Your Directors are pleased to present the 29^th Annual Report on the business and operation of the Company together with Audited Statement of Accounts for the financial year ended March 31, 2023.

FINANCIAL RESULTS

The Company's financial performance for the year ended March, 2023 is summarized below:

FINANCIAL PERFORMANCE OVERVIEW (STANDALONE BASIS)/ STATE OF COMPANY'S AFFAIRS

The brief highlights of the Company's performance (standalone) during the financial year 2022-23:

• Total revenue from operations increased to '2157.99 crores as against '1630.34 crores in the previous year - an increase of 32.36%.

• Earnings before Interest, Depreciation, Amortization, Exceptional Items & Tax for the current year is '247.06 crores against '163.11 crores in the previous year - an increase of 51.47%.

• Profit before Tax (PBT) and Profit after Tax (PAT) for the current year are '219.16 crores and '161.20 crores respectively against '138.34 crores and ' 105.91 crores in the previous year - an increase of 58.42% and 52.20% respectively.

• Earnings per share is '13.54 for the year under review. CHANGE IN THE NATURE OF BUSINESS

There was no change in the nature of the business of the Company during the financial year ended March 31, 2023.

AMOUNTS Transferred TO Reserves

During the year under review, no amount was transferred to any of the reserves by the Company.

DIVIDEND

The Board of Directors at their meeting held on May 30, 2023, has recommended payment of '1.00 i.e. (50%) per equity share of the face value of '2 (Rupee Two Only) each as final dividend for the financial year ended March 31, 2023. The payment of final dividend is subject to the approval of the shareholders at the

ensuing Annual General Meeting (AGM) of the Company.

The dividend distribution policy is available on our website at: https://www.ace-cranes.com/home/investor-policies-and-programme-codes.

SHARE CApITAL

During the FY 2022-23, there is no change in the share capital of the Company and the Company has not issued any:

(a) Shares with differential rights;

(b) Sweat equity shares;

(c) Bonus shares;

(d) Debenture, bond and any other securities. employee stock option SCHEME (ESOS)

The 'Action Construction Equipment Limited Employee Stock Option Scheme 2021 ("Scheme") is in line with the SEBI (Share Based Employee Benefits and Sweat Equity) Regulations, 2021 ("SBEB Regulations") and there were no material changes to the scheme during the financial year 2022-23.

The Scheme is being implemented in accordance with the SBEB Regulations and the resolution(s) passed by the members. The Secretarial Auditors Certificate would be available during the Annual General Meeting for inspection by the members. The details as required to be disclosed under the Act and/ or SBEB Regulations would be available on the Company's website at www.ace-cranes.com.

UTILIZATION OF FUNDS RAISED THROUGH Qip

The reporting of the utilisation of funds, as on March 31, 2023, raised through the Qualified Institutional Placements (QIP) are as follows:

LISTING OF SHARES

The equity shares of the Company are listed on the National Stock Exchange of India Limited (NSE) and BSE Limited (BSE). The listing fee for the year 2023-24 has already been paid to both the Stock Exchanges.

CREDIT RATING

ICRA Limited on April 25, 2023 has re-affirmed the ratings of the Company as per below given details and outlook on the longterm Rating is Stable.

MATERIAL CHANGES AND COMMITMENTS, IF ANY

No material changes and commitments affecting the financial position of the Company occurred between the end of the financial year to which this financial statement relate and the date of this report.

DISCLOSURES RELATING TO SUBSIDIARY COMPANY AND CONSOLIDATED FINANCIAL STATEMENTS

As on March 31, 2023, the Company has following subsidiaries Companies/Firms.

Note : SC Forms SA, Romania, a subsidiary of the Company is under voluntary dissolution and liquidation process as per applicable laws in Romania.

In accordance with Section 129(3) of the Companies Act, 2013, Regulations 33 of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 and applicable Accounting Standards, the Company has prepared consolidated financial statements of the Company and its subsidiaries, which form part of the Annual Report. For details please refer the Consolidated Financial Statements.

A statement containing the salient features of the financial statement/highlights of performance of our subsidiaries in the prescribed Form AOC-1 is attached as Annexure-I to this Report.

There are no associates and Joint Ventures Companies within the meaning of Section 2(6) of the Companies Act, 2013 (Act) and there has been no material change in the nature of the business of the subsidiaries except SC Forma SA which is under voluntary dissolution and liquidation process.

