* Pursuant to the sub-division of the equity shares of the Company, all the issued, subscribed and paid-up equity shares of nominal value of Rs. 100/- each (Rupees One Hundred Only) of the Company, subdivided into equity shares of Rs. 10/- (Rupee Ten Only) each fully paid-up w.e.f 10.03.2022

b) Rights, preferences and restrictions attached to shares

The company has one class of equity shares having face value of Rs. 10 each. Each shareholder is eligible for one vote per share held. The dividend proposed (if any) by the Board of Directors is subject to the approval of the shareholders in the ensuing Annual General Meeting, except in case of interim dividend. In the event of liquidation, the equity shareholders are eligible to receive the remaining assets of the Company after distribution of all preferential amounts, in proportion to their shareholding.

The company has issued all equity shares for cash except 377360 equity shares for Rs. 30,00,01,200/-, which have been allotted to unsecured loan holders by way of conversion of loan into equity shares on 31.07.2021

The Company has allotted fully paid up 2829910 shares by way of bonus share on 31.03.2022, other than such allotment company has not issued any bonus shares in last five years.

The Company has not bought back shares in last five years.

NOTE 32: CONTINGENT liabilities and events occuring after balance sheet

DATE

a) The Haryana Government levied a Local Area Development Tax (the LADT Act) w.e.f. 05.05.2000 on the manufacturing units in the state of Haryana on the entry of goods for use and consumption. Some units have challenged the Act in the Hon'ble Punjab and Haryana High Court. The matter is currently sub-judice. The Hon'ble Punjab and Haryana High Court disallowed the petition in December, 2001 and the units, had by a Special Leave Petition, and challenged the order of High Court in the Hon'ble Supreme Court. The Hon'ble Supreme Court referred the matter to a 'five judges' Constitutional Bench, which laid certain parameters to examine the Act on those lines. On the basis of these parameters the Hon'ble High Court declared the Act to be ultra-virus on 14^th March, 2007. Since, this issue was being canvassed by various High Courts, the Hon'ble Supreme Court gave an Interim Order that those states where the High Courts have given judgment in favor of the petitioner, and no tax would be collected. In the meantime, the Haryana Government has repealed the LADT

Act and introduced another Act by the name of 'Entry Tax' on the same lines. That Act was also been held ultra-virus by the High Court.

In the meantime, in October 2009 the Hon'ble Supreme Court vide order dated 30-10-2009, directing the Company to file the Returns of LADT with the Assessing Officer with a direction to the A.O. to vet the returns and they passed the Assessment Order according with law, but stayed. The entry tax matters of the states have been referred to larger 'Nine Judges' Constitutional Bench of the Supreme Court on 16-04-2010. Nine Judge bench was constituted in July 2016 and answered the question related to constitutional matters and direct to further proceeding to three Judge bench of Hon'ble Supreme Court and now Hon'ble Supreme Court has passed the order on 21st March, 2017 referring the matter to Hon'ble High Court of Punjab & Haryana at Chandigarh, Punjab.

Accordingly, there is total liability up to Nov, 2021 amounting to Rs 1,949.76 Lakhs (without interest), previous year 1,949.76 Lakhs which is considered as contingent liability.

b) The company, in compliance to U.P sales tax department directions vide order dated 05^th May,2018, has deposited Rs. 435.43 Lakhs (including interest), (Previous Year Rs 435.43 Lakhs) whole disputed demand under protest. Now, company has filed Writ petition in Supreme court on 30^th March, 2019 And supreme court passed the order on 3rd May, 2019 referring the matter to Hon'ble Allahabad High Court. Hence in opinion of the company it is a contingent liability on account of Entry tax and final liability will be accounted for on final decision of Hon'ble Allahabad High Court.

c) Further company has also deposited Rs 32.48 Lakhs with Sales Tax authorities against detention of goods vehicles in earlier years.

NOTE 33: MICRO and small medium enterprises

There are no identified Micro and Small Enterprises, to whom the Company owes dues, which are outstanding as on 31^st March, 2023 and identified MSME creditors to whom payment delayed beyond 45 days. This information is disclosed as required under the Micro, Small and Medium Enterprises Development Act, 2006

The Company has initiated the process of obtaining the confirmation from suppliers who have registered themselves under the Micro, Small and Medium Enterprises Development Act, 2006 (MSMED Act, 2006) but has not received the same in totality. The

above information is compiled based in the extent of responses received by the company from its suppliers.

Note 34: Letter of credit for supply of raw material opened on behalf of company amounting to Rs 2473.84 Lakhs as on 31.03.2023 has been included in Trade payable as secured creditors for Bills discounted under letter of credit.

Note 35: I n the opinion of the company, 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 in the Balance Sheet and subject to confirmation/reconciliation.

However, for the year under review Debtors/ Accounts Receivables amounting to Rs 447.94 Lakhs has been sold to LVS Financial Services Private Limited for Rs 392.00 Lakhs i.e., at a discount of Rs 55.94 Lakhs.

Note 36: Employee Benefits

The Accounting Standard 15 (Revised 2005) have been made applicable from F.Y. 200708, the requisite information and disclosure have been given separately for the year and previous year.

a) Gratuity valuation is done by the company on Actuarial Valuation basis during the year FY 2022-23. For the current period gratuity valuation details are as follows,

b) Leave Encashment

The obligation for leave encashment for Rs 6.08 Lakhs recognized, provided for and paid on yearly basis.

c) Provision for contribution to defined contribution plan, recognized as expenses during the year as under:

Amount of Rs 38.03 Lakhs (Previous year Rs 35.40 Lakhs) towards contribution to provident fund and pension fund is recognised as an expense and included in Employee Benefit Expenses in Notes to Accounts forming part of Financial Statements.

