Notes to Accounts of Beryl Drugs Ltd.

Mar 31, 2024

Note No. 13.01: Debts due by directors or other officers of the Company

Debts due by directors or other officers of the Company or any of them either severally or jointly with any other persons or debts due by firms or private companies respectively in which any director is a partner or a director or a member as on 31 March 2024 - NIL (31.3.2023 - NIL)

Note No. 13.04

Since Mostly the customer of the company are an organization which is controlled by the various departments of State Government of India, even then company has been made provision for loss allowance in the past and as on 31st March 2024, the company is not assure for their recovery to some extent.

NOTE 19.04 :

Terms/ Rights attached to equity shares :

The Company has only one class of shares i.e. equity shares having a face value of Rs. 10. All these shares have the same rights and preferences with respect to payment of dividend, repayment of capital and voting. Dividend on equity shares whenever proposed by the Board of Directors is subject to the approval of the shareholders in the Annual General Meeting. In the event of liquidation of the Company, the holders of equity shares will be entitled to receive remaining assets of the Company, after distribution of preferential amounts. The distribution will be in proportion to the number of equity shares held by the shareholders.

Nature and purpose of components of other equity :

1 "Retained earnings: Retained earnings are the profits that the Company has earned till date, less any transfers to general reserve, dividends, or other distributions paid to shareholders."

Note No. 21.02:

There are no defaults as on the Balance Sheet date in repayment of the above loans and interest thereon.

Note No. 21.03- Charges not registed with ROC till date:

The Company has taken a loan from Kotak Mahindra Bank for Rs. 175 Lakhs on 01/11/2021, for which charge has not been created till date. However, management is under process for creation of charge.

Note No. 21.04- Utilisation of Funds

The loan has been utlised for the purpose for which it was obtained and no short term funds have been used for long term purpose.

Note No. 21.05- Difference between books debt statement submitted to bank and balance as per books:

The Monthly statements of Book Debts filed by the company with the banks are in agreement with the books of accounts of the company, except some differences as mentioned as below :-

Note No. 23.01 : Debts due by directors or other officers of the Company

Debts due by directors or other officers of the Company or any of them either severally or jointly with any other persons or debts due by firms or private companies respectively in which any director is a partner or a director or a member as on 31 March 2023 - NIL (31.3.2022 - NIL)

Note No. 29.01: Other Adjustments of Rs. 318.11 Lakhs (PY Rs. 1.68 Lakhs) is related to Delay Supply Charges deducted by the Tamilnadu Medical Services Corporation Limited and Rs. 3.26 Lakhs is related to Delay Supply Charegs deducted by Karnataka State Medical Supplies Corporation Limited.

Note No. 29.02: Sale of Goods for the year ended 31st March 2023 has been recasted/regrouped after deducting Other Adjustment of Delay Supply Charges deducted by Karnataka State Medical Supplies Corporation Limited.

38. Previous year''s figures have been regrouped, re-casted and re-arranged wherever necessary to make them comparable with those of the current year.

40. Disclosure as per Ind AS 116, “Leases”

i. As Lessee:

The 3 industrial land allotted by MPAKVN is on a lease of 30 years, which is further renewable and is recognized in the financial statements. Since the yearly lease payments for such leases are not material, the management has decided to apply the recognition exemption as per Para 5(b) of IND AS 116, wherein the entity need not apply the requirements for which, the recognition and measurement of lease liability for which the underlying asset is of low value. There is another property on lease whose rentals are Rs. 0.72 Lakhs per annum and the rent agreements for 11 months are cancellable and are generally renewable in mutual consent or mutually agreeable terms.

ii. As Lessor

The company has given its Godown to various parties on monthly rent. The rent agreements for 11 months are cancellable and are generally renewable in mutual consent or mutually agreeable terms. The rental income on such Godown is included in other income.

41. Disclosure as per Ind AS-37, “Provisions, Contingent Liabilities and Contingent Assets”:

( R in Lakhs)
S.	Particulars	2023-2024	2022-2023
No.		Amount	Amount
1)	Contingent Liabilities Guarantees issued by Bank on behalf of the Company.	30.87	25.87
	Performance Guarantees/ Other money for which the company is contingently liable	43.81	98.11
	Claims against the Company /disputed liabilities not acknowledged as debts:	NIL	NIL
	M.P. Entry Tax 1998-99	0.83	0.83
	Vat Tax 2015-16	1.46	1.46
	TDS Defaults on Traces (various FY)	2.65	2.69
	Income Tax AY 2021-22	-	0.05
2)	Commitments :
	Estimated amount of Contracts remaining to be executed on Capital Account and not provided for (net of advances).	-	18.90
	Other Commitments	NIL	NIL
3)	Impact of pending litigations: There are no other material pending litigations against the company, which will impact its financial position.	NIL	NIL

42. Segmental Reporting:

The Company is engaged in the sole segment of Drug Manufacturing. There are, therefore, no separate segments within the Company as defined by IND AS-108(Operating Segments)

43. During the year, Borrowing Costs amounting of Rs. NIL (previous year Rs. Nil) has been Capitalized to Property, Plant and Equipments.

45. The Company has no subsidiary. Hence requirement of Consolidated Financial Statement is not applicable to the Company.

46. In the opinion of the Board Current Assets, Loans & Advances are approximately of the value stated, if realized in the ordinary course of business. The provision for Depreciation & amortization and all known liability are adequate. There is no Contingent liability other than stated.

47. Details of Dues To Micro And Small Enterprises As Defined Under The Micro, Small And Medium Enterprises Development Act, 2006:

As on the date of Balance Sheet, the Company has not received (except as given in Table) any communication from any of its suppliers regarding the applicability of Micro, Small and Medium enterprises development Act, 2006 to them, as such, information as required under the act cannot be complied and therefore not given for the year.

The following information has been determined to the extent such parties have been identified on the basis of information available with the company:-

The above information regarding Micro and Small Enterprises has been determined on the basis of information available with the Company basis the details provided by the enterprises.

48. Disclosure as per IND AS-113, “Fair value measurement”

The carrying amount of Short term borrowing, Trade payables, Trade Receivables, Cash & cash equivalents and other financial assets and liabilities are considered to be recorded at their fair value due to their short term nature. There are no transfer between Level 1, Level 2 & Level 3 during the year ended 31.03.2024.

50. Details of Corporate Social Responsibility Expenditure:

As per Section 135 of the Companies Act, 2013, The company is not liable to spend the specified amount on CSR activities as per the norms. Hence, no separate reporting is required for the same.

51. Disclosure related to Investment Property:

Fair Value as on 31.3.2024 of Investment property based on valuation of an independent registered valuer dt. 20/07/2020 is as follows because current valuation is under process and not obtain upto

date of our audit report. Hence, disclosure has been made on the said mentioned date valuation:

a. Land on P.H.No. 18, Survey No. 278/1, Plot No. 100, Gram Kelodhala, Tehsil & District, Indore : Fair Value Rs. 8029488.00

b. Godown constructed on (a) above: Fair Value Rs. 11900000.00

Fair Value as on 31.3.2024 of Investment property based on Guideline valuation is as follows because current valuation is under process and not obtain upto date of our audit report. Hence, disclosure has been made on such guideline valuation:

a. Land on P.H.No. 189, Survey No. 278/1, Plot No. 109,110, 115, Gram Kelodhala, Tehsil & District, Indore: Fair Value Rs. 140 Lacs.