In accordance with Section 136 of the Companies Act, 2013, the audited financial statements, including the consolidated financial statements and related information of the Company and accounts of its subsidiaries, are available on our website at www.ace-cranes.com. These documents will also be available for inspection during business hours at our registered office.

In terms of the Company's Policy on determining "material subsidiary", during the financial year ended March 31, 2023, there is no material subsidiary of the Company whose income exceeds 10% of the consolidated income of the Company in the immediately preceding financial year.

The Policy for determining material subsidiaries may be accessed on the Company's website at https://www.ace-cranes.com/ home/investor-policies-and-programme-codes.

BOARD OF DIRECTORS

In accordance with the provisions of Companies Act, 2013 (hereinafter referred as "the Act") and Articles of Association of the Company, Mr. Sorab Agarwal (DIN: 00057666), Whole-Time

Director of the Company will retire by rotation at the ensuing AGM and being eligible, offers himself for re-appointment. Details related to his re-appointment as required to be disclosed under Companies Act/listing Regulations is given as Annexure-I, to the notice of 29^th AGM.

The Board of Directors, in their meeting held on May 30, 2023, had recommended the re-appointment and remuneration of Mr. Vijay Agarwal (DIN:00057634), as Chairman & Managing Director, Mrs. Mona Agarwal (DIN:00057653), as Executive Director and Mr. Sorab Agarwal (DIN:00057666) as Executive Director for a further period of 5 years w.e.f. October 1, 2023, subject to the approval of the shareholders in the ensuing Annual General Meeting. Their appointment is appropriate and in the best interest of the Company. Details related to their reappointment as required to be disclosed under Companies Act/ listing Regulations is given as Annexure-I, to the notice of 29^th AGM.

The Company has received declarations from all the Independent Directors of the Company confirming that they meet with criteria of independence as prescribed under sub-section (6) of Section 149 of the Act and under Regulation 16(1)(b) of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (hereinafter referred as "the Listing Regulations").

In the opinion of Board of Directors of the Company, Independent Directors on the Board of Company hold highest standards of integrity and are highly qualified, recognized and respected individuals in their respective fields. It's an optimum mix of expertise (including financial expertise), leadership and professionalism.

KEY MANAGERIAL PERSONNELS (KMP)

Pursuant to the provisions of Section 203 of the Companies Act, 2013 read with Rules made thereunder following are designated as Key Managerial Personnel (KMP) of the Company:

• Mr. Vijay Agarwal, Chairman & Managing Director;

• Mrs. Mona Agarwal, Whole-Time Director;

• Mr. Sorab Agarwal, Whole-Time Director;

• Mrs. Surbhi Garg, Whole-Time Director;

• Mr. Rajan Luthra, Chief Financial Officer (CFO); and

• Mr. Anil Kumar, Company Secretary & Compliance Officer.

number of board meetings

During the financial year 2022-23, four (4) Board Meetings were held. For details thereof kindly refer to the Corporate Governance Report forming part of this Annual Report.

Pursuant to the requirements of Schedule IV to the Companies Act, 2013 and the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, separate Meeting of the Independent Directors of the Company was also held on February 06, 2023, without the presence of Non-Independent Directors and members of the management, to review the performance of Non-Independent Directors and the Board as a whole, the performance of the Chairperson of the Company, taking into account the views of Executive Directors, Non-Executive NonIndependent Directors and also to assess the quality, quantity and timeliness of flow of information between the Company management and the Board.

ANNUAL GENERAL MEETING (AGM)

During the financial year 2022-23, 28^th Annual General Meeting of the Company was held on September 20, 2022 at 12:00 noon through Video Conferencing ("VC")/Other Audio Visual Means ("OAVM").

COMMITTEES OF THE BOARD

The Board has 5 (Five) mandatory level committees: Audit Committee, Nomination and Remuneration Committee, Stakeholders Relationship Committee, Corporate Social Responsibility Committee and Risk Management Committee. During the year, all recommendations made by the committees were approved by the Board. A detailed note on the composition of the Board and its committees, including its terms of reference is provided in the Corporate Governance Report forming part of this Annual Report.

