Specimen of Management Representation Letter on Statutory Audit

TO,
THE PARTNERS
XXXX ASSOCIATES LLP
CHARTERED ACCOUNTANTS
PUNE
Dear Sir,
Ref: Statutory Audit of XXXX India Private Limited for the year ended 31st March, 20XX
Sub: Management Representation Letter
This representation letter is provided in connection with your audit of the financial
statements for the year ended 31st March, 20XX for the purpose of expressing an opinion as
to whether the financial statements give a true and fair view of the financial position and of
the results of the operations of the Company for the year then ended. We acknowledge our
responsibility for preparation of the financial statements in accordance with the
requirements of the Companies Act, 2013 and recognized accounting policies and practices,
including the Accounting Standards notified under section 133 of Companies Act, 2013.
This responsibility also includes the maintenance of adequate accounting records in
accordance with the provisions of the Act for safeguarding of the assets of the Company and
for preventing and detecting 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 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 financial statements, we 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. We are also responsible for overseeing the
company’s financial reporting process.
We hereby, confirm to the best of our knowledge and belief, the following representations:
ACCOUNTING POLICIES AND BASIS FOR PREPARATION OF FINANCIAL STATEMENTS

1. The accounting policies which are material or critical in determining the results of
operations for the year or financial position are set out in the financial statements
and are consistent with those adopted in the financial statements for the previous
year except as stated otherwise. The financial statements are prepared on historical
cost convention and on accrual basis and on a going concern concept and in
compliance with the Accounting Standards notified under Section 133 of the
Companies Act, 2013 and the relevant provisions of the Companies Act 2013 and
relevant rules thereto.
2. The Company follows the accrual basis of accounting. Except in the following cases
where the same are recorded on cash basis.
3. We confirm that accounting policies as disclosed in the Note No. __ are true and
correct and being consistently followed by the Company. There is no deviation in the
accounting policies from the accounting policies disclosed in the financial
statements.
4. The financial statements are prepared on a going concern basis.
5. We have provided you with:
a) Access to all information of which we are aware that is relevant to the
preparation of the financial statements, such as records, documentation and
other matters;
b) Additional information that you have requested from us for the purpose of
the audit; and
c) Unrestricted access to persons within the entity from whom you determined
it necessary to obtain audit evidence.
EQUITY & LIABILITIES SHAREHOLDER’S FUNDS SHARE CAPITAL

1. The authorized Share Capital of the Company is Rs. 1,00,000 divided into 10000
number of Equity Shares of Rs.10/-each.
2. The Issued, Subscribed & Paid-up Share Capital of the Company is Rs 1,00,000
divided into 10000 number of Equity Shares of Rs 10/- each.
3. Following are the details of shareholders having more than 5 % shareholding in the
Company as on 31st March 20XX.

Name of Shareholder As at March 31, 20XX As at March 31, 2021

No of Equity Percentage No of Equity Percentage
shares held shares held
9800 98% 9800 98%

4. Following are the details of promoters as on 31st March 20XX

Name of Shareholder As at March 31, 20XX As at March 31, 2021
No of Equity Percentage No of Equity Percentage
shares held shares held
9800 98% 9800 98%
100 1% 100 1%
100 % 100 %

5. Reconciliation of Numbers of Shares:

Particulars Equity Shares Preference

Shares
 Number Rs. Number Rs.
Shares outstanding at the beginning of the 10000 100000 10000 100000
year
Shares issued during the year 0 0 0 0
Shares bought back during the year 0 0 0 0
Shares outstanding at the end of the year 10000 100000 10000 100000

RESERVES & SURPLUS

We confirm that the Company has complied with all the statutory requirements of various
statutes which govern the Company, relating to the transfer to various reserves and their
utilisation in the manner specified in the relevant statute.
LIABILITIES

We confirm that all the liabilities of the Company are correctly classified into Current and
Non-Current based upon the criteria as set out in Schedule III to the Companies Act, 2013.
Also, the requirements of the Accounting Standards notified under Section 133 of the
Companies Act, 2013 have been considered while making such classification.
OTHER LIABILITIES & PROVISIONS

1. In our opinion, the provision for all the known liabilities including all losses expected
to arise from events which had occurred by 31st March 20XX are adequate and are
not in excess of the amount reasonably necessary.
2. Balance of Sundry creditors and other liabilities are subject to confirmation and
reconciliation. Consequential adjustment thereof, if any will be given effect into the
books of account in the year of such adjustment. However, in view of the
management, it will not have any material impact on the financial statements.
3. Ageing for trade payables outstanding as at March 31, 2022 is as follows:

Outstanding for following periods from the date of

Not
Trade payables transaction
due
Less than 1-2 2-3 More than 3
Total
1 year years years years
MSME - - - - - -

Others - - - - - 50.00
Disputed dues -
MSME - - - - - -
Disputed dues -
Others - - - - - -
Total -
4. Provision for Current Income Tax computed as per provisions of the Income Tax Act,
1961 amounting to Rs. has been charged to Statement of Profit & Loss and
considered to be adequate.
5. The name of the “Micro, Small and Medium suppliers defined under “The Micro,
Small and Medium Enterprises Development Act 2006” to the extent identified have
been provided and the balances have accordingly been reflected under Sundry
Creditors with details as per the said Act provided in a separate tabulation at Note
No._ / or could not be identified as the necessary evidence is not in the possession
of the Company.
6. Advances received from customers represent sums received in the normal course of
business either for supply of goods or for the services to be rendered and are not in
the nature of loans.
7. There is no major change in / deviation from any accounting estimate applied by the
Company as compared to the previous year.
DEFERRED TAX LIABILITIES / ASSETS

Deferred Tax Liabilities/ (Assets) amounting to Rs. has been accounted during the year as
per the provisions of Accounting Standard 22, “Accounting for Taxes on Income” and
considered to be adequate. Deferred Tax Assets are recognized only to the extent there is
virtual certainty that the assets will be realized in the future. The unrealizable deferred tax
assets have been reversed during the year
ASSETS

We confirm that all the assets of the Company are correctly classified into Current and Non-
Current based upon the criteria as set out in Schedule III to the Companies Act, 2013. Also,
the requirements of the Accounting Standards notified under Section 133 of the Companies
Act, 2013 have been considered while making such classification.
The Company has a satisfactory title to all the assets stated in the financial statements and
there are no liens, mortgages, or other encumbrances on the assets of the Company, except
those that are disclosed in the financial statements.
In the opinion of the Board, current assets including loans and advances have a value on
realisation in the ordinary course of the business at least equal to the amount at which they
are stated.
PROPERTY, PLANT AND EQUIPMENT (PPE)

1. All the PPE are in usable conditions and are classified correctly. None of the PPEs are
revalued during the year.
2. The Company has a satisfactory title to all the assets stated in the financial
statements and there are no liens, mortgages, or other encumbrances on the assets
of the Company, except those that are disclosed in Notes to the financial statements.
3. The net book values at which PPEs are stated in the balance sheet are arrived at:
a. After taking into account all capital expenditure on additions thereto, but no
expenditure properly chargeable to revenue.
b. After providing adequate depreciation on PPEs during the period as required
by the law.
c. After eliminating the cost and accumulated depreciation relating to items
sold, discarded, demolished, or destroyed.
d. After attributing borrowing costs of acquisition of PPEs as part of the cost of
such PPE, if applicable.
4. Depreciation on PPEs is provided on the basis of useful life as given in the Schedule II
to the Companies Act, 2013.
5. We confirm that none of the items, which is in nature of revenue expenditure have
been capitalised and none of the items, which is in the nature of capital expenditure
have been charged to statement of profit and loss for the year.
INVESTMENTS

1. Current investments as appearing in the Balance Sheet consist of only investments

which are by their nature readily realisable and intended to be held for not more
than one year from the balance sheet date. All other investments have been shown
in the Balance Sheet as long-term investments.
2. Current investments have been valued at the lower of cost or market value. Long
term investments have been valued at cost, except that any permanent diminution
in their values has been provided for ascertaining their carrying amounts.
3. All the investments as appearing in the Balance Sheet belong to the entity and they
do not include any investments held on behalf of any other person.
LOANS & ADVANCES

1. All the Loans and advances are considered good and fully recoverable except those
which are specifically shown as doubtful in the financial statements. Adequate
provision has been made for bad and doubtful loans and advances.
2. In regard to Loans and advances particulars has been given separately in respect of
following in the financial statements:
a) Loans and advances considered good and in respect of which the company is
fully secured.
b) Loans and advances considered good for which the company holds no
security other than the debtor’s personal security, and
c) Loans and advances considered doubtful or bad.
3. We confirm that there are no other loans and advances due from any related party
except as are stated in the financial statements.
4. Adequate interest provision has been made wherever applicable
5. Balance of loans and advances are subject to confirmation and reconciliation.
Consequential adjustment thereof, if any will be given effect in the books of account
in the year of such adjustment.
6. Advances to creditors amounting to Rs. …..are in the nature of advance only and no
entry is pending to be accounted there against as at 31st March ,
7. Balance with GST department as per books are matching with the balance as per GST
records.
INVENTORIES

1. Inventories at the year-end consisted of the following:

Particulars Quantity Value (Rs.)

