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Notes to Accounts of Suraj Ltd.

Mar 31, 2014

1. Contingent liabilities not provided for :

(a) Demand of Rs. 2,24,379/- for the accounting year 2003-04, Demand of Rs. 1,40,975/- for the accounting year 2004-05, Demand of Rs. 1,05,14,581/- for the accounting year 2008-09 and Demand of Rs. 1,79,35,983/- for the accounting year 2009-10 raised by Sales Tax authorities, which is disputed by the Company.

Demand of Rs. 4,68,300/- raised by Income Tax authorities, for Assessment year 2010-11 which is disputed by the Company.

Demand of Rs. 9,17,386/- raised by Income Tax authorities, for Assessment year 2001-02 which is disputed by the Company.

Penalty of Rs. 73,62,856/- raised by Income Tax authorities, for Assessment year 2009-10 which is disputed by the Company.

(b) The Income tax authorities carried out a search and seizure operations on the premises of Company during the Financial Year. However the company has not received any order or appraisal report in connection with this search and seizure by the Income Tax Department.

(c) In connection with the Search conducted by Excise Department during the year to ascertain the facts regarding evasion of Central Excise Duty by the company, the department had insisted for reversal of Cenvat Credit of Rs.75 lacs in RG-23 Part - II on the basis of preliminary statement of the company. However, in absence of receipt of any final report for ascertainment of evasion of any excise duty by the company, the company had considered this reversal credit of Rs. 75 lacs as advance excise duty in the books of accounts and shown under the group "Short Term Loans & Advances" in the Balance Sheet.

2. Estimated amount of contracts remaining to be executed on capital account and not provided for in the Accounts (net of advances) NIL

3. In terms of accounting policy (E) for the accounting of export incentives, estimated benefit of Rs 389.74 Lacs have been taken in to account under DES Scheme. Steps are being taken to import raw materials and utilize the same.

4. (a) Payment of Managerial Remuneration : In view of inadequacy of profit for the year 2013-14, remuneration paid by the company to the Chief Financial Officer, Managing Director, Director & Whole Time Director is in excess of the limit prescribed u/s 198 read with Schedule - XIII to the Companies Act. 1956

(b) Since the statutory records of inventory had been seized by Excise Authority in connection with Search conducted on 06.12.2013 under the Provision of Central Excise Act, 1944, we have examined Xerox copies of such records for the period April'' 2013 to December'' 2013 for the purpose of our Audit.

5. In the opinion of the Directors, the current assets, loans and advances are approximately of the value stated, if realized in the ordinary course of business and provision for all known and determined liabilities (except wherever otherwise stated)are adequate and not in excess of the amount reasonably necessary.

6. Balances under Sundry Debtors, Sundry Creditors, Loans & Advances are subject to confirmation and reconciliation with the respective parties/ concerns. Necessary adjustment if any, thereon having an importance of revenue nature, will be made in the year of such confirmation / reconciliation.

7. Employee Benefits

As per Accounting Standard 15 "Employee Benefits", the disclosure of Employee benefits as defined in the Accounting Slandered are given below. :

a) Gratuity ( (defined benefits plans)

The Company has defined gratuity plan. Every employee who has completed five years or more of service gets a gratuity on death or resignation or retirement at 15 days salary (last drawn salary) for each completed year of service. The scheme is funded with an insurance company in the form of qualifying insurance policy.

b) Leave wages (long term employment benefit)

The leave wages are payable to all eligible employees at the rate of daily salary for each day of accumulated leave on death or on resignation or upon retirement on attaining superannuation age.

a) Primary Segment :

The Company''s operations predominantly relates to a single segment namely "Stainless Steel Tubes & Pipes" which as per Accounting Standards 17 is considered as the only reportable business segment.

b) Secondary Segment :

Secondary Segment is geographical, which is determined on the basis of location of the customer, is classified as either domestic or overseas and the same is as under :

