Auditor Report of Beekay Steel Industries Ltd.

Mar 31, 2023

Beekay Steel Industries Limited.

Report on the Audit of the Standalone Ind AS Financial Statements

Opinion

We have audited the accompanying Standalone Ind AS Financial Statement of BEEKAY STEEL INDUSTRIES LIMITED, which comprise the Balance Sheet as at 31^st March, 2023, the Statement of Profit and Loss(including other comprehensive income), the Statement of Changes in Equity, the Statement of Cash Flows for the year ended on that date, and a summary of the significant accounting policies and other explanatory information.

In our opinion and to the best of our information and according to the explanations given to us, the aforesaid 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 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 Standalone state of affairs of the Company as at March 31, 2023, the Standalone profit, Standalone total comprehensive income, Standalone changes in equity and its Standalone 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 (SAs). Our responsibilities under those Standards are further described in the Auditor''s 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 (ICAI) together with the independence 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 we have obtained 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 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.

Information Other than the Standalone Financial Statements and Auditor''s Report Thereon

The Company''s Board of Directors is responsible for the preparation of the other information. The other information comprises the information included in the Management Discussion and Analysis, Board''s Report including Annexures to Board''s Report, Business Responsibility Report, Corporate Governance and Shareholder''s Information, but does not include the Standalone financial statements and our auditor''s report thereon

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.

Management''s Responsibility 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, total comprehensive income, changes in equity and cash flows 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 standalone financial statements 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, management is responsible for assessing the Company''s ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless management either intends to liquidate the Company or to cease operations, or has no realistic alternative but to do so.

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

Auditor''s Responsibilities 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 controls relevant to the audit in order to design audit procedures that are appropriate in the circumstances. Under section 143(3X0 of the Act, we are also responsible for expressing our opinion on whether the Company and its subsidiary companies which are companies incorporated in India, has adequate internal financial controls system in place and the operating effectiveness of such controls.

¦ Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and related disclosures made by management.

¦ Conclude on the appropriateness of management''s use of the going concern basis of accounting and, based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the ability of the Company 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.

¦ 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 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 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.

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 auditor''s report unless law or regulation precludes public disclosure about the matter or when, in extremely rare circumstances, we determine that a matter should not be communicated in our report because the adverse consequences of doing so would reasonably be expected to outweigh the public interest benefits of such communication.

Report on Other Legal and Regulatory Requirements

1. As required by 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.

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;

c) The Balance Sheet, the Statement of Profit and Loss including other comprehensive income, Statement of Changes in Equity and the Statement of the 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 Ind AS specified under Section 133 of the Act, read with Rule 7 of the Companies (Accounts) Rules, 2014.

e) On the basis of the written representations received from the directors as on 31 March 2023 taken on record by the Board of Directors, none of the directors is disqualified as on 31 March 2023 from being appointed as a director in terms of Section 164 (2) of the Act.

f) With respect to the adequacy of the internal financial controls over financial reporting 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 over financial reporting.

g) With respect to the other matters to be included in the Auditor''s Report in accordance with the requirements of section 197(16) of the Act, as amended : In our opinion and to the best of our information and according to the explanations given to us, the remuneration paid by the Company to its directors during the year is in accordance with the provisions of section 197 of the Act.

h) With respect to the other matters to be included in the Auditor''s Report in accordance with Rule 11 of the Companies (Audit and Auditors) Rules, 2014, in our opinion and to the best of our information and according to the explanations given to us:

i) The Company has disclosed the impact of pending litigations on its financial position in its Standalone financial statements.

ii) The Company has made provision, as required under the applicable law or accounting standards, for material forseeable losses, if any, on long-term contracts including derivative contracts.

iii) There has been no delay in transferring amounts, required to be transferred, to the Investor Education and Protection Fund by the Company.

iv) (a) The Management has represented that, to

the best of its knowledge and belief, no funds (which are material either individually or in the aggregate) have been advanced or loaned or invested (either from borrowed funds or share premium or any other sources or kind of funds) by the Company to or in any other person or entity, including foreign entity (''Intermediaries”), with the understanding, whether recorded in writing or otherwise, that the Intermediary shall, whether, directly or indirectly lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the Company (''Ultimate Beneficiaries”) or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries;

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

(c) Based on the audit procedures that have been considered reasonable and appropriate in the circumstances, nothing has come to our notice that has caused us to believe that the representations under sub-clause (i) and (ii) of Rule 11(e), as provided under (a) and (b) above, contain any material misstatement.

v) As stated in Note 2.12.3 to the standalone financial statements.

(a) The final dividend proposed in the previous year,declared and paid by the company during the year is in accordance with Section 123 of the Act, as applicable.

(b) The Board of Directors of the Company have proposed final dividend for the year which is subject to the approval of the members at the ensuing Annual General Meeting. The amount of dividend proposed is in accordance with section 123 of the Act, as applicable.

1. As required by the Companies (Auditor''s Report) Order, 2020

(''the order'') issued by the Central Government of India in terms of section 143(11) of the Act, we give in the Annexure B, a statement on the matters specified in the paragraph 3 and 4 of the Order.

For RUSTAGI & ASSOCIATES

Chartered Accountants

Firm''s Registration Number.: 314194E

S. K. RUSTAGI

(Partner)

Membership No. 051860 UDIN No.: 23051860BGSHJM7576 Place: 59, Bentinck Street, Kolkata - 700 069 Date: 29^th May, 2023

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Mar 31, 2018

Report on the Standalone Ind AS Financial Statements

We have audited the accompanying Standalone Ind AS Financial Statement of BEEKAY STEEL INDUSTRIES LIMITED, which comprise the Balance Sheet as at 31st March, 2018, the Statement of Profit and Loss(including other comprehensive income), the Statement of Changes in Equity, the Statement of Cash Flows for the year then ended and a summary of the significant accounting policies and other explanatory information.

Management’s Responsibility for the Standalone Ind AS Financial Statements

The Company’s Board of Directors is responsible for the matters stated in Section 134(5) of the Companies Act, 2013 (“the Act”) with respect to the preparation and presentation of these Standalone Ind AS 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 Indian Accounting Standards (Ind AS) prescribed under section 133 of the Act read with the Companies (Indian Accounting Standards) Rules,2015, as amended, 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 Standalone Ind AS Financial Statements that give a true and fair view and are free from material misstatement, whether due to fraud or error.

Auditor’s Responsibility

Our responsibility is to express an opinion on these Standalone Ind AS Financial Statements based on our audit.

We have taken into account the provisions of the Act, the accounting and auditing standards and matters which are required to be included in the audit report under the provisions of the Act and the Rules made thereunder.

We conducted our audit in accordance with the Standards on Auditing specified under Section 143(10) of the Act.Those Standards require that we comply with ethical requirements and plan and perform the audit to obtain reasonable assurance about whether the Standalone Ind AS Financial Statements are free from material misstatement.

An audit involves performing procedures to obtain audit evidence about the amounts and the disclosures in the Standalone financial statements. The procedures selected depend on the auditor’s judgment, including the assessment of the risks of material misstatement of the Standalone financial statements, whether due to fraud or error. In making those risk assessments, the auditor considers internal financial control relevant to the Company’s preparation of the Standalone financial statements that give a true and fair view in order to design audit procedures that are appropriate in the circumstances. An audit also includes evaluating the appropriateness of the accounting policies used and the reasonableness of the accounting estimates made by the Company’s Directors, as well as evaluating the overall presentation of the Standalone Ind AS Financial Statements.

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion on the standalone financial statements.

Opinion

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 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 31st March, 2018, and its profit, total comprehensive income, the changes in equity and its cash flows for the year ended on that date.

Report on Other Legal and Regulatory Requirements

1. 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;

c) The Balance Sheet, the Statement of Profit and Loss including other comprehensive income, Statement of Changes in Equity and the Statement of the 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 Indian Accounting Standards prescribed under Section 133 of the Act.

e) On the basis of the written representations received from the directors as on 31 March 2018 taken on record by the Board of Directors, none of the directors is disqualified as on 31 March 2018 from being appointed as a director in terms of Section 164 (2) of the Act.

f) With respect to the adequacy of the internal financial controls over financial reporting of the Company and the operating effectiveness of such controls, refer to our separate Report in ‘Annexure A’ ; and

g) With respect to the other matters to be included in the Auditor’s Report in accordance with Rule 11 of the Companies (Audit and Auditors) Rules, 2014, in our opinion and to the best of our information and according to the explanations given to us:

i) The Company has disclosed the impact of pending litigations on its financial position in its Standalone financial statements-refer to Note 32 to the Standalone financial Statements.

ii) The Company has made provision, as required under the applicable law or accounting standards, for material forseeable losses, if any, on long-term contracts including derivative contracts.

iii) There has been no delay in transferring amounts, required to be transferred, to the Investor Education and Protection Fund by the Company.

