Notes to Accounts of Surani Steel Tubes Ltd.

Mar 31, 2025

11. Provisions, Contingent Liabilities and Contingent Assets

Provisions involving a substantial degree of estimation in
measurement are recognized when there is a present
obligation as a result of past events and it is probable that
there will be an outflow of resources. Contingent
liabilities are not recognized but are disclosed in the
accounts by way of a note. Contingent assets are neither
recognized nor disclosed in the financial statements.

12. Foreign Currency Transactions

All transactions in foreign currency, are recorded at the
rates of exchange prevailing on the dates when the
relevant transactions taken place. Exchange differences
arising on foreign currency transactions are recognized as
income or expense in the period in which they arise.

13. Taxes on Income

Tax expense for a year comprises of current tax, deferred
tax. Current tax is measured after taking into
consideration, the deductions and exemptions admissible
under the provisions of the Income-tax Act, 1961.

Deferred Tax Liability (assets) has been recognized as per
Accounting Standard - 22 (Accounting for Taxes on
Income). Deferred tax is recognised on timing differences,
being the differences between the taxable income and the
accounting income that originate in one period and are
capable of reversal in one or more subsequent periods.
Deferred tax is measured using the tax rates and the tax
laws enacted or substantially enacted as at the reporting
date. Deferred tax liabilities are recognised for all timing
differences. Deferred tax assets in respect of unabsorbed
depreciation and carry forward of losses are recognised
only if there is virtual certainty supported by convincing
evidence that there will be sufficient future taxable
income available to realise such assets. Deferred tax
assets are recognised for timing differences of other items
only to the extent that reasonable certainty exists that
sufficient future taxable income will be available against
which these can be realised. Deferred tax assets and
liabilities are offset if such items relate to taxes on income
levied by the same governing tax laws and the Company
has a legally enforceable right for such set off. Deferred
tax assets are reviewed at each Balance Sheet date for
their realisability. Current and deferred tax relating to
items directly recognised in reserves are recognised in
reserves and not in the statement of profit and loss.

Minimum Alternate Tax (MAT) paid in accordance with the
tax laws, which gives future economic benefits in the form
of adjustment to future income tax liability is considered
as an asset if there is convincing evidence that the
company will pay normal income tax. Accordingly, MAT is
recognized as an asset in the Balance sheet when it is
probable that future economic benefit associated with it
will flow to the Company.

14. Cash Flow statement

The cash flow statement is prepared by the indirect

method set out in Accounting standard 3 (AS 3) on “Cash
flow statement” and present the cash flow by operating,
investing and financing activities of the Company.

Cash and cash equivalents for the purposes of cash flow
statement comprise cash at bank and in hand and short¬
term investments with an original maturity of three
months or less.

15. Goods and Service Tax Credit

Input Tax Credit is accounted for on accrual basis on
purchase of eligible inputs, capital goods and services.

16. Government Grant

Grants and subsidies from the government are recognized
when there is reasonable assurance that

a. The company will comply with the conditions
attached to them, and

b. The grant/ subsidy will be received.

Grant received against specific property, plant and
equipment are adjusted to the cost of the assets and
those to the nature of promoter''s contribution are
credited to Capital reserve. Revenue grants are
recognized as income on a systematic basis in the
statement of profit and loss in accordance with the
related scheme and in the period in which these are
accrued.

17. Borrowin g Cost

Interest and other costs in connection with the borrowings
of the funds to the extents related/ attributed to the
acquisition/ construction of qualifying assets are
capitalized up to the date when such assets are ready for
their intended use and other borrowing cost are charged to
the statement of profit and loss.

18. Other Accounting Policies

Accounting policies not specifically referred to are in
accordance with generally accepted accounting
principles.

NOTE 2D TERMS/ RIGHTS ATTACHED TO EQUITY SHARES

The Company has only one class of equity shares having a par value of ?10/- per share. Each holder of equity shares is entitled to
one vote per share and ranks pari passu.

In the event of liquidation of the Company, the holders of equity shares will be entitled to receive any of the remaining assets of
the Company after distribution of all preferential amounts. The distribution will be in proportion to the number of equity shares
held by the shareholders.

