To
The Members,
Natural Biocon (India) Limited
Your directors have pleasure in presenting their 32nd Annual Report on the business and operations of the Company together with its Audited Accounts for the year ended March 31, 2024. The Management Discussion and Analysis is also included in this Report.
1. FINANCIAL RESULTS:
The highlights of the financial results of the Company for the financial year ended March 31, 2024 are as under:
(Rs. In Lacs)
Particulars
Year Ended
Gross Sales/Income
Depreciation
Profit/(Loss) before Tax
T axes/ Deferred Taxes
Profit/(Loss) After Taxes
P& L Balance b/f
2. BRIEF DESCRIPTION OF THE COMPANY'S WORKING DURING THE YEAR/STATE OF COMPANY'S AFFAIR:
During the year under review the total income was Rs. 1353.37 Lacs as compared to Rs. 125.43 Lacs of the previous Year 2022-23. After making all necessary provisions for current year and after taking into account the current year net profit and total provisions for taxation, Rs. 15.27 Lacs surplus carried to Balance Sheet.
During the year, world-wide restrictions have been imposed against use of coal-tar colors and world health, food and drug authorities have restricted the use of coal-tar color in consumables while some of the European countries have virtually banned the use of coal-tar color and hence strictly restricted its uses especially in consumable items. Hence management of the Company has also decided to venture into the chemical and agriculture produce, also due to which some of the region of the State of Gujarat has been selected for trading in the chemical and agriculture produce segment to the various related industries. The Company has received good response in the chemical and agriculture produce segment.
3. CHANGE IN THE NATURE OF BUSINESS:
The Company is engaged in the Business of Agriculture Activity. There was no change in the nature of the business of the Company during the year under review.
4. CHANGE OF NAME:
During the year the company has not changed its name.
5. FINANCE:
The Company has not borrowed loan from any Bank during the year under review.
6. SHARE CAPITAL:
The paid-up Equity Share Capital as on March 31, 2024 was Rs. 11,37,28,000.
A) Allotment of equity shares pursuant to conversion of convertible warrants:
During the year under review company has not issue equity shares pursuant to conversion of convertible warrants.
B) Issue of equity shares with differential rights:
During the year under review, the Company has not issued any shares with differential voting rights.
C) Issue of sweat equity shares:
During the year under review, the Company has not issued any sweat equity shares.
D) Issue of employee stock options:
During the year under review, the Company has not issued any employee stock options.
E) Provision of money by company for purchase of its own shares by employees or by trustees for the benefit of employees:
The Company has no scheme of provision of money for purchase of its own shares by employees or by trustees for the benefit of employees. Hence the details under rule 16 (4) of Companies (Share Capital and Debentures) Rules, 2014 are not required to be disclosed.
7. DIVIDEND:
The Board of Director of the company has not recommended dividend for the financial year 2023-24.
8. REPORT ON PERFORMANCE AND FINANCIAL POSITION OF SUBSIDIARIES, ASSOCIATES AND JOINT VENTURE COMPANIES:
The Company has no subsidiaries, Associates and Joint Venture Companies.
9. DIRECTORS AND KMP:
a) Key Managerial Personnel:
The following are the Key Managerial Personnel of the Company.
Mr. Arunkumar Prajapati
Mr. Gopal Trivedi
With deep regret, we report sad demise of Shri. Manish Patel, the Chief Financial Officer and Executive Director of the Company, on April 27, 2024. Your Directors would like to place on record their highest gratitude and appreciation for the invaluable contributions made by late Shri Manish Patel to the Company. Further, the Company is in the process of appointing a Chief Financial Officer of the Company.
b) Director:
The following are the Director of the Company.