Raw Materials (including components)
Work-in-Process
Finished Goods
Stock in Trade
Stores and Spare Parts
Loose Tools
Others (specifying each major head separately)
Total

2. All quantities were determined by actual physical count or weight or measurement

that was taken under our supervision and in accordance with written instructions, on
(date/dates of physical verification), except as following cases:

S Particulars
r
1. .
2.

3. Inventories recorded in the books as at 31/03/20XX aggregating to Rs. are based

upon the physical inventories taken as at 31/03/20XX (date of physical verification)
by actual count, weight or measurement. The material discrepancies noticed on
physical verification of stocks as compared to book records have been properly dealt
with in the books of account and subsequent transactions recorded in the accounts
fairly reflect the changes in the inventories up to (balance sheet date), where
 physical verification of inventories is carried out at a date other than the closing
date.
4. All goods included in the inventory are the property of the entity, none of the goods
are held as consignee for others or as bailee, and, except as set out below, none of
the goods are subject to any charge.
5. Goods in Transit shown in the financial statements are correct and have been
included in the relevant head of the inventory item.
6. All inventories owned by the entity, wherever located, have been recorded, including
goods sent on consignment.
7. Inventories have been valued on as per Accounting Standard 2:

Particulars Basis
Raw Materials (including components)
Work-in-Process
Finished Goods
Stock in Trade
Stores and Spare Parts
Loose Tools
Others (specifying each major head separately)
(In describing the basis/bases of valuation, the method of ascertaining the cost (e.g. FIFO,
Average Cost or LIFO) should also be stated. Similarly, the extent to which overheads have
been included in the cost should also be stated.)
8. Adequate provisions have been made in respect of excess, slow-moving, damaged,
or obsolete inventories.
9. We confirm that no item of inventories has a net realizable value in the ordinary
course of business, which is less than the amount at which it is included in
inventories.
10. We confirm that the basis of valuation of inventories is same as that used in the
previous year.
11. The Company has maintained proper records of inventory and physical verification
has been carried out at reasonable intervals.
TRADE RECEIVABLES

1. All the trade receivables including receivables outstanding for more than six months
are considered good and fully recoverable with the exception of those specifically
shown as doubtful in the Balance Sheet. Adequate provision has been made for bad
and doubtful debts. Proper disclosures have been made in respect of secured and
unsecured receivables.
2. Trade Receivables ageing schedule is as under:

Outstanding for following periods from the date of

transaction
Trade Receivables
Less
6 months 1-2 2-3 More than
than 6 Total
-1 year years years 3 years
months
(i) Undisputed Trade
Receivables considered
good - - - -
(ii) Undisputed Trade
Receivables —
considered doubtful 0.00 - - 00.00
(iii) Disputed Trade
Receivables considered
good - - - -
(iv) Disputed Trade
Receivables considered
doubtful - - - - - -

Total 00.00 - - 00.00

3. In regard to trade receivables particulars has been given separately in respect of

following in the financial statements:
a) Debts considered good and in respect of which the company is fully secured.
b) Debts considered good for which the company holds no security other than
the debtor’s personal security, and
c) Debts considered doubtful or bad.
4. A separate disclosure has also been made in respect of following: Receivables due
by-
i. Directors or other officers of the company;
ii. Firms in which any director is a partner;
iii. Private companies in which any director is a director or a member.
5. Balance of trade receivables are subject to confirmation and reconciliation.
Consequential adjustment thereof, if any will be given effect in the books of account
in the year of such adjustment.
6. We confirm that there are no dues from related parties except those as disclosed in
the financial statements.
CASH & CASH EQUIVALENTS