Amounts recognized in profit and loss account for:

Rental Income on Godown given on rent is Rs. 12.73 Lacs (P.Y. Rs.12.73 Lacs).

52. Disclosure as per IND As 107, Financial Instruments a. Capital management

The Company''s objectives when managing capital is to safeguard their ability to continue as a going concern, so that they can continue to provide returns for shareholders and benefits for other stakeholders. In order to maintain or adjust the capital structure, the Company adjusts the amount of dividends paid to shareholders, return capital to shareholders or issue new shares.

For the purpose of Company''s capital management, Capital includes Issued Equity share capital. Gearing Ratio is ratio of Net debts (total borrowings (long term as well as short term) net of cash & cash equivalents) divided by total equity capital. Accordingly, the Company has calculated gearing ratio as at 31 March, 2024 and 31 March, 2023. The gearing ratio is as follows:

b. Financial risk management objective and policies:

This section gives an overview of the significance of financial instruments for the Company and provides additional information on the balance sheet. Details of significant accounting policies, including the criteria for recognition, the basis of measurement and the basis on which income and expenses are recognized, in respect of each class of financial asset and financial liability are disclosed in Note No. 1

Financial assets and liabilities: The accounting classification of each category of financial instruments, and their carrying amounts, are set out below:

c. Fair value of financial assets and financial liabilities that are not measured at fair value

Management considers that the carrying amounts of financial assets and financial liabilities recognized in the Financial Statements.

d. Defaults and breaches

There is no default in loans payable recognized at the end of the reporting period.

e. Risk management framework

The Company''s business is subject to several risks and uncertainties including financial risks. The Company''s documented risk management polices act as an effective tool in mitigating the various financial risks to which the business is exposed to in the course of their daily operations. The risk management policies cover areas such as liquidity risk, interest rate risk, counterparty and concentration of credit risk and capital management. Risks are identified through a formal risk management programme with active involvement of senior management personnel and business managers. The Company''s risk management process is in line with the corporate policy. Each significant risk has a designated ‘owner'' within the Company at an appropriate senior level. The potential financial impact of the risk and its likelihood of a negative outcome are regularly updated.

The risk management process is coordinated by the Management Assurance function and is regularly reviewed by the Company''s Audit Committee. The overall internal control environment and risk management programme including financial risk management is reviewed by the Audit Committee on behalf of the board. The risk management framework aims to:

• improve financial risk awareness and risk transparency

• identify, control and monitor key risks

• identify risk accumulations

• provide management with reliable information on the Company''s risk situation

• improve financial returns Treasury management

The Company''s treasury function provides services to the business, co-ordinates access to domestic and international financial markets, monitors and manages the financial risks relating to the operations of the Company through internal risk reports which analyses exposures by degree and magnitude of risks. These risks include market risk (including currency risk and interest rate risk), credit risk and liquidity risk.

Treasury management focuses on capital protection, liquidity maintenance and yield maximization. Financial risk

The Company''s Board of Directors approves financial risk policies comprising liquidity, foreign currency, interest rate and counterparty credit risk. The Company does not engage in the speculative treasury activity but seeks to manage risk and optimize interest through proven financial instruments. i. Credit risk

Credit risk refers to the risk that counterparty will default on its contractual obligations resulting in financial loss to the Company. The Company has adopted a policy of only dealing with creditworthy counterparties as a means of mitigating the risk of financial loss from defaults. The Company is exposed to credit risk for receivables, cash and cash equivalents, bank balances other than cash and cash equivalents, investments and loans.

Regarding trade and other receivables, the Company has accounted for impairment based on expected credit losses method as at 31 March, 2024 and 31 March, 2023 based on expected probability of default.

Deposits are with government departments and with lessor so chances of default are very minimal.

For short-term loans and advances, counterparty limits are in place to limit the amount of credit exposure to any counterparty.

None of the Company''s cash equivalents are past due or impaired. ii. Liquidity risk

Liquidity risk arises from the Company''s inability to meet its cash flow commitments on time. Prudent liquidity risk management implies maintaining sufficient stock of cash and marketable securities. The Company maintains adequate cash and cash equivalents alongwith the need based credit limits to meet the liquidity needs.

53. Beryl Security Limited, is a group company which has only MD and Other director are common & these KMP have also shareholding in the other company, hence company has not considered Consolidation of Financial Statement as per IND As 110.

55. Wilful Defaulter

The company has not declare wilful defaulter by any bank or financial institution or other lender.

56. Events after reporting date:

There have been no events after the reporting date that require adjustment/disclosures in these financial statements.

57. Undisclosed income

As explained by the management and records examined by us, no transactions were observed which remain unrecorded in the books of accounts that can materially impact the financial position of the company as at the balance sheet date. Further, no instances of transactions surrendered or disclosed as income during the year in the tax assessments under the Income Tax Act, 1961 which previously remain unrecorded, offered as income in the books of accounts during the year.

58. Details of Benami Property held:

During the year 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 rules made there under.

59. Indications of impairment:

In the opinion of management ,there are no indications, internal or external which could have the effect of Impairing the value of assets to any material extent as at the Balance Sheet date requiring recognition in terms of Ind AS 36.

61. Details of Crypto Currency or Virtual Currency

The company has not traded or invested in crypto currency or Virtual currency during the year.

62. The Company, has no long-term contracts including derivative contracts having material foreseeable losses as at 31 March 2024.

63. There is nothing to report with regard to Disclosure related to Loans or Advances in the nature of loans are granted to promoters, directors, KMPs and the related parties (as defined under Companies Act, 2013,) either severally or jointly with any other person since no such transaction.

64. During the year no scheme of arrangement has been formulated by the Company/pending with any competent authority.

65. The Company has no subsidiary. The Company is in compliance with the number of layers as prescribed under clause (87) of section 2 of the Companies Act, 2013 read with the Companies (Restriction on Number of Layers) Rules, 2017.

66. During the year the company has not advanced or loaned or invested funds (either borrowed funds or share premium or any other sources or kind of funds) to any other person or entity including foreign entities (intermediaries) with the understanding (whether recorded in writing or otherwise) that the intermediary shall

(i) directly or indirectly lend or invest in other person or entities identified in any manner whatsoever by or on behalf of company (ultimate beneficiaries) or

(ii) provide any guarantee, security or the like to or behalf of the ultimate beneficiaries. The company has not given guarantee or provided security.

67. 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

(i) directly or indirectly lender invest in any manner whatsoever by or on behalf of the funding party (ultimate beneficiaries) or

(ii) provide any guarantee, security or the like to or on behalf of the (ultimate beneficiaries) or

(iii) provide any guarantee, security or the like to or on behalf of the ultimate beneficiaries.