NOMINATION AND REMUNERATION pOLICY

The Board of Directors has framed a policy which lays down a framework in relation to remuneration and appointment of Directors, Key Managerial Personnel and Senior Management of the Company. The Policy broadly lays down the guiding principles, philosophy and the basis for payment of remuneration to Executive and Non-Executive Directors (by way of sitting fees), Key Managerial Personnel, Senior Management and other employees. The policy also provides the criteria for determining qualifications, positive attributes and Independence of Director and criteria for appointment of Key Managerial Personnel / Senior Management and performance evaluation. The above

policy has been posted on the website of the Company at https://www.ace-cranes.com/home/investor-policies-and-programme-codes.

DIRECTORS' RESPONSIBILITY STATEMENT

Pursuant to the provisions of clause (c) of Sub-section (3) of Section 134 of the Companies Act, 2013, your Directors hereby confirm that they:

(i) Have followed in the preparation of Annual Accounts for the financial year 2022-23, the applicable Accounting Standards and no material departures have been made for the same;

(ii) Had selected such accounting policies and applied them consistently and made judgments and estimates 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, 2023 and of the profit of the Company for the year ended on that date;

(iii) Had taken proper and sufficient care 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;

(iv) Had prepared the annual accounts on a going concern basis;

(v) Have laid down internal financial controls to be followed by the Company and that such internal financial controls are adequate and are operating effectively; and

(vi) Have devised proper systems to ensure compliance with the provisions of all applicable laws and that such system are adequate and operating effectively.

ANNUAL PERFORMANCE EVALUATION OF THE BOARD, ITS COMMITTEES AND INDIVIDUAL DIRECTORS

Pursuant to the provisions of Companies Act, 2013 and Regulation 25 (3) of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, as amended, Independent Directors at their separate meeting, without participation of the Non-Independent Directors and Management have considered and evaluated the Board's performance and performance of the Chairman and Non- Independent Directors. The Independent Directors in the said meeting have also assessed the quality, quantity and timeliness of flow of information between the Company Management and the Board.

The Board of Directors has evaluated the performance of each of the Independent Directors (without participation of the relevant Director). The Board has carried out the annual evaluation of its own performance and that of its Directors individually. The evaluation criteria as approved by the Nomination and Remuneration Committee included various aspects of the functioning of Board such as composition, process and procedures

including adequate and timely information, attendance, decision making, roles and responsibilities etc.

The performance of individual directors including the Chairman was evaluated on various parameters such as industry knowledge & experience, vision, commitment, time devoted etc. The evaluation of Independent Directors was based on aspects like participation & contribution to the Board decisions, knowledge, experience and integrity etc.

STATUTORY AUDITORS

As per provisions of Section 139(1) of the Act, the Company has appointed M/s B S R & Co. LLP, Chartered Accountants (Firm Regn. No. 101248W/W-100022) as Statutory Auditors of the Company for a period of 5 (Five) years (April 01, 2022 to March 31, 2027) i.e. till the conclusion of the 33^rd AGM to be held in the calendar year 2027, in the AGM of the Company held on September 20, 2022.

Statutory Auditors' Report

The observations of Statutory Auditors in its reports on standalone and consolidated financials are self-explanatory and therefore, do not call for any further comments. There are no qualifications, reservations or adverse remarks made by Statutory Auditors in their reports.

SECRETARIAL AUDITORS

Pursuant to the provisions of Section 204 of the Companies Act, 2013 read with corresponding Rules framed thereunder, M/s Vasisht & Associates, Company Secretaries, were appointed as the Secretarial Auditors of the Company to carry out the secretarial audit for the year ending March 31, 2023.

Secretarial Audit Report

A Secretarial Audit Report given by the Secretarial Auditors in Form No. MR-3 is annexed with this Report as Annexure-II. There are no qualifications, reservations or adverse remarks made by Secretarial Auditors in their Report.

Secretarial Compliance Report

Pursuant to SEBI circular no CIR/CFD/CMD1/27/2019 dated February 08, 2019, in addition to secretarial audit, Annual Secretarial Compliance Report given by M/s Vasisht & Associates, Company Secretaries on compliance of all applicable SEBI Regulations and circulars/guidelines issued there under is annexed as Annexure-Ni.

COST AUDITORS

As per Section 148 of the Companies Act, 2013, the Company is required to have the audit of its cost records conducted by a Cost Accountant in practice.

Pursuant to the provisions of Section 141 read with Section 148 of the Companies Act, 2013 and Rules made thereunder, M/s Vandana Bansal & Associates, Cost Accountants (Firm Registration No. 100203) had been appointed as the Cost Auditor of the Company for the year ending March 31, 2023.

