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You can view full text of the latest Auditor's Report for the company.

BSE: 500113ISIN: INE114A01011INDUSTRY: Steel

BSE   ` 137.15   Open: 137.05   Today's Range 135.00
138.15
+0.10 (+ 0.07 %) Prev Close: 137.05 52 Week Range 99.20
143.20
Year End :2025-03 

1. We have audited the accompanying standalone financial statements of Steel
Authority of India Limited ('the Company'), which comprise the Balance Sheet as at
31 March 2025, the Statement of Profit and Loss (including Other Comprehensive
Income), the Statement of Cash Flow and the Statement of Changes in Equity for
the year then ended, and notes to the standalone financial statements, including
material accounting policy information and other explanatory information, in
which are included the returns for the year ended on that date audited by the
branch auditors of the Company's branches/units/marketing regions as listed in
Appendix 1.

2. In our opinion and to the best of our information and according to the explanations
given to us, and based on the consideration of the reports of the branch auditors as
referred to in paragraph 17 below, except for the effects of the matters described
in the Basis for Qualified Opinion section of our report, 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 ('Ind AS') specified under section 133 of
the Act read with the Companies (Indian Accounting Standards) Rules, 2015 and
other accounting principles generally accepted in India, of the state of affairs of
the Company as at 31 March 2025, and its profit (including other comprehensive
income), its cash flows and the changes in equity for the year ended on that date.

Basis for Qualified Opinion

3 a) As referred in note 47.2 (a) to the accompanying standalone financial statements, The Nine Judge Bench of the
the constitutional validity of the Entry Tax Act has been upheld by the Hon'ble Hon'ble Supreme court, vide its
Supreme Court and the matters relating to levy of entry tax are now pending order dated 11th November, 2016,
before Regular Benches of the High Court. Pending decision by the Hon'ble High upheld the Constitutional validity
Court of Jharkhand, the management is of the view that no adjustment is required of the Entry Tax legislations passed
in the accompanying standalone financial statements of the Company for the by the various States. However, the
disputed entry tax demand in Jharkhand state amounting to ? 105.13 crore as Bench directed that certain other
on 31 March 2025. However, in the absence of sufficient appropriate evidence to matters raised by the Petitioner,
support the management's view, we are of the opinion that a provision for entry such as matter relating to Entry
tax liability should be recognised in the standalone financial statements. Tax amounting to ?105.13 crore on

goods entering into the local area of
Jharkhand from other States, etc. may
be determined by regular benches
hearing the matters. However,
pending decision by the Courts,
the disputed Entry Tax liabilities of
?105.13 crore have been treated by
the Company as Contingent Liability.

3 b) As referred in Note 47.2 (b) to the accompanying standalone financial
statements, the Company has accounted for ?344.75 crore refundable by Damodar
Valley Corporation (DVC) pursuant to the tariff order of Jharkhand State Electricity
Regulatory Commission (JSERC) dated 10th December, 2024, which follows the
directions of the Appellate Tribunal for Electricity (APTEL). The refund which is to be
adjusted in 24 equal monthly instalments in the power bills has commenced from
January 2025. As per the communication from DVC, the total refund amount of
?344.75 crore includes ?175.82 crore towards principal and ?168.93 crore towards
interest. Management is of the view that APTEL has still not issued final orders,
as such JSERC tariff orders may still be subject to change due to the outcome of
ongoing legal case pending before APTEL. However, the Company has adjusted
the entire refund amount, including interest, against the total advance amount
appearing in the books. This is not in compliance with the requirements of Ind AS
109, which require application of the Effective Interest Method and recognition of
interest income separately in the Standalone Statement of Profit and Loss.

The Company continues to carry an amount of ?448.03 crore (?216.87 crore shown
in Other Current Asset, ?132.09 crore shown in Other Current Financial Asset and
?99.07 crore shown in Other Non-Current Financial Asset) as advance paid to DVC for
the period from FY 2012-13 to FY 2016-17. The said amount is not under any legal
or regulatory dispute, and management has not provided sufficient appropriate
audit evidence demonstrating the basis for its continued recoverability. In our
opinion, the amount should have been provided for in the standalone financial
statements for the year ended 31st March, 2025. Had the aforesaid matters been
appropriately accounted for, the interest component embedded in the refund
instalments would have been recognized as income as per Ind AS 109, resulting in
a lower loss and higher equity for the year. Further, advances aggregating ?448.03
crore should have been provided for, which would have resulted in a decrease in
current assets, an increase in the loss, and a corresponding reduction in equity as
at 31st March, 2025.