8 As required by Accounting Standard 18 issued by Institute of Chartered Accountants of India relating to Related Party Disclosure, information is as under:

a) Related parties and nature of relationship

* Directors of the Company : * Associate Companies :

1 Shri Ashok T. Shah 1 Suraj Enterprise Pvt. Ltd.

2 Shri Gunvant T. Shah

3 Shri Kunal T. Shah

4 Shri Bipin K. Prajapati

5 Shri Ketan R. Shah

6 Shri Dipak H. Shah

7 Shri Haren R.Desai

8 Shri Bhupendrasinh B Patel

9. The Company has initiated the process of identifying the suppliers who qualify under the definition of micro and small enterprises, as defined under the Micro, Small and Medium Enterprises Development Act, 2006. Since no intimation has been received from the suppliers regarding their status under the said Act as at 31st March 2014, disclosures relating to amounts unpaid as at the year end, if any, have not been furnished. In the opinion of the management, the impact of interest, if any, that may be payable in accordance with the provisions of the Act is not expected to be material.


Mar 31, 2013

1. Contingent liabilities not provided for :

Demand of Rs. 2,24,379/- raised by Sales Tax authorities, for the accounting year 2003-04 and Demand of Rs. 1,40,975/- for the accounting year 2004-05 which is disputed by the Company.

Demand of Rs. 6,81,310/- after giving appeal effect raised by Income Tax authorities, for Assessment year 2008-09 which is disputed by the Company.

Demand of Rs. 2,29,491/- raised by Income Tax authorities, for Assessment year 2009-10 which is disputed by the Company.

Demand of Rs. 4,68,300/- raised by Income Tax authorities, for Assessment year 2010-11 which is disputed by the Company.

2. Estimated amount of contracts remaining to be executed on capital account and not provided for in the Accounts (net of advances) NIL

3. In terms of accounting policy (E) for the accounting of export incentives, estimated benefit of Rs 228.35 Lacs have been taken in to account under DES Scheme. Steps are being taken to import raw materials and utilize the same.

4. In the opinion of the Directors, the current assets, loans and advances are approximately of the value stated, if realized in the ordinary course of business and provision for all known and determined liabilities (except wherever otherwise stated)are adequate and not in excess of the amount reasonably necessary.

5. Balances under Sundry Debtors, Sundry Creditors, Loans & Advances are subject to confirmation and reconciliation with the respective parties/ concerns. Necessary adjustment if any, thereon having an importance of revenue nature, will be made in the year of such confirmation / reconciliation.

6. Employee Benefits

As per Accounting Standard 15 "Employee Benefits", the disclosure of Employee benefits as defined in the Accounting Standard are given below :

a) Gratuity ( (defined benefits plans)

The Company has defined gratuity plan. Every employee who has completed five years or more of service gets a gratuity on death or resignation or retirement at 15 days salary (last drawn salary) for each completed year of service. The scheme is funded with an insurance company in the form of qualifying insurance policy.

b) Leave wages (long term employment benefit)

The leave wages are payable to all eligible employees at the rate of daily salary for each day of accumulated leave on death or on resignation or upon retirement on attaining superannuation age.

7 As required by Accounting Standard 18 issued by Institute of Chartered Accountants of India relating to Related Party Disclosure, information is as under:

a) Related parties and nature of relationship

* Directors of the Company : * Associate Companies :

1 Shri Ashok Shah 1 Suraj Enterprise Pvt. Ltd.

2 Shri Gunvant Shah 2 TBS Metal Pvt. Ltd.

3 Shri Kunal Shah 3 Spice Metal Ltd.

4 Shri Bipin Prajapati

5 Shri Ketan Shah

6 Shri Dipak Shah

7 Shri Haren Desai

8 Shri Bhupendrasinh Patel

8. The Company has initiated the process of identifying the suppliers who qualify under the definition of micro and small enterprises, as defined under the Micro, Small and Medium Enterprises Development Act, 2006. Since no intimation has been received from the suppliers regarding their status under the said Act as at 31st March 2013, disclosures relating to amounts unpaid as at the year end, if any, have not been furnished. In the opinion of the management, the impact of interest, if any, that may be payable in accordance with the provisions of the Act is not expected to be material.

