We have audited the accompanying standalone financial statements of NMDC Steel Limited ("the Company”), which comprise the Balance Sheet as at March 31,
2025, and the Statement of Profit and Loss (including Other Comprehensive Income), Statement of Changes in Equity and the Statement of Cash Flows for the year ended on that date and notes to the Standalone financial statements including a summary of material accounting policies and other explanatory information.
In our opinion and to the best of our information and according to the explanations given to us, the aforesaid Standalone financial statements give the information required by the Companies Act, 2013 ("the Act”) in the manner so required and give a true and fair view in conformity with the Indian Accounting Standards prescribed under section 133 of the Act read with the Companies (Indian Accounting Standards) Rules, 2015, as amended, ("Ind AS”) and other accounting principles generally accepted in India, of the state of affairs of the Company as at March 31, 2025, and its loss, total comprehensive loss, changes in equity and its cash flows for the year ended on that date.
Basis for Opinion
We conducted our audit of the standalone financial statements in accordance with the Standards on Auditing ("SAs”) specified under section 143(10) of the Act.
Our responsibilities under those Standards are further described in the Auditor's Responsibility for the Audit of the Standalone financial Statements section of our report. We are independent of the Company in accordance with
the Code of Ethics issued by the Institute of Chartered Accountants of India (ICAI) together with the ethical requirements that are relevant to our audit of the Standalone financial statements under the provisions of the Act and the Rules made thereunder, and we have fulfilled our other ethical responsibilities in accordance with these requirements and the ICAI's Code of Ethics.
We believe that the audit evidence obtained by us is sufficient and appropriate to provide a basis for our audit opinion on the Standalone financial statements.
Key Audit Matters
Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the standalone financial statements for the financial year ended March 31, 2025. These matters were addressed in the context of our audit of the standalone financial statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters. For each matter below, our description of how our audit addressed the matter is provided in that context.
We have determined the matters described below to be the key audit matters to be communicated in our report.
We have fulfilled the responsibilities described in the Auditor's responsibilities for the audit of the standalone financial statements section of our report, including in relation to these matters. Accordingly, our audit included the performance of procedures designed to respond to our assessment of the risks of material misstatement of the standalone financial statements. The results of our audit procedures, including the procedures performed to address the matters below, provide the basis for our audit opinion on the accompanying standalone financial statements.
S
.. Key Audit Matter No
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Auditor's Response
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1 Litigation Matters, Provisions and Contingent Liabilities related to ongoing litigations
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The Company has certain significant ongoing legal and arbitration proceedings, tax cases for various complex matters with the Courts and other forums, continuing from earlier years.
Management's disclosures with regards to provisions and contingent liabilities relating to ongoing litigations are presented in note 2.28
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Our audit procedures included and were not limited to the following:
We have tested the design, implementation and operating effectiveness of the controls established by the Company in the process of evaluation of litigation matters.
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No
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Key Audit Matter
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Auditor's Response
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to the Company's Financial Statements. Refer note 1.3.ix for related material accounting policy information adopted by the Company.
The assessment of whether a liability is recognised as a provision or disclosed as a contingent liability in the standalone financial statements is inherently subjective and requires significant management judgement in determination of the cash outflows, interpretation of applicable laws and regulations, and careful examination of pending assessments at various levels of regulatory authorities.
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We have assessed the management's position through discussions with the in-house legal expert , the probability of success in the aforesaid cases, and the magnitude of any potential loss.
We have reviewed the legal and professional expenses incurred and discussed with the management on the developments in respect of these litigations during the year ended 31st March, 2025 till the date of approval of the Standalone Financial Statements.
Rolled out of enquiry letters to the Company's legal counsel.
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Due to complexity involved in these litigation matters, management's judgement regarding recognition, measurement and disclosure of provisions for these legal proceedings is inherently uncertain and might change over time as the outcomes of the legal cases are determined.
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We have reviewed the disclosures made by the Company in the Financial Statements in accordance with the applicable Indian Accounting Standards.
We have Obtained Management representation letter on the assessment of these matters.
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Accordingly, it has been considered as a key audit matter.