Impact of all the above qualifications on the accompanying standalone financial
statements for the year ended 31 March 2025 is as under:

As at 31st March 2025

Particulars

Reported

balances

Balances after impact
of all the qualifications
which are quantified

Other Equity

51,525.88

50,972.72

Deferred Tax Liability

6,422.33

6,283.11

Other Non Current Financial
Assets

622.47

523.40

Other Current Financial
Assets

1,221.31

1,089.22

Other Current Assets

2,910.94

2,694.07

Other Current Liabilities

4196.07

4,301.20

The Company's view is that the
cases are sub-judice and pending
for adjudication before the various
judicial authorities for a long time.
Further, the civil appeal filed by DVC
pertaining to tariff of 2004-09 against
the Order of the Appellate Tribunal
for Electricity (APTEL), have been
dismissed by the Hon'ble Supreme
Court of India vide its Order dated 3rd
December, 2018. Accordingly, State
Electricity Regulatory Commission
(SERC) will finalise the retail tariff
as directed by APTEL, the financial
implication of which can only be
ascertained after the Tariff fixation
by SERC. Jharkhand SERC (JSERC)
finalised the Category-wise Retail
Supply Tariff of DVC for the period
from FY 2006-07 to FY 2011-12 vide
order dated 31st October, 2023.
However, DVC has preferred an
appeal before Hon'ble APTEL against
the order of the JSERC regarding the
consideration of non-tariff income
in totality in the tariff order. APTEL
vide its order dated 5th February,
2024 allowed the appeal of DVC with
request to the Commission to pass
an order afresh at the earliest.

The Commission in light of the
Order of Hon'ble APTEL, passed the
remand Order dated 23.07.2024.
DVC challenged it before the Hon'ble
APTEL regarding incorrect treatment
of non-tariff income by JSERC in its
tariff order. Hon'ble APTEL vide its
interim order dated 15th Oct 2024
stayed the impugned tariff and
JSERC was directed to calculate
category wise tariff for the period
under consideration. SAIL filed Civil
Appeals before the Supreme Court,
against this interim order of Hon'ble
APTEL, however, Supreme Court vide
its order dated 27th Jan. 2025 stated
that it was not inclined to interfere
with the impugned judgment passed
by the Appellate Tribunal. In line
with direction of Hon'ble APTEL, the
JSERC has re-computed the ARR and
category-wise tariff for the period FY
2006-07 to FY 2011-12 and issued
the tariff order dated 10th Dec. 2024.

Our audit report on the standalone financial statements of the company for the year
ended 31 March 2024 was also modified in respect of above matters.

4 We conducted our audit in accordance with the Standards on Auditing specified
under section 143(10) of the Act. Our responsibilities under those standards are
further described in the Auditor's Responsibilities for the Audit of the Standalone
Financial Statements section of our report. We are independent of the Company
in accordance with the Code of Ethics issued by the Institute of Chartered
Accountants of India ('ICAI') together with the ethical requirements that are
relevant to our audit of the 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 together with the audit evidence obtained
by the branch auditors, in terms of their reports referred to in paragraph 17 of the
Other Matter section below is sufficient and appropriate to provide a basis for our
qualified opinion.

On the basis of this order, DVC has
communicated to BSL regarding
refund of total amount of ?344.75
Crore. DVC started refunding the
amount through adjustment in the
power bill from January 2025 onward
to be completed in 24 equal monthly
instalments.

The amount of ? 587.72 crores
paid to DVC retained as advance
in the books of accounts has now
been adjusted with the refundable
amount of ? 344.75 Crores. The
monthly instalment of ? 12.82 crores
received for the period Jan 2025 to
Mar 2025 has been accounted as
deduction to the total receivable
amount. Further, ? 50 crore advance,
and liability of ? 76.10 crore kept in
books of accounts related to that
period has also been adjusted with
the total advance amount of ?587.72
crore. After consideration of the
above amounts, the net advance
with M/s DVC of ?216.87 crore has
been treated as contingent liability.
In addition, the claims receivable
from M/s DVC is ?306.29 crore.

