Tinna Rubber & Infrastructure Ltd Directors Report.

To

The Members of

TINNARUBBERAND INFRASTRUCTURE LIMITED

Tinna House,

No. 6, Sultanpur (Mandi Road)

Mehrauli, Delhi-110030

Report on the Standalone Ind AS Financial Statements Qualified Opinion

We have audited the accompanying standalone Ind AS financial statements of TINNA RUBBER AND INFRASTRUCTURE LIMITED ("the Company"), which comprise the Balance Sheet as at March 31, 2020, and the Statement of Profit and Loss (including other comprehensive income), the Statement of Cash Flows, and the Statement of Changes in Equity for the year then ended, and a summary of significant accounting policies and other explanatory information (hereinafter referred to as Ind AS Financial Statements).

In our opinion and to the best of our information and according to the explanation given to us, except for the effects of the matter described in the basis of Qualified Opinion section of our report, the aforesaid standalone Ind AS 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 31,2020, net loss and total comprehensive loss, changes in equity and its cash flows for the year ended on that date.

Basis for Qualified Opinion

The Company had incurred marketing promotion expenses, and other expenses, amounting to Rs. 80.43 lakhs during the financial year 2018-19 which has been amortized over a period of three years as is more appropriately referred in note no. 33(11) ofthe accompanying financial statement. The same is not in accordance with provisions of Ind AS 38 "Intangible Assets" (Para 69). Consequently, the net loss and total comprehensive income for the year ended 31st March, 2019 was understated by Rs. 53.621akhs, and other non-current assets and other current assets were overstated by Rs. 26.81 lakhs each. During the year, had the correct accounting treatment been followed by the Company, Loss for the year would have been lower by Rs. 26.81Lakhs and current assets lower by Rs. 26.81 Lakhs.

We conducted our audit in accordance with the Standards on Auditing (SAs) specified under section 143(10) of the Companies Act 2013, as amended ("The Act"). Our

responsibilities under those Standards are further described in the "Auditors Responsibilities for the Audit ofthe Standalone Financial Results" 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 statement under the provisions ofthe 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 obtained by us is sufficient and appropriate to provide a basis for our qualified opinion.

Emphasis of Matter

a) We draw attention to note no. 33(2) of the accompanying statement, in relation to accounting of financial guarantee provided by the company in respect of borrowings available by one of its associate and other group companies based in India and disclosure of the same as contingent liability as is more fully described therein.

b) We draw attention to Note no. 33(4)(a) of the accompanying Standalone Ind AS Financial Statements which describes the basis of fair value ofthe Companys investment of Rs. 643.36 lakhs in M/s BGK Infratech Private Limited and Rs. 37.29 lakhs in M/s Puja Infratech LLP which are to be valued at fair value through other comprehensive income in accordance with IND AS 109"Financial Instruments" as specified under section 133 of the Act, read with Rule 7 of the Companies (Accounts) Rules, 2014 and the Companies (Indian Accounting Standards) Rules, 2015. The Valuation involves significant management judgments and estimates on the valuation methodology and various assumptions used in determination of value in use/fair value by independent valuation experts as is more fully described in the aforesaid note. Based on the management policy, no change in fair value of the investee company is considered necessary for the current financial year.

c) We draw attention to Note no. 32(A)(a) of the accompanying Standalone Ind AS Financial Statement, with regard to provision of interest on term loan availed from India Bulls Commercial Credit Limited (IBCCL) as is more fully described in the above note. Since the matter is under arbitration, the impact of the outcome cannot be determined at the reporting date and hence not provided for.

d) We draw attention to Note no. 33(23) of the accompanying Standalone financial statement, which describes the uncertainties and the impact of Covid-19 pandemic on the Companys operations and financial

results as assessed by the management. The impact of these uncertainties on the Companys operations is dependent on future developments.

Our opinion is not modified in respect of above matters.

Key Audit Matters

Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the standalone financial statements of the current period. These matters were addressed in the context of our audit of the standalone financial statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters. We have determined the matters described below to be the key audit matters to be communicated in our report.

