Auditor Report of Citurgia Biochemicals Ltd.

Mar 31, 2024

We have audited the financial statements of M/s CITURGIA BIOCHEMICALS LIMITED ("the Company"),
which comprise the balance sheet as at 31st March 2024, and the statement of Profit and Loss and statement
of cash flows for the year then ended, and notes to the financial statements, including a summary of
significant accounting policies and other explanatory information.

In our opinion and to the best of our information and according to the explanations given to us, the aforesaid
Standalone financial statements give the information required by the Companies Act, 2013 ("the Act") in the
manner so required and give a true and fair view in conformity with the Indian Accounting Standards
prescribed under section 133 of the Act read with the Companies (Indian Accounting Standards) Rules, 2015,
as amended, ("Ind AS") and other accounting principles generally accepted in India, of the state of affairs of
the Company as at March 31, 2024, its profit/loss and its cash flows for the year ended on that date,

a) In the case of the balance sheet, of the state of affairs of the company as at March 31, 2024

b) In the case of the Profit and Loss Account, of the profit for the period ended on that date and

c) In the case of cash flow statement, for the cash flows for the year ended on that date

d) And the changes in equity for the year ended on that date

Basis for Opinion

We conducted our audit of Standalone Financial Statement in accordance with the Standards on Auditing
specified under section 143(10) of the Companies Act, 2013. Our responsibilities under those Standards are
further described in the Auditor''s Responsibilities for the Audit of the Financial Statements section of our
report. We are independent of the Company in accordance with the Code of

Ethics issued by the Institute of Chartered Accountants of India together with the ethical requirements that
are relevant to our audit of the financial statements under the provisions of the Companies Act, 2013 and the
Rules thereunder, and we have fulfilled our other ethical responsibilities in accordance with these
requirements and the Code of Ethics. We believe that the audit evidence we have obtained is sufficient and
appropriate to provide a basis for our opinion.

Key Audit Matters

Key audit matters are those matters that, in our professional judgment, were of most significance in our audit
of the standalone financial statements of the current period. These matters were addressed in the context of
our audit of the standalone financial statements as a whole, and in forming our opinion thereon, and we do
not provide a separate opinion on these matters. We have determined the matters described below to be the
key audit matters to be communicated in our report.

S. No.	Key Audit Matter	Auditor''s Response
1.	Nil	Nil

Information other than the financial statements and auditors'' report thereon

The Company''s board of directors is responsible for the preparation of the other information. The other
information comprises the information included in the Board''s Report including Annexures to Board''s Report
but does not include the financial statements and our auditor''s report thereon.

Our opinion on the financial statements does not cover the other information and we do not express any form
of assurance conclusion thereon.

In connection with our audit of the financial statements, our responsibility is to read the other information
and, in doing so, consider whether the other information is materially inconsistent with the financial
statements or our knowledge obtained during the course of our audit or otherwise appears to be materially
misstated.

If, based on the work we have performed, we conclude that there is a material misstatement of this other
information, we are required to report that fact. We have nothing to report in this regard.

Responsibilities of Management and Those Charged with Governance for the Financial Statements

The Company''s Board of Directors is responsible for the matters stated in section 134(5) of the Companies
Act, 2013 ("the Act") with respect to the preparation of these financial statements that give a true and fair
view of the financial position, financial performance and cash flows of the Company in accordance with the
accounting principles generally accepted in India, including the Accounting Standards (AS) specified under
section 133 of the Act. This responsibility also includes maintenance of adequate accounting records in
accordance with the provisions of the Act for safeguarding of the assets of the Company and for preventing
and detecting frauds and other irregularities; selection and application of appropriate accounting policies;
making judgments and estimates that are reasonable and prudent; and design, implementation and
maintenance of adequate internal financial controls, that were operating effectively for ensuring the accuracy
and completeness of the accounting records, relevant to the preparation and presentation of the financial
statements that give a true and fair view and are free from material misstatement, whether due to fraud or
error.

In preparing the financial statements, management is responsible for assessing the Company''s ability to
continue as a going concern, disclosing, as applicable, matters related to going concern and using the going
concern basis of accounting unless management either intends to liquidate the Company or to cease
operations, or has no realistic alternative but to do so.

Those Board of Directors are also responsible for overseeing the Company''s financial reporting process.
Auditor''s Responsibilities for the Audit of the Financial Statements

Our objectives are to obtain reasonable assurance about whether the 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 SAs will always detect a material misstatement when it exists. Misstatements can arise from
fraud or error and are considered material if, individually or in the aggregate, they could reasonably be
expected to influence the economic decisions of users taken on the basis of these financial statements.

As part of an audit in accordance with SAs, we exercise professional judgment and maintain professional
skepticism throughout the audit. We also:

• Identify and assess the risks of material misstatement of the 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 Companies Act, 2013, we are
also responsible for expressing our opinion on whether the company has adequate internal financial
controls system in place and the operating effectiveness of such controls.

• Evaluate the appropriateness of accounting policies used and the reasonableness of accounting
estimates and related disclosures made by management.

• Conclude on the appropriateness of management''s use of the going concern basis of accounting and,
based on the audit evidence obtained, whether a material uncertainty exists related to events or
conditions that may cast significant doubt on the Company''s ability to continue as a going concern. If
we conclude that a material uncertainty exists, we are required to draw attention in our 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 financial statements, including the
disclosures, and whether the financial statements represent the underlying transactions and events in
a manner that achieves fair presentation.

Materiality is the magnitude of misstatements in the standalone financial statements that, individually or in
aggregate, makes it probable that the economic decisions of a reasonably knowledgeable user of the
standalone financial statements may be influenced. We consider quantitative materiality and qualitative
factors in (i) planning the scope of our audit work and in evaluating the results of our work; and (ii) to
evaluate the effect of any identified misstatements in the standalone financial statements.

We communicate with those charged with governance regarding, among other matters, the planned scope and
timing of the audit and significant audit findings, including any significant deficiencies in internal control that
we identify during our audit.

We also provide those charged with governance with a statement that we have complied with relevant ethical
requirements regarding independence, and to communicate with them all relationships and other matters that
may reasonably be thought to bear on our independence, and where applicable, related safeguards.

Report on Other Legal and Regulatory Requirements

1. As required by the Companies (Auditor''s Report) Order, 2020 ("the Order"), issued by the Central
Government of India in terms of sub-section (11) of section 143 of the Companies Act, 2013, we give
in the ''Annexure A'', a statement on the matters specified in paragraphs 3 and 4 of the Order, to the
extent applicable.