Note 35 Confirmation of Trade Receivable, Trade Payables and Others

The Company has carried out exercise of balances confirmation of trade receivable, trade payable, advances given, and other
financial and non-financial assets and liabilities and have received confirmations in most of the cases. In few cases, such
balances are subject to confirmation/ reconciliation and their balances are stated as per books of accounts. Adjustments, if
any will be accounted for on confirmation/ reconciliation of the same, which in the opinion of the management will not have a
material impact.

In accordance with the principles given in Accounting Standard on Segment Reporting (AS-17) specified under Section 133 of
the Act, read with the Companies (Accounting Standards) Rules, 2021, as applicable, the Company has only reportable single
business segment of business i.e., manufacturing ERW MS PIPES and Trading of MS PIPES. As regards geographical segment,
company operates in single segment i.e., India only. Hence, no separate disclosure is given as perAS - 17 “Segment Reporting”.

In term of Accounting Standard on ‘Impairment of Assets’ (AS - 28) specified under Section 133 of the Act, read with the
Companies (Accounting Standards) Rules, 2021, as applicable, according to the assessment made by the management there is
no indication that the assets of the Company are impaired as on the Balance Sheet date. Accordingly, the Company has not
provided any impairment loss in the accounts during the year.

Note 43

There being no import, export and foreign exchange earning/outgo during the period under review so that additional
information pursuant to the provisions of Schedule III to the Act is not provided.

Explanation for change in the ratio by more than 25%

1. Due to increase in current assets.

2. Due to increase in average total equity.

3. Due to considerable increase in turnover vis-a-vis increase in trade receivables.

4. Due to decrease in trade payable and expenses payable.

5. Due to considerable increase in turnover.

6. Due to increase in earnings before exceptional item, tax and finance costs

Note 45 Additional Regulatory Disclosures as per Schedule III of Companies Act, 2013

1. Details of Benami Property held

No proceedings have been initiated or pending against the Company for holding any benami property under the
Prohibition of Benami Property Transactions Act, 1988 (45 of 1988) and the rules made thereunder as amended from time
to time.

2. Title deeds of immovable properties

The title deeds of all immovable properties disclosed in the financial statements included in property, plant and
equipment and capital work in progress are held in the name of the Company as at the balance sheet date.

3. Revaluation of property, plant and equipment

As per the Company’s accounting policy, property, plant and equipment and intangible assets are carried at historical
cost (less accumulated depreciation and impairment, if any), hence the revaluation related disclosures required as per
Additional Regulatory Information of Schedule III (revised) to the Act, is not applicable.

4. Security of current assets against borrowings

The Company has not sanctioned facilities from banks. As such there is no requirement of periodic returns to be filed by
the Company with such banks.

5. Wilful defaulter

The Company has no obligation for debt repayment and interest service yet. Wilful defaulter related disclosures required
as per Additional Regulatory Information of Schedule III (revised) to the Companies Act, is not applicable.

6. Relationship with Struck off companies

The Company has no transaction during the year with companies struck off under section 248 of the Companies Act, 2013
or section 560 of the Companies Act, 1956.

7. Registration of charges or satisfaction with Registrar of Companies

During the financial year, there is no delay by the Company in the registration of charges or satisfaction with Registrar of
Companies beyond statutory period except in one case which is disclosed as under:

8. Compliance with number of layers of companies

The Company has complied with number of layers prescribed under clause (87) of section 2 of the Act read with the
Companies (Restriction of number of layers) Rules, 2017.

9. Compliance with approved Scheme(s) of Arrangements

No Scheme of Arrangements has been approved by the Competent Authority in terms of sections 230 to 237 of the
Companies Act, 2013 during the year. Hence, the requirements of disclosure of effect of such Scheme of Arrangements in
the books of account in accordance with the Scheme and in accordance with accounting standards are not applicable.

10. Utilisation of Borrowed funds and share premium

(A) 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(s) or entity(ies), including foreign entities (Intermediaries) during
the year with the understanding (whether recorded in writing or otherwise) that the Intermediary shall:

(i) 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

(ii) provide any guarantee, security or the like to or on behalf of the Ultimate Beneficiaries.

(B) The Company has not received any fund from any person(s) or entity(ies), including foreign entities (Funding
Party) during the year with the understanding (whether recorded in writing or otherwise) that the Company shall:

(i) 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

(ii) provide any guarantee, security or the like to or on behalf of the Ultimate Beneficiaries.

Note 45 Additional Regulatory Disclosures as per Schedule III of Companies Act, 2013 (Contd.)

