Tata Steel Auditors Report


To the Members of Tata Steel Limited Report on the Audit of the Standalone Financial Statements

Opinion

1. We have audited the accompanying standalone financial statements of Tata Steel Limited ("the Company"), which comprise the Balance Sheet as at March 31, 2024, and the Statement of Profit and Loss (including Other Comprehensive Income), the Statement of Changes in Equity and the Statement of Cash Flows for the year then ended, and notes to the standalone financial statements, including material accounting policy information and other explanatory information.

2. 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 accounting principles generally accepted in India, of the state of affairs of the Company as at March 31, 2024, and total comprehensive income (comprising of profit and other comprehensive income), changes in equity and its cash flows for the year then ended.

Basis for Opinion

3. We conducted our audit 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 "Auditors responsibilities 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 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 thereunder, and we have fulfilled our other ethical responsibilities in accordance with these requirements and the Code of Ethics. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.

Key audit matters

4. Key audit matters are those matters that, in our professional judgement, were of most significance in our audit of the standalone financial statements of the current period. 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.

Key audit matter

How our audit addressed the key audit matter

Business Combination under Common Control Amalgamation of Tata Steel Long Products Limited (TSLP), Tata Steel Mining Limited (TSML), Tata Metaliks Limited

Our audit procedures included the following:

• We understood from the management, assessed and tested the design and operating effectiveness of the Companys key controls over the accounting for business combinations.

(TML), The Tinplate Company of India Limited (TCIL) and S&T Mining Company Limited (S&T)

[Refer to Note 2(d) to the standalone financial statements

• We traced the assets and liabilities as at April 1, 2022 and results for the financial year ended March 31, 2023 of TSML, TSLP, S&T, TCIL and TML from the audited standalone Financial Statements / Information of the respective subsidiaries.

"Business combination under common control" and Note 43 to the standalone financial statements]

Pursuant to the National Company Law Tribunal (NCLT) Orders received during the year, subsidiaries of the Company, viz., TSML, TSLP, S&T, TCIL and TML ("Transferor Companies") were merged with the Company. The Appointed Dates as per the Schemes of Amalgamation is April 1, 2022 for TSLP, S&T, TCIL and TML and April 1, 2023 for TSML.

• We recomputed the value of fully paid-up equity shares issued as the consideration with reference to the NCLT Orders.

• We evaluated the Companys accounting of the business combinations in accordance with the pooling of interests method in Appendix C of Ind AS 103, Business Combinations in accordance with the NCLT Orders.

The Company has accounted for the business combinations using the pooling of interests method in accordance with Appendix C of Ind AS 103, Business Combinations in accordance with the NCLT Orders. The carrying value of the assets and liabilities of the subsidiaries as at April 1, 2022 (being the beginning of the previous period presented), as appearing in the consolidated financial statements of the Company before the merger have been incorporated in the books with merger adjustments, as applicable.

• We tested the managements computation of determining the amount recorded in the capital reserve.
• We assessed the adequacy and appropriateness of the disclosures made in the standalone financial statements.

Based on the above work performed, no significant exceptions were noted in the accounting for business combinations under common control in respect of the Amalgamation of TSLP, TSML, TML, TCIL and S&T.

The Company has allotted fully paid-up equity shares to the eligible shareholders of the erstwhile subsidiaries TSLP, TCIL and TML in accordance with the respective Schemes.

The Company has recognised capital reserve of _791.47 crore in "Other Equity".

Considering the complex accounting involved, the aforesaid business combinations treatment in the standalone financial statements has been considered to be a key audit matter.

 

Key audit matter

How our audit addressed the key audit matter
Assessment of carrying value of investments in T Steel Our audit procedures included the following:

Holdings Pte. Ltd. (TSH), a wholly owned subsidiary and Neelachal Ispat Nigam Limited (NINL), a subsidiary company

• We obtained an understanding from the management, assessed and tested the design and operating effectiveness of the Companys key controls over the impairment assessment of investments.

[Refer to Note 2(c) to the standalone financial statements

– "Use of estimates and critical accounting judgements –

• We evaluated the appropriateness of the Companys accounting policy in respect of impairment assessment of investments in subsidiaries.

Impairment", Note 2(l) to the standalone financial statements

- "Investments in subsidiaries, associates and joint ventures", 2(m)(I) to the standalone financial statements – "Financial

Assets", Note 6 to the standalone financial statements –"Investments", Note 6(iii) and 6(iv) to the standalone financial statements]

• We evaluated the Companys process regarding impairment assessment by involving auditors valuation experts, where considered necessary, to assist in assessing the appropriateness of the impairment assessment models, underlying assumptions relating to discount rate, terminal value etc.

The Companys equity investment in its subsidiary T Steel

Holdings Pte. Ltd. (TSH) amounts to I43,815.17 crore (net of impairment).

• We evaluated the cash flow forecasts by comparing them to the budgets, as applicable, and our understanding of the internal and external factors.

The above equity investment in TSH is carried at cost.

The Companys investment in 0.01% non-convertible, non- cumulative redeemable preference shares (NCRPS) and equity investment in its subsidiary Neelachal Ispat Nigam

• We checked the mathematical accuracy of the impairment assessment models and agreed the relevant data with the latest budgets, actual past results and other supporting documents, as applicable.

Limited (NINL) amounts to I5,507.78 crore and I8,689.04 crore respectively.

The Company accounts for investment in NCRPS of NINL initially at fair value and subsequently at amortised cost.

• We assessed the sensitivity analysis and evaluated whether any reasonably foreseeable change in assumptions could lead to impairment.

Contractual cash flows from the NCRPS represent the principal (I4,560.54 crore) plus accrued interest (I947.24 crore) aggregating to I5,507.78 crore as on March 31, 2024.

