Auditor Report of Astron Paper & Board Mill Ltd.

Mar 31, 2025

ASTRON PAPER & BOARD MILL LIMITED

REPORT ON THE STANDALONE FINANCIALSTATEMENTS:

DISCLAIMER OF OPINION:

We were engaged to audit the accompanying standalone financial statements of ASTRON PAPER & BOARD MILL LIMITED (“the Company”), which comprise the standalone balance sheet as at March 31, 2025, the standalone statement of profit and loss including other comprehensive income, standalone statement of changes in equity and standalone statement of cash flows for the year then ended, and notes to the standalone financial statements, including a summary of the material accounting policies and other explanatory information (hereinafter referred to as “Standalone Financial Statements”).

We do not express an opinion on the accompanying standalone financial statements of the Company. Because of the significance and materiality of the matters described in the Basis for Disclaimer of Opinion section of our report, we have not been able to obtain sufficient appropriate audit evidence to provide a basis for an audit opinion on these standalone financial statements and accordingly we do not express an opinion on the accompanying standalone financial statements of the Company.

BASIS FOR DISCLAIMER OF OPINION:

i. The company has availed working capital and other loans from various banks for an amount exceeding Rs. 5.00 crores against the security of its assets including current assets. As a part of terms of sanction with various banks, the company is required to submit various monthly, quarterly and periodical statements including stock statements and statement of various assets charged for availing loans including working capital loans.

In spite of our specific request to the management of the company, the company has not made available to us such periodical statements if any as submitted to the banks for our verification. In absence of availability of such statements, we have not been able to verify the details and reported amounts as submitted to the banks in quarterly and periodical statements and those accounted in the books of account and variance if any between quarterly and periodical statements and books of accounts, accuracy and truthfulness of reported particulars including that reported amounts as submitted to the bank and defaults with regard to the loans availed by the company with regard to submission of such returns and statements and availability of drawing power or limits against such loans.

As all of the bank loans accounts have been declared as NPA, there was no drawing power available against the outstanding bank loan accounts as at March 31, 2025.

We draw attention to Note No. 17, 19 & 20 to the Standalone Financial Statements regarding reported amounts of defaults by the company with regard to non-current and current borrowings and interest on such borrowings from various banks. The company has reported defaults of Rs. 7,879.73 Lakhs including interest as at March 31, 2025 towards bank loans. However, in absence sufficient appropriate audit evidence with regard to defaults committed by the company towards loans from various bank, we are unable to verify the details of defaults committed by the company towards such loans and their consequential impact on reported amounts in the standalone financial statements and appropriate disclosure of such defaults, security offered, repayment terms, availability of security, initiation of legal actions by banks against the company including that for fraud if any and other terms and conditions relating to loan accounts.

ii. The company has shut down its plant at Halved since 8th of September, 2024 and has not resumed the production since the closure upto the date of this report. The other plant of the company at Bhuj has also been non-operational. The shut-down of plants and non- resumption of production, substantial cash losses incurred in the last three financial years as well as during the current financial year, nonutilization of production capacity, substantial reduction in sales turnover over the period and other financial factors including availability of liquid sources of funds have affected net worth of company significantly and these factors along with substantial tax demands against which litigations are pending and all of the bank loan accounts becoming NPA and company being declared as defaulter by banks have affected the overall business operations of the company and its ability to resume business activities and to continue the business in the normal course of business as going concern. However, the management of the company has prepared and presented the standalone financial statements assuming its status as going concern. In our opinion, the going concern status of the company has been substantially and materially adversely affected and, in our opinion, the accompanying standalone financial statements for the year ended March 31, 2025 should have been prepared and presented considering the status of the company as not being going concern.

However, in absence sufficient appropriate audit evidence regarding grounds on the basis of which the management of the company has prepared and presented standalone financial statements as going concern, we disclaim our opinion as to the going concern status of the company as at March 31, 2025.

iii. No Provision has been made by the company for outstanding export trader receivables of Rs. 1.60 crores and domestic trade receivables of Rs. 1.09 crores which have been outstanding since long. The company continues to recognize and classify

these trade receivables as good for recovery. Had the company made provision for doubtful debts, the losses for the year would have been higher by Rs. 2.69 crores and consequent net-worth lower by Rs. 2.69 crores.

The management of the company has not provided to us for our verification the sufficient appropriate audit evidences on the basis of which it has been assumed that the above trade receivables have been good for recovery at the values at which they have been stated in the standalone financial statements.

iv. The company has not made any provision of for Expected Credit Losses on trade receivables and other financial instruments for the financial year ended 31st March, 2025 other than as reported in para (iv) above as required to be made as per Ind-AS-109 ‘Financial Instruments”.

v. We refer to Note No. 7 of the Standalone Financial Statement regarding “Non-Current Financial Assets: Loans & Advances in respect of loans given to wholly owned subsidiary company.

The company has given loans to its wholly owned subsidiary company Balaram Papers Private Limited amounting to Rs. 28.66 Crores. The company has not charged any interest on loans and advances of Rs. 28.66 Crores for the financial year ended March 31, 2025. The subsidiary company has been incurring losses over the years and its net-worth is substantially negative. The subsidiary company has also outstanding liabilities to be discharged towards bank loans and also to trade payables and other liabilities. The plant of the subsidiary company is also non-operational and the subsidiary company has not carried out any substantial business activities for the year ended March 31, 2025. Further, the company vide extraordinary general meeting of its members held on 7th February, 2025 resolved to dispose of the whole of the undertaking of the wholly owned subsidiary company. These factors along with possibility of non-resumption of business activities by the subsidiary in near foreseeable future indicate that the company may not be able to recover the entire amounts of balances of loans as outstanding from the wholly owned subsidiary company and accordingly such loans should have been stated at fair value of amounts realizable if any. However, company has neither accounted any interest for the current financial year nor stated such loans at fair value of realization and continued to carry such investment without providing for any interest as receivable for the current financial year. Had the company recognized such loans as impaired as per Ind-AS 109 “Financial Instruments”, the fair value of such loans would have been much lower than at which they have been carried in the standalone financial statements and consequent net-worth of the company would have been lower.

vi. The company has made investments in 40,35,000 Equity Share of Rs. 10.00 each amounting to Rs. 4.04 Crores in the wholly owned subsidiary company Balaram Papers Private Limited. The company has at the Extra Ordinary General Meeting of its members held on 7th February, 2025 resolved to dispose of the undertaking of wholly owned subsidiary. Because of the factors stated in para (v) above, these investments should have been impaired. However, no provision has been made for Impairment

on such investments and the company has continued to carry such investment at the cost of its acquisition. Had the company made provision for impairment losses on such investment the realizable value of such investment would have been much lower than at which they have been carried in the standalone financial statements or would not have any realizable value at all and consequent net-worth of the company would have been lower to that extent.

vii. Inventories of Imported Raw Materials in respect of which Bill of Entries have been filed but have not been lifted from port have not been accounted in the books of account. As informed to us by the management of the company, the company had received notices for auction against such inventories. As informed to us by the management of the company, some of the goods lying at port have been disposed of through auction. However, no details of goods sold through auction have been made available to us for our verification. The goods sold through auction have not been recognized in the books of account either as sale or inventories. The custom duty paid in respect of goods lying at port or disposed of through the process of auction has been classified as recoverable amount from the custom authorities in the books of account. The payments made to import suppliers have been recognized as amounts recoverable from the respective party in the standalone financial statements. The company has further not accounted corresponding liabilities towards suppliers if any in the books of account. Had the company accounted for above transactions the reportable amounts of revenue, assets, liabilities and losses for the year would have been different from what has been stated in the standalone financial statements.

We refer to Note No. 34(IV) to the standalone financial statements wherein the company has reported amounts of Rs. 5.78 Crores as Advances Paid for Imported Raw Materials.

