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Precision Camshafts Ltd. Notes to Accounts
Search Company 
You can view the entire text of Notes to accounts of the company for the latest year
Market Cap. (Rs.) 1043.89 Cr. P/BV 1.24 Book Value (Rs.) 88.86
52 Week High/Low (Rs.) 206/104 FV/ML 10/1 P/E(X) 20.37
Bookclosure 23/07/2026 EPS (Rs.) 5.40 Div Yield (%) 0.91
Year End :2026-03 

(xvi) Segment Reporting

Segments are identified based on the manner in which
the Chief Operating Decision Maker ('CODM') decides
about resource allocation and reviews performance.
The Company is engaged in manufacturing of auto¬
components (camshafts.& others) based on similarity
of activities/products, risk and reward structure,

organisation structure and internal reporting systems,
the Company has structured its operations into a single
operating segment ; however based on the geographic
distribution of activities, the CODM has identified India
and outside India as two reportable geographical
segments. Refer Note No 34 for segment information
presented.

(xv) Provisions and Contingent Liabilities

The Company estimates the provisions that have
present obligations as a result of past events, and it is
probable that an outflow of resources will be required
to settle the obligations. These provisions are reviewed
at the end of each reporting date and are adjusted to
reflect the current best estimates.

The Company uses significant judgement to disclose
contingent liabilities. Contingent liabilities are disclosed
when there is a possible obligation arising from past
events, the existence of which will be confirmed only
by the occurrence or non-occurrence of one or more
uncertain future events not wholly within the control
of the Company or a present obligation that arises
from past events where it is either not probable that
an outflow of resources will be required to settle the
obligation or a reliable estimate of the amount cannot
be made. Contingent assets are neither recognized nor
disclosed in the financial statements.

Estimation of fair value

The fair value of the property as at March 31, 2026, is ' 356.32 Lakhs (March 31, 2025 is ' 317.23 Lakhs). The valuation
was performed by a registered valuer as defined under Rule 2 of the Companies (Registered Valuers and Valuation) Rules,
2017. The valuation has been carried out using a valuation model in accordance with the principles recommended by the
International Valuation Standards Council (IVSC).

Description of valuation techniques used and key inputs to valuation on investment properties:

The Company is earning rental income from the property. Accordingly, the fair value of the property has been determined
based on prevailing market rates, as assessed by an independent valuer and derived from observable market data. This
valuation reflects the estimated amount for which the property could be exchanged between knowledgeable and willing
parties at the reporting date.

5D) Impairment of investment in subsidiary

During the year ended March 31, 2026, the Company evaluated indicators of impairment in accordance with Ind AS 36 -
Impairment of Assets. This assessment was prompted by factors such as a decline in operational performance and changes
in the outlook for future profitability, among other potential indicators, in relation to its investment in PCL International
Holding B.V., a wholly owned subsidiary.

The recoverable amount of the investment in PCL International Holding B.V. is primarily dependent on the operational
and financial performance of its two key step-down subsidiaries, EMOSS Mobile Systems B.V and MFT Motoren and
Fahrzeugtechnik GmbH, Germany, which have been identified as significant Cash-Generating Units (CGUs) for the purpose
of this impairment assessment.

However, MFT Motoren und Fahrzeugtechnik GmbH, Germany, has filed an application for initiation of insolvency and
liquidation proceedings before the Dresden District Court. The Court has admitted the application and a provisional
liquidator was appointed on September 08, 2025.

As the subsidiary is under liquidation, its financial statements are being prepared on a liquidation basis. In accordance
with the requirements of Ind AS 36 - Impairment of Assets, management has reassessed the recoverable amount of its
investment in, and loan given (including accrued interest thereon) to, MFT Motoren und Fahrzeugtechnik GmbH, Germany
and accordingly recognised an impairment loss of
' 5,775.57 Lakhs during the year ended March 31, 2026, representing
entire carrying value of the investment and loan outstanding (including accrued interest).

