State Trading Corporation of India Limited REPORT ON THE AUDIT OF THE STANDALONE FINANCIAL STATEMENTS
We have audited the accompanying standalone financial statements of The State Trading Corporation of India Limited ("the Company"), which comprise the Balance Sheet as at 31st March, 2025, the Statement of Profit and Loss (including Other Comprehensive Income), the statement of changes in Equity and the Standalone Cash Flow Statement for the year then ended, notes to the Standalone financial statements including a summary of the significant accounting policies and other explanatory information (hereinafter referred to as "The Standalone Financial Statements").
Qualified Opinion
IIn our opinion and various issues as mentioned in the Basis for Qualified Opinion paragraphs, the aforesaid Standalone Financial Statements except for the qualified opinion give the information required by the Companies Act 2013 ("the Act") in the manner so required and present a true and fair view in conformity with the Indian Accounting Standards prescribed under Section 133 of the Act read with the Companies ( Indian Accounting Standards ) Rule 2015 as amended, ("Ind AS") and other accounting principles generally accepted in India, of the state of affairs of the Company as at 31st March 2025 and its net profit and other comprehensive income, changes in equity and its cash flows for the year ended on that date.
Basis for Qualified Opinion
1. Non-Current Assets held for Sale
i. Refer to Note No.4(a) of Standalone Financial Statements, non-availability of title deeds in the name of the company in respect of following properties namely:
a) Leasehold Building
i. Leasehold land at Jawahar Vyapar Bhawan valued at Rs. 55,929 lacs
ii. Leasehold land at Housing Colony at Aurobindo Marg valued at Rs. 12,394 lacs
b) Freehold Building
i. 8 Residential Flats at Asian Games Village Complex, allotted by DDA amounting to Rs. 2720 lacs
ii. 7 apartments in different locations of Mumbai amounting to Rs. 1918 lacs
iii. Flats at Ahemdabad
Further, lease period for plot at Mallet Bunder, Mumbai Port Trust has already expired and the land has been handed over to Mumbai Port Trust. Surrender certificate has been executed on 12.11.2021. But this still continues to be shown as non-current assets held for sale. Thus, non- current assets held for sale has been overstated by Rs. 11.67 lacs. It will also have consequential impact on the Statement of Profit and Loss account resulting into overstatement of profit by Rs. 11.67 lacs.
Further the farm tanks installed at Mallet Bunder amounting to Rs. 14.84 lacs have also been handed over on as is where is basis. The company has not raised any debit note for the same and thus non-current assets are being overstated by Rs. 14.84 lacs.
Further to this, the auction of the STC assets was conducted by MBPT on 11.06.2024 and the assets were ultimately sold for Rs. 355 lacs, with the previously forfeited EMD of Rs. 25 Lacs. STC calculated its total receivables from MBPT at Rs. 418 lacs which includes the sale proceeds, EMD and deposits. STC to set off this amount against the Rs. 257 lacs Lease rent payable, (amount yet to be reconciled with MBPT) resulting in a net receivable of Rs. 161 lacs from MBPT. Refer Note 57.
Further, company has not amortized the value of the leasehold properties according to the IND AS 116 for the period expired till 31.03.2025 resulting into overstatement of non-current assets held for sale and consequential impact on profit of the company, the amount whereof could not be quantified in absence of complete data from the Company.
ii. Refer Note No. 4, for non-adjustment of value/area in Fixed Assets Register against areas acquired by Delhi Metro Rail Corporation (DMRC) for construction of Metro Station & by L&DO for widening of the Road during Asian Games, as well as the flats/area of land sold by the company to The Handicrafts and Handloom Exports Corporation of India Limited (HHEC) for its Housing colony. Management is in correspondence with DMRC and concerned departments. This has resulted into overstatement of non-current assets held for sale and consequential impact on profit of the company, the amount whereof could not be quantified in absence of complete data from the Company.
2. Trade Receivables
All trade receivables amounting to 1,69,710.16 lacs as per Note No. 9 have been outstanding for more than 3 years. The Company has made provision for bad and doubtful debts amounting to Rs. 62,727.62 lacs and another sum of Rs. 1,06,982.54 lacs have been shown as "Having Significant increase in credit risk"since the same is under litigation. As per
Note No.9, it is explained that no provision has been made for the same since the relevant creditors will be paid only after recovery of these trade receivables, though in most of the cases agreements are not tripartite.