Mrs. Darshangi Patel
Mr. Suryakant Lohar
Mr. Bhaskar Vishe
With deep regret, we report sad demise of Shri. Manish Patel, the Chief Financial Officer and Executive Director of the Company, on April 27, 2024. Your Directors would like to place on record their highest
gratitude and appreciation for the invaluable contributions made by Shri Manish Patel to the Company. Further, the Company is in the process of appointing an Executive Director of the Company.
c) Appointment/Re-appointment:
Pursuant to the provisions of Section 152 and other applicable provisions if any, of the Companies Act, 2013, Mr. Arunkumar Prajapati (DIN: 08281232), Managing Director of the Company is liable to retire by rotation at the forthcoming Annual General Meeting and he is being eligible offers himself for re-appointment.
d) Changes in Directors and Key Managerial Personnel:
During the year, there were no changes in the Composition of Board Directors due to Appointments and Resignations of Directors and KMP:
However, we report unfortunate demise of Shri. Manish Patel, the Chief Financial Officer and Executive Director of the Company, on April 27, 2024.
e) Declaration by an Independent Director(s) and reappointment, if any:
All Independent Directors have given declarations that they meet the criteria of independence as laid down under Section 149(6) of the Companies Act, 2013 and Regulation 25 of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015.
The Independent Directors have complied with the Code of Conduct for Independent Directors prescribed in Schedule IV of the Companies Act, 2013 and the Code of conduct formulated by the Company as hosted on the Company's Website i.e., www.naturalbiocon.com
10. ANNUAL RETURN:
Pursuant to Sub-section 3(a) of Section 134 and Sub-section (3) of Section 92 of the Companies Act, 2013 read with Rule 12 of Companies (Management and Administration) Rules, 2014, the copy of the draft Annual Return of the Company for the Financial Year ended on 31 March, 2024 in Form MGT-7 is uploaded on website of the Company and can be accessed at www.naturalbiocon.com
11. NUMBER OF MEETINGS OF THE BOARD:
During the year the Board of Directors met four times (05). The details of the board meetings are provided in Corporate Governance Report.
02/05/2023
12. DIRECTORS' RESPONSIBILITY STATEMENT:
To the best of their knowledge and belief and according to the information and explanations obtained by them, your Directors made the following statements in terms of Section 134(3) (c) of the Companies Act, 2013:
a. That in the preparation of the annual financial statements for the year ended March 31, 2024, the applicable accounting standards have been followed along with proper explanation relating to material departures, if any;
b. That such accounting policies have been selected and applied consistently and judgment and estimates have been made that are reasonable and prudent so as to give a true and fair view of the state of affairs of the Company as at March 31, 2024 and of the profit of the Company for the year ended on that date;
c. That proper and sufficient care has been taken for the maintenance of adequate accounting records in accordance with the provisions of the Companies Act, 2013 for safeguarding the assets of the Company and for preventing and detecting fraud and other irregularities;
d. That the annual financial statements have been prepared on a going concern basis.
e. That proper internal financial controls were in place and that the financial controls were adequate and were operating effectively;
f. That system to ensure compliance with the provisions of all applicable laws were in place and were adequate and operating effectively.
13. DETAIL OF FRAUD AS PER AUDITORS REPORT:
There is no fraud in the Company during the Financial Year ended March 31, 2024. This is also being supported by the report of the auditors of the Company as no fraud has been reported in their audit report for the financial year ended March 31, 2024.
14. BOARD'S COMMENT ON THE AUDITORS' REPORT:
There were no qualifications, reservations or adverse remarks made by Auditors in their respective reports. Observation made by the Statutory Auditors in their Report are self-explanatory and therefore, do not call for any further comments under section 134(3)(f) of the Companies Act, 2013.
15. AUDITORS:
A. Statutory Auditors:
In terms of Section 139 of the Companies Act, 2013 ("the Act"), and the Companies (Audit and Auditors) Rules, 2014, made thereunder, the present Statutory Auditors of the Company M/s. Sanket Shah, Chartered Accountants, Ahmedabad (M. No. 150873) were appointed as Statutory Auditors of the Company from Annual General Meeting of year 2021 and that they shall hold the office of the Statutory Auditors of the Company from the conclusion of this meeting until the conclusion of the Annual General Meeting which will be held in the year 2026 on such remuneration as may be fixed by the Board of Directors in consultation with them.
The certificate of eligibility under applicable provisions of the Companies Act, 2013 and corresponding Rules framed thereunder was furnished by them towards appointment of a 5 (Five) years term.
B. Secretarial Audit:
Pursuant to the provisions of Section 204 of the Companies Act, 2013 and The Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014, the Company has appointed PCS Rupali Modi, Practicing Company Secretary, to undertake the Secretarial Audit of the Company. The Secretarial Audit Report is annexed herewith as "Annexure -A".
Reply for qualification Remark in Secretarial Audit Report:
1. Although company has not published/advertised the financial result Financial Year 2023-2024 under review in the newspaper. However, the same was uploaded on the company website as well as BSE Portal and available at public.
2. The Company has again instructed all the Independent Directors and explained them about necessity of submitting declaration as required under Section 149(6) of the Companies Act, 2013. The Company is hopeful to obtain it from Independent Directors in a short period.
3. The Company is in the process of appointing a Chief Financial Officer as prescribed under Section 203 of the Companies Act, 2013.
4. Since the Company is not having any confirmation about the MSME status of the vendor/supplier, the Company has not filed e-form MSME -1 pursuant to Order 2 and 3 dated 22 January, 2019 issued under Section 405 of the Companies Act, 2013.
5. The Company has put a stern effort to obtain death certificate of late Mr. Manish Patel and after the date of Balance Sheet, we could obtain and file with the regulatory body.
6. The company is in the process of complying with the same.
16. TRANSFER TO RESERVES:
Out of the profits available for appropriation, no amount has been transferred to the General Reserve and the balance amount of Rs. 15.27 lacs have been carried forward from profit & loss account to Balance Sheet, during the year under review.
17. DEPOSITS:
The Company has not accepted or renewed any deposits during the year. There are no outstanding and overdue deposits as at March 31, 2024.
18. PARTICULARS OF LOANS, GUARANTEES OR INVESTMENTS UNDER SECTION 186:
The Details of Loans, Guarantees and Investments as covered under the provisions of Section 186 of the Companies Act, 2013 are given in the notes to the Financial Statements. The Company is in compliance with provisions of section 186 of the Companies Act, 2013.
19. PARTICULARS OF CONTRACTS OR ARRANGEMENTS WITH RELATED PARTIES:
The company has not entered into any contracts or arrangements/ transactions with related party during the year under review.
20. SIGNIFICANT AND MATERIAL ORDERS PASSED BY THE REGULATORS OR COURTS:
There are no significant material orders passed by the Regulators /Courts which would impact the going concern status of the Company and its future operations.
21. PROCEEDINGS UNDER INSOLVENCY AND BANKRUPTCY CODE, 2016:
During the year under review, there were no proceedings that were filed by the Company or against the Company, which are pending (except the previous years which was already disclosed) under the Insolvency and Bankruptcy Code, 2016 as amended, before National Company Law Tribunal or other Courts.
22. DETAILS OF DIFFERENCE BETWEEN VALUATION AMOUNT ON ONE TIME SETTLEMENT AND VALUATION WHILE AVAILING LOAN FROM BANKS AND FINANCIAL INSTITUTIONS:
During the year under review, there has been no one time settlement of loans from the Bank or Financial Institutions.
23. BOARD EVALUATION:
Pursuant to the provisions of the Companies Act, 2013 and SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, the Board has carried out an annual performance evaluation of its own performance, the directors individually as well as the evaluation of the working of its Audit, Nomination & Remuneration and Compliance Committees. The manner in which the evaluation has been carried out has been explained in the Corporate Governance Report.
24. CORPORATE SOCIAL RESPONSIBILITY:
In terms of the provisions of Section 135 of the Act and Rule 9 of the Companies (Accounts) Rules, 2014, the Company has not required to formulate and implement any Corporate Social Responsibility Initiatives as the said provisions are not applicable to the Company during the year under review.
25. BUSINESS RISK MANAGEMENT:
The Company has laid down a Risk Management Policy and identified threat of such events which if occurs will adversely affect either / or, value to shareholders, ability of company to achieve objectives, ability to implement business strategies, the manner in which the company operates and reputation as "Risks". Further such Risks are categorized in to Strategic Risks, Operating Risks & Regulatory Risks. A detailed exercise is carried out to identify, evaluate, manage and monitoring all the three types of risks.
26. INTERNAL CONTROL SYSTEMS AND THEIR ADEQUACY:
The Company has an Internal Control System, commensurate with the size, scale and complexity of its operations. During the year under review, the company retained external audit firm to review its existing internal control system with a view of tighten the same and introduce system of self-certification by all the process owners to ensure that internal controls over all the key business processes are operative. The scope and authority of the Internal Audit (IA) function is defined in the Internal Audit Charter.
The Internal Audit Department monitors and evaluates the efficacy and adequacy of internal control system in the Company, its compliance with operating systems, accounting procedures and policies at all locations of the Company and its subsidiaries. Based on the report of internal audit function, process owners undertake corrective action in their respective areas and thereby strengthen the controls. Significant audit observations and corrective actions thereon are presented to the Audit Committee of the Board, basis the Internal Audit Report received.
27. DETAILS IN RESPECT OF ADEQUACY OF INTERNAL FINANCIAL CONTROLS WITH REFERENCE TO THE FINANCIAL STATEMENTS:
The Company has adequate and proper internal financial controls with reference to the Financial Statements during the year under review.
28. VIGIL MECHANISM / WHISTLE BLOWER POLICY:
The Company has a vigil mechanism named Whistle Blower Policy to deal with instances of fraud and mismanagement, if any. The details of the Whistle Blower Policy is explained in the Corporate Governance Report and also posted on the website of the Company.
29. EMPLOYEE RELATIONS:
Employee relations throughout the Company were harmonious. The Board wishes to place on record its sincere appreciation of the devoted efforts of all employees in advancing the Company's vision and strategy to deliver good performance.
30. NOMINATION & REMUNERATION POLICY OF THE COMPANY:
The Board has, on the recommendation of the Nomination & Remuneration Committee framed a policy for selection and appointment of Directors, Senior Management and their remuneration. The Remuneration Policy
is stated in the Corporate Governance Report and is also available on the Company's website at www.naturalbiocon.com.
31. CORPORATE GOVERNANCE REPORT AND MANAGEMENT DISCUSSION & ANALYSIS REPORT:
The Company has been proactive in the following principles and practices of good corporate governance. A report in line with the requirements of Regulation 27(2) of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 the report on Management Discussion and Analysis and the Corporate Governance practices followed by the Company and the Auditors Certificate on Compliance of mandatory requirements are given as an "Annexure B & C" respectively to this report.
Your Company is committed to the tenets of good Corporate Governance and has taken adequate steps to ensure that the requirements of Corporate Governance as laid down in Regulation 27(2) of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 are complied with.
As per 27(2) of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 with the Stock Exchanges, the Corporate Governance Report, Management Discussion and Analysis and the Auditor's Certificate regarding compliance of conditions of Corporate Governance are attached separately and form part of the Annual Report.
32. CONSERVATION OF ENERGY, TECHNOLOGY ABSORPTION AND FOREIGN EXCHANGE EARNINGS AND OUTGO:
During the year conservation of energy, technology absorption and foreign exchange earnings and outgo stipulated under Section 134(3)(m) of the Companies Act, 2013 read with Rule, 8 of the Companies (Accounts) Rules, 2014, is nil.
33. MATERIAL CHANGES AND COMMITMENTS. IF ANY, AFFECTING THE FINANCIAL POSITION OF THE COMPANY WHICH HAVE OCCURRED BETWEEN THE END OF THE FINANCIAL YEAR OF THE COMPANY TO WHICH THE FINANCIAL STATEMENTS RELATE AND THE DATE OF THE REPORT:
There are no material changes and commitments, affecting the financial position of the Company which has occurred between the end of financial year as on 31st March, 2024 and the date of Director's Report except the following:
The company has increased the authorized capital vide it's extra-ordinary general meeting dated May 23, 2024, from the existing Rs.12,00,00,000 (Rupees Twelve Crores Only) divided into 1,20,00,000 (One Crores Twenty Lacs) Equity Shares of Rs.10/- each to Rs. 30,00,00,000 (Rupees Thirty Crores Only) divided into 3,00,00,000 (Three Crores) Equity Shares of Rs.10/- each by addition of Rs. 18,00,00,000 (Rupees Eighteen Crores only) divided into 1,80,00,000 (One Crores Eight Lacs) Equity Shares of Rs. 10/- each.
Further the company has increased it's paid capital has been increased from 11,37,28,000 to 25,78,28,000 at various instances from the end of financial year, and till the date of this report.
34. PARTICULARS OF EMPLOYEES:
The table containing the names and other particulars of employees in accordance with the provisions of Section 197(12) of the Companies Act, 2013, read with Rule 5(1) of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014, is provided as "Annexure- D" to the Board's report.
None of the employees of the Company drew remuneration of Rs.1,02,00,000/- or more per annum and Rs.8,50,000/- or more per month during the year. No employee was in receipt of remuneration during the year or part thereof which, in the aggregate, at a rate which is in excess of the remuneration drawn by the managing director or whole-time director or manager and holds by himself or along with his spouse and dependent children, not less than two percent of the equity shares of the company. Hence, no information is required to be furnished as required under Rule, 5(2) and 5(3) of The Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014.
35. OBLIGATION OF COMPANY UNDER THE SEXUAL HARASSMENT OF WOMEN AT WORKPLACE (PREVENTION. PROHIBITION AND REDRESSAL) ACT, 2013:
The Company has zero tolerance for sexual harassment at workplace and has adopted a policy against sexual harassment in line with the provisions of Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and the rules framed there under.
During the financial year 2023-24, the company has not received any complaints on sexual harassment and hence no complaints remain pending as of March 31, 2024.
36. SECRETARIAL STANDARDS:
The Directors State that applicable Secretarial Standards - 1, 2, 3 and 4 issued by the Institute of Company secretaries of India relating to ‘Meetings of the Board of Directors' and General Meetings' and ‘Report of the Board of Directors' respectively, have been duly followed by the Company.
37. ACKNOWLEDGMENT:
Your Directors acknowledge thanks ton to the various Central and State Government Departments, Organizations and Agencies for the continued help and co-operation extended by them. The Directors also gratefully acknowledge all stakeholders of the Company viz. customers, members, dealers, vendors, banks and other business partners for the excellent support received from them during the year. The Directors place on record their sincere appreciation to all employees of the Company for their unstinted commitment and continued contribution to the Company.
SECRETARIAL AUDIT REPORT FORM MR - 3
FOR THE FINANCIAL YEAR ENDED 31st March, 2024
[Pursuant to section 204(1) of the Companies Act, 2013 and rule No.9 of the Companies (Appointment and Remuneration
Personnel) Rules, 2014]
To,
Natural Biocon (India) Limited (CIN: L24299GJ1992PLC018210)
1007, Sankalp Iconic, Opp. Vikram Nagar Iscon Temple Cross Road,
S. G. Highway, Ahmedabad 380054
We have conducted the Secretarial Audit of the compliance of applicable statutory provisions and the adherence to good corporate practices by Natural Biocon (India) Limited (hereinafter called "the company") for the audit period covering the financial year ended on 31st March, 2024. Secretarial Audit was conducted in a manner that provided me a reasonable basis for evaluating the corporate conducts/statutory compliances and expressing my opinion thereon.
Based on my verification of company's books, papers, minute books, forms and returns filed and other records maintained by the company and also the information provided by the Company, its officers, agents and authorized representatives during the conduct of secretarial audit, We hereby report that in my opinion, the company has, during the audit period covering the financial year ended on 31st March, 2024 complied with the statutory provisions listed hereunder and also that the Company has proper Board-processes and compliance-mechanism in place to the extent, in the manner and subject to the reporting made hereinafter:
1. We have examined the books, papers, minute books, forms and returns filed and other records maintained by the Company, for the financial year ended on 31st March, 2024, according to the provisions of:
(i) The Companies Act, 2013 (the Act) and the rules made there under and the Companies Act, 1956, to the extent it is applicable.
(ii) The Securities Contracts (Regulation) Act, 1956 (‘SCRA') and the rules made there under;
(iii) The Depositories Act, 1996 and the Regulations and Bye-laws framed there under;
(iv) Foreign Exchange Management Act, 1999 and the rules and regulations made there under to the extent of Foreign Direct Investment, Overseas Direct Investment and External Commercial Borrowings;
(v) The following Regulations and Guidelines prescribed under the Securities and Exchange Board of India Act,
1992 (‘SEBI Act'):-
(a) The Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011;
(b) The Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015;
(c) The Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018;
(d) The Securities and Exchange Board of India (Registrars to an Issue and Share Transfer Agents) Regulations,
1993 regarding the Companies Act and dealing with client;
(e) The Securities and Exchange Board of India (Listing Obligations and Disclosure Requirement) Regulations, 2015 (effective from 01st December, 2015)
We have also examined compliance of the following to the extent applicable:
(i). Secretarial Standards with regard to Meeting of Board of Directors (SS-1) and General Meetings (SS- 2) issued by The Institute of Company Secretaries of India (effective from 01st July, 2015); under the provisions of Companies Act, 2013;
We have relied upon the representation made by the Company and its Officers for systems and mechanism formed by the Company for compliances under applicable Acts, Laws and Regulations to the Company, as identified and confirmed by the management of the company. According to Representation letter, acts applicable to the Company are all General Laws such Direct and Indirect Taxation related, Labor Laws and other incidental laws of respective States.