68. 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 w.e.f. 01 April 2023.

69. Deferred Tax Assets are recognized to the extent there is reasonable certainty that sufficient future taxable income be available to realize those assets at each Balance Sheet Date. The Carrying amount of Deferred Tax Assets is reviewed to reassess realization.

70. Since the date of last Balance Sheet there have been no material change affecting the accounts as on 31st March, 2024.

71. Company has complied with all rule, regulation and laws applicable to company including all Labour and tax laws (Both State and Central) and all liabilities under such applicable laws have been fully paid/provided for in the accounts of the company for the year ended 31.03.2024.

72. There have been no event subsequent year end which require adjustment or disclosure in the financial statement or notes thereto except those disclosed in the notes to the financial statement.

73. Company has complied with all condition and requirement of SEBI (Listing and Obligation and Disclosure Requirement, 2015) regarding Corporate Governance.

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Mar 31, 2015

Background

Beryl Drugs Limited (The Company) is a public Limited Company Domiciled in India and Its Shares are listed On Stock Exchange. The Company is principally Engaged in Manufacturing of Bulk Drugs.

NOTE NO. 1

BASIS OF PREPARATION

The financial statements of the company have been prepared in accordance with generally accepted accounting principle in India (India GAAP). The company has prepared these financial statement to comply with all material respect with the accounting standard notified under section 133 of the companies act 2013,Read with rule 7 of Companies (Accounts) Rules,2014. The Financial Statement has been prepared under the Historical cost convention on the Accrual Basis Except in case of the Asset which has been recorded on fair value and Assets for Which Provision for Impairment is Made. The accounting policy have been consistently applied by the company and are consistent with those used in the Previous Year.

NOTE NO. 2

SUMMARY OF SIGNIFICANT ACCOUNTING POLICY

NOTE 3

Loan of HDFC car loan with Interest payable @ 10.25 % p.a repayable in 36 equal installment over a Period of 3 years commencing from 05/06/2014.

NOTE 4

Defined Benefit Plan - The employees' gratuity fund scheme is a defined benefit plan. The present value of obligation is determined based on acturial valuation using the Project Unit Credit Method, which recognises each period of service as giving rise to additional unit of employee benefit entitlement and measures each unit separately to build up the final obligation.

National Bank is Secured Against Hypothecation Of Stock Of Raw Material, Packaging Material, Finished Goods Consumable Stores and Spares, Bills, receivables and and spares, bills, book debts & all other movable both present & future) ( The Cash Credit Is Repayable On Demand) And Interest Rate Is 14.25% p.a.)

NOTE 5

Provision for Wealth Tax of Rs.112368.90/-(PY 114284.40) has been made during the year, however the company has not paid the wealth tax of financial year 2012-13 and 2013-14.

NOTE 6

Liabilities of Entry tax, service tax and excise have been provided as per Return filed. However additional liability if any arising on assessment shall be provided for on completion of assessment.

NOTE 7

Defined Benefit Plan: Refer to note 7.1 NOTE - 11.3

Excise Duty is made on the closing Stock of finished goods as per the Guidance Notes on Accounting for Excise Duty.

NOTE 8

Company has not availed the Cenvat benefit on capital goods purchased during the year.

Expenses relating to construction of building capitalised during the year and included in capital work in progress.

NOTE 9

Pursuant to the enactment of companies act 2013,the company has applied the estimated useful lives as specified in schedule II. Accordingly the unamortised carrying value is being depriciated/amortised over remaining useful lives. The written down value of Fixed Assets whose lives have expired as at 1st april 2014 Have been adjusted From the opening balance of Profit & Loss Account amounting to Rs.93750.42/-

NOTE 10

Investment in Equity Shares is stated at cost. Company has made the investment in Beryl Securities Ltd., a Company under the same management.

NOTE 11

The Company has measured the deferred tax in accordance with AS-22 issued by the ICAI and amount recognized in profit & loss account.

NOTE 12

The company has given advances amounting to Rs.7931216/- (P.Y. Rs. 9719535/-) including interest free loan of Rs.21,31,216/- out of their spare funds to firm, companies and parties without obtaining registration under section 45I of the RBI Act, however same is not applied for because advances of said fund is 12.21.% (Approx.) of the total funds (Share capital and Reserve and Surplus) of the company.

NOTE 13

Loans & Advances includes Rs.643222.00 (P.Y. Rs. 668222.00) over due from other parties on account of advance against capital assets. Further no provision for sticky advances has been made due to management in hope that the advances will be settled through full recovery thereof, in due course.

NOTE 14

Due from customer Rs. 36414.00 (PY Rs. 36414.00) considered doubtful but no provision for doubtful debt has been made in pursuance of follow up with said customer(s).

NOTE 15

In the opinion of the Board of Directors the current assets are expected to be realized in, within 12 months from the reporting date or in the company's normal operating cycle and have value on realization in the ordinary courses of business at least equal to the amount at which they are stated in the Balance Sheet and provision for all known liabilities is adequate and not in excess of the amount reasonably necessary.

NOTE 16

Sales are Inclusive of Freight and Octroi Claimed In the Sales Invoice but net of Excise Duty and Sales return.

NOTE 17

The above rent received of Rs.48000/- is pertaining to rent received from the Beryl Securities Ltd., a company under the same management

NOTE 18

The Company availed Cenvat benefit on purchase of material and netted from the cost of these goods/ material. Cenvat is adjusted against excise duty to the extent utilized against clearance of the material.

NOTE 19

Particulars of employees who are in receipt of remuneration aggregating to more than Rs.60,00,000.00 per annum or Rs.5,00,000.00 p.m. are not given since there is no such employees.

NOTE 20

Stores and spares, coal and consumable chemical are charged to profit and loss account as and when these are incurred NOTE-28.2 Travelling, Conveyance expenses also included expenditure incurred by the Directors of the Company for the purpose of business of the Company.

21. Previous year's figures have been regrouped and re-casted, re-arranged wherever necessary to make them comparable with those of the current year

22. Under the Micro, Small and Medium Enterprises Development Act, 2006 certain disclosure are required to be made relating to Micro Small and Medium Enterprises (SME). The company is in process of compiling relevant information from its suppliers about their coverage under the said Act. Since the relevant information is not readily available, no disclosure have been made in the accounting, however in view of the management the amount due to the suppliers are paid within the mutually agreed credit period and therefore there will not be any interest that may be payable in accordance with the provision of the Act

23. The Company has filed its return of the income up to Assessment Year 2014-2015 and the Income Tax Assessment of the Company has been completed upto Assessment Year 2013-14.

