Tata Steel Long Products Ltd Directors Report.

To the Members of Tata Steel Long Products Limited (formerly Tata Sponge Iron Limited)

Report on the Audit of the Standalone Financial Statements Opinion

1. We have audited the accompanying Standalone Financial Statements of Tata Steel Long Products Limited ("the Company"), which comprise the Balance Sheet as at March 31, 2020, the Statement of Profit and Loss (including Other Comprehensive Income), the Statement of Changes in Equity and the Statement of Cash Flows for the year then ended, and Notes to the Standalone Financial Statements, including a summary of significant accounting policies and other explanatory information (hereinafter referred to as "the Standalone Financial Statements").

2. In our opinion and to the best of our information and according to the explanations given to us, the aforesaid Standalone Financial Statements give the information required by the Companies Act, 2013 ("the Act") in the manner so required and give a true and fair view in conformity with the accounting principles generally accepted in India, of the state of affairs of the Company as at March 31, 2020, its total comprehensive income (comprising loss and other comprehensive income), its changes in equity and its cash flows for the year then ended.

Basis for opinion

3. 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.

Emphasis of Matter

4. We draw your attention to Note 45 to the Standalone Financial Statements which explains the uncertainties and managements assessment of the financial impact due to the lockdown / restrictions related to the COVID-19 pandemic imposed by the Governments, for which a definitive assessment of the impact is dependent upon future economic conditions. Our opinion is not modified in respect of this matter.

Key audit matters

5. 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 year. 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.

