VIII. Provisions, Contingent Liabilities & Contingent asset

1. Provisions are recognised only when:

(i) the Company has a present obligation (legal or constructive) as a result of a past event; and

(ii) it is probable that an outflow of resources embodying economic benefits will be required to settle the
obligation; and

(iii) a reliable estimate can be made of the amount of the obligation

When the effect of the time value of money is material, the enterprise determines the level of provision by
discounting the expected cash flows at a pre-tax rate reflecting the current rates specific to the liability.
The expense relating to any provision is presented in the Statement of Profit and Loss net of any
reimbursement.

2. Contingent Liabilities: Contingent liability is disclosed in case of:

(i) a present obligation arising from past events, when it is not probable that an outflow of resources will
be required to settle the obligation; and

(ii) a present obligation arising from past events, when no reliable estimate is possible.

3. Contingent assets are disclosed where an inflow of economic benefits is probable. Provisions,
contingent liabilities and contingent assets are reviewed at each Balance Sheet date. Where the
unavoidable costs of meeting the obligations under the contract exceed the economic benefits expected
to be received under such contract, the present obligation under the contract is recognised and measured
as a provision.

IX. Earnings Per Share

The Company reports basic and diluted earnings per share in accordance with Ind AS 33 on Earnings per
share.

Basic EPS is calculated by dividing the net profit or loss for the year attributable to equity shareholders by
the weighted average number of equity shares outstanding during the year.

For calculating diluted earnings per share, the net profit or loss for the year attributable to equity
shareholders and the weighted average number of shares outstanding during the year are adjusted for
the effects of all dilutive potential equity shares. Dilutive potential equity shares are deemed converted as
of the beginning of the period, unless they have been issued at a later date. In computing the dilutive
earnings per share, only potential equity shares that are dilutive and that either reduces the earnings per
share or increases loss per share are included.

X. Effective interest rate method

The Company recognises interest income/expense using the effective interest rate, i.e., a rate that
represents the best estimate of a constant rate of return over the expected life of the loans. The effective
interest method also accounts for the effect of potentially different interest rates at various stages and
other characteristics of the product life cycle (including prepayments and penalty interest and charges).
This estimation, by nature, requires an element of judgement regarding the expected behavior and life¬
cycle of the instruments, as well expected changes to India’s base rate and other fee income/expense that
are integral parts of the instrument.

XI. Impairment of financial assets using the expected credit loss method

The impairment provisions for financial assets are based on assumptions about risk of default and
expected loss rates. The Company uses judgement in making these assumptions and selecting the
inputs to the impairment calculation, based on the Company’s history, existing market conditions as well
as forward looking estimates at the end of each reporting period.

XII. Recognition of NPA

a) All credit exposures are classified into performing and non-performing assets as per the RBI
guidelines. Further, NPAs are classified into Sub-Standard, Doubtful & Loss Assets based on the
criteria stipulated by RBI. Provisions are made on Standard, Sub-Standard and Doubtful Assets at
the rates prescribed by RBI. Loss Assets & Unsecured portion of Doubtful Assets are provided/
written off as per the RBI guidelines. Additional provisions are made against specific non-performing
assets over and above what is stated above, if in the opinion of the management, increased
provisions are necessary. The Company has duly complied with the prudential norms relating to
income recognition, asset classification and provisioning for bad and doubtful debts as applicable to
it.

b) NPA Provision has been written back of those accounts whose recovery is affected during the
year.

Note No. 04

Accounting Judgments, Estimates and Assumptions

The preparation of financial statements in conformity with the IND AS requires the management to make
judgments, estimates and assumptions that affect the reported amounts of revenues, expenses, assets
and liabilities and the accompanying disclosure and the disclosure of contingent liabilities, at the end of
the reporting period. Estimates and underlying assumptions are reviewed on an ongoing basis. Revisions
to accounting estimates are recognised in the period in which the estimates are revised and future periods
are affected. Although these estimates are based on the management’s best knowledge of current events
and actions, uncertainty about these assumptions and estimates could result in the outcomes requiring a
material adjustment to the carrying amounts of assets or liabilities in future periods.

In particular, information about significant areas of estimation, uncertainty and critical judgments in
applying accounting policies that have the most significant effect on the amounts recognised in the
financial statements is included in the following notes:

I. Business Model Assessment

Classification and measurement of financial assets depends on the results of the SPPI and the business
model test. The Company determines the business model at a level that reflects how groups of financial
assets are managed together to achieve a particular business objective. This assessment includes
judgement reflecting all relevant evidence including how the performance of the assets is evaluated and
their performance measured, the risks that affect the performance of the assets and how these are
managed and how the managers of the assets are compensated. The Company monitors financial assets
measured at amortised cost or fair value through other comprehensive income that are derecognised
prior to their maturity to understand the reason for their disposal and whether the reasons are consistent
with the objective of the business for which the asset was held. Monitoring is part of the Company’s
continuous assessment of whether the business model for which the remaining financial assets are held
continues to be appropriate and if it is not appropriate whether there has been a change in business model
and so a prospective change to the classification of those assets.

II. Fair value measurement

When the fair values of financial assets and financial liabilities recorded in the balance sheet cannot be
measured based on quoted prices in active markets, their fair value is measured using various valuation
techniques. The inputs to these models are taken from observable markets where possible, but where
this is not feasible, a degree of judgment is required in establishing fair values. Judgments include
considerations of inputs such as liquidity risk, credit risk and volatility. Changes in assumptions about
these factors could affect the reported fair value of financial instruments.

III. Impairment of loans portfolio

The measurement of impairment losses across all categories of financial assets requires judgement, in
particular, the estimation of the amount and timing of future cash flows and collateral values when

determining impairment losses and the assessment of a significant increase in credit risk. These
estimates are driven by a number of factors, changes in which can result in different levels of allowances.
It has been the Company’s policy to regularly review its models in the context of actual loss experience
and adjust when necessary.

In line with Reserve Bank of India Master Circular on Prudential norms on Income Recognition, Asset
Classification and Provisioning pertaining to Advances and Clarifications dated April 01,2023 borrower
accounts shall be flagged as overdue as part of the day-end processes for the due date, irrespective of the
time of running such processes. Similarly, classification of borrower accounts as Non-Performing Asset /
Stage 3 shall be done as part of day-end process for the relevant date i.e. more than 90 days overdue and
NPA/Stage 3 classification date shall be the calendar date for which the day end process is run. In other
words, the date of Non-Performing Asset / Stage 3 shall reflect the asset classification status of an
account at the day-end of that calendar date.

The Company has carried out the requirement in line with Reserve Bank of India Clarification and
accordingly the change in accounting policy is effective financial year 2023-24.

IV. Contingent liabilities and provisions other than impairment on loan portfolio

Provisions and liabilities are recognised in the period when it becomes probable that there will be a future
outflow of funds resulting from past operations or events and the amount of cash outflow can be reliably
estimated. The timing of recognition and quantification of the liability requires the application of judgement
to existing facts and circumstances, which can be subject to change. The carrying amounts of provisions
and liabilities are reviewed at each Balance sheet date and revised to take account of changing facts and
circumstances.

V. Effective Interest Rate (EIR) method

The Company’s EIR methodology, recognises interest income/expense using a rate of return that
represents the best estimate of a constant rate of return over the expected behavioral life of loans given /
taken and recognises the effect of potentially different interest rates at various stages and other
characteristics of the product life cycle (including prepayments and penalty interest and charges). This
estimation, by nature, requires an element ofjudgement regarding the expected behavior and life-cycle of
the instruments, as well expected changes to India’s base rate and other fee income/expense that are
integral parts of the instrument.

31. Segmental Reporting:

The Company is engaged in the sole segment of NBFC Activity. There are, therefore, no separate
segments within the Company as defined by IND AS-108(Operating Segments)

32. The company did not have any long term contract including derivative contract for which there
were any material foreseeable losses.

33. During the year, Borrowing Costs amounting of Rs. Nil has been capitalized to Property, Plant &
Equipment's.

34. The Company has no subsidiary. Hence requirement of Consolidated Financial Statement is not
applicable to the Company.

35. In the opinion of the Board Current Assets, Loans & Advances are approximately of the value
stated, if realized in the ordinary course of business. The provision for Depreciation & amortization
and all known liability are adequate. There is no Contingent liability other than stated.

36. Wilful Defaulter

The company has not taken any loans hence, there is no question of declaration of wilful defaulter
by any bank or financial institution or other lender.

37. Details of Dues To Micro And Small Enterprises As Defined Under The Micro, Small And
Medium Enterprises Development Act, 2006:

As on the date of Balance Sheet, the Company has not received any communication from any of
its suppliers regarding the applicability of Micro, Small and Medium enterprises development Act,
2006 to them, as such, information as required under the act cannot be complied and therefore not
given for the year.

The following information has been determined to the extent such parties have been identified on
the basis of information available with the company:-

42. Loans and advances other than doubtful have been considered as good and fully recoverable.
However, in terms of Reserve Bank of India Guidelines applicable to Non-Banking Finance
Companies, a provision for standard assets Rs. 2.17 Lakhs (Previous year Rs. 2.17 Lakhs) has
been made as on date. The Doubtful Loans and Advances relates to M/s Jai Girnari Infratech, Indore
amounting to Rs. 21.83 Lakhs (including the Unrealized Interest of Rs. 8.24 Lakhs) has been fully
written off in earlier years as per the IRAC Norms. Hence no further provision in current year.

43. The Company has been classified as loan and investment Company by the Reserve Bank of India
pursuant to registration as a Non-Banking Finance Company and as per information of the
management said registration as Non-Banking Finance Company with RBI is also continued for the
year.

44. The Company had given Rs. 20.00 Lakhs as advance against purchase of a plot of Rs. 20 Lakhs at
R.R. Industrial Park, Indore in earlier years. However, possession and registry of said properties
were pending till 31st March 2024. Management has opined the said Capital Advance are good and
recoverable.

45. The Bombay Stock Exchange has levied fine of Rs. 2.54 Lakhs towards Non-compliance with the
constitution of nomination and remuneration committee and Non-submission of shareholding
pattern within the period prescribed but management informed as they applied for its waiver before
BSE hence not provided in the books of accounts being contingent nature.

46. Disclosure as per IND As 107, Financial Instruments

a. Capital management

The Company maintains an actively managed capital base to cover risks inherent in the business
which includes issued equity capital and all other equity reserves attributable to equity shareholders
of the Company.

The primary objectives of the Company's capital management policy are to ensure that the
Company complies with externally imposed capital requirements and maintains strong credit ratings
and healthy capital ratios in order to support its business and to maximise shareholder value.

RBI requires NBFC's to maintain a minimum capital to risk weighted assets ratio (CRAR) consisting
of Tier-I and Tier-II Capital of 15% of their aggregate risk weighted assets. Since the Company is a
“NBFC-NSI-ND”, hence it is not required to compute the financial ratios.

b. Financial risk management objective and policies:

This section gives an overview of the significance of financial instruments for the Company and
provides additional information on the balance sheet. Details of significant accounting policies,
including the criteria for recognition, the basis of measurement and the basis on which income and
expenses are recognized, in respect of each class of financial asset and financial liability are disclosed
in Note No. 1

Financial assets and liabilities: The accounting classification of each category of financial instruments,
and their carrying amounts, are set out below:

As at 31st march, 2024

c. Fair value of financial assets and financial liabilities that are not measured at fair value

Management considers that the carrying amounts of financial assets and financial liabilities
recognized as lying in the Financial Statements

d. Defaults and breaches

There is no default in loans payable recognized at the end of the reporting period because company
is No Loan or Deposit accepting company.

e. Risk management framework

The Company's business is subject to several risks and uncertainties including financial risks. The
Company's documented risk management polices act as an effective tool in mitigating the various
financial risks to which the business is exposed to in the course of their daily operations. The risk
management policies cover areas such as liquidity risk, interest rate risk, counterparty and
concentration of credit risk and capital management. Risks are identified through a formal risk
management programme with active involvement of senior management personnel and business
managers. The Company's risk management process is in line with the corporate policy. Each
significant risk has a designated ‘owner' within the Company at an appropriate senior level. The
potential financial impact of the risk and its likelihood of a negative outcome are regularly updated.

The risk management process is coordinated by the Management Assurance function and is
regularly reviewed by the Company's Audit Committee. The overall internal control environment
and risk management programme including financial risk management is reviewed by the Audit
Committee on behalf of the board. The risk management framework aims to:

• improve financial risk awareness and risk transparency

• identify, control and monitor key risks

• identify risk accumulations

• provide management with reliable information on the Company's risk situation

• improve financial returns

a. Treasury management

The Company's treasury function provides services to the business, co-ordinates access to
domestic and international financial markets, monitors and manages the financial risks relating to
the operations of the Company through internal risk reports which analyses exposures by degree
and magnitude of risks. These risks include market risk (including currency risk and interest rate
risk), credit risk and liquidity risk.

Treasury management focuses on capital protection, liquidity maintenance and yield maximization.

b. Financial risk

The Company's Board of Directors approves financial risk policies comprising liquidity, foreign
currency, interest rate and counterparty credit risk. The Company does not engage in the
speculative treasury activity but seeks to manage risk and optimize interest through proven financial
instruments.

c. Credit risk

Credit risk refers to the risk that counterparty will default on its contractual obligations resulting in
financial loss to the Company. The Company has adopted a policy of only dealing with creditworthy
counterparties as a means of mitigating the risk of financial loss from defaults. The Company is
exposed to credit risk for receivables, cash and cash equivalents, bank balances other than cash
and cash equivalents, investments and loans.

Regarding trade and other receivables, the Company has accounted for impairment based on
expected credit losses method as at 31 March, 2024 and 31 March, 2023 based on expected
probability of default.

Deposits are with government departments and with lessor so chances of default are very minimal.

For short-term loans and advances, counterparty limits are in place to limit the amount of credit
exposure to any counterparty.

None of the Company's cash equivalents are past due or impaired.

d. Liquidity risk

Liquidity risk arises from the Company's inability to meet its cash flow commitments on time. Prudent
liquidity risk management implies maintaining sufficient stock of cash and marketable securities.
The Company maintains adequate cash and cash equivalents alongwith the need based credit
limits to meet the liquidity needs.

e. Market Risk

Market risk that the fair value or future cash flows of financial instruments will fluctuate due to
changes in market variables such as interest rates, foreign exchange rates and equity prices. The
Company classifies exposures to market risk into either trading or non-trading portfolios and
manages each of those portfolios separately.

47. Beryl Securities Limited, is a group company which has only MD and Other director are common but
no shareholding in the other company as on 31.03.2024, hence company has not considered
Consolidation of Financial Statement as per IND As 110.

48. Undisclosed income

'As explained by the management and records examined by us, no transactions were observed
which remain unrecorded in the books of accounts that can materially impact the financial position
of the company as at the balance sheet date. Further, no instances of transactions surrendered or
disclosed as income during the year in the tax assessments under the Income Tax Act, 1961 which
previously remain unrecorded, offered as income in the books of accounts during the year.

49. Details of Benami Property held:

During the year no proceedings have been initiated or pending against the company for holding any
Benami Property under the Benami Transactions (Prohibition) Act, 1988 (45 of 1988) and rules
made there under.

50. Indications of impairment:

In the opinion of management ,there are no indications, internal or external which could have the
effect of Impairing the value of assets to any material extent as at the Balance Sheet date requiring

recognition in terms of Ind AS 36.

51. Relationship with Struck off Companies :

There are no transactions during the year with struck off Companies as at 31st March 2024.

52. Registration of charges or satisfaction with Registrar of Companies (ROC)

The Company does not have any borrowings from any bank, financial institutions and other lender,
hence the provisions of Section 77 of the Companies Act, 2013 is not applicable.

53. Title deeds of Immovable Properties not held in name of the Company

The Company does not possess any immovable property whose title deeds are not held in the name
of the Company during the financial year ended March 31, 2024 and March 31, 2023. (Except
Advances given against property but registration is still pending)

54. Details of Crypto Currency or Virtual Currency

The company has not traded or invested in crypto currency or Virtual currency during the year.

55. The Company has no borrowings from banks or financial institutions on the basis of security of
current assets with respect to which, hence the periodical returns or statements of current assets
required to be filed by the Company with banks or financial institutions is not applicable.

56. The Company, has no long-term contracts including derivative contracts having material
foreseeable losses as at 31 March 2024.

57. There is nothing to report with regard to Disclosure related to Loans or Advances in the nature of
loans are granted to promoters, directors, KMPs and the related parties (as defined under
Companies Act, 2013,) either severally or jointly with any other person since no such transaction.

58. The Company has not advanced or loaned or invested funds in during the year (either borrowed
funds or share premium or any other sources or kind of funds) to any other person or entity 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 person or entities identified
in any manner whatsoever by or on behalf of company (ultimate beneficiaries) or (ii) provide any
guarantee, security or the like to or behalf of the ultimate beneficiaries. The company has not given
guarantee or provided security.

59. The Company has not received any fund from any person(s) or entity(ies) including foreign entities
(funding party) with the understanding (whether recorded in writing or otherwise) that the Company
shall (i) directly or indirectly lendor invest in any manner whatsoever by or on behalf of the funding
party (ultimate beneficiaries) or (ii) provide any guarantee, security or the like to or on behalf of the
(ultimate beneficiaries) or (iii) provide any guarantee, security or the like to or on behalf of the
ultimate beneficiaries.

66. Institutional set-up for Liquidity Risk Management

The Board of Directors of the Company has an overall responsibility and oversight for the
management of all the risks, including liquidity risk, to which the Company is exposed to in the
course of conducting its business. The Board approves the governance structure, policies, strategy
and the risk limits for the management of liquidity risk. The Board of Directors approves the
constitution of the Risk Management Committee (RMC) for the effective supervision, evaluation,
monitoring and review of various aspects and types of risks, including liquidity risk, faced by the
Company. The meetings of RMC are held at quarterly interval. Further, the Board of Directors also
approves constitution of Asset Liability Committee (ALCO), which functions as the strategic
decision-making body for the asset-liability management of the Company from risk-return
perspective and within the risk appetite and guard-rails approved by the Board. The main objective
of ALCO is to assist the Board and RMC in effective discharge of the responsibilities of asset liability
management, market risk management, liquidity and interest rate risk management and also to
ensure adherence to risk tolerance/limits set up by the Board. ALCO provides guidance and
directions in terms of interest rate, liquidity, funding sources, and investment of surplus funds. ALCO
meetings are held once in a month or more frequently as warranted from time to time. The minutes of
ALCO meetings are placed before the RMC and the Board of Directors in its next meeting for its
perusal/ approval/ ratification.

67. The Code on Social Security 2020 (‘the Code') relating to employee benefits, during the
employment and post-employment, has received Presidential assent on September 28, 2020. The
Code has been published in the Gazette of India. Further, the Ministry of Labour and Employment
has released draft rules for the Code on November 13, 2020.However, the effective date from which
the changes are applicable is yet to be notified and rules for quantifying the financial impact are also
not yet issued.

The Company will assess the impact of the Code and will give appropriate impact in the financial
statements in the period in which, the Code becomes effective and the related rules to determine the
financial impact are published.

68. Additional disclosures pursuant to Para 19 of Master Directions - Non-Banking Financial Company -
Systemically Important Non-Deposit taking company and Deposit taking company (Reserve Bank)
Directions, 2016.

As per our report of even date

For, Subhash Chand Jain Anurag & Associates FOR AND ON BEHALF OF THE BOARD OF DIRECTORS

Chartered Accountants
FRN : 004733C

Akshay Jain (SUDHIR SETHI) (SANJAY SETHI) (KAMLESH GUPTA)

Partner MANAGING DIRECTOR DIRECTOR COMPANY SECRETARY

M No. : 447487 DIN : 00090172 DIN : 00090277 ICSI.M.No.: A32408

UDIN : 24447487BKAFRK7839

Place : Indore Place : Indore

Date : 29.05.2024 Date : 29.05.2024