The above disputed demands stated
at (3a) and (3b), contested on valid
and bonafide grounds, have been
treated as contingent liabilities as
these are not probable that present
obligations exist as on 31st March,
2025. Therefore, there is no adverse
impact on Profit for the year.


Emphasis of Matters

5. We draw attention to the following:

a) Note 47.4 to the accompanying standalone financial statements, wherein the
Company has disclosed a demand of ?1905.52 crores raised by the Water Resources
Department, Government of Jharkhand (including interest and penalty) towards
revised water charges for industrial use from Tenu Ghat dam, as a contingent
liability. The said demand arises pursuant to Notification No. 272 & 275 dated
April 1, 2011, and a subsequent Notification No. 2/PMC/Jalapurti-175/2007-30
dated January 17, 2023. Although the Company had initially obtained interim
relief through a writ petition which has been disposed of and the challenge to the
notification has been dismissed by the Single Bench of Hon'ble Jharkhand High
Court. The Company has preferred an appeal before the Division Bench, which is
pending as on the reporting date. Further, the Company has commenced payment
of the entire amount as billed by the Water Resources Department from February
2025 onwards. This matter has been considered as a contingent liability by plant
as on March 31,2025.

b) Note 49.2 to the accompanying standalone financial statements, which describes
that the revenue from operations include sales to government agencies
aggregating to ? 9,496.05 crore for the year ended 31st March 2025 (cumulative
upto 31st March 2025 of ? 18,143.43 crore) which is recognized on the basis of
provisional prices as per the terms if sales with such Government agencies.

c) Note 49.10 to the accompanying standalone financial statements, wherein
the Company has recognised sub-grade iron ore fines inventory amounting to
? 3,867.41 crores (40.22 Million Tonnes) as at 31st March, 2025, of which inventory
amounting to ? 1,195.05 crores (12.34 Million Tonnes) is lying at the Topailore
lease as per the latest drone survey report. The Company continues to carry such
inventory at net realisable value, based on the average selling price of similar
grade fines declared by Indian Bureau of Mines (IBM), adjusted for estimated
selling expenses. However, the Company is yet to receive the necessary dispatch
permission from the relevant authority for the Topailore lease, and no alternate
arrangements for disposal or internal consumption are presently available.

d) Note 49.14 to the accompanying standalone financial statement, regarding
suspension of certain officers and employees of the Company in the previous
year and its subsequent revocation basis directions from the Ministry of Steel,
Government of India. The matter is pending investigation by external investigative
agencies on aspects relating to policy/pricing decisions of the Company as per
directions of the Lokpal of India vide its order dated 10 January 2024. In view of
the management, basis their internal assessment, the matter is not likely to have a
material impact on the operations of the Company and/or these financial results.

e) Note 49.15 of the accompanying standalone financial statements, which describes
that a claim of ?3.60 crores has been recognized in the books of accounts in
relation to irregular transactions. Out of this, an amount of ?0.45 crores has been
recovered, and efforts are ongoing to recover the balance of ?3.15 crores. Pending
recovery, a provision of ?3.15 crores has been made in the books of accounts.

Our opinion is not modified in respect of these matters.

Key Audit Matters

6. Key audit matters are those matters that, in our professional judgment, and based
on the consideration of the reports of the branch auditors as referred to paragraph
17 below, were of most significance in our audit of the standalone financial
statements of the current period. These matters were addressed in the context of
our audit of the standalone financial statements as a whole, and in forming our
opinion thereon, and we do not provide a separate opinion on these matters.

7 In addition to the matters described in the Basis for Qualified Opinion, we have
determined the matters described below to be the key audit matters to be
communicated in our report.

Key audit matter

How our audit addressed the key
audit matter

Provision and contingent liabilities
relating to ongoing litigations

The Company is subject to a number
of legal, regulatory and tax cases
for which final outcome cannot be
easily predicted and which could
potentially result in significant
liabilities.

Management's disclosures with
regards to provisions and contingent
liabilities relating to ongoing
litigations are presented in note
47.1 to the Company's Standalone
Financial Statements. Refer note
3.15 for related material accounting
policy information adopted by the
Company.

The assessment of whether a liability
is recognised as a provision or
disclosed as a contingent liability in
the standalone financial statements
is inherently subjective and requires
significant management judgement
in determination of the cash outflows
from the business, interpretation
of applicable laws and regulations,
and careful examination of pending
assessments at various levels of
regulatory authorities.