24. Contingent Liability not provided AS ON AS ON 2014-2015 2013-2014

1. Claim against the Company not Acknowledged as debts.

a. Commercial Tax Authority 82865.00 82865.00

(Against Entry Tax 98-99)

(Against Entry Tax 12-13) 320624.00 Nil

(Against M.P Vat Tax 11-12) Nil 229617.00

(Against M.P Vat Tax 12-13) 1142415.00 Nil

(Against CST 12-13) 12937.00 Nil

b. Central excise department (Against Excise duty ) 8825970.00 8825970.00

c. Central excise department has filed SLP before Hon'ble Supreme Court against appeal allowed by Hon'ble M.P. High Court Bench, Indore in connection of non liability of excise on the company product. Nevertheless, company is in hope of dismissal of appeal of the department hence no provision is made in the account, involving a Total Amount of Rs.8825970/-

d. The Company have not made Provision in Books of Accounts for Demand raised by Various Tax Authorities including Rs.320624 (Entry Tax 2012-13), Rs.1142415(Vat Tax 2012-13),Rs.12937 (CST 2012-13).Thus the Profits are overstated by the Aforementioned Amounts. In respect of above items future cash outflows if any are determinable only on receipt of judgment pending at various forum/ authority.

25. Interest received include Rs. 798531/- from loan given to Malwa real estate development pvt. Ltd., Rs. NIL from Radheshwari Developers Pvt. ltd.

26. The company had a trading division which has been disposed of pursuant to a single plan during the current year, but said trading division does not qualify as a business component Hence the related disclosure as prescribed in AS-24 -"Discontinuing operation" are not provided.

27. The Company is liable to pay Tax collected on source for scrap sale made during the Year, but as per management's contention, they are not liable for TCS as they will receive form 27 C from the Purchaser of scrap.

28. a) The company has bought land in Pithampur under lease agreement, which is in the nature of operating lease. Required disclosure as per AS - 19 "Leases" are as follow:

b) General description of lease term:

Assets are taken on lease for a period of 30 years.

ii) As leaser

The company has given own office to Beryl Securities Limited on monthly rent. The rent agreement for 11 months are cancelable and are generally renewable in mutual consent or mutually agreeable terms. The rental income on such is included in other income.

29. Company has given Inter corporate advances to Malwa real estate development pvt. Ltd. of Rs. 53,00,000/ - and to Radheshwari Developers Pvt. Ltd. of Rs. 10,00,000/- which are outstanding since many years. Moreover out of above advances, Company has not charged any interest from Radheshwari Developers Pvt. Ltd.

30. The company has received state capital subsidy with reference to the total investment in an undertaking, thus the government grants are in the nature of Promoters' contribution as Per AS - 12- "GOVERNMENT GRANTS" and hence credited to Capital Subsidy Account.

31. Working capital facilities are secured by hypothecation of stock of raw material, packing material and finished goods, stores and spares not relating to plant and machinery (consumable stores & spares) bills, receivables and book debts and all other movable both present and future. These are further secured by personal guarantee of the Managing Director and Whole Time Director of the Company.

32. Company has credited a sum of Rs. 35830.00/-.( P.Y Rs 22630.00 /)- under the head "Receipt from Government Authority pending for reconciliation" which is received against sale to government authorities (given under the head- Advance Received from Customer) but the same amount is still pending from earlier year for allocation & reconciliation for want of their information.

33. Disclosure in accordance with the Accounting Standard- (AS-18) "Related Party Disclosure" issued by the Institute of Chartered Accountants of India and notified under the Companies Accounting Standards Rules, 2006 the name of the related parties and the relevant disclosure is as under:

a) Name of the related party and description of relationship.

i) Key Management personnel

1) Mr. Sanjay Sethi , Managing Director

2) Mr. Ashish Baraskar , CFO

3) Mrs. Neha Sharma , CS

ii) Companies / Entities under the control of key management personnel 1) M/s Beryl Securities Ltd.

iii) Relative of director

1) Sangita Sethi

2) Soniya Sethi

The following transactions were carried out with the related parties in the ordinary course of business.

34. The Company has not given any advance (s) in the nature of loan to any party as defined in clause 32 of the listing agreement. As per the company policy interest free loan given to employees are not considered under this clause. Loan and Advance in the nature of loans to associates/employees disclosure pursuant to Clause 32 of the listing agreement is as under :

35. Balance of all Debtors/ Creditors/ lenders and borrowers are subject to confirmation.

36. The company has appointed women director with effect from 1/10/2014 as Per Section 149(1) of the Companies Act 2013.

37. Provision for current Income tax has been made in accordance with the provision of Income tax act and has been shown net off payment of advance tax Rs. 3.75 Lacs and TDS Rs. 176820/- made during the year.

38. In the opinion of management all current asset, loans and advances have value of realization atleast equal to the extent considered good and stated in the balance sheet.

39. Sitting fees has been waived by all the director's of the company.

40. Prior period items includes Rs.350803 on account of coal purchase as prior period expense .

41. Company has made the investment amounting to Rs.67.84 lacs (P.Y. Rs.67.84 lacs) in Beryl Securities Ltd., a Company under the same management.

42. The Books of Account is showing CST Payable Amounting to Rs. 217283.94/- because Government sale of Second and Third Quarter has not been posted in return & the company is also facing problem in revising the same.

43. Company has discontinued the trading division in during the year whose shareholder approval is awaited.

44. Pursuant to companies act 2013 (the Act) becoming effective from 1st April 2014, The company has reworked depreciation with reference to the estimated useful life's of fixed Assets prescribed under schedule II to the Act. As a result the charge for depreciation is higher by Rs. 1966394.20/- for the year ended 31st march 2015.pursuant to the transitional provision prescribed in schedule II to the companies act 2013, The company has fully depreciated the carrying value of assets net of residual value where the remaining useful life of the assets was determined to be NIL as on 1st April 2014 and has adjusted an amount of Rs. 93750.42/- against the opening surplus balance in the Statement of Profit & Loss under Reserve & Surplus.

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Mar 31, 2014

NOTE 1.1 During the year Company has issued Forfeiture notice in respect of call money in arrear and has only received Rs. 342750/- as against the call money. But company could not receive the remaining unpaid call money of 59300 no. of equity shares even given final reminder. Thus after passing board resolution dated 25th Jan 2014 Company has forfeited 59300 no. of Equity Shares (against which amount paid up was Rs. 219750/-) during the year due to non payment of their arrears.

NOTE - 2.1

Defined Benefit Plan The employees'' gratuity fund scheme is a defined benefit plan. The present value of obligation is determined based on acturial valuation using the Project Unit Credit Method, which recognises each period of service as giving rise to additional unit of employee benefit entitlement and measures each unit separately to build up the final obligation.

NOTE -3.1

Short term loan from Punjab National Bank is Secured Against Hypothecation Of Stock Of Raw Material, Packaging Material, Finished Goods Consumable Stores and Spares, Bills, receivables andand spares, bills, book debts & all other movable both present & future) ( The Cash Credit Is Repayable On Demand And Interest Rate Is 14.25% p.a.)

NOTE:3.2

The loan of Beryl Securities Ltd., represents loan due to the Company under same Management.

NOTE -4.

Provision for Wealth Tax of Rs.114284 .4/-(PY 164206.00) has been made during the year, however the company has not paid the wealth tax of last financial year 2012-13.

NOTE -4.2

Liabilities of Entry tax, service tax and excise have been provided as per Return filed. However additional liability if any arising on assessment shall be provided for on completion of assessment.

