Report on the Audit of the Standalone Financial Statements Opinion
We have audited the accompanying Standalone Financial Statements of NHPC Limited ("the Company"), which comprise the Balance Sheet as at March 31, 2023, the Statement of Profit and Loss (including Other Comprehensive Income), the Statement of Changes in Equity and the Statement of Cash Flows for the year then ended, and Notes to the Standalone Financial Statements, including a summary of significant accounting policies and Other Explanatory Notes for the year ended on that date (hereinafter referred to as "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 Indian Accounting Standards prescribed under section 133 of the Act read with the Companies (Indian Accounting Standards) Rules, 2015, as amended, ("Ind AS") and the accounting principles generally accepted in India, of the state of affairs of the Company as at March 31,2023, and total comprehensive income (comprising of profit and other comprehensive income), changes in equity and its cash flows for the year ended on that date.
Basis for Opinion
We conducted our audit in accordance with the Standards on Auditing (SAs) specified under section 143(10) of the Act. Our responsibilities under those Standards are further described in the "Auditors' 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 Standalone Financial Statements under the provisions of the Act and the Rules thereunder, and we have fulfilled our other ethical responsibilities in accordance with these requirements and the Code of Ethics. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our 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 standalone fi nancial statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters. We have considered the matters described below to be the Key Audit Matters for incorporation in our Report.
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1.
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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 31,2023, the Company has recognized Regulatory Deferral Account Debit balances of ' 6420.12 Crores (' 6948.11 Crores up to March 31, 2022) as given in Note 14.1 of the Standalone Financial Statements.
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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.
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This include accruals aggregating to ' 3470.59 Crores on account of interest cost and other attributable expenses pertaining to Subansiri Lower HE Project for the period from the date of interruption of work i.e. 16.12.2011 till 30.09.2019 as indicated in Note 34(22A) of Standalone Financial Statements.
Regulatory Deferral Accounts Debit Balances are determined based on tariff regulations and past tariff orders and are subject to verifi cation 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 beneft will flow to the entity as a 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 notifcations.
The accruals made as above are vital and proprietary to the business in which the Company is operating. In absence of specif c notif cation and rate f xation, these are based on the management's assumptions and estimates which are subject to f nalization of tariff by CERC and commencement of operations of the Projects.
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• Evaluating the various assumptions considered by the management for arriving at the value of Cash Generating Unit, Note 34(18) of Standalone Financial Statements in case of Subansiri Lower HE Project and adequacy thereof with respect to the carrying value of the Project in Progress and balances pertaining to the said project under Regulatory Deferral Accounts.
• 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.
• Reviewing the adequacy and reasonableness of amounts recognised 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.
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2.
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Impairment Assessment of carrying amount of: A. Property, Plant and Equipment (PPE) and Capital Work in Progress (CWIP)
Each of the Power Station/ Project has been considered as Cash Generating Units (CGU) of the Company and impairment indicators and requirements thereof have been assessed with respect to the Property, Plant and Equipment (PPE) and Capital Work in Progress (CWIP) as given in Note 34(18) of the Standalone Financial Statements. This has been assessed that no signif cant change with an adverse effect on the Company has taken place during the year or is expected to take place in the near future, in the technological, economic or legal environment in which the Company operates. Based on the assessment, the Company has concluded that there exists no signifcant impairment indicator or any impairment in respect of the CGUs of the Company tested for impairment during the year 2022-23. Based on the above assessment, no provision for impairment against PPE or CWIP has been considered necessary by the Company.
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Our audit procedures based on which we arrived at the conclusion regarding reasonableness of the impairment assessment of carrying amount of PPE, CWIP & Investments in/ Loans to Subsidiaries/ Joint Ventures include the following:
• Critical evaluation of internal and external factors impacting the entity and indicators of impairment (or reversal thereof) in line with Ind AS 36.
• Review of impairment valuation models used in relation to CGU to determine the recoverable amount by analysing the key assumptions used by management in this respect including:
- Consistency with respect to forecast for arriving at the valuation and assessing the potential impact of any variances;
- Price assumptions used in the models;
- Factoring of risk inherent to the CGUs in the Cash Flow projections or the discount rate.
- The assumption/estimation for the weighted average cost of capital and rate of discount for arriving at the value in use.
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Impairment exercise undertaken which justifies the carrying amount of certain assets as above include the regulatory deferral account balances pertaining to Subansiri Lower HE Project as dealt with under para 1 above, is significant and vital to the Company's operations.
Evaluation of the impairment involves assessment of value in use of the Cash Generating Units (CGUs) and requires signifi cant judgements and assumptions about the future cash flow forecasts, forecast production, forecast volumes, prices and discount rate.
B. Company's investments in and loans to Subsidiaries and Joint Ventures
The Company has investments in a subsidiary (Loktak Downstream Hydroelectric Corporation Limited) and a joint venture (National High Power Test Laboratory Private Limited) with a carrying value of ' 135.96 Crores. Further, the Company has also provided loan to the joint venture amounting to ' 18.40 Crore.
The Company accounts for its investments in subsidiaries and joint ventures at cost (subject to impairment assessment). Management regularly reviews whether there are any indicators of impairment of investments with reference to Ind AS 36 'Impairment of Assets'. If such indicators exist, impairment loss is determined and recognised in accordance with the accounting Policy of the Company.
In case of the subsidiary, due to the delay in investment sanction (PIB & CCEA) and high projected tariffs, the Company has recognised impairment allowance of ' 105.56 Crores during the year ended March 31, 2023, in respect of the investment made in the subsidiary.
The joint venture, on the other hand, has been incurring continuous losses, and accordingly, during the year ended March 31, 2023, the Company has recognised impairment allowance of ' 16.33 Crores, in respect of the investment made in the joint venture and ' 18.40 Crores in respect of loan provided to the joint venture. Refer Note 34(18) of Standalone Financial Statements.
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• Reviewed the Government Policy and approval for setting up the Projects, decision of the Board of Directors and the efforts and steps being undertaken in this respect.
• Reliance has been placed on management projections for completion timeline, volume of generation and resultant revenue based on expected tariff there against.
• Obtained and read the fi nancial statements of the Subsidiaries and joint ventures to identify any disclosure for impairment of assets in their standalone financial statements.
• Evaluation of adequacy and appropriateness of disclosures made in the Standalone Financial Statements.
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Further, the Company has not recognised interest income of ' 2.10 Crores during the current fi nancial year (' 1.67 Crores during the year ended March 31, 2022) from its joint venture due to signifcant uncertainty in realization.
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3.
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Contingent Liabilities - against claim from Contractors (Note 34(1)(a)(i) of Standalone Financial Statements)
Various claims lodged by the Contractors against Capital Works amount to ' 9971.13 Crores of which ' 1116.93 Crores have been provided for, ' 8556.95 Crores have been disclosed under Contingent Liabilities and in respect of the rest of the claims, possibility of any outflow in settlement is considered as remote. This includes matters under arbitration and/ or before the Court which have been decided against the Company. Further, amounts have been paid/deposited pursuant to the NITI Aayog directions or Court order in some cases as referred in Note 34 (1) (e) (i) & (ii) of the Standalone Financial Statements.
Claims made against the Company are signifcant. These are pending for decision before arbitration or other judicial forums and consequential and possible impact thereof. Provisions/disclosure required have been based on the management's assessment of the probability of the occurrence of the liability.
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Our audit procedures based on which we arrived
at the conclusion regarding reasonableness of the
Contingent Liabilities include the following:
• Obtained the status of the cases from the legal department and their view on the matter;
• Evaluated the contractual terms and conditions and management's rationale for the adequacy of the provision so far made and the amount remaining unprovided against the demands made against the Company;
• Discussion with management and perusing/ reviewing the correspondences, Memos and Notes on related matters.
• Reliance has been placed on the legal views and decisions on similar matters and probability of the liability arising therefrom and provision made by the Management pending f nal judgement/ decisions;
• Reviewed the appropriateness and adequacy of the disclosure and provision by the management as required in terms of the requirement of Ind AS 37 "Provisions, Contingent Liabilities and Contingent Assets".
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4.
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Expenditure incurred on Survey and Investigation Projects and those under preconstruction stage upto 31.03.2023
Expenditure of ' 1293.90 Crores as given in Note 2.2.3 of the Standalone Financial Statements has been incurred for conducting survey and investigation on projects. This includes Interest, administrative and other costs attributable to these projects. Out of this ' 964.21 Crores (including ' 2.19 Crores during the year) have been provided for, keeping in view uncertainty with respect to clearances, approvals for implementing the Projects, leaving ' 329.69 Crores which has been carried forward as Capital Work in Progress. Further, Capital Work in Progress also includes Projects where active construction activities are yet to be undertaken.
Interest, Administrative and other Costs are capitalized till the projects are abandoned, however, provisions are made as given herein above in cases where in view of the management there are uncertainties in implementing the projects undertaken.
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Our audit procedures based on which we arrived at the conclusion regarding the carrying amount of expenditure incurred on survey and Investigation Projects include the following:
• Obtained the status of the Projects under Survey and Investigation stage as provided by the management and the reason thereof of keeping them in abeyance.