Since the amounts involved are
significant and due to the range of
possible outcomes leading to high
estimation and uncertainty that
requires significant management
and auditor judgement, this matter
is considered to be a key audit matter
for the current year audit.

Our audit procedures included, but

were not limited to the following:

• Obtained understanding of the
process of identification and
measurement of provisions and
contingent liabilities relating to
ongoing litigations implemented by
the Management, through various
discussions held with Company's
legal and finance personnel.

• Evaluated the design and tested
the operating effectiveness of
the controls put in place by
the management in relation to
assessment of the outcome of the
pending litigations.

• Inspected the summary of litigation
matters and discussed key
developments during the year with
the Company's Legal and Finance
personnel.

• Inspected and evaluated, where
applicable, external legal and/
or regulatory advice sought by
the Company. Obtained direct
confirmations from the dealing
lawyers for certain material ongoing
litigations.

• Evaluated the design and tested
the operating effectiveness of
the controls put in place by
the management in relation to
assessment of the outcome of the
pending litigations.

• Inspected the summary of litigation
matters and discussed key
developments during the year with
the Company's Legal and Finance
personnel.

• Inspected and evaluated, where
applicable, external legal and/
or regulatory advice sought by
the Company. Obtained direct
confirmations from the dealing
lawyers for certain material ongoing
litigations.

• Discussed and challenged the
management's assessment of
the likelihood, magnitude and
accounting of any liability that
may arise in certain material cases.
Accordingly, we reviewed the
amount of provisions recognised
and contingent liabilities
disclosed in the standalone
financial statements and exercised
our professional judgment to
assess appropriateness of such
conclusions, involving experts as
required.

• Evaluated the adequacy of
disclosures made in the Company's
standalone financial statements in
accordance with the applicable
accounting standards.

Property, plant and equipment and
intangible assets (including capital
work in progress)

As at 31st March 2025 the Company has
Property, Plant and Equipment ('PPE'),
Intangible Asset ('IA') and CapitalWork-
in-Progress ('CWIP') with carrying
value of ? 65,022.90 crore, ? 1425.69
crore, ? 7206.21 crore, respectively, as
disclosed in note 4, note 7 and note
5 of the accompanying Standalone
Financial Statements. Refer note 3.1
for the material accounting policy
information adopted by the Company
for recognition and measurement of
such non-current assets.

Determination of carrying values
and their respective depreciation
and amortisation amounts of PPE,
IA and CWIP requires considerable
management judgement. These
include the decisions to capitalise
or expense costs, the annual asset
life review, the timeliness of the
capitalisation of assets and the use
of management's assumptions and
estimates for the determination and
measurement of assets retired from
active use, in accordance with the
requirements of Ind AS 16 - Property,
Plant and Equipment ('Ind AS 16') and
Ind AS 38 - Intangible Assets ('Ind AS
38').

Our audit procedures included, but

were not limited to the following:

• Obtained an understanding
of the management's process
of recording the transactions
pertaining to capital expenditure
incurred by the company and
evaluated the accounting policies
adopted by the company in
accordance with the requirements
of Ind AS 16 and Ind AS 38.

• Evaluated the design and tested
the operating effectiveness of
the controls put in place by the
management in relation to the
above process.

• Tested the amounts capitalized
during the year, on a sample
basis, by inspecting supporting
documents and evaluating
whether assets capitalized
satisfied the recognition criteria
and were recognized accurately
in the correct periods and with
correct amounts.

• Reviewed the judgements made
by management in determination
of carrying values of the specified
non-current assets including
the nature of underlying costs
capitalized, determination of
realizable value of the assets
retired from active use, the
appropriateness of useful lives
applied in the calculation of
depreciation as determined
by technical assessment by
management and external
technical experts, where required,
and evaluation of appropriateness
of long standing CWIP balances
pertaining to long-term projects.

The carrying value of CWIP also
includes balances pertaining to long¬
term projects which requires careful
examination of continuity and viability
of such projects.

Considering the significance of
amounts involved in the context of
the balance sheet of the Company and
the level of judgements and estimates
required, we consider this to be a key
audit matter in the current year audit.

By-products inventory

Refer to note 3.7 of summary of
material accounting policy information
and other explanatory information for
valuation of by-products amounting
to ? 4,901.03 crore as at 31st March
2025 and significant accounting
judgements, estimates and
assumptions related thereto and the
note 3.21.4 of the standalone financial
statements.

Inventories of by-products mainly
consist of sub- grade fines, iron and
steel scrap embedded in BF slag and LD
slag and slime, and tailings containing
iron ore fines, which are accumulated
in stock piles.

Further, as explained in notes 49.10,
pursuant to the order of Ministry of
Mines, Government of India dated 16th
September 2019, certain by-products
were allowed to be sold and hence,
were valued for the first time in the
previous years.

The management of the Company also
sought the opinion of Expert Advisory
Committee of the ICAI ('EAC Opinions')
on recognition and measurement of
by-product inventories.

Valuation of such items requires
management to exercise significant
judgement in respect of use of
estimates for determination of the
quantity, quality and valuation rate of
these items.

Further, basis the expected future
salability and plans for captive
consumption of such by-product
inventories, the management has
classified inventory expected to be
sold / consumed after 12 months from
the date of balance sheet, being the
operating cycle of the Company, as
non-current inventory.

• Evaluated the appropriateness and
adequacy of the related disclosures
in the standalone financial
statements in accordance with the
applicable accounting standards.

in conjunction with the EAC
Opinions obtained by the
management.

• In assessing management's
assessment of the value of
by products, we discussed in
detail with the management
to understand the procedures
adopted in ascertaining the
quantity and quality (including
gradation) of the by- products
considered for valuation.

Our audit procedures included, but

were not limited to the following:

• Obtained an understanding of
the processes and procedures,
including controls relating to
identification of sub grade fines,
iron and steel scrap embedded
in BF slag and LD slag and slime
containing iron ore fines ('by¬
products').

• Evaluated the accounting policy
adopted by the Company for
valuation of the by-product
inventory in accordance with the
requirements of Ind AS 2, Inventory

• Management's estimate of the
NRV was verified with reference
to the average selling price (ASP)
published by the Indian Bureau of
Mines. We also obtained technical
analysis report from external
experts sought by management
for determining the quantity of by¬
products and the chemical analysis
report used by the management
for arriving at the quality (including
gradation) of fines.

Owing to the insignificant movement
in sales / consumption of such by¬
products inventory, the materiality
of the carrying value thereof and the
complexities discussed above, we have
considered this area as a key audit
matter in the current year audit.

Further, the management's assessment
of classification and valuation of
aforesaid inventory as described in
note 49.10 is considered fundamental
to the understanding of the users of
the standalone financial statements.

• Obtained management's

working of estimated future
sales / consumption used for
classification of the by- product
inventory between current and
non-current, and tested the
underlying assumptions basis our
understanding of the processing
and further approvals required for
sale of such inventory in addition
to evaluating management's
estimates on availability of
demand for such by-products.

• Evaluated the appropriateness and
adequacy of the related disclosures
in the standalone financial
statements in accordance with the
applicable accounting standards.

Information other than the Standalone Financial Statements and Auditor's

Report thereon

8 The Company's Board of Directors are 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 auditor's report
thereon. The Annual Report is expected to be made available to us after the date
of this auditor's report.

Our opinion on the standalone financial statements does not cover the other
information and we will 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
in the audit or otherwise appears to be materially misstated.

When we read the Annual Report, if we conclude that there is a material
misstatement therein, we are required to communicate the matter to those
charged with governance.

Responsibilities of Management and Those Charged with Governance for the

Standalone Financial Statements

9 The accompanying standalone financial statements have been approved by the
Company's Board of Directors. The Company's Board of Directors are responsible
for the matters stated in section 134(5) of the Act with respect to the preparation
and presentation of these standalone financial statements that give a true
and fair view of the financial position, financial performance including other
comprehensive income, changes in equity and cash flows of the Company in
accordance with the Ind AS specified under section 133 of the Act and other
accounting principles generally accepted in India. 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.

10 In preparing the standalone financial statements, the Board of Directors 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 the Board of Directors either intends to
liquidate the Company or to cease operations, or has no realistic alternative but
to do so.

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

Auditor's Responsibilities for the Audit of the Standalone Financial Statements

12 Our objectives are to obtain reasonable assurance about whether the standalone
financial statements as a whole are free from material misstatement, whether
due to fraud or error, and to issue an auditor's report that includes our opinion.
Reasonable assurance is a high level of assurance, but is not a guarantee that an
audit conducted in accordance with Standards on Auditing 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.

13 As part of an audit in accordance with Standards on Auditing, specified under
section 143(10) of the Act we exercise professional judgment and maintain
professional skepticism throughout the audit. We also:

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

Obtain an understanding of internal 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 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 Board of Directors' use of the going concern
basis of accounting and, based on the audit evidence obtained, whether a material
uncertainty exists related to events or conditions that may cast significant doubt
on the Company's ability to continue as a going concern. If we conclude that a
material uncertainty exists, we are required to draw attention in our auditor's
report to the related disclosures in the financial statements or, if such disclosures
are inadequate, to modify our opinion. Our conclusions are based on the audit
evidence obtained up to the date of our auditor's report. However, future events
or conditions may cause the Company to cease to continue as a going concern;

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

Obtain sufficient appropriate audit evidence regarding the financial statements/
financial information of the Company and its branches/units/marketing regions
or the business activities within the Company to express an opinion on the
standalone financial statements. We are responsible for the direction, supervision
and performance of the audit of standalone financial statements of the Company
and such branches/units/marketing regions included in the standalone financial
statements, of which we are the independent auditors. For the other branches/
units/marketing regions included in the standalone financial statements,
which have been audited by the branch auditors, such branch auditors remain
responsible for the direction, supervision and performance of the audits carried
out by them. We remain solely responsible for our audit opinion.

14 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.

15 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.

16 From the matters communicated with those charged with governance, we
determine those matters that were of most significance in the audit of the
standalone financial statements of the current period and are therefore the key
audit matters. We describe these matters in our auditor's report unless law or
regulation precludes public disclosure about the matter or when, in extremely
rare circumstances, we determine that a matter should not be communicated in
our report because the adverse consequences of doing so would reasonably be
expected to outweigh the public interest benefits of such communication.

Other Matter

17 We did not audit the annual financial statements/financial information of 09
branches/units/marketing regions included in the standalone financial statements
of the Company whose annual financial statements/financial information reflects
total assets of ? 52,214.50 crore as at 31 March 2025, and the total revenues of
? 38,643.44 crore, total net loss after tax of ? 34.62 crore, total comprehensive
loss of ? 13.22 crore, and cash outflow (net) of ? 6.15 crore, respectively, for the
year ended on that date, as considered in the standalone financial statements.
These annual financial statements/financial information have been audited by the
branch auditors whose reports have been furnished to us by the management,
and our opinion on the standalone financial statements, in so far as it relates to
the amounts and disclosures included in respect of branches/units/marketing
regions, and our report in terms of sub-section (3) of section 143 of the Act in so far
as it relates to the aforesaid branches, is based solely on the report of such branch
auditors.

18 We draw attention to the fact that during the year ended 31st March 2025, the
Company was not in compliance with the requirements of Section 149, 177,
and 178 of the Companies Act, 2013, read with Regulations 17, 18, and 19 read
with Schedule II of the SEBI (Listing Obligations and Disclosure Requirements)
Regulations, 2015, relating to the composition of the Board of Directors and its
committees. The Board of Directors consisted of 11 members, of which only 3 are
independent directors, which is less than the prescribed minimum of one-third as
per Section 149(4) of The Companies Act, 2013. During the year, the Company did
not had a woman director as well as 3 other independent directors on the Board
but until April 2025. Consequently, the Audit Committee and the Nomination
and Remuneration Committee were also not constituted in accordance with the
above-mentioned applicable provisions during the financial year. The standalone
financial results for the year ended 31st March 2025, as stated in Note 1, were
approved by the Board on the recommendation of the Audit Committee.

Our opinion above on the standalone financial statements, and our report on
other legal and regulatory requirements below, are not modified in respect of the
above matters with respect to our reliance on the work done by and the reports of
the branch auditors.

19 The standalone financial statements of the Company for the year ended 31 March
2024 were audited jointly by the predecessor auditors, M/s Walker Chandiok & Co.
LLP, M/s J N Gupta & Co. LLP, M/s SPARK & Associates Chartered Accountants LLP
and M/s Vinod Singhal & Co. LLP, who have expressed a qualified opinion on those
standalone financial statements vide their audit report dated 20 May 2024.