2. As required by the Companies (Auditor’s Report) Order, 2016 (‘the order’) issued by the Central Government of India in terms of section 143(11) of the Act, we give in the Annexure B, a statement on the matters specified in the paragraph 3 and 4 of the Order.

1. We have audited the internal financial controls over financial reporting of BEEKAY STEEL INDUSTRIES LIMITED as of March 31, 2018 in conjunction with our audit of the standalone financial statements of the Company for the year ended on that date.

Management’s Responsibility for Internal Financial Controls

2. The Company’s 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 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 Company’s policies, the safeguarding of its assets, the prevention and detection of frauds and errors, the accuracy and completeness of the accounting records, and the timely preparation of reliable financial information, as required under the Companies Act, 2013.

Auditors’ Responsibility

3. Our responsibility is to express an opinion on the Company’s internal financial controls over financial reporting based on our audit. We conducted our audit in accordance with the Guidance Note on Audit of Internal Financial Controls Over Financial Reporting (‘the Guidance Note’) and the Standards on Auditing, issued by ICAI and deemed to be prescribed under section 143(10) of the Companies Act, 2013, 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 over financial reporting 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 over financial reporting and their operating effectiveness. Our audit of internal financial controls over financial reporting included obtaining an understanding of internal financial controls over financial reporting, 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 auditor’s judgement, including the assessment of the risks of material misstatement of the Standalone 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 Company’s internal financial controls system over financial reporting.

Meaning of Internal Financial Controls Over Financial Reporting

6. A Company’s internal financial control over financial reporting 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 Company’s internal financial control over financial reporting includes those policies and procedures that:

(i) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the Company.

(ii) 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

(iii) provide reasonable assurance regarding prevention or timely detection of unauthorised acquisition, use, or disposition of the Company’s assets that could have a material effect on the financial statements.

Inherent Limitations of Internal Financial Controls Over Financial Reporting

7. Because of the inherent limitations of internal financial controls over financial reporting, 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 over financial reporting to future periods are subject to the risk that the internal financial control over financial reporting 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 over financial reporting and such internal financial controls over financial reporting were operating effectively as at March 31, 2018, 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 Controls Over Financial Reporting issued by the Institute of Chartered Accountants of India.

(i) a) The Company has maintained proper records showing full particulars, including quantitative details and situation of fixed assets.

b) The Company has a regular programme of physical verification of its fixed assets by which fixed assets are verified in a phased manner over a period of three years. In accordance with this program, certain fixed assets were verified during the year and no material discrepancies were noticed on such verification. In our opinion, this periodicity of physical verification is reasonable having regard to the size of the Company and the nature of its assets.

c) According to the information and explanations given to us and on the basis of our examination of the records of the Company, the title deeds of immovable properties are held in the name of the Company.

(ii) The physical verification of inventory has been conducted at reasonable intervals by the management during the year.The discrepancies noticed on physical verification of inventory as compared to book records were not material and have been appropriately dealt with in the books of accounts.

(iii) There are Companies,firms, LLPs or other parties covered in the register to be maintained under section 189 of the Companies Act, 2013. However, the Company has not granted loan to such Companies, firms, LLPs or other parties.

(iv) In our opinion, and according to the information and explanations given to us, the Company has not granted any loans, investments, guarantees and security during the year that would attract provisions of Section 185 & 186 of the Act.

(v) The Company has not accepted any deposits from public within the meaning of sections 73, 74, 75 and 76 of the Act and the rules framed there under to the extent notified.

(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. 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, however not , made a detailed examination of the records with a view to determine whether they are accurate or complete.

(vii) a) According to the information and explanations given to us and the records of the company examined by us , in our opinion, the company is generally regular in depositing undisputed statutory dues including Provident Fund, Employees’ State Insurance, Income Tax, Service Tax, Goods and Service Tax, Value Added Tax, Customs Duty, Excise Duty, Cess and other material statutory dues, as applicable, with the appropriate authorities.

b) According to the information and explanations given to us, there were disputed amount payable in respect of Income Tax relating to F.Y. 2010-11 amounting RS.11,56,430/- and RS.2,67,322/- relating to F.Y 2013-14 which have remained outstanding as at 31st March, 2018 for a period of more than six months from the date they become payable. However no undisputed dues is payable in respect of wealth-tax, sales-tax, value added tax, service tax, customs duty and excise duty which have remained outstanding as at 31.03.2018 for a period of more than six months from the date they became payable.

c) According to the records of the Company, there are dues of sales tax, income tax, customs tax/wealth tax, value added tax, service tax, excise duty / cess which have not been deposited on account of dispute.

Nature of Dues	Period to which the matter pertains	Forum where disputes is pending	Amount Involved (Rs.)
Excise Duty	1998-1999	Hon’ble High Court, Kolkata	8,31,204
-- Do --	1997-1998	Customs, Excise & Service Tax Appeallate Tribunal, Kolkata.	10,67,07,795
-- Do --	2014-2016	Commissioner of Central Excise(Appeals), Visakhapatnam	1,69,501
-- Do --	2005-2008	Customs, Excise & Service Tax Appeallate Tribunal, Kolkata.	31,50,000
-- Do --	2009-2013	Customs, Excise & Service Tax Appeallate Tribunal, Kolkata.	4,56,51,910

-- Do --	2015-2016	Commissioner of Central Excise(Appeals), Ranchi	18,72,227
-- Do --	2015-2016	Customs, Excise & Service Tax Appeallate Tribunal, Kolkata.	1,22,043
-- Do --	2016-2017	Commissioner of Central Excise(Appeals), Ranchi	1,54,566
-- Do --	2009-2014	Customs, Excise & Service Tax Appeallate Tribunal, Hyderabad.	89,78,682
-- Do --	2012-2015	Customs, Excise & Service Tax Appeallate Tribunal, Hyderabad.	7,29,718
-- Do --	2012-2014	Customs, Excise & Service Tax Appeallate Tribunal, Chennai	8,81,095
Sales Tax	2010-2011	West Bengal Taxation Tribunal & Appellate Board	19,06,567
-- Do --	2013-2014	The Appellate Deputy Commissioner, Vijayawada	9,50,466
-- Do --	2013-2015	The Appellate Deputy Commissioner, Vijayawada	1,23,71,775
Income Tax	2011-2012	The Commissioner of Income Tax(Appeal-11), Kolkata	9,76,48,084
-- Do --	2014-2015	The Commissioner of Income Tax(Appeal-1), Kolkata	6,33,508
-- Do --	2015-2016	The Commissioner of Income Tax(Appeal-1), Kolkata	26,03,773

(viii) According to the records of the Company examined by us and the information and explanation given to us, the Company has not defaulted in repayment of loans or borrowings to any financial institution or bank or Government as at the balance sheet date.

(ix) In our opinion, and according to the information and explanations given to us, the term loans have been applied for the purposes for which they were obtained.

(x) 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, and according to the information and explanations given to us, we have neither come across any instance of material fraud by the Company or on the Company by its officiers or employees, noticed or reported during the year, nor have we been informed of any such cases by the Management.

(xi) The Company has paid/ provided for managerial remuneration in accordance with the requiste approvals mandated by the provisions of section 197 read with Schedule v to the Act.

(xii) As the Company is not a Nidhi Company and the Nidhi Rules, 2014 are not applicable to it. Accordingly, paragraph 3(xii) of the order are 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 such related party transactions have been disclosed in the Standalone financial statements as required under Indian Accounting Standards (Ind AS) 24, Related Party Disclosures.

(xiv) The Company has not made any preferential allotment or private placement of shares or fully or partly convertible debentures during the year under review. Accordingly, paragraph 3(xiv) of the order are not applicable to the Company.

(xv) The Company has not entered into any non cash transactions with its directors or persons connected with them. Accordingly, paragraph 3(xv) of the order are not applicable to the Company.

(xvi) The Company is not required to be registered under section 45-IA of the Reserve Bank of India Act, 1934. Accordingly,paragraph 3(xvi) of the order are not applicable to the company.

For LIHALA & CO

Chartered Accountants

Firm’s Registration Number.315052E

Rajesh Lihala

Place: 11, Crooked Lane, Kol - 69 Partner

Date: 30th May 2018 Membership No. 052138

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Mar 31, 2016

To the Members of Beekay Steel Industries Limited.

Report on the Financial Statements

We have audited the accompanying financial statement of BEEKAY STEEL INDUSTRIES LIMITED , which comprise the Balance Sheet as at 31st March, 2016, the Statement of Profit and Loss, the Cash Flow Statement for the year then ended and a summary of the significant accounting policies and other explanatory information.