9. Previous year figures have been regrouped and/or rearranged whenever necessary.


Mar 31, 2012

1. Contingent liabilities not provided for

Demand of Rs. 2,24,379/- raised by Sales Tax authorities, for the accounting year 2003-04 which is disputed by the Company.

Demand of Rs. 1,40,975/- raised by Sales Tax authorities, for the accounting year 2004-05 which is disputed by the Company.

Demand of Rs. 68,35,283/- raised by Income Tax authorities, for Assessment year 2007-08 which is disputed by the Company.

Demand of Rs. 14,99,230/- after giving appeal effect raised by Income Tax authorities, for Assessment year 2008-09 which is disputed by the Company.

Demand of Rs. 2,29,491/- raised by Income Tax authorities, for Assessment year 2009-10 which is disputed by the Company.

Demand of Rs. 89,96,224/- raised by Income Tax authorities, for Assessment year 2009-10 which is disputed by the Company.

2. Estimated amount of contracts remaining to be executed on capital account and not provided for in the Accounts (net of advances) NIL

3. In terms of accounting policy (E) for the accounting of export incentives, estimated benefit of Rs. 295.36 Lacs have been taken in to account under DES Scheme. Steps are being taken to import raw materials and utilize the same.

4. In the opinion of the Directors, the current assets, loans and advances are approximately of the value stated, if realized in the ordinary course of business and provision for all known and determined liabilities (except wherever otherwise stated)are adequate and not in excess of the amount reasonably necessary.

5. Balances under Sundry Debtors, Sundry Creditors, Loans & Advances are subject to confirmation and reconciliation with the respective parties/ concerns. Necessary adjustment if any, thereon having an importance of revenue nature, will be made in the year of such confirmation / reconciliation.

6. Employee Benefits

As per Accounting Standard 15 "Employee Benefits", the disclosure of Employee benefits as defined in the Accounting Slandered are given below. :

a) Gratuity ( (defined benefits plans)

The Company has defined gratuity plan. Every employee who has completed five years or more of service gets a gratuity on death or resignation or retirement at 15 days salary (last drawn salary) for each completed year of service. The scheme is funded with an insurance company in the form of qualifying insurance policy.

b) Leave wages (long term employment benefit)

The leave wages are payable to all eligible employees at the rate of daily salary for each day of accumulated leave on death or on resignation or upon retirement on attaining superannuation age.

7. Segment Reporting

a) Primary Segment

The Company's operations predominantly relates to a single segment namely "Stainless Steel Tubes & Pipes" which as per Accounting Standards 17 is considered the only reportable business segment.

8. During the year Company has paid Managerial Remuneration to Managing Director and Whole-time Directors aggregating to Rs. 120.00 lacs which is in excess of the limit prescribed u/s. 198 and 309 of the Companies Act read with Schedule - XIII of the Companies Act, 1956 due to inadequacy of Profit. The company has initiated steps to obtain the approval of Shareholders in ensuing Annual General Meeting.

9. The Company has initiated the process of identifying the suppliers who qualify under the definition of micro and small enterprises, as defined under the Micro, Small and Medium Enterprises Development Act, 2006. Since no intimation has been received from the suppliers regarding their status under the said Act as at 31st March 2012, disclosures relating to amounts unpaid as at the year end, if any, have not been furnished. In the opinion of the management, the impact of interest, if any, that may be payable in accordance with the provisions of the Act is not expected to be material.

10. Previous year comparatives

Till the year ended 31st March, 2011, the Company was using pre-revised Schedule VI to the Companies Act, 1956, for preparation and presentation of its financial statements. During the year ended 31st March, 2012, the revised Schedule VI notified under the Companies Act, 1956, has become applicable to the Company. The Company has reclassified previous year figures to conform to this year's classification.

