A Oneindia Venture

Auditor Report of Vapi Enterprise Ltd.

Mar 31, 2025

Vapi Enterprise Limited Vapi.

Report on Audit of Standalone Financial Statements Opinion

We have audited the financial statements of Vapi Enterprise Limited (the “Company”) which comprise the Balance sheet as at 31 March 2025, and the statement of profit and loss (including other comprehensive income), statement of changes in equity 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 financial statements give the information required by the Companies Act, 2013 in the manner so required and give a true and fair view in conformity with the Indian Accounting Standards prescribe under section 133 of the Act read with the Companies (Indian Accounting Standards) Rules 2015, as amended, (“Ind AS”) and accounting principles generally accepted in India, of the state of affairs of the Company as at 31 March 2025, and its profit, total comprehensive profit its cash flow and changes in equity for the year ended on that date.

Basis for opinion

We conducted our audit in accordance with the Standards on Auditing (SAs), specified under section 143(10) of the Companies Act 2013. Our responsibilities under the Standards are further described in the ‘Auditor’s Responsibilities for the Audit of the Financial Statement’ 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 ethical requirements that are relevant to our audit of the financial statements under the provisions of the Companies Act, 2013 and the Rules there under, and we have fulfilled our 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.

Emphasis of Matters Paragraph :

Without qualifying our opinion, we draw your serious attention to the followings:

i. The following accounting standard is not complied by the company:

a. Indian Accounting Standard (Ind AS-19) on “Employee Benefits”; regarding nonprovisioning of employee benefits.

ii. We are unable to form an opinion about the obligations of:

a. Electricity deposit having balance of Rs. 2,14,16,973/- as on the period ended 31st March, 2025, the accrued interest income is not accounted for as the amount is paid under protest and management is not sure about the outcome of the appeal. (Refer Note No 20)

b. The management has sold the factory land and they have informed us that they are in the process of starting a new business from the proceeds of sale of land. But yet, no detailed plan or business type is informed to us by management. The company is exploring the business, new markets, projects and partnerships. Accordingly, basis the explanation, we are of the opinion that there is no significant doubt on the going concern assumption in the preparation of the financial statements. (Refer Note No 22)

c. Following is the obligation on which we are unable to form an opinion:

Particulars

Amount

There are trade payable / other payable of which is still unpaid by

Rs.4,76,083 /-

the entity till year end 31st March, 2025.

The effect of the above on assets and liabilities, as well as Profit and Reserves is not ascertainable.

iii. Long Term Inter Corporate Borrowings:

Loan of Rs. 47,48,076/-were taken from company in which one of the Directors of the Company is a related party. We have obtained confirmation of such loan, and based on information and explanation provided by the management such loans are payable. Accordingly, we have not modified our opinion in this regard.

iv. Security deposit of Rs. 12,00,000/- :

This security deposit is towards premises taken on rent from M.K. Principal Pvt. Ltd. in year 2013. This Deposit is related to the DGVCL Appeal case discussed at point 20 of the notes to accounts. As informed by the management, the said amount are payables related to operations of the Company and will be settled upon conclusion of the case, this balance funds shall be released. Accordingly, we have not modified our opinion in this regard.

Other Information

The Company’s Board of Directors is responsible for the other information. The other information comprises the information included in the Annual 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 in the audit or otherwise appears to be materially misstated. If, based on the work we have performed, we conclude that there is no material misstatement of this other information, we are required to report that fact.

We have nothing to report in this regard.

The Company’s Board of Directors is responsible for the matters stated in Section 134(5) of the Companies Act, 2013 with respect to the preparation of these financial statements that give a true and fair view of the financial position and financial performance, including other comprehensive income, cash flows and changes in equity of the Company in accordance with the Ind AS and other accounting principles generally accepted in India. This responsibility also includes maintenance of adequate accounting records in accordance with the provisions of the Act for safeguarding 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, the board of director is responsible for assessing the company’s ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless the Board of directors either intends to liquidate the company or to cease operations, or has no realistic alternative but to do so.

The 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 objective 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 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.

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.

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

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 Section 143(11) of the Act, 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 accounts as required by law, have been kept by the Company so far as it appears from our examination of the books;

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

(d) In our opinion, the financial statements comply with Ind AS specified under Section 133 of the Act.

(e) On the basis of the written representations received from the directors as on 31 March 2025 taken on record by the Board of Directors, none of the directors is disqualified as on 31 March 2025 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”

(g) 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, no funds (which are material either individually or in the aggregate) 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 or entity, including foreign entity (“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, no funds (which are material either individually or in the aggregate) have been received by the Company from any person or entity, including foreign entity(“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;

(c) based on the 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 misstatement.

v. The Company has not declared or paid any dividend during the financial year.

vi. Based on our examination carried out in accordance with the Implementation Guidance on Reporting on Audit Trail under Rule 11(g) of the Companies (Audit and Auditors) Rules,2014 (Revised 2025 Edition) issued by the Institute of Chartered Accountants of India, which included test checks, we report that the company have used an 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 stating from 14.09.2024 for all relevant transactions recorded in the software. Further, during the course of our audit, we did not come across any instance of audit trail feature being tampered with.