Management''s Responsibility for the Financial Statements

The Company''s Board of Directors is responsible for the matters stated in Section 134(5) of the Companies Act, 2013 ("the Act") with respect to the preparation and presentation of these financial statements that give a true and fair view of the financial position, financial performance and cash flows of the Company in accordance with the accounting principles generally accepted in India, including the Accounting Standards specified under Section 133 of the Act, read with Rule 7 of the Companies (Accounts) Rules, 2014. This responsibility also includes maintenance of adequate accounting records in accordance with the provisions of the Act for safeguarding the assets of the Company and for preventing and detecting frauds and other irregularities; selection and application of appropriate accounting policies; making judgments and estimates that are reasonable and prudent; and design, implementation and maintenance of adequate internal financial controls, that were operating effectively for ensuring the accuracy and completeness of the accounting records, relevant to the preparation and presentation of the financial statements that give a true and fair view and are free from material misstatement, whether due to fraud or error.

Auditor''s Responsibility

Our responsibility is to express an opinion on these financial statements based on our audit.

We have taken into account the provisions of the Act, the accounting and auditing standards and matters which are required to be included in the audit report under the provisions of the Act and the Rules made there under.

We conducted our audit in accordance with the Standards on Auditing specified under Section 143(10) of the Act and other applicable authoritative pronouncements issued by the Institute of Chartered Accountants of India. Those Standards and pronouncements require that we comply with ethical requirements and plan and perform the audit to obtain reasonable assurance about whether the financial statements are free from material misstatement.

An audit involves performing procedures to obtain audit evidence about the amounts and the disclosures in the financial statements. The procedures selected depend on the auditor''s judgment, including the assessment of the risks of material misstatement of the financial statements, whether due to fraud or error. In making those risk assessments, the auditor considers internal financial control relevant to the Company''s preparation of the financial statements that give a true and fair view in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on whether the Company has in place an adequate internal financial controls system over financial reporting and the operating effectiveness of such controls. An audit also includes evaluating the appropriateness of the accounting policies used and the reasonableness of the accounting estimates made by the Company''s Directors, as well as evaluating the overall presentation of the financial statements.

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion on the standalone financial statements.

Opinion

In our opinion and to the best of our information and according to the explanations given to us, the aforesaid financial statements give the information required by the 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 31 March 2016 and its profit and its cash flows for the year ended on that date.

Report on Other Legal and Regulatory Requirements

1. As required by the Companies (Auditor''s Report) Order, 2016 issued by the Central Government of India in terms of sub-section (11) of section 143 of the Act (hereinafter referred to as the "Order"), and on the basis of such checks of the books and records of the Company as we Considered appropriate and according to the information and explanations given to us, we give in the Annexure B a statement on the matters specified in the paragraph 3 and 4 of the Order.

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

a) We have sought and obtained all the information and explanations which to the best of our knowledge and belief were necessary for the purposes of our audit.

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

c) The balance sheet, the statement of profit and loss and the cash flow statement dealt with by this Report are in agreement with the books of account;

d) In our opinion, the aforesaid financial statements comply with the Accounting Standards specified under Section 133 of the Act, read with Rule 7 of the Companies (Accounts) Rules, 2014;

e) On the basis of the written representations received from the directors as on 31 March 2016 taken on record by the Board of Directors, none of the directors is disqualified as on 31 March 2016 from being appointed as a director in terms of Section 164 (2) of the Act;

f) With respect to the adequacy of the internal financial controls over financial reporting of the Company and the operating effectiveness of such controls, refer to our separate Report in Annexure A.

g) With respect to the other matters to be included in the Auditor''s Report in accordance with Rule 11 of the Companies (Audit and Auditors) Rules, 2014, in our opinion and to the best of our information and according to the explanations given to us:

i) The Company has disclosed the impact, if any, of pending litigations as at March 31, 2016 on its financial position in its financial statements.

ii) The Company has made provision as at March 31,2016,as required under the applicable law or accounting standards, for material foreseeable losses, if any, on long-term contracts including derivative contracts.

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 31,2016.

Referred to in paragraph 10(f) of the Independent Auditors'' Report of even date to the members of BEEKAY STEEL

INDUSTRIES LIMITED on the standalone financial statements for the year ended March 31, 2016

Report on the Internal Financial Controls under Clause (i) of Sub-section 3 of Section 143 of the Act.

1. We have audited the internal financial controls over financial reporting of BEEKAY STEEL INDUSTRIES LIMITED as of March 31, 2016 in conjunction with our audit of the standalone financial statements of the Company for the year ended on that date.

Management''s Responsibility for Internal Financial Controls

2. The Company''s 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 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 Company''s policies, the safeguarding of its assets, the prevention and detection of frauds and errors, the accuracy and completeness of the accounting records, and the timely preparation of reliable financial information, as required under the Act.

Auditors'' Responsibility

3. Our responsibility is to express an opinion on the Company''s internal financial controls over financial reporting based on our audit. We conducted our audit in accordance with the Guidance Note on Audit of Internal Financial Controls Over Financial Reporting (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 over financial reporting 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 over financial reporting and their operating effectiveness. Our audit of internal financial controls over financial reporting included obtaining an understanding of internal financial controls over financial reporting, 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 auditor''s judgment, 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 Company''s internal financial controls system over financial reporting.

Meaning of Internal Financial Controls Over Financial Reporting

6. A Company''s internal financial control over financial reporting 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 Company''s internal financial control over financial reporting includes those policies and procedures that:

(i) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the Company.

(ii) 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 authorizations of management and directors of the Company; and

(iii) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the Company''s assets that could have a material effect on the financial statements.

Inherent Limitations of Internal Financial Controls Over Financial Reporting

7. Because of the inherent limitations of internal financial controls over financial reporting, 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 over financial reporting to future periods are subject to the risk that the internal financial control over financial reporting 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 over financial reporting and such internal financial controls over financial reporting were operating effectively as at March 31, 2016, 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 Controls Over Financial Reporting issued by the Institute of Chartered Accountants of India.

The Annexure referred to in our Independent Auditors’ Report to the members of the company on the financial statements for the year ended 31.03.2016, we report that :

(i) a) The Company is maintaining proper records showing full particulars including quantitative details and situation, of fixed assets.

b) The fixed assets 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, it is reasonable having regard to the size of the company and the nature of its assets. Pursuant to the programme, a portion of the fixed assets has been physically verified by the Management during the year and no material discrepancies have been noticed on such verification.

(ii) The physical verification of inventory has been conducted at reasonable intervals by the management during the year. The discrepancies noticed on physical verification of inventory as compared to book records were not material and have been appropriately dealt with in the books of accounts.

(iii) There are firms covered in the register to be maintained under section 189 of the Companies Act, 2013 however Company have not granted loan to such Company as such the Clause does not have any application.

(iv) In our opinion, and according to the information and explanations given to us, the Company has compiled with the provisions of Section 185 and 186 of the Companies Act, 2013 in respect of loans and investments made, and guarantees and security provided by it.

(v) The Company has not accepted any deposits from public within the meaning of sections 73, 74, 75 and 76 of the Act and the rules framed there under to the extent notified.

(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. 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) According to the information and explanations given to us and the records of the company examined by us ,

in our opinion, the company is generally regular in depositing the undisputed statutory dues in respect of sales tax including value added tax, though there has been a slight delay in few cases, and is regular in depositing undisputed statutory dues including provident fund, employees'' state insurance, income tax, service tax, duty of customs, duty of excise, cess and other material statutory dues, as applicable, with the appropriate authorities.

b) According to the information and explanations given to us, there were undisputed amount payable in respect of Income Tax relating to F.Y. 2010-11 amounting Rs. 11,56,430/- which have remained outstanding as at 31st March, 2016 for a period of more than six months from the date they become payable. However no undisputed dues is payable in respect of wealth-tax, sales-tax, value added tax, service tax, customs duty and excise duty which have remained outstanding as at 31.03.2016 for a period of more than six months from the date they became payable.

c) According to the records of the Company, there are dues of sales tax, income tax, customs tax/wealth tax, value added tax, service tax, excise duty / cess which have not been deposited on account of any dispute.

Particulars	Financial year to which the matter pertains	Forum where matter is pending	Amount Involved (?)
Excise Duty	1998-1999	Hon''ble High Court, Kolkata	831,204
— Do —	2010-2011	Comm., Central Excise (Appeal),Visakhapatnam	590,078
— Do —	2011-2015	Commissioner of Central Excise(Appeals), Chennai	168,541
— Do —	2005-2008	Customs ,Excise & Service Tax Appeallate Tribunal, Kolkata.	3,150,000
— Do —	2009-2013	The Commissioner of Central Excise & Service Tax. Jamshedpur	45,651,910
— Do —	2013-2014	Commissioner of Central Excise(Appeals), Ranchi	52,501
— Do —	2009-2013	Commissioner of Central Excise(Appeals), Ranchi	2,509,575
— Do —	2012-2014	Comm., Central Excise (Appeal),Visakhapatnam	788,884
— Do —	2012-2014	Comm., Central Excise (Appeal), Chennai	902,623
Sales Tax	2010-2011	Senior Joint Commissioner of Sales Tax (kolkata)	1,906,567
— Do —	2012-2013	Joint Commissioner (Appeal) of Sales Tax (Jamshedpur)	8,959,689
Income Tax	2004-2005	Income Tax Appellate Tribunal, Kolkata	4,128,981
— Do —	2011-2012	The Commissioner of Income Tax(Appeal-1), Kolkata	67,142,440

d) The amounts required to be transferred to the Investor Education and Protection Fund in accordance with the provisions of the Companies Act, 1956 (1 of 1956) and rules made there under have been transferred to such fund within time.