Sr. Key Audit Matter No. Auditors Response
1 Evaluation of uncertain tax positions Principal Audit Procedures
The Company has material uncertain tax positions including matters under dispute which involves significant judgment to determine the possible outcome of these disputes. Obtained details of completed tax assessments and demands for the year ended March 3 1, 2020from management. We involved our internal experts to challenge the managements underlying assumptions in estimating the tax provision and the possible outcome of the disputes. Our internal experts also considered legal precedence and other rulings in evaluating managements position on these uncertain tax positions. Additionally, we considered the effect of new information in respect of uncertain tax positions as at April 1, 2019to evaluate whether any change was required to managements position on these uncertainties.
Refer Note no. 32(A)(c) and to the Standalone Financial Statements
2 Taxation We evaluated the design and implementation of controls in respect of provision for current tax and the recognition and recoverability of deferred tax assets.
Significant judgments are required in determining provision of income taxes, both current and deferred, as well as the assessment of provision for uncertain tax position including estimates of interest and penalties where appropriate.
We discussed with management the adequate implementation of policies and control regarding current and deferred tax.
We examined the procedure in place for the current and deferred tax calculation for completeness and valuation and audited the related tax computation and estimates in the light of our knowledge of the tax circumstances. Our work was conducted with our tax specialist.
We performed the assessment of the material components impacting the tax expenses, balance and exposures. We reviewed and challenged the information reported by components with the support of our own tax specialist, where appropriate.
In respect of deferred tax assets and liabilities, we assess the appropriateness of managements assumptions and estimates to support deferred tax assets for tax losses carried forward and related disclosures in financial statements. Based on the procedure performed above, we obtained sufficient audit evidence to corroborate managements estimates regarding current and deferred tax balances.

Information Other than the Standalone Financial Statements and Auditors Report Thereon

The Companys Board of Directors is responsible for the other information. The other information comprises the information included in the Annual report but does not include the Ind AS financial statements and our auditors report thereon. The Annual Report is expected to be made available to us after the date of this Auditors Report. Our opinion on the Ind AS 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 Ind AS financial statements, our responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent with the 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 Charges with Governance for the Standalone Ind AS Financial Statements

The Companys Board of Directors is responsible for the matters stated in Section 134(5) ofthe Companies Act, 2013 ("the Act") with respect to the preparation of these standalone Ind AS financial statements that give a true and fair view ofthe financial position, financial performance including other comprehensive income, cash flows and changes in equity of the company in accordance with accounting principles generally accepted in India, including the Indian Accounting Standards specified under Section 133 of the Act, read with Rule 7 of the Companies (Accounts) Rules, 2014 and the Companies (Indian Accounting Standards) Rules, 2015.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 ofthe Ind AS financial statements that give atrue and fair view and are free from material misstatement, whether due to fraud or error.

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

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

Auditors Responsibility for the Audit of Ind AS Financial Statements

Our objectives are to obtain reasonable assurance about whether the Ind AS 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 Ind AS financial statements.

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

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

• Obtain an understanding of internal financial controls relevant to the audit in order to design audit procedures that are appropriate in the circumstances. Under section 143(3)(i) of the Act, we are also responsible for

expressing our opinion on whether the Company has adequate internal financial controls system in place and the operating effectiveness of such controls.

• Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and related disclosures made by management.

• Conclude on the appropriateness of managements use of the going concern basis of accounting and, based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Companys ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditors report to the related disclosures in the standalone Ind AS 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 agoing concern.

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

Materiality is the magnitude of misstatements in the standalone Ind AS financial statements that, individually or in aggregate, makes it probable that the economic decisions of a reasonably knowledgeable user of the Ind AS financial statements may be influenced. We consider quantitative materiality and qualitative factors in (i) planning the scope of our audit work and in evaluating the results of our work; and (ii) to evaluate the effect of any identified misstatements in the Ind AS financial statements.

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

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

From the matters communicated with those charged with governance, we determine those matters that were of most significance in the audit of the standalone Ind AS financial statements of the current period and are therefore the key auditmatters. 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, 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 a statement on the matters specified in paragraphs 3 and 4 ofthe Order, to the extent applicable.

2. As required by Section 143(3) ofthe 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, and the Statement of Profit and Loss including the Statement of Other Comprehensive Income, the Cash Flow Statement and the Statement of Changes in Equity dealt with by this Report are in agreement with the books of account.