2. As required by Section 143 (3) of the Act, we report that:

a) We have sought and obtained all the information and explanations which to the best of our
knowledge and belief were necessary for the purposes of our audit.

b) In our opinion, proper books of account as required by law have been kept by the Company so far
as it appears from our examination of those books.

c) The Balance Sheet, the Statement of Profit and Loss and the Cash Flow Statement dealt with by
this Report are in agreement with the books of account.

d) In our opinion, the aforesaid financial statements comply with the Ind AS specified under Section
133 of the Act, read with Rule 7 of the Companies (Accounts) Rules, 2014.

e) On the basis of the written representations received from the directors as on 31st March, 2024
taken on record by the Board of Directors, none of the directors is disqualified as on 31st March,
2024 from being appointed as a director in terms of Section 164 (2) of the Act.

f) With respect to the adequacy of the internal financial controls with reference to financial
statements of the Company and the operating effectiveness of such controls, refer to our separate
Report in ''Annexure B''.

3. 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, in our opinion and to the best of our information and
according to the explanations given to us:

i. The Company does not have any pending litigations which would impact its financial position.

ii. The Company did not have any long-term contracts including derivative contracts for which
there were any material foreseeable losses.

iii. There were no amounts which were required to be transferred to the Investor Education and
Protection Fund by the Company.

iv. (a) The management has represented that, to the best of its knowledge and belief, other than
as disclosed in the notes to the accounts, no funds have been advanced or loaned or invested
(either from borrowed funds or share premium or any other sources or kind of funds) by the
company to or in any other person(s) or entity(ies), including foreign entities

("Intermediaries"), with the understanding, whether recorded in writing or otherwise, that the
Intermediary shall, whether, directly or indirectly lend or invest in other persons or entities
identified in any manner whatsoever by or on behalf of the company ("Ultimate Beneficiaries")
or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries;

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

(c) Based on such audit procedures that have been considered reasonable and appropriate in
the circumstances, nothing has come to our notice that has caused us to believe that the
representations under sub-clause (i) and (ii) of Rule 11(e), as provided under (a) and (b)
above, contain any material mis-statement.

v. No dividend has been declared or paid during the year by the company.

For G.P.Keshri & Associates.

Chartered Accountants
Sd-

(CA. Gopal Prasad Keshri)

Partner
FRN:017251N
M.NO.: 098476

Place: New Delhi

Date: 22.05.2024

UDIN:24098476BKHJQU7075

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Mar 31, 2014

We have audited the accompanying financial statements of CITURGIA BIOCHEMICALS LIMITED ("the Company). Which comprise the balance sheet as at 31st March 2014, the statement of profit and loss and the cash flow statement for the year then ended, and a summary of significant accounting policies and other explanatory information.

MANAGEMENT''S RESPONSIBILITY FOR THE FINANCIAL STATEMENTS

Management is responsible for the preparation of these financial statements that give true and fair view of the financial position, financial performance and cash flows of the company in accordance with accounting standard referred to in sub section(3G) of section 211 of companies Act 1956 ("the Act"). This responsibility includes the design, implementation and maintenances of internal control relevant to the preparation and presentation of financial statements that give a true and fair view and are free from material misstatement, whether due to fraud or error.

AUDITOR''S RESPONSIBILITY

Our responsibility is to express an opinion on these financial statements based on our audit. We conducted our audit in accordance with the standards on auditing issued by the Institute of chartered accountant of India. Those standards require that we comply with ethical requirements and plan and perform the audit to obtain reasonable assurance about whether the financial statements are free from material misstatement.

An audit involves performing procedures to obtain audit evidence about the amounts and disclosures in the financial statements. The procedures selected depend on the auditor''s judgment, including the assessment of the risks of material misstatement of the financial statement whether due to fraud or error. In making those risk assessments the auditor considers internal control relevant to the Company''s Preparation and fair presentation of the financial statement in order to design audit procedures that are appropriate in the circumstances. An audit also includes evaluating the appropriateness of accounting policies used and the reasonableness of the accounting estimates made by the management as well as evaluating the overall presentation of the financial statements.

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion.

OPINION

In our opinion, and to the best of our information and according to the explanation given to us, the financial statements give the information required by the Act in the manner so required and give a true and fair view in conformity with the accounting principles generally accepted in India:

a) In the case of balance sheet , the state of affairs of the company as at march31,2014,

b) In the case of statement of profit and loss of the profit for the year ended on that date, and

c) In the case of the cash flow statement, of the cash flows of the company for the year ended on that date.

REPORT ON OTHER LEGAL AND REGULATORY REQUIREMENTS

1. As required by the companies (auditor''s report) order, 2003 ("the Order") issued by the Central government of India in terms of sub-section (4a) of section 227 of the Act , we give in the annexure a statement on the matters specified in paragraphs 4 and 5 of the order.

2. As required by the section 227(3) of the act, we report that :

(a) We have obtained all the information and explanations which to the best of our knowledge and belief were necessary for the purpose of the audit.

(b) In our opinion, proper books of accounts as required by law have been kept by the company so far as appears from our examination of those books.

(c) The balance sheet, the statement of profit and loss and the cash flow statement dealt with by this report are in agreement with the books of account.

(d) In our opinion , the balance sheet, statement of profit and loss, and the cash flow statement comply with the accounting standards referred to in sub-section (3C)of section 211 of companies act 1956

(e) On the basis of written representation received from the directors as on 31st march 2014, and taken on record by the board of directors, none of the directors is disqualified as on 31st march 2014, from being appointed as a director in terms of clause (g) of sub- section (1) of section 274 of Companies Act, 1956.

Annexure to the Auditors Report

(Referred to in Paragraph 1 of our report of even date on the accounts for the period ended 31st March, 2014 of CITURGIA BIOCHEMCIALS LIMITED)

(i) (a) As explanation given by the management in respect of its fixed assets in schedule D forming part of accounts regarding the lock out by State Government of Uttarakhand at the Rishikesh Plant, subject thereto The company has maintained proper records of fixed assets showing full particulars including quantitative details and location of fixed assets at head office.

(b) Assets were not physically verified during the period by the management in view of lockout by State Government of Uttarakhand at Rishikesh plant as disclosed.

(ii) (a) As per information and explanation received from the management the inventory has not been physically verified during the period under audit due to lockout at Rishikesh plant.

(b) Not applicable

(c) In view of lockout the same is not applicable

(iii)

(a) The company has not granted unsecured loans to any party covered in the register maintained under section 301 of the companies Act, 1956.

(b) According to the information & explanations given to us the rate of the interest and other terms & conditions in respect of unsecured loans given by the company, are not prima facie prejudicial to the interest of the company.

(c) In our opinion and according to the information and explanations given to us, the receipt of principle amount and interest is regular.

(d) In our opinion and according to the information and explanations given to us there are no overdue amounts in respect of the unsecured loans given by the company.

(e) The company has not taken unsecured loans from party covered in the register maintained under section 301 of the companies act 1956.

(f) Whether the rate of interest and other terms and conditions of loans taken

by the company, secured or unsecured are prima facie prejudicial to the interest of the company and ------Not Applicable--------

(g) Whether payment of the principal amount and interest are also regular. --- -Not Applicable--------------

( iv ) In our opinion and according to the information and explanation given to us, there are adequate internal control procedures commensurate with the size of the company and the nature of its business for the purchase fixed assets and other items and not prima facie prejudicial to the interest of the company.

(v) (a) Transactions that need to be entered into a register in pursuance of section 301 of the Act have been entered.

(b) In our opinion and to the best of our knowledge each of these transaction exceeding the value of Rs. 5 lacs in respect of any party and in any one financial year, have been made at prices which are reasonable having regard to the prevailing market prices at the relevant time.

(vi) Since the company has not accepted any deposited from public accordingly the provision requiring that whether the directives issued by the Reserve Bank of India and the provisions of section 58 A and 58AA of the Act the rules framed there under, were applicable have been complied with is not applicable to the company.

(vii) In view of lock out at calcium carbonate division at Rishikesh the company has been unable to conduct the internal audit for the period end report.

(viii) The provisions requiring maintenance of cost records as prescribed by the Central Government under clause (d) of sub-section (1) of section 209 of the Act are not applicable to the company.

(ix) (a) The provisions of investor Education and Protection Fund are not applicable to the company. With reference to the provisions of the Sales Tax , Wealth Tax, Customs Duty and Excise Duly/Cess are applicable to the company. The company is not regular in depositing its statutory dues in respect of ESIC, EPF & Income Tax with the appropriate authorities amount of Rs. 2.20 lacs is outstanding as payable for statutory liabilities and tds as on 31.03.2014.

(b) As per records of the company there are disputed amounts payable as at 31.03.2014 in respect of income tax, wealth tax, custom duty and excise duty etc. Further as per notes of accounts liabilities towards income tax, sales tax/excise and ESIC matter are lying with respective tribunal/courts and the same are shown as contingent liability.

(x) In our opinion and to the best of our knowledge and as per information and explanation received from the management the company has not defaulted in repayment of dues to a bank.

(xi) The provisions requiring that, whether adequate documents and records are maintained in cases where the company has granted loans and advances on the basis of security by way of pledge of shares, debentures and other securities are not applicable to the company.

(xii) To the best to our knowledge the provisions special statues applicable to chit fund are not applicable to the company.

(xiii) Since the company is not dealing in shares and securities comments under this clause of the order are not required.

(xiv) As per explanation/ representation received from the management the company has not given any guarantee for loans taken by others from bank or financial institutions hence the provisions requiring whether the terms and conditions whereof are prejudicial to the interest of the company, are not applicable to the company.

(xv) The company has not availed any short-term loan from the bank to the best of our knowledge & belief.

(xvi) The company has not utilized the funds on short-term basis for long term investment and vice-versa.

(xvii) As per information given to us the company ahs not made preferential allotment of shares to parties and companies covered in the Register maintained under section 301 of the Act.

(xviii) The provisions requiring that whether securities have been created in respect of debentures issued, are not applicable to the company.

(xix) The provisions requiring that, whether the management has disclosed on the end use of money raised by public issues and the same has been not applicable to the company which is prejudicial to the interest of members of company.

(xx) No fraud on or by the company has been noticed or reported during the period.

For RANJAN GUPTA & CO. Chartered Accountants

Sd/- Ranjan Gupta Proprietor M.No. 082408

Place: New Delhi Date: 29.05.2014

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Mar 31, 2013

We have audited the accompanying financial statements of CITURGIA BIOCHEMICALS LIMITED ("the Company). Which comprise the balance sheet as at 31st March 2013, the statement of profit and loss and the cash flow statement for the year then ended, and a summary of significant accounting policies and other explanatory information.

MANAGEMENT''S RESPONSIBILITY FOR THE FINANCIAL STATEMENTS

Management is responsible for the preparation of these financial statements that give true and fair view of the financial position, financial performance and cash flows of the company in accordance with accounting standard referred to in sub section(3G) of section 211 of companies Act 1956 ("the Act"). This responsibility includes the design, implementation and maintenances of internal control relevant to the preparation and presentation of financial statements that give a true and fair view and are free from material misstatement, whether due to fraud or error.

AUDITOR''S RESPONSIBILITY

Our responsibility is to express an opinion on these financial statements based on our audit. We conducted our audit in accordance with the standards on auditing issued by the Institute of chartered accountant of India. Those standards require that we comply with ethical requirements and plan and perform the audit to obtain reasonable assurance about whether the financial statements are free from material misstatement.

An audit involves performing procedures to obtain audit evidence about the amounts and disclosures in the financial statements. The procedures selected depend on the auditor''s judgment, including the assessment of the risks of material misstatement of the financial statement whether due to fraud or error. In making those risk assessments the auditor considers internal control relevant to the Company''s Preparation and fair presentation of the financial statement in order to design audit procedures that are appropriate in the circumstances. An audit also includes evaluating the appropriateness of accounting policies used and the reasonableness of the accounting estimates made by the management as well as evaluating the overall presentation of the financial statements.

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion.

OPINION

In our opinion, and to the best of our information and according to the explanation given to us, the financial statements give the information required by the Act in the manner so required and give a true and fair view in conformity with the accounting principles generally accepted in India:

(a) In the case of balance sheet , the state of affairs of the company as at march31 , 2013, (b) In the case of statement of profit and loss of the profit for the year ended on that date, and (c) In the case of the cash flow statement, of the cash flows of the company for the year ended on that date.

REPORT ON OTHER LEGAL AND REGULATORY REQUIREMENTS

1. As required by the companies (auditor''s report) order, 2003 ("the Order") issued by the Central government of India in terms of sub-section (4a) of section227 of the Act , we give in the annexure a statement on the matters specified in paragraphs 4 and 5 of the order.

2. As required by the section 227(3) of the act, we report that :

(a) We have obtained all the information and explanations which to the best of our knowledge and belief were necessary for the purpose of the audit.

(b) In our opinion, proper books of accounts as required by law have been kept by the company so far as appears from our examination of those books.

