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ITI LTD.

04 December 2024 | 12:00

Industry >> Telecom Equipments & Accessories

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ISIN No INE248A01017 BSE Code / NSE Code 523610 / ITI Book Value (Rs.) 18.57 Face Value 10.00
Bookclosure 08/11/2024 52Week High 384 EPS 0.00 P/E 0.00
Market Cap. 27798.46 Cr. 52Week Low 210 P/BV / Div Yield (%) 15.58 / 0.00 Market Lot 1.00
Security Type Other

AUDITOR'S REPORT

You can view full text of the latest Director's Report for the company.
Year End :2024-03 

Our Audit report on Indian Accounting Standards Standalone Financial Statements of the Company for the financial year 2023-24 under audit as approved by the BOD on May 28, 2024 and reported upon by us on the same date, has been revised by us in the light of the comments made in the supplementary audit carried out by Comptroller and Auditor General of India (CAG) in terms of section of 143(6) of the Companies Act, 2013. Accordingly, this audit report supersedes our earlier audit report dated May 28, 2024. Our audit procedures on events subsequent to the date of our original audit report issued on May 28, 2024, is restricted solely to observations made by CAG.

Disclaimer of Opinion

We were engaged to audit the accompanying Indian Accounting Standards Standalone Financial Statements of ITI Limited (“the Company”) which comprise the Balance Sheet as at March 31, 2024, the Statement of Profit and Loss (including Other Comprehensive Income), the Statement of Cash Flows, Statement of Changes in Equity for the year then ended and a summary of significant accounting policies and other explanatory information (herein after referred to as ‘SFS’).

We do not express an opinion on the accompanying SFS of the Company. Because of the significance of the matters described in the ‘Basis for Disclaimer of Opinion’ section of our report, we have not been able to obtain sufficient appropriate audit evidence to provide a basis for an audit opinion on these SFS.

Basis for Disclaimer of Opinion

1) The SFS of the Company for the year ended March 31, 2023, as approved by the Board of Directors on May 29, 2023, was reported upon by the earlier auditor M/s GRSM & Associates, Chartered Accountants vide their report issued on the same date. Vide this report, they had qualified their opinion on the said SFS due to the significance of the matters described in the ‘Basis for qualified opinion’ section of their report and their inability to quantify/ascertain the impact of the items on the SFS and for the said financial year. Their qualifications and observations may continue to impact the SFS for the current year. Management has not provided us with any quantification of the effect of these items on the current years’ SFS and we are accordingly unable to comment on the same.

2) In terms of SA 510 - Initial Audit Engagements -Opening Balances issued by the Institute of Chartered Accountants of India (‘ICAI’), we sought details and current status of certain items of assets and liabilities reflected in the SFS as at March 31,2024. Management did not furnish us requisite breakup and current status of cumulative debit and credit balances aggregating to Rs. 3,563.55 lakhs & 10,652.02 lakhs respectively carried forward from the said Balance Sheet and reflecting debit and credit balances in the same accounts aggregating to Rs. 3,690.45 lakhs & Rs. 15,500.23 lakhs respectively as at March 31,2024. Summaries of such accounts are furnished in Annexure- D to this report.

3) The land (Freehold/leasehold) records maintained by the Company and detailed records held by the civil engineering department (‘Civil’)

could not be correlated, in the absence of an appropriate coding/ cross-referencing system (refer note 1 to SFS). All the deficiencies in documentation to the extent identified and other matters have been based on the records maintained by Civil. Attention of the members is invited to paragraph 1(c) of “Annexure A” of our audit report on matters required to be dealt with in terms of The Companies (Auditors’ Report) Order, 2020 (“the Order”), wherein we have expressed our inability to comprehensively identify land not in the name of the Company. Many of these deficiencies have significant bearing on the title of the Company to such properties.

4) Attention is drawn to note 1 to SFS regarding property tax payable in respect of land and buildings being recognized either being based on estimates or not determined at all in the absence of demands from the revenue authorities and/or pending updations/reconciliations of land records as per asset records with records of Civil. Due to nonavailability of proper records, adequacy / completeness / correctness of provisions recognized, its impact on SFS could not be ascertained.