Further there has been no recovery during the Financial Year 2024-25 and there is no major update of legal cases which are pending at various forums. Thus trade receivable are not stated at realizable value less cost to be incurred to recover these trade receivables. There is also no balance confirmation available for these trade receivables as on 31.03.2025 and hence we are unable to comment upon the genuineness and effect of the same on the financial statements, if any.
We are of the view that all trade receivables amounting to 1,69,710.16 lacs are considered doubtful of recovery resulting into short provision for doubtful debts amounting to Rs. 1,06,982.54 lacs. Thus the provision for bad and doubtful debts has been understated by Rs. 1,06,982.54 lacs and consequential impact on the statement of profit and Loss account resulting into overstatement of profit by Rs. 1,06,982.54 lacs.
Further in case of M/s Rajat Pharmaceuticals Ltd (RPL), under note no.39, Pt.No.4, who drew bills of exchange on STC which were accepted upon receipt of overseas buyer's pre-acceptance to STC's bills of exchange. However, the foreign buyers defaulted in making payments against the export bills and have gone into liquidation. A sum of Rs.52786 lacs has been admitted by the liquidator of one of the foreign buyer's i.e. Loben Trading Co. Pte. Ltd, Singapore. A Decree of Rs 6247 lacs approx. has been passed by Hon'ble Bombay High Court in favour of STC against the dues from another foreign buyer i.e Sweetland Trading Pte Ltd., Singapore. As of current date, RPL has gone into liquidation and official liquidator is appointed by Hon'ble High Court of Bombay. The matter is also under investigation by CBI. Banks & Financial institutions have filed legal suit against RPL before DRT/High Court Mumbai, making STC also a party to the case claiming Rs. 47647 lacs.
STC has filed non-money claim suit before different Courts at Delhi & Mumbai for declaring Bills of Exchanges of STC as null and void and unenforceable against STC which were conditionally accepted by STC on back-to-back basis i.e. STC will make payment to Rajat/Banks only upon receipt of export proceeds from the foreign buyers.
STC had filed 272 Criminal Complaints u/s 138 of N.I Act in New Delhi in 2009 which were transferred from MM Court, Patiala House District Court, New Delhi to the 33rd MM Court, Ballard Pier, Mumbai. Now the matters have been again transferred to M.M. Court, Mazgaon, Bombay. STC is claiming an amount or Rs.45,635 lacs from M/s Rajat towards cheque bounce. Cases are at the stage of issuing of summons/arguments on issuing of summons.
Also refer to Note No. 39, for matters other than RPL, as all these matters are sub-judice and/or under investigation of CBI and we are unable to comment upon the genuineness and effect of the same on the Financial Statements.
3. Foreign Currency Receivables and Payables
Currently, as per books of accounts, USD 3,149.35 lacs and Euros 20.90 lacs is receivable from its foreign buyers and USD 41.49 lacs and Pound 0.04 lacs is payable to its foreign suppliers. In nutshell, there are foreign buyers and creditors standing in the financials of STC which have not been revalued in the FY2024-25.
Thus, the Company has not complied with Ind AS 21 (regarding Effects of Changes in Foreign Exchange) by not revaluing the carrying amounts, in most cases, of foreign currency receivables and payables, which are under litigation/disputed. Therefore, we are unable to ascertain the potential impact on the financial statements, if any.
4. Other Current Assets
i. Refer Note No. 14-"Other Current Assets for non-provisioning in respect of Duties and taxes recoverable, CST (coal) amounting to Rs. 6.89 lacs which is non recoverable and still not written off.
ii. Refer Note No. 11- Other Financial Assets -Claims Recoverable: For non-provisioning in respect of Claims Recoverable o/s since more than 3 years amounting to Rs.3157.74 lacs where no present status is ascertained by the management of the Company and still not written off.
This is non-compliance of IND AS -36 as no provision has been made for impaired assets.
All these current assets are being reflected at their carrying amounts instead of on Realization values.
This has resulted into overstatement of Current assets by Rs. 3157.74 lacs and overstatement of profit by Rs.3157.74 lacs.