In absence of sufficient appropriate audit evidence with regard to position of goods lying at port and disposed of through auction if any, we disclaim our opinion as regard to inventories, revenues, assets and liabilities in this regard.

viii. The company has not made any provision towards gratuity liabilities as per Ind AS-19 “Employee Benefits” for the financial year ended 31st March, 2025.

ix. The outstanding balances of trade receivables and trade payables as at March 31, 2025 as reported in the standalone financial statements have not been contra confirmed by the respective parties and hence the same are subject to confirmations and subsequent reconciliations and subject to claim and legal proceedings for recovery, damages, charges if any of respective parties against the company.

x. As informed to us by the management of the company, due to shut down of the plants, the quality of waste papers, chemical items, packing materials, coal and finished goods has deteriorated and hence they have been written down below their cost as per the estimates made by the management of the company regarding recoverable value of such inventories. The company has written down inventories of Rs. 9.74 crores during financial year ended March 31, 2025. The reported

amounts of losses for the financial year ended 31st March, 2025 includes the effect of such write down under respective head of raw materials consumed, fuel consumed, packing materials consumed and variation in stock of Finished Goods. The inventories of stores and work-in-process have not been revalued. The inventories as at March 31, 2025 have been carried at such revalued amount or cost as the case may be. In our opinion, the quality of inventories may have further substantially deteriorated and hence consequent net realizable value of such inventories may also have been lower than the value at which they have been carried in the standalone financial statements as at March 31, 2025. Such treatment is contrary to the valuation principles laid down in Ind-AS 2 “Inventories”. Had the company applied recognition and measurement principles as laid down in the Ind-AS 2, the carrying amounts of inventories may have been different from at which they have been carried in the standalone financial statements. The management of the company has not provided to us physical verification report of inventories held by the company as at March 31, 2025 and hence the carrying amounts as reported in the standalone financial statements as at March 31, 2025 are subject to physical verification and subsequent reconciliations and application of valuation principles as laid out in Ind-AS 2.

In absence of availability of sufficient appropriate audit evidence, physical verification report, details of valuation of inventories and the verification and valuation of such inventory being technical matter, we disclaim our opinion as to the amounts of inventory as reported in the standalone financial statements.

xi. The company has carried items of PPE at cost less accumulated depreciation upto March 31, 2025. However, due to the plants being non-operational for a substantial period of time during the financial year and other factors affecting the recoverable amounts of items of PPE, the recoverable value of some of the items or class of items within PPE may have suffered impairment. The company has not applied impairment test in respect of tangible PPE for the financial year ended March 31, 2025 as required to be made as per Ind-AS 36 “Impairment of Assets”. The management of the company has not provided to us physical verification report of PPE held by the company as at March 31, 2025 and hence the carrying amounts as reported in financial statements as at March 31, 2025 are subject to physical verification and subsequent reconciliations and application of accounting principles of impairment as laid out in Ind-AS 36.

In absence of availability of sufficient appropriate audit evidence, physical verification report and the verification and valuation of each item of PPE being technical matter, we disclaim our opinion as to the carrying value of PPE as reported in the standalone financial statements.

xii. We draw attention to “Statement of Changes in Equity” to the standalone financial statements relating to Equity. The net-worth of the company eroded substantially due to continuous losses in the last few years. As at March 31, 2025 the current liabilities of the company are far in excess of its current assets. The company has been declared as defaulters by banks in

respect of loans granted by them to the company as the company has failed to discharge its liabilities towards bank loans. These factors along with other factors referred to in basis of disclaimer of opinion para herein above, cast significant doubt on the company’s ability to continue as going concern and discharge its liabilities towards bank creditors, other creditors and statutory liabilities.

However, the standalone financial statements have been prepared and presented by the management of the company assuming company being a going concern.

xiii. In spite of our specific request to the management of the company, the company has not made available to us details and status of pending litigations against the company and its possible impact on the financial statements including litigations relating to commitment of fraud by the company if any.

As a result of the matters stated in para (i) to (xiii) above and other factors affecting procedures to be applied by us to verify the reported amounts and disclosures in the standalone financial statements, we have not been able to obtain sufficient appropriate audit evidence to provide the basis of our opinion on the standalone financial statements and reported amounts and disclosures in the standalone financial statements including that reported in notes to the financial statements.

MATERIAL UNCERTAINTY RELATED TO GOING CONCERN:

We draw attention to Basis of Disclaimer of Opinion section of our audit report as reported herein above. Due to the materiality of the factors stated Basis of Disclaimer of Opinion, financial position of the company, defaults with regard to bank and other creditors, substantial erosion of the net-worth of the company, continuous substantial losses in the business, the liabilities being far in excess of the available assets, possible effect of impairment of assets and realizable value of financial instruments and assets, closure of business operations, substantial tax demands being in excess of net-worth of the company and pending substantial legal matters, all financial parameters being negative and adverse and other factors affecting the possibility of discharge of liabilities from available sources of funds, the going concern status of the company has been substantially and materially adversely affected which indicates that a material uncertainty exists that may cast significant doubt on the company’s ability to continue as going concern and in our opinion, the accompanying standalone financial statements for the year ended March 31, 2025 should have been prepared and presented considering the status of the company as not being going concern.

However, for the reasons more as described in Note No. 35(s) to the standalone financial statements, the management of the company has prepared and presented the accompanying standalone financial statements assuming the status of the company as a Going Concern.

RESPONSIBILITY OF MANAGEMENT AND THOSE CHARGED WITH GOVERNANCE FOR THE STANDALONE FINANCIAL STATEMENTS:

The Company’s Management and Board of Directors are responsible for the matters stated in section 134(5) of the Companies Act, 2013 (“the Act”) with respect to the preparation of these standalone financial statements that give a true and fair view of the financial

position, financial performance including other comprehensive income, cash flows and changes in equity of the Company in accordance with the Indian Accounting Standards (Ind AS), accounting principles generally accepted in India, including the Indian Accounting Standards specified under Section 133 of the Act, read with the Companies (Indian Accounting Standard) Rules, 2015 as amended.

This responsibility also includes the maintenance of adequate accounting records in accordance with the provision of the Act for safeguarding of the assets of the Company and for preventing and detecting the 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 control, 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.

In preparing the standalone financial statements, management and Board of Directors are 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 is also responsible for overseeing the Company’s financial reporting process.

AUDITOR’S RESPONSIBILITIES FOR THE AUDIT OF THE STANDALONE FINANCIAL STATEMENTS:

Our responsibility is to conduct an audit of the standalone financial statements in accordance with the Standard on Auditing and issue an auditor’s report thereon.

However, because of the matters described in the Basis for Disclaimer of Opinion section of our report, we have not been able to obtain sufficient appropriate audit evidence to provide a basis for an audit opinion on the accompanying standalone financial statements.

We are independent of the Company in accordance with the Code of Ethics and provisions of the Act that are relevant to our audit of the standalone financial statements in India under the Act, and we have fulfilled our other ethical responsibilities in accordance with the Code of Ethics and the requirements under the Act.

OTHER MATTER:

i. According to the information and explanations given to us, the determination of the transactions with MSME vendors and balances thereof, have been done based on the either certificate received from the respective parties or confirmation in that regard from the parties. In absence of complete reconciliation in this respect, completeness of the disclosures in respect of MSME vendors, liability for interest thereon as per MSME Act and legal action for claim of recovery by the respective MSME Parties in this regard for outstanding dues, if any and on Income Tax computations thereon on payments made beyond specified date to be ascertained.

Our opinion is not modified in respect of matters stated in para (i) above.

REPORT ON OTHER LEGAL AND REGULATORY REQUIREMENTS:

1. As required by The Companies (Auditor’s Report) Order, 2020 issued by The Central Government Of India in term of section 143 (11) of The Companies Act, 2013 and except for the possible effects of the matters described in the Basis for Disclaimer of Opinion section, we enclose in the Annexure-A hereto a statement on the matters specified in paragraphs 3 and 4 of the said order, to the extent applicable to the company.

2. As required by section 143(3) of the Act, based on our audit we report that:

a) As described in the Basis for Disclaimer of Opinion section, we have sought but have not been able to obtain all the information and explanations which to the best of our knowledge and belief were necessary for the purposes of our audit.

b) Due to the effects/possible effects of the matter described in the Basis for Disclaimer of Opinion section and for the matters stated in the paragraph below on reporting under Rule 11(g), we are unable to state whether 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 Standalone Balance Sheet, Standalone the Statement of Profit and Loss including Other Comprehensive Income, the Standalone Statement of Changes in Equity & the Standalone Statement of Cash Flows dealt with by this Report are in agreement with the books of account;

d) Due to the effects/possible effects of the matter described in the Basis for Disclaimer of Opinion section, we are unable to state whether the financial statements comply with the Indian Accounting Standards specified under section 133 of the Act.

e) The matter described in the Basis for Disclaimer of Opinion section particularly going concern matter, in our opinion, may have an adverse effect on the functioning of the Company.

f) On the basis of written representations received from the directors of the Company as on March 31, 2025, and taken on record by the Board of Directors, none of the directors are disqualified as on March 31, 2025, from being appointed as a director in terms of sub-section (2) of section 164 of Act;

g) The reservation relating to maintenance of accounts and other matters connected therewith are as stated in the Basis for Disclaimer Opinion section, in the paragraph (b) above on reporting under Section 143(3)(b) and in paragraph below on reporting under Rule 11(g);

h) With respect to the adequacy of internal financial control over financial reporting of the Company with reference to standalone financial statements and the operating effectiveness of such controls, refer to our separate report in Annexure-B.

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

i. The Company had the following litigations pending as at the end of the financial year which may impact its financial position on final disposal of the respective matters.
Sr. No.	Name of The Party/Department	Brief Facts of the Case	Financial Impact
1.	Star Papers	Suit Filed under Section 138 of the Negotiable Instruments Act, 1881 For Recovery of Dues For Sales of Goods	33,58,877/-
2.	Hi Tech Multi Forms	Suit Filed under Section 138 of the Negotiable Instruments Act, 1881 For Recovery of Dues For Sales of Goods (Suit Continuing but amount written off in the books of account)	14,65,029/-
3.	Shreeji Enterprise	Suit Filed For Recovery Of Dues For Sales of Goods	16,67,194/-
4.	Videocon Industries Limited	Operational Creditor in NCLT Proceedings For Recovery Of Dues For Sales of Goods	8,00,221/-
5.	Royal Sundaram General Insurance Company-Vehicle Claim	Claim for Loss of Vehicle	5,88,750/-
6.	Commissioner of Income Tax-Appeals	Disputed Income Tax Liabilities On Account Of Income Tax Assessment Order Passed Under Section 143(3) by the Office of Central Circle 1(1), Ahmedabad for A.Y. 202122	NIL [Demand Amount Included in Order Passed Under Section 147 dated 24/03/20245]
7.	Commissioner of Income Tax-Appeals	Disputed Income Tax Liabilities On Account Of Income Tax Assessment Order Passed Under Section 143(3) by the Office of Central Circle 1(1), Ahmedabad for A.Y. 2022-23 [Addition of Rs. 38,81,09,281/- made on protective basis]	51,77,20,750/-
8.	Commissioner of Income Tax-Appeals	Disputed Income Tax Liabilities On Account Of Income Tax Assessment Order Passed Under Section 147 by the Office of Central Circle 1(1), Ahmedabad for A.Y. 2020-21	7,72,85,920/-
9.	Commissioner of Income Tax-Appeals	Disputed Income Tax Liabilities On Account Of Income Tax Assessment Order Passed Under Section 147 by the Office of Central Circle 1(1), Ahmedabad for A.Y. 2021-22	65,28,77,060/-
10.	Office of the Commissioner of Central Goods and Service Tax, Audit Commissionerate, Rajkot	RCM Liability on Ocean Freight (Company has paid Rs. 30,59,267/- under protest)	30,59,267/-
11.	District Consumer Dispute Redressal Commissioner, Mehsana	Fire Insurance Claim filed with The New India Assurance Company Limited for materials destroyed due to fire held at the premises of Balaram Papers Private Limited (wholly owned subsidiary company), located at 112/1-1, Dhanali Road, Near Deem-Roll Tech Limited, At & Post Ganeshpura, Taluka Kadi, District Mahesana. The claim and case filed by Balaram Papers Private Limited. However, the amount is recoverable by the company from the subsidiary company.	3,35,38,210/-

However, due to the effects/possible effects of the matter described in the Basis for Disclaimer of Opinion paragraph and nonavailability of sufficient appropriate audit evidence regarding pending litigations, we are unable to state whether the Company has disclosed the impact of pending litigations on its financial position in its standalone financial statements and whether such disclosures are complete, true and fair.

[Refer Note No. 31 to the standalone financial statements]

ii. Except for the effects/possible effects of the matter described in the Basis for Disclaimer of Opinion section, the Company did not have any long-term contracts including derivative contracts for which there were any material foreseeable losses.

iii. As at 31st March, 2025 there were no amounts which were required to be transferred to the Investor Education and Protection Fund by the Company.

iv. Management Representation:

a. The Management of the Company has represented to us that to the best of it’s 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(s) or entity(ies), including foreign entities (“Intermediaries”), with the understanding, whether recorded in writing or otherwise, that the Intermediary shall, directly or indirectly lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the Company (“Ultimate Beneficiaries”) or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries.

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

c. Based on audit procedures which we considered reasonable and appropriate in the circumstances, nothing has come to our notice that has caused us to believe that the representations under sub-clause (i) and

PLACE: AHMEDABAD DATED: 29TH MAY, 2025

(ii) of Rule 11(e) Companies (Audit and Auditors) Rules, 2014 (as amended) and provided in clauses (a) and (b) above contain any material mis-statement.

v. The company has not declared or paid any dividend during the year.

vi. Based on our examination, which included test checks, the Company has used accounting software for maintaining its books of account for the financial year ended March 31, 2025 which has a feature of recording audit trail (edit log) facility. However, the company has not provided to us the details of audit trail records for the entire financial year ended on March 31, 2025. In absence of audit trial records, we are unable to express our opinion whether the audit trial feature of the said software was enabled and operated throughout the year for all relevant transactions in the software or whether there were any instances of the audit trial feature being tempered with.

In absence of availability of complete audit trial records, we are unable to express our opinion as to whether the required audit trial has been preserved by the company as per the statutory requirement of record retention or not.

vii. With respect to the matter to be included in the Auditors’ Report under Section 197(16) of the Act:

In our opinion and according to the information and explanations given to us, the remuneration paid by the Company to its directors during the current year is in accordance with the provisions of Section 197 of the Act read with Schedule V to the Companies Act, 2013. The remuneration paid to any director is not in excess of the limit laid down under Section 197 of the Act read with Schedule V to the Companies Act, 2013. The Ministry of Corporate Affairs has not prescribed other details under Section 197(16) of the Act which are required to be commented upon by us.

FOR AND ON BEHALF OF SNDK & ASSOCIATES,

CHARTERED ACCOUNTANTS, FIRM REG. NO. W100060

KISHAN R. KANANI

PARTNER M. No. 192347 UDIN: 25192347BMNTLI8061

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Mar 31, 2024

We have audited the standalone financial statements of ASTRON PAPER & BOARD MILL LIMITED (“the Company”), which comprise the Standalone Balance Sheet as at March 31, 2024, the Standalone Statement of Profit and Loss (Including Other Comprehensive Income), the Standalone Statement of Changes In Equity and the Standalone Statement of Cash Flows for the year then ended and notes to the standalone financial statements, including a summary of significant accounting policies and other explanatory information

(hereinafter referred to as “Standalone Financial Statements”).

In our opinion and to the best of our information and according to the explanations given to us except for the effect for the possible effects of matters described in the Basis for Qualified Opinion & Other Matter section of our report and effect of observations, disclaimers and qualifications if any which are nonquantifiable as reported in Annexure A to this report being report on matters specified in paragraph 3 and 4 of the Companies (Auditor''s Report) Order, 2020 issued by The Central Government Of India in term of section 143 (11) of The Companies Act, 2013 ,

the aforesaid standalone financial i. statements give the information required by the Companies Act, 2013 (“Act”) in the manner so required and give a true and fair view in conformity with the accounting principles generally accepted in India including Indian Accounting Standards (''Ind AS’) specified under Section 133 of the Act read with the Companies (Indian Accounting Standards) Rules, 2015 as amended, of the state of affairs of the Company as at March 31, 2024, and its loss and other comprehensive loss, changes in equity and its cash flows for the year ended on that date.