(h) With respect to the matter to be included in the Auditors’ Report under Section 197(16) of the Act, in our opinion and according to the information and explanations given to us, the limit prescribed by section 197 for maximum permissible managerial remuneration is not applicable to a private limited company.

Other Matter

The financial statements of The Company for the year ended March 31, 2024 were audited by another auditor who has expressed a qualified opinion on those financial statements vide their report dated 29 May, 2024.

For M I Shah And Co

Chartered Accountants

ICAI Firm Registration No: 119025W

SD/-

CA Manish I. Shah

Proprietor

Membership No. 106342

Place: Vapi

Date: 29-05-2025 ICAI UDIN: 25106342BMGXUE9987


Mar 31, 2024

Vapi Enterprise Limited (Formerly known as Vapi Paper Mills Limited)

Report on the audit of the Standalone Financial Results Opinion

We have audited the accompanying standalone quarterly financial results of Vapi Enterprise Limited (Formerly known as Vapi Paper Mills Limited) for the quater ended 31st March,2024 and the year to date results from the period 1st April 2023 to 31st March 2024,attached herewith, being submitted by the company pursuant to the requirement of regulation 33 of the SEBI (Listing Obligation and Disclosure Requirement) Regulations, 2015 as amended ("Listing Regulations").

In our opinion and to the best of our information and according to the explanations given to us these standalone financial results:

I. are presented in accordance with the requirements of Regulation 33 of the Listing Regulations in this regard; and

II. Give a true and fair view in conformity with the recognition and measurement principles laid down in the applicable accounting standards and other accounting principles generally accepted in India of the net profit/loss and other comprehensive income and other financial information for the quarter ended 31St March, 2024 as well as the year to date results for the period from 1st April 2023 to 31st March 2024.

Basis for Qualified Opinion

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

i. In our opinion, the following accounting standards are not complied by the company:

a. Indian Accounting Standard (Ind AS-19) on "Employee Benefits"; regarding nonprovisioning of employee benefits

b. Indian Accounting Standard (Ind AS-105) on "Non-current Assets Held for Sale and Discontinued Operations"

c. Indian Accounting Standard (Ind AS-12) on "Income tax".

The effect of the above on assets and liabilities, as well as loss and reserves is not ascertainable.

ii. We are unable to form an opinion about the obligations of:

a. Electricity deposit having balance of Rs. 2,14,16,973/- as on the period ended on 31st March, 2024, the accrued interest income is not accounted as the amount is paid under protest and management is not sure about the outcome of the appeal.

b. The management has sold all the lands and they are of the opinion of starting a new business from the proceeds of sale of land, but yet no detailed plan or business type is informed to us by management. Hence there is significant doubt on the going concern of the entity.

c. Following are the obligation we are unable to form an opinion on:

Sr.No

Particulars

Amount

1.

Long term borrowings from inter corporate which is subject to confirmations.

Rs.47,48,076/-

2.

There are trade payable / other payable of which is still unpaid by the entity till year end 31st march 2024.

Rs.4,76,083 /-

3.

Entity has closed down the operation and sold all the assets and demolished the existing structure but yet not refunded the security deposit of M.K Principal Pvt LTD (electricity deposit) till year end 31st March 2024

Rs. 12,00,000/-

The effects of the matters referred to Para above on assets and liabilities, as well as Losses and reserves could not be ascertainable.

Management''s Responsibilities for the Standalone Financial Results

These quarterly financial results as well as the year to date standalone financial results have been prepared on the basis of the interim financial statements. The Company''s Board of Directors are responsible for the preparation of these financial results that give a true and fair view of the net profit/loss and other comprehensive income and other financial information in accordance with the recognition and measurement principles laid down in Indian Accounting Standard 34, ''Interim Financial Reporting'' prescribed under Section 133 of the Act read with relevant rules issued thereunder and other accounting principles generally accepted in India and in compliance with Regulation 33 of the Listing Regulations. This responsibility also includes maintenance of adequate accounting records in accordance with the provisions of the Act for safeguarding of the assets of the Company and for preventing and detecting frauds and other irregularities; selection and application of appropriate accounting policies; making judgments and estimates that are reasonable and prudent; and design, implementation and maintenance of adequate internal financial controls that were operating effectively for ensuring the accuracy and completeness of the accounting records, relevant to the preparation and presentation of the standalone financial results that give a true and fair view and are free from material misstatement, whether due to fraud or error.

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

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

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

Our objectives are to obtain reasonable assurance about whether the standalone financial results 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 standalone financial results.