5. Provisions
Refer Note No. 38, for non-provision of a demand of Rs. 4,743 lacs out of total demand received from Land and Development Office - New Delhi amounting to Rs. 13,283 lacs (for the period March,2004 to July, 2018) which has resulted in overstatement of profit by Rs 4,743 lacs and understatement of liabilities. However, it has been shown as contingent liability. Also, company has not provided for interest accruing on the said demand amount (to be calculated at the rate of 10%) approx. Profits are overstated and liabilities are understated by the amount yet to be ascertained by Management. Director General of Audit has intimated short provision of Rs.75.92 cr towards interest (calculated @10% p.a. on Rs.132.83 cr from 14th July 2018 upto 31st March 2024) which will further cumulate till final payment to L&DO. Profits are overstated and liabilities are understated by the amount yet to be ascertained by Management.
Further, Company has not ascertained liability/provisional liability for Non-compliance of the various conditions of the Lease deed (including non-deposit of 25% of the gross rent received by STC from its tenants) payable to L&DO for the period August 2018 to March 2025, and the interest thereon. Amount is unascertained by the management. Profits are overstated and liabilities are understated by the amount yet to be ascertained by Management.
6. Trade Payables
Refer Note No.21, All the trade payables amounting to Rs. 1,09,654.70 lacs are without any balance confirmation and are outstanding for more than 3 financial years.
No amount is payable to these parties as these are suppliers who have entered into legal agreement with STC wherein no amount is payable to them until and unless the amount is recovered from the buyer. Thus, the management has not accorded any treatment to these trade payables and to that extent, liabilities are overstated.
7. Statutory Dues
GST
Refer Note No.14, The GST input receivable and payable balances are not reconciled by the Company as on March 31,2025. GST input Rs 54.21 lacs - non claimable but no provision has been made. Profit of the company is overstated by the same amount.
Tax Deducted at Source
TDS deducted will be reconciled with form 26AS at the time of submitting Income Tax return, as on the date of report the complete information is not available.
No provision has been made for TDS default of Rs 7.29 lacs pending, submission of correction statements
8. Investments (Refer Note No.8)
• STCL Limited (Subsidiary Company): As confirmed by STC management "Accounts for the FY2024-25 could not be prepared and hence were not made available for consolidation purpose. As per Reg 33 of SEBI (LODR), 2015, every listed company which is having subsidiary company is required to approve its consolidated financial accounts within 60 days from the end of financial year, and in case of non-compliance of Reg 33 of SEBI (LODR), 2015, Regulatory penalty will be levied on STC by each of the stock exchanges separately."
The availability/recovery of asset and/or write off could not be ascertained by the management.
• NSS Satpura Agro Development Company Ltd. (Joint Venture): The company has been strike off as per MCA site. However, still it is appearing in the books of accounts of STC India Limited. The availability/recovery of asset and/ or write off could not be ascertained by the management.
• Sea Lac Agro Ventures Limited: The latest financials of the JV are not available for verification. The availability/ recovery of asset and/or write off could not be ascertained by the management.
• Maharashtra Small Scale Industries Development: The latest financials of the JV are not available for verification. The availability/recovery of asset and/or write off could not be ascertained by the management.
• Andhra Pradesh Trade Promotion Corporation Limited: The latest financials of the JV are not available for verification. The availability/recovery of asset and/or write off could not be ascertained by the management.
• Sindhu Resettlement: The latest financials of the JV are not available for verification. The availability/recovery of asset and/or write off could not be ascertained by the management.
9. Other Equity (Refer Note No.19):
An amount of "Exchange Fluctuation Reserves: Rs.649.53 lacs" & "Bonus Reserve: Rs.0.33 lacs" are appearing in the books of accounts since long. As confirmed by management, these reserves are created long back and details shall be provided in next financial year. We are unable to ascertain its possible impact, if any, on the standalone financial statements of the Company.
10. Other Observations
i. Refer Note No. 24, customer at credit includes amount payable to U.P. Government amounting to Rs.603 lacs. As informed by the management, the company has made various other claims on U.P Government and accordingly dues of Rs. 3382.23 lacs is recoverable from U.P. Government for which debit note dated March 10,2014 was raised. However, the said claim was not recognized in the standalone financial statements of the company till date, as
its ultimate collection was not certain. In absence of information on acceptability of the said claim by the UP Government, we are unable to ascertain its possible impact, if any, on the standalone financial statements of the Company.
ii. The impact of the following observations is not ascertainable: -
a. Refer to Cases and Disputes and matters under Litigation and amounts covered under Contingent Assets and Contingent Liabilities, since majority of the matters are subjudice, it is not possible to quantify the liabilities and the interest obligation if any on these cases.