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2
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Property, plant and equipment and intangible assets (including capital work in progress)
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As at 31st March 2025 the Company has Property, Plant and Equipment (PPE'), Capital Work-in¬ Progress ('CWIP') and Intangible Asset (IA') with carrying value of H 20,083.48 crore, H 717.19 crore and H 4.72 crore respectively, as disclosed in note 2.1.1, note 2.2 and note 2.3 of the accompanying Standalone Financial Statements.
Refer note 1.3.iv.(a),(b) and note 1.3.v for the material accounting policy information adopted by the Company for recognition and measurement of Property, Plant and Equipment, CWIP and Intangible Assets.
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Our procedures included and were not limited to the following:
We have obtained an understanding of the company's capitalization policy and management's process of recording the transactions pertaining to capital expenditure incurred by the company and evaluated the accounting policies adopted by the company in accordance with the requirements of Ind AS 16 and Ind AS 38.
We have evaluated the design and tested the operating effectiveness of the controls put in place by the management in relation to the above process. We have obtained componentization reports issued by third party management experts for capitalizations carried out during the year and have assessed appropriateness of basis of componentization and estimates of useful life.
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Determination of carrying values and their respective depreciation and amortisation amounts of PPE, IA and CWIP requires considerable management judgement. The decisions to capitalise or expense costs, the useful life review, residual value review the timeliness of the capitalisation of assets, Spare Parts Capitalization and the use of management's assumptions and judgementsfor the determination and measurement of assets retired from active use,
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We have tested the amounts capitalized during the year, on a sample basis, by inspecting supporting documents and evaluating whether assets capitalized satisfied the recognition criteria in accordance with Indian Accounting Standards and were recognized accurately in the correct periods and with correct amounts.
We have reviewed the judgements made by management in determination of carrying values of the specified noncurrent assets including the nature of underlying costs capitalized, determination of realizable value of the assets retired from active use, the appropriateness of useful lives and residual values applied in the calculation of depreciation as determined by technical assessment by management and
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S
No
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Key Audit Matter
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Auditor's Response
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in accordance with the requirements of Ind AS 16 - Property, Plant and Equipment ('Ind AS 16') and Ind AS 38 - Intangible Assets ('Ind AS 38').
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external technical experts, where required, and evaluation of appropriateness of long outstanding CWIP balances pertaining to long-term projects.
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Considering the significance of amounts involved in the context of the balance sheet of the Company and the level of judgements and estimates required, we consider this to be a key audit matter in the current year audit.
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We have evaluated the appropriateness and adequacy of the related disclosures in the financial statements in accordance with Schedule III to the Companies Act, 2013 and the applicable Indian accounting standards.
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3
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Inventories
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As at 31 March 2025, the Company has a significant amount of inventory comprising raw materials of H 1275.73 crores, work-in-progress of H 563.17 crores and finished goods of H 810.25 crores. Inventories are valued at the lower of cost and net realisable value (NRV) in accordance with Ind AS 2 - Inventories.
Refer to the note no. 2.7 Inventories to the Financial statements and Refer note 1.3.vi. for the material accounting policy information adopted by the Company for recognition and measurement of inventories.
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Our procedures included and were not limited to the following:
We have understood and performed the walkthroughs of the inventory valuation process and controls over recording and monitoring inventory.
We have evaluated the design and implementation of internal controls with regard to the Inventory valuation, Obsolescence assessment, Physical verification processes. We Observed inventory counts conducted by management or third parties at selected locations and verified count sheets to test the accuracy of inventory records.
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The determination of cost involves judgment in selecting an appropriate cost formula, particularly for items with fluctuating prices. The assessment of NRV involves significant estimation, especially in respect of slow-moving, obsolete, or excess inventories and for products where selling prices are volatile or uncertain.
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We have performed sample testing of inventory valuation by verifying the basis of cost (raw materials, labour, overhead allocation) in SAP through purchase orders terms and conditions and observed the cost calculation, cost allocation through Cost Run Process in SAP on a sample basis, then compared it with the accounting policy and verified the accounting treatment given in the SAP Books.
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Due to the volume of inventory, estimation involved in determining NRV, and the judgment in identifying obsolete or slow-moving inventory, this area is considered a key audit matter.
The Management has appointed an external technical expert to carry out the physical verification of Raw materials which consists of Coal, Iron Ore and Coke products (by-products). The external technical expert team carried out the physical verification of the said categories of inventory from 26.03.2025 to 04.04.2025 with the objective to quantify the actual physical stock available at various locations within the plant.
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We have assessed the Net Realisable Value (NRV) by reviewing sales data after year-end for selected inventory items and compared the cost to actual selling prices less estimated selling costs and also evaluated the reasonableness of estimates and assumptions used.
We have reviewed the disclosures made in the financial statements in accordance with Ind AS 2 for adequacy and appropriateness.
We have reviewed the appointment procedures followed for selecting the management expert, enquired & obtained the details of previous work history, experience in the current field to assess the competency and interacted with the team of experts understood the working mechanism, results from the devices and stockpile measuring tools being used in the stock verification process.
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We have Obtained an understanding of the communication between the management and the expert for information and collection of daily results of physical verification of inventory - Raw materials and Byproducts.
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No
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Key Audit Matter
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Auditor's Response
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Based on the report provided by the external
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We were present during the physical verification of
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technical expert, the Company has given the
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raw material & by-products and observed the process
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necessary effect in the financial statements with
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performed by the external technical expert. Obtained the
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respect to deviation between the physical stock
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report provided by the external technical expert from the
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and book stock in SAP.
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management and analysed the same with respect to the reports generated from the devices used and noted the quantity deviations with respect to actual stock in SAP.
We have compared the quantity deviations of the Inventory physically verified with the deviation levels (as % norms for shortages) as recommended by the company and noticed to be within the set levels as compared with the industry standards.
We have also conducted the Physical verification of Finished Goods (HR Coils) on a sample basis and identified the actual stock based on the coil ID located in the sector- wise bay location in the plant and also verified the physical verification conducted by the management for total finished goods and semi-finished goods. We have reviewed the disclosures made in the financial statements in accordance with Ind AS 2 for adequacy and appropriateness with respect to the number of losses.
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4
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Recognition of Revenue from Contract with Customers
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Revenue is a significant item in the financial
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Our audit procedures included but were not limited to the
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statements and is one of the key performance indicators of the Company. The Company
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following:
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recognizes revenue from sale of goods and services
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We have understood and evaluated the Company's revenue
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as per the five-step model prescribed under Ind AS
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recognition policy and assessed the compliance with Ind AS
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115 - Revenue from Contracts with Customers.
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115. We have evaluated the design and tested the operating effectiveness of internal controls relating to revenue
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The Company has recognised the revenue from operations of H 8503.05 crores during the FY 2024-
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recognition.
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25 from the manufacture and sale of Hot-Rolled
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We have tested, on a sample basis, contracts with
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(HR Coils), HR Sheets, Pig Iron, Pit Iron and other
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customers to assess whether the five-step model under Ind
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by-products.
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AS 115 is correctly applied, which included the following:
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The revenue recognition criteria have been
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- Conducted the detailed study of the agreement on
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disclosed under the point xii of the material
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a sample basis with customers (including the MOU's
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accounting policies.
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entered with other peers in the industry like SAIL etc) and identified the performance obligations in each contract
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Application of Ind AS 115 involves significant
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agreement. Evaluated the transaction prices and identified
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judgement in identifying performance obligations,
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the allocating process of the transaction price to the
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determining transaction price, allocating the
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performance obligations. Finally tested the accuracy of
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transaction price to performance obligations, and assessing the timing of revenue recognition
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timing of revenue recognized and amounts determined.
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(whether at a point in time or over time).
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We have performed a detailed walkthrough process and understood the Business and Sales Process of the company. We have held detailed discussions with management and process owners to understand the nature of goods/services sold and reviewed the typical contract terms with customers (standard and customized contracts). Understood the process of order receipt, dispatch/delivery,
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S
No
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Key Audit Matter
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Auditor's Response
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Given the complexity and the volume of transactions, there is a risk of inappropriate recognition of revenue, particularly close to the year end.