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 standalone financial results, 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, but not for the purpose of expressing an opinion on the effectiveness of the company''s internal control.

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

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

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

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.

For Chirag N Shah and Associates, Chartered Accountants,FRN : 118215W

CHIRAG i- » chirag

DN: cn=CHIRAG NAVNIT SHAH,

NAVNIT SRS5—,„,

QMAIJ 395a''aN5Ubma?eirdta5992367b6C0cC6991b52bb3819

6ce3f7668fod97578327

Chirag Shah Partner,

Membership No: 105145 Place of Signing: Mumbai Date: 29-05-2024 UDIN: 24105145BKFUVX3475


Mar 31, 2014

We have audited the accompanying financial statements of Vapi Enterprise Limited ("the Company- Formerly Known as Vapi Paper Mills Limited"), which comprise the Balance Sheet as at March 31, 2014, and the Statement of Profit and Loss and Cash Flow Statement for the year ended March 31, 2014, and a summary of significant accounting policies and other explanatory information.

Management''s Responsibility for the Financial Statements

The Company''s Management is responsible for 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 Standards notified under the Companies Act, 1956 (the Act) read with the General Circular 15/2013 dated 13th September, 2013 of the Ministry of Corporate Affairs in respect of Section 133 of the Companies Act, 2013 and in accordance with the accounting principles generally accepted in India. This responsibility includes the design, implementation and maintenance of internal control relevant to the preparation and fair presentation of the 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 Accountants 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 disclosures and amounts 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 statements, 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 statements in order to design audit procedures that are appropriate in the circumstances but not for the purpose of expressing an opinion on the effectiveness of the Company''s internal control.

An audit also includes evaluating the appropriateness of accounting policies used and the reasonableness of the accounting estimates made by 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.

Basis for Qualified Opinion

i. In our opinion, the following accounting standards are not complied by the company:

1. Accounting Standard (AS-15) on "Employee Benefits"; regarding non provisioning of employee benefits

2. Accounting Standard (AS-24) on "Discontinuing Operations"

3. Accounting Standard (AS-28) on "Impairment of Assets".

4. Accounting Standard (AS-22) on "Deferred tax".

The effect of the above on assets and liabilities, as well as loss and reserves is not ascertainable.

ii. We are unable to form an opinion about the realisability of:

a. Balance of Rs.31,09,647/- of long term trade payables is subject to confirmation and adjustment, if any, required upon such confirmations are not determinable.

b. Balance of Rs.54,75,000/- of Long term borrowings from others is subject to confirmation and adjustment, if any, required upon such confirmations are not determinable.

The effects of the matters referred to para above on assets and liabilities, as well as profit and reserves could not be ascertainable.

Qualified Opinion

In our opinion and to the best of our information and according to the explanations given to us, (subject to the possible effects of the matter described in the Basis for Qualified Opinion paragraph), 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:

1) in the case of the Balance Sheet, of the state of affairs of the Company as at March 31, 2014;

2) in the case of the Statement of Profit and Loss, of the profit for the year ended on that date; and

3) in the case of the Cash Flow Statement, of the cash flows for the year ended on that date.

Emphasis of Matter:

We draw attention that the Company''s accumulated losses as on March 31, 2014 were Rs.15,90,82,708/- as against paid up capital and reserves of Rs.9,02,08,547/-. Hence, Company''s net worth is negative. However, the accounts are prepared on the basis that Company is a going concern. In our opinion, the ability of the Company to continue as a going concern is dependent upon the surplus that may be generated out of present activity as well as promoters bringing in funds to finance losses. Our opinion on this matter is not qualified.

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 under provisions of section 227(3) of the Companies Act, 1956, 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 our audit;

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

c) The Balance Sheet, Statement of Profit and Loss and 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 Cash Flow Statement comply with the accounting standards notified under the Act read with the General Circular 15/2013 dated 13th September, 2013 of the Ministry of Corporate Affairs in respect of Section 133 of the Companies Act, 2013 subject to those mentioned under "basis for qualified opinion".

e) On the basis of written representations received from the directors as on March 31, 2014, taken on record by the Board of Directors, none of the directors is disqualified as on March 31, 2014, from being appointed as a director in terms of Section 274(1)(g) of the Act.

ANNEXURE TO AUDITORS'' REPORT

[Referred to in paragraph 1 of our report on Other Legal and Regulatory Requirements]

(i) In respect of fixed assets:

a. The Company has not maintained proper records showing full particulars including quantitative details and situation of Fixed Assets.

b. The fixed assets have not been physically verified by the management. In the absence of physical verification, we are not in a position to comment on the discrepancies, if any, between physical and book balances and the impact thereof.

c. In our opinion, the Company has not disposed off substantial part of fixed assets during the year, and the going concern status of the company is not affected.

