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Company Information

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GOODLUCK INDIA LTD.

20 December 2024 | 12:00

Industry >> Steel - Tubes/Pipes

Select Another Company

ISIN No INE127I01024 BSE Code / NSE Code 530655 / GOODLUCK Book Value (Rs.) 348.72 Face Value 2.00
Bookclosure 28/09/2024 52Week High 1330 EPS 40.40 P/E 23.01
Market Cap. 3043.86 Cr. 52Week Low 720 P/BV / Div Yield (%) 2.67 / 0.65 Market Lot 1.00
Security Type Other

DIRECTOR'S REPORT

You can view full text of the latest Director's Report for the company.
Year End :2023-03 

Directors' Report

Dear Shareholders,

The Board of Directors of your Company takes pleasure in presenting 37th Annual Report and audited Standalone accounts on
the business and operations of your Company for the financial year ended 31st March 2023.

Particulars

2022-23

2021-22

Gross Revenue

3,086

2,617

Earnings before interest, tax & depreciation

218

187

Finance cost

66

57

Depreciation

33

29

Profit before tax

120

101

Profit after tax

87

75

Earning per Share (in ')

32.97

29.48

1. RESULTS OF OPERATIONS AND THE STATE OF
COMPANY’S AFFAIRS

The Company achieved remarkable growth during the
FY 2022-23 by selling highest ever volume of engineered
products, i.e., 316718 MT which is 20% higher than the
previous FY 2021-22. The Company has total 364,000
tons manufacturing capacity. And this year, company
have added 18,000 metric tons in forging division.
Goodluck is into four major vertical, which are ERW
Steel Tube, Precision tube, Precision engineering and
fabrication and forging. The company has started its
solar in a separate vertical owing to the superlative
demand in this segment. Also aerospace and defence too
are other area of interest, which in management opinion
requires social especial focus. The Company caters
many diverse sectors of the economy that include auto,
infra, high speed railway, specialized infrastructure, solar,
aerospace and defence components.

The Company on a consolidated basis registered a
robust turnover of
' 3,047.98 crore in FY23 as against
' 2,577.72 crore in the previous FY22, recording a growth
of 18.24%. EBITDA increased by 17.26% to
' 219.15
crore in FY 2022-23 compared to '186.88 crore in
FY 2021-22. PAT stood at
' 87.80 crore in FY 2022-23 as
against
' 75 crore in FY 2021-22. The company's debt
equity ratio improved from 1.15 to 0.95 in FY23. The EPS
during the financial year is
' 33.31 per share.

2. DIVIDENDS

On the basis of market capitalization as on 31st March 2023,
the Company has succeeded in making space under the
top 1000 listed entities and as per the requirement under
regulation 43A of SEBI (LODR) Regulations, 2015 and as

per Companies Act, 2013, the Board of Directors of the
Company had approved a Dividend Distribution Policy in
its meeting held on 08th April 2023.

This Policy will regulate the process of dividend
declaration and its pay-out by the Company in accordance
with the provisions of Companies Act, 2013 read with
SEBI (LODR) regulations, 2015. The Policy is available
on the Company's website: https://www.goodluckindia.
com/pdf/dividend-distribution-policy.pdf

Based on Company's healthy performance during the
year, the Company has distributed the Interim dividend
@100%, i.e.
' 2/- per equity share, on the paid up equity
share capital for the financial year 2022-23.

The Board of Directors recommended a Final dividend
@ 150%, i.e.
' 2.50 /- per equity Share on 27256250
equity shares of 2 each of the Company, for the year
ended 31st March 2023, subject to the approval of the
Members at the ensuing Annual General Meeting.

3. CORPORATE GOVERNANCE AND ADDITIONAL
INFORMATION TO SHAREHOLDERS

The company is committed to maintain high standards
of corporate governance. A separate report on corporate
governance, pursuant to regulations of SEBI (Listing
Obligations and Disclosure Requirements) Regulations,
2015, is provided with a certificate from the Statutory
Auditors of the Company regarding compliance of
conditions of Corporate Governance as stipulated
under Listing Regulations, including the management
discussion and analysis, and shareholders' information
forms a part of this report.

As required by Regulation 17(8) read with Schedule II
Part B of the Listing Regulations, the Management and
CFO of the Company have given appropriate certifications,
inter alia, confirming the correctness of the financial
statements and cash flow statements, adequacy of the
internal control measures and reporting of matters to the
Audit Committee to the Board of Directors.

Details of the depository system and listing of shares
and Registrar & Share Transfer Agent are given in the
section Shareholder information, which forms a part of
the Corporate Governance Report.

4. BUSINESS RESPONSIBILITY AND
SUSTAINABILITY REPORT

Pursuant to Regulation 34(2)(f) of the Listing
Regulations and SEBI circular no. SEBI/LAD-NRO/
GN/2021/2 dated 5th May 2021, your Company
provides the prescribed disclosures in new reporting
requirements on Environmental, Social and Governance
("ESG") parameters called the Business Responsibility
and Sustainability Report ("BRSR") which includes
performance against the nine principles of the National
Guidelines on Responsible Business Conduct and
the report under each principle which is divided into
essential and leadership indicators. The BRSR is given
as an integral part of this annual report.

5. CONSERVATION OF ENERGY, TECHNOLOGY
ABSORPTION, FOREIGN EXCHANGE EARNINGS
AND OUTGO

Details of conservation of energy, technology absorption,
foreign exchange earnings and outgo undertaken by
the Company along with the information in are given in
Annexure 'A' to the Directors' Report.

6. DIRECTORS AND KEY MANAGEMENT
PERSONNEL

In accordance with the provisions of Section 152 of
the Companies Act, 2013 and in terms of the Article
of Association of Company, Mr. Ramesh Chandra Garg
(DIN: 00298129), Whole Time Director is liable to retire
by rotation at the ensuing AGM and being eligible, offer
himself for re-appointment. The proposal regarding
his re-appointment is placed for approval by the
shareholders.

Mr. Vijender Kr. Tyagi, Mr. Ishwar C Agasti and
Mr. Rahul Goel, the independent Directors of the Company
have completed their tenure on 29th September 2022
and cease to be an independent director on the Board of
the Company.

Mr. Rajiv Goel (DIN: 05161245) and Ms. Rajni Abbi
(DIN: 08867489) who were appointed as Non- Executive
Independent Director of the Company for a terms of five
consecutive years with effect from 29th September 2022
in terms of the provision of Section 149 (10) of the
Companies Act, 2013.

Mr. Satish Kumar Gupta (DIN: 00354707),
Mr. Madhur Gupta (DIN: 03193827) and Ms. Charu Jindal
(DIN: 09776017), who were appointed as an Additional
Independent Director, by the Board of Directors with effect
from 29th October 2022 and has been regularized as an
Independent Non-Executive Director of the Company
with effect from 05th December 2022.

On account of preoccupation, Ms. Rashmi Garg
(DIN: 08188918) has shown her inability to continue with
the position of Independent Director of the Company and
ceased to be director with effect from 09th November
2022.

Mr. Satish Gupta, on account of his professional
commitment has shown his inability to continue with
the position of Independent Director of the Company
and submitted his resignation. The Board considered his
resignation and he ceased to be director with effect from
08th April 2023.

7. NUMBER OF MEETINGS OF THE BOARD AND ITS
COMMITTEES

The details of the meetings of the Board of Directors
and its Committees, convened during the financial year
2022-23 are mentioned under the Corporate Governance
Report which forms a part of this report.

8. STATUTORY AUDITORS

At the Company's 33rd AGM held on September 30, 2019,
M/s Vipin Kumar & Co. (Firm Registration No- 002123C),
Chartered Accountants, has been appointed as the
Statutory Auditor of the Company for a term of 5 years to
hold office until the conclusion of the 38th Annual General
Meeting.

The report of the Statutory Auditor forms part of the
Integrated Report and Annual Accounts for FY 2022-23.
The said report does not contain any qualification,
reservation, adverse remark or disclaimer. The Notes on
financial statements referred to in the Auditor's Report
are self-explanatory and do not call for any further
comments.

No fraud has been reported by the Auditor under section
143(12) of the Companies Act, 2013 requiring disclosure
in the Board's Report.

9. SECRETARIAL AUDITOR

The Board has appointed M/s Ravi S Sharma
& Associates, Practicing Company Secretary
(FCS - 7336), to conduct Secretarial Audit for the
financial year 2022-23. The Secretarial Audit Report
for the financial year ended 31st March 2023 is annexed
herewith marked as
Annexure 'B' to this Report.

10. COST AUDITOR

The Board of Directors of your Company, on the
recommendations made by the Audit Committee has
approved the appointment of S. R. Kapur, Practicing Cost
Accountant, (M. No. 4926) as the Cost Auditor of your
Company to conduct the audit of cost records for the
financial year 2023-24. The remuneration proposed to
be paid to the Cost Auditor, subject to your ratification
at the ensuing 37th Annual General Meeting.

Your Company has received consent from S. R. Kapur,
Practicing Cost Accountant, to act as the Cost Auditor
for conducting audit of the cost records for the financial
year 2023-24 along with a certificate confirming their
independence and arm's length relationship.

11. AUDITOR'S REPORTS

The Statutory Auditor's Report to the Shareholders
together with Accounts for the year ended
31 st March 2023 and notes thereon are attached, which
are self-explanatory. The observations of Statutory
Auditors and Secretarial Auditors in their report, read with
the relevant Notes to Accounts are self-explanatory and
therefore, do not require any further explanation.

The Statutory Auditors of the Company have not reported
any fraud as specified under the second proviso of
Section 143(12) of the Companies Act, 2013 (including
any statutory modification(s) or re-enactment(s) for
the time being in force). The Auditors' Report for the
financial year ended 31 st March 2023, does not contain
any qualification, reservation or adverse remark.

12. MANAGEMENT DISCUSSION AND ANALYSIS

The Management Discussion and Analysis forms
an integral part of this report and gives details of the
overall industry structure, economic developments,
performance and state of affairs of your Company's
businesses, internal controls and their adequacy, risk &
concerns, risk management systems and other material
developments etc. during the financial year 2022-23.

13. PUBLIC DEPOSITS

Your Company has not invited or accepted any fixed
deposits during the year as per the provisions of

Section 73(2) of the Companies Act, 2013, and the
rules made there under and as such, no amount of
principal or interest was outstanding on the date of the
Balance Sheet.

14. INTERNAL FINANCIAL CONTROLS

The Board of your Company has laid down internal
financial controls to be followed by the Company and
that such internal financial controls are adequate and
operating effectively. Your Company has adopted
policies and procedures for ensuring the orderly and
efficient conduct of its business, including adherence to
the Company's policies, the safeguarding of its assets,
the prevention and detection of frauds and errors,
the accuracy and completeness of the accounting
records, and the timely preparation of reliable financial
disclosures.

15. SUBSIDIARIES/JOINT VENTURES/ASSOCIATE
COMPANIES

A separate section on the performance and financial
position of the subsidiary company in Form
AOC- I is part of the report and is annexed herewith as
Annexure 'C'.

As per the SEBI Listing Regulations, a policy on
material subsidiaries as approved by the Board of
Directors, may be accessed on the Company's website
www.goodluckindia.com.

16. INDEPENDENT DIRECTORS DECLARATION

During the financial year 2022-23, the Board of the
Company consists of Mr. Rajiv Goel, Mrs. Rajni Abbi,
Mr. Madhur Gupta, Ms. Charu Jindal and Mr. Satish Gupta
as Independent Directors. These Directors have confirmed
that they fulfill all the requirements as stipulated in
Section 149(6) of the Companies Act, 2013 so as to
qualify themselves to be appointed as an Independent
Directors under the provisions of the Companies Act,
2013 and the Rules thereunder.

Every Independent Director, at the first meeting of
the Board in which he participates as a Director and
thereafter at the first meeting of the Board in every
financial year, gives a declaration that he meets the
criteria of independence as provided under law.

The Board of Directors confirm that the Independent
directors appointed during the year also meet the criterial
of integrity, expertise and experience in terms of Rule 8
of the Companies (Accounts) Rules, 2014.

17. DISCLOSURE AS PER THE SEXUAL HARASSMENT
OF WOMEN AT WORKPLACE (PREVENTION,
PROHIBITION AND REDRESSAL) ACT, 2013

The Company has in place a policy on prevention,
prohibition and redressal of Sexual Harassment at
workplace in line with the provisions of the Sexual
Harassment of Women at Workplace (Prevention,
Prohibition and Redressal) Act, 2013 and the Rules
thereunder. The Policy has been formed to prohibit,
prevent or deter the commission of the acts of sexual
harassment at workplace and to provide the procedure for
redressal of complaints pertaining to sexual harassment.
The Company is an equal employment opportunity
provider and is committed for creating a healthy working
environment that enables employees to work without
fear of prejudice, gender bias and sexual harassment.
The Company also believes that all employees of the
Company have the right to be treated with dignity.

During the Financial Year 2022-23, the Company has
not received any complaints of sexual harassment.
The Company is committed to providing a safe and
conducive work environment to all of its employees and
associates.

