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SJVN LTD.

09 May 2025 | 12:00

Industry >> Power - Generation/Distribution

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ISIN No INE002L01015 BSE Code / NSE Code 533206 / SJVN Book Value (Rs.) 37.18 Face Value 10.00
Bookclosure 21/02/2025 52Week High 160 EPS 2.32 P/E 38.34
Market Cap. 34939.81 Cr. 52Week Low 81 P/BV / Div Yield (%) 2.39 / 2.02 Market Lot 1.00
Security Type Other

AUDITOR'S REPORT

You can view full text of the latest Director's Report for the company.
Year End :2024-03 

The revised Independent Auditor's Report on Standalone Ind AS Financial Statements SJVN Limited is issued in supersession to our earlier Report dated May 29, 2024. In compliance of the Comptroller & Auditor General (C&AG) of India's Provisional comments dated 11th July,2024 on "key audit matter on Regulatory Deferral Account Debit Balances", which does not affect the true & fair view and our opinion on the Standalone Ind AS Financial Statements as expressed earlier in any manner. The revised report is issued adding the aforesaid key audit matter as pointed out by CA&G of India in our earlier Independent Auditor's report. Further, we confirm that none of the figures have been undergone any change in the Standalone Ind AS Financial Statements of the Company as at 31st March 2024.

Opinion

We have audited the accompanying standalone financial statements of SJVN Limited (''the Company"), which comprise the Balance Sheet as at March 31, 2024, the Statement of Profit and Loss (including Other Comprehensive Income), Statement of changes in Equity, Statement of Cash Flows for the year then ended, and Notes to the financial statements including a summary of the material accounting policies and other explanatory information (hereinafter referred to as "the standalone financial statements").

In our opinion and to the best of our information and according to the explanations given to us, the aforesaid standalone financial statements give the information required by the Companies Act, 2013 ("the Act") in the manner so required and give a true and fair view in conformity with the accounting principles generally accepted in India and Indian Accounting Standards prescribed under section 133 of the Act read with companies (Indian Accounting Standard) Rules 2015, as amended, (Ind AS) and other accounting principles generally accepted in India, of the state of affairs (financial position) of the Company as at March 31, 2024 and its profit (financial performance including Other Comprehensive Income), Change in Equity and its cash flows for the year ended on that date.

Basis for Opinion

We conducted our audit of the standalone financial statements in accordance with the Standards on Auditing 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 (ICAI) together with the independence requirements that are relevant to our audit of the standalone financial statements under the provisions of the Act and the Rules made there under, 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 our audit opinion on the standalone financial statements.

Emphasis of Matter:

We draw attention to the following matters:

a. Note No. 2.2 (b) with respect to the Bagodra Solar Power Project has been transferred to SJVN Green Energy Limited, a wholly owned subsidiary during the F.Y. 2023-24.

b. Note No. 2.16 with respect to the Land and buildings which are underutilized and not yielded the appropriate returns have been transferred from Property, plant S equipment's and classified as held for sale. Land and Building situated at Dehradun, which had been classified as held for sale during a previous year, has been sold during the year and profit on sale of the same amounting to '3370 lakh has been shown under other income.

c. Note No. 2.31 to the standalone financial statements which describes the Energy sales and interest from beneficiaries include an amount of '1748 lakh and Nil respectively (Previous year '27033 lakh and '11694 lakh) respectively pertaining to earlier years on receipt of tariff orders during the year.

d. Note No. 2.37 (a) During the financial year-2023-24, the Government of Himachal Pradesh has cancelled the allotment of the Jangi Thopan Hydro Electric Project of 804MW, which was allotted to SJVN on a BOOT basis. The company as well as the Ministry of Power, Government of India, has requested the Government of Himachal Pradesh to revoke the cancellation. Pending outcome of these requests, a provision has been created of '1776 lakhs for expenditure incurred on this project.

e. Note No. 2.37 (c) During the year Hon'ble Delhi High Court set aside the Arbitration Tribunal Award in respect of the minimum wages case in respect of Nathpa Jhakri Hydro Power Station (NJHPS) vide Judgment dated 12.07.2023. This judgment by the Single Judge was challenged by the contractor in an appeal under Section 37 of the Arbitration S Conciliation Act before the Double Bench of the Hon'ble Delhi High Court. The Double Bench up held the judgment passed by the Single Judge. Since, there is presently no obligation on the company, the provision for the same created during earlier years has been reversed.