• We have discussed the key assumptions and sensitivities with those charged with governance.

The above equity investment in NINL is carried at cost.

• We evaluated the appropriateness of the disclosures made in the standalone financial statements.

Where an indication of impairment exists, the carrying value of investment is assessed for impairment and where applicable an impairment provision is recognised.

Based on the above procedures performed, no significant exceptions were noted in the managements assessment in relation to the carrying value of investments in aforesaid subsidiaries.

The impairment assessment for such investments have been carried out by the management in accordance with Ind AS 36 and Ind AS 109, as applicable.

The key inputs and judgements involved in the impairment of unquoted investments include:

• Cash flows forecast/incremental cash flows including assumptions on capacity expansion

• Discount rates
• Terminal growth rate

• Economic and entity specific factors incorporated in the impairment assessment models.

The accounting for above investments is a key audit matter as the determination of recoverable value for impairment assessment involves significant management judgement and estimates.

 

Key audit matter

How our audit addressed the key audit matter

Assessment of litigations and related disclosures of contingent liabilities

Our audit procedures included the following:

• We understood from the management, assessed and tested the design and operating effectiveness of the Companys key controls surrounding assessment of litigations relating to the relevant laws and regulations.

[Refer to Note 2(c) to the standalone financial statements - "Use of estimates and critical accounting judgements

– Provisions and contingent liabilities", Note 34(A) to the standalone financial statements "Contingencies" and Note 35 to the standalone financial statements – "Other significant litigations"]

• We have reviewed the legal and other professional expenses and enquired with the management for recent developments and the status of the material litigations which were reviewed.

As at March 31, 2024, the Company has exposures towards litigations relating to various matters as set out in the aforesaid Notes. Significant management judgement is required to assess such matters to determine the probability of occurrence of material outflow of economic resources and whether a provision should be recognised or a disclosure should be made. The management judgement is also supported with legal advice in certain cases, as considered appropriate. As the ultimate outcome of the matters are uncertain and the positions taken by the management are based on the application of their best judgement, related legal advice including those relating to interpretation of laws/regulations, it is considered as a key audit matter.

• We performed our assessment on a test basis on the underlying calculations supporting the contingent liabilities/ other significant litigations disclosed in the standalone financial statements.
• We used auditors experts/specialists to gain an understanding and to evaluate the disputed tax matters.
• We considered external legal opinions, where relevant, obtained by management.
• We evaluated managements assessments by understanding precedents set in similar cases and assessed the reliability of the managements past estimates/judgements.
• We evaluated managements assessment around those matters that are not disclosed or not considered as contingent liability, as the probability of material outflow is considered to be remote by the management.
• We assessed the adequacy of the Companys disclosures. Based on the above work performed, no significant exceptions were noted in the assessment in respect of litigations and related disclosures relating to contingent liabilities/other significant litigations in the standalone financial statements.

Other Information

5. The Companys Board of Directors is responsible for the other information. The other information comprises Management Discussion and Analysis and Boards report (but does not include the standalone financial statements and our auditors report thereon), which we obtained prior to the date of this auditors report, and additional information excluding those referred above that would be included in the Integrated Report (titled as ‘Tata Steel Integrated Report & Annual Accounts 2023-24), which is expected to be made available to us after the date of our report. 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 identified above and, in doing so, consider whether the other information is materially inconsistent with the standalone financial statements, or our knowledge obtained in the audit or otherwise appears to be materially misstated.

If, based on the work we have performed on the other information that we obtained prior to the date of this auditors report, 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.

When we read the additional information, as mentioned above, that would be included in the Integrated Report, if we conclude that there is a material misstatement therein, we are required to communicate the matter to those charged with governance and take appropriate actions as applicable under the relevant laws and regulations.

Responsibilities of management and those charged with governance for the Standalone Financial Statements

6. The Companys 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, changes in equity and cash flows of the Company in accordance with the accounting principles generally accepted in India, including the Accounting Standards specified 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 of the assets of the Company and for preventing and detecting frauds and other irregularities; selection and application of appropriate accounting policies; making judgments and estimates that are reasonable and prudent; and design, implementation and maintenance of adequate internal financial controls, that were operating effectively for ensuring the accuracy and completeness of the accounting records, relevant to the preparation and presentation of the standalone financial statements that give a true and fair view and are free from material misstatement, whether due to fraud or error.

7. In preparing the standalone financial statements, management is responsible for assessing the Companys 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 Companys financial reporting process.

Auditors responsibilities for the Audit of the Standalone Financial Statements

8. 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 auditors 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.

9. As part of an audit in accordance with SAs, we exercise professional judgement and maintain professional scepticism 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 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 management.

• Conclude on the appropriateness of managements 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 Companys ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditors 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 auditors 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.

10. 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 de_ciencies in internal control that we identify during our audit. 11. 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. 12. From the matters communicated with those charged with governance, we determine those matters that were of most significance in the audit of the standalone financial statements of the current period and are therefore the key audit matters. We describe these matters in our auditors report unless law or regulation precludes public disclosure about the matter or when, in extremely rare circumstances, we determine that a matter should not be communicated in our report because the adverse consequences of doing so would reasonably be expected to outweigh the public interest benefits of such communication.