(viii)According to the records of the company examined by us and the information and explanation given to us, the Company has not defaulted in repayment of loans or borrowings to any financial institution or bank or Government or dues to debenture holders as at the balance sheet date.

(ix) In our opinion, and according to the information and explanations given to us, the term loans have been applied for the purposes for which they were obtained.

(x) 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, and according to the information and explanations given to us, we have neither come across any instance of material fraud by the Company or on the Company by its officers or employees, noticed or reported during the year, nor have we been informed of any such cases by the Management.

(xi) 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.

(xii) As the Company is not a Nidhi Company and the Nidhi Rules, 2014 are not applicable to it, the provisions of clause 3(xii) of the order are 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 such related party transactions have been disclosed in the financial statements as required under Accounting Standard (AS) 18, Related Party Disclosures specified under Section 133 of the Act, read with rule 7 of the Companies (Accounts) Rules, 2014.

(xiv)The Company has not made any preferential allotment or private placement of shares or fully or partly convertible debentures during the year under review. Accordingly, the provisions of clause 3(xiv) of the order are not applicable to the Company.

(xv) The Company has not entered into any non cash transactions with its directors or persons connected with him. Accordingly, the provisions of Clause 3(xv) of the order are not applicable to the Company.

(xvi)The Company is not required to be registered under section 45-IA of the Reserve Bank of India Act, 1934. Accordingly, the provisions of clause 3(xvi) of the order are not applicable to the company.

For RUSTAGI & ASSOCIATES

Chartered Accountants

Place : 59, Bentinck Street, Firm Regd. No.314194E

Kolkata - 700 069. Sd/_-

Dated : 30th day of May, 2016 (S.K. RUSTAGI)

Partner Mem. No.051860

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Mar 31, 2015

We have audited the accompanying financial statement of BEEKAY STEEL INDUSTRIES LIMITED ("the company"), which comprise the Balance Sheet as at 31st March, 2015, the Statement of Profit and Loss, the Cash Flow Statement for the year then ended and a summary of the significant accounting policies and other explanatory information.

Management's Responsibility for the Financial Statements

The Company's Board of Directors is responsible for the matters stated in Section 134(5) of the Companies Act, 2013 ("the Act") with respect to the preparation and presentation of these financial statements that give a true and fair view of the financial position, financial performance and cash flows of the Company in accordance with the accounting principles generally accepted in India, including the Accounting Standards specified under Section 133 of the Act, read with Rule 7 of the Companies (Accounts) Rules, 2014. This responsibility also includes maintenance of adequate accounting records in accordance with the provisions of the Act for safeguarding the assets of the Company and for preventing and detecting frauds and other irregularities; selection and application of appropriate accounting policies; making judgments and estimates that are reasonable and prudent; and design, implementation and maintenance of adequate internal financial controls, that were operating effectively for ensuring the accuracy and completeness of the accounting records, relevant to the preparation and presentation of the financial statements that give a true and fair view and are free from material misstatement, whether due to fraud or error.

Auditor's Responsibility

Our responsibility is to express an opinion on these financial statements based on our audit.

We have taken into account the provisions of the Act, the accounting and auditing standards and matters which are required to be included in the audit report under the provisions of the Act and the Rules made thereunder.

We conducted our audit in accordance with the Standards on Auditing specified under Section 143(10) of the Act. Those Standards require that we comply with ethical requirements and plan and perform the audit to obtain reasonable assurance about whether the financial statements are free from material misstatement.

An audit involves performing procedures to obtain audit evidence about the amounts and the disclosures in the financial statements. The procedures selected depend on the auditor's judgment, including the assessment of the risks of material misstatement of the financial statements, whether due to fraud or error. In making those risk assessments, the auditor considers internal financial control relevant to the Company's preparation of the financial statements that give a true and fair view in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on whether the Company has in place an adequate internal financial controls system over financial reporting and the operating effectiveness of such controls. An audit also includes evaluating the appropriateness of the accounting policies used and the reasonableness of the accounting estimates made by the Company's Directors, as well as evaluating the overall presentation of the financial statements.

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion on the standalone financial statements.

Opinion

In our opinion and to the best of our information and according to the explanations given to us, the aforesaid financial statements give the information required by the 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 31 March 2015 and its profit and its cash flows for the year ended on that date.

Report on Other Legal and Regulatory Requirements

1. As required by the Companies (Auditor's Report) Order, 2015 ("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 a statement on the matters specified in the paragraph 3 and 4 of the Order, to the extent applicable.

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

a) We have sought and obtained all the information and explanations which to the best of our knowledge and belief were necessary for the purposes of our audit.

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

c) The balance sheet, the statement of profit and loss and the cash flow statement dealt with by this Report are in agreement with the books of account;

d) In our opinion, the aforesaid financial statements comply with the Accounting Standards specified under Section 133 of the Act, read with Rule 7 of the Companies (Accounts) Rules, 2014;

e) On the basis of the written representations received from the directors as on 31 March 2015 taken on record by the Board of Directors, none of the directors is disqualified as on 31 March 2015 from being appointed as a director in terms of Section 164 (2) of the Act; and

f) With respect to the other matters to be included in the Auditor's Report in accordance with Rule 11 of the Companies (Audit and Auditors) Rules, 2014, in our opinion and to the best of our information and according to the explanations given to us:

i) The Company has disclosed the impact of pending litigations on its financial position in its financial statements - Refer Note No. 37 to the financial statements;

ii) The Company has made provision, as required under the applicable law or accounting standards,

for material foreseeable losses, if any, on long-term contracts including derivative contracts - Refer Note_____to the financial statements; and

iii) There has been no delay in transferring amounts, required to be transferred, to the Investor Education and Protection Fund by the Company.

Annexure to the Auditors' Report

The Annexure referred to in our Independent Auditors's Report to the members of the company on the financial statements for the year ended 31.03.2015, we report that:

(i) a) The Company has maintained proper records showing full particulars including quantitative details and situation of fixed assets.

b) All the assets have not been physically verified by the management during the year but there is a regular programme of verification which, in our opinion, is reasonable having regard to the size of the Company and the nature of its assets. No material discrepancies were noticed on such verification.

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

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

c) On the basis of our examination of the records of inventory, we are of the opinion that the Company is maintaining proper records of inventory. The discrepancies noticed on verification between the physical stocks and the book records were not material.

(iii) a) There are no firms covered in the register to be maintained under section 189 of the Companies Act, 2013 to which the Company has granted loans and therefore other sub part of this clause is not applicable.

(iv) In our opinion and according to the information and explanations given to us, there are adequate internal control procedures commensurate with the size of the Company and the nature of its business with regard to purchases of inventory, fixed assets and with regard to the sale of goods and services. During the course of our audit, no major weakness has been noticed in the internal controls.

(v) The Company has not accepted any deposits from public

(vi) We have broadly reviewed the books of account relating to materials, labour and other items of cost maintained by the Company pursuant to the Rules made by the Central Government for the maintenance of cost records under section 148(1) of the Companies Act, 2013 and we are of the opinion that prima facie the prescribed accounts and records have been made and maintained.

(vii) a) According otthe records of the Company, the Company is regular in depositing with appropriate authorities undisputed statutory dues including provident fund, employees' state insurance, income-tax, sales-tax, value added tax, wealth-tax, custom duty, excise-duty, service tax cess and other statutory dues applicable to it.

b) According to the information and explanations given to us, there were undisputed amount payable in respect of Income Tax relating to F.Y. 2008-09 and F.Y. 2010-11 amounting Rs. 11,67,469/- which have remained outstanding as at 31st March, 2015 for a period of more than six months from the date they become payable. However no undisputed dues is payable in respect of wealth-tax, sales-tax, value added tax, service tax value added rax, service tax, customs duty and excise duty which have remained outstanding as at 31.03.2015 for a period of more than six months from the date they became payable.

c) According to the records of the Company, there are dues of sales tax, income tax, customs tax/wealth tax, value added tax, service tax, excise duty/cess which have not been deposited on account of any dispute.

Excise Duty 1998-1999 Hon'ble High Court, Kolkata 831,204

Particulars Financial year to Forum where which the matter matter is pertains pending

— Do — 2001-2002 Jt. Comm. Of Central Excise, — Do — 2002-2003 Jamshedpur

— Do — 1994-1995 Comm., Central Excise (Appeal)

— Do — 2010-2011 Comm., Central Excise (Appeal), Vishakapatanum

— Do — 2008-2013 Commissioner of Central Excise (Appeals), Chennai

— Do — 2005-2008 Customs,Excise & Service Tax Appeallate Tribunal, Kolkata.