BASIS FOR QUALIFIED OPINION:

. We draw attention to Note No. 11 of the Standalone Financial Statement regarding “Current Financial Assets: Trade Receivables” which includes export trade receivable of Rs. 1,55,58,318/- outstanding for more than three years, which the company has considered as good for recovery. In our opinion, the same should have been considered as doubtful and necessary provision for doubtful debts should have been made by the company. Nonprovision of such doubtful debts of Rs. 1,55,58,318/- has resulted into understatement of loss and overstatement of outstanding balance of current trade receivables and shareholder’s fund by Rs. 1,55,58,318/-.

We draw attention to Note No. 7 of the Standalone Financial Statement regarding “Non-Current Financial Assets: Loans & Advances in respect of loans given to wholly owned subsidiary company. The company has given long term loans and advances of Rs. 20,85,21,063/- to its wholly owned subsidiary company Balaram Papers Private Limited classified as long term loans & advances which was outstanding for more than twelve months as at the current financial year end date. This amount includes long term loans and advances of Rs. 8,65,10,628/- given in the financial year 2022-23 and balance amount of Rs. 12,20,10,435/- given prior to financial year 2022-23. The company has charged interest on loans and advances of Rs. 12,20,10,435/-. However, no interest has been charged on loans and advances of Rs. 8,65,10,628/-. Non charging of interest on loans and advances of Rs. 8,65,10,628/- has resulted into over statement of loss of Rs. 77,85,957/- and understatement of outstanding balance of long-term loans & advances and shareholder’s fund by Rs. 77,85,957/-.

We conducted our audit in accordance with the Standards on Auditing (SAs) specified under Section 143(10) of the Act. Our responsibilities under those SAs 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 ethical requirements that are relevant to our audit of the standalone financial statements under the provisions of the Act and the Rules thereunder, and we have fulfilled our

other ethical responsibilities in accordance with these requirements and the Code of Ethics. We believe that the audit evidence we have obtained is sufficient and appropriate except for availability of quarterly and periodical stock statement and other returns submitted by the company for availing and utilizing working capital limits and other limits from various banks during the year to provide a basis for our opinion.

EMPHASIS OF MATTER:

We draw attention to the following matters in the Notes to the Financial Statements:

I. Note No. 36(d)(1) relating to the disputed Income Tax Liabilities amounting to Rs. 36,15,110/- for A.Y. 2021-22.

II. Note No. 36(d)(2) relating to the disputed Income Tax Liabilities amounting to Rs. 51,77,20,750/- for A.Y. 2022-23.

III. Note No. 36(d)(3) relating to RCM Liabilities on Ocean Freight Rs. 30,59,267/-.

IV. Note No. 36(o) relating to Revenue from Operations in the form of GST Subsidy Claim amounting to Rs. 8,25,00,000/- accounted in the financial year 2021-22 and non-realization of any amount during the current financial year. [Refer to Note No. 36(o)]

V. Note No. 36(m) relating to income tax search carried out at the registered office of the company and subsequent initiation of assessment proceedings for various assessment years. [Refer to Note No. 36(m)]

Our opinion is not modified in respect of the above referred matters.

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. In addition to the matters described in the Basis for Qualified Opinion Section and Emphasis of Matters section, we have determined the matters described below to be the key audit matters to be communicated in our report.

Description of Key Audit Matters:

The Key Audit Matter How the matter was addressed in

our audit

1. Impairment Evaluation of Investment in a Subsidiary (Refer to Note No. 6 & 36(p)

The carrying amount of the investments (held at cost less impairment, if any) made in a subsidiary as at 31st March, 2024 was Rs. 4.04 Crores. The initial cost of investment was also Rs. 4.04 Crores.

We consider the valuation of these investments to be at a high risk of significant misstatement, or to be subject to a significant level of judgment since the company is wholly owned subsidiary company and representation made us by the management of the company regarding recoverable of value of the individual item of assets or Group of Cash Generating assets on overall basis being higher that the value at which they have been carried in the financial statements. However, due to their materiality in the context of total assets of the Company and since the subsidiary company has been incurring losses over the period and has not carried out any business activities during the current financial year, this is considered to be significant to our

• Comparing the carrying amounts of investments with the balance sheet of the subsidiary to identify whether their net assets were in excess of their carrying amount and assessing whether that subsidiary has historically been profit-making.

• The management representation regarding recoverable values of asset or group of assets being designated as cash generating unit.

• Considering the adequacy of disclosures in respect of the investments in the subsidiary.

overall audit strategy and planning and future possibilities of impairment if the assumptions made by the management regarding recoverable value do not materialize as estimated. As stated above, the subsidiary company however has been making losses over the year and has not carried out any operational activities during the current financial year.

2. Litigations and Claims (Refer to Note No. 32 & 36(d)
The Company operates in various States	• Gained an understanding of the
within India as well as export of goods and	process of identification	of claims,
import of raw materials which exposes the	litigations and contingent liabilities
company to a variety of different Laws and	and identified key controls in the
Regulations and implications and	process. For selected controls we
interpretations thereof. The company is	have performed tests of controls.
also exposed to provisions relating to the	• Obtained the summary of Company’s
taxes on Income on account of search	legal and tax cases and critically
operations carried out at the registered	assessed management’s	position
office of the company. In such regulatory	through discussions with	the Legal
environment, the Company is subject to	Counsel, appropriate	senior
some legal and tax related claims which	management and operational
have been disclosed for in the financial	management, on both the probability
statements based on the facts and	of success in significant cases, and the
circumstances of each case.	magnitude of any potential loss.
Taxation and litigations have been	• Assessed management’s estimate of
identified as a key audit matter due to the	the possible outcome	of the
status of legal proceedings, quantum of	litigations, the relevant disclosures
demands raised, timescales involved for	made within the financial statements
resolution and the potential financial	to address whether they
impact of these on the financial	appropriately reflect the	facts and
statements. Further, such tax litigations	circumstances of the respective tax
involve significant management judgment	and legal exposures	and the
in assessing the exposure of each case and thus a risk that such cases may not be adequately provided for or disclosed.	requirements of relevant accounting standards.

3. Claims Receivable on Imported Raw Materials:
The Company imports raw materials i.e.	• Gained an understanding of
waste paper and some of the chemicals	the process of identification
which constituted 82.18% of the total cost	of claims, identified key
of raw materials consumed for the	controls in the process and
financial year 2023-24.	past trend of amounts at
In cases of quality differences, the company files quality claims with the respective suppliers. After due verification process, the quality claims are allowed and paid by the respective	which claims were finally settled with the amount for which claims were filed. For selected controls we have performed tests of controls.
supplier depending upon the quality	• Assessed management’s
differences. The amounts of claims filed	estimate of the amount of
and actual claims received varies	overall claims receivable as at
depending upon the final quality	the end of the financial year,
assessment and its acceptance by the	the possibility of
respective suppliers and the company.	recoverability, assessed
In respect of claims filed but not accepted/approved by the suppliers as at the end of the financial year, the company accounts for such claims at the estimated	overall past trend of claims filed and amounts recovered and the requirements of relevant accounting
amount of claim likely to be realized based on the past trend and management estimate of the likely recoverability of claims. Such treatment involves significant management judgment in assessing the recoverability in each case and thus a risk that such claims may not be adequately and properly accounted for.	standards.

INFORMATION OTHER THAN THE STANDALONE FINANCIAL STATEMENTS AND AUDITORS’ REPORT THEREON

The Company’s management and Board of Directors is responsible for the other information. The other information comprises the information included in the Annual Report, but does not include the 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 in the 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.

RESPONSIBILITY OF MANAGEMENT AND THOSE CHARGED WITH GOVERNANCE FOR

THE STANDALONE FINANCIAL STATEMENTS:

The Company’s Management and Board of Directors are responsible for the matters stated in section 134(5) of the Companies Act, 2013 (“the Act”) with respect to the preparation of these standalone financial statements that give a true and fair view of the financial position, financial performance including other comprehensive income, cash flows and changes in equity of the Company in accordance with the Indian Accounting Standards (Ind AS), accounting principles generally accepted in India, including the Indian Accounting Standards specified under Section 133 of the Act, read with the Companies (Indian Accounting Standard) Rules, 2015 as amended.