5) Requisite details of certain land and buildings owned by the Company/ taken on lease (sale/lease deed, location, purpose for which property is put to use, categorization between Property, Plant, & Equipment (‘PPE’) and Investment property (IP), whether any amortization of the same is required, income derived therefrom, etc.) were not furnished to us. The original cost and written down value of such assets as at March 31, 2024, aggregated to Rs. 7,657.03 lakhs & Rs. 7,592.54 lakhs respectively. The Company has recognized income to an extent of Rs. 334.91 lakhs on certain items of land and buildings although the relevant leases had expired and to the best of our knowledge, are yet to be renewed. Further, the Company has also not furnished the fair values of its IPs, the basis of determining its fair value, rental income derived from such properties and direct operating expenses (including repairs and maintenance) arising from IP that generated rental income during the year etc., in accordance with IndAS 40 -Investment Property.

6) In terms of the Material Significant Accounting Policies, the Company has not provided any documentation as to the evaluation carried out to test for any impairment of assets in compliance with IndAS 36 ‘Impairment of Assets’.

7) Capital work in progress as at March 31,2024, included the following assets, which to the best of our knowledge has been put to use but continued therein ostensibly for want of certain documents. We are unable to validate the carrying value/ageing data with the relevant documents and the effect of non-recognition of depreciation in the SFS.

Description of asset

Carrying value as at March 31, 2024 (Rs. In lakhs)

New Data Centre

2,669.45

Other Capital Work in Progress

3,923.39

NIFT building (Refer Note 2 to SFS)

6,582.06

8) The Company has not identified lease contracts entered into by it as a lessee/lessor within the meaning of IndAS 116 - Leases and has not consequently adopted the principles of recognition, measurement

and disclosure contemplated therein, contrary to accounting policy but has expensed off/taken to income from/to rent payable/receivable to the statement of profit and loss as per contractual terms. Security deposits paid/received thereon not recognized in the Statement of Profit or Loss in accordance with Ind AS 109 - Financial Instruments.

9) The Company did not have a system of appropriating payments received against specific bills raised in Tally Prime software (books of accounts) and only maintains a running account of bills raised and payments received. Consequently, the Company has certain excel workings based on which the age-wise data in respect of trade receivables as specified in Schedule III of the Companies Act, 2013 are furnished. We could not independently validate the ageing data so furnished with the books of accounts and have relied on such excel workings. Further, the Company has also not obtained confirmation of balances / statements of account / reconciliation with books of accounts. The data furnished in note 4(b) and 7 to the SFS could not be validated by us. Trade receivables include Rs. 18,099.63 lakhs & Rs. 1,95,310.44 lakhs representing debts exceeding 6 months but less than one year and debts exceeding one year and ranging up to/ beyond three years. The Company has not assessed and recognized the quantum of expected credit loss in terms of IndAS 109 - ‘Financial Instruments’ and has not furnished the requisite disclosures required in respect thereof.

10) The Company has not made provision for credit losses in respect of the following items included under Current Assets - Financial Assets, which are doubtful of recovery:

a. Rs. 5,847.90 lakhs, receivable from C-DOT towards rent from premises leased out to them for the period from 2005-06 to 2010-11.

b. Recoverable from HCL Infosystems Limited of Rs. 1,690.20 lakhs as compensation on account of the excess amount spent by the Mankapur Unit of the Company based on the agreement between ITI, HCL and Alcatel.

c. Recoverable from Himachal Futuristic Communications Ltd of Rs. 1,049.41 lakhs towards Liquidated Damages.

d. Receivable from Mindarray towards encashment of letter of credit of Rs. 1,023.00 lakhs.

e. Receivable from South Western Railway of Rs. 2,908.02 lakhs towards consideration receivable for sale of land.

f. Amounts receivable held under the head Claims and Expenses recoverable Inland amounting to Rs. 344.48 lakhs (breakup not available).

Accordingly, if provision for credit losses were made by the Company, the loss for the year would have been higher and the net current assets lesser by Rs. 12,863.01 lakhs.

11) The Company had received soft loan from the Government of India (GoI) in the financial year 2014-15 of Rs. 30,000 lakhs carrying interest at the rate of 1%. This loan was not recognized at fair value after considering the market borrowing rate. The Company has not identified financial assets and financial liabilities within the meaning of IndAS 1 09 and has not consequently adopted the principles of recognition, measurement and disclosure contemplated therein.