Signature to Notes 1 to 26

1. The Company has only one class of equity shares having a par value of Rs. 10 per share, each shareholder is eligible for one vote per share. The dividend proposed by the Board of Directors is subject to the approval of shareholders, except in case of interim dividend in the event of liquidation, the equity shareholders are eligible to receive the remaining assets of the Company, after distribution of all preferential amounts, in proportion of their shareholding.

2. Company has not bought back any equity shares during the priod of five years immediately preceeding the Balance sheet date.However the Company has alloted 1,13,39,400 equity shares as bonus shares during F.Y .2007-2008 and also alloted 22,55,000 equity shares for consideration other than cash pursant to the scheme of amalgmation during F.Y. 2009-2010

Corporate Loan from Punjab National Bank of Rs. 15 Crore and other Term Loan aggregating to Rs. 48.5 Crores are secured by equitable mortgage on Immovable Properties of the company situated at Survey No. 771, 772, 773, 774, 779, 767, 779/A at village -Thol , Taluka Kadi Dist. Mehsana, & land of Wind mill at survey no. 367/2 Village -Vanku Taluka Abdasa, District Kutch Gujarat and Property of the company situated at "Suraj House", Vidhyanagar Soc, Usmanpura, Ahmedabad on first charge basis and personal guarantees of Directors of the Company viz. Ashok T. Shah, Kunal T. Shah & Gunvant T. Shah and corporate guarantee of M/s. Suraj Impex Pvt. Ltd.

Term Loan of Rs. 8 Crore is repayable in 20 equal Quarterly installment of Rs. 4000000/- starting from July 2007 and last installment due on July 2012. Term Loan of Rs. 3 Crore is repayable in 20 equal Quarterly installment of Rs. 1500000/- starting from Nov 2007 and last installment due on Nov. 2012. Term Loan of Rs. 37.50 Crore is repayable in 22 equal Quarterly installment of Rs. 17050000/- starting from June 2010 and last installment due on Sep. 2015 and Corporate Loan of Rs. 15 Crore is repayable in 17 equal Quarterly installment of Rs. 8823530/- starting from June 2011 and last installment due on Sep. 2015.


Mar 31, 2011

1. Contingent liabilities not provided for :

Demand of Rs. 2,24,379/- raised by Sales Tax authorities, for the accounting year 2003-04 which is disputed by the Company.

Demand of Rs. 1,40,975/- raised by Sales Tax authorities, for the accounting year 2004-05 which is disputed by the Company.

Penalty Demand of Rs. 2,06,340/- raised by Income Tax authorities, for Assessment year 2001-02 which is disputed by the Company.

Demand of Rs. 92,796/- raised by Income Tax authorities, for Assessment year 2007-08 which is disputed by the Company.

Demand of Rs. 16,35,840/- raised by Income Tax authorities, for Assessment year 2008-09 which is disputed by the Company.

Demand of Rs. 30,09,730/- raised by Income Tax authorities, for Assessment year 2008-09 which is disputed by the Company.

2. Estimated amount of contracts remaining to be executed on capital account and not provided for in the Accounts (net of advances) NIL

3. In terms of accounting policy (J) for the accounting of export incentives, estimated benefit of Rs. 163.04 Lacs have been taken in to account under DES Scheme. Steps are being taken to import raw materials and utilize the same.

4. Securities :

a) Term Loan of Rs. 6200 Lacs availed from Punjab National Bank is secured by way of first charge over company's block of assets including all the immovable properties, both present and future situated at Survey No. 771,772,773,774,777 & 779/A, at Village Thol, Tal. Kadi, Dist. Mehsana and also on land situated at Survey No. 767/2 at Village Vanku Moti Sondholli Dist. Kutch and first charge over Suraj House situated at Usmanpura Ahmedabad and personal guarantees of Directors of the Company viz. Ashokbhai T Shah, Kunalbhai T Shah & Gunvantbhai T Shah and corporate guarantee of M/s. Suraj Impex Pvt. Ltd.