For step-down subsidiary, EMOSS Mobile Systems B.V:

The recoverable amount is determined as the higher of:

- Value in Use (VIU) of the underlying CGUs, and

- Fair Value Less Costs of Disposal (FVLCD).

The VIU has been determined based on discounted cash flow forecasts derived from the most recent Board-approved
budgets and strategic business plans, covering a forecast period of three years, with further extrapolation into perpetuity
using a steady-state cash flow. These projections reflect sustainable long-term industry performance, balancing average
conditions through the cycle of profitability.

During the year ended March 31, 2026, no impairment loss has been recognized in respect of the investments in PCL
International Holding B.V.which holds investments in EMOSS Mobile Systems B.V. pursuant to the impairment assessment
carried out in accordance with Ind AS 36 - Impairment of Assets (March 31, 2025'7,300 Lakhs).

The Company has performed a sensitivity analysis as part of its impairment assessment, including an evaluation of the
impact of changes in the discount rate and other key assumptions. Based on the analysis performed, management believes
that no reasonably possible change in any of the key assumptions used in determining the recoverable amount would cause
the carrying amount of the investment to exceed its recoverable value, after considering the impairment loss recognised
in prior years.

Terms/rights attached to equity shares

The Company has only one class of equity shares having a par value of ' 10 per share (March 31, 2025: ' 10 per share).

Each holder of equity shares is entitled to one vote per share. The Company declares and pays dividends in Indian
Rupees.

The Board of Directors, in their meeting on May 27, 2025, proposed a final dividend of ' 1.00 per equity share and the same
was approved by the shareholders at the Annual General Meeting held on July 30, 2025. The amount was recognized as
distributions to equity shareholders during the year ended March 31, 2026 and the total appropriation was
' 949.86 Lakhs.

The Board of Directors, in their meeting on May 22, 2026, proposed a final dividend of ' 1.00 per equity share for the year
ended March 31, 2026. The payment of dividend is subject to approval of shareholders at the ensuing Annual General
Meeting of the Company.

In the event of liquidation of the Company, the holders of equity shares will be entitled to receive remaining assets of the
Company, after distribution of all preferential amounts.The distribution will be in proportion to the number of equity shares
held by the shareholders.

General reserve

The Company has transferred a portion of the net profit of the Company before declaring dividend to general reserve
pursuant to the earlier provisions of Companies Act 1956. Mandatory transfer to general reserve is not required under the
Companies Act 2013.

Retained earnings

Retained earnings are the profits that the Company has earned till date, less any transfers to general reserve, dividends or
other distributions paid to shareholders and any other adjustments.

Other comprehensive income

This represents the cumulative gains and losses arising on remeasurements of defined employee benefit plans (net of
taxes).

The Company does not have any defaults in repayment of loans and interest during the year and as at the reporting date.

Packing credit are secured by first pari passu charge by way of hypothecation of current assets including inventories and
trade receivables. Further, the facilities are collaterally secured by extension of pari passu charge by way of hypothecation
of plant and machinery and equitable mortgage of factory land and building situated at Plot No D5 to D7 & D7-1, MIDC
Chincholi, Solapur. The loan has been secured by the personal guarantee of directors Mr. Yatin S. Shah and Dr. Suhasini Y.
Shah.

29. EARNINGS PER SHARE (EPS)

Basic EPS amounts are calculated by dividing the profits for the year attributable to equity share holders of the Company
by weighted average number of equity shares outstanding during the year.

Diluted EPS amounts are calculated by dividing the profit attributable to equity share holders of the Company by the
weighted average number of equity shares outstanding during the year plus the weighted average number of equity shares
that would be issued on conversion of all the dilutive potential equity shares into equity shares.

The following reflects the profit and share data used in the basic and diluted EPS computation

The Board of Directors, in their meeting on May 23, 2024, proposed a final dividend of ' 1.00 per equity share and the same
was approved by the shareholders at the Annual General Meeting held on July 26, 2024. Subsequently, the dividend has
been paid by the Company in FY 2024-25.