Steel Authority of India Limited (SAIL)
being a Government Company,
Directors (including Independent
Directors) are appointed based on
the nomination by Government of
India. The status of the vacancies
in various positions in the Board
and the consequence of the same
for non -compliance with request
for filling up the vacancies in the
positions of the Executive Directors
and Independent Directors was
pursued by the Company with the
Administrative Ministry vide our
letter dated 21.03.2025, 30.10.2024,
08.04.2024 and 22.03.2024. The
same was also taken-up with the
Administrative Ministry and DPE
earlier also. The Board has been
regularly kept informed in this
regard.

Report on Other Legal and Regulatory Requirements

20 Based on our audit, and on the consideration of the reports of the branch auditors
as referred to in paragraph 17 above, we report that the provisions of section
197 read with Schedule V to the Act are not applicable to the Company since the
Company is a Government company as defined under section 2(45) of the Act.
Accordingly, reporting under section 197(16) is not applicable.

21 As required by the Companies (Auditor's Report) Order, 2020 ('the Order') issued
by the Central Government of India in terms of section 143(11) of the Act we give
in the Annexure I, a statement on the matters specified in paragraphs 3 and 4 of
the Order, to the extent applicable.

22 Further to our comments in Annexure I, as required by section 143(3) of the Act
based on our audit, and on the consideration of the reports of the branch auditors
as referred to in paragraph 17 above, we report, to the extent applicable, that:

a) We have sought and except for the matters described in the Basis for Qualified
Opinion section, obtained all the information and explanations which to the best
of our knowledge and belief were necessary for the purpose of our audit of the
accompanying standalone financial statements;

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 and
proper returns adequate for the purposes of our audit have been received from
the branches not visited by us, except for the effects of the matters described
in the Basis for Qualified Opinion section and except for the matters stated in
paragraph 21(i)(vi) below on reporting under Rule 11(g) of the Companies (Audit
and Auditors) Rules, 2014 (as amended).

c) The reports on the accounts of the branch offices of the Company audited under
section 143(8) of the Act by the branch auditors have been sent to us and have
been properly dealt with by us in preparing this report;

d) The standalone financial statements dealt with by this report are in agreement
with the books of account and with the returns received from the branches not
visited by us;

e) Except for the effects of the matters described in the Basis for Qualified Opinion
section, in our opinion, the aforesaid standalone financial statements comply with
Ind AS specified under section 133 of the Act;

f) The provisions of section 164(2) of the Act are not applicable to the Company
since the Company is a Government company as defined under section 2(45) of
the Act;

g) The qualification/modification relating to the maintenance of accounts and other
matters connected therewith are as stated in paragraph 3 of the Basis for Qualified
Opinion section, paragraph 21(b) above on reporting under section 143(3)(b)
of the Act and paragraph 21(i)(vi) below on reporting under Rule 11(g) of the
Companies (Audit and Auditors) Rules, 2014 (as amended);

h) With respect to the adequacy of the internal financial controls with reference to
standalone financial statements of the Company as on 31 March 2025 and the
operating effectiveness of such controls, refer to our separate report in Annexure
II wherein we have expressed an unmodified opinion; and

i) With respect to the other matters to be included in the Auditor's Report in
accordance with rule 11 of the Companies (Audit and Auditors) Rules, 2014 (as
amended), in our opinion and to the best of our information and according to
the explanations given to us and based on the consideration of the reports of the
branch auditors as referred to in paragraph 17 above:

i. Except for the effects of the matters described in paragraph 3 of the Basis for
Qualified Opinion section, the Company, as detailed in note 47.1 to the standalone
financial statements, has disclosed the impact of pending litigations on its financial
position as at 31 March 2025;

ii. The Company did not have any long-term contracts including derivative contracts
for which there were any material foreseeable losses as at 31 March 2025;

iii. There were no amounts which were required to be transferred to the Investor
Education and Protection Fund by the Company during the year ended 31 March
2025 except ? 1.00 crore pertaining to unclaimed matured deposits which was
required to be deposited in the Investor Education and Protection Fund during the
year ended 31st March 2018 and which has not been deposited till 31st March 2025;