18. RISK MANAGEMENT POLICY

On the basis of market capitalization as on 31st March 2023,
the Company has succeeded in making space under the
top 1000 listed entities and as per the requirement under
regulation 21 of SEBI (LODR) Regulations, 2015 and as
per Companies Act, 2013, the Company has constituted a
Risk Management Committee of the Board in its meeting
held on April 08, 2023 which will help in development
and implementation of a Risk Management Policy for
the Company including identification therein of elements
of risk, if any, which may threaten the existence of the
Company.

In compliance with the requirement of the Companies Act,
2013 the Company has put in place Risk Minimization
and Assessment Procedures. In order to effectively and
efficiently manage risk and address challenges, the
Company has formulated Risk Management Policy.

The objective of any risk identification and assessment
process is to evaluate the combination of likelihood
and level of negative impacts from an event. The three
main components of risk assessment are business risk,
service/operational risk and external risk.

The Company manages the risk in line with current
risk management best practices. This facilitates the
achievement of our objectives, operational effectiveness
and efficiency, protection of people and assets, informed

decision-making and compliance with applicable laws
and regulations.

19. CHANGE IN THE NATURE OF BUSINESS

In pursuance to Rule 8(5) of Companies (Accounts)
Rules, 2014, there is no change in the nature of business
of Company.

20. MATERIAL ORDERS

In pursuance to Rule 8(5) (vii) of Companies (Accounts)
Rules, 2014, there were no significant or material orders
were passed by the Regulators or Courts or Tribunals
during the financial year 2022- 23 which would impact
the going concern status and Company's operations in
future.

21. PARTICULARS OF LOANS GIVEN, INVESTMENTS
MADE, GUARANTEES GIVEN AND SECURITIES
PROVIDED

Particulars of loans given, investments made, guarantees
given and securities provided along with the purpose for
which the loan or guarantee or security is proposed to
be utilized by the recipient are provided in the financial
statements.

22. FAMILIARIZATION PROGRAMME FOR BOARD
MEMBERS

The Board members are provided with necessary
documents, reports and internal policies to enable
them to familiarize with the Company's procedures
and practices. Periodic presentations are made at the
Board and Board Committee Meetings, on business
and performance updates of the Company. The details
of such familiarization programmes for Independent
Directors are posted on the website of the Company and
can be accessed at the link https://www.goodluckindia.
com.

23. POLICY ON RELATED PARTY TRANSACTIONS

All Contracts/transactions/arrangements entered into by
the Company during the financial year with the Related
Parties were in ordinary course of business and on an
arm's length basis and in accordance with the provisions
of the Companies Act, 2013, read with the Rules issued
thereunder and the Listing Regulations. Further, there
were no transactions with related parties which qualify
as material transactions under the Listing Regulations.

All transactions with related parties were reviewed and
approved by the Audit Committee. Omnibus approval is
obtained for un-foreseen transactions. Subsequently on
a quarterly basis the transactions are presented to the
Audit Committee, specifying the nature, value and terms
and conditions of the same.

The Company has made transactions with related
parties pursuant to Section 188 of Companies Act, 2013.
The particulars of material contracts or arrangements
with related parties referred to in sub-section (1) of
section 188 in the Form AOC-2 is annexed herewith as
Annexure 'D'.

The Company has formulated a policy on materiality
of related party transactions and also on dealing with
Related Party Transactions which has been uploaded
on the Company's website at the weblink: https://
www.goodluckindia.com.

24. POLICY ON APPOINTMENT AND
REMUNERATION TO BE PAID TO DIRECTORS, KEY
MANAGERIAL PERSONNEL (KMP) AND OTHER
EMPLOYEES AND CRITERIA FORMULATED
BY THE COMMITTEE FOR DETERMINING
QUALIFICATION, ATTRIBUTES, INDEPENDENCE
OF A DIRECTOR

The Board has adopted a policy, on remuneration to be
paid to Directors, Key Managerial Personnel and other
employees and Criteria for Appointment of Directors.
The objective of the policy is to define the criteria for
qualification, qualities and characteristics for the Board
as a whole and to ensure that Executive/Non-Executive
Directors and Key Managerial Personnel are sufficiently
compensated for their performance.

Policy on appointment of Directors

The Composition and strength of the Board of Directors
("the Board") of the Company is subject to the provisions
of the Companies Act, 2013, Listing Regulations
and Articles of the Association of the Company.
The Nomination and Remuneration Committee is
responsible for evaluating the qualifications of each
candidate to be appointed as Director on the Board.
In general, it is expected from a Director to possess
appropriate skills, experience and knowledge in one or
more fields of finance, law, management, sales, marketing,
administration, research, corporate governance, technical
operations or other disciplines related to the Company's
business or in the area of his expertise and to have
ample experience and a proven record of professional
success, leadership and the highest level of personal and
professional ethics, integrity and values.

Remuneration Policy

Non-Executive Independent Directors may receive
sitting fees for attending the Meeting of the Board and
Committees thereof. The Executive Directors and
other employees are paid remuneration by way of
salary, perquisites, allowances. Perquisites and
retirement benefits are paid as per the Company policy.

The remuneration of Executive Directors, as recommended
by the Nomination and Remuneration Committee, is
approved and further recommended by Board of Directors
to the Members for approval. Remuneration and annual
pay of Executive Directors and employees is determined
keeping in view the industry benchmark and the relative
performance of the Company.

Criteria for Determining Qualifications, Positive
Attributes & Independence of Director

A director shall possess appropriate skills, experience
and knowledge in one or more fields of finance, law,
management, sales, marketing, administration, research,
corporate governance, operations or other disciplines
related to the company's business or in the area of his
expertise.

A director shall be a person of integrity, who possesses
relevant expertise and experience and who shall uphold
ethical standards of integrity and probity; act objectively
and constructively; exercise his responsibilities in
a bona-fide manner in the interest of the company;
devote sufficient time and attention to his professional
obligations for informed and balanced decision making;
and assist the company in implementing the best
corporate governance practices.

Directors should be free to present their view point
independently, Company has also adopted to conduct
the separate meeting of the independent Directors,
which will ensure that the independent directors of the
Company can review the performance of the Board and
Chairman. Moreover, the Directors should meet the
other requirements of the Companies Act, 2013 and
Regulation 16(1) (b) of Listing Regulations concerning
independence of directors. A complete Remuneration
Policy is available Company's website at the weblink:
https://www.goodluckindia.com .

25. EVALUATION OF THE BOARD'S PERFORMANCE

In terms of the requirement of the Companies Act, 2013
and the Listing Regulations, an annual performance
evaluation of the Board is undertaken where the Board
formally assesses its own performance with the aim
to improve the effectiveness of the Board and the
Committees. During the year, Board evaluation cycle was
completed by the Company internally which included the
evaluation of the Board as a whole, Board Committees
and the Peer evaluation of the Directors. The exercise
was carried out through a structured evaluation to
evaluate the performance of individual directors
including the Board Chairman along with the Chairman
of the Nomination and remuneration Committee of the
Company. The evaluation process focused on various

aspects of the functioning of the Board and Committees,
experience and competencies, performance of specific
duties and obligations, governance issues, etc.

The evaluation of Independent Directors was carried
out by the entire Board and that of the Chairman and
the Non-Independent Directors were carried out by the
Independent Directors.

The performance of the Board was evaluated on the
basis of the criteria such as the Board composition and
structure, effectiveness of Board process, information
and functioning etc. The performance of the committees
was evaluated on the basis of the criteria such as
the composition of the committees, effectiveness of
committee meetings, etc. The Board and Nomination and
Remuneration Committee reviewed the performance of
the individual directors on the basis of the criteria such
as the contribution of individual director to the Board and
committee meetings like preparedness on the issue to be
discuss meaningful and constructive contribution and
inputs in meetings, etc.

The Directors were satisfied with the evaluation results,
which reflected the overall engagement of the Board and
its Committees with the Company.

In the coming year, the Board intends to enhance
focus on diversity of the Board through the process
of induction of members having industry expertise,
strategic plan, exploring the new drivers of growth and
further enhancing engagement with investors.

26. CORPORATE SOCIAL RESPONSIBILITY
INITIATIVES

In compliance with Section 135 of the Companies
Act, 2013 read with the Companies (Corporate Social
Responsibility Policy) Rules 2014, the Company has
established Corporate Social Responsibility (CSR)
Committee and statutory disclosures with respect to the
CSR Committee and an Annual Report on CSR Activities
forms part of this Report as
Annexure 'E'. The CSR
Policy may be accessed on the Company's website at
the weblink: https://www.goodluckindia.com

27. BUY BACK OF SECURITIES

The Company has not bought back any of its securities
during the year under review.