The Board of Directors, in their meeting on May 27, 2025, proposed a final dividend of ' 1.00 per equity share and the same
was approved by the shareholders at the Annual General Meeting held on July 30, 2025. Subsequently, the dividend has
been paid by the Company in current year.

The Board of Directors, in their meeting on May 22, 2026, proposed a final dividend of ' 1.00 per equity share for the year
ended March 31, 2026. The payment of dividend is subject to approval of shareholders at the ensuing Annual General
Meeting of the Company.

31. DISCLOSURE PURSUANT TO EMPLOYEE BENEFITS

A. Defined contribution plans:

Amount of ' 415.88 Lakhs (March 31, 2025: ' 466.36 Lakhs) is recognised as expenses and included in note no. 23
"Employee benefit expense"

B. Defined benefit plans:

Gratuity:

The Company has a defined benefit gratuity plan in India (funded). The Company's defined benefit gratuity plan which
requires contributions to be made to a separately administered fund.

The gratuity plan is governed by the payment of gratuity Act, 1972. Under the act, employee who has completed five years
of service is entitled to specific benefit. The level of benefits provided depends on the member's length of service and
salary at retirement age.

Risk Exposure
Asset volatility

The plan liabilities are calculated using a discount rate set with reference to bond yields; if plan assets under perform this
yield, this will create a deficit. AH plan assets are maintained in a trust fund managed by Life Insurance Corporation of India
(LIC) who has been providing consistent and competitive returns over the years. The Company has opted for a traditional
fund wherein all assets are invested primarily in risk averse markets. The Company has no control over the management
of funds but this option provides a high level of safety for the total corpus. A single account is maintained for both the
investment and claim settlement and hence, 100% liquidity is ensured. Also, interest rate and inflation risk are taken care
of.

Changes in bond yields

A decrease in bond yields will increase plan liabilities, although this will be partially offset by an yields increase in the value
of the plans' bond holdings.

Future salary escalation and inflation risk

Since price inflation and salary growth are linked economically, they are combined for disclosure purposes. Rising salaries
will often result in higher future defined benefit payments resulting in higher present value of liabilities. Further, unexpected
salary increases provided at the discretion of the management may lead to uncertainties in estimating this increasing risk.

Asset-Liability mismatch risk

Risk which arises if there is a mismatch in the duration of the assets relative to the liabilities. By matching duration with
the defined benefit liabilities, the Company is successfully able to neutralize valuation swings caused by interest rate
movements. Hence, companies are encouraged to adopt asset-liability management.

32: COMMITMENTS AND CONTINGENCIES

a. Commitments

(i) Estimated amount of contracts remaining to be executed on capital account and not provided for (net of advances):
As at March 31, 2026, the Company had commitments of
' 5,009.10 Lakhs (March 31, 2025 : ' 4,403.59 Lakhs).

(ia) Sub-Notes:

a. The Collector of stamps, Solapur has demanded payment of stamp duty of ' 31.79 Lakhs (March 31, 2025:
' 31.79 Lakhs) for cancellation and issue of equity shares after amalgamation of Precision Valvetrain Components
Limited (PVPL) with the Company in year 2007-2008. The Company has filed an appeal against demand made by
the Collector of Stamps, Solapur with controlling revenue authority, Pune.

b. The Company had received an order from the Commisioner of Provident fund for the year May 2003 to
May 2006 demanding PF liability amounting to ' 24.23 Lakhs (March 31, 2025: ' 24.23 Lakhs) excluding interest.
The Company had filed writ petition with the Hon'ble High court Mumbai against the said order and had paid
' 12.12 Lakhs under protest.

c. The Company had received an order from the Commissioner of Central Excise Pune for the year 2002-03,
2003-04 and 2004-05 demanding excise duty amounting to ' 20.76 Lakhs (March 31, 2025: ' 20.76 Lakhs)
on sales tax retained under sales tax deferral scheme. The Company had filed apperial against the order with
CESTAT and CESTAT via its order transfer the said case to the jurisdiction commissionrate

d. The Company had received order from Assessing Officer for the assessment year 2014-15 for demand of
income tax amounting to ' 1,701.16 Lakhs (March 31, 2025'1,701.16 Lakhs) towards disallowance of ESOP
expenditures and other disallowances. The Company had filed appeal against the above order with commissioner
of income tax (Appeals) and has paid '335.41 Lakhs under protest.