NOTE: 4.3

Defined Benefit Plan: Refer to note 4.

NOTE: 4.4

The above provision for Excise Duty is made on the closing Stock of finished goods as per the Guidance on Accounting for Excise Duty.

NOTE 5.1

Company has not availed the Cenvat benefit on capital goods purchased during the year.

Expenses relating to construction of building capitalised during the year and included in capital work in progress.

NOTE - 6.1

Company Investment in Equity Shares is stated at cost. Company has made the investment in Beryl Securities Ltd., a Company under the same management.

NOTE - 7.1

The Company has measured the deferred tax in accordance with AS-22 issued by the ICAI and amount recognized in profit & loss account.

NOTE -8.1

The company has given advances amounting to Rs.9719535/- (P.Y. Rs. 10253054/-) including interest free loan of Rs.21,07,794/- out of their spare funds to firm, companies and parties without obtaining registration under section 45I of the RBI Act, however same is not applied for because advances of said fund is 15.10% (Approx.) of the total funds (Share capital and Reserve and Surplus) of the company.

NOTE -8.2

Loans & Advances includes Rs.668222.00 (P.Y. Rs. 1605911.00) over due from other parties on account of advance against capital assets. Further no provision for sticky advances has been made due to management in hope that the advances will be settled through full recovery thereof, in due course.

NOTE -9.1

Due from customer Rs. 36414.00 (PY Rs. 848327.00) considered doubtful but no provision for doubtful debt has been made in persuance of follow up with said customer(s).

NOTE -10.1

In the opinion of the Board of Directors the current assets are expected to be realized in, within 12 months from the reporting date or in the company''s normal operating cycle and have value on realization in the ordinary courses of business at least equal to the amount at which they are stated in the Balance Sheet and provision for all known liabilities is adequate and not in excess of the amount reasonably necessary.

NOTE -10.2

Company is running a trading unit for sales of Ranbaxy product and separate Books of account has been maintained but profit/loss of said unit has been transferred as result from operation and investment of said unit has been shown as current investment of the year without incorporating other transaction in the company''s books of accounts

NOTE -11.1

The above rent received of Rs. 48000/- is pertaning to rent received from the Beryl Securities Ltd., a company under the same management.

NOTE -11.1

The Company availed Cenvat benefit on purchase of material and netted from the cost of these goods/ material. Cenvat is adjusted against excise duty to the extent utilized against clearance of the material.

NOTE -12.1

Particulars of employees who are in receipt of remuneration aggregating to more than Rs.60,00,000.00 per annum or Rs.5,00,000.00 p.m. are not given since there is no such employees.

NOTE -13.1

Travelling, Conveyance expenses also included expenditure incurred by the Directors of the Company for the purpose of business of the Company.

14. Previous year''s figures have been regrouped and re-casted, re-arranged wherever necessary to make them comparable with those of the current year

15. Under the Micro, Small and Medium Enterprises Development Act, 2006 certain disclosure are required to be made relating to Micro Small and Medium Enterprises (SME). The company is in process of compiling relevant information from its suppliers about their coverage under the said Act. Since the relevant information is not readily available, no disclosure have been made in the accounting, however in view of the management the amount due to the suppliers are paid within the mutually agreed credit period and therefore there will not be any interest that may be payable in accordance with the provision of the Act

16. The Company has filed its return of the income up to Assessment Year 2013-2014 and the Income Tax Assessment of the Company has been completed upto Assessment Year 2012-13.

17. The Company has not appointed Whole Time Company Secretary as per requirement of Sec. 383A of the Companies Act, 1956 during the current year. However company has appointed a whole time company secretary w.e.f. 01.05.2014.

18. Contingent Liability not provided AS ON AS ON

2013-2014 2012-2013

1. Claim against the Company not acknowledged as debts.

a. Commercial Tax Authority 82865.00 82865.00

(against Entry Tax)

b. Listing fees of Indore & Ahmadabad Stock Exchange (if any) will be liable, even approved for delisting with these stock exchanges by the members. By virtue of this future profitability to that extend may affect.

c. Company has filed an Appeal to Deputy Commissioner of VAT for the demand of Rs.229617/- raised against VAT of the F.Y-2011-2012 by the department.

d. Central excise department has filed SLP before Hon''ble Supreme Court against appeal allowed by Hon''ble M.P. High Court Bench, Indore in connection of non liability of excise on the company product. But company is in hope of dismissal of appeal of the department hence no provision has been made in the account.

19. The company has not given any loan or advance in the nature of loan to its subsidiaries associates or firms/ company in which directors are interested. However, there are no loan or advances in the nature of loan where is

a) No repayment schedule or repayment schedule beyond seven years or

b) No interest or interest (except in case as reported in note no. 12.1 & 34) is below the rate specified in Section 372A of the Companies Act, 1956.

20. Interest received include Rs. 954730/- from loan given to Malwa real estate development pvt. Ltd., Rs. NIL from Radheshwari Developers Pvt. ltd. And Rs. 17490/- from Dabang Dunia Publication Pvt. Ltd.

21. Company has given Inter corporate advances to Malwa real estate development pvt. Ltd. of Rs. 53,00,000/- and to Radheshwari Developers Pvt. Ltd. of Rs. 10,00,000/- which are pertaing to earlier years and a fresh loan of Rs 415741/- to Dabang Duniya Publications (P) ltd. during the current year. Moreover out of above advances, Company has not charged any interest from Radheshwari Developers Pvt. Ltd. and also given fresh loan to Dabang Duniya Publications (P) ltd. @ 13.11% which is less than prevailing interest rates of bank (company is availing credit facilities from bank @ 14.25%) during the year thus company has contravened the provisions of Sec. 372A of Companies Act,1956.

22. Working capital facilities are secured by hypothecation of stock of raw material, packing material and finished goods, stores and spares not relating to plant and machinery (consumable stores & spares) bills, receivables and book debts and all other movable both present and future. These are further secured by personal guarantee of the Managing Director and Whole Time Director of the Company.

23. Company has credited a sum of Rs. 22630/-.( P.Y Rs 106606/)- under the head "Receipt from Government Authority pending for reconciliation" which is received against sale to government authorities (given under the head- Advance Received from Customer) but the same amount is pending since earlier years for allocation & reconciliation for want of their information.

24. Credit balance of HDFC Bank represents cheques issued by the company but not presented to the bank by the parties.

25. Disclosure in accordance with the Accounting Standard- (AS-18) "Related Party Disclosure" issued by the Institute of Chartered Accountants of India and notified under the Companies Accounting Standards Rules, 2006 the name of the related parties and the relevant disclosure is as under:

a) Name of the related party and description of relationship.

i) Key Management personnel

1) Mr. Sanjay Sethi, Managing Director

2) Mr. Sudhir Sethi, Whole time Director

ii) Companies / Entities under the control of key management personnel 1) M/s Beryl Securities Ltd.

iii) Relative of director

1) Sangita Sethi

2) Soniya Sethi

26. Insurance claim is subject to confirmation with relevant document of insurance company who sanctioned the said claim.