12) Inventories with book value of Rs. 22,220.13 lakhs, included several old items lying in the various site/stores for which NRV as at March 31, 2024, was not made available. The Company’s inventories

included old inventory and has not performed any ageing, usefulness and serviceability assessment held at various units to ascertain obsolete inventory. Company did not furnish the physical verification reports which was reportedly conducted as explained to us and in the absence of any excess/shortage list readily available we could not verify if there were any adjustments required to be made to the books of account. A ready list of inventories was not furnished to confirm the bifurcation of raw materials & production stores, materials issued against fabrication contracts, non-production stores, work in process production/installation, manufactured components, finished goods, stock reconciliation account, material in transit and goods pending inspection. We have relied on such list furnished in various excel sheets and could not independently validate the stock records with amounts as furnished in note 6 to the audited SFS. In the absence of full data, we are unable to obtain sufficient appropriate audit evidence regarding the valuation of such stores and spares and whether the same is in accordance with IndAS 2 - Inventories.

13) In respect of certain current/non-current liabilities complete details/ nature and ageing in respect of each amounts payable, reasons for their pendency, reasons for non-claim by parties, confirmation/ statement of account/reconciliation were not made available.

14) Reference is invited to note 17(c) to SFS regarding disclosure of information pertaining to vendors under Micro, Small and Medium Enterprises Development Act, 2006, pending identification of such vendors and consequential non-provision for interest, if any, in terms of section 23 of the said act, consequent effect on SFS not ascertained.

15) The Company has not carried-out any fair valuation as was required in terms of the IndAS 109 ‘Financial Instruments’ in respect of all financial assets and liabilities which are receivable/payable beyond a period of 12 months from the date of initial recognition (examples: certain employee receivables, retention money payable, security deposits accepted/paid, etc.) for the purposes of determination of amortized costs and amortization/recognition of expenses/income of the differential between amortized cost and contractual amounts payable/receivable.

16) The Company’s contribution to ITI Employees Provident Fund Trust (‘PF Trust’) covering all units as detailed in point 22(e) of the Material Accounting Policies has been considered as a defined contribution plan and not that to a defined benefit plan both for the current year and prior years. Accordingly, the liability to the trust should have been evaluated actuarily and recognized rather than 12% of the eligible salaries to be made over during the year. Consequent disclosures required in terms of IndAS 19 - Employee Benefits have not been furnished.

17) The Company has not evaluated actuarily its liability to the Kalyanakari Death Benefit Scheme of its employees in the event of shortfall between the funds available from recoveries from employees & interest thereon and amount payable to deceased employees in any year.

18) The Company has not reconciled its books of accounts with its GST returns filed across all its units/divisions/corporate office (turnover, exempt turnover, taxes payable, input tax credit available and availed and tax deducted at source) in the absence of which we are unable to ascertain any effect on the SFS. Company to examine the advances received by it and identify the goods and service portion of the respective advances received based on respective contracts and ensure GST remittance on such service portion of advances received. Matter may be examined by the Company regarding such compliance and appropriate action be taken. Pending such bifurcation

of goods and service portion we are unable to ascertain if there is GST liability on advances and consequent interest provision thereon in the books of accounts. The Company has not filed its annual return of reconciliation of turnover between books and returns for certain registrations pertaining to financial years 2021-22 and 2022-23 respectively, contrary to rule 80 of the CGST Rules, 2016.

19) The Company has not reconciled the entries in Form 26AS and AIS in the Income Tax portal website with the books. Due to lack of adequate ready data/reconciliation, we are unable to independently validate the entries in Form 26AS / AIS / TIS and consequent disclosures in the SFS of advance tax/refunds/disputed taxes, if any.

20) The Company has reported to the extent ascertained in respect of contingent liabilities and capital commitments as detailed in note 31 to SFS. In the absence of full and comprehensive list across all divisions of the Company with testing of the probability of the liability devolving with appropriate legal advice wherever required, we are unable to ascertain the completeness/accuracy of the values reported in the said note and any provisions that may be required in this respect.

21) The Company has not identified warranty obligations as a distinct performance obligation within the meaning of IndAS 115 - Revenue from contracts with customers and recognizes the same as and when obligations arise on the plea that it generally has a back-to-back claim against its vendors. The Company has not provided us with the requisite documentation indicating such rights in each and every contract entered into by it.

22) Palakkad Unit has received an amount of Rs. 51 lakhs from certain customers as of March 31, 2024 which have not been accounted for in the books of account since the management is unable to map these receipts with the specific invoices raised by it. Accordingly, the bank balances of the Company are understated to the tune of Rs. 51 lakhs as of March 31, 2024, and the Accounts receivable balances are overstated to the same extent. (As per the audit report issued by Balaram & Nandakumar, Chartered Accountants dated May 24, 2024)

23) Company has not compiled and disclosed the requisite data detailed below in terms of Schedule III, division II to the Act.

Sl.No

Requisite disclosures not furnished

1.

Fair value of investment property

2.

Relationship with Struck off Companies

a. Attention is invited to note 22 of the SFS where in the Company has enumerated the status of a contract with Ministry of Defense, GoI, for supply and establishment of Army Static Switched Communication Network (ASCON) at an agreed consideration. In terms of the said contract, the Company was to mandatorily demonstrate its complete solution so as to bring out its capabilities vis-a-vis the requirements of the customer, which would be evaluated by the latter and form an essential part of the test bed evaluation process. We are informed for the reasons stated in the said note that the test best approval is awaited as at March 31, 2024, which is expected upon completion of certain activities as detailed therein. The Company has proceeded with part execution of the contract pending test bed final approval and in the opinion of the management of the Company is not impacting the revenue already recognized up to March 31,2024, to an aggregate extent of Rs. 1,48,686.48 lakhs. We have relied on the representations made by the Company and do not express any independent opinion on such revenue recognized.

b. The Company has entered into contracts with a customer for implementation of a network within a specified area at an aggregate consideration (excluding O&M and taxes) of Rs. 2,48,954.87 lakhs. As against this, the Company has recognized revenue to an extent of Rs. 2,36,701.57 lakhs although the contract is not complete. In the absence of the percentage completion, we are unable to obtain sufficient appropriate audit evidence in support of the revenue recognition.

c. The Company’s system of revenue recognition is based upon the percentage of completion method. The Company had inadequate documentation to support reassessment of total costs of each contract and costs yet to be incurred on every reporting date, backed by customer attested data of work completed and certified, work completed but yet to be certified and internal assessment of cost incurred in respect of work in progress. The Company has also recognized unbilled revenues to an aggregate extent of Rs. 2,17,467.63 lakhs as at year end. This includes unbilled revenue recognized up to March 31,2023, and yet to be billed to the customer as at March 31, 2024, upon certification of the work. The Company has not furnished us an analysis of unbilled revenue identifying the milestones to be achieved before the same can be billed, the further costs yet to be incurred to achieve such milestone, and the estimate of likely costs of rework/modifications that is to be incurred in the process of achieving certification. Accordingly, we could not obtain sufficient appropriate audit evidence of revenue recognized.

25) Attention is invited to note 22 & note 25 of the SFS where in Company enumerated breakups of ‘Sales under broad heads’ & ‘Service Income under broad heads’ (Note 22), ‘Goods purchased under broad heads’ (Note 25(a)) and ‘Service Expenses under broad heads’ (Note 25(b)). We could not independently validate the breakup so furnished with the books of accounts and have relied on workings.

26) Attention is invited to Note 31 of the SFS where in the Company has reported certain non-compliances. We understand that there are non-compliance with various provisions of SEBI Listing Regulations towards Quorum for Board meeting, Non-compliance with the constitution of Audit Committee, Nomination and Remuneration Committee, Stakeholders Relationship Committee and Risk Management Committee. Due to lack of adequate ready data/ information, we are unable to independently validate the amounts in the said note. Company has confirmed to us that, representation to the Stock Exchanges for waiver of penalty has been submitted as the non-compliance as regards to the said non-compliances was not due to any negligence and also the BSE/NSE had given waiver in the past year. Accordingly, the Company is confident that further penalties also will be waived on the same grounds. Consequential non-provision for penalty and interest and consequent effect on SFS not ascertained.

Common to all matters dealt with above:

We are unable to obtain sufficient appropriate audit evidence to form an opinion on the SFS due to the potential interaction of the multiple/ undetected misstatements, if any, contained therein and their possible individual and cumulative effect on the SFS, which may be material and pervasive, accordingly forms a basis for the disclaimer of opinion.

Material Uncertainty on Going Concern

The Company incurred a net loss of Rs. 56,906 lakhs during the year ended March 31, 2024. In spite of events or conditions which may cast a doubt on the ability of the Company to continue as a going

concern, the management is of the opinion that going concern basis of accounting is appropriate in view of the continued support of the Government of India, high value of order book under execution with adequate margins, adequate working capital borrowing from banks already sanctioned, conversion of unbilled revenue into billed revenue by completing the contract milestones within next 12 months, step-up the recovery processes to collect the billed dues as mentioned in the note 31 of the SFS. Our opinion is not modified in respect of this matter. Also, refer to our comments under para 19 of Annexure - A to this report.