Cost audit report for financial year 2022-23 will be filed with the Ministry of Corporate Affairs within stipulated time period.

INTERNAL AUDIT

The Board of Directors of the Company has appointed Internal Auditor of the Company, to audit the function and activities of the Company and to review various operations of the Company; the Company continued to implement their suggestions and recommendations to improve the control environment.

DETAILS IN RESpECT OF Frauds REpORTED BY Auditors

other than those which are reportable to the central

GOVERNMENT

The Statutory Auditors, Secretarial Auditors and Cost Auditors of the Company have not reported any frauds to the Audit Committee or to the Board of Directors under Section 143 (12) of the Companies Act, 2013, including rules made there under.

corporate social responsibility (CSR)

The Company's CSR activities are primarily done through its trust namely ACE Emergency Response Service. The CSR Committee of the Board of Directors has been formed comprising of three directors with Chairman being Independent Director. CSR Committee has framed and formulated a CSR Policy indicating the activities to be undertaken by the Company, in accordance with schedule VII of the Act and the Companies (Corporate Social Responsibility Policy) Rules, 2014 issued under the Act. The same has also been approved and reviewed from time to time by the Board. The updated CSR policy is available at the website of the Company at https://www.ace-cranes.com/home/investor-policies-and-programme-codes.

The Annual Report FY 2022-23 on CSR Activities, as stipulated under the Act forms an Integral part of this Report and is appended as Annexure-IV.

corporate GOVERNANCE

Your Company reaffirms its commitment to the good corporate

governance practices and has adopted the Code of Conduct which has set out the systems, processes and policy conforming to international standards.

In compliance with Regulation 34 of the Listing Regulations a separate report on corporate governance along with a certificate from Practicing Company Secretary regarding compliance of the conditions of Corporate Governance as stipulated under Schedule V of the Listing Regulations forms part of this Annual Report.

MANAGEMENT DISCUSSION AND ANALYSIS

Management Discussion and Analysis for the year as stipulated under Schedule V of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 as amended is separately given and forms part of this Annual Report and provides a more detailed analysis on the performance of individual businesses and their outlook.

CONTRACTS OR ARRANGEMENTS WITH RELATED pARTIES

All contracts or arrangements or transactions that were entered into by the Company during the financial year with related parties were on an arm's length basis and in the ordinary course of business. During the year, the Company had not entered into any contracts or arrangements or transactions with related parties which could be considered material in accordance with Companies Act and SEBI Regulations and the policy of the Company on materiality of related party transaction. All related party transactions have been approved by the Audit Committee and the Board.

Further, the prescribed details of related party transactions of the Company in Form No. AOC-2, in terms of section 134 of the Act read with Rule 8 of the Company (Accounts) Rules, 2014 is given as Annexure-V to this report.

The Policy on materiality of related party transactions and dealing with related party transactions may be accessed on the Company's website at https://www.ace-cranes.com/home/ investor-policies-and-programme-codes.

Your Directors draw attention of the members to note no. 33 in the notes to accounts in the Standalone Financial Statements which sets out related party disclosures.

DISCLOSURE ON AUDIT COMMITTEE

The Audit Committee as on March 31, 2023 comprises of the following Directors: Mr. Avinash Parkash Gandhi (Chairman), Mr. Vijay Agarwal, Mr. Shriniwas Vashisht, and Dr. Jagan Nath Chamber as Members. For more details kindly refer to the section 'Committees of the Board-Audit Committee', in the Corporate Governance Report, which forms part of this Annual Report. All recommendations of Audit Committee were accepted by the Board of Directors.

RISK MANAGEMENT

The Company has constituted a Risk Management Committee in Compliance with the requirements of Regulation 21 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. The details of this Committee and its terms of reference are set out in the Corporate Governance Report, which forms part of this Annual Report.

The Company has also formulated the Risk Management Policy, to identify risks and minimize their adverse impact on business and strives to create transparency which in turn enhances the Company's competitive advantage.

According to the aforesaid business risk policy, the Company has identified the business risks associated with its operations and an action plan for its mitigation of the same is put in place. The business risks and its mitigation have been dealt with in the Management Discussion and Analysis Section of this Annual Report.

INTERNAL FINANCIAL CONTROLS

The Company has in place adequate internal financial controls with reference to financial statements. Such controls were tested during the financial year and no material weaknesses in the design or operation were observed. Review of the financial controls is done on an ongoing basis.

INTERNAL CONTROL SYSTEMS AND THEIR ADEQUACY

Your Company maintains adequate internal control system and procedures commensurate with its size and nature of operations. The internal control systems are designed to provide a reasonable assurance over reliability in financial reporting, ensure appropriate authorization of transactions, safeguarding the assets of the Company and prevent misuse/ losses and legal compliances.

The internal control system includes a well-defined delegation of authority and a comprehensive Management Information System coupled with quarterly reviews of operational and financial performance, a well-structured budgeting process with regular monitoring of expenses and Internal audit. The Internal Audit reports are periodically reviewed by the management and the Audit Committee and necessary improvements are undertaken, if required.

During the year, such controls were tested and no reportable material weakness in the design or operation was observed.

WHISTLE BLOWER POLICY/ VIGIL MECHANISM

The Company has a vigil mechanism for Directors and Employees to report their concerns about unethical behavior, actual or suspected fraud or violation of the Company's Code of Conduct. The mechanism provides for adequate safeguards against victimization of effected Director(s) and Employee(s). Directors and Employees have direct access to the Chairman of the Audit Committee. It is affirmed that no personnel of the Company has been denied access to the Audit Committee.

The Whistle Blower Policy is available on Company's website at https://www.ace-cranes.com/home/investor-policies-and-programme-codes. During the year, no case of genuine concerns received under this policy.

COMpLIANCE WITH SECRETARIAL STANDARDS

The Company has devised proper systems to ensure compliance with the provisions of all applicable Secretarial Standards issued by the Institute of Company Secretaries of India (ICSI) and that such systems are adequate and operating effectively.

pOLICY ON pREVENTION, pROHIBITION AND REDRESSAL OF SEXUAL HARASSMENT Of WOMEN AT WORKpLACE

The Company has laid down sexual harassment policy pursuant to provision of Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and Rules made thereunder. The objective of this policy is to provide protection against sexual harassment of women at workplace and for the prevention and redressal of complaints of sexual harassment and for matters connected therewith. The Company has zero tolerance on sexual harassment at workplace. During the financial year 2022-23, no complaint was received under this policy.

RESEARCH AND DEVELOpMENT

Your Company continues to invest in a comprehensive Research & Development (R&D) programme to develop a unique source of sustainable competitive advantage and build future readiness by leveraging contemporary advances in several relevant areas of science and technology and blending the same with classical concepts of product development.

The Company has dedicated R&D centers at Jajru Road, Faridabad and at Dudhola Link Road, Dudhola Village, Palwal. Both these centers have accreditations from the Ministry of Science and Technology, Govt. of India. Both the centers continuously carries out Research and Developments for developing new products and also focus on the quality of products, making them more economical, cost effective and user friendly.

DETAILS OF SIGNIFICANT AND MATERIAL ORDERS pASSED BY THE REGULATORS OR COURTS OR TRIBUNALS IMpACTING THE GOING CONCERN STATUS AND COMpANY'S OpERATIONS IN FUTURE

There was no significant and material order passed by the regulators or courts or tribunals impacting the going concern status and Company's operations in future.

particulars of remuneration of directors/ kmp/

EMpLOYEES

Disclosures pertaining to remuneration and other details as required under Section 197(12) of the Companies Act, 2013 and Rule 5(1), 5(2) and 5(3) of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014 is attached as Annexure-VI to this Report.

PUBLIC DEPOSITS

During the year under review, the Company has not accepted any public deposits under Chapter V of the Companies Act, 2013 and as such, no amount on account of principal or interest on public deposits was outstanding as of March 31, 2023.

PARTICULARS OF LOANS, GUARANTEES OR INVESTMENTS UNDER SECTION 186 OF THE COMPANIES ACT, 2013

Particulars of loans, guarantees and investments under Section 186 of the Companies Act, 2013 as at the end of the financial year 2022-23 are provided in the notes to standalone financial statements.

CONSERVATION OF ENERGY, TECHNOLOGY ABSORPTION AND FOREIGN EXCHANGE EARNINGS AND OUTGO

Information pursuant to conservation of energy, technology absorption and foreign exchange earnings and outgo, as required to be disclosed under the Companies Act, 2013 is annexed as Annexure-VII and forms a part of this report.

ANNUAL RETURN

The extracts of the Annual Return of the Company in Form MGT-9, as they stood on the close of the financial year i.e. March 31, 2023 is furnished in Annexure-VIII and forms part of this Report.