27. The company has given advances aggregating to Rs. 69,96,761/- to the directors and relatives during the current year and the year balance is NIL but such advances required prior approval of Central Government u/s 295 of the act however in the opinion of the company said advances does not required such approval due to advances was given for some business commitments.

28. Balance of all Debtors/ Creditors/ lenders and borrowers are subject to confirmation.

29. Provision for current Income tax has been made in accordance with the provision of Income tax act and has been shown net off payment of advance tax Rs. 4.00 Lacs and TDS Rs. 157653/- made during the year.

30. In the opinion of management all current asset, loans and advances have value of realization atleast equal to the extent considered good and stated in the balance sheet.

31. Sitting fees has been waived by all the director''s of the company.

32. Prior period items includes Rs. 276/- on account of Machinery repairs, Rs.154415/- on account of Freight, Rs. 40419/ on account of loss of goods in transit & Rs. 8989/- on account of VAT audit fees as prior period expenses and Rs. 179737/- on account of Sale as prior period income.

33. Company has made the investment amounting to Rs.67.84 lacs (P.Y. Rs.67.84 lacs) in Beryl Securities Ltd., a Company under the same management.

34. There is no impairment of assets accordingly no adjustment in respect of loss or impairment of assets is required to be made in the accounts

---

Mar 31, 2013

1. Previous year''s figures have been regrouped and re-casted, re-arranged wherever necessary to make them comparable with those of the current year.

2. Company has not made the provision as per AS-13 for Rs.712320/- an account of diminution in value of share of Beryl Securities Ltd, a company in which director are director due to in temporary nature. However, to that extent profit and investment for the year has been over stated.

3. Company has credited a sum of Rs. 106606/- under the head "Receipt from Government Authority pending for reconciliation" which is received against sale to government authorities (given under the head Sundry creditor) but the same amount has not been reconciled from respective ledger accounts of said authorities.

Therefore such amount is subject to confirmation & reconciliation from govt. authorities.

4. The company has given advances amounting to Rs. 10253054/- (P.Y. Rs. 4800103/- ) out of their spare funds to firm, companies and parties without obtaining registration under section 45I of the RBI Act, due to non liable because advances of said fund is 16.10%(Approx.) of the total funds (Share capital and Reserve and Surplus) of the company further company has been given loans & advances of Rs. 3657775/- on interest free loan in during the year.

5. Under the Micro, Small and Medium Enterprises Development Act, 2006 certain disclosure are required to be made relating to Micro Small and Medium Enterprises (SME). The company is in process of compiling relevant information from its suppliers about their coverage under the said Act. Since the relevant information is not ready available, no disclosure have been made in the accounting, however in view of the management the amount due to the suppliers are paid within the mutually agreed credit period and therefore there will not be any interest that may be payable in accordance with the provision of the Act.

6. The Company has filed its return of the income up to Assessment Year 2012-2013 and the Income Tax Assessment of the Company has been completed upto Assessment Year 2011-12.

7. Travelling, Conveyance and Sales Promotion Expenses also included expenditure incurred by the Directors of the Company for the purpose of business of the Company.

8. Loans & Advances including Rs.1605911.00 (P.Y. Rs. 17, 79, 838.00) over due from other parties on account of advance against capital assets. And no provision for doubtful advances has been made due to parties are discharging their contractual obligations and is hopeful of acquiring the goods or its settlement through full recovery thereof, in due course.

9. Loans & Advances given to Nishit Construction of Rs. 75000/- as capital advance but same has been written off in during the year due to non recoverable in opinion of management.

10. The Company has not availed any Cenvat benefit on capital goods purchased during the year.

11. All balances of sundry debtors, sundry creditors and loans and advances are subject to analysis and confirmation by the parties.

12. In the opinion of the Board of Directors the current assets are expected to be realized in, or is intended for sale or consumption within 12 months from the reporting date or in the company''s normal operating cycle and have value on realization in the ordinary courses of business at least equal to the amount at which they are stated in the Balance Sheet and provision for all known liabilities is adequate and not in excess of the amount reasonably necessary.

13. The Company availed Cenvat benefit on purchase of material and netted from the cost of these goods/ material. Cenvat is adjusted against excise duty to the extent utilized against clearance of the material.

14. The Company has not appointed Whole Time Company Secretary as per requirement of Sec. 383A of the Companies Act, 1956 till date. However company is in process to appoint Full Time Company Secretary and have taken suitable effects for the same.

15. Other income includes Rs.48, 000.00 (P.Y. Rs.48, 000.00) as rent received from Beryl Securities Ltd., a Company under the same Management.

16. The company has not given any loan or advance in the nature of loan to its subsidiaries associates or firms/ company in which directors are interested. However, there are no loan or advances in the nature of loan where is

a) No repayment schedule or repayment schedule beyond seven years or

b) No interest or interest (except in case as reported in note no. 30) is below the rate specified in Section 372A of the Companies Act, 1956.

17. Working capital facilities are secured by hypothecation of stock of raw material, packing material and finished goods, stores and spares not relating to plant and machinery (consumable stores & spares) bills, receivables and book debts and all other movable both present and future. These are further secured by personal guarantee of the Managing Director and Whole Time Director of the Company.

18. Particulars of employees who are in receipt of remuneration aggregating to more than Rs.60,00,000.00 per annum or Rs.5,00,000.00 p.m. are not given since there is no such employees.

19. Sitting fee payable to Directors has been waived by each one of them.

20. Provision for Wealth Tax of Rs. 164206/- (P.Y. Rs. Nil) has been made during the year.

21. The disclosure required as per AS-15 "Employee Benefit" issued by the Institute of Chartered Accountants of India (ICAI) and notified under the Companies Accounting Standards Rules, 2006 based management report as under.

22. The disclosure required as per AS-15 "Employee Benefit" issued by the Institute of Chartered Accountants of India (ICAI) and notified under the Companies Accounting Standards Rules, 2006 based management report as under.

i) Employee defined Benefit Plan as per Actuarial Valuation on 31/03/2013 as under:

23. Identification of Segments:

(a) Identification of Segments:

Primary Segment

Business Segment: The Company''s operating business are organized and managed separately according to the nature of products, with each segment representing a strategic business unit that offers different products. The identified segments are Trading Division and Manufacturing Division.

Secondary Segment. The company caters only to the need of Indian Market representing a singular economic environment with similar risk & reward, hence there are no reportable geographical segments.

24. Disclosure in accordance with the Accounting Standard- (AS-18) "Related Party Disclosure" issued by the Institute of Chartered Accountants of India and notified under the Companies Accounting Standards Rules, 2006 the name of the related parties and the relevant disclosure is as under:

a) Name of the related party and description of relationship.

i) Key Management personnel

1) Mr. Sanjay Sethi , Managing Director

2) Mr. Sudhir Sethi , Whole time Director

ii) Companies / Entities under the control of key management personnel 1) M/s Beryl Securities Ltd.

25. In accordance with the Accounting Standard-20 (AS-20) "Earning per Share" (Basic & Diluted) issued by the Institute of Chartered Accountants of India has been computed by dividing the net profit attributable to equity shareholder for the year by the weighted average number of equity shares outstanding during the year. There are no diluted potential equity shares.