f. Note No. 2.47 As required by Ind AS 36, an assessment of impairment of assets was carried out and based on such assessment, the company has recognized impairment losses of '13870 lakh (PY: Nil) in respect of following renewable projects during the year-

i) In respect of Sadla Wind Power Plant, impairment loss of '10,108 lakh (PY: Nil) has been recognized under depreciation, amortization S impairment expenses in statement of profit S loss. The recoverable amount of the Cash Generating Unit (CGU) is value in use and has been assessed at '14,232 lakh. The carrying amount of the CGU is '24,340 lakh.

ii) In respect of Khirvire Wind Power Plant, impairment loss of '3,488 lakh (PY: Nil) has been recognized under depreciation, amortization S impairment expenses in statement of profit S loss. The recoverable amount of the Cash Generating Unit (CGU) is value in use and has been assessed at '10,982 lakh. The carrying amount of the CGU is '14,470 lakh.

iii) In respect of Charanka Solar PV Power Plant, impairment loss of '274 lakh (PY: Nil) has been recognized under depreciation, amortization S impairment expenses in statement of profit S loss. The recoverable amount of the Cash Generating Unit (CGU) is value in use and has been assessed at '1,952 lakh. The carrying amount of the CGU is '2,226 lakh.

g. Note No. 2.48(B)(v) with respect to imposition of Water Cess by Govt. of Himachal Pradesh vide notification dated 16.02.2023 on the generation of electricity in Himachal Pradesh. The company has filed writ petition against the said notification with the Hon'ble High Court of Himachal Pradesh. Subsequently, the Hon'ble High Court of Himachal Pradesh has ruled in favour of the company, declaring the levy unconstitutional. However, the Government of Himachal Pradesh has filed an appeal to the Supreme Court against the decision. The amount billed till date has been disclosed contingent liabilities of '28019 Lakhs.

h. Note No. 2.63 with respect to Three hydro power projects - 210MW Luhri Hydro Electric Project Stage-1, 382MW Sunni Dam Hydro Electric Project, and 66MW Dhaulasidh Hydro Electric Project - were allotted to SJVN through Memorandum of Understanding (MOU) by the Government of Himachal Pradesh (GoHP). As per clause 6 of the MOU, the detailed terms and conditions of Implementation Agreements shall be formulated with the mutual consent of GoHP and SJVN. GoHP, via letter dated 06.08.2022, forwarded a mutually agreed Implementation Agreement to be signed between GoHP and SJVN. However, Implementation Agreement for these projects is yet to be signed. Pending signing of mutually Agreed Implementation Agreement between GoHP and SJVN for these projects, SJVN has commenced work on these projects to avoid time and cost overruns and an expenditure of '226,041 Lakh has been incurred on these projects till 31.03.2024. The Government of Himachal Pradesh has issued a notice with regard to commencement of work on these projects in absence of Implementation Agreement. GoHP seeks to re-negotiate the previously agreed terms S conditions and relaxations in respect of these projects before signing of Implementation Agreement. SJVN has submitted their replies to the above notice and also filed a petition in the Hon'ble High Court of Himachal Pradesh to address the issue. The Hon'ble High Court has directed GoHP that no coercive action shall be taken against SJVN with regard to the subject matter of dispute. The case is currently pending and the company is actively engaged in resolving the matter. (GoHP)

Our opinion is not modified in respect of these matters.

Key Audi! Mailers

Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the standalone financial statements of the current period. These matters were addressed in the context of our audit of the standalone financial statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters.

For each matter below, description of how our audit addressed the matter is provided in that context. We have determined the matters described below to be the key audit matters to be communicated in our report.

S.No.

Key Audit Mailer

How our audit addressed the Key Audit Matter

1

Contingent Liabilities and provisions:

There are number of litigations pending before various forums against the company and the management's judgement is required for estimating the amount to be disclosed as contingent liability and for creating the adequate amount of provision, wherever required.

We identified this as a key audit matter because the estimates on which these amounts are based involve a significant degree of management judgement in interpreting the cases and it may be subject to management bias.

(Refer Note No. 2.48 to the Standalone Financial Statements , read with the Material Accounting Policy No. 1.18)

We have obtained an understanding of the company's internal instructions and procedures in respect of estimation and disclosure of contingent liabilities and adopted the following audit procedures:- understood and tested the design and operating effectiveness of controls as established by the management for obtaining all relevant information for pending litigation cases;

- discussed with the management any material developments and latest status of legal matters;

- examined management's judgements and assessments whether provisions are required;

- considered the management assessments of those matters that are not disclosed as the probability of material outflow is considered to be remote;

- reviewed the adequacy and completeness of disclosures;

Based on the above procedures performed, the estimation and disclosures of contingent liabilities and creation of provisions are considered to be adequate and reasonable.