Key Audit Matter How our audit addressed the key audit matter
Assessment of Purchase Price Allocation on acquisition of business in accordance with Ind AS 103, Business Combination and the appropriateness of the carrying value of the acquired Property, plant and equipment, Right-of-use assets, Other intangible assets and Goodwill as at the year end Our procedures included the following:
• We understood from the management, assessed the design and tested the operating effectiveness of the Companys key controls over the accounting of business combination and the impairment assessment.
[Refer to Notes 02.07, 02.08 and 38 to the Standalone Financial Statements – "Business Combinations"] • We have evaluated the competence, capabilities and objectivity of the managements expert engaged for the PPA, obtained an understanding of the work of the expert, and evaluated the appropriateness of the experts work as audit evidence.
On April 9, 2019, the Company acquired the steel division of Usha Martin Limited, pursuant to the Business Transfer Agreement ("BTA") as described in the aforesaid Note. The Company determined the acquisition to be a business combination in accordance with Ind AS 103 ‘Business Combinations. Ind AS 103 requires the identified assets and liabilities be recognised at fair value at the date of acquisition with the excess of the acquisition cost over the identified fair value of recognised assets and liabilities as goodwill. • We have traced the value of the consideration transferred with reference to the BTA.
• We have carried out our evaluation, by involving our experts ("auditors expert") to :
The Company appointed independent professional valuers to perform valuation of assets for the purpose of allocation of the consolidated purchase price to the respective assets and liabilities acquired (hereinafter referred to as ‘the purchase price allocation or ‘the PPA). The Management determined that the fair values of the net identifiable assets acquired was Rs. 404,297.54 lakh as part of the PPA and accordingly, the consideration paid in excess of the net assets acquired resulted in recognition of Goodwill of Rs. 565.55 lakh. i) review the PPA and assess the reasonableness of the underlying key assumptions used in determining the fair value of assets and liabilities as at the acquisition date.
ii) review the managements assessment / method including the key assumptions related to the projections, the discount rate used in the assessment of the carrying values as at the year end.
• We have verified the managements computation of goodwill.
• We have also assessed the adequacy and appropriateness of the disclosures made in the Standalone Financial Statements.
Significant assumptions and estimates are used as of the date of acquisition in the determination of the fair values of the identified assets acquired and liabilities assumed in the transaction.
Further, as at the year end, significant judgements were made by the management in respect of the future projections and the discount rate used in applying the value in use method in assessing the carrying value of the acquired Property, plant and equipment (including Capital work-in-progress), Right-of-use assets, Other intangible assets and the Goodwill. Based on our procedures performed above, we noted that the PPA of the consideration is in accordance with Ind-AS 103 Business Combination and that the carrying value of the acquired Property, plant and equipment (including Capital work-in-progress), Right-of- use assets, Other intangible assets and Goodwill as at the year end was appropriate.
Accordingly, these are considered to be a key audit matter. The Management concluded that the recoverable amount is higher than their carrying values and that no impairment provision is warranted.
Recovery of expenses and related disclosures of contingent liabilities for Radhikapur Coal Block Our audit procedures included the following:
[Refer to Note 33(d) and 33(e) to the Standalone Financial Statements] • Evaluation of the design and testing of operating effectiveness of the controls implemented by the management to assess the recoverability of expenses incurred towards Radhikapur (East) Coal Block and related disclosures in the Standalone Financial Statements.
The Company has financial exposure aggregating Rs. 17,892.69 lakh (reflected in the Standalone Financial Statements as capital advances – Rs. 16,791.69 lakh, property, plant and equipment – Rs. 566.00 lakh, and capital work in progress – Rs. 535.00 lakh) incurred in earlier years, on the Radhikapur (East) Coal Block, which was deallocated pursuant to the Order of the Honble Supreme Court of India in 2014. • Obtained an updated understanding of the basis of the managements judgement including discussion with the Companys inhouse legal counsel.
The Coal Mines (Special Provisions) Rules, 2014, promulgated pursuant to the aforesaid Order, prescribes that the successful bidder will be called upon to pay to the prior allotee, the expenses incurred by the prior allotee towards land and mine infrastructure. The Company has submitted the statement of expenses and other details to the Nominated Authority of the Ministry of Coal (‘MoC). The above matter is pending as on the balance sheet date. • Tested a sample of expenses incurred on the coal block.
• Considered the legal opinion obtained by the management to understand the status and the managements assessment of the likely outcome of the on-going litigation.
The MoC had also issued notice for invocation of the bank guarantee of Rs. 3,250 lakh in November 2012 towards performance conditions for original allocation of the coal block for which the Company filed a writ petition in Honble High Court of Delhi. The bank guarantee had lapsed and not renewed after November 2015 as the Honble High Court of Delhi had directed the Company to keep the bank guarantee live as well as to the MoC to take decision by that date, against which however, there was no communication from MoC by the said date. MoC again issued notice for invocation of bank guarantee / depositing amount in December 2015 for which the Company again filed a writ petition before Honble High Court of Delhi. The Honble High Court of Delhi in its judgement of May 27, 2020 remanded the matter to the MoC to consider afresh on the aspect whether the delay in achieving the milestones is attributable to the Company and has directed the Company to ensure that the bank guarantee furnished by it is kept alive till the said decision is rendered by the MoC. Pending finalisation of the matter, the amount has been disclosed as contingent liability. • Obtained evidence supporting the on-going discussions of the Company with the MoC/ Nominated Authority of MoC.
Based on the above work performed, we found the managements judgement on assessment of recoverability of the related expenses incurred and the disclosure of the contingent liability in respect of performance guarantee for coal block allocation, to be reasonable.
This is considered to be a key audit matter as significant judgements are involved regarding recoverability of the aforesaid amount incurred and possible obligation related to bank guarantee that is subject to decision/approvals of the regulatory authorities.

Other Information

6. The Companys Board of Directors is responsible for the other information. The other information comprises the information in the Corporate Profile and the Directors Report along with the Annexures to the Directors Report included in the Companys annual report (titled as Tata Steel Long Products Limited Integrated Report & Annual Accounts 2019-20), but does not include the 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 in the audit or otherwise appears to be materially misstated. If, based on the work we have performed, we conclude that there is a material misstatement of this other information, we are required to report that fact. We have nothing to report in this regard.

Responsibilities of management and those charged with governance for the Standalone Financial Statements

7. The Companys Board of Directors is responsible for the matters stated in section 134(5) of 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, changes in equity 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 of the assets of the Company and for preventing and detecting frauds and other irregularities; selection and application of appropriate accounting policies; making judgments and estimates that are reasonable and prudent; and design, implementation and maintenance of adequate internal 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.

8. 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 is also responsible for overseeing the Companys financial reporting process.