(d) In our opinion, except for the effects/possible effects of the matters described in the Basis for Qualified Opinion paragraph above, the aforesaid standalone financial statements comply with the Indian Accounting Standards prescribed under Section 133 of the Act and the rules prescribed thereunder.

(e) On the basis of the written representations received from the directors as on 31st March, 2020 taken on record by the Board of Directors, none of the directors is disqualified as on 31st March, 2020 from being appointed as a director in terms of Section 164 (2) oftheAct.

(f) The qualifications relating to maintenance of accounts and other matters connected therewith are as stated in the Basis for Qualified Opinion paragraph above.

(g) The Company has paid/provided managerial remuneration of Rs. 56 Lakhs to a director upto November 2019 in accordance with provisions of section 197 read with Schedule V to the Act.

The Company has passed a Board resolution for increase in managerial remuneration from Rs.7 lakhs per month to Rs.10 lakhs per month which is subject to approval of shareholders by way of special resolution as required under the provisions of section 197, read together with Schedule V to the Act.

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

(i) With respect to the other matters to be included in the Auditors Report in accordance with Rule 11 of the Companies (Audit and Auditors) Rules, 2014, 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 Ind AS financial statements. (Refer note no. 32(A))

(ii) The Company has made provision, as required under the applicable law or accounting standards, for material foreseeable losses, if any, on long-term contracts including derivative contracts

(iii) There has been no delay in transferring amounts, required to be transferred, to the Investor Education and Protection Fund by the Company.

For V.R.Bansal& Associates
Chartered Accountants
Firm Registration No. 016534N
(Rajan Bansal)
Partner
Membership No. 093591
UDIN: 20093591AAAAKN9512
Place: Delhi
Dated: 01-08-2020

Annexure-A referred to in paragraph 1 under the heading "Report on other legal and regulatory requirements" of our report of even date

Re: TINNA RUBBER AND INFRASTRUCTURE LIMITED (the Company)

1. a. The Company has maintained proper records showing full particulars, including quantitative details and situation of

fixed assets

b. The Company has a phased periodical programme of physical verification of all fixed assets, which in our opinion is reasonable having regard to the size of the Company and the nature of its assets. No material discrepancies have been noticed on such verification.

c. As per explanation given to us, the title deeds of immovable properties are held in the name of the Company.

2. As per explanations given to us, inventories have been physically verified by the management at reasonable intervals. In our opinion, the frequency of the verification is reasonable and no material discrepancies have been noticed on physical verification of stocks as compared to b ook records.

3. The Company has not granted loans, secured or unsecured to Companies, firms, Limited Liability Partnership or other parties covered in the register maintained under section 189 of the Companies Act, 2013. Accordingly provisions of clause 3

(a) , (b), (c) ofthe Order are not applicable to the Company.

4. In our opinion and according to the information and explanation given to us, provisions of section 185 and 186 of the Companies Act, 2013, in respect of loans to directors including entities in which they are interested and in respect of loans and advances given, investments made and guarantees and securities given have been complied with by the Company. As per explanations given to us by the management, the approval to the scheme by the shareholders of the Company under Sections391 and 394 ofthe Act accounted for in the Financial Year 2017-18, shall be deemed to have their approval under the provisions of Section 186 and no separate approval from the shareholders shall be required.

5. According to the information and explanation given to us, the Company has not accepted any deposits as per the provisions of Section 73 to 76 or any other relevant provisions ofthe Companies Act and the rules framed thereunder.

6. We have broadly reviewed the cost records maintained by the Company pursuant to the rules made by the Central Government for the maintenance of cost records under section 148 (1) of the Companies Act, 2013, related to the manufacture of Rubber and Rubber Product-waste, Pairings and Scrap of Rubber and are ofthe opinion that, prima facie, the prescribed accounts and cost records have been maintained. We have not, however, made a detailed examination of the same.

7. (a). The Company is generally regular in depositing undisputed statutory dues including Provident Fund, Employees

State Insurance, Income-Tax, Sales-Tax, Service tax, Duty of Customs, Duty of Excise, Value Added Tax, Goods and Service Tax, Cess and any other statutory dues, however with delays. Interest on Sales Tax payable amounting to Rs.

10.09 lakhs is in arrears as at 31st March, 2020 concerned for a period of more than six months from the date they become payable.