2.

Properly, Plant £ Equipment:

There are areas where management judgement impacts the carrying value of property plant and equipment and their respective depreciation rates. These include the decision to capitalize or expense costs; the annual asset life review; the timeliness of the capitalisation of assets and the use of management assumptions and estimates for the determination or the measurement and recognition criteria for assets retired from active use. Due to the materiality in the context of the balance sheet of the Company and the level of judgement and estimates required, we consider this to be as area of significance.

(Refer Note No. 2.1 to the Standalone Financial Statements, read with the Material Accounting Policy No. 1.3)

We assessed the controls in place over the fixed asset cycle, evaluated the appropriateness of capitalisation process Performed tests of details on costs capitalised, the timeliness and accuracy of the capitalisation of the assets and the de-recognition criteria for assets retired from active use. In performing these procedures, we reviewed the judgements made by management including the nature of underlying costs capitalised; determination of realizable value of the assets retired from active use; the appropriateness of asset lives applied in the calculation of depreciation; the useful lives of assets prescribed in schedule II of the Companies Act, 2013 and the useful lives of certain assets as per the technical assessment of the management.

We have observed that the management has regularly reviewed the aforesaid judgements and there are no material deficiencies in measurement and recognition of property, plant and equipment.

3.

Capital work-in-progress (CWIP):

The company is involved in various capital works like construction of new power projects, installation of new plant and machinery, civil works etc. These projects/works take a substantial period of time to get ready for intended use and due to their materiality in the context of the balance sheet of the Company, this is considered to be an area which had the significant effect on the overall audit strategy and allocation of resources in planning and completing our audit.

(Refer Note No. 2.2 to the Standalone Financial Statements, read with the Material Accounting Policy No. 1.4 S 1.5)

We performed an understanding and evaluation of the system of internal control over the capital work-in-progress, with reference to identification and testing of key controls.

When it is ready for the intended use, we assessed the progress of the project and the intention and ability of the management to carry forward and bring the asset to its state of intended use.

We assessed the timeliness and accuracy of capitalisation of assets when it is ready for the intended use.

During the period under review, we found that Jangi Thopa hydro Project has been written off from the books.

4.

Deferred Tax Asset relating io MAT Credit Entitlement:

We have obtained an understanding for recognition of deferred tax asset

The company has recognised deferred tax asset relating to MAT credit entitlement during the year. Utilization of MAT credit will result in lower outflow of Income Tax in future years. The recoverability of this deferred tax asset relating to MAT credit entitlement is dependent upon the generation of sufficient future taxable profits to utilize such entitlement within the stipulated period prescribed under the Income Tax Act,1961.

We identified this as a key audit matter because due to use of management estimate in forecasting future taxable profits for recognition of MAT credit entitlement considering the recoverability of such tax credits within allowed time frame as per the provisions of the Income Tax Act,1961. (Refer Note 2.40)

relating to MAT credit entitlement. We have reviewed the estimate of management regarding future taxable profits and reasonableness of the considerations /assumptions used for the same.

Based on the above procedures performed, the recognition and measurement of Deferred tax asset relating to MAT credit entitlement are considered adequate and reasonable. (Refer Note 2.40)

5.

Recoverability of carrying value of property plant and equipment:

As at 31st March 2024, the Company had significant amounts of property, plant and equipment, and capital work in progress under development which were carried at historical cost less depreciation.

We focused our efforts on the Cash Generating Unit ("CGU") at (a) Sadla Wind Power Plant; (b) Khirvire Wind Power Plant;(c) Charanka Solar PV Power Plant; as it had identified impairment (charge) / reversal indicators.

Recoverability of property plant and equipment and capital work in progress being carried at cost has been identified as a key audit matter due to:

- The significance of the carrying value of assets being assessed.

- The fact that the assessment of the recoverable amount of the Company's CGU involves significant judgements about the future cash flow forecasts, start date of the plant and the discount rate that is applied.

(Refer Note No. 2.1 S 2.2 to the Standalone Financial Statements, read with the material Accounting Policy No. 1.4)

Our audit procedures included the following:

• Obtained and read the Company's policies, processes and procedures in respect of identification of impairment indicators, recording and disclosure of impairment charge/ (reversal) and identified key controls. For selected controls we have performed tests of controls.

• Assessed through an analysis of internal and external factors impacting the Company, whether there were any indicators of impairment in line with Ind AS 36.

• In relation to the CGU at (a) Sadla Wind Power Plant; (b) Khirvire Wind Power Plant; (c) Charanka Solar PV Power Plant; segment where impairment (charge) / reversal indicators were identified, obtained and evaluated the valuation models used to determine the recoverable amount by assessing the key assumptions used by management, which included:

- Evaluated the valuation methodology adopted by the management i.e. determination of Value-in-Use in light of the facts and circumstances of the matter.

- Assessed management's forecasting accuracy by comparing prior year forecasts to actual results and assessed the potential impact of any variances.

- Compared the production forecasts used in the impairment tests with management's approved reserves and resources estimates

- Tested the weighted average cost of capital used to discount the impairment models.

- Tested the integrity of the models together with their clerical accuracy.

- Tested arithmetical accuracy of bifurcation of expenses

- Tested the reports provided by management's external experts for impairment testing for assets of the Company

• Assessed the disclosures made by the Company in this regard and evaluated the considerations leading to disclosure of above impairment (change) / reversal.

6.

Regulatory Deferral Account Debit Balances and accruals of revenue pending tariff Notifications

The operating activities of the Company are subject to cost of service regulations whereby tariff charged for electricity generated is based on allowable capital and other cost and expenses and stipulated return there against. The Company invoices its customers on the basis of pre-approved/ provisional tariff which is subject to truing up. The Company recognizes revenue as the amount invoiced to customers based on pre-approved/provisional tariff rates agreed with the regulator. As the Company is entitled to a fixed return on equity, the difference between the revenue recognized and entitlement as per the regulations is recognized as regulatory assets/ liabilities.

As at March 31, 2024, the Company has recognized Regulatory Deferral Account Debit balances of '78,435 lakhs ('79,612 lakhs to March 31, 2023) as given in Note 2.17 of the Standalone Financial Statements. Regulatory Deferral Accounts Debit Balances are determined based on tariff regulations and past tariff orders and are subject to verification and approval by the regulators. The Regulatory Deferral Accounts Debit Balances are recognized on undiscounted basis based on the estimates and assumptions with respect to the probability that future economic benefit will flow to the entity as a

Our audit procedures based on which we arrived at the conclusion regarding reasonableness of the carrying value of Regulatory Deferral Account Debit Balances include the following:

Understanding and testing the design and operating effectiveness of controls as established by the management for accrual of income and determination of the amounts recoverable there against.

Obtaining and understanding of the amount recoverable in terms of CERC Regulations and assessing, testing and evaluating the reasonableness thereof keeping in view the significant judgements applied by the management for such assessments.

The above includes the evaluation of the CERC guidelines and acceptance of the claim made by the Company in the past and the trend of disallowances on various count and adherences and compliances thereof by the management and rationale for assumptions taken under the given situation and business environment.

Assessing the application of provisions of Ind AS 114, Guidance Note on Accounting of Rate Regulated Activities issued by ICAI for recognition of regulatory deferral balances.

result of actual or expected action of regulator under applicable regulatory framework and therefore recoverability thereof is dependent upon Tariff Regulations and related approvals and notifications.

The accruals made as above are vital and proprietary to the business in which the Company is operating. In absence of specific notification and rate fixation, these are based on the management's assumptions and estimates which are subject to finalization of tariff by CERC and commencement of operations of the Projects.

Reviewing the adequacy and reasonableness of amounts recognized and measurement policies followed by the Company and adequacy of the disclosure made with respect to the same in the Standalone Financial Statements of the Company.

Information Other than the Standalone Financial Statements and Auditor's Report Thereon

The Company's Board of Directors is responsible for the preparation of the other information. The other information comprises the information included in the Management Discussion and Analysis, Board's Report including Annexure to Board's Report, Business Responsibility Report, Corporate Governance and Shareholder's Information, (but does not include the standalone financial statements and our auditor's report thereon), which are 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 hereon.

In connection with our audit of the standalone financial statements, our responsibility is to read the other information 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 the other information, if we conclude that there is a material misstatement therein, we are required to communicate the matter to those charged with governance and take appropriate actions, if required.

Responsibility of Management and Those Charged with Governance for the Standalone Financial Statements

The Company's Board of Directors is responsible for the matters stated in section 134(5) of 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, total comprehensive income, changes in equity and cash flows of the Company in accordance with accounting principles generally accepted in India, including the Indian Accounting Standards (Ind AS) prescribed under section 133 of the Act.