Refers to Note No.38, in respect of litigation matters, their present status and provisioning, if any, required and on-going investigations into the alleged irregularities; further, the Company's past operations have exposed it to the risk of extensive litigation and contractual claims from third parties with increased litigation costs not fully provided for. Due to the range of potential outcomes, voluntary retirement of employees dealing with these cases and the significant uncertainty around the resolution of various claims, the amount of ultimate liabilities, if any, to be recorded in the statements as provision is not ascertainable.
b. Refer to Claims recoverable from HHEC & CCIC, co-owner to the property at Jawahar Vyapar Bhawan, who have not paid their share of expenses to STC since last many years amounting to Rs. 2693.54 lacs (Rs. 687.69 lacs for HHEC & Rs.2005.85lacs for CCIC) as on March 31,2025. The matter is said to be under correspondence with HHEC & CCIC.
STC received a demand of Rs. 8,002 Lacs from NDMC during 2016-17 towards property tax for the period from 1999-2000 to 2016-17 and the same has been allocated proportionately to CCIC & HHEC. Out of total demand of Rs. 8,002 Lacs, STC has paid Rs. 2,212 Lacs during 2016-17 against which CCIC has paid its share of Rs. 115 Lacs. However, HHEC has not paid its share, hence provision to the extent of share of HHEC out of payment of Rs. 2,212 Lacs has already been made. The matter was pending at Patiala House Court, Delhi, which has vide its order dated 24.03.2025.
HHEC in pursuance to its Board approval dtd. 29.01.2024 submitted a proposal for surrendering back its share of 4.5% office space in JVB and 64 staff quarters at STC housing colony at zero cost to STC in lieu of outstanding dues payable to STC.
Accordingly, STC's Board on 08.08.2024 accorded approval to their offer and HHEC has handed over second floor annexe (3,795.21 sq.ft.) out of 12,667sq.ft.to STC on 26.03.2025.
Since separate valuation of the 2nd floor annex is not available and the total dues pending from HHEC is yet to be reconciled, the necessary accounting entries shall be passed in the books of accounts only upon vacation/ handing of the entire share as mentioned above by HHEC. Refer Note No. 39
c. Borrowings
Refer to Note No. 20, the view of the default by the company in paying due to interest amount to the banks, STC was declared NPA. The lender banks have initiated DRTproceedings against the company. The memorandum of the OTS (MOTS) proposal with lender banks is still in progress
Borrowings have been reflected at Rs.80623.24 lacs. Further, STC is in the process of finalizing the OTS proposal with the lender banks wherein, STC is pursuing alternative course of settlement for payment of Rs. 5,000 lacs upfront and Rs. 625 lacs as monthly instalment for 24 months to lender banks instead of transfer of immovable properties & formal proposal submitted to the lender banks which is under consideration with lender bank. The same has been updated in DRT proceeding & the next date of hearing is 15.07.2025. The amount of liability is subject to final settlement / court order/Approval from Board of Director of the company.
NFRA circular dated 28.11.2022, states that interest has to be recognized on its borrowings even if classified as NPA by lender banks and OTS is being negotiated with them. STC is expecting the OTS will be concluded during FY 2025-26. Hence, the appropriate treatment in books shall be done at that time. Impact of OTS proceedings and interest liability on borrowing is not quantified by management We conducted our audit in accordance with the Standards on Auditing (SAs) specified under section 143(10) of the Companies Act, 2013. Our responsibilities under those Standards are further described in the Auditor's Responsibilities for the Audit of the Standalone Financial Statements section of our report. We are independent of the Company in accordance with the Code of Ethics issued by the Institute of Chartered Accountants of India together with the ethical requirements that are relevant to our audit of the financial statements under the provisions of the Companies Act, 2013 and we have fulfilled our other ethical responsibilities in accordance with these requirements and the ICAI's Code of Ethics.
We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for opinion (including the basis for the qualified opinion)
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 financial statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters.
Information Other than the Financial Statements and Auditor's Report thereon
The Company's Board of Directors is responsible for the other information. The other information comprises the information included in the Management Discussion and Analysis, Annual Report on CSR activities, Report on Corporate Governance, Secretarial Auditor's Report Information, but does not include the standalone financial statements and our auditor's report thereon. The Management Discussion and Analysis, Annual Report on CSR activities, Report on Corporate Governance, Secretarial Auditor's Report is expected to be made available to us after the date of this auditors' report. Our opinion on the standalone financial statements does not cover the other information and we do not express any form of assurance conclusion thereon.
In connection with our audit of the standalone financial statements, our responsibility is to read the other information identified above when it becomes available to us and, in doing so, consider whether the other information is materially inconsistent with the standalone financial statements or our knowledge obtained during the course of our audit or otherwise appears to be materially misstated.
When we read such other information as and when made available to us and if we conclude that there is a material misstatement therein, we are required to communicate the matter to those charged with governance.
Other Matters
• Non - compliance of Regulation 33 SEBI (LODR): As per Reg 33 of SEBI (LODR), 2015, every listed company shall publish its Financial Results within 60 days from the end of the last quarter, and in case of non-compliance of Reg 33 of SEBI (LODR), 2015, Regulatory penalty will be levied on The State Trading Corporation of India Limited by each of the stock exchanges separately.
• Statutory Committee: As confirmed by STC management, the company is unable to re-constitute the Statutory Committees i.e. Audit Committee, Stakeholders Relationship Committee, Nomination & Remuneration Committee, CSR Committee and Risk management Committee due to non-availability of Independent Directors on the Board of the Company
• Secretarial Audit Report is not yet received upto the date of Annual audit.
Responsibilities of Management and Those Charged with Governance for the Standalone Financial Statements
The Company's Board of Directors are responsible for the matters stated in section 134(5) of the Companies Act, 2013 ("the Act") with respect to the preparation of these standalone financial statements that give a true and fair view of the financial position, financial performance, (changes in equity) and cash flows of the Company in accordance with the accounting principles generally accepted in India, including the Indian Accounting Standards (Ind AS) specified under section 133 of the Act read with the Companies (Indian Accounting Standards) Rules, 2015 as amended. 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 implementation and maintenance of accounting policies; making judgments and estimates that are reasonable and prudent; and design, implementation and maintenance of adequate internal financial controls, that were operating effectively for ensuring the accuracy and completeness of the accounting records, relevant to the preparation and presentation of the financial statement that give a true and fair view and are free from material misstatement, whether due to fraud or error.
Management has prepared these financial statements on non-going concern basis as per decision of the Board of Directors.
Board of Directors are also responsible for overseeing the Company's financial reporting process. However, it is to point out that there are no Full Time Working Directors in the Company as on 31st March, 2025 and the Company is functioning only with the assistance of Independent Directors and Director (Finance) on Additional Charge.
Auditors' Responsibilities for the Audit of the Standalone Financial Statements
Our objectives are to obtain reasonable assurance about whether the standalone financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor's 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 financial statements.
As part of an audit in accordance with SAs, we exercise professional judgment and maintain professional skepticism throughout the audit. We also:
• Identified and assessed the risks of material misstatement of the 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.
• Obtained 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.
• Evaluated the appropriateness of accounting policies used and the reasonableness of accounting estimates and related disclosures made by management.
• Concluded on the appropriateness of management's use of the non-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 Company's ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditor's report to the related disclosures in the 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 auditor's report. However, future events or conditions may cause the Company to cease to continue as a going concern.
• Evaluated the overall presentation, structure and content of the financial statements, including the disclosures, and whether the financial statements represent the underlying transactions and events in a manner that achieves fair presentation.
However the financial statements of the Company have been prepared on non-going concern basis as decided by the Board of Directors.
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 and importance in the audit of the financial statements of the current period and are therefore the key audit matters. We describe these matters in our auditor's 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 (Auditor's 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, and on the basis of such checks of the books and records of the Company as we considered appropriate and according to the information and explanation given to us, we give in the Annexure "A" a statement on the matters specified in paragraphs 3 and 4 of the Order, to the extent applicable.
2. As required by Section 143(3) of the Act, we report that:
i. We have sought and obtained all the information and explanations, except for the matters referred in "Basis for Qualified Opinion"- Impact of which is partly non-ascertainable, which to the best of our knowledge and belief were necessary for the purposes of our audit and if not, the details thereof and the effect of such information on the financial statements.
ii. In our opinion, proper books of account as required by law have been kept by the Company, except for the matters referred in "Basis for Qualified Opinion', so far as it appears from our examination of those books and proper returns adequate for the purposes of our audit have been received from the company.
iii. The Balance Sheet, the Statement of Profit and loss including the Statement of Other Comprehensive Income, the Cash Flow Statement and Statement of Changes in Equity dealt with by this Report are in agreement with the books of account.
iv. In our opinion, the aforesaid standalone financial statements comply with the Indian Accounting Standards, except for the Basis for Qualified opinion, specified under Section 133 of the Act, read with the Companies (Indian Accounting Standards) Rules, 2015 as amended.
v. The going concern matter described under "Material uncertainty in relation to Going Concern" paragraph above, in our opinion, may have an adverse effect on the functioning of the company.
vi. Pursuant to the Notification No. GSR 463(E) dated 5th June 2015 issued by the Ministry of Corporate Affairs, Government of India, provisions of sub-section (2) of Section 164 of the Act are not applicable to the Company, being a Government Company;
vii. With respect to the adequacy of the internal financial controls over financial reporting of the Company and the operating effectiveness of such controls, refer to our separate Report in "Annexure B". Our report expresses a qualified opinion on the adequacy and operating effectiveness of the Company's internal financial controls over financial reporting.
viii. Pursuant to the Notification No. GSR 463(E) dated 5th June 2015 issued by the Ministry of Corporate Affairs, Government of India, provisions of Section 197 of the Companies Act, 2013, are not applicable to the Company, being a Government Company; and
ix. With respect to the other matters to be included in the Auditor's Report in accordance with Rule 11 of the Companies (Audit and Auditors) Rules, 2014, as amended in our opinion and to the best of our information and according to the explanations given to us:
a. The Company has not been able to disclose the impact of pending litigations on its financial position in its financial statements, refer note 38 & 39 to the financial statements.
b. The Company did not have any long-term contracts including derivative contracts for which there were any material foreseeable profits.
c. During the year, the Company has made no transfer to Investor Education and Protection Fund due to heavy accumulated profits. Therefore, question of delay in transferring amounts, required to be transferred, by the Company does not arise.
d. i) The Management of the Company , whose financial statements have been audited under the Act, have represented to us that, to the best of their knowledge and belief, other than as disclosed in notes to accounts, no funds (which are material either individually or in the aggregate) have been advanced or loaned or invested (either from borrowed funds or share premium or any other sources or kind of funds) by the Company to or in any other person or entity, including foreign entity ('Intermediaries') with the understanding, whether recorded in writing or otherwise, that the intermediary shall, whether 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 provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries.
ii) The respective Management of the Company, whose financial statements have been audited under the Act, have represented to us that, to the best of their knowledge and belief, no funds (which are material either individually or in the aggregate) have been received by the Company from any person or entity, including foreign entity ('Funding Parties') with the understanding, whether recorded in writing or otherwise, that the Company shall, 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 provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries.
(iii) Based on the audit procedures that have been considered reasonable and appropriate in the circumstances performed by us, whose financial statements have been audited under the Act, nothing has come to our attention that has caused us to believe that the representations under sub-clause (i) and (ii) of Rule 11 (e) as provided under (a) and (b) above, contain any material misstatement.
e. There has been no dividend declared during the year.
f. According to the information and explanation provided to us and based on our examination which included test checks, the Company have used accounting software (Tally Prime) for maintaining its books of account, which have a feature of recording audit trail (edit log) facility and the same has operated throughout the year for all relevant transactions recorded in the respective software. Audit trail at database level is enabled in Tally Software for all the relevant transactions recorded in the software and the audit trail feature has not been tampered. The audit trail has been preserved by the company as per the statutory requirements for record retention at application level and for database level with effect from its enablement.
According to the information and explanation provided to us and based on our examination which included test checks, Audit trail (edit log) is being maintained at application level and for database level in respect of, "Performance Management System", Payroll Software and "Leave Management System" upto 31.03.2025 which are not interfaced with each other as well as the accounting software. As a result of above, Manual Accounting entries are being made on periodical basis in the Tally ERP Accounting software.
3. We are enclosing our report in terms of Section 143 (5) of the Act, on the directions and sub-directions issued by the Comptroller and Auditor General of India, on the basis of such checks of the books and records of the Company as we considered appropriate and according to the information and explanations given to us, in Annexure- C.
For P V A R & ASSOCIATES
CHARTERED ACCOUNTANTS
FRN No. 005223C
Sd/-
(CA RUCHI AGARWAL)
Partner
Membership No. 504134
UDIN : 25504134BMGZFP6893
Place: New Delhi
Date: 13.06.2025
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