(b) . According to the records of the company, the dues of income-tax, sales tax, service-tax, duty of custom, duty of exercise, value added tax and cess on account of any dispute are as follows

S.No. Name of Statute Nature of Dues Amount (Rs. in lakhs) Financial Year Forum where dispute is pending
1. Income Tax Act, 1961 Income Tax 73.50 2000-2001 High Court of Delhi
2. Income Tax Act, 1961 Income Tax 456.12 2013-2014 Income Tax Appellate Tribunal, Delhi
3. Income Tax Act, 1961 Income Tax 1.86 2009-2010 Income Tax Appellate Tribunal, Delhi
4. Income Tax Act,1961 Income Tax 651.61 2013-14 Commissioner oflncome Tax(Appeals) Delhi
5. Service Tax Service Tax (excluding penalties and interest) 50.12 01.04.2008 to 30.06.2012 Honble High Court, Allahabad
6. Excise Duty Excise Duty (excluding interest and penalty) 5.50 2010-2011 to 2011-2012 Customs, Excise & Service Tax Appellate Tribunal, West Zonal Bench, Ahmedabad
7. Excise Duty Excise Duty (excluding interest and penalty) 97.60 May, 2010 to July, 2012 Customs, Excise & Service Tax Appellate Tribunal, West Zonal Bench, Ahmedabad
8. Excise Duty Excise Duty (excluding interest and penalty) 1.45 2011-2012 Commissioner of Central Excise (Appeals), Mumbai
9. Excise Duty Excise Duty (excluding interest and penalty)&and reversal of CENVAT credit for input and input services 71.26 2012- 13 to 2013- 14 (up to December 2014) Customs, Excise & Service Tax Appellate Tribunal, West Zonal Bench, Chandigarh
10. Excise Duty Interest and Penalty on Excise Duty Liability 104.00 2012-2013 to 20132014 (up to December 2014) Customs, Excise & Service Tax Appellate Tribunal, West Zonal bench, Chandigarh
11. Excise Duty Excise Duty & Service Tax Liability (Excluding Interest and penalty on excise Duty & services Tax Liability 92.12 2014-2015 Customs, Excise & Service Tax Appellate Tribunal, Chandigarh
12. Custom Duty Countervailing Duty 40.61 2013-2014 Honble High Court ofDelhi
13. Custom Duty Countervailing Duty 110.97 2014-2015 Honble High Court ofDelhi
14. Custom Duty Countervailing Duty 113.22 2015-2016 Honble High Court ofDelhi
15. Custom Duty Countervailing Duty 85.48 2016-2017 Honble High Court ofDelhi
16. Custom Duty Countervailing Duty 6.14 April 2017 to June 2017 Honble High Court ofDelhi
17. Custom Duty Redemption Fine and Penalty 10.00 September 2015to31, October 2015 Customs Excise & Service Tax Appellant Tribunal, Allahabad

8. (a) The Company has taken loans from Banks and Financial Institutions. The delays noticed in repayment are as under:

Name of Bank/ Financial Institution Amount (Including Interest) (Rs. in lakhs) Due Date of Instalment Actual Date of Payment
India bulls Commercial Credit Limited 24.69 05-04-2019 17-04-2019
India bulls Commercial Credit Limited 6.64 05-04-2019 17-04-2019
India bulls Commercial Credit Limited 24.69 05-05-2019 16-05-2019
India bulls Commercial Credit Limited 6.64 05-05-2019 16-05-2019
India bulls Commercial Credit Limited 24.69 05-06-2019 11-06-2019
India bulls Commercial Credit Limited 6.64 05-06-2019 11-06-2019
India bulls Commercial Credit Limited 24.69 05-07-2019 23-07-2019
India bulls Commercial Credit Limited 6.64 05-07-2019 23-07-2019
India bulls Commercial Credit Limited 24.69 05-08-2019 27-08-2019
India bulls Commercial Credit Limited 6.64 05-08-2019 27-08-2019
India bulls Commercial Credit Limited 24.69 05-09-2019 12-09-2019
India bulls Commercial Credit Limited 6.64 05-09-2019 12-09-2019
India bulls Commercial Credit Limited 24.69 05-10-2019 28-10-2019
India bulls Commercial Credit Limited 6.64 05-10-2019 28-10-2019
India bulls Commercial Credit Limited 4.60 05-11-2019 26-11-2019
India bulls Commercial Credit Limited 24.69 05-12-2019 30-12-2019
India bulls Commercial Credit Limited 6.64 05-12-2019 30-12-2019
India bulls Commercial Credit Limited 24.69 05-01-2020 28-01-2020
India bulls Commercial Credit Limited 6.64 05-01-2020 28-01-2020
India bulls Commercial Credit Limited 18.46 05-02-2020 28-02-2020
India bulls Commercial Credit Limited 4.92 05-02-2020 28-02-2020

