Company during the year.

(xii) The Company is not a Nidhi Company. Therefore, the provisions of clause (xii) of the Order are not applicable to the Company.

(xiii) In our opinion and according to the information and explanation provided to us, all transactions with the related parties are in compliance with section 177 and 188 of Companies Act, 2013 and the details 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 the entity.

(b) We have considered the internal audit reports issued till date to the Company during the year under audit.

(xv) In our opinion and according to the information and explanations provided to us, the company has not entered into any non-cash transactions with directors or persons connected with him, accordingly Para 3(xv) of the Order is not applicable.

(xvi) In our opinion, the company is not required to be registered under section 45 IA of the Reserve Bank of India Act, 1934 and hence, reporting under clause (xvi)(a), (b) and (c) of the order is not applicable.

(xvii) The Company has not incurred any cash losses during the financial year and in the immediately preceding financial year.

(xviii) There has been no resignation of the statutory auditors of the Company during the year under audit.

(xix) On the basis of the Examination of records and according to the information and explanation given to us, on the basis of the financial ratios, ageing and expected dates of realization of financial assets and payment of financial liabilities, other information accompanying the financial statements, the auditors knowledge of the Board of Directors and management plans, the auditor is of the opinion that no material uncertainty exists as on the date of the audit report that Company is capable of meeting its liabilities existing at the date of balance sheet as and when they fall due within a period of one year from the balance sheet date. We, however, state that this not an assurance as to the future viability of the company. We further state that our reporting is based on the facts upto the date of 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) In our opinion and according to the information and explanation given to us, Company has made the provision for CSR in the books of account according to the provisions of section 135, however, the unspent Amount is of Rs. 8,85,542.00 as on balance sheet date, in respect of other than ongoing

projects. The unspent amount required to be transferred to a Fund specified in Schedule VII to the Companies Act within a period of six months from the expiry of the financial year in compliance with second proviso to sub-section (5) of section 135 of the said Act since the time period for such transfer i.e. six months from the end of the financial year has not elapsed till the date of our report.

(b) Based upon the audit procedures performed and the information and explanations given by the management, there is no amount remaining unspent under sub-section (5) of section 135 of the Companies Act, pursuant to any ongoing project and clause (xx)(b) of the order is not applicable.

For O. Aggarwal & Co.

Chartered Accountants FRN: 005755N

Sd/-

CA SHUBHAM GUPTA Partner

Membership no.: 539733 UDIN- 24539733BKENJZ3940 Place: New Delhi Date: 29-05-2024

“Annexure B” to the Independent Auditors Report of even date on the Financial Statements of

Swastik Pipe Limited

Referred to in paragraph 2(e) under ‘Report on Other Legal and Regulatory Requirements of our report of even date to the financial statements of the Company for the year ended March 31, 2024:

We have audited the internal financial controls over financial reporting of Swastik Pipe Limited (“the Company”) as of March 31, 2024 in conjunction with our audit of the 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”. 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 (ICAI). Those Standards and the Guidance Note require that we comply with ethical requirements and plan and perform the audit to obtain reasonable assurance about whether adequate internal financial controls over financial reporting was established and maintained and if such controls operated effectively in all material respects.

Our audit involves performing procedures to obtain audit evidence about the adequacy of the internal financial controls system over financial reporting and their operating effectiveness. Our audit of internal financial controls over financial reporting included obtaining an understanding of internal financial controls over financial reporting, assessing the risk that a material weakness exists, and testing and evaluating the design and operating effectiveness of internal control based on the assessed risk. The procedures selected depend on the auditors judgment, including the assessment of the risks of material misstatement of the financial statements, whether due to fraud or error.

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

Meaning of Internal Financial Controls Over Financial Reporting

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

(1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the company; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the company are being made only in accordance with authorizations of management and directors of the company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the companys assets that could have a material effect on the financial statements”

Inherent Limitations of Internal Financial Controls 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 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 O. Aggarwal & Co.

Chartered Accountants FRN: 005755N

Sd/-

CA SHUBHAM GUPTA Partner

Membership no.: 539733 UDIN: 24539733BKENJZ394 Place: New Delhi Date: 29-05-2024