Auditors responsibilities for the Audit of the Standalone Financial Statements

9. Ourobjectivesaretoobtainreasonableassuranceaboutwhether 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.

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

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

• Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances. Under Section 143(3)(i) of the Act, we are also responsible for expressing our opinion on whether the company has adequate internal financial controls with reference to Standalone Financial Statements 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.

11. 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.

12. 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.

13. 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

14. 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 B a statement on the matters specified in paragraphs 3 and 4 of the Order, to the extent applicable.

15. As required by Section 143(3) of the Act, we report that:

(a) We have sought and obtained all the information and explanations which to the best of our knowledge and belief were necessary for the purposes of our audit.

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

(c) The Balance Sheet, the Statement of Profit and Loss (including other comprehensive income), the Statement of Changes in Equity and the Statement of Cash Flows dealt with by this Report are in agreement with the books of account.

(d) In our opinion, the aforesaid Standalone Financial Statements comply with the Accounting Standards specified under Section 133 of the Act.

(e) On the basis of the written representations received from the directors taken on record by the Board of Directors, none of the directors is disqualified as on March 31, 2020 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 with reference to Standalone Financial Statements of the Company and the operating effectiveness of such controls, refer to our separate Report in "Annexure A".

(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, 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, if any, of pending litigations as at March 31, 2020 on its financial position in its Standalone Financial Statements – Refer Note 33 to the Standalone Financial Statements;

ii. The Company has long-term contracts including derivative contracts as at March 31, 2020 for which there were no material foreseeable losses. Refer Note 46 to the Standalone Financial Statements;

iii. There has been no delay in transferring amounts, required to be transferred, to the Investor Education and Protection Fund by the Company during the year ended March 31, 2020, except for amounts aggregating to Rs. 5.31 lakh, which according to information and explanations provided by the management is held in abeyance due to pending legal cases - Refer Note 47 to the Standalone Financial Statements.

iv. The reporting on disclosures relating to Specified Bank Notes is not applicable to the Company for the year ended March 31, 2020.

16. As stated in the note 36(C) to the Standalone Financial Statements, the Company has paid/ provided remuneration amounting to Rs. 192.71 lakh to managing directors which is subject to approval of shareholders by way of special resolution in the ensuing annual general meeting as required by section 197 read with Schedule V to the Act.

For Price Waterhouse & Co Chartered Accountants LLP
Firm Registration Number: 304026E/E-300009
Chartered Accountants
Pinaki Chowdhury
Partner
Kolkata Membership Number 057572
June 9, 2020 UDIN: 20057572AAAAAL9421

ANNEXURE A TO INDEPENDENT AUDITORS REPORT

Referred to in paragraph 15(f) of the Independent Auditors Report of even date to the members of Tata Steel Long Products Limited (formerly Tata Sponge Iron Limited) on the Standalone Financial Statements for the year ended March 31, 2020

Report on the Internal Financial Controls with reference to the Standalone Financial Statements under Clause (i) of Sub-section 3 of Section 143 of the Act

1. We have audited the internal financial controls with reference to the Standalone Financial Statements of Tata Steel Long Products Limited ("the Company") as of March 31, 2020 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

2. 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 Act.

Auditors Responsibility

3. Our responsibility is to express an opinion on the Companys internal financial controls with reference to Standalone Financial Statements 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 deemed to be prescribed under section 143(10) of the Act 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 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 with reference to Standalone Financial Statements was established and maintained and if such controls operated effectively in all material respects.

4. Our audit involves performing procedures to obtain audit evidence about the adequacy of the internal financial controls system with reference to Standalone Financial Statements and their operating effectiveness. Our audit of internal financial controls with reference to Standalone Financial Statements included obtaining an understanding of internal financial controls with reference to Standalone Financial Statements, 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 judgement, including the assessment of the risks of material misstatement of the Standalone Financial Statements, whether due to fraud or error.

5. 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 with reference to Standalone Financial Statements.