The matured deposit have already
been claimed by the successors/
relatives of the individuals but is
pending for submission of document
of proof of legal heir by the claimants.
Appropriate procedure is being
followed for refunding the matured
deposits to the legal heirs.

iv.

a. The management has represented that, to the best of its knowledge and belief,
as disclosed in note 51.7(a) to the standalone financial statements, no funds
have been advanced or loaned or invested (either from borrowed funds or
securities premium or any other sources or kind of funds) by the Company to or
in any person(s) or entity(ies), including foreign entities ('the 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 ('the Ultimate Beneficiaries') or provide any guarantee, security or
the like on behalf the Ultimate Beneficiaries;

b. The management has represented that, to the best of its knowledge and
belief, as disclosed in note 51.7(b) to the standalone financial statements, no
funds have been received by the Company from any person(s) or entity(ies),
including foreign entities ('the Funding Parties'), with the understanding,
whether recorded in writing or otherwise, that the Company shall, whether
directly or indirectly, lend or invest in other persons or entities identified
in any manner whatsoever by or on behalf of the Funding Party ('Ultimate
Beneficiaries') or provide any guarantee, security or the like on behalf of the
Ultimate Beneficiaries; and

c. Based on such audit procedures performed as considered reasonable and
appropriate in the circumstances, nothing has come to our notice that has
caused us to believe that the management representations under sub-clauses
(a) and (b) above contain any material misstatement.

v. The interim/final dividend paid by the Company during the year ended 31 March
2025 in respect of such dividend declared for the previous year is in accordance
with section 123 of the Act to the extent it applies to payment of dividend

As stated in note 49.16 to the accompanying standalone financial statements,
the Board of Directors of the Company have proposed final dividend for the year
ended 31 March 2025 which is subject to the approval of the members at the
ensuing Annual General Meeting. The dividend declared is in accordance with
section 123 of the Act to the extent it applies to declaration of dividend.

vi. Based on our examination which included test checks except for the instance
mentioned below, the Company, in respect of financial year commencing on 1
April 2024, have used accounting software for maintaining its books of account
which have a feature of recording audit trail (edit log) facility and the same have
been operated throughout the year for all relevant transactions recorded in the
software. Further, during the course of our audit we did not come across any
instance of audit trail feature being tampered with, other than the consequential
impact of the exception given below.

Nature of exception noted

Details of Exception

Audit trail facility is being imple¬
mented shortly.

Instances of accounting software for
maintaining books of account which
did not have a feature of recording
audit trail (edit log) facility

The audit trail feature of certain
accounting software used for
maintaining books of accounts of
one plant does not have a feature of
recording audit trail (edit log) facility.
Additionally, certain features of audit
trail (edit log) were not enabled for the
entire financial year at one plant.

Instances of accounting software for
maintaining books of account for
which the feature of recording audit
trail (edit log) facility was not operated
throughout the year for all relevant
transactions recorded in the software

The audit trail feature was not enabled
at the database level for certain
accounting software for corporate
office, one unit, five marketing regions
and seven plants to log any direct data
changes, used for maintenance of all
accounting records by these corporate
office/unit/marketing regions/plants.

The matter is under review for neces¬
sary action.

23 As required by section 143(5) of the Act, we give in 'Annexure III', a statement on
the matters specified in the directions issued by the Comptroller and Auditor
General of India in respect of the Company.

For J N Gupta & Co. LLP For S P A R K & Associates Chartered

Chartered Accountants Accountants LLP

Firm Registration No. 006569C/W100892 Chartered Accountants

Firm Registration No. 005313C/C400311

CA. Akansh Gupta

Partner CA. Nilesh Gupta

M.No. 456312 Partner

UDIN: 25456312BMUICY2917 M.No. 406020

UDIN: 25406020BMUHVJ8498

For Vinod Singhal & Co. LLP

Chartered Accountants For APT & Co. LLP

Firm Registration No. 005826C/C400276 Chartered Accountants For and on behalf of the Board of

Firm Registration No. 014621C/N500088 Directors

CA. Shivani Gupta Sd/-

Partner CA. Ashish Goyal (Amarendu Prakash)

MNo- 078389 Partner Chairman & Managing Director

UDIN: 25078389BMOYNA3698 M.No. 534775

UDIN: 25534775BMJIYR6268

Place: New Delhi Place : New Delhi

Date: 28th May 2025 Date: 11th August, 2025