Accordingly, revenue recognition has been identified as a key audit matter
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invoicing, and revenue recognition procedures also correlated with the process flow in SAP. We have also looked into the industry-specific revenue recognition nuances (with Inco-terms such as Ex-Works, Delivery at Point, CIF etc)
We have walked through the entire order-to-cash cycle and observed the Sales order processing: Verified the controls over acceptance and authorization of orders. Verified the Inventory dispatches with respect to evaluation of how dispatch/delivery is recorded (e.g., shipping documents, delivery challans).
We have Observed the process of Invoicing: Reviewed how invoices are generated and linked to dispatch documentation. Revenue recognition: Identified the point at which revenue is recognized and assessed if it aligns with transfer of control per Ind AS 115. We have traced how payments are matched against invoices and accounted in SAP as a part of cash application procedures.
We have Performed the substantive analytical procedures and trend analysis on revenue streams for product wise, customer wise to identify any unusual patterns or inconsistencies. We have Tested the revenue transactions occurring near year-end as a part of our cut off procedures related to quarter end/ year end to determine whether revenue was recognized in the correct accounting period. We have Assessed the disclosures in the financial statements relating to revenue recognition (including the disaggregated revenue disclosures) to ensure adequacy and compliance with Ind AS 115 and the requirements of Schedule III to the Companies Act, 2013.
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Emphasis of Matter
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Other Matter
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1.
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We draw attention to Note 2.32.15 to the standalone Ind AS financial statements, which describes the management's assessment that the interest clause relating to delayed payments under a Long-Term Agreement with a supplier is not enforceable in substance. This conclusion is based on historical commercial practice, confirmation obtained from the supplier, and the absence of any claims or intent to enforce the clause. Accordingly, no provision has been made in respect of such interest.
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1. The Standalone financial statements for the year ended March 31,2025 includes comparative financial information for the year ended March 31,2024. The Standalone financial statements for the year ended March 31,2024 have been audited by predecessor auditor, M/s Sanjiv Shah & Associates, who expressed unmodified opinion on those financial statements vide their revised report dated July 24,2024.
Our opinion is not modified for the above matter.
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2.
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We draw attention to Note 2.30.1 to the standalone financial statements, which describes the delayed compliance from the approved Scheme of Arrangement as approved by Ministry of Corporate Affairs with regard to non-identification of employees of demerged Company to the resulting Company till the year under audit.
Our opinion is not modified in respect of this matter.
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Information Other than the financial Statements and Auditor's Report Thereon
• The Company's Board of Directors is responsible for the other information. The other information comprises the information included in the Board's report and the Annexures to the Board's report but does not include Standalone financial statements, and our auditor's report thereon.
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• Our opinion on the standalone 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 standalone financial statements, our responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent
with the Standalone financial statements or our knowledge obtained during the course of our audit or otherwise appears to be materially misstated.
• If, based on the work we have performed, we conclude that there is a material misstatement of this other information, we are required to report that fact. We have nothing to report in this regard.
Responsibilities of Company Management and Those Charged with Governance for the Standalone Financial Statements
The Company's Board of Directors is responsible for the matters stated in Section 134(5) of the Act with respect to the preparation of these standalone financial statements 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 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 statement that give a true and fair view and are free from material misstatement, whether due to fraud or error.
In preparing the standalone financial statements,
Company 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 the Board of Directors either intends to liquidate the Company or to cease operations, or has no realistic alternative but to do so.
The Company's Board of Directors are also responsible for overseeing the Company's financial reporting process.
Auditor's Responsibility for the Audit of the Standalone Financial Statements
Our objectives are to obtain reasonable assurance about whether the Standalone financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor's report that includes our opinion. Reasonable assurance is a high level of assurance but is not a guarantee that an audit conducted in accordance with SAs will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these standalone 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 standalone 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 financial control relevant to the audit in order to design audit procedures that are appropriate in the circumstances. Under section 143(3)(i) of the Act, we are also responsible for expressing our opinion on whether the Company has adequate internal financial controls with reference to standalone financial statements 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
the 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 Standalone 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 standalone financial statements, including the disclosures, and whether the standalone financial statements represent the underlying transactions and events in a manner that achieves fair presentation.
