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42 The Company is in the process of conducting a transfer pricing study as required by the transfer pricing regulations
under the Income Tax Act, 1961 (‘regulations’) to determine whether the transactions entered during the
year ended March 31, 2025, with the associated enterprises were undertaken at “arm’s length price”. The
management confirms that all the transactions with associate enterprises are undertaken at negotiated prices on
usual commercial terms and is confident that the aforesaid regulations will not have any impact on the financial
statements, particularly on the amount of tax expense and that of provision for taxation.
43 ADDITIONAL REGULATORY INFORMATION/DISCLOSURES TO THE EXTENT APPLICABLE TO THE
COMPANY
- No funds have been advanced or loaned or invested either from borrowed funds or share premium or any
other sources or kind of funds by the company to or in any other person or entity, including foreign entities
(“Intermediaries”), with the understanding, whether recorded in writing or otherwise, that the Intermediary shall,
whether, directly or indirectly lend or invest in other persons or entities identified in any manner whatsoever by
or on behalf of the Company (“Ultimate Beneficiaries”) or provide any guarantee, security or the like on behalf
of the Ultimate Beneficiaries.
- There are no funds received by the Company from any person or entity, including foreign entities (“Funding
Party”) 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.
- No transactions to report against Benami Property held under Prohibition of Benami Property Transactions
Act, 1988 and rules made thereunder.
- The Company does not have any such transaction which is not recorded in the books of accounts that has
been surrendered or disclosed as income during the year in the tax assessments under the Income Tax Act,
1961 (such as, search or survey or any other relevant provisions of the Income tax Act, 1961.
- The Company has not been declared wilful defaulter by any bank or financial institution or government or any
government authority.
44 PHYSICAL SERVER OF BOOKS OF ACCOUNTS
Ministry of corporate affairs has amended the Rule 3 of the Companies (Accounts) Rules, 2014 (the “Accounts
Rules”) vide notification dated August 05, 2022, relating to the mode of keeping books of account and other
books and papers in electronic mode. Back-ups of the books of account and other books and papers of the
company maintained in electronic mode are now required to be retained on a server located in India on daily
basis as prescribed under Rule 3(5) of the Accounts Rules.
The Company has identified SAP (primary accounting software) and certain other applications for which the
aforementioned provision and guidance is applicable and the Company is in compliance with the aforesaid
requirement except (a) in case of SAP, the back-ups has not been taken on daily basis throughout the year and
(b) for certain other applications operated by third-party service providers such back-ups has not been retained
on a server located in India on daily basis.
45 AUDIT TRAIL
The Company has used accounting software for maintaining its books of account which has a feature of recording
audit trail (edit log) facility and the same has operated throughout the year for all relevant transactions recorded
in the software, except that, audit trail feature is not enabled for certain changes made using privileged/
administrative access rights in so far it relates to such accounting software. Further, no instances of audit trail
feature being tampered with respect to the above accounting software has been noted where audit trail has
been enabled. Also, the Company has used certain accounting softwares which are operated by third-party
software service providers for maintaining its books of account. Management is not in possession of necessary
information to determine whether audit trail feature of the said software was enabled and operated throughout
the year for all relevant transactions recorded in the software or whether there were any instances of the audit
trail feature being tampered with during the year.
Integrated Annual Report 2024-25
281