Report on other legal and regulatory requirements

13. As required by the Companies (Auditors Report) Order, 2020 ("the Order"), issued by the Central Government of India in terms of sub-section (11) of Section 143 of the Act, we give in the Annexure B a statement on the matters specified in paragraphs 3 and 4 of the Order, to the extent applicable. 14. As required by Section 143(3) of the Act, we report that: (a) We have sought and obtained all the information and explanations which to the best of our knowledge and belief were necessary for the purposes of our audit. (b) In our opinion, proper books of 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 14(h) (vi) below on reporting under Rule 11(g) of the Companies (Audit and Auditors) Rules, 2014 (as amended). (c) The Balance Sheet, the Statement of Profit and Loss (including other comprehensive income), the Statement of Changes in Equity and the Statement of Cash Flows dealt with by this Report are in agreement with the books of account. (d) In our opinion, the aforesaid standalone financial statements comply with the Accounting Standards specified under Section 133 of the Act. (e) On the basis of the written representations received from the directors, taken on record by the Board of Directors, none of the directors is disqualified as on March 31, 2024, from being appointed as a director in terms of Section 164(2) of the Act. (f) With respect to the maintenance of accounts and other matters connected therewith, reference is made to our remarks in paragraph 14(b) above on reporting under Section 143(3)(b) and paragraph 14(h)(vi) below on reporting under Rule 11(g) of the Rules.

(g) 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". (h) With respect to the other matters to be included in the Auditors Report in accordance with Rule 11 of the Rules, 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 standalone financial statements – Refer Notes 34(A) and 35 to the standalone financial statements; ii. The Company did not have any long-term contracts including derivative contracts for which there were any material foreseeable losses. iii. There has been no delay in transferring amounts, required to be transferred, to the Investor Education and Protection Fund by the Company during the year ended March 31, 2024. iv. (a) The management has represented that, to the best of its knowledge and belief, other than as disclosed in Notes 6(viii) and 7(v) 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 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) The management has represented that, to the best of its knowledge and belief, as disclosed in the Notes 6(ix) and 7(vi) 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, 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; and (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 (a) and (b) contain any material misstatement. v. The dividend declared and paid during the year by the Company is in compliance with Section 123 of the Act. vi. Based on our examination, which included test checks, the Company has used multiple accounting software for maintaining its books of account which have a feature of recording audit trail (edit log) facility and that has operated throughout the year for all relevant transactions recorded in accounting software, except for modifications, if any, made by certain users with specific access in five applications and for direct database changes for all the accounting software. During the course of performing our procedures, except for the aforesaid instances of audit trail not maintained where the question of our commenting on whether the audit trail has been tampered with does not arise, we did not notice any instance of audit trail feature being tampered with.

15. The Company has paid/ provided for managerial remuneration in accordance with the requisite approvals mandated by the provisions of Section 197 read with Schedule V to the Act.

For Price Waterhouse & Co Chartered Accountants LLP
Firm Registration Number: 304026E/E-300009

Subramanian Vivek

Partner
Membership Number 100332
UDIN: 24100332BKGFNL1709

ANNEXURE A TO INDEPENDENT AUDITORS REPORT

Referred to in paragraph 14(g) of the Independent Auditors Report of even date to the members of Tata Steel Limited on the standalone financial statements as of and for the year ended March 31, 2024

Report on the Internal Financial Controls with reference to Standalone Financial Statements under clause (i) of sub-section 3 of Section 143 of the Act

1. We have audited the internal financial controls with reference to standalone financial statements of Tata Steel Limited ("the Company") as of March 31, 2024 in conjunction with our audit of the standalone financial statements of the Company for the year ended on that date.

Managements Responsibility for Internal Financial Controls

2. The Companys management is responsible for establishing and maintaining internal financial controls based on the internal control over financial reporting criteria established by the Company considering the essential components of internal control stated in the Guidance Note on Audit of Internal Financial Controls Over Financial Reporting ("the Guidance Note") issued by the Institute of Chartered Accountants of India ("ICAI"). These responsibilities include the design, implementation and maintenance of adequate internal financial controls that were operating effectively for ensuring the orderly and efficient conduct of its business, including adherence to companys 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 information, as required under the Act.

Auditors Responsibility

3. Our responsibility is to express an opinion on the Companys internal financial controls with reference to standalone financial statements based on our audit. We conducted our audit in accordance with the Guidance Note and the Standards on Auditing deemed to be prescribed under Section 143(10) of the Act to the extent applicable to an audit of internal financial controls, both applicable to an audit of internal financial controls and both issued by the ICAI. Those Standards and the Guidance Note require that we comply with ethical requirements and plan and perform the audit to obtain reasonable assurance about whether adequate internal financial controls with reference to standalone financial statements was established and maintained and if such controls operated effectively in all material respects.

4. Our audit involves performing procedures to obtain audit evidence about the adequacy of the internal financial controls system with reference to standalone financial statements and their operating effectiveness. Our audit of internal financial controls with reference to standalone financial statements included obtaining an understanding of internal financial controls with reference to standalone financial statements, assessing the risk that a material weakness exists, and testing and evaluating the design and operating effectiveness of internal control based on the assessed risk. The procedures selected depend on the auditors judgement, including the assessment of the risks of material misstatement of the financial statements, whether due to fraud or error.

5. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion on the Companys internal financial controls system with reference to standalone financial statements.

Meaning of Internal Financial Controls with reference to financial statements

6. A companys internal financial controls with reference to financial statements is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles. A companys internal financial controls with reference to financial statements includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the company; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the company are being made only in accordance with authorisations of management and directors of the company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorised acquisition, use, or disposition of the companys assets that could have a material effect on the financial statements.

Inherent Limitations of Internal Financial Controls with reference to financial statements

7. Because of the inherent limitations of internal financial controls with reference to financial statements, including the possibility of collusion or improper management override of controls, material misstatements due to error or fraud may occur and not be detected. Also, projections of any evaluation of the internal financial controls with reference to financial statements to future periods are subject to the risk that the internal financial controls with reference to financial statements may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

Opinion

8. In our opinion, the Company has, in all material respects, an adequate internal financial controls system with reference to standalone financial statements and such internal financial controls with reference to standalone financial statements were operating effectively as at March 31, 2024, based on the internal control over financial reporting criteria established by the Company considering the essential components of internal control stated in the Guidance Note issued by ICAI.

For Price Waterhouse & Co Chartered Accountants LLP
Firm Registration Number: 304026E/E-300009

Subramanian Vivek

Partner
Membership Number 100332
UDIN: 24100332BKGFNL1709

ANNEXURE B TO INDEPENDENT AUDITORS REPORT

Referred to in paragraph 13 of the Independent Auditors Report of even date to the members of Tata Steel Limited on the standalone financial statements as of and for the year ended March 31, 2024 In terms of the information and explanations sought by us and furnished by the Company, and the books of account and records examined by us during the course of our audit, and to the best of our knowledge and belief, we report that: i. (a) (A) The Company is maintaining proper records showing full particulars, including quantitative details and situation, of Property, Plant and Equipment.

(B) The Company is maintaining proper records showing full particulars of Intangible Assets.

(b) The Property, Plant and Equipment are physically verified by the Management according to a phased programme designed to cover all the items over a period of three years which, in our opinion, is reasonable having regard to the size of the Company and the nature of its assets. Pursuant to the programme, a portion of the Property, Plant and Equipment has been physically verified by the Management during the year and no material discrepancies have been noticed on such verification. (c) The title deeds of all the immovable properties (other than properties where the Company is the lessee and the lease agreements are duly executed in favour of the lessee), as disclosed in Note 3 on Property, plant and equipment and Note 4 on Right-of-use assets to the standalone financial statements, are held in the name of the Company, except for the following:

Whether Period held
Gross carrying promoter, (i.e. dates of Reason for not being

Description of

value

Held in the name of

director or capitalisation held in the name of the

property

(J crore)

their relative or provided

Company
employee in range)#
Freehold Land 213.83

Not Applicable

No March, 1928 to Title Deeds not available
April, 2020 with the Company
Buildings 116.52

Not Applicable

No January, 1960 to Title Deeds not available
March, 1990 with the Company
Freehold Land 16.57

Tata Steel BSL Limited

No April, 2020 For certain properties
Freehold Land 122.12

Bhushan Steel Limited (earlier name of

No April, 2020 acquired through

Tata Steel BSL Limited)

amalgamation/merger,
the name change in the
Freehold Land 1.92

Bhushan Steel & Strips Limited

No April, 2020 name of the Company is

(earlier name of Tata Steel BSL Limited)

pending
Freehold Land 195.16

Tata Steel Long Products Limited/ Tata

No April, 2022

Sponge Iron Limited (earlier name of Tata

Steel Long Products Limited)

Freehold Land 10.53

Tata Steel Mining Limited

No April, 2023
Freehold Land 8.04

Rohit Ferro Tech Limited

No April, 2023
Freehold Land 0.12

T S Alloys Limited (earlier name of Tata

No April, 2023

Steel Mining Limited)

Freehold Land 0.04

The Tinplate Company of India Limited

No April, 2022
Freehold Land 4.02

Tata Metaliks Limited

No April, 2022
Freehold Land 0.45

Bharat Minex Private Limited

No April, 2022
Freehold Land 0.83

Usha Martin Limited

No April, 2022
Freehold Land 0.21

Chandrakali Devi

No April, 2022
Freehold Land 0.08

Bhagwan Singh

No April, 2022
Freehold Land 0.02

Premnath Prasad

No April, 2022
Freehold Land 0.07

Laljahari Devi

No April, 2022
Whether Period held

Gross carrying

promoter, (i.e. dates of Reason for not being

Description of

value

Held in the name of director or capitalisation held in the name of the

property

(J crore)

their relative or provided

Company
employee in range)#
Freehold Land

0.08

Gopinath Pradhan No April, 2022
Buildings

3.08

Indian Tube Company Limited No January, 1960
Buildings

15.89

Tata SSL Limited No January, 1989 to
January, 1991
Buildings

1.17

Tata Steel Mining Limited No April, 2023
Buildings

0.71

Usha Martin Limited No April, 2022
Right-of-use

9.02

Tata Steel BSL Limited No April, 2020
Land
Right-of-use

179.40

Bhushan Steel Limited (earlier name of No April, 2020
Land Tata Steel BSL Limited)
Right-of-use

139.93

Bhushan Steel & Strips Limited (earlier No April, 2020
Land name of Tata Steel BSL Limited)
Right-of-use

3.28

Jawahar Metal Industries Private Limited No April, 2020
Land (earlier name of Tata Steel BSL Limited)
Right-of-use

23.79

Tata Metaliks Limited No April, 2022 to
Land May, 2023
Right-of-use

131.85

Tata Sponge Iron Limited (earlier name No April, 2022
Land of Tata Steel Long Products Limited)
Right-of-use

2.36

Usha Martin Limited No April, 2022
Land
Right-of-use

19.76

Tata Steel Mining Limited No May, 2023
Land
Right-of-use

29.46

Rohit Ferro Tech Limited No April, 2023
Land
Right-of-use

1.13

Rohit Ferro Tech Private Limited No April, 2023
Land
Right-of-use

6.47

Rawmet Ferrous Industries Private No April, 2023
Land Limited (earlier name of Tata Steel
Mining Limited)
Right-of-use

0.74

The Tinplate Company of India Limited No April, 2022 to
Buildings January, 2023
Right-of-use

0.15

Not Applicable No Not Available Lease Deed not available
Land with the Company

# In case of immovable properties acquired from entities which got merged with the Company have been considered with effect from the merger effect given.

(d) The Company has not revalued its Property, Plant and Equipment (including Right-of-use assets) or intangible assets during the year. Accordingly, the reporting under Clause 3(i)(d) of the Order is not applicable to the Company. (e) Based on the information and explanations furnished to us, no proceedings have been initiated on or are pending against the Company for holding benami property under the Prohibition of Benami Property Transactions Act, 1988 (as amended in 2016) (formerly the Benami Transactions (Prohibition) Act, 1988 (45 of 1988)) and Rules made thereunder, and therefore the question of our commenting on whether the Company has appropriately disclosed the details in the standalone financial statements does not arise. ii. (a) The physical verification of inventory (excluding stocks with third parties) has been conducted at reasonable intervals by the Management during the year and, in our opinion, the coverage and procedures of such verification by Management is appropriate. In respect of inventory lying with third parties, these have substantially been confirmed by them. In respect of inventories of stores and spares, the Management has a verification programme designed to cover the items over a period of three years. The discrepancies noticed on physical verification of inventory as compared to book records were not 10% or more in aggregate for each class of inventory. (b) During the year, the Company has been sanctioned working capital limits in excess of I5 crores, in aggregate, from banks on the basis of security of current assets. The Company has filed quarterly returns or statements with such banks, which are in agreement with the books of account other than those as set out below.

Name of the Bank

Aggregate working capital limits sanctioned (J crore) Nature of Current Asset offered as Security Quarter ended Amount disclosed as per quarterly return/ statement (J crore) Amount as per books of account (J crore) Di_erence (J crore) Reasons for difference
State Bank of India 2,000.00 Refer Note 1 June 30, 2023 1,559.27 1,576.04 (16.77) Incorrect amount of
and consortium of below September 30, 2023 1,668.58 1,682.22 (13.64) Export advance
banks
December 31, 2023 1,859.27 1,874.57 (15.30)
State Bank of India 2,000.00 Refer Note 1 June 30, 2023 4,557.60 4,554.09 3.51 Incorrect amount of
and consortium of below September 30, 2023 7,990.37 7,989.23 1.14 creditor for Goods
banks under LC
December 31, 2023 5,245.20 5,250.40 (5.20)
State Bank of India 45.00 Refer Note 2 September 30, 2023 64.89 74.44 (9.55) Incorrect amount
below December 31, 2023 40.74 62.71 (21.97) of Goods-in-transit
0f Inventory of
erstwhile Tata
Metaliks Limited
(merged with the
Company)
June 30, 2023 408.83 393.67 15.16 Incorrect amount of
September 30, 2023 415.97 382.93 33.04 creditors for goods
of erstwhile Tata
December 31, 2023 280.70 234.47 46.23 Metaliks Limited
(merged with the
Company)
Kotak Mahindra 68.00 Refer Note 3 June 30, 2023 370.33 393.67 (23.34) Incorrect amount of
Bank Limited, HDFC 80.00 below creditor for goods
Bank Limited, DBS 70.00 of erstwhile Tata
Bank Limited, Bank 9.75 Metaliks Limited
of Baroda, ICICI Bank 105.00 (merged with the
Limited Company)

Note 1: Pari-passu charge on the Companys entire current assets namely stock of raw materials, finished goods, stocks-in-process, consumables stores and spares and book debts at its plant sites or anywhere else, in favour of the Bank, by way of hypothecation.

Note 2: Hypothecation first charge over inventory and receivables and other current assets on pari-passu basis with other working capital lenders of erstwhile Tata Metaliks Limited under Multiple Banking Arrangement subject to sharing of pari-passu sharing letters by such Banks.

Note 3 a) Kotak Mahindra Bank Limited: First pari-passu charge on current assets both present and future of erstwhile Tata Metaliks Limiteds Kharagpur unit, along with other lenders in multiple banking arrangement. b) HDFC Bank Limited: First pari-passu charge on current assets of erstwhile Tata Metaliks Limited with other WC lender. c) DBS Bank Limited: First pari-passu charge on the current assets of erstwhile Tata Metaliks Limiteds Kharagpur unit. d) Bank of Baroda: First pari-passu charge on current assets of erstwhile Tata Metaliks Limited including raw materials, work in progress, finished goods and all the receivables with other working capital lenders. e) ICICI Bank Limited: First pari-passu charge on book debts, stock and other current assets of erstwhile Tata Metaliks Limited.

Also refer Note 17(iv) to the standalone financial statements. iii. (a) The Company has, during the year, made investments in six companies and thirty four mutual fund schemes, granted unsecured loans to five companies and six hundred and forty eight employees and stood guarantee for six companies. The aggregate amount during the year, and balance outstanding at the balance sheet date with respect to such loans and guarantees to subsidiaries, associates and to parties other than subsidiaries, joint ventures and associates are as per the table given below:

Particulars

Guarantees (I crores) Loans* (I crores)
Aggregate amount granted/ provided during the year
Subsidiaries 462.98 8,720.53
Associates 32.13 -
Others - 2.98
Balance outstanding (gross) as at balance sheet date in respect of the above cases
Subsidiaries 406.45 8,441.10
Associates 25.87 -
Others - 2.27

* excluding loans given to erstwhile Tata Metaliks Limited (merged with the Company referred to in Note 43 to the standalone financial statements) The above amounts are included in Note 7 on Loans and Note 34(B) on Commitments to the standalone financial statements. (b) In respect of the aforesaid investments, guarantees and loans, the terms and conditions under which such investments were made, guarantees provided and loans were granted are not prejudicial to the Companys interest, based on the information and explanations provided by the Company.

(c) In respect of the loans outstanding as on the balance sheet date, the schedule of repayment of principal and payment of interest has been stipulated by the Company except for two loans aggregating I9.60 crores (fully provided in books) where no schedule of repayment of principal and payment of interest has been stipulated. Except for the aforesaid instances (where in the absence of stipulation of repayment/payment terms, we are unable to comment on the regularity of repayment of principal and payment of interest) and the following instance, the parties are repaying the principal amounts, as stipulated, and are also regular in payment of interest, as applicable.

Name of the entity

Amount (I crores) Due Date Extent of delay (provided in range) Remarks
Tayo Rolls Limited 81.30 Multiple Dates 2,192 days - The amounts pertain to principal and interest,
2,787 days which are overdue as at March 31, 2024. The
entity is under corporate insolvency resolution
process. The Company has filed its claim as
financial creditor. The amounts are fully provided
in books.

(d) In respect of the following loan, the total amount overdue for more than ninety days as at March 31, 2024 is I81.30 crores. Based on the information and explanations given to us, the entity is under corporate insolvency resolution process and accordingly, the Company is not taking any further steps for the recovery of the principal and interest amounts, other than those mentioned in clause (iii)(c) above against Tayo Rolls Limited.

No. of cases

Principal Amount Overdue (I crores) Interest Overdue (I crores) Total Overdue (I crores) Remarks
One 67.00 14.30 81.30 The amounts are fully provided in books

(e) Following loans were granted to same parties, which has fallen due during the year and were renewed/extended. Further, no fresh loans were granted to same parties to settle the existing overdue loans.

Name of the parties *

Aggregate amount of dues renewed or extended (I crores) * Percentage of the aggregate to the total loans granted during the year *
Tata Steel Downstream Products Limited 50.00 0.57%

* excluding renewal/ extension of loans to erstwhile Tata Steel Mining Limited (merged with the Company referred to in Note 43 to the standalone financial statements)

The above amounts are included in Note 7 on Loans to the standalone financial statements.

(f) The loans granted during the year, including to related parties had stipulated the scheduled repayment of principal and payment of interest and the same were not repayable on demand. No loans were granted during the year to promoters. iv. In our opinion, and according to the information and explanations given to us, the Company has complied with the provisions of Sections 185 and 186 of the Companies Act, 2013 in respect of the loans and investments made, and guarantees and security provided by it, as applicable. v. The Company has not accepted any deposits or amounts which are deemed to be deposits referred in Sections 73, 74, 75 and 76 of the Act and the Rules framed there under. vi. Pursuant to the rules made by the Central Government of India, the Company is required to maintain cost records as specified under Section 148(1) of the Act in respect of its products and services. We have broadly reviewed the same and are of the opinion that, prima facie, the prescribed accounts and records have been made and maintained. We have not, however, made a detailed examination of the records with a view to determine whether they are accurate or complete. vii. (a) In our opinion, except for dues in respect of royalty, the Company is generally regular in depositing undisputed statutory dues in respect of income tax, employees state insurance, labour welfare fund and electricity duty, though there has been a slight delay in a few cases, and is regular in depositing undisputed statutory dues, including provident fund, sales tax, service tax, duty of customs, duty of excise, value added tax, cess, goods and services tax and other material statutory dues, as applicable, with the appropriate authorities. We are informed that the Company has applied for exemption from operations of Employees State Insurance Act at some locations. We are also informed that actions taken by the authorities at some locations to bring the employees of the Company under the Employees State Insurance Scheme has been contested by the Company and payment has not been made of the contribution demanded. The extent of the arrears of statutory dues outstanding as at March 31, 2024, for a period of more than six months from the date they became payable are as follows:

Name of the statute

Nature of dues Amount (I crores) Period to which the amount relates Due date Date of Payment
The Mines and Minerals Royalty 2,471.08 March, 2021 to Various dates till Not yet paid
(Development and Regulation) September, 2023 September 30, 2023
Amendment Act, 2021

(b) The particulars of statutory dues referred to in sub-clause (a) as at March 31, 2024 which have not been deposited on account of a dispute, are as follows:

Name of the statute

Nature of dues Amount (net of payments) (I crores) Amount paid (I crores) Period to which the amount relates (FY) Forum where the dispute is pending
Income Tax Act 1961 Income Tax 2,026.96 1,132.20 1998-99, 2006-07 to Tribunal
2013-14, 2015-16,
2016-17, 2018-19
402.67 125.60 2008-09, 2012-13 to CIT Appeals
2017-18, 2019-20,
2020-21
1.51 - 2017-18, 2019-20 Deputy
Commissioner/
Assistant
Commissioner of
Income Tax
Customs Act, 1962 Customs duty 4.06 0.18 2017-18 to 2020-21 Commissioner
15.98 2.30 1984-85, 1993-94, High Court
2002-03, 2017-18
6.59 3.77 2005-06 to 2008-09, Supreme Court
2013-14
107.49 14.11 2010-11 to 2015-16, Tribunal
2017-18, 2018-19
Bihar Electricity Duty Act, 1948 Electricity Duty 21.32 - 2007-08 to 2010-11, Deputy Commissioner
2012-13
6.33 - 2011-12 to 2015-16 High Court
0.30 - 2004-05 to 2007-08 Tribunal
Employee State Insurance Act, Employee State 25.20 - 1996-97, 2005-06 to High Court
1948 Insurance 2009-10, 2017-18 to
2021-22
Entry Tax Laws Entry Tax 0.35 0.29 2007-08 to 2010-11, Additional
2014-15 Commissioner
6.02 - 2008-09, 2011-12, Assessing Officer
2014-15
0.37 - 2015-16 to 2020-21 Assistant
Commissioner
0.65 0.56 2001-02, 2005-06, Deputy Commissioner
2006-07
9.16 4.33 2000-01 to 2002-03, High Court
2005-06 to 2012-13,
2014-15, 2016-17
0.11 0.24 2008-09 to 2011-12 Joint Commissioner
1.19 1.21 2007-08 to 2010-11 Tribunal
Mines and Mineral (Development Excess Mining 132.91 - 1998-99 to 2010-11 Additional Chief
and Regulation) Act, 1957 / Common Secretary, Steel &
Cause Mines
2,994.49 573.83 2011-12 to 2014-15 High Court
Central Excise Act, 1944 Excise Duty 10.54 0.92 2017-18 Additional
Commissioner
0.09 - 2010-11, 2011-12 Assistant
Commissioner
48.28 6.04 1988-89, 2006-07 to Commissioner
2009-10, 2011-12,
2013-14 to 2017-18
38.39 0.10 1989-90, 2003-04 to High Court
2008-09, 2017-18
2.24 1.07 2010-11, 2016-17 Joint Commissioner
597.82 40.44 2002-03 to 2019-20 Tribunal