• Understanding and testing the design and operating effectiveness of controls as established by the management for accounting the expenses incurred (a) for survey and investigation projects and the Policy followed for making provisions/ write off for such expenses given the nature of business of the Company, (b) for project under pre-construction stage and allocation of Borrowing and other cost incurred and allocated there against.
• Evaluating the management's rationale with respect to continuing such projects under Capital Work in Progress in spite of there being uncertainties and delay in implementing the same and expected economic use of the same in future.
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In the event of related Projects not being undertaken, amounts spent on survey and investigation and those incurred/ allocated prior to construction thereof will no longer be eligible to be carried forward as Capital Work in Progress.
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• Evaluating the tenure of pre and under construction stage of project and management contention of normal period required for the same given the location, size and nature in each case of the respective project.
• The matter being technical and proprietary to the nature of business in which the Company is operating, reliance has been placed on the management's contention and representation on the matter.
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5.
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Recognition of MAT Credit and Regulatory Deferral (Credit) balances
During the current Financial Year, the Company has assessed the recoverability of unrecognised MAT Credit of ' 945.96 Crores available to it. Based on such assessment, the Company has recognized deferred tax asset relating to MAT credit entitlement of ' 417.31 Crores (' 1478.62 Crores upto March 31,2022) as the amount of MAT Credit which shall be available for utilization by the Company in future years by way of lower outflow of Income Tax in future years. Out of the MAT Credit recognised, ' 328.94 Crores has been utilized during the current Financial Year.
Correspondingly, in respect of ibid deferred tax asset relating to MAT credit entitlement, Regulatory Deferral (Credit) Balance of ' 923.20 Crores (' 1313.27 Crores upto March 31, 2022) has been recognized, being the amount, which shall be passed on to the beneficiaries in future as per CERC Tariff Regulations.
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.
The recognition of MAT Credit and Regulatory Deferral (Credit) balance there against is important to the intended users of the Standalone Financial Statements in view of its materiality and requirement of judgement 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.
Relevant disclosures in this regard have been provided at Notes 14.2, 18, 30.1, 31,34(22)(E) read with Signifi cant Accounting Policy No. 20.0(b) of the Standalone Financial Statements.
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Our audit procedures based on which we arrived at the conclusion regarding appropriateness of MAT Credit recognized and Regulatory Deferral (Credit) balances created there against include the following:
• Understanding and testing the operating effectiveness of the Company's control relating to taxation and assessment of carrying amount of deferred tax assets/ liabilities.
• Review of the Company's accounting Policy in respect of deferred tax assets on unutilized MAT credit and current year developments, if any, requiring change in such Policy and management contention on the same.
• Evaluation of tax credit entitlement as legally available to the Company based on internal forecasts prepared by the Company and probability of future taxable income.
• Review of underlying assumptions for consistency and uncertainty involved and principle of prudence for arriving at a reasonable degree of probability of utilisation of MAT Credit recognized.
• Review of implication pertaining to regulatory regime under which the Company operates and estimations prepared by the Company regarding MAT Credit arising out of generation activity to be passed on to beneficiaries and impact thereof on the Standalone Financial Statements under the given current Regulatory provisions and period of applicability thereof.
• Evaluation of adequacy and appropriateness of disclosures made in the Standalone Financial Statements.
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Information other than the Financial Statements and Auditors' Report thereon
The Company's Board of Directors is responsible for the other information. The other information comprises the information included in the Annual Report, but does not include the Standalone Financial Statements and our auditors' report thereon. The other information as stated above 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, 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 as stated above and if we conclude that there is a material misstatement therein, we are required to communicate the matter to those charged with governance and describe necessary actions required as per applicable laws and regulations.
Responsibilities 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 state of affairs (financial position), Profit or Loss (financial performance including other comprehensive income), changes in equity and cash flows of the Company in accordance with the accounting principles generally accepted in India, including the Indian Accounting Standards specified 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 of 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.
Those Board of Directors are also responsible for overseeing the Company's financial reporting process.
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 auditors' 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 Standard on Auditing (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 scepticism 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 control 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 with reference to Standalone Financial Statements 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 auditors' 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 auditors' report. However, future events or conditions may cause the Company to cease to continue as a going concern; and
• 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 Standalone 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 Standalone 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 auditors' 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
i. 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 Act, we give in the "Annexure A" a statement on the matters specified in paragraphs 3 and 4 of the Order, to the extent applicable.
ii. Based on the verification of books of account of the Company and according to information and explanations given to us, we give below a report on the Directions issued by the Comptroller and Auditor General of India in terms of Section 143 (5) of the Act:
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Directions
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Reply
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1
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Whether the Company has system in place to process all the accounting transactions through IT system? If yes, the implications of processing of accounting transactions outside IT system on the integrity of the accounts along with the financial implications, if any, may be stated.
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According to the information and explanations given to us and based on our audit, all accounting transactions are routed through ERP system implemented by the Company. Period end Standalone Financial Statements are compiled offline based on balances and transactions generated from ERP system.
We have neither been informed nor have we come across during the course of our audit any accounting transactions having impact on the integrity of the accounts along with the financial implications which have been processed outside the IT system.
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Directions
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2
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Whether there is any restructuring of an existing loan or cases of waiver/write off of debts/loans/ interest etc. made by a lender to the Company due to the Company's inability to repay the loan? If yes, the financial impact may be stated. Whether such cases are properly accounted for? (In case, lender is a government company, then this direction is also applicable for statutory auditor of lender company)
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According to information and explanations given to us and based on our audit, there is no case of restructuring of an existing loan or cases of waiver/write off of debts / loans / interest etc. made by lender to the Company. Further, in respect of loan given by the Company to National High Power Test Laboratory Private Limited (Joint Venture) where interest was receivable in half yearly instalments starting from 30.04.2021 and principal was repayable in 20 equal half yearly instalments starting from 31.10.2022, interest accrued for the FY 2021-22 amounting to ' 1.67 Crore and for the FY 2022-23 amounting to ' 2.10 Crores respectively have not been accounted for in view of signifi cant uncertainty of realization due to cash losses incurred by the Joint Venture.
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3
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Whether funds (grants/ subsidy etc.) received/ receivable for specific schemes from Central/ State Government or its agencies were properly accounted for/utilized as per its terms and conditions? List the cases of deviation.
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According to information and explanations given to us and based on our audit, the Company has accounted for and utilized the funds received for specific schemes from Central/State agencies as per the terms and conditions of the schemes.
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iii. Further to our comments in the annexure referred to in the paragraph above, as required by Section 143(3) of the Act, 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 purposes 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 Changes in Equity and the Statement of Cash Flows dealt with by this Report are in agreement with the books of account.
d) in our opinion, the aforesaid Standalone Financial Statements comply with the Indian Accounting Standards specified under Section 133 of the Act.
e) in terms of Notification no. G.S.R. 463 (E) dated 05th June 2015 issued by the Ministry of Corporate Affairs, provisions of Section 164(2) of the Act regarding disqualifications of the Directors, are not applicable as it is a Government Company.
f) With respect to the adequacy of the internal fi nancial controls with reference to Standalone Financial Statements of the Company and the operating effectiveness of such controls, refer to our separate Report in "Annexure B". Our report expresses an unmodified opinion on the adequacy and operating effectiveness of the Company's internal control; and
g) With respect to the other matters to be included in the Auditors' Report in accordance with Rule 11 of the Companies (Audit and Auditors) Rules, 2014 and Companies (Audit and Auditors) Amendment Rules, 2021 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 34(1) to the Standalone Financial Statements.
ii. The Company did not have any material foreseeable losses against long-term contracts including derivative contracts and thereby requirement for making provision in this respect is not applicable to the Company.
iii. There has been no delay in transferring amounts which were required to be transferred to the Investor Education and Protection Fund by the Company.
iv. As per notification number G.S.R. 463 (E) dated 5th June, 2015 issued by Ministry of Corporate Affairs, section 197 of the Act as regards the managerial remuneration is not applicable to the Company, since it is a Government Company.
v. a. The management has represented that, to the best of its knowledge and belief, no funds 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 persons or entities, including foreign entities ("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 to or on behalf of the 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 persons or entities, including foreign entities ("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 from or on behalf of the Ultimate Beneficiaries; and
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 representations under sub clause (v) (a) and (v) (b) contain any material mis-statement.
vi. The dividend declared or paid during the year by the Company is in compliance with Section 123 of the Act.
vii. The Proviso to Rule 3(1) of the Companies (Accounts) Rules, 2014 for maintaining books of account using accounting software which has a feature of recording audit trail (edit log) facility is applicable to the Company with effect from April 1,2023, and accordingly, reporting under Rule 11(g) of Companies (Audit and Auditors) Rules, 2014 is not applicable for the financial year ended March 31,2023.
For K G Somani & Co LLP For Chaturvedi & Co. For P C Bindal and Co.
Chartered Accountants Chartered Accountants Chartered Accountants
FRN:006591N/N500377 FRN:302137E FRN: 003824N
(Bhuvnesh Maheshwari) (S C Chaturvedi ) (Manushree Bindal)
Partner Partner Partner
M. No.088155 M. No. 012705 M. No. 517316
UDIN: 23088155BGYWED5558 UDIN: 23012705BGWLYC7299 UDIN: 23517316BGYPFX8650
Place: New Delhi Date: May 29, 2023
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