11. Crypto currency or Virtual Currency transactions

The Company has not operated in any crypto currency or Virtual Currency transactions.

12. Undisclosed Income

The Company has not surrendered or disclosed as income any transaction not recorded in the books of account during the
year in the tax assessments under the Income-tax Act, 1961.

13. Information on Details of Loans, Guarantees and Investments under Section 186 of the Act.

a. The Company has not granted any loan or advance in nature of loan to promoters, directors, key managerial
personnel and related parties as defined under the Act either severally or jointly with any other person that is (a)
repayable on demand; or (b) without specifying any terms or period of repayment. The Company has granted loans
to the following parties (other stated above):

Note 46

The Company has used accounting software for maintaining its books of account which has a feature of recording audit trail
(edit log) facility and the same has operated throughout the year for all relevant transactions recorded in the software, except
that audit trail feature is not enabled at the database level and certain master fields (Asset Master, Customer Master and
Vendor Master) for users with certain privileged access rights as it related to the accounting software''s. Further no instance of
audit trail feature being tampered with was noted in respect of the software. Additionally, the audit trail of prior year has been
preserved by the Company as per the statutory requirements for record retention.

Note 47

The figures for the corresponding previous year have been regrouped/reclassified, wherever considered necessary, to make
them comparable with current year classification.

The figures of the financial statements are represented as ? in Lakhs upto two decimal places leaving the scope of rounding up
variations.

The accompanying notes from an integral part of the standalone financial statements.

This is the standalone balance sheet referred to in our report of even date.

for Anu and Associates for and on behalf of the Board of Directors of Surani Steel Tubes Limited

Chartered Accountants

ICAI Firm Registration Number 019624N

CA. Parveen Kumar Vijay Singla Chetan Singla

FCA., Partner Managing Director Director

Membership Number 531655 DIN: 00156801 DIN: 00549795

UDIN: 25531655BMHVDU7540

Place: Chandigarh Pavni Singla Mohinder Singh

Date: May 29, 2025 Whole-time Director cum Company Secretary

Chief Financial Officer Membership Number: A21587

PAN: HFWPK7352P

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Mar 31, 2024

Note 2D Terms/ Rights attached to Equity Shares

The Company has only one class of equity shares having a par value of ? 10/- per share. Each holder of equity shares is entitled to one vote per share and ranks pari passu.

In the event of liquidation of the Company, the holders of equity shares will be entitled to receive any of the remaining assets of the Company after distribution of all preferential amounts. The distribution will be in proportion to the number of equity shares held by the shareholders.

The Company had allotted 7264036 convertible warrants to persons belonging to ''non-promoter'' category on July 04, 2023, for an issue price of ? 135/- per warrant. Out of total issue price, ? 67.50 (50% of the issue price) per warrant was received as the initial subscription amount at the time of allotment of the warrants. During the year ended March 31, 2024, out of 7264036 convertible warrants, the company had converted 2350000 warrants by receiving balance subscription amount ? 67.50 (50% of the issue price).

Working capital loan from HDFC bank

- Quarterly return or statements were in agreement with books of account.

- The loan stands repaid and closed as at the year end. The loan was secured by hypothecation of stock and receivables and security margin for bank guarantee and Letter of Credit. Collaterally secured by personal guarantees from property owners and Directors/ shareholders and deposits with bank of ? 50 Lakh lien marked in favour of bank.

NOTE 32 CONFIRMATION OF TRADE RECEIVABLE, TRADE PAYABLES AND OTHERS

The Company has carried out exercise of balances confirmation of trade receivable, trade payable, advances given, and other financial and non-financial assets and liabilities and have received confirmations in most of the cases. In few cases, such balances are subject to confirmation/ reconciliation and their balances are stated as per books of accounts. Adjustments, if any will be accounted for on confirmation/ reconciliation of the same, which in the opinion of the management will not have a material impact.

In the opinion of the Board of directors, assets other than property, plant and equipment and intangible assets have a value on realised in the ordinary course of the business at least equal to the amount at which they are stated in the Balance Sheet and provisions for all known / expected liabilities have been made.

In accordance with the principles given in Accounting Standard on Segment Reporting (AS-17) specified under Section 133 of the Act, read with the Companies (Accounting Standards) Rules, 2021, as applicable, the Company has only reportable single business segment of business i.e., manufacturing ERW MS PIPES and Trading of MS PIPES. As regards geographical segment, company operates in single segment i.e., India only. Hence, no separate disclosure is given as per AS - 17 "Segment Reporting".

NOTE 37 ACCOUNTING STANDARD 22 (AS-22) “ACCOUNTING FOR TAXES ON INCOME"

In compliance with the Accounting Standard-22 relating to "Accounting for Taxes on Income" the deferred tax liability of current year is charged/ (credited) to statement of profit and loss.

There are no Micro and Small Enterprises, to whom the Company owes dues as at March 31, 2024 (Nil as at March 31, 2023). This has been determined to the extent the status of such parties could be identified on the basis of information available with the Company.

NOTE 40 IMPAIRMENT OF ASSET

In term of Accounting Standard on ''Impairment of Assets'' (AS - 28) specified under Section 133 of the Act, read with the Companies (Accounting Standards) Rules, 2021, as applicable, according to the assessment made by the management there is no indication that the assets of the Company are impaired as on the Balance Sheet date. Accordingly, the Company has not provided any impairment loss in the accounts during the year.

NOTE 41

There being no import, export and foreign exchange earning/ outgo during the period under review so that additional information pursuant to the provisions of Schedule III to the Act is not provided.

NOTE 42 ANALYTICAL RATIOS (CONTD.)

1. The current assets are increased compared to increase in current liability, hence there is increase in ratio.

2. Debt service coverage ratio increase due to increase in EBITDA.

3. Return on equity ratio higher due to increase in net profit after tax.

4. It has reduced because of considerable increase in inventory vis-a-vis turnover.

5. Trade receivables turnover ratio increased due to lower trade receivable and increased turnover.

6. Trade payable turnover ratio increased due to lower trade payable and increased purchases.

7. It has reduced because of considerable increase in average working capital vis-a-vis turnover.

8. Due to increase in profit after tax for current year as compared to previous year.

9. Due to increase in earnings before tax and finance costs as compared to previous year.

NOTE 43 ADDITIONAL REGULATORY DISCLOSURES AS PER SCHEDULE III OF COMPANIES ACT, 20131. Details of Benami Property held

No proceedings have been initiated or pending against the Company for holding any benami property under the Prohibition of Benami Property Transactions Act, 1988 (45 of 1988) and the rules made thereunder as amended from time to time.

2. Title dees of immovable properties

The title deeds of all immovable properties disclosed in the financial statements included in property, plant and equipment and capital work in progress are held in the name of the Company as at the balance sheet date.

3. Revaluation of property, plant and equipment

As per the Company''s accounting policy, Property, Plant and Equipment and intangible assets are carried at historical cost (less accumulated depreciation and impairment, if any), hence the revaluation related disclosures required as per Additional Regulatory Information of Schedule III (revised) to the Companies Act, is not applicable.

4. Security of current assets against borrowings

The Company had borrowings from banks or financial institutions on the basis of security of current assets during the year. The quarterly returns or statements of current assets filed by the Company with banks or financial institutions are in agreement with the books of account. Hence, requirements of furnishing summary of reconciliation and reasons of material discrepancies do not apply.

5. Wilful defaulter

The Company had borrowings from banks or financial institutions or other lenders. However, the Company has not been declared a wilful defaulter at any time during the year or after the end of reporting period, but before the date when financial statements are approved or in an earlier period and the default has continued for the whole or part of the current year by any bank or financial institution or other lender.

6. Relationship with Struck off companies

The Company has no transaction during the year with companies struck off under section 248 of the Companies Act, 2013 or section 560 of the Companies Act, 1956.

7. Registration of charges or satisfaction with Registrar of Companies

During the financial year, there is no delay by the Company in the registration of charges or satisfaction with Registrar of Companies beyond statutory period except in one case which is disclosed as under:

8. Compliance with number of layers of companies

The Company is not having any subsidiary. Hence, requirement of compliance with the number of layers prescribed under clause (87) of section 2 of the Act read with Companies (Restriction on number of Layers) Rules, 2017 is not applicable.

9. Compliance with approved Scheme(s) of Arrangements

No Scheme of Arrangements has been approved by the Competent Authority in terms of sections 230 to 237 of the Companies Act, 2013 during the year. Hence, the requirements of disclosure of effect of such Scheme of Arrangements in the books of account in accordance with the Scheme and in accordance with accounting standards are not applicable.

NOTE 43 ADDITIONAL REGULATORY DISCLOSURES AS PER SCHEDULE III OF COMPANIES ACT, 2013 (CONTD.)## Utilisation of Borrowed funds and share premium

(A) 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(s) or entity(ies), including foreign entities (Intermediaries) during the year with the understanding (whether recorded in writing or otherwise) that the Intermediary shall:

(i) 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

(ii) provide any guarantee, security or the like to or on behalf of the Ultimate Beneficiaries.

(B) The Company has not received any fund from any person(s) or entity(ies), including foreign entities (Funding Party) during the year with the understanding (whether recorded in writing or otherwise) that the Company shall:

(i) 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

(ii) provide any guarantee, security or the like to or on behalf of the Ultimate Beneficiaries.

## Crypto currency or Virtual Currency transactions

The Company has not operated in any crypto currency or Virtual Currency transactions.

## Undisclosed Income

The Company has not surrendered or disclosed as income any transaction not recorded in the books of account during the year in the tax assessments under the Income-tax Act, 1961.

## Loans or advances - Additional disclosures

a. The Company has not granted any loan or advance in nature of loan to promoters, directors, key managerial personnel and related parties as defined under the Act either severally or jointly with any other person that is (a) repayable on demand; or (b) without specifying any terms or period of repayment.

b. Particulars of investments - Refer note 14 non-current investment.

c. There is no guarantee given or security provided by the Company.

The Company has used accounting software for maintaining its books of account which has a feature of recording audit trail (edit log) facility and the same has operated throughout the year for all relevant transactions recorded in the software, except that audit trail feature is not enabled at the database level and certain master fields (Asset Master, Customer Master and Vendor Master) for users with certain privileged access rights as it related to the accounting softwares. Further no instance of audit trail feature being tampered with was noted in respect of the software.

NOTE 45

The figures for the corresponding previous year have been regrouped/ reclassified, wherever considered necessary, to make them comparable with current year classification.

The figures of the financial statements are represented as ? in Lakhs upto two decimal places leaving the scope of rounding up variations.

The accompanying notes from an integral part of the financial statements.

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Mar 31, 2023

TERMS / RIGHTS ATTACHED TO EQUITY SHARES

The Company has only one class of equity shares having a par value of '' 10 per share. Each holder of equity shares is entitled to one vote per share and ranks pari passu.

In the event of liquidation of the Company, the holders of equity shares will be entitled to receive any of the remaining assets of the Company after distribution of all preferential amounts. The distribution will be in proportion to the number of equity shares held by the shareholders.

25 ADDITIONAL REGULATORY INFORMATION1 Revaluation of property, plant and equipment

The Company has not revalued any of the property, plant and equipment during the year.

2 Loans or advances - Additional disclosures

The Company has not granted any loan or advance in nature of loan to promoters, directors, key managerial personnel and related parties as defined under the Companies Act, 2013 either severally or jointly with any other person that is (a) repayable on demand; or (b) without specifying any terms or period of repayment.

b. Particulars of Investments - Refer Note 11 on Non-current Investments.

c. There is no guarantee given or security provided by the Company.

3 Undisclosed Income

The Company has not surrendered or disclosed as income any transaction not recorded in the books of account during the year in the tax assessments under the Income-tax Act, 1961.

4 Capital work-in-progress (CWIP)

The Company is not having any capital work-in-progress during the year or previous year.

5 Intangible assets under development

The Company is not having any intangible asset under development during the year or previous year.

6 Details of Benami Property held

No proceedings have been initiated or pending against the Company for holding any benami property under the Prohibition of Benami Property Transactions Act, 1988 (45 of 1988) and the rules made thereunder as amended from time to time.

7 Security of current assets against borrowings

The Company has borrowings from banks or financial institutions on the basis of security of current assets during the year. The quarterly returns or statements of current assets filed by the Company with banks or financial institutions are in agreement with the books of account. Hence, requirements of furnishing summary of reconciliation and reasons of material discrepancies do not apply.

8 Wilful defaulter

The Company has borrowings from banks or financial institutions or other lenders. However, the Company has not been declared a wilful defaulter at any time during the year or after the end of reporting period, but before the date when financial statements are approved or in an earlier period and the default has continued for the whole or part of the current year by any bank or financial institution or other lender.

