b. The Company has filed suit against Kerala Financial Corporation with respect to the demand of Rs. 11 lakhs as pre-closure charges on the term loans. As per the interim order of High Court of Kerala the above mentioned amount has been transferred to Kerala Financial Corporation as security deposit.

3. Some of the balances in Trade Receivables, Trade Payables and Loans and Advances are subject to confirmation.

4. The Company has not recorded any transaction in the books of accounts that has been surrendered or disclosed as income during the year in the tax assessments under the Income Tax Act, 1961 (such as, search or survey or any other relevant provisions of the Income Tax Act, 1961)

9. The company has no immovable property (other than properties where the Company is the lessee and the lease agreements are duly executed in favor of the lessee) whose title deeds are not held in the name of the company.

10. The Company has not revalued its Property, Plant and Equipment during the year and Companies (Registered Valuers and Valuation)/

Rules, 2017 is not applicable during the year. jj

b. There is no capital-work-in progress, whose completion is overdue or has exceeded its cost compared to its original plan.

c. There is no Intangible assets under development by the company during the year.

13. Disclosures required under section 22 of the Micro, Small and Medium Enterprises Development Act, 2006:

Note: Dues to Micro and Small Enterprises have been determined to the extent such parties have been identified on the basis of information collected by the management.

CALICUT, rm

14. No proceedings have been initiated or pending against the company for holding any benami property under the Benami Transactions (Prohibition) Act, 1988 (45 of 1988) and the rules made thereunder during the year.

15. The company is not declared as a willful defaulter by any bank or financial institution or other lender during the year.

16. The company has no transactions with companies struck off under section 248 of the Companies Act, 2013 or section 560 of Companies Act, 1956.

17. No charges or satisfaction are yet to be registered with Registrar of Companies beyond the statutory period during the financial year.

18. The number of layers prescribed under clause (87) of section 2 of the Act read with Companies (Restriction on number of Layers) Rules, 2017 is not applicable for the company during the year.

19. The company has not entered any Scheme of Arrangements during the year and sections 230 to 237 of the Companies Act, 2013 is not applicable to the company.

20. The company has not advanced or loaned or invested funds (either borrowed funds or share premium or any other sources or kind of fimds) to any other person(s) or entity(ies), including foreign entities (Intermediaries) with the understanding (whether recorded in writing or otherwise) that the Intermediary shall 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.

21. The company has not received any fund from any person(s) or entity(ies), including foreign entities (Funding Party) with the understanding (whether recorded in writing or otherwise) that the company shall 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.

22. The company has used the borrowings from banks and financial institutions for the specific purpose for which it was taken at the balance sheet date.

23. The Company has established an Employees’ Gratuity Fund under the name of Newmalayalam Steel Private Limited Employees Group Gratuity Fund Trust effective from 01/04/2022. The trust has been approved under Part C of the Fourth Schedule to the Income Tax Act, 1961, on 28/06/2023. As of 31/03/2023, the Company had created a provision for gratuity amounting to ?62.33 Lakhs based on the valuation report provided by Life Insurance Corporation of India (LIC). On 30th October 2023, the Company made a payment of ?62.33 Lakhs to the Gratuity Trust as part of its funding obligations towards the defined benefit plan.

Actuarial valuation requires a provision for gratuity of Rs. 43.47 Lakhs as on 31.03.2024 whereas the provision for the same was made for Rs. 62.33 Lakhs during the financial year 2022-2023 which resulted in an extra provision amounting to Rs. 18.86 Lakhs. During the current year the same was considered as Income from excess provision of gratuity amounting to Rs. 18.86 Lakhs.

The fund value of Newmalayalam Steel Private Limited Employees Group Gratuity Fund Trust with LIC as on 31/03/2024 is 64.38 Lakhs.