This responsibility also includes maintenance of adequate accounting records in accordance with the provisions of the Act for safeguarding the assets of the Company and for preventing and detecting frauds and other irregularities; selection and application of appropriate accounting policies; making judgments and estimates that are reasonable and prudent; and design, implementation and maintenance of adequate internal financial controls, that were operating effectively for ensuring the accuracy and completeness of the accounting records, relevant to the preparation and presentation of the standalone financial statements that give a true and fair view and are free from material misstatement, whether due to fraud or error.

In preparing the standalone financial statements, management is responsible for assessing the Company's ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless management either intends to liquidate the Company or to cease operations, or has no realistic alternative but to do so.

The Board of Directors are responsible for overseeing the Company's financial reporting process.

Auditor's 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 standalone financial statements.

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

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

• Obtain an understanding of internal financial controls relevant to the audit in order to design audit procedures that are appropriate in the circumstances. Under section 143(3)(i) of the Act, we are also responsible for expressing our opinion on whether the Company has adequate internal financial controls system in place and the operating effectiveness of such controls.

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

• Conclude on the appropriateness of management's use of the going concern basis of accounting and, based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the 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 standalone 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.

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

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

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

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

From the matters communicated with those charged with governance, we determine those matters that were of most significance in the audit of the standalone 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 in terms of Section 143(11) of the Act, we

give in "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(5) of the Act, for the additional directions under the Companies Act' 2013, we have annexed Annexure "B" to this report for the

additional direction under section 143(5) of the Companies Act' 2013 as issued by the Comptroller and Auditor General of India.

3. As required by Section 143(3) of the Act, based on our audit we report that:

a) We have sought and obtained all the information and explanations which to the best of our knowledge and belief were necessary for the purpose of our audit;

b) In our opinion proper books of account as required by law have been kept by the Company so far as it appears from our examination of those books.

c) The Balance Sheet, the Statement of Profit and Loss (including Other Comprehensive Income), the statement of cash flows and Statement of Changes in Equity dealt with by this Report are in agreement with the relevant books of account.

d) In our opinion, the aforesaid standalone financial statements comply with the Accounting Standards specified under Section 133 of the Act, read with relevant rules issued thereunder.

e) In view of exemptions given vide Notification No. G.S.R. 463(E) dated 5th June 2015 issued by Ministry of Corporate Affairs, the provisions of Section 164 (2) of the Companies Act, 2013 regarding disqualification of directors are not applicable to the company.

f) With respect to the adequacy of the internal financial controls over financial reporting of the company and the operating effectiveness of such controls, kindly refer to our separate report in Annexure "C”

g) As per Notification No. GSR 463(E) dated 5th June 2015 issued by Ministry of Corporate Affairs, the provisions of Section 197 of the Companies Act, 2013 is not applicable to the Government Companies. Accordingly, reporting in accordance with requirements of provisions of section 197(16) of the act is not applicable on the company.

h) 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:

i. The company has disclosed the impact of pending litigations on its financial position in its standalone financial statements. Refer Note No. 2.48 to the standalone financial statements;

ii. The company has made provision, as required under the applicable law or accounting standards, for material foreseeable losses, if any, on long term contracts including derivative contracts;

iii. There has been no delay in transferring amounts which were required to be transferred to Investor Education and Protection Fund by the company.

iv. (a) The management has represented that, to the best of its knowledge and belief, no funds have been advanced or loaned or invested by the company to or in any other person(s) or entities, including foreign entities ("Intermediaries"), with the understanding that the intermediary shall whether directly or indirectly lend or invest in other persons or entities identified in any manner by or on behalf of the company (Ultimate Beneficiaries) or provide any guarantee, security or the like on behalf of ultimate beneficiaries.

(b) The management has represented that, to the best of its knowledge and belief, no funds have been received by the company from any person(s) or entities including foreign entities ("Funding Parties") with the understanding that such 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 guarantee, security or the like on behalf of the Ultimate beneficiaries.

(c) Based on such audit procedures as considered reasonable and appropriate in the circumstances, nothing has come to our notice that has caused us to believe that the above representations given by the management contain any material mis-statement.

v. The dividend declared or paid during the year by the company is in compliance of section 123 of the Act.

vi. Based on our examination which included test checks, the company has used an accounting software for maintaining its books of account which has a feature of recording audit trail (edit log) facility and the same has operated throughout the year for all relevant transactions recorded in the software. Further, during the course of our audit, we did not come across any instance of audit trail feature being tampered with.

For APT & Co LLP Chartered Accountants FRN: 014621C/N500088

(Ashish Goyal)

Partner

Membership No 534775 UDIN: 24534775BKAK2R7159 Place: New Delhi Date: August 05,2024