28. VIGIL MECHANISM

The Company is committed to adhere to the highest
standards of ethical, moral and legal conduct of business
operations. To maintain these standards, the Company
encourages its employees who have concerns about

suspected misconduct to come forward and express
these concerns without fear of punishment or unfair
treatment. A Vigil (Whistle Blower) mechanism provides
a channel to the employees and Directors to report to
the management concerns about genuine concerns
or grievances, unethical behavior, actual or suspected
fraud or violation of the Codes of conduct or legal or
regulatory requirements incorrect or misrepresentation
of any financial statements and reports, etc. The detail
vigil mechanism may be accessed on the Company's
website at the weblink: https://www.goodluckindia.com.

29. ANNUAL RETURN

Pursuant to Section 134(3)(a) and 92(3) of the Act, the
Annual Return for financial year 2022-23 of the Company
has been placed on the website of the Company at
https://www.goodluckindia.com.

30. PARTICULARS OF EMPLOYEES

Particulars of employees and the ratio of the
remuneration of each director to the median employee's
remuneration and other details in terms of Section
197 of the Companies Act, 2013 read with Rule 5(1)
of the Companies (Appointment and Remuneration of
Managerial Personnel) Rules, 2014 is attached herewith
as
Annexure 'F'.

31. PAYMENT OF LISTING FEES

Annual listing fee for the year 2022-23 has been paid by
the Company to the stock exchanges where the company
is listed, i.e., BSE Ltd. and National Stock Exchange
Limited.

32. MATERIAL CHANGES AND COMMITMENTS
AFFECTING THE FINANCIAL POSITION OF THE
COMPANY AS ON 31ST MARCH 2023

During the year, there was no change in the general
nature of business of your Company. Except as
disclosed elsewhere in this Report, no material change or
commitment has occurred which would have affected the
financial position of your Company between the end of
the financial year to which the financial statements relate
and the date of the report. No significant and material
order was passed by the regulators or courts or tribunals
which would have impacted the going concern status
and your Company's operations in future. Your Company
has not made any provision of money for the purchase
of, or subscription for, shares of your Company or its
holding company, to be held by or for the benefit of the
employees of your Company and hence the disclosure as
required under Rule 16(4) of Companies (Share Capital
and Debentures) Rules, 2014 is not required. No fraud
took place in the Company during the year and hence,

no such reporting was made to the Audit Committee and
the Board under Rule 13(3) of the Companies (Audit and
Auditors) Rules, 2014.

33. DETAILS OF APPLICATION PENDING UNDER
INSOLVENCY AND BANKRUPTCY CODE, 2016

During the year under the review, there has been no
application made or proceeding pending in the knowledge
of the company under the Insolvency and Bankruptcy
Code, 2016.

34. There is no instance for one-time settlement with Banks
or Financial Institutions. Hence, there is no question of
difference between amount of the valuation done at the
time of one-time settlement and the valuation done while
taking loan from the Banks or Financial Institutions.

35. DIRECTORS RESPONSIBILITY STATEMENT

As stipulated in Section 134(3) (c) of Companies
Act, 2013, your Directors subscribe to the "Directors
Responsibility Statement" and confirm as under:

a. That in the preparation of the annual accounts,
the applicable accounting standards have been
followed along with proper explanations relating to
material departures.

b. That the directors have selected such accounting
policies and applied them consistently and made
judgments and estimates that are reasonable and
prudent so as to give a true & fair view of the state
of affairs of the Company at the end of Financial
Year 2022-23 and of the Profit & Loss A/c of the
Company for that period.

c. That the directors have taken proper and sufficient
care of the maintenance of adequate accounting
records in accordance with the provisions of this
Act for safeguarding the assets of the company
and for preventing and detecting fraud and other
irregularities.

d. That the directors have prepared the annual
accounts on a going concern basis.

e. The directors, in case of a listed company, have laid
down internal financial controls to be followed by the
Company and that such internal financial controls
are adequate and were operating effectively.

f. The directors have devised proper systems to ensure
compliance with the provisions of all applicable
laws and that such systems were adequate and
operating effectively.

36. APPRECIATION

Your Directors wish to thank and acknowledge with
gratitude for assistance and co-operation received from
the financial institutions, banks, government authorities,
customer, vendors, and members during the year under
review. Your directors also wish to place on record their
deep sense of appreciation for the committed services
by the executives, staff and workers of the company.

On behalf of the Board of Directors

M. C. GARG

Chairman

Date: 2nd September 2023

Place: Ghaziabad