(ii) In respect of Inventories:

a. Since the company is not having inventory, the para 4(ii)(a) of the order is not applicable.

b. Since the company is not having inventory, the para 4(ii)(b) of the order is not applicable.

c. Since the company is not having inventory, the para 4(ii)(c) of the order is not applicable.

(iii) In respect of loans, secured or unsecured, granted or taken by the company to/from companies, firms or other parties covered in the register maintained under Section 301 of the Companies Act,1956

a. The company has not granted any loan to companies, firms or other parties covered in the register maintained under section 301 of the Companies Act, 1956 and therefore, reporting requirement:

1. Under clause 4(iii)(a) of the order is not applicable to the company.

2. Under clause 4(iii)(b) of the order is not applicable to the company.

3. Under clause 4(iii)(c) of the order is not applicable to the company.

4. Under clause 4(iii)(d) of the order is not applicable to the company.

b. The company has taken loan from two companies and two individuals listed in the register maintained under section 301 of the Companies Act, 1956. The maximum amount involved during the year was Rs. 8,33,52,967/- and the year- end balance of loans taken from such parties was Rs. 8,17,24,555/- c. In our opinion, the rate of interest and other terms and conditions on which loans have been taken from companies, firms or other parties listed in the register maintained under section 301 of the Companies Act, 1956 are not, prima facie, prejudicial to the interest of the company. d. In respect of loans taken by the company the principal amount is repayable on demand. As per information and explanation given to us, no demand of the interest/principal amount has been made during the financial year.

(iv) In our opinion and according to the information and explanations given to us, there are adequate internal control procedures commensurate with the size of the company and the nature of its business with regard to purchases of inventory, fixed assets and with regard to the sale of goods and services. During the course of our audit, we have not observed any continuing failure to correct major weaknesses in internal controls.

(v) In respect of the contracts or arrangements referred to in section 301 of the Companies Act, 1956:

a. According to the information and explanations given to us, we are of the opinion that the transactions that need to be entered into the register maintained under section 301 of the Companies Act, 1956 have been so entered.

b. In our opinion and according to the information and explanations given to us, transactions made in pursuance of such contracts or arrangements entered in the register maintained under section 301 of the Companies Act, 1956 and exceeding the value of Rs.5,00,000/- in respect of any party during the year have been made at prices which are reasonable having regard to market prices prevailing at the relevant time or compared to prices at which purchases were made from other parties.

(vi) According to information and explanations given to us, the company has not accepted any deposits from public during the concerned financial year. However, in respect of unsecured loans from parties obtained in earlier years and outstanding as on March 31, 2014, the Company has not complied with the provisions of sections 58A of the Companies Act, 1956 and the Companies (Acceptance of Deposit) Rules, 1975 (hereinafter referred to as Rules), as mentioned hereunder:

a. The Company has not maintained liquid assets as required by Rule 3A of the Rules.

b. The Company has not filed statement in lieu of advertisements with the Registrar of Companies under Rule 4A (1) of the Rules, and

c. The Company has not filed returns of deposits with the Registrar of Companies, under Rule 10 of the Rules.

Further, we are informed that no Order has been passed by the Company Law Board (''the CLB'') or National Company Law Tribunal (''the NCLT'') or Reserve Bank of India (''the RBI'') or any Court or any other Tribunal.

(vii) The Company does not have formal internal audit system.

(viii) As per the information and explanation given to us, the company is not required to maintain cost records pursuant to the Companies (Cost Accounting Records) Rules, 2011 prescribed by the Central Government under Section 209 (1) (d) of the Companies Act, 1956.

(ix) In respect of statutory dues:

a. In our opinion and according to the information and explanation given to us, the company has been generally regular in depositing undisputed statutory dues including Provident Fund, Sales Tax, Income Tax, Wealth Tax, Investor Education and Protection Fund, Custom duty, Excise duty, and other statutory dues as may be applicable to the company except in case of Professional tax . Income Tax deducted at Source and Service Tax dues there were paid late. The companies contribution towards profession tax is not provided for and the staff profession tax of Rs.80,715/- is outstanding for a period more than six months from the date they become payable. b. According to the information and explanation given to us, there are no dues of sale tax, income tax, customs duty, wealth tax, excise duty and cess which have not been deposited on account of any dispute.

(x) In our opinion, the company has been registered for a period more than five years, the accumulated losses of the company are more than fifty percent of its net worth and it has not incurred cash loss in the current year and in the immediately preceding financial year.

(xi) In our opinion and according to the information and explanations given to us, the company has not raised loans from financial institution or bank neither issued debentures therefore the reporting requirement of clause 4(xi) of the Order is not applicable.

(xii) The company has not granted loans and advances on the basis of security by way of pledge of shares, debentures and other securities. Therefore, the reporting requirement under clause 4(xii) the Order is not applicable to the company.

(xiii) In our opinion, the company is not a chit fund or a nidhi mutual benefit fund / society. Therefore the reporting requirement under clause 4(xiii) the Order is not applicable to the company.