1. We confirm that wherever there is a restriction from being exchanged or used to

settle a liability for at least twelve months after the reporting, the cash and cash
equivalents of the Company are classified into non-current and all other cash and
cash equivalents are classified as Current based upon the criteria as set out in
Schedule III to the Companies Act, 2013. Also, the requirements of the Accounting
Standards notified under Section 133 of the Companies Act, 2013 have been
considered while making such classification.
2. The total cash balance in hand of the Company as on 31st March, was Rs. _
.We confirm that the cash balance was lying with the authorized person as on
the Balance Sheet date.
3. There were no remittances in transit as on the date of the Balance Sheet.
4. Bank Balances as per the books of account are matching with the balances as per
Bank and wherever the same are not matching, a reconciliation statement has been
prepared. We confirm that items appearing in the Bank Reconciliation are cleared
subsequent to the Balance Sheet date.
5. Adequate interest provision has been made on the fixed deposits with Bank. We
confirm that all the fixed deposit receipts are lying with the authorized person and it
has no lien or charge other than those disclosed in the financial statements.
6. We confirm that -
a. There are no earmarked balances or money held as a margin money or security
against borrowing, guarantees etc., other than those which are disclosed in the
financial statements.
b. There are no restrictions on the use of cash or cash equivalents other than those
which are disclosed in the financial statements.
c. Bank deposits with more than 12 months maturity have been disclosed
separately.
STATEMENT OF PROFIT AND LOSS

1. We confirm that the statement of profit and loss have been prepared in accordance
with Schedule III to the Companies Act, 2013. Also, the requirements of the
Accounting Standards notified under Section 133 of the Companies Act, 2013 have
been followed while preparing the statement of profit and loss.
2. Except as disclosed in the financial statements, the results for the year were not
materially affected by:
a) Transactions of a nature not usually undertaken by the company;
b) Circumstances of an exceptional or non-recurring nature;
 c) Charges or credits relating to prior years;
d) Changes in accounting policies.
3. All the expenses and income have been accounted on accrual basis and adequate
provision have been made thereof.
4. Directors’ remuneration paid during the year is in accordance with and within the
ceiling prescribed by the Companies Act, 2013. We have completed all the necessary
formalities in this regard.
5. Income and expenses which are required to be shown separately as per the
requirement of Schedule III to the Companies Act, 2013 are shown separately in the
financial statements.
6. All the unusual, extraordinary and prior period items have been disclosed separately
in the financial statements.
CASH FLOW STATEMENT

1. The Cash Flow Statement has been prepared under the "Indirect Method" as set out
in the Accounting Standard - 3 on Cash Flow Statement notified under Section 133 of
the Companies Act, 2013.
2. Cash and Cash Equivalents at the end of the year consist of Cash in Hand and
Balances with Banks.
GENERAL

1. We have made available to you all the statutory financial records and related data
(including computer-generated records) and all the books of accounts maintained by
the Company.
2. The Company has maintained all the records, financial and statutory, as required by
the Companies Act, 2013. All the transactions and operations of the Company have
been fully recorded in the said records that are used as a basis for the preparation of
the financial statements.
3. There are no transactions that have not been properly recorded in the said
accounting records that are used as a basis for preparation of the financial
statements.
4. There have been no irregularities involving management or employees who have a
significant role in the system of internal control that could have a material effect on
the financial statements.
5. The financial statements are free of material misstatements, error or omissions.
6. The company has complied with all aspects of contractual agreements that could
have a material effect on the financial statements in the event of non-compliance.
There has been no non-compliance with requirements of regulatory nature that
 could have a material effect on the financial statements in the event of non-
compliance.
7. We have no plans or intentions that may materially affect the carrying value or
classification of assets and liabilities reflected in the financial statements.
8. All possible care has been taken to ensure the compliance of applicable provisions of
the Companies Act, 2013 and other laws governing the enterprise. There have been
no material violations of the applicable laws and regulations the effect of which
would result in an adjustment to the financial statements or may have to be
considered for disclosure of contingencies. All the disclosures required to be made
under the Companies Act, 2013 or otherwise have been duly made.
9. The disclosures given in notes to accounts in respect of requirements of Schedule III
to the Companies Act, 2013 are true and correct to the best of our knowledge and
belief and are complete in all respects.
10. The Company does not have benami property held in its name. There are no
proceedings being initiated or pending against the Company for holding any Benami
property under the Benami Transactions (Prohibition) Act, 1988 and rules made
there under.
11. There is no income surrendered or disclosed as income during the current or
previous year in the tax assessments under the Income Tax Act, 1961, that has not
been recorded in the books of account.
12. The Company is not declared as "willful defaulter" by any bank or financial institution
or other lenders.
13. The Company has neither traded nor invested in crypto currency or virtual currency
during the current or previous year.
14. The provisions of Corporate Social Responsibility as per Section 135 of the
Companies Act, 2013, are not applicable to the Company.
OR
The Company has constituted CSR Committee as per the provisions of section 135 of
the Companies Act, 2013 and all the relevant provisions given in the said section and
Companies (Corporate Social Responsibility Policy) Rules, 2014 are complied with.
CONTINGENT LIABILITIES