26. The Company has not given any advance(s) in the nature of loan to any party as defined in clause 32 of the listing agreement. As per the company policy interest free loan given to employees are not considered under this clause. Loan and Advance in the nature of loans to associates/employees disclosure pursuant to Clause 32 of the listing agreement is as under:

27. Liabilities of Entry tax, service tax and excise have been provided as per Return filed. However additional liability if any arising on assessment shall be provided for on completion of assessment

28. Disclosure in respect of provision pursuant to Accounting Standard 29:

29. Operating lease:

Assets taken on lease, under which the lesser effectively retains all the risks and rewards of ownership, are classified as operating lease operating lease payment are recognized as expenses in the profit and loss accounts on a straight line basis over the lease term.

30. Company has given Inter corporate advances to Malwa real estate development pvt. Ltd. of Rs. 5793471/-, and to Radheshwari Developers Pvt. Ltd. of Rs. 10,00000/- but same advances are subject to obtained Specified Approval as prescribed u/s 372A of the companies Act.1956.

31. Company has run trading unit to sale purchase of Ranbaxy product and separate Books of account has been maintained but profit of said unit, Transfer as Income from operation and investment of said unit has been shown as current investment of the year without transferring other transaction in the companies books.

32. a) Company has written off Rs. 1842672/- trade dues including health department of government of MP without denial of such debtors of the company.

(b) Company has not made any provision for doubtful debt, Rs. 848327/- (P.Y. 2287263/-) due to continue follow up.

---

Mar 31, 2012

NOTE : 1. The above Cash Flow statement has been prepared under the indirect method & set on in accounting slandered 3 Cash Flow statements.

2. Figure in Minus indicates outflows.

3. Cash and cash equivalents at the end of the year include balance with bank.

4. Previous year's figure have been regrouped / rearranged / recanted wherever necessary to made them comparable with those of current year.

"5. Above Cash Flow has been prepared after consolidating to the operation figures of Trading division, thus Cash " & Cash equivalent is also included Cash & Cash equivalent of Rs. 0.23 of Trading Division."

1. The revised schedule VI as notified under The Companies Act, 1956 has been applicable to the company for the presentation of financial statement for the year ended 31st March, 2012. The adoption of the revised schedule VI requirement has significantly modified the presentation and disclosure which have been complied with the financial statement. Previous year's figures have been regrouped and re-casted, re- arranged wherever necessary to make them comparable with those of the current year..

2. Company has not made the provision as per AS-13 for Rs.18, 38, 464/- an account of diminution in value of share of Beryl Securities Ltd, a company in which director are director due to in temporary nature. However, to that extent profit and investment for the year has been over stated.

3. Company has credited a sum of Rs. 1161358/- under the head "Receipt from Government Authority pending for reconciliation" which is received against sale to government authorities (given under the head Sundry Debtors) but the same amount has not been reconciled from respective ledger accounts of said authorities. Therefore such amount is subject to confirmation & reconciliation from govt. authorities

4. The company has advances amounting to Rs. 4800103/- (P.Y. Rs. 4865912/- ) out of their spare funds to firm, companies and parties without obtaining registration under section 45I of the RBI Act, due to non liable because advances of said fund is 5.64%(Approx.) of the total funds of the company.

5. Under the Micro, Small and Medium Enterprises Development Act, 2006 certain disclosure are required to be made relating to Micro Small and Medium Enterprises (SME). The company is in process of compiling relevant information from its suppliers about their coverage under the said Act. Since the relevant information is not ready available, no disclosure have been made in the accounting, however in view of the management the amount due to the suppliers are paid within the mutually agreed credit period and therefore there will not be any interest that may be payable in accordance with the provision of the Act.

6. The Company has filed its return of the income up to Assessment Year 2011-2012 and the Income Tax Assessment of the Company has been completed up to Assessment Year 2010-11.

7. Travelling, Conveyance and Sales Promotion Expenses also included expenditure incurred by the Directors of the Company for the purpose of business of the Company.

8. Loans & Advances including Rs.17, 79, 838.00 (P.Y. Rs. 15, 78, 381.00) over due from other parties on account of advance against capital assets. Hence it is required to be strictly reviewed by the Management. However the Management is confident that the parties are discharging their contractual obligations and is hopeful of acquiring the goods or its settlement through full recovery thereof, in due course.

9. The Company has not availed any Canvas benefit on capital goods purchased during the year.

10. All balances of debtors, creditors and advances are subject to analysis and confirmation by the parties. Because letter of confirmation of balance to parties have not been issued. The Management does not expect any material difference (except stated otherwise) affecting the current year financial statement..

11. In the opinion of the Board of Directors the current assets are expected to be realized in, or is intended for sale or consumption within 12 months from the reporting date or in the company's normal operating cycle and have value on realization in the ordinary courses of business at least equal to the amount at which they are stated in the Balance Sheet and provision for all known liabilities is adequate and not in excess of the amount reasonably necessary.

12. The Company availed Cenvat benefit on purchase of material and netted from the cost of these goods/ material. Cenvat is adjusted against excise duty to the extent utilized against clearance of the material.

13. The Company has not appointed Whole Time Company Secretary as per requirement of Sec. 383A of the Companies Act, 1956 till date. However company is in process to appoint Full Time Company Secretary and have taken suitable effects for the same.

14. Other income includes Rs.48, 000.00 (P.Y. Rs.48, 000.00) as rent received from Beryl Securities Ltd., a Company under the same Management.

15. Power & Fuel Expenses also include Coal of Rs. 54, 64, 173.00 (P.Y Rs 46, 56, 442.36) purchase during the year and same has been debited on procurement basis.

16. Contingent Liability not provided

2011-2012 2010-2011

1. Claim against the Company not acknowledged as debts.

a. Commercial Tax Authority 82865.00 82865.00 (against Entry Tax)

b. Central Excise Authority-

(1) Tax 327190.00 327190.00

(2) Penalty 327190.00 327190.00

c. Show Cause notice issued by the 8825970.00 8825970.00 central excise department against

Liability of excise duty of IV fluid.

But same is pending for order (A/c year 2001-02 to 2007-08)

d. Listing fees of Indore & Ahmadabad Stock Exchange (if any) will be liable, even approved for delisting with these stock exchanges by the members. By virtue of this future profitability to that extend may affect.

17. The company has not given any loan or advance in the nature of loan to its subsidiaries associates or firms/ company in which directors are interested. However, there are no loan or advances in the nature of loan where is

a) No repayment schedule or repayment schedule beyond seven years or

b) No interest or interest is below the rate specified in Section 372A of the Companies Act, 1956.

18. Working capital facilities are secured by hypothecation of stock of raw material, packing material and finished goods, stores and spares not relating to plant and machinery (consumable stores & spares) bills, receivables and book debts and all other movable both present and future. These are further secured by personal guarantee of the Managing Director and Whole Time Director of the Company.