The company has not spent the current year CSR fund of Rs 17.75 Lakhs. On 23/01/2023 company received a request letter from Poyya Grama Panchayath with respect to a proposal of drinking water facility which will benefit the people around the company. Company has decided to contribute an amount required for the purchase of land for this project by accumulating the CSR funds under section 135 for the FY 2022-23, FY 2023-24 & FY 2024-25. Following amounts are deposited with SBI CSR Deposit with respect to above mentioned project.

(a) The company has no related party transactions for CSR activities during the year.

(b) The company has not made any provision with respect to a liability incurred by entering into a contractual obligation for CSR activities during the year.

The Company has decided to sub-divide the existing face value ofRs 1000/- to Rs 10/- in its Extra Ordinary General Meeting held on 04 th November 2023. Consequent to the sub division the number of paid up shares increased from 1,26,476 to 1,26,47,600. This increase will be reflected in the EPS calculation as well and the same would be reduced due to the increase in the number of shares.

The subdivision has resulted in a major increase in the change in shareholding percentage of the promoters.

Primary Security

1 .GECL Loans - Hypothecation charge over Stocks and Receivables 2.SBI Solar Loan - Hypothecation of Solar Panel and related equipments

3. Vehicle Loans - Hypothecation of Eicher Truck & Car

4. SBITerm Loans -

(I) Hypothecation of Plant & Machinery

(II) Equitable Mortgage over following immovable properties

a. 107.85 ares of land in the name of Sri Varghese V D S/o Davis V V in Sy No 262/3-30 at Pallipuram Village, Kodungallur Taluk.

b. 87.61 ares of land in the name of Smt Molly Varghese W/o Varghese V D in Sy No 262/3-29 at Pallipuram Village, Kodungallur Taluk.

Collateral Security

1 SB1 solar Loan and GECL Loans -

Equitable Mortgage over following immovable properties

a. 19.33 Ares of land in the name of Smt Molly Varghese W/o Varghese V D, in SY no 155/2 at Perambra Village in Chalakudy Taluk

b. 28.34 Ares of land in the name ofM/s Newmalayalam Steel P Ltd in Sy no 388/l-2p, 388/4-3p, 388/5-3p, 388/3-3p, 388/3-2p, 388/4-2p, 388/5-2p, at Poyya Village, Kodungallur Taluk.

c. 56.33 Ares of land in the name of Shri Varghese V D S/o Davis V V inSy No 571/1 situated at Poyya Village, Kodungalloor Taluk

Primary Security

l .Cash Credit and GECL Loans - Hypothecation charge over Stocks and Receivables 2.SBI Solar Loan - Hypothecation of Solar Panel and related equipments

3. Vehicle Loans - Hypothecation of Eicher Truck & Car

4. SBI Term Loans -

(I) Hypothecation of Plant & Machinery

(II) Equitable Mortgage over following immovable properties

a. 107.85 ares of land in the name of Sri Varghese V D S/o Davis V V in Sy No 262/3-30 at Pallipuram Village, Kodungallur Taluk.

b. 87.61 ares of land in the name of Smt Molly Varghese W/o Varghese V D in Sy No 262/3-29 at Pallipuram Village, Kodungallur Taluk.

Collateral Security

1 .Cash Credit, SBI solar Loan and GECL Loans -Equitable Mortgage over following immovable properties

a. 19.33 Ares of land in the name of Smt Molly Varghese W/o Varghese V D, in SY no 155/2 at Perambra Village in Chalakudy Taluk b. 28.34 Ares of land in the name of M/s Newmalayalam Steel P Ltd in Sy no 388/l-2p,

Kodungallur Taluk.

c. 56.33 Ares of land in the name of Shri Varghese V D S/o Davis V V inSy No 571/1 situated at Poyya Village, Kodungalloor Taluk

All SBI Credit facilities are secured by Personal Guarantee of Shri. V D Varghese,Shri. Cyriac Varghese, Smt. Molly Varghese, Shri. Mahendra Kumar Jain, Shri. Divya Kumar Jain,Smt Suman Jain.