e The Company had received an order from Assessing Officer for the assessment year 18-19 for demand of income
tax amounting to
' 7.08 Lakhs (March 31, 2025: ' 7.08 Lakhs) towards disallownce u/s 14A of the Act. The
Company has paid the said demand within due date specified by the department.Further assessing officer had
passed an order u/s 270A imposing a penalty for
' 3.47 Lakhs (March 31, 2025'3.47 Lakhs) Lakhs for under
reporting of income for incremental disallowance made u/s 14A of the act. The Company had filed appeal against
the penalty order with Commissioner of Income Tax (Appeals) and has paid
' 0.70 Lakhs under protest.

f The Company had received order from the commissoner of State Tax(GST) for the year 2017-18 demanding GST
amounting to
' 200.62 Lakhs (March 31, 2025: 200.62 Lakhs) (including interest and penalty) on tooling income
& Mismatch in Input tax credit. The Company had filed writ petition with the Hon'ble High court Mumbai against
the said order.

g During the financial year 2023-24, the Company received a draft assessment order under Section 144C(1) of
the Income-tax Act, 1961, for Assessment Year 2020-21. The draft order proposed adjustments relating to
international transactions pertaining to corporate guarantees and a disallowance under Section 14A of the Act,
aggregating to
' 19.47 Lakhs. The Company filed objections against the proposed adjustments before the Dispute
Resolution Panel (DRP).

During the financial year 2024-25, the Company received the final assessment order pursuant to the directions
issued by the DRP and subsequently filed an appeal before the Income Tax Appellate Tribunal (ITAT), Pune. The
Company also paid an amount of
' 7.79 Lakhs under protest against the said demand.

During the current year, the Company received a favourable order from the ITAT, Pune, directing the Assessing
Officer (AO) to recompute the relevant adjustments and finalise the assessment in accordance with the directions
of the Tribunal.

h. During the financial year 2023-24, the Company received a draft assessment order under Section 144C(1) of
the Income-tax Act, 1961, for Assessment Year 2021-22. The draft order proposed an adjustment in respect
of international transactions relating to corporate guarantees amounting to '5.41 Lakhs. The Company
filed objections against the proposed adjustment before the Dispute Resolution Panel (DRP). Subsequently,
during the financial year 2024-25, the DRP issued its directions and the final assessment order was passed.
Aggrieved by the said order, the Company filed an appeal before the Income Tax Appellate Tribunal
(ITAT), Pune. The Company has also deposited the disputed tax demand of '5.40 Lakhs under protest.
During the current year, the Company received a favourable order from the ITAT, wherein the matter was
remanded to the Assessing Officer (AO) with directions to recompute the adjustment and finalise the assessment
in accordance with the observations of the ITAT.

In all the cases mentioned above outflow is not probable, and hence not provided by the Company.

(ii) Corporate guarantees

The Company has also given corporate gurantee on behalf of it's wholly owned subsidiary Memco Engineering Pvt.
Ltd., to the lender bank. The outstanding amount of corporate guranteee is '317.50 Lakhs (March 31, 2025'504.89
Lakhs).

34. SEGMENT INFORMATION

The Company is engaged in manufacturing of camshafts. Based on similarity of activities/products, risk and reward
structure, organisation structure and internal reporting systems, the Company has structured its operations into a single
operating segment; however based on the geographic distribution of activities, the chief operating decision make identified
India and outside India as two reportable geographical segments.

The revenue information above is based on the locations of the customers.

Company's significant revenues are derived from two customers (March 31, 2025: two customers) contributing 10% or
more to the Company revenue, representing approximately 19,794.77 Lakhs (March 31, 2025 : ' 17,368.78 Lakhs) of
the Company's total revenue from operations.