 

Name of the statute

Nature of dues Amount (net of payments) (I crores) Amount paid (I crores) Period to which the amount relates (FY) Forum where the dispute is pending
Goods & Services Tax Act, 2017 Goods & 1.16 - 2018-19, 2019-20 Additional
Services Tax Commissioner
8.32 0.05 2017-18 to 2019-20 Assistant
Commissioner
170.82 0.21 2017-18, 2019-20 to Commissioner
2021-22
32.85 - 2017-18 to 2022-23 Deputy Commissioner
Jharkhand Mineral Area Mineral Area 58.51 18.00 2005-06, 2006-07, High Court
Development Authority Act, 2000 Development 2008-09, 2009-10,
Fee 2011-12 to 2013-14,
2016-17
8.23 - 1992-93 to 1994-95, Supreme Court
2005-06
Employees Provident Fund & Provident - 1.02 1997-98 High Court
Miscellaneous Provisions Act, Fund
1952
Mineral Concession Rules, 1960 Royalty on 408.48 2.60 2009-10 to 2014-15 Mines Tribunal
Minerals 1,366.78 1,211.92 2000-01 to 2007-08 Supreme Court
Minerals (Other than Atomic and Royalty on 597.70 218.50 2020-21, 2021-22 High Court
Hydro Carbons Energy Mineral) Minerals
Concession Rules - 2016
Sales Tax Laws Sales Tax 362.04 2.36 1983-84, 2002-03, Additional
2012-13, 2016-2017, Commissioner
2017-18
30.23 2.85 1973-74, 1980-81 to Assistant
1991-92, 1994-95 to Commissioner
1996-97, 2004-05,
2015-16 to 2017-18
215.37 4.56 1988-89, 1989-90, Commissioner
1991-92, 1993-94,
1994-95, 2001-02 to
2003-04, 2013-14
5.83 0.55 1975-76, 1985-86 to Deputy Commissioner
1887-88, 1997-98 to
2001-02, 2008-09,
2011-12, 2013-14,
2016-17, 2017-18
10.01 1.23 1977-78, 1978-79, High Court
1983-84, 1991-92,
1992-93, 1995-96,
1996-97, 2000-01,
2008-09
62.64 0.54 1979-80, 2012-13, Joint Commissioner
2014-15, 2016-17,
2017-18
0.41 0.19 1983-84, 1988-89, Sales Tax Officer
1990-91, 1992-93,
1994-95, 1995-96
14.36 5.94 1977-78, 1984-85, Tribunal
1987-88, 1989-90 to
1998-99, 2001-02,
2003-04 to 2009-10,
2013-14 to 2015-16

 

Name of the statute

Nature of dues Amount (net of payments) (I crores) Amount paid (I crores) Period to which the amount relates (FY) Forum where the dispute is pending
Sales Tax Laws Sales Tax (VAT) 44.15 0.46 2005-06, 2012-13 to Additional
2016-17 Commissioner
0.68 0.12 2005-06, 2006-07, Assistant
2016-2017, 2017-18 Commissioner
16.28 0.08 2006-07 to 2011-12, Commissioner
2014-15
34.68 0.17 2006-07, 2010-11 to Deputy Commissioner
2011-12, 2013-14,
2015-16, 2016-17
265.50 1.07 2001-02, 2003-04, High Court
2007-08, 2010-11,
2012-13 to 2015-16
4.17 - 2015-16 to 2017-18 Joint Commissioner
4.14 4.55 2005-06 to 2009-10, Tribunal
2013-14 to 2015-16,
2017-18
Service Tax Laws Service tax 0.88 - 2005-06 to 2010-11 Additional
Commissioner
1.55 0.03 2010-11 to 2017-18 Assistant
Commissioner
3.54 0.13 2004-05 to 2007-08, Commissioner
2012-13 to 2016-17
0.30 - 2010-11 High Court
3.18 0.12 2016-17, 2017-18 Joint Commissioner
211.07 7.97 2001-02 to 2016-17 Tribunal
Indian Stamp Act, 1899 Stamp Duty 5,165.00 414.00 2013-14 High Court
State Water Tax Laws Water Tax 1,371.81 511.37 1980-81 to 1993-94, High Court
1995-96 to 2022-23

The following matter has been decided in favour of the Company although the department has preferred appeal at higher levels:

Name of the statute

Nature of dues Amount (net of payments) (I crore) Period to which the amount relates (FY) Forum where the dispute is pending
Customs Act, 1962 Customs Duty 248.24 2006-07 to 2008-09 Supreme Court
Central Excise Act, 1944 Excise Duty 235.48 2004-05 Supreme Court
16.34 2009-10 Tribunal
26.84 2006-07 to 2008-09 Commissioner

viii. There are no transactions in the books of account that has been surrendered or disclosed as income during the year in the tax assessments under the Income Tax Act, 1961, that has not been recorded in the books of account. ix. (a) Except as described below, the Company has not defaulted in repayment of loans or other borrowings or in the payment of interest to any lender during the year.