(xiv) In our opinion, the company is not dealing in or trading in shares, securities, debentures and other investments. Accordingly, the reporting requirement under clause 4(xiv) the Order is not applicable to the company.

(xv) We are informed that, the company has not given any guarantee for loans taken by others from banks or financial institutions. Accordingly, the reporting requirement under clause 4(xiv) the Order is not applicable to the company.

(xvi) According to the information and explanations given to us, the company has not availed any term loans during the year. Accordingly, the reporting requirement under clause 4(xvi) of the order is not applicable to the company.

(xvii) According to the information and explanations given to us and on an overall examination of the balance sheet of the company, we report that no funds raised on short term basis have been used for long term investment.

(xviii)According to the information and explanations given to us, the company has not made any preferential allotment of shares to parties and companies covered in the register maintained under section 301 of the Companies Act, 1956.

(xix) According to the information and explanations given to us, the company has not issued debentures during the year.

(xx) According to the information and explanations given to us, the company has not raised any money by way of public issue during the year.

(xxi) According to the information and explanations given to us, no fraud on or by the company has been noticed or reported during the year.

For Chirag N Shah & Associates Chartered Accountants FRN.118215W

Sd/- Hetal C. Shah Partner Membership No: 111610 Place: Mumbai Date : 31st May, 2014, 2014


Mar 31, 2012

1. We have audited the attached Balance Sheet of VAPI PAPER MILLS LIMITED as at 31st March 2012, and also Statement of Profit and Loss for the year ended on that date annexed thereto and the cash flow statements for the year ended on that date. 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.

2. We conducted our audit in accordance with 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 statement presentation. We believe that our audit provides a reasonable basis for our opinion.

3. 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 Companies Act, 1956, we enclose in the Annexure, a statement on the matters specified in paragraphs 4 and 5 of the said Order.

4. The Company's accumulated losses as on March 31, 2012 were Rs 146,240 thousands as against paid up capital and reserves of Rs 90,209 thousands. Hence Company's net worth is negative. However the accounts are prepared on the basis that Company is a going concern. In our opinion the ability of the Company to continue as a going concern is dependent upon the surplus that may be generated out of present activity as well as promoters bringing in funds to finance losses as mentioned in note no. 23.

5. Subject to the foregoing and further to our comments in the Annexure referred to above, we report that:

(i) 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;

(ii) 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. The Company has no branches.

(iii)The Balance Sheet, Profit & Loss Account and Cash flow statement dealt with by this report are in agreement with books of account

(iv) in our opinion, the balance sheet, statement of profit and loss and cash flow statement dealt with by this report comp with the accounting standards referred to in sub-section (3C) of section 212 of the Companies Act 1956 except: section 211I

a) Accounting Standard (AS-15) on "Employee Benefits"; regarding non provisioning of employee benefits (Refer Note 26).

b) Accounting Standard (AS-17) on "Accounting for Segment Reporting."

C) Accounting Standard (AS-24) on "Discounting Operations" (Refer Note 35).

d) Accounting Standard (AS-28J on "Impairment of Assets".

The effect of the above on assets and liabilities, as well as loss and reserves is not ascertainable. well loss and

(v) On the basis of written representations received from the directors as on 31st March 2012 and taken on record by the Board of Directors, we report that none of Directors is disqualified as on 31st March 2012 from being appointed as a director in terms of Clause (g) of sub Section (1) of Section 274 of the Companies Act 1956.

(vi) a) We are unable to form an opinion about the realisability or otherwise of long term loans and advances of Rs. 9,251 thousands as no payment is received since long time and the confirmation of balances have not been obtained from the parties.

b) We are unable to form an opinion about the realisability or otherwise of trade receivables of Rs. 6,053 thousands as no payment is received since long time and the confirmation of balances have not been obtained from the parties.

c) We are unable to form an opinion about the realisability or otherwise long term trade advances to other suppliers of Rs. 4,750 thousands as no services are rendered or payment is received since long time and the confirmation of balances have not been obtained from the parties.

d) Balance of Rs. 1,000 thousands of Share Application Money is sublet confirmation and adjustment, if any required upon such confirmations are not determinable.

e) Balance of Rs. 4,964 thousands of long term trade payables is subject confirmation and adjustment, if any required upon such confirmations are not determinable.

f) Balance of Rs. 1190 thousands of Trade Deposits is subject confirmation and adjustment if any required upon such confirmations are not determinable.

(vii) The effect of the matters referred to para (vi) above on assets and liabilities, as well as loss and reserves could not be quantified.

(viii) Subject to our remarks in Para 4, 5 (iv), (vi) and (vii) above, in our opinion and to the best of our information and according to the explanations given to us, the Said accounts give the information required by the Companies Act, 1956, 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 of the state of affairs of the Company as at 31 st March, 2012

b) in the case of statement of Profit & Loss of the Profit for the year ended on that date; and

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

ANNEXURE TO AUDITORS' REPORT (Referred to in paragraph (3) of our report of even date)

(i) (a) The Company has not maintained proper records showing full particulars including quantitative details and situation of Fixed Assets.

(b) The fixed assets have not been physically verified by the management. In the absence of physical verification, we are not in a position to comment on the discrepancies, if any, between physical and book balances and the impact thereof.

(c) In our opinion, the Company has not disposed off substantial part of fixed assets during the year.

(ii) (a) The inventory has been physically verified at regular intervals during the year by the management, In our opinion this frequency of verification is reasonable.

(b) The procedures of physical verification of inventories followed by the management are reasonable and adequate in relation to the size of the company and the nature of its business.

(c) The company is maintaining proper records of inventory. As informed to us, the discrepancies noticed on verification between the physical stocks and the book records were not material.

(iii) (a) The company has not granted any loan to companies, firms or other parties covered in the register maintained under section 301 of the Companies Act, 1956 and therefore, reporting requirement under clause 4(iii} (a) to (d) of the Order are not applicable to the company.

(b) The company had taken loan from two companies and four individuals listed in the register maintained under section 301 of the Companies Act, 1956. The maximum amount involved during the year was Rs. 84,254 thousands and the year-end balance of loans taken from such parties was Rs. 82,932 thousands.

(c) In our opinion, the rate of interest and other terms and conditions on which loans have been taken from companies, firms or other parties listed in the register maintained under section 301 of the Companies Act, 1956 are not, prima facie, prejudicial to the interest of the company.

(d) In respect of loans taken by the company the principal amount is repayable on demand.

(iv) In our opinion and according to the information and explanations given to us, there are adequate internal control procedures commensurate with the size of the company and the nature of its business with regard to purchases of inventory, fixed assets and with regard to the sale of goods and services. During the course of our audit, we have not observed any continuing failure to correct major weaknesses in internal controls.

(v) (a) According to the information and explanations given to us we are of the opinion that the transactions that need to be entered into the register maintained under section 301 of the Companies Act 1956 have been so entered.

(b) In our opinion and according to the information and explanations given to us, transactions made in pursuance of such contracts or arrangements entered in the register maintained under section 301 of the Companies Act, 1956 and exceeding the value of Rs 5,00,000/- in respect of any party during the year have been made at prices which are reasonable having regard to market prices prevailing at the relevant time or compared to prices at which purchases were made from other parties.

(vi) During the year the Company has not accepted deposits from public However in respect of unsecured loans from parties obtained in earlier years and outstanding as on March 31, 2012, the Company has not complied with the provisions of sections 58 A of the Companies Act 1956 and the Companies (Acceptance of Deposit) Rules, 1975 (hereinafter referred to as Rules), as mentioned hereunder:

a) The Company has not maintained liquid assets as required by Rule 3A of the Rules.

b) The Company has not filed statement in lieu of advertisements with the Registrar of Companies under Rule 4A (1) of the Rules, and

c) The Company has not filed returns of deposits with the Registrar of Companies, under Rule 10 of the Rules.

Further, we are informed that no Order has been passed by the Company Law Board ('the CLB') or National Company Law Tribunal ('the NCLT') or Reserve Bank of India ('the RBI') or any Court or any other Tribunal.

(vii) The Company does not have formal internal audit system.

(viii) The company has not maintained cost records pursuant to the Companies (Cost Accounting Records) Rules, 2011 prescribed by the Central Government under Section 209 (1) (d) of the Companies Act,

(ix) (a) In our opinion and according to the information and explanation given to us, the company has been generally regular in undisputed statutory dues including Provident Fund, Sales Tax, Income Tax Wealth Tax, Investor Education and Protection Fund, Custom duty Excise duty, Professional tax and other statutory dues as may be applicable to the company except in case of Income Tax deducted at Source and Service Tax dues where there was delay.

(b) According to the information and explanations given to us no undisputed amounts payable in respect of income tax, sales tax, wealth tax, service tax and custom duty were in arrears as at March 31, 2012 for a period of more than six months from the date they became payable.

(c) According to the information and explanation given to us there are no dues of sale tax, income tax, customs duty, wealth tax, excise duty and cess which have not been deposited on account of any dispute. y

(x) In our opinion, the accumulated losses of the company are m ore than fifty percent of its net worth and it has incurred cash loss both in the current year and in the immediately preceding financial year.

(xi) In our opinion and according to the information and explanations given to us, the company has not raised loans from financial institution or bank neither issued debentures therefore the reporting requirement of clause 4(xi) of the Order is not applicable.

(xii) The company has not granted loans and advances on the basis of security by way of pledge of shares, debentures and other securities Therefore, the reporting requirement under clause 4 (xii) the Order is not applicable to the company.