Materiality is the magnitude of misstatements in the standalone financial statements that, individually or in aggregate, makes it probable that the economic decisions of a reasonably knowledgeable user of the Standalone financial statements may be influenced. We consider quantitative materiality and qualitative factors in (i) planning the scope of our audit work and in evaluating the results of our work; and (ii) to evaluate the effect of any identified misstatements in the standalone financial statements.
We communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit and significant audit findings, including any significant deficiencies in internal control that we identify during our audit.
We also provide those charged with governance with a statement that we have complied with relevant ethical requirements regarding independence, and to communicate with them all relationships and other matters that may reasonably be thought to bear on our independence, and where applicable, related safeguards.
Report on Other Legal and Regulatory Requirements
1. As required by Section 143(3) of the Act, based on our audit, 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 of accompanying financial statements.
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 stated in paragraph i(vi) below on reporting under Rule 11(g).
c) The Balance Sheet, the Statement of Profit and Loss including Other Comprehensive
Income, Statement of Changes in Equity and the Statement of Cash Flows dealt with by this Report are in agreement with the relevant books of account.
d) In our opinion, the aforesaid Standalone financial statements comply with the Ind AS specified under Section 133 of the Act.
e) The provisions of Section 164(2) of the Act are not applicable to the Company vide Ministry of Corporate Affairs notification G.S.R 464 (E) dated 5th June 2015 since the Company is a Government company as defined under section 2(45) of the Act;
f) With respect to the adequacy of the internal financial controls with reference to standalone financial statements of the Company and the operating effectiveness of such controls, refer to our separate Report in "Annexure A”. Our report expresses an unmodified opinion on the adequacy and operating effectiveness of the Company's internal financial controls with reference to standalone financial statements;
g) With respect to the matter to be included in the Auditor's Report under section 197(16) of the Act, as amended, we are informed that the Company being a Government company, as defined in section 2(45) of the Act, the provisions of section 197 read with Schedule V, of the Act, relating to managerial remuneration are not applicable to the Company, in terms of Ministry of Corporate Affairs notification G.S.R 464 (E) dated 5th June 2015;
h) The modification relating to the maintenance of accounts and other matters connected therewith are as stated in the paragraph b above on reporting under section 143(3)
(b) and paragraph i(vi) below on reporting under Rule 11(g).
i) 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, 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 impact of pending litigations on its financial position in its financial statements - Refer note 2.28 to the standalone financial statements.
As part of our audit procedures, we sought direct confirmation from the legal counsel of the Company to corroborate the financial impact of the disclosed
pending litigations; however, we did not receive any response. Consequently, we have relied solely on the management's representation and disclosures made in the financial statements.
ii. The company does 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, as disclosed in Note 2.29.ix to the standalone financial statements no funds have been advanced or loaned or invested (either from borrowed funds or share premium or any other sources or kinds 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, 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, as disclosed in Note 2.29.x to the standalone financial statements, 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, 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 audit procedures performed by 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 the 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 year and has not proposed final dividend for the year.
vi. Based on our examination which included test checks and more fully described in note 2.32.17 to the standalone financial statements, the Company has used an accounting software for maintaining its books of account for the year ended March 31, 2025, which has a feature of recording audit trail (edit log) facility and the same has operated throughout the year for
all the relevant transactions recorded in such software except that the feature of recording audit trail (edit log) at the data base level to log any direct changes for the accounting software used for maintaining the books of account was not enabled. Further, during the course of our audit we did not come across any instance of the audit trail feature being tampered with.
Audit trail, except at the database level, has been preserved by the Company as per the statutory requirements for record retention.
2. As required by the Companies (Auditor's Report) Order, 2020 ("the Order”) issued by the Central Government in terms of Section 143(11) of the Act, we give in "Annexure B” a statement on the matters specified in paragraphs 3 and 4 of the Order.
3. As Required by Comptroller and Auditor General of India in terms of sub section (5) of section 143 of the Act, we give in the "Annexure C” statement on directions issued.
For SHARAD & ASSOCIATES
Chartered Accountants Firm's registration number: 06377S
Sharad Sinha
Partner
Membership Number: 202692
Hyderabad, May 27,2025 UDIN: 25202692BMHZAJ7857
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