Nature of borrowing

Name of lender Amount not paid on due date (I crores) Whether principal or interest No. of days delay
Domestic term loan Central Bank of 5.00 Principal 7 days
India

Also refer Note 17(ii) on Borrowings to the standalone financial statements.

(b) On the basis of our audit procedures, we report that the Company has not been declared Wilful Defaulter by any bank or financial institution or government or any government authority.

(c) In our opinion, the term loans have been applied, on an overall basis, for the purposes for which they were obtained. Also refer Note 17(x) to the standalone financial statements regarding the unutilised amount lying temporarily as at March 31, 2024 in fixed deposits out of the proceeds from the issuance of non-convertible debentures in March 2024. (d) According to the information and explanations given to us, and the procedures performed by us, and on an overall examination of the standalone financial statements of the Company, we report that no funds raised on short-term basis have been utilised for long-term purposes by the Company.

(e) On an overall examination of the standalone financial statements of the Company, we report that the Company has not taken any funds from any entity or person on account of or to meet the obligations of its subsidiaries, associates or joint ventures.

(f) According to the information and explanations given to us and procedures performed by us, we report that the Company has not raised loans during the year on the pledge of securities held in its subsidiaries, joint ventures or associate companies. x. (a) The Company has not raised any money by way of initial public offer or further public offer (including debt instruments) during the year. Accordingly, the reporting under clause 3(x)(a) of the Order is not applicable to the Company. (b) The Company has not made any preferential allotment or private placement of shares or fully or partially or optionally convertible debentures during the year. Accordingly, the reporting under clause 3(x)(b) of the Order is not applicable to the Company. xi. (a) During the course of our examination of the books and records of the Company, carried out in accordance with the generally accepted auditing practices in India, we have neither come across any instance of material fraud by the Company or on the Company, noticed or reported during the year, nor have we been informed of any such case by the Management. (b) A report under sub-section (12) of Section 143 of the Companies Act, 2013 has been filed (subsequent to the balance sheet date) by us in Form ADT-4 as prescribed under rule 13 of Companies (Audit and Auditors) Rules, 2014 with the Central Government of India (Refer Note 46 to the standalone financial statements).

(c) During the course of our examination of the books and records of the Company carried out in accordance with the generally accepted auditing practices in India, the Company has received whistle-blower complaints during the year, which have been considered by us for any bearing on our audit and reporting under this clause. As explained by the management, there were certain complaints in respect of which investigations are ongoing as on the date of our report and our consideration of the complaints having any bearing on our audit is based on the information furnished to us by the management. xii. As the Company is not a Nidhi Company and the Nidhi Rules, 2014 are not applicable to it, the reporting under clause 3(xii) of the Order is not applicable to the Company. xiii. The Company has entered into transactions with related parties in compliance with the provisions of Sections 177 and 188 of the Act. The details of related party transactions have been disclosed in the standalone financial statements as required under Indian Accounting Standard 24 "Related Party Disclosures" specified under Section 133 of the Act.

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

(b) The reports of the Internal Auditor for the period under audit have been considered by us. xv. In our opinion, the Company has not entered into any non-cash transactions with its directors or persons connected with him. Accordingly, the reporting on compliance with the provisions of Section 192 of the Act under clause 3(xv) of the Order is not applicable to the Company. xvi. (a) The Company is not required to be registered under Section 45-IA of the Reserve Bank of India Act, 1934. Accordingly, the reporting under clause 3(xvi)(a) of the Order is not applicable to the Company. (b) The Company has not conducted non-banking financial / housing finance activities during the year. Accordingly, the reporting under clause 3(xvi)(b) of the Order is not applicable to the Company. (c) The Company is not a Core Investment Company (CIC) as defined in the regulations made by the Reserve Bank of India. Accordingly, the reporting under clause 3(xvi)(c) of the Order is not applicable to the Company.

(d) Based on the information and explanations provided by the management of the Company, the Group has seven CICs as part of the Group. We have not, however, separately evaluated whether the information provided by the management is accurate and complete. xvii. The Company has not incurred any cash losses in the financial year or in the immediately preceding financial year. xviii. There has been no resignation of the statutory auditors during the year and accordingly the reporting under clause 3(xviii) of the Order is not applicable to the Company.

xix. On the basis of the financial ratios, ageing and expected dates of realisation of financial assets and payment of financial liabilities, other information accompanying the standalone financial statements, our knowledge of the Board of Directors and management plans and based on our examination of the evidence supporting the assumptions, nothing has come to our attention, which causes us to believe that any material uncertainty exists as on the date of the audit report that the Company is not capable of meeting its liabilities existing at the date of balance sheet as and when they fall due within a period of one year from the balance sheet date. We, however, state that this is not an assurance as to the future viability of the Company. We further state that our reporting is based on the facts up to the date of the audit report and we neither give any guarantee nor any assurance that all liabilities falling due within a period of one year from the balance sheet date will get discharged by the Company as and when they fall due. xx. The Company has during the year spent the amount of Corporate Social Responsibility as required under sub-section (5) of Section 135 of the Act. Accordingly, reporting under clause 3(xx) of the Order is not applicable to the Company. xxi. The reporting under clause 3(xxi) of the Order is not applicable in respect of audit of standalone financial statements. Accordingly, no comment in respect of the said clause has been included in this report.

For Price Waterhouse & Co Chartered Accountants LLP
Firm Registration Number: 304026E/E-300009

Subramanian Vivek

Partner
Membership Number 100332
UDIN: 24100332BKGFNL1709