(xiii) In our opinion, the company is not a chit fund or a nidhi mutual benefit fund / society. Therefore the reporting requirement under clause 4(xiii) the Order is not applicable to the company.

(xiv) In our opinion, the company is not dealing in or trading in shares securities debentures and other investments. Accordingly, the reporting requirement under clause 4(xiv) the Order is not applicable to the company.

(xv) We are informed that, the company has not given any guarantee for loans taken by others from banks or financial institutions. Accordingly, the reporting requirement under clause 4(xiv) the Order is not applicable to the company.

(xvi) According to the information and explanations given to us, the company has not availed any term loans during the year.

(xvii) According to the information and explanations given to us and on an overall examination of the balance sheet of the company, we report that no funds raised on short term basis have been used for long term investment.

(xviii) According to the information and explanations given to us, the company has not made any preferential allotment of shares to parties and companies covered in the register maintained under section 301 of the Companies Act, 1956.

(xix) According to the information and explanations given to us, the company has not issued debentures during the year.

(xx) According to the information and explanations given to us, the company has not raised any money by way of public issue during the year.

(xxi) According to the information and explanations given to us, no fraud on or by the company has been noticed or reported during the year.



For Manubhai & Co. Chartered Accountants Firm Reg. No. : 106041W

(K. M. Patel) Partner Membership No. 45740

Place: Ahmedabad Date :29th June, 2012


Mar 31, 2010

1. We have audited the attached Balance Sheet of VAPI PAPER MILLS LIMITED, as at 31st March 2010, and also Profit and Loss Account for the year ended on that date annexed thereto and the cash flow statements for the year ended on that date. 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.

2. We conducted our audit in accordance with 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 statement presentation. We believe that our audit provides a reasonable basis for our opinion.

3. As required by the Companies (Audi tor s K.S port) Order, 2003 issued by the Central Government of India in terms of sub-section (4A) of section 227 of the Companies Act, 1956, we enclose in the Annexure, a statement on the matters specified in paragraphs 4 and 5 of the said Order.

4. Further to our comments in the Annexure referred to above, we report that:

(i) We have obtained all the information and explanations which to the best of our knowledge and behef were necessary for the purposes of our audit;

(ii) 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. The Company has no branches.

(iii) The Balance Sheet, Profit & Loss Account and Cash flow statement dealt with by this report are in agreement with books of account;

(iv) In our opinion, the balance sheet, profit and loss account and cash flow statement dealt with by this report comply with the accounting standards referred to in sub- section (3C) of section 211 of the Companies Act, 1956 except Accounting Standard (AS-15) on "Employee Benefits"; Accounting Standard (AS-17) on "Accounting for Segment Reporting"; AS -11 on "Effects of changes in foreign exchange rates — revised 2003" and Accounting Standard (AS-24) on "Discontinuing Operations" notified under company Accounting SfrmdaM Rules, 2006 the effect of the same on loss, assets and liabili ascertainable

(v) On the basis of written representations received from the directors, as on 31 st March 2010 and taken on record by the Board of Directors, we report that none of directors is disqualified as on 31st March 2010 from being appointed as a director in terms of Clause (g) of sub Section (1) of Section 274 of the Companies Act, 1956.

(vi) We are unable to form an opinion about readability or otherwise of loans and advances ofRs. 9,250 thousand as no payment was received since long time and the confirmation of balances have not been obtained from the said party. The effect of the same on loss, reserves and assets could not be quantified.

(vii) Subject to our comments in Para (vi) above, in our opinion and to the best of our information and according to the explanations given to us, the said accounts give the information required by the Companies Act, 1956, 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 of the state of affairs of the Company as at 31st March, 2010

b) in the case of Profit & Loss Account of the Loss for the year ended on that date; and

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



ANNEXURE TO AUDITORSREPORT [Referred to in paragraph (3) of our report of even date]

(i) (a) The Company has not maintained proper records showing full particulars including quantitative details and situation of Fixed Assets.

(b) We are informed by the management that all fixed assets were physically verified during the year. As informed to us, no material discrepancies have been noticed on such verification as compared to records maintained by the company.

(c) During the year, the Company has disposed off substantial part of its assets. However this has not affected going concern.

(ii) (a) The inventory has been physically verified at regular intervals during the year by the management. In our opinion this frequency of verification is reasonable.

(b) The procedures of physical verification of inventories followed by the management are reasonable and adequate in relation to the size of the company and the nature of its business.

(c) The company is maintaining proper records of inventory. As informed to us, the discrepancies noticed on verification between the physical stocks and the book records were not material.

(iii) (a) The company has not granted any loan to companies, firms or other parties covered in the register maintained under section 301 of the Companies Act, 1956 and therefore, the provisions of clause 4(iii) (a) to (c) of the Companies (Auditors Report) Order,2003 are not applicable to the company.