Emphasis of Matter

a. The Company had received funds towards capital expenditure as part of the financial assistance approved by Cabinet Committee on Economic Affairs (CCEA) when the Company was declared a Sick Company as per provisions of the Sick Industrial Companies Act, 1985.

b. The Company is not in compliance with the requirements of having a specified proportion/ number of independent directors.

c. The Company continues to carry a land admeasuring 77 acres having a carrying value of Rs. 19,470 lakhs under Property, Plant & Equipment after receiving intimation of re-possession by the Government of Kerala as the Company has disputed the same, and the matter is under adjudication of the Apex Court.

[Refer Note No.31 of the SFS for the above matters]

Our opinion is not modified in this respect in respect of the above matters.

MANAGEMENT’S RESPONSIBILITY FOR SFS

The Board of Directors of the Company is responsible for the matters stated in Section 134(5) of the Companies Act, 2013 (“the Act”) with respect to the preparation of these SFS that give a true and fair view of the financial position, financial performance including other comprehensive income, cash flows and changes in equity of the Company in accordance with the accounting principles generally accepted in India, including the Indian Accounting Standards (IndAS) prescribed under Section 133 of the Act. This responsibility also includes maintenance of adequate accounting records in accordance with the provisions of the Act for safeguarding 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 adequateinternal financial controls, that were operating effectively for ensuring the accuracy and completeness of the accounting records, relevant to the preparation and presentation of the SFS that give a true and fair view and are free from material misstatement, whether due to fraud or error.

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

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

AUDITOR’S RESPONSIBILITY FOR THE AUDIT OF SFS

Our responsibility is to conduct an audit of the SFS in accordance with Standards on Auditing and to issue an auditor’s report. However, because

of the matters described in the Basis for Disclaimer of Opinion section of our report, we were not able to obtain sufficient appropriate audit evidence to provide a basis for an audit opinion on SFS.

We are independent of the Company in accordance with the ethical requirements in accordance with the requirements of the Code of Ethics issued by ICAI and the ethical requirements as prescribed under the laws and regulations applicable to the Company.

Other Matters

We did not audit the Financial Statements (‘FS’) of the Mankapur, Raebareli, Srinagar, Naini and Palakkad Branches included in the SFS of the Company, whose FS reflect total assets of Rs. 1,93,893.25 lakhs as at March 31,2024, and total income of Rs. 19,023.13 lakhs for the year ended on that date as considered in the SFS (excluding inter-unit balances and transactions). The FS of these components have been audited by the component auditors whose report has been furnished to us, and our opinion in so far as it relates to the amounts and disclosures included in respect of these components is solely on the report of such component Auditors.

Our opinion is not modified in respect of these matters.

REPORT ON OTHER LEGAL AND REGULATORY REQUIREMENTS

1) As required by the Companies (Auditors’ Report) Order, 2020 (“the Order”) issued by the Central Government 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 which is subject to the possible effects of the matters described in the ‘Basis for Disclaimer of Opinion’ section of our Independent auditor’s report and in our report on the Internal Financial Controls over Financial Reporting with reference to SFS.

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

a. As described in the Basis for Disclaimer of Opinion section above, we have sought but were not able to obtain all the information and explanations which to the best of our knowledge and belief were necessary for the purposes of our audit.

b. In our opinion, proper books of account as required by law have been kept by the Company so far as it appears from our examination of those books, except for the matters described in the Basis for Disclaimer of Opinion section above.

c. The report on the accounts of any branch office of the Company audited under sub-section (8) by a person other than the Company auditor has been sent to us under the proviso to that sub-section and the manner in which he has dealt with it in preparing his report.

d. The Balance Sheet, the Statement of Profit and Loss including Other Comprehensive Income, Statement of Changes in Equity, and the Cash Flow Statement dealt with by this Report are in agreement with the books of account, except for the matters stated in the Basis for Disclaimer of Opinion section of our Report.

e. Due to the possible effects of the matter described in the Basis for Disclaimer of Opinion section above, we are unable to state whether the aforesaid SFS comply with the Indian Accounting Standards prescribed under section 1 33 of the Act read with Companies (Indian Accounting Standards) Rules, 2021, as amended.

f. Due to the possible effect of the matters described in the Basis for Disclaimer of Opinion section above, we are unable to state whether they have any adverse effect on the functioning of the Company.

g. As per GSR- 463 (E) dated June 5, 2015, issued by the Ministry of Corporate Affairs, the provisions of Section 164(2) of the Companies Act, 201 3 regarding disqualification of director(s) is not applicable to the Company, since it is a Government Company.