Further, a copy of the Annual Return of the Company containing the particulars prescribed under section 92 of the Companies Act, 2013, in Form MGT-7, as they stood on the close of the financial year i.e. March 31, 2022 is uploaded on the website of the Company at https://www.ace-cranes.com/home/mgt-7.

INVESTORS EDUCATION AND pROTECTION Fund (IEpF)

In accordance with the applicable provisions of Companies Act, 2013 read with Investor Education and Protection Fund (Accounting, Audit, Transfer and Refund) Rules, 2016 ("IEPF

Rules"), all unclaimed dividends are required to be transferred by the Company to the IEPF, after completion of seven (7) years. Further, according to IEPF Rules, the shares on which dividend has not been claimed by the shareholders for seven (7) consecutive years or more shall be transferred to the demat account of the IEPF Authority.

The details relating to amount of dividend transferred to the IEPF authority and corresponding shares on which dividends were unclaimed for seven (7) consecutive years, are provided in the Corporate Governance Report section of this Annual Report.

AWARDS AND RECOGNITIONS

Your Company continues to deliver unmatched performance amongst its peers and has been conferred with awards every year. The Company was awarded with many awards and recognition. The significant award includes:

• Transformative Trailblazing Leader - Mr Vijay Agarwal by Business Icons of India;

• Innovative Construction Equipment Award by CE&CR Magazine;

• Fortune India- Ranked 171 in the Next 500 Companies;

• India's 20 Most Impactful Power Brands by Daily Indian Media;

• Power Brands India's Most Dynamic Leader-2022 to Mr. Vijay Agarwal;

• Bestseller in Mobile Cranes Category Award- 10^th Equipment India Awards 2022;

• Person of the Year Award to Mr. Sorab Agarwal by Equipment India 2022;

• Best n Sales - Pick & Carry Cranes at Equipment Times Award Feb 2023.

BUSINESS RESpONSIBILITY AND SUSTAINABILITY REpORT (BRSR)

Pursuant to the provision of Regulation 34(2)(f) of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, the Business Responsibility and Sustainability Report (BRSR) for the financial year 2022- 23 is annexed as Annexure-IX and forms a part of this report.

DIVIDEND DISTRIBUTION pOLICY

In compliance with the provisions of Regulation 43A of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, as amended, the Board of Directors of the Company have adopted the Dividend Distribution Policy of the Company ("the Policy"). The policy inter alia, lays down various parameters relating to declaration/recommendation of dividend. The policy is available on the Company's website at weblink : https://www. ace-cranes.com/public/front/pdf/Dividend_Distribution_Policy_ ACE_2021.pdf

OTHER INFORMATION

Your Directors state that no disclosure or reporting is required in respect of the following items as there were no transactions on these items during the year under review or said items are not applicable to the Company:

1. The Managing Director and the Whole Time Directors has not received any remuneration or commission from any of its subsidiaries.

2. During the year under review, the company has not done any buy back of equity shares.

3. The Disclosure pertaining to explanation for any deviation or variation in connection with certain terms of a public issue, right issue, preferential issue etc. is not applicable to the Company.

4. No application has been made under the Insolvency and Bankruptcy Code; hence the requirement to disclose the details of application made or any proceeding pending under the Insolvency and Bankruptcy Code, 2016 (31 of 2016) during the year along with their status as at the end of the financial year is not applicable;

5. The requirement to disclose the details of difference between amount of the valuation done at the time of onetime settlement and the valuation done while taking loan from the Banks or Financial Institutions along with the reasons thereof, is not applicable; and

6. Your Company does not fall under the category of large corporate, as defined under SEBI vide its circular SEBI/HO/ DDHS/CIR/P/2018/144 dated November 26, 2018, as such no disclosure is required in this regard.

ACKNOWLEDGEMENT

The Board places on record its appreciation for the support and continued co-operation extended by all the customers, vendors, dealers, bankers, regulators and business associates. The Board places on record its appreciation to all the employees for their dedicated and committed services. Your Directors deeply acknowledgethe continued trust and confidence that the shareholders place in the management and is confident that with their continued support, the Company will achieve its objectives and emerge stronger in the coming years.

Action Construction Equipment Limited

Sd/

Place : Faridabad Vijay Agarwal

Date : May 30, 2023 Chairman & Managing Director