Note 37: Segment Reporting

Based on guiding principle given in Accounting Standard 17 Segment reporting, Issued by the Institute of Chartered Accountants of India:

a) Primary Segment (Business Segment):

The Company is engaged in the business of Manufacturing of ERW Black Pipe, Galvanized Steel Tubes, Cold Rolled Strips, S.T. Poles, Solar Mounting Structures and similar nature goods. The entire operations are governed by the same set of risk and returns. Hence, the same has been considered as representing a single Business Segment.

b) Secondary Segment (Geographical Segments)

During the both reporting periods, Current and previous year, the Company's major sale are located only in India. Hence, the same has been considered as representing a single Geographical Segment.

Note 38: Corporate Social Responsibility

The provisions of section 135 of the Companies Act, 2013 is applicable on the company for the F.Y 2022-23 but average of net profit of the preceding financial years does not amounts to profit and hence no liability arise towards the contribution to CSR. However, Board approves Voluntarily to spend Rs 4.12 Lakhs (Previous Year Rs 3.09 Lakhs) in the current financial year towards promoting Education, Health Care, etc.

Also, as per section 135 of the Companies Act, 2013, a company is the process of forming a CSR committee. The Company's management is actively considering various CSR programs that may be taken up in the next financial year.

NOTE 41: Balances under some of the Trade Receivables, Trade Payable, Loans and Advances Payable or Receivable and other current assets including balance with revenue authorities are subject to confirmation and their classification are subject to reconciliation.

NOTE 42: Borrowings from banks and financial institutions were applied for the specific purpose for which the borrowings were obtained at the balance sheet date.

Note 43: Title deeds of Immovable Property are held in name of the Company.

NOTE 44: During the year, the Company has not revalued its Property, Plant and Equipment.

Note 45: Loans & Advance To Related Parties

There are no Loans or Advances in the nature of loans that are granted to promoters, Directors, KMPs and the related parties (as defined under Companies Act, 2013,) either severally or jointly with any other person, that are:

(a) repayable on demand or

(b) without specifying any terms or period of repayment

The Company does not have any capital-work-in progress, whose completion is overdue or has exceeded its cost compared to its original plan. Further, Company does not have Intangible assets under development,

NOTE 47: During the year no proceedings have been initiated or are pending against the Company as at 31.03.2023 for holding any benami property under the Benami Transactions (Prohibition) Act, 1988 (45 of 1988) and rules made thereunder.

NOTE 48: Quarterly returns or statements of current assets filed by the Company with banks or financial institutions are materially in agreement with the books of accounts

NOTE 49: During the year, the company has not been declared willful defaulter by any bank or financial institution or other lender.

Note 50: Relationship With Struck Off Companies

The company have following transactions with companies struck off under section 248 of the Companies Act, 2013 or section 560 of Companies Act, 1956.

Note 51: Registration Of Charges Or Satisfaction With Registrar Of Companies

There is no charges or satisfaction yet to be registered with Registrar of Companies beyond the statutory period. However, in the following case the company have not filed

e-form CHG-4 for satisfaction of charge with Registrar of companies due to nonavailability of NOC for below mentioned loan:

Note 52: Compliance With Number Of Layers Of Companies

The company does not have any subsidiary hence the number of layers prescribed under clause (87) of section 2 of the Act read with Companies (Restriction on number of Layers) Rules, 2017 is not applicable.

Note 54: Compliance With Approved Scheme(S) Of Arrangements

The company does not have any Scheme of Arrangements approved by the Competent Authority in terms of sections 230 to 237 of the Companies Act, 2013.

Note 55: Utilization Of Borrowed funds And Share premium:

a) The Company has not advanced or loaned or invested (either from borrowed funds or share premium or any other sources or kind of funds) to 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,

(i) 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

(ii) Provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries;

b) The Company has not received the funds 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,

(i) 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

(ii) Provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries.

Note 56: Undisclosed income

There were no transactions which were not recorded in the books of accounts that has been surrendered or disclosed as income during the year in the tax assessments under the Income Tax Act, 1961.

Note 57: Details Of Crypto Currency Or Virtual Currency

During the year, the company had not traded or invested in Crypto Currency or Virtual Currency, hence this note is not applicable.

Note 58: utilization Of funds raised through IPO under regulation 32 (1) Of The sebi (Listing Obligations and Disclosure Requirements) Regulations, 2015:

During the financial year under the company has successfully completed its Initial Public Offer (IPO) of 62,52,000 equity shares of Rs 10/- each at a price of Rs 100/- per share (Including a premium of Rs 90 per share), aggregating to Rs 6,252.00 Lakhs. Shares offered in IPO were allotted on 7^th October 2022 and listed on 12^th October 2022.

Pursuant to Regulation 32(1)(a) and 32(1)(b) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, the Company hereby provide the details of the proceeds of IPO:

The management has decided to change the share issue expenses towards Share Capital raised during the F.Y 2022-23 through IPO to Securities Premium Account as permitted by Section 52(2)(c) of The Companies Act, 2013.

Note 59: Opertaing Leases

The Company has taken Plant and Machineries on Non- Cancellable lease from "Siemens Factoring Private Limited" during the year for a tenor of 36 months, the terms of which

states that on end of lease, the Lessee (Swastik Pipe Limited) has an option to purchase the leased assets. However, management is of the opinion that the lease period does not cover the maximum useful life of leased assets, and the said lease agreements should be classified as operating Lease.

NOTE 60: The figures of the previous year have been regrouped / recast, wherever necessary, to conform to the current year figures including those on account of adoption of Schedule-III of the Companies Act, 2013.