— Do — 2009-13 The Commissioner of Central Excise & Service Tax, Jamshedpur

Income Tax 2004-05 Income Tax Appellate Tribunal, Kolkata

— Do — 2011-12 The Commissioner of Income Tax (Appeal-1), Kolkata



Particulars Amount Involved (Rs)

— Do — 144,046 — Do — 276,757

— Do — 94,185

— Do — 590,078

— Do — 210,156

— Do — 3,150,000

— Do — 49,353,416

Income Tax 6,063,651

— Do — 76,142,440

d) These amounts required to be transferred to the Investor Education and Protection Fund in accordance with the provisions of the Companies Act, 1956 (1 of 1956) and rules made thereunder have been transferred to such fund within time.

(viii) The accumulated losses of the Company are not more than fifty per cent of its net worth. The Company has not incurred any cash losses during the financial year covered by our audit and the immediately preceding financial year.

(ix) Based on our audit procedures and on the information and explanations given by the management, we are of the opinion that the Company has not defaulted in repayment of dues to a financial institution, bank or debenture holders.

(x) The Company has not given any guarantee for loans taken by others from bank or financial institutions.

(xi) The term loans have been applied for the purpose for which they were raised.

(xii) Based upon the audit procedures performed and information and explanations given by the management, we report that no fraud on or by the Company has been noticed or reported during the course of our audit.

For RUSTAGI & ASSOCIATES Place : 59, Bentinck Street, Chartered Accountants Kolkata - 700 069. Firm Regd. No.314194E

Dated : 30th day of May, 2015

Sd/- (S.K. RUSTAGI) Partner Mem. No.051860

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Mar 31, 2014

We have audited the accompanying Financial Statements of BEEKAY STEEL INDUSTRIES LIMITED, which comprise the Balance Sheet as at March 31, 2014, and the Statement of Profit and Loss and the Cash Flow Statement for the year then ended, and a summary of significant accounting policies and other explanatory information.

2. Management''s Responsibility for the Financial Statements

The Company''s Management is resposible for the preparation of these financial statements that give a true and fair view of the financial position, financial performance and cash flows of the Company in accordance with the Accounting Standards notified under the Companies Act, 1956 (the Act) read with the General Circular 15/2013 dated 13th September, 2013 of the Ministry of Corporate Affairs in respect of Section 133 of the Companies Act, 2013 and in accordance with the accounting principles generally accepted in India. This responsibility includes the design, implementation and maintenance of internal control relevant to the preparation and presentation of the financial statements that give a true and fair view and are free from material misstatement, whether due to fraud or error.

3. Auditor''s Responsibility

Our responsibility is to express an opinion on these financial statements based on our audit. We conducted our audit in accordance with the Standards on Auditing issued by The Institute of Chartered Accountants of India. Those Standards require that we comply with ethical requirements and plan and perform the audit to obtain resonable assurance about whether the financial statements are free from material misstatement.

An Audit involves performing procedure to obtain audit evidence about the amounts and disclosures in the financial statements. The procedures selected depend on the auditor''s judgement, including the assessment of the risks of material misstatement of the financial statements, whether due to fraud or error. In making those risk assessments, the auditor considers internal control relevant to the Company''s preparation and fair presentation of the financial statements in order to design audit procedures that are appropriate in the circumstances. An audit also includes evaluating the appropriateness of accounting policies used and the resonableness of the accounting estimates made by management, as well as evaluating the overall presentation of the financial statements.

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion.

4. Opinion

In our opinion and to the best of our information and according to the explanations given to us, the Financial Statements give the information required by the Act, in the manner so required and give a true and fair view in conformity with the accounting principles generally accepted in India:

a) In the case of the Balance Sheet, of the state of affairs of the Company as at March 31, 2014; and

b) In the case of the Profit and Loss Account, of the Profit for the year ended on that date.

c) In case of Cash Flow Statement, of the Cash Flows of the Company for the year ended on that date.

5. Report on Other Legal and Regulatory Requirements

As required by the Companies (Auditor''s Report) Order, 2003 issued by the Central Government of India in terms of Sub-section (4A) of Section 227 of the Companies Act, 1956, we enclose in the Annexure a statement on the matters specified in paragraphs 4 and 5 of the said Order to the extent applicable.

a) We have obtained all the information and explanation which to the best of our knowledge and belief were necessary for the purpose of our audit.

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

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

d) In our opinion, the Balance Sheet, the Statement of Profit and Loss and the Cash Flow Statement comply with Accounting Standards notified under the Act read with the General Circular 15/2013 dated 13th September, 2013 of the Ministry of Corporate Affairs in respect of section 133 of the Companies Act, 2013.

e) On the basis of written representations received from the Directors as on March 31, 2014 and taken on record by the Board of Directors, none of the Directors are disqualified as on 31st March, 2014, from being appointed as a director in terms of clause (g) of sub-section (1) of section 274 of the Companies Act, 1956.

With reference to the Annexure referred to in Paragraph 4 of the report of the Auditors to the Members of BEEKAY STEEL INDUSTRIES LIMITED for the year ended 31st March, 2014 on the basis of the records produced to us for verification / perusal such checks as we considered appropriate, and in terms of information and explanations given to us on our enquiries, We state that:

1) In respect of its Fixed Assets:

(a) The Company has maintained proper records showing full particulars, including, quantitative details and situation of Fixed Assets on the basis of available information.

(b) As explained to us, considering the nature of the Fixed Assets, the same have been physically verified by the management at reasonable intervals during the year in a phased manner. According to the information''s and explanations given to us and the records produced to us for our verification, discrepancies noticed on such physical verification were not material and the same have been properly dealt in the books of accounts.

(c) Fixed Assets disposed off during the year were not significant and would neither have an impact on the operation of the Company nor affected.

2) In respect of its Inventories:

(a) As explained to us, the inventories were physically verified during the year by the Management the frequency of verificaiton is reasonable.

(b) The procedures of physical verification of inventory followed by management were found reasonable and adequate in relation to the size of the Company and the nature of its business.

(c) The Company has maintained proper records of inventory. In our opinion and according to the information and explanations given to us, the maintenance of records for inventory is adequate and discrepancies noticed on physical verification of inventories have been property dealt with in the books of account.

3) a) The Company has taken Unsecured Loan from Companies which are covered by the Act. The terms and condition of such loan are prima facie not prejudicial to the interest of the Company. The Maximum amount outstanding during the year including accrued interest was Rs.1,42,54,986/- and the year end balance is Rs. 88,03,718/-

b) The Company has taken unsecured loan from directors during the year and the year end balance is Rs.1 0,617,855/- inclusive of accrued interest which falls under the category of the Companies, Firms or other parties under the Act.

4) In our opinion and according to the explanations given to us, there are adequate internal control procedures commensurate with the size of the Company and the nature of its business with regard to purchase of inventory including components, equipment, other assets and for the sale of goods. In our opinion there is no major weaknesses in internal control.

5) In respect of contracts or arrangements entered in the Register maintained in pursuanance of Act, to the best of our knowledge and according to the information and explanations given to us:

(a) The particulars of contracts or arrangements referred to Section 301 that needed to be entered in the Register maintained under said Section have been so entered.

(b) where each of such transaction is in excess of Rs. 5 lakhs in respect of any party, the transactions have been made at prices which are prima facie reasonable having to the prevailing market prices at the relevant time.

6) The Company has not accepted any public, deposits during the year. Therefore, the provisions of clause (vi) of paragraph 4 of the Order are not applicable to the Company.

7) In the basis of the internal audit reports broadly reviewed by us, we are of the opinion that the Company has an adequate internal audit system commensurate with the size of the Company and the nature of its business.

8) The Company has maintained cost records as prescribed by the central government under section 209(1)(a) of the Act. We have not made a detailed examination of such records with a view to determine whether they are accurate or complete.

9) (a) There were undisputed amounts payable in respect of Income Tax relating to Financial Year''s from 2006 -2007 to 2010-2011 amounting Rs. 16,64,604 which have remained outstanding as at 31st March, 2014 for a period of more than six months from the date they become payable. But no undisputed dues is payable in respect of Wealth Tax, Custom Duty, Excise Duty, Cess, Service Tax, Investor Education and Protection Fund, Employee State Insurance and Other materials statutory dues applicable to it which have remained outstanding as at 31st March, 2014 for a period of more than six months from the date they become payable.

(b) According to the information and explanations given to us, the details of Statutory dues of Sales tax, Excise Duty & Service Tax which have not deposited on account of dispute are given below :

Particulars Financial year to which Forum where matter is pending the matter pertains

Excise Duty 1998-1999 Hon''ble High Court, Kolkata

-- Do -- 2001-2002 Jt. Comm. Of Central Excise, -- Do -- 2002-2003 Jamshedpur

-- Do -- 1994-1995 Comm., Central Excise (Appeal)

-- Do -- 2011-2012 Comm., Central Excise (Appeal), Vishakapatanum

-- Do -- 2010-2011 Comm., Central Excise (Appeal), Vishakapatanum

-- Do -- 2008-2012 Comm., Central Excise (Appeal), Vishakapatanum

-- Do -- 2004-2008 Customs,Excise & Service Tax Appeallate Tribunal, Bangalore.