Meaning of Internal Financial Controls with reference to financial statements

6. A companys internal financial controls with reference to financial statements 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 controls with reference to financial statements 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 with reference to the financial statements

7. Because of the inherent limitations of internal financial controls with reference to financial statements, 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 with reference to financial statements to future periods are subject to the risk that the internal financial controls with reference to financial statements may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

Opinion

8. In our opinion, the Company has, in all material respects, an adequate internal financial controls system with reference to the Standalone Financial Statements and such internal financial controls with reference to the Standalone Financial Statements were operating effectively as at March 31, 2020, 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. (Also refer paragraph 4 of the main audit report).

For Price Waterhouse & Co Chartered Accountants LLP
Firm Registration Number: 304026E/E-300009
Chartered Accountants
Pinaki Chowdhury
Partner
Kolkata Membership Number 057572
June 9, 2020 UDIN: 20057572AAAAAL9421

ANNEXURE B TO INDEPENDENT AUDITORS REPORT

Referred to in paragraph 14 of the Independent Auditors Report of even date to the members of Tata Steel Long Products Limited (formerly Tata Sponge Iron Limited) on the Standalone Financial Statements as of and for the year ended March 31, 2020 i. (a) The Company is maintaining proper records showing full particulars, including quantitative details and situation, of fixed assets.

(b) The fixed assets of the Company are physically verified by the Management according to a phased programme 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 the nature of its assets. Pursuant to the programme, a portion of the fixed assets has been physically verified by the Management during the year and no material discrepancies have been noticed on such verification.

(c) The title deeds of immovable properties, as disclosed in Note 3 on Property, Plant and Equipment and Note 4 on Right-of-use assets to the standalone financial statements, are held in the name of the Company, except for the following immovable properties acquired pursuant to the business acquisition as stated in Notes 3.01 and 4 (f) respectively to the standalone financial statements, whose title deeds are not held in the Companys name:

Particulars Gross Block Net Block
(Rs. in lakh) (Rs. in lakh)
Freehold Land 7,735.05 7,735.05
Building 71.10 62.89
Leasehold Land 86.54 83.66
Leasehold Building 330.00 322.63

Further, a reconciliation of the title deeds (which are in the physical possession of a bank for loans taken by the Company) in respect of freehold land (as reflected in underlying books and records of the Company) aggregating Rs. 30.80 lakh and gross block of leasehold buildings aggregating Rs. 3.02 lakh (net block Rs. 1.82 lakh), with the confirmation from the bank, is under process. ii. The physical verification of inventory (excluding stocks with third parties) have been conducted at reasonable intervals by the Management during the year. In respect of inventory lying with third parties, these have substantially been confirmed by them. The discrepancies noticed on physical verification of inventory as compared to book records were not material. 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. Therefore, the provisions of Clause 3(iii), (iii)(a), (iii)(b) and (iii)(c) of the said Order are not applicable to the Company. iv. In our opinion, and according to the information and explanations given to us, the Company has complied with the provisions of Section 185 and 186 of the Companies Act, 2013 in respect of the loans and investments made, and guarantees and security provided by it, as applicable. v. The Company has not accepted any deposits from the public within the meaning of Sections 73, 74, 75 and 76 of the Act and the Rules framed there under to the extent notified. vi. Pursuant to the rules made by the Central Government of India, the Company is required to maintain cost records as specified under Section 148(1) of the Act in respect of its products.

We have broadly reviewed the same, and are of the opinion that, prima facie, the prescribed accounts and records have been made and maintained. We have not, however, made a detailed examination of the records with a view to determine whether they are accurate or complete. vii. (a) According to the information and explanations given to us and the records of the Company examined by us, in our opinion, the Company is generally regular in depositing undisputed statutory dues in respect of professional tax and income taxes, though there has been a slight delay in a few cases, and is regular in depositing undisputed statutory dues, including, provident fund (refer remarks below), employees state insurance, sales tax, service tax, duty of customs, duty of excise, value added tax, cess, goods and service tax and other material statutory dues, as applicable, with the appropriate authorities. Also refer note 37.03 to the financial statements regarding managements assessment on certain matters relating to provident fund.

Further, for the period March 1, 2020 to March 31, 2020, the Company has paid Goods and Service Tax and filed Form GSTR 3B after the due date but within the timelines allowed by the Central Board of Indirect Taxes and Customs under the Notification Number 31/2020 dated April 3, 2020 on fulfilment of conditions specified therein, other than for one registration for which the Company is yet to pay Goods and Service Tax and file Form GSTR 3B for the period March 1, 2020 to March 31, 2020, for which the timeline is June 24, 2020 as per the aforesaid Notification.