Non-current operating assets*

All of the Company's non current operating assets are within India as on March 31, 2026 and March 31, 2025.

* As defined in paragraph 33 (b) of Ind AS 108 "Operating segments" non current assets excludes financial instruments,
deferred tax assets and post-employment benefit assets.

The fair value of the financial assets and liabilities is included at the amount at which the instrument could be exchanged in
a current transaction between willing parties, other than in a forced or liquidation sale.

36. FAIR VALUE HIERARCHY

The following is the hierarchy for determining and disclosing the fair value of financial instruments by valuation technique:

• Level 1 - Quoted prices (unadjusted) in active markets for identical assets or liabilities.

• Level 2 - Inputs other than quoted prices included within Level 1 that are observable for the asset or liability, either
directly (i.e. as prices) or indirectly (i.e. derived from prices).

• Level 3 - Inputs for the assets or liabilities that are not based on observable market data (unobservable inputs).

The following methods and assumptions were used to estimate the fair values:

> The fair values of the quoted mutual funds are based on price (i.e. the NAV of the mutual funds) quotations at the
reporting date.

> The fair values of derivative forward contracts is determined using the marked-to-market valuation done by the banks.

> The Fair value of Level 3 is determined on the basis of best estimate & information available.

B) Fair value of financial assets and liabilities measured at amortised cost

The management assessed that cash and cash equivalents (including term deposits), trade receivables, trade payables,
borrowings and other financial liabilities approximate their carrying amounts because of the short term nature of these
financial instruments.

The amortized cost using effective interest rate (EIR) of non-current financial assets consisting of security deposit, lease
liability, loans to subsidiary and term deposit with more than 12 months are not significantly different from the carrying
amount.

For financial assets and liabilities that are measured at fair value, the carrying amounts are equal to the fair values.

37. CAPITAL MANAGEMENT

For the purpose of the Company's capital management, capital includes issued equity capital, share premium and all other
equity reserves attributable to the equity holders.

The primary objective of the Company's capital management is to maximise the shareholder value and to ensure the
Company's ability to continue as a going concern.The company manages its capital structure and makes adjustments for
compliance with the requirements of the financial covenants. To maintain or adjust the capital structure, the Company
may adjust the dividend payment to shareholders, return capital to shareholders. The Company monitors gearing ratio i.e.
total debt in proportion to its overall financing structure, i.e. equity and debt. Total debt comprises of short term borrowing
which represents packing credit and cash credit taken from bank. The Company manages the capital structure and makes
adjustments to it in the light of changes in economic conditions and the risk characteristics of the underlying assets.

Foreign currency risk is the risk that the fair value or future cash flows of an exposure will fluctuate because of changes
in foreign exchange rates. The Company's exposure to the risk of changes in foreign exchange rates relates primarily to
the Company's operating activities (when revenue or expense is denominated in a foreign currency) and loan given to
subsidiary.

When a derivative is entered into for the purpose of being a hedge, the Company negotiates the terms of those derivatives to
match the terms of the hedged exposure. For hedges of forecast transactions the derivatives cover the period of exposure
from the point the cash flows of the transactions are forecasted up to the point of settlement of the resulting receivable or
payable that is denominated in the foreign currency.

38. FINANCIAL RISK MANAGEMENT OBJECTIVES AND POLICIES

The Company's principal financial liabilities, other than derivatives, comprise of short term borrowings, lease liabilities
and trade and other payables. The main purpose of these financial liabilities is to finance the Company's operations. The
Company's principal financial assets include security deposits, trade and other receivables, investments in mutual funds
and cash and cash equivalents that derive directly from its operations and loan given to subsidiary.

Foreign currency sensitivity

The following tables demonstrate the sensitivity to a reasonably possible change in USD, EUR and JPY exchange rates,
with all other variables held constant. The impact on the Company's profit before tax is due to changes in the fair value of
monetary assets and liabilities including non-designated foreign currency derivatives and embedded derivatives.