(c) The balance sheet, the statement of profit and loss and the cash flow statement dealt with by this report are in agreement with the books of account.

(d) In our opinion , the balance sheet, statement of profit and loss, and the cash flow statement comply with the accounting standards referred to in sub-section (3C)of section 211 of companies act 1956

(e) On the basis of written representation received from the directors as on 31st march 2013, and taken on record by the board of directors, none of the directors is disqualified as on 31st march 2013, from being appointed as a director in terms of clause (g) of sub-section (1) of section 274 of Companies Act, 1956.

Annexure to the Auditors Report

(Referred to in Paragraph 1 of our report of even date on the accounts for the period ended 31st March, 2013 of CITURGIA BIOCHEMCIALS LIMITED)

(i) (a) As explanation given by the management in respect of its fixed assets in schedule D forming part of accounts regarding the lock out by State Government of Uttarakhand at the Rishikesh Plant, subject thereto, The company has maintained proper records of fixed assets showing full particulars including quantitative details and location of fixed assets at head office.

(b) Assets were not physically verified during the period by the management in view of lockout by State Government of Uttarakhand at Rishikesh plant as disclosed.

(ii) (a) As per information and explanation received from the management the inventory has not been physically verified during the period under audit due to lockout at Rishikesh plant.

(b) Not applicable

(c) In view of lockout the same is not applicable (iii)

(a) The company has not granted unsecured loans to any party covered in the register maintained under section 301 of the companies Act, 1956.

(b) According to the information & explanations given to us the rate of the interest and other terms & conditions in respect of unsecured loans given by the company, are not prima facie prejudicial to the interest of the company.

(c) In our opinion and according to the information and explanations given to us, the receipt of principle amount and interest is regular.

(d) In our opinion and according to the information and explanations given to us there are no overdue amounts in respect of the unsecured loans given by the company.

(e) The company has not taken unsecured loans from party covered in the register maintained under section 301 of the companies act 1956.

(f) Whether the rate of interest and other terms and conditions of loans taken by the company, secured or unsecured are prima facie prejudicial to the interest of the company and Not Applicable

(g) Whether payment of the principal amount and interest are also regular.

Not Applicable

( iv ) In our opinion and according to the information and explanation given to us, there are adequate internal control procedures commensurate with the size of the company and the nature of its business for the purchase fixed assets and other items and not prima facie prejudicial to the interest of the company.

(v) (a) Transactions that need to be entered into a register in pursuance of section 301 of the Act have been entered.

(b) In our opinion and to the best of our knowledge each of these transaction exceeding the value of Rs. 5 lacs in respect of any party and in any one financial year, have been made at prices which are reasonable having regard to the prevailing market prices at the relevant time.

(vi) Since the company has not accepted any deposited from public accordingly the provision requiring that whether the directives issued by the Reserve Bank of India and the provisions of section 58 A and 58AA of the Act the rules framed there under, were applicable have been complied with is not applicable to the company.

(vii) In view of lock out at calcium carbonate division at Rishikesh the company has been unable to conduct the internal audit for the period end report.

(viii) The provisions requiring maintenance of cost records as prescribed by the Central Government under clause (d) of sub-section (1) of section 209 of the Act are not applicable to the company.

(ix) (a) The provisions of investor Education and Protection Fund are not applicable to the company. With reference to the provisions of the Sales Tax , Wealth Tax, Customs Duty and Excise Duly/Cess are applicable to the company. The company is not regular in depositing its statutory dues in respect of ESIC, EPF & Income Tax with the appropriate authorities amount of Rs. 12.31 lacs is outstanding as payable for statutory liabilities and tds as on 31.03.2013.

(b) As per records of the company there are disputed amounts payable as at 31.03.2013 in respect of income tax, wealth tax, custom duty and excise duty etc. Further as per notes of accounts liabilities towards income tax, sales tax/excise and ESIC matter are lying with respective tribunal/courts and the same are shown as contingent liability.

(x) In our opinion and to the best of our knowledge and as per information and explanation received from the management the company has not defaulted in repayment of dues to a bank.

(xi) The provisions requiring that, whether adequate documents and records are maintained in cases where the company has granted loans and advances on the basis of security by way of pledge of shares, debentures and other securities are not applicable to the company.

(xii) To the best to our knowledge the provisions special statues applicable to chit fund are not applicable to the company.

(xiii) Since the company is not dealing in shares and securities comments under this clause of the order are not required.

(xiv) As per explanation/representation received from the management the company has not given any guarantee for loans taken by others from bank or financial institutions hence the provisions requiring whether the terms and conditions whereof are prejudicial to the interest of the company, are not applicable to the company.

(xv) The company has not availed any short-term loan from the bank to the best of our knowledge & belief.

(xvi) The company has not utilized the funds on short-term basis for long term investment and vice-versa.

(xvii) As per information given to us the company has not made preferential allotment of shares to parties and companies covered in the Register maintained under section 301 of the Act.

(xviii) The provisions requiring that whether securities have been created in respect of debentures issued, are not applicable to the company.

(xix) The provisions requiring that, whether the management has disclosed on the end use of money raised by public issues and the same has been not applicable to the company which is prejudicial to the interest of members of company.

(xx) No fraud on or by the company has been noticed or reported during the period.

For RANJAN GUPTA & CO.

Chartered Accountants

Ranjan Gupta (FCA)

M.No.500-82408

Place : New Delhi

Date : 30th May, 2013

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Mar 31, 2012

We have audited the attached Balance Sheet of CITURGIA BIOCHEMICALS LIMITED as at 31st March 2012, and also the Profit & Loss Account and Cash Flow Statement for the year ended 31st March 2012 thereto. These financial statements are the responsibility of the Company''s management. Our responsibility is to express an opinion on these financial statements based on our audit. "

We conducted our audit in accordance with the auditing standards generally accepted in India. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement. An audit includes examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements. An audit also includes assessing the accounting principles used and significant estimates made by management as well as evaluating the overall financial statements presentation. We believe that our audit provides a reasonable basis for our opinion.

We report that: -

1. As required by the Company''s (Auditor''s Report)(amendment) order, 2004 notified by the Central Government of India in the Department of Company Affaires (vide notification no. GSR 766 (E) dated 25.11.2004 in terms of sub-section (4A) of section 227 of the Companies Act, 1956 (1 of 1956) we enclose in the Annexure hereto a statement of the matters specified in paragraph 4 and 5 of the said order.