19. Particulars of employees who are in receipt of remuneration aggregating to more than Rs. 60,00,000.00 per annum or Rs.5,00,000.00 p.m. are not given since there is no such employees.

20. Sitting fee payable to Directors has been waived by each one of them.

21. Provision for Wealth Tax has not been made because no liability comes on the Company as per the expert opinion obtained by the Management.

22. The disclosure required as per AS-15 "Employee Benefit" issued by the Institute of Chartered Accountants of India (ICAI) and notified under the Companies Accounting Standards Rules, 2006 based management report as under.

23. Identification of Segments:

(a) Identification of Segments:

Primary Segment

Business Segment: The Company's operating business are organized and managed separately according to the nature of products, with each segment representing a strategic business unit that offers different products. The identified segments are Trading Division and Manufacturing Division.

Secondary Segment

The company caters only to the need of Indian Market representing a singular economic environment with similar risk & reward, hence there are no reportable geographical segments.

24. Disclosure in accordance with the Accounting Standard- (AS-18) "Related Party Disclosure" issued by the Institute of Chartered Accountants of India and notified under the Companies Accounting Standards Rules, 2006 the name of the related parties and the relevant disclosure is as under:

a) Name of the related party and description of relationship.

i) Key Management personnel

1) Mr. Sanjay Sethi , Managing Director

2) Mr. Sudhir Sethi , Whole time Director

ii) Companies / Entities under the control of key management personnel

1) M/s Beryl Securities Ltd.

Particulars given above have been identified on the basis of information available with the Company.

25. In accordance with the Accounting Standard-20 (AS-20) "Earning per Share" (Basic & Diluted) issued by the Institute of Chartered Accountants of India has been computed by dividing the net profit attributable to equity shareholder for the year by the weighted average number of equity shares outstanding during the year. There are no diluted potential equity shares.

26. Liabilities of Entry tax, service tax and excise have been provided as per Return filed. However additional liability if any arising on assessment shall be provided for on completion of assessment

27. Operating lease:

Assets taken on lease, under which the lesser effectively retains all the risks and rewards of ownership, are classified as operating lease operating lease payment are recognized as expenses in the profit and loss accounts on a straight line basis over the lease term

---

Mar 31, 2010

1. Company has identified the doubtful debtors Rs.24,05,549.72 (P.Y Rs.Nil) in during the year, but no provision for Rs.24,05,549.72 has been made for said doubtful debts. Thus the Profit & Debtors of the company for the year has been over stated by said amount.

2. Company has not made the provision as per AS-13 for Rs.61,05,600/- due to permanent diminution in value of share of Beryl Securities Ltd, a company in which director are director thus to that extent profit and investment for the year has been over stated.

3. Since quotations of shares of Beryl Securities Ltd, are not available on the last day of the year hence market value of investments in said companys shares has been taken on the basis of latest available quotation.

4. As on 31st March 2010, No supplier has intimated the company about its status as Micro or Small Enterprises or its registration with the appropriate authority under the Micro, Small and Medium enterprises development act 2006. However the total outstanding dues to Micro, Small and Medium enterprises separately given in note no 22 of notes to accounts.

5. The Company has filed its return of the income upto Assessment Year 2009-2010 and the Income Tax Assessment of the Company have been completed upto Assessment Year 2008-2009.

6. Travelling, Conveyance and Sales Promotion Expenses also included expenditure incurred by the Directors of the Company for the purpose of business of the Company.

7. Contingent Liability not provided

2009- 2010 2008-2009



1. Bank Guarantee in favour of 829000.00 1787000.00 Authorities/third parties

2. Bill discounted Nil Nil

3. Claim against the Company not acknowledged as debts.

a. Commercial Tax Authority 82865.00 82865.00 (against Entry Tax)

b. Central Excise Authority- (1) Tax 327190.00 327190.00

(2) Penalty 327190.0 327190.00

c. Show Cause notice issued by 8825970.00 8473559.00 The central excise department against Liability of excise duty or IV fluid. But same is pending For order (A/c year 2001-02 to 2007-08)

d. Listing fees of Indore & Ahmedabad Stock Exchange (if any) will be liable, even approved for delisting with these stock exchange by the members. By virtue of this future profitability to that extend may affect.

8. The company has not given any loan or advance (except advance Rs. 2095698.00 to Director for expenses & other) in the nature of loan to its subsidiaries associates or firms/company in which directors are interested. However, there are no loan or advances in the nature of loan where is

a) No repayment schedule or repayment schedule beyond seven years or

b) No interest or interest is below the rate specified in Section 372A of the Companies Act, 1956.

9. Working capital facilities are secured by hypothecation of stock of raw material, packing material and finished goods, stores and spares not relating to plant and machinery (consumable stores & spares) bills, receivables and book debts and all other movable both present and future. These are further secured by personally guaranteed by the Managing Director and Whole Time Director of the Company.

b) The company has been advised that, the computation of Net Profit for the purpose of Managerial Remuneration under section 349 of the Companies Act, 1956 need not to be enumerated since no commissionby way of percentage of profit is payable for the year to any of the director.

10. Sitting fee payable to Directors have been waived by each one of them.

11. Loans & Advances including Rs.4832248.00 (P.Y. Rs.5628423.00) over due from other parties on account of advance against capital assets. Hence it is required to be strictly reviewed by the Management. However the Management is confident that the parties are discharging their contractual obligations and is hopeful of acquiring the goods or its settlement through full recovery thereof, in due course.

12 The Company has not availed any Cenvat benefit on capital goods purchased during the year.

13 All balances of debtors, creditors and advances are subject to analysis and confirmation by the parties. Because letter of confirmation of balance to parties have not been issued. The Management does not expect any material difference (except stated otherwise) affecting the current year financial statement.

14 Corresponding figures of the previous year have been regrouped re-casted and re-arranged to make them comparable with current years figures wherever necessary.

15 In the opinion of the Board of Directors the current assets, loans and advances including deposits have value on realization in the ordinary courses of business at least equal to the amount at which they are stated in the Balance Sheet and provision for all known liabilities is adequate and not in excess of the amount reasonably necessary.

16 The Company availed Cenvat benefit on purchase of material and netted from the cost of these goods/ material. Cenvat is adjusted against excise duty to the extent utilized against clearance of the material.

17 All bank balances are subject to reconciliation with bank.

18 The Company has not appointed Whole Time Company Secretary as per requirement of Sec. 383A of the Companies Act, 1956 till date. However company is in process to appoint Full Time Company Secretary and have take suitable effects for the same.

19 Other income includes Rs.48,000.00 (P.Y. Rs.48,000.00) as rent received from Beryl Securities Ltd., a Company under the same Management.

20 Provision for Wealth Tax has not been made because no liability comes on the Company as per the expert opinion obtained by the Management.

21 Additional information as far as applicable pursuant to the provisions of Paragraph 3, 4C, 4D of part II of the Schedule VI of the Companies Act, 1956 has been furnished as per Annexure - I.

22 Balance Sheet abstract and the companys general business profit in pursuant to Part IV of Schedule VI to the Companies Act, 1956 has been furnished as per Annexure - II.