The Company is exposed to market risk, credit risk and liquidity risk. The Company's senior management oversees the
management of these risks. All derivative activities for risk management purposes are carried out by specialist teams
that have the appropriate skills, experience and supervision. It is the Company's policy that no trading in derivatives for
speculative purposes may be undertaken. The Board of Directors reviews and agrees policies for managing each of these
risks, which are summarised below.

Market risk

Market risk is the risk that the fair value of future cash flows of a financial instrument will fluctuate because of changes in
market prices. Market risk comprises three types of risk: interest rate risk, currency risk and other price risk, such as equity
price risk and commodity risk. Financial instruments affected by market risk include loans and borrowings, and derivative
financial instruments.

The sensitivity analysis in the following sections relate to the position as at March 31, 2026 and March 31, 2025.

The analysis exclude the impact of movements in market variables on the carrying values of gratuity and other post
retirement obligations and provisions.

Interest rate risk

Interest rate risk is the risk that the fair value or future cash flows of a financial instrument will fluctuate because of
changes in market interest rates. The Company's exposure to the risk of changes in market interest rates relates primarily
to the Company's short-term debt obligations with floating interest rates.

The Company is affected by the price volatility of certain commodities. Its operating activities require the ongoing
manufacture of camshafts and therefore require a continuous supply majorly of pig iron, MS scrap and resin coated sand.

The Company's exposure to the risk of exchange in key raw material prices are mitigated by the fact that the price
increases/decreases from the vendors are passed on to the customers based on understanding with the customers. Hence
the fluctuation of prices of key raw materials do not materially affect the statement of profit and loss. Also as at March
31, 2026, there were no open purchase commitments/ pending material purchase order in respect of key raw materials.
Accordingly, no sensitivity analysis have been performed by the management.

Credit risk

Credit risk is the risk that counterparty will not meet its obligations under a financial instrument or customer contract,
leading to a financial loss. The Company is exposed to credit risk from its operating activities (primarily trade receivables)
and from its financing activities, including deposits with banks and financial institutions, foreign exchange transactions and
other financial instruments.

Trade receivables

Customer credit risk is managed subject to the Company's established policy, procedures and control relating to customer
credit risk management. Credit quality of a customer is assessed and individual credit limits are defined in accordance with
this assessment. Outstanding customer receivables are regularly monitored.

An impairment analysis is performed at each reporting date on an individual basis for major clients. The maximum exposure
to credit risk at the reporting date is the carrying value of trade receivables disclosed in note 8. The Company does not
hold collateral as security. The Company evaluates the concentration of risk with respect to trade receivables as low, as its
customers are located in several jurisdictions and industries and operate in largely independent markets.

Financial instruments and cash deposits

Credit risk from balances with banks and financial institutions is managed by the Company's treasury department in
accordance with the Company's policy.

The investment of surplus funds is made in mutual funds and fixed deposits which are approved by the Director.

The Company's maximum exposure to credit risk for the components of the balance sheet at March 31, 2026 and March
31, 2025 is the carrying amounts as illustrated in note 9.

Liquidity risk

Liquidity risk is the risk that the Company will not be able to meet its financial obligation as they become due. The Company
manages its liquidity risk by ensuring, as far as possible, that it will always have sufficient liquidity to meet its liability when
due.

40. CORPORATE SOCIAL RESPONSIBILITY EXPENDITURE

As per Section 135 of the Companies Act, 2013, a Company, meeting the applicability threshold, needs to spend at least
2% of its average net profit for the immediately preceding three financial years on corporate social responsibility (CSR)
activities. The areas for CSR activities are health care, education, sustainability, social issues. A CSR committee has been
formed by the Company as per the Act. The funds are utilized through the year on these activities which are specified in
Schedule VII of the Companies Act, 2013.

41 . TITLE DEEDS OF IMMOVABLE PROPERTIES NOT HELD IN NAME OF THE COMPANY

There are no title deeds of immovable property which are not held in the name of the Company.

42. LEASES WHERE COMPANY IS A LESSEE

During the FY 2024-25, Company has obtained land at Mangalwedha on lease for a period of 29 years. Payment of lease
rentals has been made in accordance with the rentals specified in the schedule agreed. Lease Liability has been recognised
in the books of accounts by the Company at present value of the lease payments and Right of Use asset at cost in accordance
with the requirements of IND AS 116.

53. REMUNERATION OF KEY MANAGERIAL PERSONNEL

During the financial year 2025-26, the remuneration paid to the Managing Director and Whole Time Directors exceeded
the limits prescribed under Section 197 read with Schedule V to the Companies Act, 2013 based on the effective
remuneration limits applicable to the Company for the year as computed under the provisions of the Companies Act, 2013.
Details of remuneration paid and excess over the prescribed limits are as under:

The Company is in the process of seeking approval of the shareholders by way of special resolution pursuant to the
provisions of Section 197 and Schedule V to the Companies Act, 2013 for waiver of the excess remuneration paid as stated
above.

54. UNDISCLOSED INCOME

The Company does not have any undisclosed income which is not recorded in the books of account that has been
surrendered or disclosed as income during the year and previous year in the tax assessments under the Income Tax Act,
1961 (such as, search or survey or any other relevant provisions of the Income Tax Act, 1961.)

55. DETAILS OF CRYPTO CURRENCY OR VIRTUAL CURRENCY:

The Company has not traded or invested in crypto currency or virtual currency during the financial year.

56. PREVIOUS YEAR COMPARATIVES

Previous year's figures have been regrouped/reclassified, where necessary, to correspond with the current year's
classification/disclosure.

57. EVENTS AFTER THE REPORTING PERIOD

The Board of Directors, in their meeting on May 22, 2026, proposed a final dividend of ' 1.00 per equity share for the year
ended March 31, 2026. The payment of dividend is subject to approval of shareholders at the ensuing Annual General
Meeting of the Company.

58. AUDIT TRAIL

The Ministry of Corporate Affairs (MCA) has prescribed a new requirement for companies under the proviso to Rule 3(1)
of the Companies (Accounts) Rules, 2014 inserted by the Companies (Accounts) Amendment Rules 2021 requiring
companies, which uses accounting software for maintaining its books of accounts, shall use only such accounting software
which has a feature of recording audit trail of each and every transaction, creating an edit log of each change made in the
books of accounts along with the date when such changes were made and ensuring that the audit trail cannot be disabled.
Companies must also now ensure daily backups of their financial data, to be stored on servers physically located within
India.

Pursuant to the above requirements, the Company uses two primary software systems:

a. Maintaining books of Accounts

b. Payroll Processing

The Company has used an accounting software(s) for maintaining its books of account which has a feature of recording audit
trail (edit log) facility, except that audit trail feature was not enabled at the database level in respect of such accounting
software to log any direct data changes.

Further, to the extent enabled, audit trail feature has operated throughout the year for all relevant transactions recorded in
the accounting software. Also, we did not come across any instance of audit trail feature being tampered with. Additionally,
the audit trail of prior year(s) has been preserved by the Company as per the statutory requirements for record retention to
the extent it was enabled and recorded in previous years.

The Company has used an accounting software for maintaining and processing its payroll records, which has a feature of
recording audit trail (edit log) facility and the same has been operated throughout the year for all relevant transactions
recorded in the software. Further, we did not come across any instance of audit trail feature being tampered with at
application level. Additionally, the audit trail has been preserved by the Company as per the statutory requirements for
record retention for application level. However, with respect to the database level of the said software has been managed
and maintained by a third-party service provider. In the absence of sufficient and appropriate audit evidence including
adequate coverage in SOC report we are unable to assess whether the database of the software to log any direct changes
has a feature of recording audit trail (edit log) facility and whether the same has been enabled and operated throughout
the year for all relevant transaction recorded or whether there is any instance of audit trail feature being tampered with.
Also, we are unable to assess whether the audit trail feature of prior year(s) has been preserved by the Company as per the
statutory requirements for record retention at database level.

The daily backup of both the above-mentioned software applications is maintained on servers physically located in India
and is performed on a daily basis.


 
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