(b) The company had taken loan from two companies and four individuals listed in the register maintained under section 301 of the Companies Act, 1956. The maximum amount involved during the year was Rs. 284.47 lacs and the year-end balance of loans taken from such parties was Rs. 870.56 lacs.

(c) In our opinion, the rate of interest and other terms and conditions on which loans have been taken from companies, firms or other parties listed in the register maintained under section 301 of the Companies Act, 1956 are not, prima facie, prejudicial to the interest of the company.

(d) In respect of loans taken by the company the principal amount is repayable on demand.

(iv) In our opinion and according to the information and explanations given to us, there are adequate internal control procedures commensurate with the size of the company and the nature of its business with regard to purchases of inventory, fixed assets and with regard to the sale of goods and services. During the course of our audit, we have not observed any continuing failure to correct major weaknesses in internal controls.

(v) (a) According to the information and explanations given to us, we are of the opinion that the transactions that need to be entered into the register maintained under section 301 of the Companies Act, 1956 have been so entered.

(b) In our opinion and according to the information and explanations given to us, there were no transactions made in pursuance of contracts or arrangements entered in the register maintained under section 301 of the Companies Act, 1956 and exceeding the value of rupees five lakhs in respect of any party during the year.

(vi) During the year the Company has not accepted deposits from public. However in respect of unsecured loans from parties obtained in earlier years and outstanding as on March 31, 2010, the Company has not complied with the provisions of sections 58A of the Companies Act, 1956 and the Companies (Acceptance of Deposit) Rules, 1975 (hereinafter referred to as Rules), as mentioned hereunder:

a) The Company has not maintained liquid assets as required by Rule 3A of the Rules.

b) The Company has not filed statement in lieu of advertisements with the Registrar of Companies under Rule 4 A (1) of the Rules, and

c) The Company has not filed returns of deposits with the Registrar of Companies, under Rule 10 of the Rules.

Further, we are informed that no Order has been passed by the Company Law Board (the CLB) or National Company Law Tribunal (the NCLT) or Reserve Bank of India (the RBI) or any Court or any other Tribunal.

(vii) In our opinion, the company has an internal audit system commensurate with the size and nature of its business.

(viii) The company is required to maintain cost records under section 209(1 )(d) of the Companies Act, 1956 in respect of paper manufactured by it. As informed to us, the necessary records as required by the rules are under preparation.

(ix) (a) The company is not regular in depositing statutory dues with appropriate authorities viz. Sales Tax, Excise Duty, Service Tax, Family Pension Fund, Provident Fund and Employees state insurance. However, no undisputed amounts payable in respect of such dues were in arrears, as at 31st March, 2010 for a period of more than six months from the date they became payable.

(b) According to the information and explanation given to us, there are no dues of sale tax, income tax, customs duty, wealth tax, excise duty and cess which have not been deposited on account of any dispute.

(x) In our opinion, the accumulated losses of the company are not more than fifty percent of its net worth. The company has incurred cash losses during the financial year; however the Company has incurred cash losses in the immediately preceding financial year.

(xi) In our opinion and according to the information and explanations given to us, the company has not defaulted in repayment of dues to a bank.

(xii) The company has not granted loans and advances on the basis of security by way of pledge of shares, debentures and other securities. Therefore, the provisions of clause 4(xii) of the Companies (Auditors Report) Order, 2003 are not applicable to the company.

(xiii) In our opinion, the company is not a chit fund or a nidhy mutual benefit fund / society. Therefore, the provisions of clause 4(xiii) of the Companies (Auditors Report) Order, 2003 are not applicable to the company.

(xiv) In our opinion, the company is not dealing in or trading in shares, securities, debentures and other investments. Accordingly, the provisions of clause 4(xiv) of the Companies (Auditors Report) Order, 2003 are not applicable to the company.

(xv) We are informed that, the company has not given any guarantee for loans taken by others from banks or financial institutions. Accordingly, the provisions of clause 4(xv) of the Companies (Auditors Report) Order, 2003 are not applicable to the company.

(xvi) In our opinion, the term loans have been applied for the purpose for which they were raised.

(xvii) According to the information and explanations given to us and on an overall examination of the balance sheet of the company, we report that short term funds of Rs. 74,286 thousands have been used for long term purpose.

(xviii) According to the information and explanations given to us, the company has not made any preferential allotment of shares --to parties and companies covered in the register maintained under section 301 of the Companies Act, 1956.

(xix) According to the information and explanations given to us, the company has not issued debentures during the year.

(xx) According to the information and explanations given to us, the company has not raised any money by way of public issue during the year.

(xxi) According to the information and explanations given to us, no fraud on or by the company has been noticed or reported during the year.

For Manubhai & Co.

Chartered Accountants

Firm Reg. No.: 106041W

(K. M. Patel)

Partner

Membership No. 45740

Place : Ahmedabad

Dated : September 2, 2010

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