h. The reservation/modification relating to the maintenance of accounts and other matters connected therewith are as stated in the Basis for Disclaimer of Opinion section, read with paragraph 2(b) above.

i. With respect to the adequacy of the internal financial controls over financial reporting of the Company and the operating effectiveness of such controls, refer to our separate Report in “Annexure B”. Our report expresses disclaimer of opinion on the Company’s internal financial controls over financial reporting for the reasons stated therein.

j. Except for the possible effects of the matters described in the Basis for Disclaimer of Opinion section above, with respect to the other matters to be included in the Independent Auditor’s Report in accordance with Rule 11 of the Companies (Audit and Auditors) Rules, 2014, as amended, in our opinion and to the best of our information and according to the explanations given to us:

i. The Company has disclosed the estimated impact of pending litigations on its the financial position as detailed in Note 31 to SFS, to the extent ascertained.

ii. The Company has made provision, as required under the applicable law or accounting standards, for material foreseeable losses, if any, on long-term contracts. The Company did not enter into any derivative contracts.

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

iv. a). Management has represented that, to the best of its knowledge and belief, no funds have been advanced or loaned or invested (either from borrowed funds or share premium or any other sources or kind of funds) by the Company to or in any other person(s) or entity(ies), including foreign entities (“Intermediaries”), with the understanding, whether recorded in writing or otherwise, that the Intermediary shall, whether, directly or indirectly lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the Company (“Ultimate Beneficiaries”) or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries.

b). Management has represented, that, to the best of its knowledge and belief, no funds have been received by the Company from any person(s) or entity(ies), including foreign entities (“Funding Parties”), with the understanding, whether recorded in writing or otherwise, that the Company shall, whether, directly or indirectly, lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the Funding Party (“Ultimate Beneficiaries”) or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries.

c. Based on such audit procedures that we 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) above contain any material misstatement.

v. The Company did not declare or pay any dividends during the year. Accordingly, no reporting under the said subclause is applicable.

vi. The Company uses multiple accounting software having feature of recording audit trail with edit log version (‘Tally Prime™’ and ‘Integrated Manufacturing Management System(‘IMMS’)) for maintenance of its books of account for the financial year ended March 31,2024, except in case of Network system units (‘NSU’) where the accounting software used by them did not have such feature. Based on examination, including certain test checks and discussions with the management, except for NSU, we are of the opinion that the Tally Prime Edit Log version software had a feature of recording audit trail (edit log) facility and the same is operated throughout the period from the respective dates they were implemented (refer table below) during the year. Further Palakkad unit used ‘IMMS’ software which had a feature of recording audit trail (edit log) facility and the same has been operated throughout the period based on the auditor comments of Palakkad unit vide his report dated May 24, 2024. Below are details of other units/ROs who implemented and used Tally prime (edit log) facility with effect from various dates detailed below.

Unit/RO name

Date of implementation of “Tally prime (edit log)”

RO Bangalore

07-03-2023

RO Mumbai

07-03-2023

RO Chennai

06-03-2023

RO Hyderabad

07-03-2023

RO Lucknow

29-03-2023

RO Delhi

09-03-2023

RO Kolkata

24-03-2023

RO Bhubaneshwar

07-03-2023

Corporate

19-06-2023

BGP

13-04-2022

R&D

16-05-2022

Mankapur

25-04-2023 to 29-08-2023 30-08-2023 to 31-03-2024

Raebareli

08-08-2023

Naini

25-08-2023

Srinagar

10-03-2023

Up to the above said dates of implementation, there was no system of recording audit trail. Hence, to the said extent, we are unable to comment on the requirements of rule 11(g) of the Companies (Audit and Auditors) Rules, 2014.

We have not come across any instance of the audit trail feature being tampered with for the period after the above said implementation dates.

As proviso to Rule 3(1) of the Companies (Accounts) Rules, 2014 is applicable from April 1,2023, reporting under Rule 11(g) of Companies (Audit and Auditors) Rules, 2014 on preservation of audit trail as per the statutory requirements for record retention is not applicable for the financial year ended March 31,2024.

As required by Section 143(5) of the Act, we have considered the directions issued by the Comptroller and Auditor-General of India, the action taken thereon and its impact on the accounts and SFS of the Company is given in “Annexure C”.

For B.K.RAMADHYANI & CO LLP

Chartered Accountants Firm Registration No. 002878S/S200021

(CA Vasuki H S)

Partner

Membership No. 212013 UDIN: 24212013BKCLTJ8245

Place: Bengaluru Date: July 31,2024