We draw attention to Note no. 32(A) (a) of the accompanying Standalone Ind AS Financial Statement, with regard to provision of interest on term loan availed from India Bulls Commercial Credit Limited (IBCCL) as is more fully described in the above note. Since the matter is under arbitration, the impact of the outcome cannot be determined at the reporting date and hence not provided for.

9. Based on the information and explanations given to us by the management, the Company has not raised any money by way of initial public offer/ further public offer and debt instruments. In our opinion and as per the information and explanations given to us, the monies raised by way of term loan were applied for the purpose for which, the said term loans were obtained.

10. During the course of our examination of the books of accounts carried out in accordance with generally accepted auditing practices in India, we have not come across any instance of fraud on the company or instance of fraud by the Company, either noticed or reported during the year, except one instance informed by the management regarding misdirection of deposit of one party to another and issuance ofunauthorised credit notes amounting Rs. 22.23 Lakhs and issuance of wrong invoices of Rs. 43.94 Lakhs by an ex-employee of the Company whose service had already been terminated. As informed, the Company has taken corrective steps by rectification of entries in the books of accounts wherever necessary. A sum of Rs. 16.57 Lakhs has been shown as recoverable as on 31/03/2020 on account of above, which the Company hopes to recover in full. The Company has lodged a complaint with Delhi Police in this regard. Please refer to N ote no. 33(21) of the financial statements.

11. The Company has paid/provided managerial remuneration of Rs. 56 Lakhs to a director upto November2019 in accordance with provisions of section 197 read with Schedule V to the Act.

The Company has passed a Board resolution for increase in managerial remuneration from Rs.7 lakhs per month to Rs.10 lakhs per month which is subject to approval of shareholders by way of special resolution as required under the provisions of section 197, read together with Schedule V to the Act.

12. In our opinion, the Company is not aNidhi Company. Therefore, the provisions of this clause of the order are not applicable to the Company and hence not commented upon.

13. As per the information given to us, all transactions with the related parties are in compliance with sections 177 and 188 of Companies Act, 2013 where applicable and the details have been disclosed in the Financial Statements etc. as required by the applicable accounting standards.

14. According to the information and explanations given to us and on an overall examination of the balance sheet, the Company has not made any preferential allotment or private placement of shares or fully or partly convertible debentures during the year under review and hence, reporting requirements under clause 3(14) are not applicable to the company and, not commented upon.

15. In our opinion and according to the information and explanations given to us, the Company has not entered into any non-cash transaction with directors or persons connected with him.

16. The Company is not required to be registered under sections 45-IAofthe Reserve Bank of IndiaAct, 1934.

For V. R. Bansal & Associates
Chartered Accountants
Firm Registration No. 016534N
(Rajan Bansal)
Partner
Membership No. 093591
UDIN: 20093591AAAAKN9512
Place: Delhi
Dated: 01-08-2020

Annexure -Bto the Auditors Report

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

To the Members of Tinna Rubber and Infrastructure Limited

We have audited the internal financial controls over financial reporting of TINNA RUBBER AND INFRASTRUCTURE LIMITED ("the Company") as of 31st March, 2020 in conjunction with our audit of the Standalone financial statements of the Company for the period 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 IntemalFinancial Controls over Financial Reporting issued by the Institute of Chartered Accountants oflndia (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 c ompanys 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 onAudit 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

Acompanys internal financial control over financial reporting is aprocess 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 ofthe assets ofthe 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 ofthe 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 March2020, 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 V. R. Bansal & Associates
Chartered Accountants
Firm Registration No. 016534N
(Rajan Bansal)
Partner
Membership No. 093591
UDIN: 20093591AAAAKN9512
Place: Delhi
Dated: 01-08-2020