(b) According to the information and explanations given to us and the records of the Company examined by us, there are no dues of service tax and goods and service tax as at March 31, 2020 which have not been deposited on account of any dispute. The particulars of dues of Income -tax, sales tax, duty of customs, duty of excise and value added tax as at March 31, 2020 which have not been deposited on account of a dispute, are as follows:

Name of the statute Nature of dues Amount (Rs. in lakh) Period to which the amount relates Forum where the dispute is pending
Income Tax Act, 1961 Income tax 640.43 2014-15 Commissioner of Income Tax (Appeals)
2015-16
Income Tax Act, 1961 Income tax 221.09 2013-14 Income Tax Appellate Tribunal
Central Sales Tax Act, 1957 Central Sales Tax 66.71 2005-06 High Court of Orissa
Central Sales Tax Act, 1957 Central Sales Tax 6.02 1987-88 Deputy Commissioner of Commercial Taxes
1992-93
1993-94
1998-99
Orissa Sales Tax Act, 1947 Sales Tax 2.45 1992-93 Assistant Commissioner of Sales Tax
2000-01
Orissa Sales Tax Act, 1947 Sales Tax 6.10 1987-88 Deputy Commissioner of Commercial Taxes
1989-90
1990-91
1988-89
Customs Act, 1962 Customs Duty 3311.05 2012-13 Customs, Excise and Service Tax Appellate Tribunal
The Central Excise Act, 1944 Excise Duty 205.45 2011-12 Customs, Excise and Service Tax Appellate Tribunal
Orissa Value Added Value Added Tax 7.14 2005-06 Commissioner of Commercial Taxes
Tax Act, 2004

viii. According to the records of the Company examined by us and the information and explanation given to us, the Company has not defaulted in repayment of loans or borrowings to any financial institution or bank or Government or dues to debenture holders, as applicable, as at the balance sheet date. ix. In our opinion, and according to the information and explanations given to us, the moneys raised by way of further public offer (rights issue) and term loans have been applied, on an overall basis, for the purposes for which they were obtained. x. During the course of our examination of the books and records of the Company, carried out in accordance with the generally accepted auditing practices in India, and according to the information and explanations given to us, we have neither come across any instance of material fraud by the Company or on the Company by its officers or employees, noticed or reported during the year, nor have we been informed of such case by the Management. xi. As stated in the note 36(C) to the financial statements, the Company has paid/ provided remuneration amounting to Rs. 192.71 lakh to managing directors which is subject to approval of shareholder by way of special resolution in the ensuing annual general meeting as required by section 197 read with Schedule V to the Act . Also Refer paragraph 16 of the Independent Auditors Report of even date. xii. As the Company is not a Nidhi Company and the Nidhi Rules, 2014 are not applicable to it, the provisions of Clause 3(xii) of the Order are not applicable to the Company.

xiii. The Company has entered into transactions with related parties in compliance with the provisions of Sections 177 and 188 of the Act. The details of related party transactions have been disclosed in the standalone financial statements as required under Indian Accounting Standard (Ind AS) 24, Related Party Disclosures specified under Section 133 of the Act. xiv. The Company has not made any preferential allotment or private placement of shares or fully or partly convertible debentures during the year under audit. Accordingly, the provisions of Clause 3(xiv) of the Order are not applicable to the Company. xv. The Company has not entered into any non cash transactions with its directors or persons connected with him. Accordingly, the provisions of Clause 3(xv) of the Order are not applicable to the Company. xvi. The Company is not required to be registered under Section 45-IA of the Reserve Bank of India Act, 1934. Accordingly, the provisions of Clause 3(xvi) of the Order are not applicable to the Company.

For Price Waterhouse & Co Chartered Accountants LLP
Firm Registration Number: 304026E/E-300009
Chartered Accountants
Pinaki Chowdhury
Partner
Kolkata Membership Number 057572
June 9, 2020 UDIN: 20057572AAAAAL9421