On the basis of our examination and representation made by the Company, we report that during the period under review the Company has generally complied with the provisions of the Act, Rules, Regulations, Guidelines etc. mentioned above and there are no material non-compliances that have come to my knowledge except non-compliance in respect of:
a) The Company has not published notice of meeting of the Board of Directors where financial results shall be discussed and financial results, as required under Regulation 47 of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015.
b) The Independent Directors have not submitted declaration as required under Section 149(6) of the Companies Act, 2013.
c) The Company has not appointed a Chief Financial Officer as prescribed under Section 203 of the Companies Act, 2013.
d) The Company has not filed e-form MSME -1 pursuant to Order 2 and 3 dated 22 January, 2019 issued under Section 405 of the Companies Act, 2013.
e) The Company has not filed death certificate of Mr. Manish Patel who had been appointed as the Chief Financial Officer and Executive Director of the Company, due to his demise, within the statutory time limit.
We Further Report that, there were no actions/ events in pursuance of:
a) The Securities and Exchange Board of India (Issue and Listing of Debt Securities) Regulations, 2008;
b) The Securities and Exchange Board of India (Delisting of Equity Shares) Regulations, 2021;
c) The Securities and Exchange Board of India (Buyback of Securities) Regulations, 2018;
d) The Securities and Exchange Board of India (Employee Stock Option Scheme and Employee Stock Purchase Scheme) Guidelines, 1999 and The Securities and Exchange Board of India (Share Based Employee Benefits) Regulations, 2014 notified on 28 October 2014.
Requiring compliance thereof by the Company during the period under review
We further report that The Board of Directors of the Company is duly constituted with proper balance of Executive Directors, Non-Executive Directors and Independent Directors. The changes in the composition of the Board of Directors that took place during the period under review were carried out in compliance with the provisions of the Act.
Adequate notice is given to all directors to schedule the Board Meetings, agenda and detailed notes on agenda were sent at least seven days in advance, and a system exists for seeking and obtaining further information and clarifications on the agenda items before the meeting and for meaningful participation at the meeting.
Decisions at the meetings of the Board of Directors of the Company were carried through on the basis of majority. There were no dissenting views by any member of the Board of Directors during the period under review.
We further report that there are adequate systems and processes in the company commensurate with the size and operations of the company to monitor and ensure compliance with applicable laws, rules, regulations and guidelines.
We further report that during the audit period there were no specific events / actions having a major bearing on the company's affairs except as mentioned below:
(CIN: U24299GJ1992PLC018210)
1007, Sankalp Iconic, Opp. Vikram Nagar
Iscon Temple Cross Road,
Our report of even date is to be read along with this letter:
1. Maintenance of secretarial record is the responsibility of the management of the Company. Our responsibility is to express an opinion on these secretarial records based on my audit.
2. We have followed the audit practices and processes as were appropriate to obtain reasonable assurance about the correctness of the contents of the secretarial records. The verification was done on test basis to ensure that correct facts are reflected in secretarial records. We believe that the processes and practices, we followed provide a reasonable basis for my opinion.
3. We have not verified the correctness and appropriateness of financial records and Books of Accounts of the Company.
4. Wherever required, we have obtained the Management representation about the compliance of laws, rules and regulations and happening of events etc.
5. The compliance of the provisions of corporate and other applicable laws, rules, regulations, standards is the responsibility of management. Our examination was limited to the verification of procedures on test basis.
6. The secretarial audit report is neither an assurance as to the future viability of the Company nor of the efficacy or effectiveness with which the management has conducted the affairs of the Company.