9 Relationship with Struck off companies

The Company has no transaction during the year with companies struck off under section 248 of the Companies Act, 2013 or section 560 of the Companies Act, 1956.

10 Registration of charges or satisfaction with Registrar of Companies

There are no charges or satisfaction yet to be registered with Registrar of Companies beyond the statutory period.

11 Compliance with number of layers of companies

The Company is not having any subsidiary. Hence, requirement of compliance with the number of layers prescribed under clause (87) of section 2 of the Act read with Companies (Restriction on number of Layers) Rules, 2017 is not applicable

13 Compliance with approved Scheme(s) of Arrangements

No Scheme of Arrangements has been approved by the Competent Authority in terms of sections 230 to 237 of the Companies Act, 2013 during the year. Hence, the requirements of disclosure of effect of such Scheme of Arrangements in the books of account in accordance with the Scheme and in accordance with accounting standards are not applicable.

14 Utilisation of Borrowed funds and share premium

(A) 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(s) or entity(ies), including foreign entities (Intermediaries) during the year with the understanding (whether recorded in writing or otherwise) that the Intermediary shall:

(i) 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

(ii) provide any guarantee, security or the like to or on behalf of the Ultimate Beneficiaries.

(B) The Company has not received any fund from any person(s) or entity(ies), including foreign entities (Funding Party) during the year with the understanding (whether recorded in writing or otherwise) that the Company shall:

(i) 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

(ii) provide any guarantee, security or the like to or on behalf of the Ultimate Beneficiaries.

NOTE 26 : In compliance with the accounting standard-22 relating to "Accounting for taxes on Income" the deferred tax liability of current year is debited to Profit & Loss Account.

NOTE 27 : Balances ofunsecured loans, debtors, creditors for goods, creditors for expenses, loans and advances, advance to suppliers & advance from customers are subject to confirmation and reconciliation, if any . Such adjustments, in the opinion of the management, are not likely to be material & will be carried out as and when ascertained.In the opinion of the Board, the current assets, loans and advances are approximately of the value stated therein, if realized in the ordinary course of business. The provision for all known liabilities are adequate and not in excess of the amount reasonably necessary.

NOTE 28 : CAPITAL COMMITMENTS

Estimated amount of contracts remaining to be executed on capital account and not provided for is NIL(Previous Year NIL) (Advance paid upto March 2023 is NIL )(Previous Year NIL/-).

NOTE 31 : There are no Micro and Small Enterprises, to whom the Company owes dues as at 31.03.2023 (Nil as at 31.03.2022). This has been determined to the extent the status of such parties could be identified on the basis of information available with the Company.

NOTE 35 : IMPAIRMENT OF FIXED ASSETS

In accordance with the Accounting Standard (AS-28) on ''Impairment of Assets'' notified by Companies (Accounting Standards) Rules, 2006, the company has reassessed its fixed assets and is of the view that no further impairment/reversal is considered to be necessary in view of its expected realizable value.

NOTE : 36 DISCLOSURES PERSUANT TO ACCOUNTING STANDARD - 15 (REVISED) “EMPLOYEE BENEFITS".

(a) Disclosure of Present value of Obligation as per Gratuity Valuation Report of the Company as follows

(b) Details of funded & unfunded plans are as follows:

NOTE 37 : SEGMENT REPORTING

The company is engaged in single segment of business i.e. manufacturing ERW MS PIPES & Trading of MS PIPE. As regards geographical segment, company operates in single segment i.e. India only. Hence, no seperate disclosure is given as per AS - 17 "Segment Reporting".

NOTE 38 : As per the Shareholder''s consent obtained through Postal ballot and e-voting , Company has sold undertaking(Unit-II) along with Plant and Machinory, Land and buliding Located at survey No 107, 104 and 105 at Village Sujana Muvada, Sampa- Lavad Road, Tal : Dahegam, District: Gandhinagar, Gujarat-382315

NOTE 39 : There being no foreign exchange earning/outgo during the period under review so that Additional information pursuant to the provisions of Schedule III to the Companies Act, 2013 is not provided.

NOTE 40 : Previous year figures are regrouped and rearranged wherever necessary to compare with current year figures.

NOTE 41 : Figures are rounded off to the nearest rupee in lakhs.