b) The working capital Limits of Rs. 73.50 Lacs from Punjab National Bank and 19.50 Lacs from State Bank of India are secured against Hypothecation of Raw Materials, Stock in process, Finished and Semi- finished Goods, Stores and spares, Book Debts, Other Current Assets of the company and personal guarantees of Directors of the Company viz. Ashokbhai T Shah, Kunalbhai T Shah & Gunvantbhai T Shah and corporate guarantee of M/s. Suraj Impex Pvt. Ltd. It is further secured by Second charge on all fixed assets of the company located at the factory premises at Survey No. 779/A, Thol, Taluka: Kadi Dist. Mehsana and assets of windmill at village-Vanku, Dist-Kutch.

5. Particulars of Managerial Remuneration :

As fixed monthly remuneration has been paid to the Directors' as per Schedule XIII of the Companies Act, 1956, the company has not computed net profit for the purpose of Managerial remuneration under section 349 of the Companies Act, 1956.

Managerial Remuneration paid to Managing Director and Whole Time Directors is Rs. 1,20,00,000 /- (previous year Rs. 1,17,00,000/-) included in salaries & wages.

6. In the opinion of the Directors, the current assets, loans and advances are approximately of the value stated, if realized in the ordinary course of business and provision for all known and determined liabilities (except wherever otherwise stated)are adequate and not in excess of the amount reasonably necessary.

7. Balances under Sundry Debtors, Sundry Creditors, Loans & Advances are subject to confirmation and reconciliation with the respective parties/ concerns. Necessary adjustment if any, thereon having an importance of revenue nature, will be made in the year of such confirmation / reconciliation.

8. Employee Benefits :

As per Accounting Standard 15 "Employee Benefits", the disclosure of Employee benefits as defined in the Accounting Slandered are given below. :

a) Gratuity (defined benefit plans)

The Company has defined gratuity plan. Every employee who has completed five years or more of service gets a gratuity on death or resignation or retirement at 15 days salary (last drawn salary) for each completed year of service. The scheme is funded with an insurance company in the form of qualifying insurance policy.

b) Leave wages (long term employment benefit)

The leave wages are payable to all eligible employees a the rate of daily salary for each day of accumulated leave on death or on resignation or upon retirement on attaining superannuation age.

9. Segment Reporting :

a) Primary Segment :

The Company's operations predominantly relates to a single segment namely "Stainless Steel Tubes & Pipes" which as per Accounting Standards 17 is considered the only reportable business segment.

10. As required by Accounting Standard 18 issued by Institute of Chartered Accountants of ndia relating to Related Party Disclosure, information is as under:

a) Related parties and nature of relationship

* Directors of the Company : * Associate Companies :

1 Shri Ashok T. Shah 1 Suraj Impex Pvt. Ltd.

2 Shri Gunvant T. Shah 2 Suraj Enterprise Pvt.Ltd.

3 Shri Kunal T. Shah 3 Suraj Retail Pvt. Ltd.

4 Shri Bipin K. Prajapati 4 Suraj Star Trading Pvt.Ltd.

5 Shri Ketan R. Shah 5 Suraj Commodities Pvt.Ltd.

6 Shri Dipak H. Shah 6 TBS Metal Ltd.

7 Shri Haren R.Desai

(b) Transactions that have taken place during the period April 1, 2010 to March 31, 2011 with related parties by the company.

11. Additional Information pursuant to the paragraphs 3, 4C and 4D of Part- II of Schedule VI of the Companies Act, 1956.

As certified by the management and relied upon by the auditors.

12. The Company has not received any information from 'Suppliers' regarding their status under the Micro, Small and Medium Enterprise Development Act, 2006 and hence disclosure requirements in this regard as per Schedule VI of the Companies Act, 1956 could not be provided.

13. Schedule 1 to 18 will form part of the Balance Sheet as at 31st March, 2011

14. Previous year's figures have been regrouped/reclassified and/or rearranged wherever considered necessary.

15. Particulars as required in part IV to schedule VI is annexed herewith.


Mar 31, 2010

1. Amalgamation Scheme :

The Scheme of Amalgamation of Suraj Limited with the Company as approved by the Honble High Court of Judicature at Ahmedabad has become effective on 25th August, 2010 upon obtaining all sanctions and approvals as required under the scheme and upon filing of certified true copies of the order with the Registrar of Companies, Gujarat. The appointed date of the Scheme is 1st April, 2009.

In terms of the Scheme,

i) The assets and liabilities, rights and obligation of erstwhile Suraj Limited have been vested with the Company w.e.f. April 1, 2009. The Scheme has, accordingly, been given effect to in these accounts. The amalgamation has been accounted for under the "Pooling of Interest Method" as prescribed under Accounting Standard - 14 issued by the Institute of Chartered Accountants of India as per Scheme of Amalgamation.

Accordingly, the assets and liabilities of the erstwhile Suraj Limited as at April 1, 2009 have been taken over at book value.

ii) The Authorised Share Capital of the Suraj Limited has been transferred to and merged with the Authorised Share Capital of the Company, without payment of any additional fee or stamp duty. Accordingly, Authorised Share Capital of the Company of Rs. 20,00,00,000(divided into 2,00,00,000 Equity Share of Rs. 10/- each) will be enhanced by an aggregate amount of Rs. 3,25,00,000 (divided into 32,50,000 Equity Shares of Rs. 10/- each.) making Authorised Share Capital at Rs. 23,25,00,000 (divided into 2,32,50,000 of Rs. 10/- each).

(iii) 22,50,000 equity shares of Rs. 10/- each fully paid are to be issued to the shareholders of Suraj Limited in the ration of 1 equity shares of the Company for every 1 share held in erstwhile Suraj Limited. Pending allotment as at 31st March, 2010, the amount has been included in Equity Share Suspense Account.

(iv) Current year result includes figures of the erstwhile Suraj Limited for the period 01.04.2009 to 31.03.2010, & therefore the current years figures are not comparable to those of previous year.

2. Contingent liabilities not provided for :

Demand of Rs. 2,24,379/- raised by Sales Tax authorities, for the accounting year 2003-04 which is disputed by the Company.

Demand of Rs. 1,40,975/- raised by Sales Tax authorities, for the accounting year 2004-05 which is disputed by the Company.

Penalty Demand of Rs. 2,06,340/- raised by Income Tax authorities, for Assessment year 2001-02 which is disputed by the Company.

Penalty Demand of Rs. 4,48,360/- raised by Income Tax authorities, for Assessment year 2004-05 which is disputed by the Company.

Demand of Rs. 10,48,579/- raised by Income Tax authorities, for Assessment year 2004-05 which is disputed by the Company.

Demand of Rs. 23,39,160/- raised by Income Tax authorities, for Assessment year 2007-08 which is disputed by the Company.

Demand of Rs. 21,53,467/- raised by Income Tax authorities, for Assessment year 2007-08 in respect of Transferee company which is disputed by the Company.

Demand of Rs. 9,85,448/- in respect of Service Tax for wrong availment of Service Tax credit on construction service and Rs.1,44,381/- for wrong availment and utilization of cenvat credit of capital goods.

3. Estimated amount of contracts remaining to be executed on capital account and not provided for in the Accounts (net of advances) NIL. (Previous year Rs. 298.48 Lacs)

4. In terms of accounting policy (J) for the accounting of export incentives, estimated benefit of Rs. 148.56 Lacs have been taken in to account under DES Schemes.Steps are being taken to import raw materials and utilize the same.