2. Further to our comments m the Annexure referred to in paragraph 1 above and subject to our following observations and subject to the notes to the accounts given in schedule ''N'' annexed to the Balance Sheet.

i. Pursuant to the order of the State Government of uttarakhand under which the whole premises of the company at Rishikesh have been ceased and under Government possession due to which the very existence of the company has come at a stake,

ii. Pursuant to the order of the Hon''ble High Court of Uttarakhand and thereafter the consequential orders of Hon''ble BIFR and State Government due to which substantial part of the sanctioned rehabilitation scheme i.e. change of land use and redevelopment of surplus land stands cancelled,

iii. Non-provision for the loss of Rs. 329.68 Lacs being the value of inventories in the real estate division which have come at stake due to cancellation of change of land use and non provision of consequential losses which are not quantifiable at this stage as the matter is pending before the Hon''ble Supreme Cotuit of India. As a result the losses have been understated to this extent,

iv. Inability to physically verify various fixed assets, plant and machinery and inventories and part of books of accounts lying at Rishikesh premises which are under Government seal,

v. Non-availability of bank balance confirmation certificates and unconfirmed balances of Sundry Creditors and inter corporate deposits,

VI. Despite all the above points the annual accounts of the company have been prepared on going concern concept in anticipation of getting justice from the Apex Court.

3. Further to our comments in Annexure referred to point no. 2 above we report that

a. We have obtained all die information and explanations which to the best of our knowledge and belief were necessary for the purposes of our audit

b. In our opinion proper books of accounts required by aw have been kept by the company so far as appears from our examination of those books.

c. I he balance Sheet & Profit and Loss Account dealt with by this report are in agreement with the books of account.

d. In our opinion the Balance Sheet & Profit and Loss account dealt with by this report comply with the accounting standards referred to in sub-section (3c) of section 211 of the companies Act, 1956.

e. In our opinion, and based on information & explanations given to us non of the directors are disqualified as on 31st March, 2012 from being appointed as a director in terms of clause(g) our sub-section(l) of section 274 of the companies Act, 1956

f. In our opinion and to the best- of our information and according to the explanations giver to us the said accounts read together with the significant Accounting Policies and other notes thereon give the information required by Companies Act, 1956 in the manner so required and present a true and fair view in conformity with the accounting principal generally accepted in India.

i. In so far as it relates to Balance Sheet, of the state of affairs of the Company as at 31st March 2012 and

ii. In so far as it relates to Profit & Loss account of the loss for the period ended on that date.

iii. In so far as it relates to the cash and fund flow statement for the period ended on that date.

Annexure to the Auditors Report

(Referred to in Paragraph 1 of our report of even date on the accounts for the period ended 31st March, 2012 of CITURGIA BIOCHEMCIALS LIMITED)

(i) (a) As explanation given by the management in respect of its fixed assets in schedule D forming part of accounts regarding the lock out by State Government of at the Rishikesh Plant, subject thereto

The company has maintained proper records of fixed assets showing full particulars including quantitative details and location of fixed assets at head office.

(b) Assets were not physically verified during the period by the management in view of lockout by State Government of Uttarakhand at Rishikesh plant as disclosed.

(u) (a) As per information and explanation received from the management the inventory has not been physically verified during the period under audit due to lockout at Rishikesh plant.

(b) Not applicable

(c ) In view of lockout the same is not applicable

(a) The company has not granted unsecured loans to any party covered in the register maintained under section 301 of the companies Act, 1956.

(b) According to the information & explanations given to us the rate of the interest and other terms & conditions in respect of unsecured loans given by the company, are not facie prejudicial to the interest of the company.

(c) In our opinion and according to the information and explanations given to us, the receipt of principle amount and interest is regular.

(d) In our opinion and according to the information and explanations given to us there are no overdue amounts in respect of the unsecured loans given by the company.

(e) The company has not taken unsecured loans from party covered in the register- maintained under section 301 of the companies act 1956.

(f) Whether the rate of interest and other terms and conditions of loans taken by the company, secured or unsecured are prima facie prejudicial to the interest of the company and ------Not Applicable

(g) Whether payment of the principal amount and interest are also regular. Not Applicable

(IV ) In our opinion and according to the information and explanation given to us, there are adequate internal control procedures commensurate with the size of the company and the nature of its business for the purchase fixed assets and other items and not pirma facie prejudicial to the interest of the company.

(y) (a) Transactions that need to be entered into a register in pursuance of section 301 of the Act have been entered.

(b) In our opinion and to the best of our knowledge each of these transaction exceeding the value of Rs. 5 lacs in respect of any party and in any one financial year, have been made at prices which are reasonable having regard to the prevailing market prices at the relevant time.

(vi) Since the company has not accepted any deposited from public accordingly the provision requiring that whether the directives issued by the Reserve Bank of India and the provisions of section 58 A and 58AA of the Act the rules framed there under, were applicable have been complied with is not applicable to the company.

(vii) In view of lock out at calcium carbonate division at Rishikesh the company has been unable to conduct the internal audit for the period end report.

(viii) The provisions requiring maintenance of cost records as prescribed by the Central Government under clause (d) of sub-section (1) of section 209 of the Act are not applicable to the company.

(ix) (a) The provisions of investor Education and Protection Fund are not applicable to the company. With reference to the provisions of the Sales Tax , Wealth Tax, Customs Duty and Excise Duly/Cess are applicable to the company. The company is not regular in depositing its statutory dues in respect of ESIC, EPF & Income Tax with ''the appropriate authorities A amount of Rs. 12.31 lacs is outstanding as payable for statutory liabilities and as on 31.03.2012.

(b) As per records of the company'' there are disputed amounts payable as at 31.03.2012 in respect of income tax, wealth tax, custom duty and excise duty etc. Further as per notes of accounts liabilities towards income tax, sales tax/excise and ESIC matter are lying with respective tribunal/courts and the same are shown as contingent liability.

(x) In our opinion and to the best of our knowledge and as per information and explanation received from the management the company has not defaulted in repayment of dues to a bank.

(xi) The provisions requiring that, whether adequate documents and records are maintained in cases where the company has granted loans and advances on the basis of security by way of pledge of shares, debentures and other securities are not applicable to the company.

(xii) To the best to our knowledge the provisions special statues applicable to chit fund are not applicable to the company.

(xiii) Since the company is not dealing in shares and securities comments under this clause of the order are not required.

(xiv) As per explanation/representation received from the management the company has not given any guarantee for loans taken by others from bank or financial institutions hence the provisions requiring whether the terms and conditions whereof are prejudicial to the interest of the company, are not applicable to the company.

(xv) The company has not availed any short-term loan from the bank to the best of our knowledge & belief.

(xvi) The company has not utilized the funds on short-term basis for long term investment and vice- versa.

(xvii) As per information given to us the company has not made preterennal allotment of shares to parties and companies covered in the Register maintained under section 301 of the Act.

(xviii) The provisions requiring that whether securities have been created in respect of debentures issued, are not applicable to the company.

xix) The provisions requiring that, whether the management has disclosed on the end use of money raised by public issues and the same has been not applicable to the company which is prejudicial to the interest of members of company.

xx) No fraud on or by the company has been noticed or reported during the period.

For RANJAN GUPTA & CO.

Chartered Accountants

Ranjan Gupta

(FCA)

M.No. 500-82408

Place: New Delhi

Date : 04/09/2012.

---

Mar 31, 2011

We have audited the attached Balance Sheet of CITURGIA BIOCHEMICALS LIMITED as at 31st March 2011, and also the Profit & Loss Account and Cash Flow Statement for the year ended 31st March 2011 thereto. These financial statements are the responsibility of the Company''s management. Our responsibility is to express an opinion on these financial statements based on our audit.

We conducted our audit in accordance with the auditing standards generally accepted in India. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement. An audit includes examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements. An audit also includes assessing the accounting principles used and significant estimates made by management as well as evaluating the overall financial statements presentation. We believe that our audit provides a reasonable basis for our opinion.

We report that:

1. As required by the Company''s (Auditor''s Report)(amendment) order, 2004 notified by the Central Government of India in the Department of Company Affaires (vide notification no. GSR 766 (E) dated 25.11.2004 in terms of sub-section (4A) of section 227 of the Companies Act, 1956 (1 of 1956) we enclose in the Annexure hereto a statement of the matters specified in paragraph 4 and 5 of the said order.

2.Further to our comments in the Annexure referred to in paragraph 1 above and subject to our following observations and subject to the notes to the accounts given in schedule ''N'' annexed to the Balance Sheet.

i.Pursuant to the order of the State Government of Uttarakhand under which the whole premises of the company at Rishikesh have been ceased and under Government possession due to which the very existence of the company has come at a stake,

ii.Pursuant to the order of the Hon''ble High Court of Uttarakhand and thereafter the consequential orders of Hon''ble BIFR and State Government due to which substantial part of the sanctioned rehabilitation scheme i.e. change of land use and redevelopment of surplus land stands cancelled,

iii.Non-provision for the loss of Rs. 329.68 Lacs being the value of inventories in the real estate division which have come at stake due to cancellation of change of land use and non provision of consequential losses which are not quantifiable at this stage as the matter is pending before the Hon''ble Supreme Court of India. As a result the losses have been understated to this extent,

iv. Inability to physically verify various fixed assets, plant and machinery and inventories and part of books of accounts lying at Rishikesh premises which are under Government seal,

v. Non-availability of bank balance confirmation certificates and unconfirmed balances of Sundry Creditors and inter corporate deposits,

vi. Despite all the above points the annual accounts of the company have been prepared on going concern concept in anticipation of getting justice from the Apex Court.

3.Further to our comments in Annexure referred to point no. 2 above we report that

a.We have obtained all the information and explanations which to the best of our knowledge and belief were necessary for the purposes of our audit

b.In our opinion proper books of accounts required by aw have been kept by the company so far as appears from our examination of those books.

c.The balance Sheet & Profit and Loss Account dealt with by this report are in agreement with the books of account.

d.In our opinion the Balance Sheet & Profit and Loss account dealt with by this report comply with the accounting standards referred to in sub-section (3c) of section 211 of the companies Act, 1956.

e.In our opinion, and based on information & explanations given to us non of the directors are disqualified as on 31st March, 2012 from being appointed as a director in terms of clause(g) our sub-section(1) of section 274 of the companies Act, 1956

f.In our opinion and to the best of our information and according to the explanations given to us the said accounts read together with the significant Accounting Policies and other notes thereon give the information required by Companies Act, 1956 in the manner so required and present a true and fair view in conformity with the accounting principal generally accepted in India.

i.In so far as it relates to Balance Sheet, of the state of affairs of the Company as at 31st March 2011 and

ii.In so far as it relates to Profit & Loss account of the loss for the period ended on that date.

iii.In so far as it relates to the cash and fund flow statement for the period ended on that date.

Annexure to the Auditors Report

(Referred to in Paragraph 1 of our report of even date on the accounts for the period ended 31st March, 2011 of CITURGIA BIOCHEMCIALS LIMITED)

(i)(a) As explanation given by the management in respect of its fixed assets in schedule D forming part of accounts regarding the lock out by State Government of Uttarakhand at the Rishikesh Plant, subject thereto

The company has maintained proper records of fixed assets showing full particulars including quantitative details and location of fixed assets at head office.

(b)Assets were not physically verified during the period by the management in view of lockout by State Government of Uttarakhand at Rishikesh plant as disclosed.

(ii)(a) As per information and explanation received from the management the inventory has not been physically verified during the period under audit due to lockout at Rishikesh plant.

(b)Not applicable

(c) In view of lockout the same is not applicable

(iii)(a)The company has not granted unsecured loans to any party covered in the register maintained under section 301 of the companies Act, 1956.

(b)According to the information & explanations given to us the rate of the interest and other terms & conditions in respect of unsecured loans given by the company, are not prima facie prejudicial to the interest of the company.

(c)In our opinion and according to the information and explanations given to us, the receipt of principle amount and interest is regular.

(d)In our opinion and according to the information and explanations given to us there are no overdue amounts in respect of the unsecured loans given by the company.

(e)The company has not taken unsecured loans from party covered in the register maintained under section 301 of the companies act 1956.

(f)Whether the rate of interest and other terms and conditions of loans taken by the company, secured or unsecured are prima facie prejudicial to the interest of the company and ------

Not Applicable ---------- (g) Whether payment of the principal amount and interest are also regular. ------- Not

Applicable-------------

(iv)In our opinion and according to the information and explanation given to us, there are adequate internal control procedures commensurate with the size of the company and the nature of its business for the purchase fixed assets and other items and not prima facie prejudicial to the interest of the company.

(v) (a) Transactions that need to be entered into a register in pursuance of section 301 of the Act have been entered.

(b)In our opinion and to the best of our knowledge each of these transaction exceeding the value of Rs. 5 lacs in respect of any party and in any one financial year, have been made at prices which are reasonable having regard to the prevailing market prices at the relevant time.

(vi)Since the company has not accepted any deposited from public accordingly the provision requiring that whether the directives issued by the Reserve Bank of India and the provisions of section 58 A and 58AA of the Act the rules framed there under, were applicable have been complied with is not applicable to the company.

(vii)In view of lock out at calcium carbonate division at Rishikesh the company has been unable to conduct the internal audit for the period end report.

(viii)The provisions requiring maintenance of cost records as prescribed by the Central Government under clause (d) of sub-section (1) of section 209 of the Act are not applicable to the company.

(ix)(a) The provisions of investor Education and Protection Fund are not applicable to the company. With reference to the provisions of the Sales Tax , Wealth Tax, Customs Duty and Excise Duly/Cess are applicable to the company. The company is not regular in depositing its statutory dues in respect of ESIC, EPF & Income Tax with the appropriate authorities A amount of Rs. 12.31 lacs is outstanding as payable for statutory liabilities and tds as on 31.03.2011.

(b)As per records of the company there are disputed amounts payable as at 31.03.2012 in respect of income tax, wealth tax, custom duty and excise duty etc. Further as per notes of accounts liabilities towards income tax, sales tax/excise and ESIC matter are lying with respective tribunal/courts and the same are shown as contingent liability.

(x)In our opinion and to the best of our knowledge and as per information and explanation received from the management the company has not defaulted in repayment of dues to a bank.

(xi)The provisions requiring that, whether adequate documents and records are maintained in cases where the company has granted loans and advances on the basis of security by way of pledge of shares, debentures and other securities are not applicable to the company.

(xii)To the best to our knowledge the provisions special statues applicable to chit fund are not applicable to the company.

(xiii)Since the company is not dealing in shares and securities comments under this clause of the order are not required.

(xiv)As per explanation/representation received from the management the company has not given any guarantee for loans taken by others from bank or financial institutions hence the provisions requiring whether the terms and conditions whereof are prejudicial to the interest of the company, are not applicable to the company.

(xv)The company has not availed any short-term loan from the bank to the best of our knowledge & belief.

(xvi)The company has not utilized the funds on short-term basis for long term investment and vice- versa.

(xvii)As per information given to us the company ahs not made preferential allotment of shares to parties and companies covered in the Register maintained under section 301 of the Act.

(xviii)The provisions requiring that whether securities have been created in respect of debentures issued, are not applicable to the company.

(xix)The provisions requiring that, whether the management has disclosed on the end use of money raised by public issues and the same has been not applicable to the company which is prejudicial to the interest of members of company.

(xx)No fraud on or by the company has been noticed or reported during the period.



For S.C.GARG & ASSOCIATES

Chartered Accountants

Sd/-

Subhash Garg

Partner

M.No.85615

Place:New Delhi

Date:05/09/2011.

---

Apr 20, 2010

We have audited the attached Balance Sheet of CITURGIA BIOCHEMICALS LIMITED as at 20th April, 2010, and also the Profit & Loss Account for the extended period (i.e. 1.04.2009 to 20.04.2010) annexed thereto. These financial statements are the responsibility of the Companys management. Our responsibility is to express an opinion on these financial statements based on our audit.

1. We conducted our audit in accordance with the auditing standards generally accepted in India. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement. An audit includes examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements. An audit also includes assessing the accounting principles used and significant estimates made by management as well as evaluating the overall financial statements presentation. We believe that our audit provides a reasonable basis for our opinion.

2. As required by the Companys (Auditors Report)(amendment) order, 2004 notified by the Central Government of India in the Department of Company Affaires (vide notification no. GSR 766 (E) dated 25.11.2004 in terms of sub-section (4A) of section 227 of the Companies Act, 1956 (1 of 1956) we enclose in the Annexure hereto a statement of the matters specified in paragraph 4 and 5 of the said order.

3. As per information given by the company the company its board of directors has taken decision to increased its authorized share capital from Rs. 700 lacs to 2700 lacs and allotted shares amounting to Rs. 2000 lacs on board meeting dated 17.04.2010. As the company has not yet to intimate/file the relative form no. 5 and form no. 2 with the registrar of the company.

4. We have received representation from the board of directors as to the "operation" and state of affairs of the company not having access to the assets & books of accounts lying at the plant. Subject to the above in acceptance of the directors representation and the order of Honble B1FR and the Honble AAIFR. We report that

5. Attention is invited to Note No. 1 in schedule O forming part of accounts regarding the rehabilitation scheme sanctioned by Honble BIFR. Subsequent to failure of the BIFR scheme the company has appealed. As per written explanation received from the company regarding increase in share capital by Rs. 2000 lacs and receipt of permission of change in land use from State Govt, but subject to the necessary filing of records and returns to the respective govt, bodies the accounts of the company are prepared on going concern basis in anticipation of getting one or the other permission as stated above.

6. As a consequence of continuing lockout of the Rishikesh plant

i. Physically inspect the premises based at Rishikesh, or the accounting record maintained at Rishikesh

ii. verify the stock lying at Rishikesh plant

iii. Conduct a comprehensive audit of the books of accounts of the company for the period under audit

iv. We have not obtained balance certificates from the banks/financial institutions and have relied on management representation and opening balance as per last audit report.

7. The company has not provided depreciation for the period 1.4.2010 to 20.04.2010 and loss to the extent is understated.

8. We have relied on the managements representation that they made available all the information and explanations which to the best of our knowledge and belief were necessary for the purpose of audit

9. We have relied on the managements representation as to maintenance of proper books and records as required by law at the Rishikesh plant in view of the lockout.

10. As per schedule D of the balance sheet the company has taken interoperate deposits of Rs. 275.69 lacs. As copy of agreement for the same not been verified by us hence we are unable to comment of the interest provision and repayment programme of the same.

11. Attention is invited to Note No in schedule O forming part of accounts regarding the non-provision of certain expenses amounting to Rs. 157 lacs. Consequently the loss is understated by Rs. 157 lacs.

12. The figures of deferred tax liabilities are been adjusted to the 5% of the gross block of assets during the period. The deferred tax liability as on date is Rs. 4245 lacs but the management has taken Rs. 55.55 lacs . Due to this effect the loss is understated by Rs. 13:10 lacs.

13. The company is having balance of Rs. 3.23 lacs with schedule banks in current account. We have been produced statement of account of UBl Share application account amounting to Rs. 0.06 lacs. Balance figures are subject ot confirmation of transaction/balance with other schedule banks.

14. Details of FDRs of Rs. 2.65 lac with banks atongwith copy of deposit receipts are not been produced to us for verification. Also no interest provision on the same is being done by the company hence we are unable to comment on the same.

15. The company has paid Rs. 359.35 lacs to M/s Sturdia Developers for work in progress shown under the inventory for real estate division of the company. As copy of agreement project status report not been produced to us for verification we are unable to comment on the terms/status of the said project.

16. Balances of sundry debtors and sundry creditors are subject to confirmation/reconciliation.

17. Opening balances are takes as certified by previous auditors.

18. Further to our comments in Annexure referred to point no. 2 above we report that

18.1 We have obtained all the information and explanations which to the best of our knowledge and belief were necessary for the purposes of our audit

18.2 In our opinion proper books of accounts required by aw have been kept by the company so far as appears from our examination of those books.

18.3 The balance Sheet & Profit and Loss Account dealt with by this report are in agreement with the books of account.

18.4 In our opinion the Balance Sheet & Profit and Loss account dealt with by this report comply with the accounting standards referred to in sub-section (3c) of section 211 of the companies Act, 1956.

18.5 In our opinion, and based on information & explanations given to us non of the directors are disqualified as on 20" April, 2010 from being appointed as a director in terms of clause(g) our sub-section(l) of section 274 of the companies Act, 1956

18.6 In our opinion and to the best of our information and according to the explanations given to us the said accounts read together with the significant Accounting Policies and other notes thereon give the information required by Companies Act, 1956 in the manner so required and present a true and fair view in conformity with the accounting principal generally accepted in India.

18.6.1 In so far as it relates to Balance Sheet, of the state of affairs of the Company as at 20* April, 2010 and

18.6.2 In so far as it relates to Profit & Loss account of the loss for the period ended on that date.

18.6.3 In so fare as it relates to the cash and fund flow statement for the period ended on that date. Annexure to the Auditors Report

(Referred to in Paragraph 1 of our report of even date on the accounts for the period ended 20* April, 2010 of CITURGIA BI0CHEMCIALS LIMITED)

(i) (a) As explanation given by the management in respect of its fixed assets in schedule D forming part of accounts regarding the continuing lock out at the Rishikesh Plant, subject theret.

The company has maintained proper records of fixed assets showing full particulars including quantitative details and location of fixed assets at head office.

(b) Assets were not physically verified during the period by the management in view of lockout at Rishikesh plant as disclosed.

(ii) (a) As per information and explanation received from the management the inventory has not been pHysically verified during the period under audit due to lockout at Rishikesh plant.

(b) Not applicable

(c) In view of lockout the same is not applicable

(iii) (a) The company has not granted unsecured loans to any party covered in the register maintained under section 301 of the companies Act, 1956.

(b) According to the information & explanations given to us the rate of the interest and other terms & conditions in respect of unsecured loans given by the company, are not prima facte prejudicial to the interest of the company.

(c) In our opinion and according to the information and explanations given to us, the receipt of principle amount and interest is regular.

(d) In our opinion and according to the information and explanations given to us there are no overdue amounts in respect of the unsecured loans given by the company.

(e) The company has not taken unsecured loans from party covered in the register maintained under section 301 of the companies act 1956.

(f) Whether the rate of interest and other terms and conditions of loans taken by the company, secured or unsecured are prima facie prejudicial to the interest of the company and Not Applicable

(g) Whether payment of the principal amount and interest are also regular. Not Applicable

(iv) In our opinion and according to the information and explanation given to us, there are adequate internal control procedures commensurate with the size of the company and the nature of its business for the purchase fixed assets and other items and not prima facie prejudicial to the interest of the company.

(v) (a) Transactions that need to be entered into a register in pursuance of section 301 of the Act have been entered.

(b) In our opinion and to the best of our knowledge each of these transaction exceeding the value of Rs. 5 lacs in respect of any party and in any one financial year, have been made at prices which are reasonable having regard to the prevailing market prices at the relevant time.

(vi) Since the company has not accepted any deposited from public accordingly the provision requiring that whether the directives issued by the Reserve Bank of India and the provisions of section 58 A and 58AA of the Act the rules framed there under, were applicable have been complied with is not applicable to the company.

(vii) In view of lock out at calcium carbonate division at Rishikesh the company has been unable to conduct the internal audit for the period end report.

(viii) The provisions requiring maintenance of cost records as prescribed by the Central Government under clause (d) of sub-section (1) of section 209 of the Act are not applicable to the company.

(be) (a) The provisions of investor Education and Protection Fund are not appBcable to the company. With reference to the provisions of the Sales Tax, Wealth Tax, Customs Duty and Excise Duly/Cess are applicable to the company. The company is not regular in depositing its statutory dues in respect of ESIC, EPF & Income Tax with the appropriate authorities A amount of Rs. 12.31 lacs is outstanding as payable for statutory liabilities and tds as on 20.04.2010.

(b) As per records ofthecompatry there are disouted amounts payables

custom duty and excise duty etc. Further as per notes of accounts liabilities towards income tax, sales tax/excise and ESIC matter are lying with respective tribunal/courts and the same are shown as contingent liability.

(x) The company has incurred cash loss during the period and previous year. As per informatior, receive from the company the company ahs allotted shares of Rs. 2000 lacs and Rs. 250 lacs as share warrants and effect of the same is that the net worth of the company become positive. However as the company has yet to complete the formalities with the registrar of companies hence the capital of the company is subject to approval from the ROC.

(xi) In our opinion and to the best of our knowledge and as per information and explanation received from the management the company has not defaulted in repayment of dues to a bank.

(xii) The provisions requiring that, whether adequate documents and records are maintained in cases where the company has granted loans and advances on the basis of security by way of pledge of shares, debentures and other securities are not applicable to the company.

(xiii) To the best to our knowledge the provisions special statues applicable to chit fund are not applicable to the company.

(xiv) Since the company is not dealing in shares and securities comments under this clause of the order are not required.

(xv) As per explanation/representation received from the management the company has not given any guarantee for loans taken by others from bank or financial institutions hence the provisions requiring whether the terms and conditions whereof are prejudicial to the interest of the company, are not applicable to the company.

(xvi) The company has not availed any short-term loan from the bank to the best of our knowledge & belief.

(xvii) The company has not utilized the funds on short-term basis for long term investment and vice-versa.

(xviii) As per information given to us the company ahs not made preferential allotment of shares to parties and companies covered in the Register maintained under section 301 of the Act.

(xix) The provisions requiring that whether securities have been created in respect of debentures issued, are not applicable to the company.

(xx) The provisions requiring that, whether the management has disclosed on the end use of money raised by public issues and the same has been not applicable to the company which is prejudicial to the interest of members of company.

(xxi) No fraud on or by the company has been noticed or reported during the period.

For S. C. GARG & ASSOCIATES Chartered Accountants

Subhash Garg

Partner

M. No. 85615

Place: New Delhi Date: 23/04/2010