This responsibility also includes the maintenance of adequate accounting records in accordance with the provision of the Act for safeguarding of the assets of the Company and for preventing and detecting the 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 control, 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.

In preparing the standalone financial statements, management and Board of Directors are 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 is also 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 control relevant to the audit in order to design audit procedures that are appropriate in the circumstances. Under Section 143(3)(i) of the Act, we are also responsible for expressing our opinion on whether the Company has adequate internal financial controls with reference to financial statements in place and the operating effectiveness of such controls.

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

• Conclude on the appropriateness of management’s use of the going concern basis of accounting and, based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Company’s ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditor’s report to the related disclosures in the standalone financial statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based on the audit evidence obtained up to the date of our auditor’s report. However, future events or conditions may cause the Company to cease to continue as a going concern.

• Evaluate the overall presentation, structure and content of the standalone financial statements, including the disclosures, and whether the standalone financial statements represent the underlying transactions and events in a manner that achieves fair presentation.

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

OTHER MATTER:

i. The company has availed working capital and other loans from various banks for an amount exceeding Rs. 5.00 crores. As a part of terms of

sanction with various banks, the company is required to submit various ''monthly, quarterly and periodical statements including stock statements and statement of various assets charged for availing loans including working capital loans. The company has not made available to us such periodical statements as submitted to the bank and financial institutions for our verification. In absence of availability of such statements, we are unable to express our opinion as to whether the amounts reported in the statements submitted to the banks materially vary with those accounted in the books of account and its effect on the reported amounts in the financial statements, if any and defaults if any with regard to the loans availed by the company with regard to submission of such returns and statements.

ii. According to the information and explanations given to us, the determination of the transactions with MSME vendors and balances thereof, have been done based on the either certificate received from the respective parties or confirmation in that regard from the parties. In absence of complete reconciliation in this respect, completeness of the disclosures in respect of MSME vendors, liability for interest thereon as per MSME Act, if any and on Income Tax computations thereon on payments made beyond specified date to be ascertained.

iii. The company has incurred substantial losses in the previous financial year as well as during the current financial year having substantial negative effect on the net-worth of the company and other key financial indicators.

Our opinion is not modified in respect of matters stated in para (ii) and (iii) above.

REPORT ON OTHER LEGAL AND REGULATORY REQUIREMENTS:

1. As required by The Companies (Auditor''s Report) Order, 2020 issued by The Central Government Of India in term of section 143 (11) of The Companies Act, 2013, we enclose in the Annexure-A hereto a statement on the matters specified in paragraphs 3 and 4 of the said order, to the extent applicable to the company.

2. As required by section 143(3) of the Act, based on our audit we report that:

a) Except for matter stated in para (i) of “Other Matter” paragraph above, 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 appears from our examination of those books;

c) The Standalone Balance Sheet, Standalone the Statement of Profit and Loss including Other Comprehensive Income, the Standalone Statement of Changes in Equity & the Standalone Statement of Cash Flows dealt with by this Report are in agreement with the books of account;

d) In our opinion, aforesaid Standalone Balance Sheet, the Standalone Statement of Profit and Loss including Other Comprehensive Income, the Standalone Statement of Changes in Equity & the Standalone Statement of Cash Flows comply with the Indian Accounting Standards prescribed under section 133 of the Act;

e) On the basis of written representations received from the directors of the Company as on March 31, 2024, and taken on record by the Board of Directors, none of the directors are disqualified as on March 31, 2024, from being appointed as a director in terms of sub-section (2) of section 164 of Act;

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

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

i. The Company had the following litigations pending as at the end of the financial year which may impact its financial position on final disposal of the respective matters.

Sr. No.	Name of The Party/Department	Brief Facts of the Case	Financial Impact
1.	Star Papers	Suit Filed under Section 138 of the Negotiable Instruments Act, 1881 For Recovery of Dues For Sales of Goods	33,58,877/-
2.	Hi Tech Multi Forms	Suit Filed under Section 138 of the Negotiable Instruments Act, 1881 For Recovery of Dues For Sales of Goods (Suit Continuing but amount written off in the books of account)	14,65,029/-
3.	Shreeji Enterprise	Suit Filed For Recovery Of Dues For Sales of Goods	16,67,194/-
4.	Videocon Industries Limited	Operational Creditor in NCLT Proceedings For Recovery Of Dues For Sales of Goods	8,00,221/-
5.	Royal Sundaram General Insurance Company-Vehicle Claim	Claim for Loss of Vehicle	5,88,750/-
6.	Commissioner of Income Tax-Appeals, Ahmedabad-11	Disputed Income Tax Liabilities On Account Of Income Tax Assessment Order Passed Under Section 143(3) by the Office of Central Circle 1(1), Ahmedabad for A.Y. 2021-22	36,15,110/-
7.	Commissioner of Income Tax-Appeals-Ahmedabad-11	Disputed Income Tax Liabilities On Account Of Income Tax Assessment Order Passed Under Section 143(3) by the Office of Central Circle 1(1), Ahmedabad for A.Y. 2022-23 [Addition of Rs. 38,81,09,281/- made on protective basis]	51,77,20,750/-

8.	Office of the Commissioner of Central Goods and Service Tax, Audit Commissionerate, Rajkot	RCM Liability on Ocean Freight (Company has paid Rs. 30,59,267/-under protest)	30,59,267/-
9.	District Consumer Dispute Redressal Commissioner, Mehsana	Fire Insurance Claim filed with The New India Assurance Company Limited for materials destroyed due to fire held at the premises of Balaram Papers Private Limited (wholly owned subsidiary company), located at 112/1-1, Dhanali Road, Near Deem-Roll Tech Limited, At & Post Ganeshpura, Taluka Kadi, District Mahesana. The claim and case filed by Balaram Papers Private Limited. However, the amount is recoverable by the company from the subsidiary company.	3,35,38,210/-

ii. The Company did not have any long-term contracts including derivatives contracts for which there were any material foreseeable losses.

iii. As at 31st March, 2024 there were no amounts which were required to be transferred to the Investor Education and Protection Fund by the Company.

iv. Management Representation:

a. The Management of the Company has represented to us that to the best of it’s 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(s) or entity(ies), including foreign entities (“Intermediaries”), with the understanding, whether recorded in writing or otherwise, that the Intermediary shall, directly or indirectly lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the Company (“Ultimate Beneficiaries”) or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries.

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

c. Based on audit procedures which we considered reasonable and appropriate in the circumstances, nothing has come to our notice that has caused us to believe that the representations under subclause (i) and (ii) of Rule 11(e) Companies (Audit and Auditors) Rules, 2014 (as amended) and provided in clauses (a) and (b) above contain any material mis-statement.

v. The company has not declared or paid any dividend during the year.

vi. Based on our examination, which included test checks, the Company has used accounting software for maintaining its books of account for the financial year ended March 31, 2024 which has a feature of recording audit trail (edit log) facility and the same has been in operation throughout the year for all relevant transactions recorded in the software. Further, during the course of our audit we did not come across any instance of the audit trail feature being tampered with. However, we have carried out test checks only and our opinion is based on test check only.

As proviso to Rule 3(1) of the Companies (Accounts) Rules, 2014 is applicable from April 1, 2023, reporting under Rule 11(g) of the Companies (Audit and Auditors) Rules, 2014 on preservation of audit trail as per the statutory requirements for retention of the record is not applicable for the financial year ended March 31, 2024.

3. With respect to the matter to be included in the Auditors’ Report under Section 197(16) of the Act:

In our opinion and according to the information and explanations given to us, the remuneration paid by the Company to its directors during the current year is in accordance with the provisions of Section 197 of the Act read with Schedule V to the Companies Act, 2013. The remuneration paid to any director is not in excess of the limit laid down under Section 197 of the Act read with Schedule V to the Companies Act, 2013. The Ministry of Corporate Affairs has not prescribed other details under Section 197(16) of the Act which are required to be commented upon by us.

FOR AND ON BEHALF OF

SNDK & ASSOCIATES, CHARTERED ACCOUNTANTS, FIRM REG. NO. W100060

KISHAN R. KANANI

PLACE: AHMEDABAD PARTNER

DATED: 29^th MAY, 2024 M. No. 192347

UDIN: 24192347BKAO O O3319

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Mar 31, 2023

We have audited the standalone financial statements of ASTRON PAPER & BOARD MILL LIMITED ("the Company”), which comprise the Standalone Balance Sheet as at March 31, 2023, the Standalone Statement of Profit and Loss (Including Other Comprehensive Income), the Standalone Statement of Changes In Equity and the Standalone Statement of Cash Flows for the year then ended and notes to the standalone financial statements, including a summary of significant accounting policies and other explanatory information (hereinafter referred to as "Standalone Financial Statements”).

In our opinion and to the best of our information and according to the explanations given to us except for the effect for the possible effects of matters described in the Basis for Qualified Opinion section of our report, the aforesaid standalone financial statements give the information required by the Companies Act, 2013 ("Act”) in the manner so required and give a true and fair view in conformity with the accounting principles generally accepted in India including Indian Accounting Standards (''Ind AS'') specified under Section 133 of the Act read with the Companies (Indian Accounting Standards) Rules, 2015 as amended, of the state of affairs of the Company as at March 31, 2023, and its loss and other comprehensive income, changes in equity and its cash flows for the year ended on that date.

BASIS FOR QUALIFIED OPINION

The current trade receivables reported in the financial statements include export trade receivable of Rs. 1,53,43,129/- outstanding for more than three years, which the company has considered as good for recovery. In our opinion, the same should have been considered as doubtful and necessary provision for doubtful debts should have been made by the company. Non-provision of such

doubtful debts of Rs. 1,53,43,129/- has resulted into understatement of loss and overstatement of outstanding balance of current trade receivables and shareholder''s fund by Rs. 1,53,43,129/-.

We conducted our audit in accordance with the Standards on Auditing (SAs) specified under Section 143(10) of the Act. Our responsibilities under those SAs 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 ethical requirements that are relevant to our audit of the standalone financial statements under the provisions of the Act and the Rules thereunder, and we have fulfilled our other ethical responsibilities in accordance with these requirements and the Code of Ethics. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.

EMPHASIS OF MATTER:

We draw attention to the following matters in the Notes to the Financial Statements:

I. Note No. 36(d)(1) relating to the disputed Income Tax Liabilities amounting to Rs. 36,15,110/-.

II. Note No. 36(d)(2) relating to RCM Liabilities on Ocean Freight Rs. 30,59,267/-.

III. Note No. 36(o) relating to Revenue from Operations in the form of GST Subsidy Claim amounting to Rs. 8,25,00,000/- accounted in the financial year 202122 and non-realization of any amount during the current financial year. [Refer to Note No. 36(o)]

IV. Note No. 36(m) relating to income tax search carried out at the registered office of the company. [Refer to Note No. 36(m)]

Our opinion is not modified in respect of the above referred matters.

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.

Description of Key Audit Matters:

The Key Audit Matter	How the matter was addressed in our audit
1. Impairment Evaluation of Investment in a Subsidiary (Refer to Note No. 6)
• The carrying amount of the investments (held at cost less impairment, if any) made in a subsidiary as at 31st March, 2023 was Rs. 4.04 Crores. The initial cost of investment was also Rs. 4.04 Crores. • We do not consider the valuation of these investments to be at a high risk of significant misstatement, or to be subject to a significant level of judgment. However, due to their materiality in the context of total assets of the Company, this is considered to be significant to our overall audit strategy and planning.	• Comparing the carrying amounts of investments with the balance sheet of the subsidiary to identify whether their net assets were in excess of their carrying amount and assessing whether that subsidiary has historically been profit-making. • Considering the adequacy of disclosures in respect of the investments in the subsidiary.
2. Litigations and Claims (Refer to Note No. 32 & 36(d)
• The Company operates in various States within India as well as export of goods which exposes the company to a variety of different Laws and Regulations and implications and interpretations thereof. In such regulatory environment, the Company is subject to some legal and tax related claims which have been disclosed for in the financial statements based on the facts and circumstances of each case. • Taxation and litigations have been identified as a key audit matter due to the status of legal proceedings, timescales involved for resolution and the potential financial impact of these on the financial statements. Further, such tax litigations involve significant management judgment in assessing the exposure of each case and thus a risk that such cases may not be adequately provided for or disclosed.	• Gained an understanding of the process of identification of claims, litigations and contingent liabilities and identified key controls in the process. For selected controls we have performed tests of controls. • Obtained the summary of Company''s legal and tax cases and critically assessed management''s position through discussions with the Legal Counsel, appropriate senior management and operational management, on both the probability of success in significant cases, and the magnitude of any potential loss. • Assessed management''s estimate of the possible outcome of the litigations, the relevant disclosures made within the financial statements to address whether they appropriately reflect the facts and circumstances of the respective tax and legal exposures and the requirements of relevant accounting standards.
3. Claims Receivable on Imported Raw Materials:
• The Company imports raw materials i.e. waste paper and some of the chemicals which constituted 82.05% of the total cost of raw materials consumed for the financial year 2022-23. • In cases of quality differences, the company files quality claims with the respective suppliers. After due verification process, the quality claims are allowed and paid by the respective supplier depending upon the quality differences. The amounts of claims filed and actual claims received varies depending upon the final quality assessment and its acceptance by the respective suppliers and the company.	• Gained an understanding of the process of identification of claims, identified key controls in the process and past trend of amounts at which claims were finally settled with the amount for which claims were filed. For selected controls we have performed tests of controls. • Assessed management''s estimate of the amount of overall claims receivable as at the end of the financial year, the possibility of recoverability, assessed overall past trend of claims filed and amounts recovered and the requirements of relevant accounting standards.

• In respect of claims filed but not accepted/approved

by the suppliers and the company as at the end of the financial year, the company accounts for such claims at the estimated amount of claim likely to be realized based on the past trend and management estimate of the likely recoverability of claims. Such treatment involves significant management judgment in assessing the recoverability in each case and thus a risk that such claims may not be adequately accounted for.

INFORMATION OTHER THAN THE STANDALONE FINANCIAL STATEMENTS AND AUDITORS’ REPORT THEREON

The Company''s management and Board of Directors is responsible for the other information. The other information comprises the information included in the Annual Report, but does not include the 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 in the 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 Management and Board of Directors are responsible for the matters stated in section 134(5) of the Companies Act, 2013 ("the Act”) with respect to the preparation of these standalone financial statements that give a true and fair view of the financial position, financial performance including other comprehensive income, cash flows and changes in equity of the Company in accordance with the Indian Accounting Standards (Ind AS), accounting principles generally accepted in India, including the Indian Accounting Standards specified under Section 133 of the Act, read with the Companies (Indian Accounting Standard) Rules, 2015 as amended.

This responsibility also includes the maintenance of

adequate accounting records in accordance with the provision of the Act for safeguarding of the assets of the Company and for preventing and detecting the 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 control, 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.

In preparing the standalone financial statements, management and Board of Directors are 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 is also 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 control relevant to the audit in order to design audit procedures that are appropriate in the circumstances. Under Section 143(3) (i) of the Act, we are also responsible for expressing our opinion on whether the Company has adequate internal financial controls with reference to financial statements in place and the operating effectiveness of such controls.

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

• Conclude on the appropriateness of management''s use of the going concern basis of accounting and, based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Company''s ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditor''s report to the related disclosures in the standalone financial statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based on the audit evidence obtained up to the date of our auditor''s report. However, future events or conditions may cause the Company to cease to continue as a going concern.

• Evaluate the overall presentation, structu re 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.

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

REPORT ON OTHER LEGAL AND REGULATORY REQUIREMENTS:

1. As required by The Companies (Auditor''s Report) Order, 2020 issued by The Central Government Of India in term of section 143 (11) of The Companies Act, 2013, we enclose in the Annexure-A hereto a statement on the matters specified in paragraphs 3 and 4 of the said order, to the extent applicable to the company.

2. 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 appears from our examination of those books;

c) The Standalone Balance Sheet, Standalone the Statement of Profit and Loss including Other Comprehensive Income, the Standalone Statement of Changes in Equity & the Standalone Statement of Cash Flows dealt with by this Report are in agreement with the books of account;

d) In our opinion, aforesaid Standalone Balance Sheet, the Standalone Statement of Profit and Loss including Other Comprehensive Income, the

Standalone Statement of Changes in Equity & the Standalone Statement of Cash Flows comply with the Indian Accounting Standards prescribed under section 133 of the Act;

e) On the basis of written representations received from the directors of the Company as on March 31, 2023, and taken on record by the Board of Directors, none of the directors are disqualified as on March 31, 2023, from being appointed as a director in terms of sub-section (2) of section 164 of Act;

f) With respect to the adequacy of internal financial control over financial reporting of the Company and the operating effectiveness of such controls, refer to our separate report in Annexure-B. 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 included in the Auditor''s Report in accordance with Rule 11 of the Companies (Audit and Auditors) Rules, 2014, as amended, in our opinion and to the best of our information and according to the explanations given to us:

i. The Company had the following litigations pending as at the end of the financial year which may impact its financial position on final disposal of the respective matters.

Sr. No.	Name of The Party /Department	Brief Facts of the Case	Financial Impact (in INR)
1.	Star Papers	Suit Filed under Section 138 of the Negotiable Instruments Act, 1881 For Recovery of Dues For Sales of Goods	33,58,877/-
2.	Hi Tech Multi Forms	Suit Filed under Section 138 of the Negotiable Instruments Act, 1881 For Recovery of Dues For Sales of Goods (Suit Continuing but amount written off in the books of account)	14,65,029/-
3.	Shreeji Enterprise	Suit Filed For Recovery Of Dues For Sales of Goods	16,67,194/-
4.	Videocon Industries Limited	Operational Creditor in NCLT Proceedings For Recovery Of Dues For Sales of Goods	8,00,221/-
5.	Royal Sundaram General Insurance Company-Vehicle Claim	Claim for Loss of Vehicle	5,88,750/-
6.	Commissioner of Income Tax-Appeals [NFAC]	Disputed Income Tax Liabilities On Account Of Income Tax Assessment Order Passed Under Section 143(3) by the Office of Central Circle 1(1), Ahmedabad for A.Y. 2021-22	36,15,110/-
7.	Office of the Commissioner of Central Goods and Service Tax, Audit Commissionerate, Rajkot	RCM Liability on Ocean Freight (Company has paid Rs. 30,59,267/- under protest)	30,59,267/-
8.	District Consumer Dispute Redressal Commissioner, Mehsana	Fire Insurance Claim filed with The New India Assurance Company Limited for materials destroyed due to fire held at the premises of Balaram Papers Private Limited (wholly owned subsidiary company), located at 112/1-1, Dhanali Road, Near Deem-Roll Tech Limited, At & Post Ganeshpura, Taluka Kadi, District Mahesana. The claim and case filed by Balaram Papers Private Limited. However, the amount is recoverable by the company from the subsidiary company.	3,35,38,210/-

ii. The Company did not have any long-term contracts including derivatives contracts for which there were any material foreseeable losses.

iii. As at 31st March, 2023 there were no amounts which were required to be transferred to the Investor Education and Protection Fund by the Company.

iv. Management Representation:

a. The Management of the Company has represented to us that to the best of it''s 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(s) or entity(ies), including foreign entities ("Intermediaries”), with the understanding, whether recorded in writing or otherwise, that the Intermediary shall, directly or indirectly lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the Company ("Ultimate Beneficiaries”) or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries.

b. The management of the Company has represented, that, to the best of it''s knowledge and belief no funds (which are material either individually or in the aggregate) have been received by the company from any person(s) or entity(ies), including foreign entities ("Funding Parties”),

with the understanding, whether recorded in writing or otherwise, that the company shall, whether, directly or indirectly, lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the Funding Party ("Ultimate Beneficiaries”) or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries.

c. Based on audit procedures which we considered reasonable and appropriate in the circumstances, nothing has come to our notice that has caused us to believe that the representations under sub-clause (i) and (ii) of Rule 11(e) Companies (Audit and Auditors) Rules, 2014 (as amended) and provided in clauses (a) and (b) above contain any material mis-statement.

v. The company has not declared or paid any dividend during the year.

3. With respect to the matter to be included in the Auditors'' Report under Section 197(16) of the Act:

In our opinion and according to the information and explanations given to us, the remuneration paid by the Company to its directors during the current year is in accordance with the provisions of Section 197 of the Act read with Schedule V to the Companies Act, 2013. The remuneration paid to any director is not in excess of the limit laid down under Section 197 of the Act read with Schedule V to the Companies Act, 2013. The Ministry of Corporate Affairs has not prescribed other details under Section 197(16) of the Act which are required to be commented upon by us.

FOR AND ON BEHALF OF SNDK & ASSOCIATES, CHARTERED ACCOUNTANTS, FIRM REG. NO. W100060

KISHAN R. KANANI

PLACE: AHMEDABAD PARTNER

DATED: 27TH MAY, 2023 M. No. 192347

UDIN: 23192347BGRHBL4572

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Mar 31, 2018

REPORT ON THE FINANCIAL STATEMENTS:

We have audited the accompanying financial statements of ASTRON PAPER & BOARD MILL LIMITED ("the Company"), which comprise the Balance Sheet as at March 31, 2018, the Statement of Profit and Loss (Including Other Comprehensive Income), the Statement of Changes In Equity and the Statement of Cash Flows for the year then ended and a summary of 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 in section 1 34(5) of the Companies Act, 201 3 ("the Act") with respect to the preparation of these 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) accounting principles generally accepted in India, including the Indian Accounting Standards specified under Section 133 of the Act, read the Companies (Indian Accounting Standard) Rules, 2015 as amended.

This responsibility also includes the maintenance of adequate accounting records in accordance with the provision of the Act for safeguarding of the assets of the Company and for preventing and detecting the 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 control, 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.

In conducting 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 and the Order issued under section 1 43(11) of the Act..

We conducted our audit of the Financial Statements in accordance with the Standards on Auditing specified under section 1 43(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 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 true and fair view 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 reasonableness of the accounting estimates made by 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 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:

i. In the case of the Balance Sheet of the state of the affairs of the company as at 31 st March 201 8;

ii. In the case of Statement of Profit & Loss of PROFIT (including Other Comprehensive Income) for the year ended on that date

iii. In the case of Statement of Changes in Equity, of the changes in Equity for the year ended on that date AND

iv. In the case of the Statement of Cash Flows, of the cash flows for the year ended on that date.

EMPHASIS OF MATTER:

We draw attention to the following matters in the Notes to the Financial Statements:

I. Notes No.35(c) relating to the non-provision for doubtful debts amounting to '' 59.11 lacs

II. Notes No. 35(d)(1) relating to the disputed CENVAT of Excise amounting to '' 26.43 lacs and appropriate interest as per Excise Law and Penalty of '' 26.43 lacs.

III. Notes No. 34(d)(2) relating to the disputed Income Tax Amount of '' 3.89 lacs for the A.Y. 2013-1 4.

IV. Notes No. 34(d)(3) relating to the disputed Income Tax Amount of '' 4.36 lacs for the A.Y. 2014-1 5.

V. Notes No. 34(d)(4) relating to the disputed Income Tax Amount of '' 4.59 lacs for the A.Y. 2015-1 6.

Our opinion is not modified in respect of the above referred matters.

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 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 & the Statement of Cash Flow Statement dealt with by this Report are in agreement with the books of account;

d) In our opinion, the Balance Sheet, the Statement of Profit and Loss including Other Comprehensive Income, the Statement of Changes in Equity & the Statement of Cash Flow comply with the Indian Accounting Standards prescribed under section 1 33 of the Act;

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

f) With respect to the adequacy of internal financial control 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 included in the Auditor''s Report in accordance with Rule 1 1 of the Companies (Audit and Auditors) Rules, 2014, as amended, in our opinion and to the best of our information and according to the explanations given to us :

i. The Company had the following litigations pending as at the end of the financial year which may impact its financial position on final disposal of the respective matters.

(Rs. in Lacs.)

Sr.	Name of The Party/Department	Brief Facts of the Case	Financial Impact
1.	Star Papers	Suit Filed under Section 138 of the Negotiable Instruments Act, 1881	38.03
2.	Hi Tech Multi Forms	Suit Filed under Section 138 of the Negotiable Instruments Act, 1881	21.08
3.	Shreeji Enterprise	Suit Filed For Recovery Of Dues For Sales of Goods	21.67
4.	Romano Corporation	Suit Filed For Recovery Of Dues For Sales of Goods	37.06
5.	Royal Sundaram General Insurance Company-Vehicle Claim	Claim for Loss of Vehicle	5.89
6.	CESTAT	Disputed CENVAT Claim on Fixed Assets & Penalty Thereon (Company has reversed CENVAT credit of Rs.26.43 lacs under protest) (CENVAT Rs.26.43 lacs and Penalty Rs.26.43 lacs	52.87
7.	ITAT, Ahmedabad	Disputed Income Tax Deduction Claim U/s. 35D of the Income Tax Act, 1961 for A.Y. 201 3-14 to the extent of amount disallowed	3.89

(Rs. in Lacs.)

Sr.	Name of The Party/Department		Brief Facts of the Case	Financial Impact
8.	ITAT, Ahmedabad	Disputed Income Tax Deduction Claim U/s. 35D of the Income Tax Act, 1961 for A.Y. 2014-15 to the extent of amount disallowed		4.36
9.	CIT-A-1, Ahmedabad	Disputed Income Tax Deduction Claim U/s. 35D of the Income Tax Act, 1961 for A.Y. 2014-15 to the extent of amount disallowed		5.49

ii. The Company did not have any long-term contracts including derivatives contracts for which there were any material foreseeable losses.

iii. As at 31st March, 201 8 there were no amounts which were 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 issued by The Central Government Of India in term of section 143 (11) of The Companies Act, 201 3, we enclose in the Annexure-B hereto a statement on the matters specified in paragraphs 3 and 4 of the said order, to the extent applicable to the company.

ANNEXURE "A" TO THE INDEPENDENT AUDITORS'' REPORT [REFERRED TO IN PARAGRAPH 1(f) UNDER "REPORT ON OTHER LEGAL AND REGULATORY REQUIREMENTS SECTION OF OUR REPORT OF EVEN DATE]

FINANCIAL YEAR ENDED 31ST MARCH 2018 Report on the Internal Financial Controls under Clause (i) of Sub-section 3 of Section 143 of the Companies Act, 2013 ("the Act")

We have audited the internal financial controls over financial reporting of ASTRON PAPER & BOARD MILL LIMITED ("the Company") as of March 31, 2018 in conjunction with our audit of the Ind AS financial statements of the company for the year ended on that date.

Management''s Responsibility for Internal Financial Controls

The management of the company 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.

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

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 prescribed under section 143(10) of the Companies Act, 2013, to the extent applicable to an audit of internal financial controls. 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.

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.

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

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 (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the company; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the company are being made only in accordance with authorisations of management and directors of the company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorised acquisition, use, or disposition of the company''s assets that could have a material effect on the financial statements.

Inherent Limitations of Internal Financial Controls over Financial Reporting

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

In our opinion and to the best of our information and according to the information and explanations given to us, 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 commensurate with the nature of the business of the company and operating effectively as at March 31, 201 8, 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.

ANNEXURE-B TO THE INDEPENDENT AUDITOR''S REPORT

[Referred to in paragraph 2 under "Report On Other Legal And Regulatory Requirements'' section of our report of even date to the members of ASTRON PAPER & BOARD MILL LIMITED on the financial statements of the company for the year ended 31st March, 2018 :

On the basis of such checks of the books and records of the company as we considered appropriate and according to the information and explanation given to us during the course of audit, we further report that:

i. In respect of its fixed assets:

a) According to the information and explanations given to us, the company has maintained proper records of fixed assets showing full particulars including quantitative details and situation of fixed assets.

b) As explained to us, the management in accordance with a phased programme of verification adopted by the company has physically verified the fixed asset. To the best of our knowledge, no material discrepancies have been noticed on such verification or have been reported to us.

c) According to the information and explanations given to us and on the basis of the examination of the records of the company, the title deeds of immovable properties are held in the name of the Company as at the balance sheet date.

ii. In respect of its Inventories:

a) As explained to us, the inventories have been physical verified during the year by the management of the company.

b) As explained to us, no material discrepancies were noticed on physical verification of inventory as compared to the books of account.

iii. Loans/Advances Granted:

As informed to us, during the year the company has not granted any secured/unsecured loans to any Company, Firms, Limited Liability Partnerships or Other Parties covered in the register maintained under section 1 89 of the Companies Act, 2013 and hence other matters related thereto referred to in clause III of The Companies (Auditor''s Report) Order, 2016 are not applicable .

iv. According to the information and explanations given to us, the company has not entered into any transaction of the nature referred to in Sections 185 and 1 86 of The Companies Act, 2013 in respect of any loans, investments, guarantees and security.

v. According to the information and explanations given to us, the company has not accepted any deposits from the public within the meaning of section 73,74,75 & 76 of the Act and Rules framed thereunder during the year and therefore, the provisions of clause 3(v) of the Order are not applicable to the Company.

vi. We have broadly reviewed the cost records maintained by the Company pursuant to rules made by the Central Government. We are of the opinion that prima facie the prescribed accounts and records have been maintained and made. We have however, not made a detailed examination of these records with a view to determine whether they are accurate or complete.

vii. In respect of Statutory Dues:

a) As per the information & explanations furnished to us, in our opinion the company is generally regular in depositing with appropriate authorities undisputed statutory dues of Custom Duty, Excise Duty T.D.S., VAT/ CST/GST, Service Tax, Employee Provident Fund, Cess and other material statutory dues applicable to it. There has been no outstanding as at 31st March, 2018 of undisputed liabilities outstanding for more than six months.

b) According to information and explanations given to us and so far as appears from our examination of books of account, there were no statutory dues outstanding as at 31st March, 201 8 which have not been deposited on account of any dispute.

viii. According to the information and explanations given to us, the Company has not defaulted in the repayment of loans or borrowings and payment of interest to the Banks and Financial Institutions.

ix. The company has raised moneys by way of initial public offer of Equity Shares during the year. In our opinion and according to the information and explanations given to us, the moneys raised through initial public offer of Equity Shares have been applied by the Company for the purpose for which they were raised. In our opinion and according to the information and explanations given to us, the company has applied the term loans obtained during the year for the purpose for which they had been obtained.

x. According to the information and explanations given to us, no material fraud by the company or on the company by its Officers or Employees has been noticed or reported to us by the management during the year.

xi. In our opinion and according to the information and explanations given to us, the company had paid/provided managerial remuneration in accordance with the provisions of Section 197 of the Companies Act, 201 3 read with Schedule V of the Companies Act, 201 3.

xii. As the company is not the Nidhi Company, clause (xii) of paragraph 3 of The Companies (Auditor''s Report) Order, 2016 is not applicable to it.

xiii. According to the information and explanations given to us, the company is in compliance with the provisions of sections 177 and 188 of the Companies Act, 2013, where applicable, for related party transactions and the details of related party transactions have been disclosed in the Notes to the Financial Statements in accordance with the applicable Accounting Standards.

xiv. The company has not made any preferential allotment or private placement of shares or fully or partly convertible debentures during the year, clause (xiv) of paragraph 3 of The Companies (Auditor''s Report) Order, 2016 is not applicable to it during the year.

xv. According to the information and explanations given to us, the company has not entered into any non cash transaction with directors or persons connected with them and hence clause (xv) of paragraph 3 of The Companies (Auditor''s Report) Order, 2016 is not applicable to it during the year.

xvi. As the company is not required to be registered under section 45-IA of the Reserve Bank of India, 1 934, clause (xvi) of paragraph 3 of The Companies (Auditor''s Report) Order, 201 6 is not applicable to it.

FOR AND ON BEHALF OF

S. N. SHAH & ASSOCIATES,

CHARTERED ACCOUNTANTS,

FIRM REG. NO. 109782W

S. N. SHAH

PLACE: AHMEDABAD PARTNER

DATED: 4TH MAY, 2018 M. No. 035181