-- Do -- 2008-2013 Commissioner of Central Excise (Appeals), Chennai

-- Do -- 2005-2008 Customs,Excise & Service Tax Appeallate Tribunal, Kolkata.

Sales Tax 2008-09 CIT(Appeal), Jamshedpur

-- Do -- 2007-08 The Appellate Deputy Commissioner (CT), Visakhapatnam

Sales Tax 2009-10 The Appellate Deputy Commissioner (CT), Visakhapatnam

Particulars Amount Involved (Rs.)

Excise Duty 8,31,204

-- Do -- 1,44,046

-- Do -- 2,76,757

-- Do -- 94,185

-- Do -- 11,66,247

-- Do -- 5,90,078

-- Do -- 54,94,510

-- Do -- 13,47,300

-- Do -- 2,10,156

-- Do -- 31,50,000

Sales Tax 40,13,333

-- Do -- 14,40,730

Sales Tax 2,95,46,895

10) The Company has no accumulated losses at the end of the financial year and has not incurred any cash losses during the financial year and in the financial year immediately preceeding financial year.

11) The Company has not defaulted in repayment of dues to the financial institution, banks and the company has not issued any debentures.

12) The Company has not granted any loans and advances on the basis of Security by way of pledge shares, debentures and other securities.

13) The Company is not a Chitfund/Nidhi/Mutual Benefit Fund/Society. Therefore, the provisions of clause 4 (xiii) of the Companies (Auditor''s Report) (Amendment) Order 2004 are not applicable to the Company.

14) In our opinion and according to information and explanation given to us, the Company has not made any investments in any shares & security or in any mutual fund during the year. The investments made by Company are held in its own name.

15) According to the information and explanations given to us, the Company has not given any guarantee for loan taken by any others from a bank or financial institution.

16) In our opinion and according to the information explanations given to us, the term loans have been applied for the purpose for which they were raised.

17) According to the records examined by us and information and explanation given to us, on an overall basis, funds raised on short term basis have prima facie not been used during the year for Long Term Investments

18) According to the information and explanations given to us, the Company has not made any preferential allotment of shares to parties or Companies covered under section 301 of Companies Act, 1956 at a price which is prejudicial to the interest of the Company.

19) According to the information and explanations given to us, the Company has not issued any secured debentures.

20) The Company has not raised any money by way of a Public Issue.

21) Based upon the audit procedures perfiormed and information and explanation given by the management, we report that no fraud on or by the company has been noticed or reported during the course of our audit.

For RUSTAGI & ASSOCIATES Firm Regd. No.314194E Chartered Accountants

Sd/- (S.K. RUSTAGI) Partner Mem.No.51860

59, Bentinck Street, Kolkata - 700 069 Dated : 30th day of May, 2014

---

Mar 31, 2013

1. Report on the Financial Statements

We have audited the accompanying Financial Statements of BEEKAY STEEL INDUSTRIES LIMITED, which comprise the Balance Sheet as at March 31, 2013, and the Statement of Profit and Loss and the Cash Flow Statement for the year then ended, and a summary of significant accounting policies and other explanatory information.

2. Management''s Responsibility for the Financial Statements

Management is responsible for the preparation of these Financial Statements that give a true and fair view of the financial position, financial performance and the cash Flows of the Company in accordance with the Accounting Standards referred to in sub-section (3C) of section 211 of the companies Act, 1956. This responsibility includes the design, implementation and maintenance of internal control relevant to the preparation and presentation of the Financial Statements that give a true and fair view and are free from material misstatement, whether due to fraud and error.

3. Auditor''s Responsibility

Our responsibility is to express an opinion on these financial statements based on our audit. We conducted our audit in accordance with the Standards on Auditing issued by The Institute of Chartered Accountants of India. Those Standards require that we comply with ethical requirements and plan and perform the audit to obtain resonable assurance about whether the financial statements are free from material misstatement.

An Audit involves performing procedure to obtain audit evidence about the amounts and disclosures in the financial statements. The procedures selected depend on the auditor''s judgement, including the assessment of the risks of material misstatement of the financial statements, whether due to fraud or error. In making those risk assessments, the auditor considers internal control relevant to the Company''s preparation and fair presentation of the financial statements in order to design audit procedures that are appropriate in the circumstances. An audit also includes evaluating the appropriateness of accounting policies used and the resonableness of the accounting estimates made by management, as well as evaluating the overall presentation of the financial statements.

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion.

4. Opinion

In our opinion and to the best of our information and according to the explanations given to us, the Financial Statements give the information required by the Companies Act, 1956, in the manner so required and give a true and fair view in conformity with the accounting principles generally accepted in India:

a) In the case of the Balance Sheet, of the state of affairs of the Company as at March 31, 2013; and

b) In the case of the Profit and Loss Account, of the Profit for the year ended on that date.

c) In case of Cash Flow Statement, of the Cash Flows for the year ended on that date.

5. Report on Other Legal and Regulatory Requirements

As required by the Companies (Auditor''s Report) Order, 2003 issued by the Central Government of India in terms of Sub-section (4A) of Section 227 of the Companies Act, 1956, we enclose in the Annexure a statement on the matters specified in paragraphs 4 and 5 of the said Order to the extent applicable.

a) We have obtained all the information and explanation which to the best of our knowledge and belief were necessary for the purpose of our audit.

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

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

d) In our opinion, the Balance Sheet, Statement of Profit and Loss and Cash Flow Statement comply with the Accounting Standards referred to in sub-section (3C) of Section 211 of the Companies Act, 1956.

e) On the basis of written representations received from the Directors as on March 31, 2013 and taken on record by the Board of Directors, none of the Directors are disqualified as on 31st March, 2013, from being appointed as a director in terms of clause (g) of sub-section (1) of section 274 of the Companies Act, 1956.

ANNEXURE TO THE AUDIT REPORT

With reference to the Annexure referred to in Paragraph 4 of the report of the Auditors to the Members of BEEKAY STEEL INDUSTRIES LIMITED for the year ended 31st March, 2013 on the basis of the records produced to us for verification / perusal such checks as we considered appropriate, and in terms of information and explanations given to us on our enquiries, We state that:

i) (a) The Company has maintained proper records showing full particulars, including, quantitative details and situation of Fixed Assets.

(b) As explained to us, considering the nature of the Fixed Assets, the same have been physically verified by the management at reasonable intervals during the year as per the verification schedule adopted by the company whereby all the assets are verified, in a phased manner. According to the information''s and explanations given to us and the records produced to us for our verification, discrepancies noticed on such physical verification were not material and the same have been properly dealt in the books of accounts.

(c) Fixed Assets disposed off during the year were not significant and would neither have an impact on the operation of the Company nor affect its going concern.

ii) (a) As explained to us, the inventories of finished goods and raw materials were physically verified during the year by the Management. The Company has a programme of verification of stocks having regards to the nature and location of stocks, the frequency of verificaiton is reasonable.

(b) In our opinion and according to the records produced and explanations given to us, the procedures of physical verification of inventory followed by management were found reasonable and adequate in relation to the size of the Company and the nature of its business.

(c) In our opinion and according to the information and explanations given to us the company has maintained proper records of inventory. In our opinion and according to the information and explanations given to us, the maintenance of records for inventory is adequate according to the size of Company and nature of business and discrepancies noticed on physical verification of inventories to above as compared to book records have been property dealt with in the books of account.

iii) a) According to the information and explanations given to us, the Company has taken Unsecured Loan from Companies which are covered by Section 301 of the Companies Act,1956. The terms and condition of such loan are prima facie not prejudicial to the interest of the Company. The Maximum amount outstanding during the year was Rs.4,38,84,579/- and the year end balance is Rs. 1,02,54,986/-

b) According to the information and explanations given to us, the Company has taken unsecured loan from directors during the year and the year end balance is Rs.76,07,715/- inclusive of accrued interest which falls under the category of the Companies, Firms or other parties which are covered by Section 301 of the Companies Act,1956.

iv) In our opinion and according to the explanations given to us, there are adequate internal control procedures commensurate with the size of the Company and the nature of its business with regard to purchase of inventory including components, equipment, other assets and for the sale of goods. In our opinion there is no major weaknesses in internal control.

v) In respect of contracts or arrangements entered in the Register maintained in pursuanance of Section 301 of the Companies Act, 1956, to the best of our knowledge and according to the information and explanations given to us:

(a) The particulars of contracts or arrangements referred to Section 301 that needed to be entered in the Register maintained under said Section have been so entered.

(b) where each of such transaction is in excess of Rs. 5 lakhs in respect of any party, the transactions have been made at prices which are prima facie reasonable having to the prevailing market prices at the relevant time.

vi) The Company has not accepted any public, deposits during the year within the meaning of Section 58A / 58AA or other relevant provisions of Companies Act,1956 and The Companies(Acceptance of Deposit) Rules, 1975.

vii) In the basis of the internal audit reports broadly reviewed by us, we are of the opinion that the Company has an adequate internal audit system commensurate with the size of the Company and the nature of its business.

viii) As informed to us, the company has made and maintained cost records as prescribed by the central government under section 209(1)(a) of the Act. We have not made a detailed examination of such records. However we have broadly reviewed the records maintained and are of the opinion, that primafacie the prescribed accounts and records have been maintained.

ix)According to the information and explanations given to us and on the basis of our examination of the books of accounts, there were no undisputed amounts payable in respect of Income Tax, Wealth Tax, Custom Duty, Excise Duty, Cess, Service Tax Investor Education and Protection Fund, Employee State Insurance and Other materials statutory dues applicable to it which have remained outstanding as at 31st March, 2013 for a period of more than six months from the date they become payable.

x) According to the information and explanations given to us, the Company has not granted any loans and advances on the basis of Security by way of pledge shares, debentures and other securities.

xi) The Company has no accumulated losses at the end of the financial year and has not incurred any cash losses during the financial year and in the financial year immediately preceeding financial year.

xii) According to the information and explanation given to us, the Company has not defaulted in repayment of dues to the financial institution, banks and the company has not issued any debentures.

xiii) The Company is not a Chitfund/Nidhi/Mutual Benefit Fund/Society. Therefore, the provisions of clause 4 (xiii) of the Companies (Auditor''s Report) (Amendment) Order 2004 are not applicable to the Company.

xiv) In our opinion and according to information and explanation given to us, the Company has not made any investments in any shares & security or in any mutual fund during the year. The investments made by Company are held in its own name.

xv) According to the information and explanations given to us, the Company has not given any guarantee for loan taken by any others from a bank or financial institution.

xvi) In our opinion and according to the information explanations given to us, the term loans have been applied for the purpose for which they were raised.

xvii) According to the Cash Flow Statement and other records examined by us and information and explanation given to us, on an overall basis, funds raised on short term basis have prima facie not been used during the year for Long Term Investments

xviii) According to the information and explanations given to us, the Company has not made any preferential allotment of shares to parties or Companies covered under section 301 of Companies Act, 1956 at a price which is prejudicial to the interest of the Company.

xix) According to the information and explanations given to us, the Company has not issued any secured debentures during the period covered by our report.

xx) During the period covered under our Audit Report the Company has not raised any money by way of a Public Issue.

xxi) Based upon the audit procedures performed and information and explanation given by the management, we report that no fraud on or by the company has been noticed or reported during the course of our audit.

For RUSTAGI & ASSOCIATES

Firm Regd. No.314194E

Chartered Accountants

Sd/-

(S.K. RUSTAGI)

Partner

Mem.No.51860

59, Bentinck Street,

Kolkata - 700 069.

Dated : 30th day of May, 2013

---

Mar 31, 2012

1. We have audited the attached Balance Sheet of BEEKAY STEEL INDUSTRIES LIMITED, as at 31st March, 2012, the related Profit and Loss Account and Cash Flow Statement of the Company for the year ended on that date annexed thereto. These financial statements are the responsibility of the Company''s management. Our responsibility is to express an opinion on these financial statements based on our audit.

2. We conducted our audit in accordance with the auditing standards generally accepted in India. Those Standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement. An audit includes examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements. An audit also includes assessing the accounting principles used and significant estimates made by management, as well as evaluating the overall financial statement presentation. We believe that our audit provides a reasonable basis for our opinion.

3. As required by the Companies (Auditor''s Report) Order, 2003 in terms of Sub-Section (4A) of Section 227 of the Companies Act, 1956, we enclose in the Annexure, a statement on the matters specified in paragraphs 4 and 5 of the said Order.

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

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

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

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

iv) In our opinion, the Balance Sheet, Profit & Loss Account & Cash Flow Statement dealt with this report comply with the Accounting Standards referred to in Sub-Section (3C) of Section 211 of the Companies Act, 1956;

v) On the basis of written representations received from the Directors, as on 31st March, 2012 and taken on record by the Board of Directors, we report that none of the Directors is disqualified as on 31st March, 2012 from being appointed as a Director in terms of clause (g) of Sub-section (1) of Section 274 of the Companies Act, 1956;

vi) In our opinion and to the best of our information and according to the explanations given to us, the said accounts give the information required by the Companies Act, 1956, in the manner so required and give a true and fair view in conformity with the accounting principles generally accepted in India;

a) In the case of the Balance Sheet, of the state of affairs of the Company as at March 31, 2012;

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

c) In the case of the Cash Flow Statement, of Cash Flows for the year ended on that date.

ANNEXURE TO THE AUDIT REPORT

With reference to the Annexure referred to in Paragraph 3 of the report of the Auditors to the Members of BEEKAY STEEL INDUSTRIES LIMITED for the year ended 31st March, 2012 on the basis of the records produced to us for verification / perusal such checks as we considered appropriate, and in terms of information and explanations given to us on our enquiries, We state that:

i) (a) The Company has maintained proper records showing full particulars, including, quantitative details and situation of Fixed Assets.

(b) As explained to us, considering the nature of the Fixed Assets, the same have been physically verified by the management at reasonable intervals during the year as per the verification schedule adopted by the company whereby all the assets are verified, in a phased manner. According to the information''s and explanations given to us and the records produced to us for our verification, discrepancies noticed on such physical verification were not material and the same have been properly dealt in the books of accounts.

(c) Fixed Assets disposed off during the year were not significant and would neither have an impact on the operation of the Company nor affect its going concern.

ii) (a) As explained to us, the inventories of finished goods and raw materials were physically verified during the year by the Management. The Company has a programme of verification of stocks having regards to the nature and location of stocks, the frequency of verificaiton is reasonable.

(b) In our opinion and according to the records produced and explanations given to us, the procedures of physical verification of inventory followed by management were found reasonable and adequate in relation to the size of the Company and the nature of its business.

(c) In our opinion and according to the information and explanations given to us the company has maintained proper records of inventory. In our opinion and according to the information and explanations given to us, the maintenance of records for inventory is adequate according to the size of Company and nature of business and discrepancies noticed on physical verification of inventories to above as compared to book records have been property dealt with in the books of account.

iii) a) According to the information and explanations given to us, the Company has granted an Unsecured Loan to a Company which are covered by Section 301 of the Companies Act,1956. The terms and condition of such loan are prima facie not prejudicial to the interest of the Company. The Maximum amount involved during the year was Rs. 2,745 lacs.

b) According to the information and explanations given to us, the Company has taken unsecured loan from directors during the year and the year end balance is Rs. 139.00 lacs inclusive of accrued interest which falls under the category of the Companies, Firms or other parties which are covered by Section 301 of the Companies Act,1956.

iv) In our opinion and according to the explanations given to us, there are adequate internal control procedures commensurate with the size of the Company and the nature of its business with regard to purchase of inventory including components, equipment, other assets and for the sale of goods. In our opinion there is no major weaknesses in internal control.

v) In respect of contracts or arrangements entered in the Register maintained in pursuanance of Section 301 of the Companies Act, 1956, to the best of our knowledge and according to the information and explanations given to us:

(a) The particulars of contracts or arrangements referred to Section 301 that needed to be entered in the Register maintained under said Section have been so entered.

(b) where each of such transaction is in excess of Rs. 5 lakhs in respect of any party, the transactions have been made at prices which are prima facie reasonable having to the prevailing market prices at the relevant time.

vi) The Company has not accepted any public, deposits during the year within the meaning of Section 58A / 58AA or other relevant provisons of Companies Act,1956 and The Companies (Acceptance of Deposit) Rules, 1975.

vii) In the basis of the internal audit reports broadly reviewed by us, we are of the opinion that the Company has an adequate internal audit system commensurate with the size of the Company and the nature of its business.

viii) As informed to us, the company has made and maintained cost records as prescribed by the central government under section 209(1)(a) of the Act. We have not made a detailed examination of such records. However we have broadly reviewed the records maintained and are of the opinion, that primafacie the prescribed accounts and records have been maintained.

ix) According to the information and explanations given to us and on the basis of our examination of the books of accounts, there were no undisputed amounts payable in respect of Income Tax, Wealth Tax, Custom Duty, Excise Duty, Cess, Service Tax Investor Education and Protection Fund, Employee State Insurance and Other materials statutory dues applicable to it which have remained outstanding as at 31st March, 2012 for a period of more than six months from the date they become payable.

x) According to the information and explanations given to us, the Company has not granted any loans and advances on the basis of Security by way of pledge shares, debentures and other securities.

xi) The Company has no accumulated losses at the end of the financial year and has not incurred any cash losses during the financial year and in the financial year immediately preceeding financial year.

xii) According to the information and explanation given to us, the Company has not defaulted in repayment of dues to the financial institution, banks and the company has not issued any debentures.

xiii) The Company is not a Chitfund/Nidhi/Mutual Benefit Fund/Society. Therefore, the provisions of clause 4 (xiii) of the Companies (Auditor''s Report) (Amendment) Order 2004 are not applicable to the Company.

xiv) In our opinion and according to information and explanation given to us, the Company has not made any investments in any shares & security or in any mutual fund during the year. The investments made by Company are held in its own name.

xv) According to the information and explanations given to us, the Company has not given any guarantee for loan taken by any others from a bank or financial institution.

xvi) In our opinion and according to the information explanations given to us, the term loans have been applied for the purpose for which they were raised.

xvii) According to the information and explanations given to us, the Company has not used any short term funds to pay-off long term investment and vice-versa.

xviii) According to the information and explanations given to us, the Company has not made any preferential allotment of shares to parties or Companies covered under section 301 of Companies Act, 1956 at a price which is prejudicial to the interest of the Company.

xix) According to the information and explanations given to us, the Company has not issued any secured debentures during the period covered by our report.

xx) During the period covered our Audit Report the Company has not raised any money by way of a Public Issue. However 20,00,000 Equity Shares of the Company having face value of `10/- has been issued during the year.

xxi) According to the information and explanations given to us, no material frauds on the Company has been noticed or reported during the course of our Audit.

For RUSTAGI & ASSOCIATES

Firm Regd. No.314194E

Chartered Accountants

Sd/-

(S.K. RUSTAGI)

Partner

Mem.No.51860

59, Bentinck Street,

Kolkata - 700 069.

Dated: 21st day of August, 2012

---

Mar 31, 2011

1. We have audited the attached Balance Sheet of BEEKAY STEEL INDUSTRIES LIMITED, as at 31st March, 2011 the related Profit and Loss Account and Cash Flow Statement of the Company for the year ended on that date annexed thereto. These financial statements are the responsibility of the Company’s management. Our responsibility is to express an opinion on these financial statements based on our audit.

2. We conducted our audit in accordance with the auditing standards generally accepted in India. Those Standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement. An audit includes examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements. An audit also includes assessing the accounting principles used and significant estimates made by management, as well as evaluating the overall financial statement presentation. We believe that our audit provides a reasonable basis for our opinion.

3. As required by the Companies (Auditor’s Report) Order, 2003 in terms of Sub-Section (4A) of Section 227 of the Companies Act, 1956, we enclose in the Annexure, a statement on the matters specified in paragraphs 4 and 5 of the said Order.

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

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

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

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

iv) In our opinion, the Balance Sheet, Profit & Loss Account & Cash Flow Statement dealt with the this report comply with the Accounting Standards referred to in Sub-Section (3C) of Section 211 of the Companies Act, 1956;

v) On the basis of written representations received from the Directors, as on 31st March, 2011 and taken on record by the Board of Directors, we report that none of the Directors is disqualified as on 31st March, 2011 from being appointed as a Director in terms of clause (g) of Sub-section (1) of Section 274 of the Companies Act, 1956;

vi) In our opinion and to the best of our information and according to the explanations given to us, the said accounts give the information required by the Companies Act, 1956, in the manner so required and give a true and fair view in conformity with the accounting principles generally accepted in India;

a) In the case of the Balance Sheet, of the state of affairs of the Company as at March 31, 2011;

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

c) In the case of the Cash Flow Statement, of Cash Flows for the year ended on that date.

ANNEXURE TO THE AUDIT REPORT

With reference to the Annexure referred to in Paragraph 3 of the report of the Auditors to the Members of BEEKAY STEEL INDUSTRIES LIMITED for the year ended 31st March, 2011 on the basis of the records produced to us for verification / perusal such checks as we considered appropriate, and in terms of information and explanations given to us on our enquiries, We state that:

i) (a) The Company has maintained proper records showing full particulars, including, quantitative details and situation of Fixed Assets.

(b) As explained to us, considering the nature of the Fixed Assets, the same have been physically verified by the management at reasonable intervals during the year as per the verification schedule adopted by the company whereby all the assets are verified, in a phased manner. According to the information’s and explanations given to us and the records produced to us for our verification, discrepancies noticed on such physical verification were not material and the same have been properly dealt in the books of accounts.

(c) Fixed Assets disposed off during the year were not significant and would neither have an impact on the operation of the Company nor affect its going concern.

ii) (a) As explained to us, the inventories of finished and semi-finished goods and raw materials were physically verified during the year by the Management. The Company has a programme of verification of stocks having regards to the nature and location of stocks, the frequency of verificaiton is reasonable.

(b) In our opinion and according to the records produced and explanations given to us, the procedures of physical verification of inventory followed by management were found reasonable and adequate in relation to the size of the Company and the nature of its business.

(c) According to the records produced company has maintained proper records of inventory. In our opinion and according to the information and explanations given to us, the maintenance of records for inventory is adequate according to the size of Company and nature of business and discrepancies noticed on physical verification of inventories to above as compared to book records have been property dealt with in the books of account.

iii) a) According to the information and explanations given to us, the Company has granted an Unsecured Loan to a Company which are covered by Section 301 of the Companies Act, 1956. The terms and condition of such loan are prima facie not prejudicial to the interest of the Company.

b) According to the information and explanations given to us, the Company has taken unsecured loan from directors during the year and the year end balance is Rs. 270.57 lacs inclusive of accrued interest which falls under the category of the Companies, Firms or other parties which are covered by Section 301 of the Companies Act, 1956.

iv) In our opinion and according to the explanations given to us, there are adequate internal control procedures commensurate with the size of the Company and the nature of its business with regard to purchase of inventory including components, equipment, other assets and for the sale of goods. In our opinion there is no continuous failure to correct major weaknesses in internal control.

v) In respect of contracts or arrangements entered in the Register maintained in pursuanance of Section 301 of the Companies Act, 1956, to the best of our knowledge and according to the information and explanations given to us:

(a) The particulars of contracts or arrangements referred to Section 301 that needed to be entered in the Register maintained under said Section have been so entered.

(b) where each of such transaction is in excess of Rs. 5 lakhas in respect of any party, the transactions have been made at prices which are prima facie reasonable having to the prevailing market prices at the relevant time.

vi) The Company has not accepted any public, deposits during the year (as per provision of 58A/58AA of Acceptance of Deposit Rules, 1975).

vii) In the basis of the internal audit reports broadly reviewed by us, we are of the opinion that the Company has an adequate internal audit system commensurate with the size of the Company and the nature of its business.

viii) To the best of our knowledge and according to the information given to us, the Central Government has not prescribed maintenance of Cost Records under Section 209(1)(d) of the Companies Act, 1956, in respect of the Company’s products.

ix) According to the information and explanations given to us and on the basis of our examination of the books of accounts, there were no undisputed amounts payable in respect of Income Tax, Wealth Tax, Custom Duty, Excise Duty, Cess, Service Tax Investor Education and Protection Fund, Employee State Insurance and Other materials statutory dues applicable to it which have remained outstanding as at 31st March, 2011 for a period of more than six months from the date they become payable.

x) According to the information and explanations given to us, the Company has not granted any loans and advances on the basis of Security by way of pledge shares, debentures and other securities.

xi) The Company has no accumulated losses at the end of the financial year and has not incurred any cash losses during the financial year and in the financial year immediately proceeding financial year.

xii) According to the information and explanation given to us, the Company has not defaulted in repayment of dues to the financial institution, banks and the company has not issued any debentures.

xiii) The Company is not a Chitfund/Nidhi/Mutual Benefit Fund/Society. Therefore, the provisions of clause 4 (xiii) of the Companies (Auditor’s Report) (Amendment) Order 2004 are not applicable to the Company.

xiv) In our opinion and according to information and explanation given to us, the Company has not made any investments in any shares & security or in any mutual fund during the year. The investments made by Company are held in its own name.

xv) According to the information and explanations given to us, the Company has not given any guarantee for loan taken by any others from a bank or financial institution.

xvi) In our opinion and according to the information explanations given to us, the term loans have been applied for the purpose for which they were raised.

xvii) According to the information and explanations given to us, the Company has not used any short term funds to pay-off long term investment and vice-versa.

xviii) According to the information and explanations given to us, the Company has not made any preferential allotment of shares to parties or Companies covered under section 301 of Companies Act, 1956 at a price which is prejudicial to the interest of the Company.

xix) According to the information and explanations given to us, the Company has not issued any secured debentures during the period covered by our report.

xx) During the period covered our Audit Report the Company has not raised any money by way of a Public Issue.

xxi) According to the information and explanations given to us, no material frauds on the Company has been noticed or reported during the course of our Audit. For RUSTAGI & ASSOCIATES

Firm Regd. No.314194E

Chartered Accountants

Sd/-

(S.K. RUSTAGI)

Partner

Mem.No.51860 59,

Bentinck Street,

Kolkata - 700 069.

Dated: 16th day of August, 2011