5. Securities :

a) Term Loan of Rs. 6200.00 Lacs availed from Punjab National Bank is secured by way of first charge over companys block of assets including all the immovable properties, both present and future situated at Survey No. 771,772,773,774,777 & 779/A, at Village Thol, Tal. Kadi, Dist. Mehsana and also on land situated at Survey No. 767/2 at Village Vanku Moti Sondholli Dist. Kutch and personal guarantees of promoter Directors of the Company viz. Ashokbhai T. Shah, Kunalbhai T. Shah & Gunvantbhai T. Shah and corporate guarantee of M/s. Suraj Impex Pvt. Ltd. Further the said Loan will be collaterally secured by way of second pari-passu charge on current assets of the company with SBI.

b) The working capital Limits from Punjab National Bank and State Bank of India are secured against Hypothecation of Raw Materials, Finished and Semi-finished Goods, Stores and spares, Book Debts of the company and personal guarantees of promoter Directors of the Company viz. Ashokbhai T. Shah, Kunalbhai T. Shah & Gunvantbhai T. Shah and corporate guarantee of M/s. Suraj Impex Pvt. Ltd. It is further secured by Second charge on block of Assets of the Company both movable and immovable except Office Building.

c) Term Loan of Rs. 2.00 Crore from AXIS Bank Ltd. is secured by way of first charge over companys office building & furniture fixture & equipment therein, both present and future situated at Suraj House Opp. Usmanpura Garden, Usmanpura, Ahmedabad - 14.

d) Other Loan is secured by hypothecation of cars and other vehicles..

6. Particulars of Managerial Remuneration :

As fixed monthly remuneration has been paid to the Directors as per Schedule XIII of the Companies Act, 1956, the company has not computed net profit for the purpose of Managerial remuneration under section 349 of the Companies Act, 1956.

Managerial Remuneration paid to Managing Director and Whole Time Directors is t 1,17,14,000 /- (previous year Rs. 1,17,14,000/-) included in salaries & wages.

7. In the opinion of the Directors, the current assets, loans and advances are approximately of the value stated, if realized in the ordinary course of business and provision for all known and determined liabilities (except wherever otherwise stated)are adequate and not in excess of the amount reasonably necessary.

8. Balances under Sundry Debtors, Sundry Creditors, Loans & Advances are subject to confirmation and reconciliation with the respective parties/ concerns. Necessary adjustment if any, thereon having an importance of revenue nature, will be made in the year of such confirmation / reconciliation.

9. Employee Benefits :

As per Accounting standered 15 "Employee Benefits", the disclosure of Employee benefits as defined in the Accounting Standered are given below :

a) Gratuity (defined benefit plans)

The Company has defined gratuity plan. Every employee who has completed five years or more of service gets a gratuity on death or resignation or retirement at 15 days salary (last drawn salary) for each completed year of service. The scheme is funded with an insurance company in the form of qualifying insurance policy.

10. Segment Reporting :

a) Primary Segment :

The Companys operations predominantly relates to a single segment namely "Stainless Steel Tubes & Pipes" which as per Accounting Standards 17 is considered the only reportable business segment.

11. As required by Accounting Standard 18 issued by Institute of Chartered Accountants of ndia relating to Related Party Disclosure, information is as under:

a) Related parties and nature of relationship

* Directors of the Company : * Associate Companies :

1 Shri Ashok T. Shah 1 Suraj Impex Pvt. Ltd.

2 Shri Gunvant T. Shah 2 Suraj Enterprise Limited

3 Shri Kunal T. Shah 3 Suraj Retail Pvt. Ltd.

4 Shri Bipin K. Prajapati 4 Suraj Star Trading Pvt. Ltd.

5 Shri Ketan R. Shah 5 Suraj Commodities Pvt. Ltd.

6 Shri Dipak H. Shah 6 TBS Metal Ltd.

7 Shri Haren R.Desai

(b) Transactions that have taken place during the period April 1, 2009 to March 31, 2010 with related parties by the company.

12. The Company has not received any information from Suppliers regarding their status under the Micro, Small and Medium Enterprise Development Act, 2006 and hence disclosure requirements in this regard as per Schedule VI of the Companies Act, 1956 could not be provided.

13. Schedule 1 to 19 will form part of the Balance Sheet as at 31st March, 2010

14. Previous years figures have been regrouped/reclassified and/or rearranged wherever considered necessary.

15. Particulars as required in part IV to schedule VI is annexed herewith.

 
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