1. We have disclosed in notes to the accounts all the contingent liabilities as at 31st
March, 20XX. The details thereof are given hereunder.
a) Counter Guarantee given to Bank against their Bank Guarantee Rs.
b) Claims against the Company not acknowledged as debts
c) Disputed income tax/ sales tax liability contested in appeal
 d) Capital Commitments on account of capital contracts remaining to be executed
amounting to Rs.
e) Others (Specify the nature)
2. Contingent liabilities so disclosed do not include any contingencies that are likely to
result in a loss and which, therefore require adjustment of assets and liabilities.
3. At the balance sheet date, there were no outstanding commitments for capital
expenditure excepting those disclosed in Note___ to the financial statements.
4. We confirm that there are no contingent liabilities other than those which are
disclosed in the financial statements.
EVENTS OCCURRING AFTER THE BALANCE SHEET DATE

There have been no events subsequent to the balance sheet date which require
adjustment of, or disclosure in, the financial statements or notes thereto other than
those disclosed in the financial statements.
DISCONTINUING OPERATION

We confirm that during the year, none of the business of the Company has been
discontinued and hence no additional disclosures are required in accordance with
Schedule III to the Companies Act, 2013 and Accounting Standard – 24 on
“Discontinuing Operations”.
ACCOUNTING STANDARDS

The accounts of the Company have been prepared in compliance with various
mandatory Accounting Standards notified under Section 133 of the Companies Act,
2013.
RELATED PARTY DISCLOSURE

1. The transactions with all the related parties have been properly reflected in the
financial statements in accordance with the Accounting Standard-18 on “Related
Party Transactions”.
2. Name and Designation of the key management personnel are as under:

Sr. Name of the Person Designation

No.
1.
2.
3.
3. Name of the relatives and name of the enterprises having same key management
personnel and or their relatives as the reporting enterprises with whom the
Company has entered into transactions during the year are as under

Sr. Name of the Person/ Enterprise Relation

No.
1.
2.
3.

4. Name of the Holding / Subsidiary / Fellow Subsidiary/ Step down Subsidiary

Company

Sr. Name of the Company Relation

No.
1.
2.
3.

REPRESENTATIONS RELATED TO AUDITOR’S REPORT

1. The Company has maintained proper records showing full particulars including
quantitative details and situation of fixed assets and the Company has also
maintained fixed assets register as required to be maintained under the Companies
Act 2013.
2. The fixed assets have been physically verified by the management during the year at
reasonable intervals as per the phased programme of verification and no material
discrepancies have been noticed on such verification.
3. No substantial part of the fixed assets has been disposed off during the year which
affected the going concern assumption.
4. We confirm that the loans including loans to section 189 parties, taken/granted by
the Company are on call basis.
5. In case of loan to parties covered under section 183 of Companies Act, 2013, the
maximum amount outstanding during the year in respect of loan taken and granted
was Rs. & Rs. __respectively, and the year end balances in respect of loan
taken and granted was Rs. & Rs. respectively.
6. The rate of interest and other terms and conditions on the basis of which, the said
loans have been taken or granted are not prejudicial to the interest of the Company.
7. The particulars of contracts or arrangements entered into with related party and the
parties referred to in Section 189 of the Act have been entered in the register
required to be maintained in that Section.
8. The transactions made in pursuance of such contracts or arrangements have been
made at prices which are reasonable having regard to the prevailing market prices at
the relevant time.
9. The Central Government has not prescribed the maintenance of cost records under
Section 148(1) of the Companies Act, 2013 for the products that the Company
manufactures/ to the industry to which the Company pertains.
10. There is no undisputed amount payable in respect of any statutory liability.
11. The Company is generally regular in depositing undisputed statutory dues including
provident fund and employee’s state insurance dues, income tax, sales tax, goods
and service tax, custom duty, cess and other statutory dues with the appropriate
authorities. However, in some cases, delay in payments is there.
12. The company has no statutory dues which are outstanding as on 31st March, 20XX
for a period more than six months from the date they became payable
13. The details of disputed income tax, sales tax, service tax, goods and service tax,
custom duty, excise duty and cess are as under:

Nature of dues Assessment Amount Forum where

Year involved dispute is pending

14. Proper records have been maintained of the transactions and contracts and timely
entries have been made therein in respect of company’s dealing or trading in shares,
securities, debentures and other investments.
15. The Company has not defaulted in repayment of loans or borrowing to financial
institution, bank or Government. The Company has no dues payable to debenture
holders.
16. During the year the Company has not raised money by way of initial public offer or
further public offer (including debt instruments). The term loans availed by the
Company have been applied for the purposes for which those are raised.
17. The managerial remuneration paid or provided is in accordance with the requisite
approvals mandated by the provisions of section 197 read with Schedule V to the
Companies Act, 2013.
18. All transactions with the related parties entered into by the Company are in
compliance with sections 177 and 188 of the Companies Act, 2013 where applicable
and the details have been disclosed in the financial statements etc., as required by
the applicable accounting standards.
19. The Company has not made any preferential allotment or private placement of
shares or fully or partly convertible debentures during the year under review.
20. The Company has not entered into any non-cash transactions with directors or
persons connected with them.
21. No funds raised on short-term basis have been used for long-term investments
during the year.
22. The Company have not come across any instance of material fraud on or by the
company.
23. The Company is not a NBFC and hence not required to be registered under section
45-IA of the Reserve Bank of India Act, 1934.
INQUIRIES PURSUANT TO SECTION 143 (1) OF THE COMPANIES ACT, 2013

1. The terms and conditions on which loans and advances are made by the Company
are not prejudicial to the interest of the company or its members.
2. The Company has not made any loans and advances which are secured.
3. There are no transactions that are represented merely by book entries.
4. The Company has not sold any assets consisting of shares, debentures, and other
securities at a price less than at which they were purchased by the Company.
5. No loans and advances made by the Company are shown as deposits.
6. No personal expenses of directors and employees have been charged to revenue
account, other than that payable under contractual obligations or in accordance with
generally accepted business practice and legitimate business needs.
7. In respect of shares allotted during the year for cash, we confirm that cash has been
actually received in those cases.
DIRECTORS DISQUALIFICATION

None of the directors is disqualified as mentioned in section 164(2) of the Companies

Act, 2013. No director is liable to vacate the office under any of the clauses
mentioned in section 167(1)(a) of the Companies Act, 2013.
OTHER MATTERS RELATED TO AUDITOR’S REPORT: -

1. The pending litigation in the name of company is as below:

a) …
 b) ….
We ensure that the Company has disclosed the impact of the said litigations on its
financial position.
OR
The Company does not have any pending litigations which would impact its financial
position.
2. The Company has made provision, as required under any law or accounting
standards, for material foreseeable losses, if any, on long term contracts including
derivative contracts.
OR
The Company did not have any long-term contracts including derivative contracts for
which there were any material foreseeable losses.
3. There has been no delay in transferring amounts, required to be transferred, to the
Investor Education and Protection Fund by the Company.
OR
There were no amounts which were required to be transferred to the Investor
Education and Protection Fund by the Company.
4. The Company has not advanced or loaned or invested (either from borrowed funds
or share premium or any other sources or kind of funds) any funds, to any other
persons or entities, 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 (“Ultimate Beneficiaries”) by or on behalf of the Company or
• provide any guarantee, security or the like to or on behalf of the Ultimate
Beneficiaries.
5. The Company has not received any funds from any persons or entities, including
foreign entities (“Funding Parties”), with the understanding, whether recorded in
writing or otherwise, that the Company shall:
• directly or indirectly, lend or invest in other persons or entities identified in any
manner whatsoever (“Ultimate Beneficiaries”) by or on behalf of the Funding Party
or
•provide any guarantee, security or the like from or on behalf of the Ultimate
Beneficiaries."
6. The Company has neither declared nor paid any dividend during the year
For, XXXX INDIA PRIVATE LIMITED

______________
XXXXXXXXXXXXX
DIRECTOR

Place:
Date: