Ahluwalia Contracts (india) LimitedNSE: AHLUCONT

Annual Secretarial Compliance Report 2023-24. click here more details

· Issued by Ahluwalia Contracts (India) Limited

CS

SANTOSH KUMAR PRADHAN

COMPANY SECRETARIES

Secretarial Compliance Report

Of

Ahluwalia Contracts (India) Limited

(CIN: L45101DL1979PLC009654)

For the Financial Year

Ended 31st March, 2024

I have conducted the review of the compliance of the applicable statutory provisions and the adherence to

good corporate practices by Ahluwalia Contracts (India) Limited (CIN: L45101DL1979PLC009654)

(hereinafter referred to as the Listed Entity), having its Registered Office A-177, Okhla Industrial Area, Phase-I, New Delhi-110020. Secretarial Review was conducted in a manner that provided us a reasonable basis for evaluating the corporate conducts/statutory compliances and to provide our observation thereon.

Based on our verification of the listed entity's books, paper, minutes books, forms and returns filed and other records maintained by the listed entity and also the information provided by the listed entity, its officers, agents and authorized representatives during the conduct of Secretarial Review, I hereby report that the listed entity has, during the review period covering the financial year ended on 31st March, 2024 complied with the statutory provisions listed hereunder in the manner and subject to the reporting made hereinafter:

I, Santosh Kumar Pradhan, Company Secretary in Practice, have examined:

  1. All the documents and records made available to me and explanation provided by Ahluwalia Contracts (India) Limited (CIN: L45101DL1979PLC009654) (hereinafter referred to as the Listed Entity).
  2. The filling/ submissions made by the Listed Entity to the Stock Exchanges,
  3. Website of the Listed Entity,
  4. Any other document/ filling, as may be relevant, which has been relied upon to make this report for the Financial Year ended 31st March, 2024 ("Review Period") in respect of Compliance of the Provisions of:
    1. The Securities and Exchange Board of India Act, 1992 ("SEBI Act") and the Regulation, Circulars, Guidelines issued thereunder; and
    2. The Securities Contracts (Regulation) Act, 1956 ("SCRA"), rules made thereunder and the Regulations, Circulars, Guidelines issued thereunder by the Securities and Exchange Board of India ("SEBI");

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706, 8th Floor, K.M. Trade Tower, Hotel Radisson Blu, Kaushambi, Ghaziabad-U.P.-201010

Tel.: +91-9810278845,e-mail: pradhansantosh2006@yahoo.co.in

SANTOSH KUMAR PRADHAN

COMPANY SECRETARIES

The specific Regulations, who's Provisions and the Circulars/Guidelines issued thereunder, have been examined, include:-

  1. Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015;
  2. Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018:- Not applicable during the Review period.
  3. Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011;
  4. Securities and Exchange Board of India (Buyback of Securities) Regulations, 2018:- Not applicable during the Review period.
  5. Securities and Exchange Board of India (Share Based Employee Benefits and Sweat Equity) Regulations, 2021:- Not applicable during the Review period.
  6. Securities and Exchange Board of India (Issue and Listing of Non-Convertible Securities) Regulations, 2021:- Not applicable during the Review period.
  7. Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015;
  8. Securities and Exchange Board of India (Depositories and Participants) Regulations, 2018;

and circulars/ guidelines issued thereunder and based on the above examination, I hereby report that, during the Review Period:

  1. (a) The Listed Entity has complied with the provisions of the above Regulations and the Circulars/Guidelines issued thereunder, except in respect of matters specified below:

Sr.

Complianc Regulati

Deviatio

Action

Typ

Detai

Fine

Observ

Managemen

Rem

No

e

on/

ns

Taken

e of

ls of

Amou

ations/

t Response

arks

.

Requirem Circular

by

Acti

Viola

nt

Remar

ent

No.

on

tion

ks of

(Regulat

the

ions/ci

Practici

rculars

ng

/

Compa

guideline

ny

s

Secreta

includin

ry

specific

clause)

Page 2 of 7

1

SEBI

Listed Entit

Listed

LODR

are require

Entity

Regulatio

to submit a

has not

s,

the

submitte

2015

Disclosure

on

relate

d its

party

related

party

transaction

s every

si

transacti

months

o

on

the

date

o

report

publication

for the

of

it

six

standalone

&

months

consolidate

ended

  • financia 31st

results March, as per 2023 Regulatio

n 23(9) of within

LODR the

stipulate d time period.

SANTOSH KUMAR PRADHAN

COMPANY SECRETARIES

Nation Fine

Delay

Rs.

The

The Listed

Nil

al

in

5,900

Listed

entity has

Stock

subm

/-

entity

approve its

Exchan

ission

(inclu

has

financial

ge

of

sive of

submitt

results for

(NSE)

Relat

GST)

ed the

the year

and

ed

by

related

ended 31st

Bomba

y Stock

Party

both

party

March, 2023

Exchan

trans

the

transact

on 27th May,

ge

actio

Stock

ion

2023 and

(BSE)

n

Excha

report

submitted

repor

nges

in XBRL

the report to

t for

respec

format

both Stock

the 6

tively.

with

Exchanges in

mont

BSE &

PDF file on

hs

NSE on

the same day

ende

29th

and next day,

d 31st

May,

being

Marc

2023

Sunday, the

h,

instead

listed entity

2023.

of 27th

submitted

May,

the XBRL file

2023 as

on Monday,

require

29th May,

d under

2023.

Regulati

on

23(9) of

LODR.

The Listed Entity has received Letters, clarifications and E-mails from the Stock Exchanges, which were duly replied by the Company during the period under review:

  1. The listed entity has taken the following actions to comply with the observations made in previous reports:

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SANTOSH KUMAR PRADHAN

COMPANY SECRETARIES

Sr.

Complianc Reg

Devia

Actio

Type

Details

Fine

Observations/Rema

Mana

Re

No

Requirem

ulati

tions

n

of

of

Amo

rks of the practicing

geme

mar

.

nt

on/

Take

Actio

Violati

unt

Company Secretary

nt

ks

(Regulatio Circ

n by

n

on

Respo

ns/

ular

nse

circulars/

No.

guidelines

including

specific

clause)

N.A

N.A

N.A

N.A

N.A

N.A

N.A

The Listed Entity was

N.A

Nil

not

required

to

take

any

action

as

per

observations

of

previous

year's

reports

as the

same

was already complied

by

the

Listed Entity

before

the

issue of

previous year's report.

  1. The provisions of Para 6 of Circulars no. CIR/CFD/CMD1/114/2019 issued by SEBI on 18th October, 2019 in terms of resignation of Statutory Auditors are not applicable on the Listed Entity during the Review Period as there was no change in Auditors of the Company during the Review Period.
  1. I further report that during the review period, the compliance status of the Listed entity as required under NSE Circular Ref No: NSE/CML/2023/21 dated 16th March, 2023 & NSE/CML/2023/30 dated 10th April, 2023 and the BSE Circular No. 20230316-14 dated 16th March, 2023 & 20230410-41 dated 10th April, 2023, are annexed as Annexure-A to the report.

Assumptions & Limitation of Scope and Review:

  1. Compliance of the applicable laws and ensuring the authenticity of documents and information furnished, are the responsibilities of the management of the listed entity.
  2. Our Responsibility is to report based upon our examination of relevant documents and information. This is neither an audit nor an expression of opinion.
  3. We have nor verified the correctness and appropriateness of Financial Records and Books of Accounts of the listed entity.
  4. This Report is solely for the intended purpose of compliance in terms of Regulation 24A (2) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 and is neither an assurance as to the future viability of the listed entity nor of the efficacy or effectiveness with which the management has conducted the affairs of the listed entity.

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SANTOSH KUMAR PRADHAN

COMPANY SECRETARIES

For Santosh Kumar Pradhan

Place: GhaziabadCompany Secretaries

Date: 27.05.2024

Santosh Kumar Pradhan

Proprietor

C. P. No. : 7647

FCS No. F6973

P.R. No. 1388/2021

UDIN: F006973F000462439

ANNEXURE-A

I hereby report that, during the Review Period the compliance status of the listed entity is appended as below:

Sr.

Particulars

Complian

Observations

No.

ce Status

/Remark by

(Yes/No/

PCS

NA)

  1. Secretarial Standard:
    The compliances of listed entity are in accordance with the applicable Secretarial Standard (SS) issued by the Institute of Company Secretaries India (ICSI), as notified by the Central Government under section 118(10) of the Companies Act,2013 and mandatorily applicable.
  2. Adoption and timely Updation of Policies:
    • All applicable policies under SEBI Regulations are adopted with the approval of board of directors of the listed entities.
    • All the policies are in conformity with SEBI Regulations and have been reviewed & updated on time, as per the regulations/circular/ guidelines issued by SEBI.
  4. Maintenance and disclosure on website:
    • The listed entity is maintaining a functional website
    • Timely dissemination of the documents /information under a separate section on the website.
    • Web-linksprovided in annual corporate governance reports under Regulation 27(2) are accurate and specific

Yes

Yes

Yes

Nil

Nil

Nil

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SANTOSH KUMAR PRADHAN

COMPANY SECRETARIES

which re-directs to the relevant document(s)/section of the website.

4. Disqualification of Director:

None of the Director of the Company are disqualified under

Yes

Nil

section 164 of the companies Act, 2013 as confirmed by the

listed entity.

5.

Details related to subsidiaries of listed entities have been

The

Company

examined w.r.t.:

Yes

does

not

have

(a) Identification of material subsidiary companies.

any

material

(b) Disclosure requirement of material as well as other

subsidiary

subsidiaries.

during

the

review period.

6.

Preservation of Documents:

The listed entity is preserving and maintaining records as

Yes

Nil

prescribed under SEBI Regulations and disposal of records as

per Policy of Preservation of Documents and Archival Policy

prescribed under SEBI LODR regulations, 2015.

7.

Performance Evaluation:

The listed entity has conducted performance evaluation of the

Yes

Nil

Board, Independent Directors and the committees at the start

of every financial year as prescribed in SEBI Regulations.

8.

Related party Transactions:

(a) The listed entity has obtained prior approval of Audit

Committee for all related party transactions; or

Yes

Nil

(b) The listed entity has provide detailed reasons along with

confirmation whether the transactions were subsequently

approved/ratified/rejected by the Audit Committee, in case no

prior approval has been obtained.

9.

Disclosure of events or information:

The listed entity has provided all the required disclosure(s)

Yes

Nil

under Regulation 30 along with Schedule III of SEBI LODR

Regulation, 2015 within the time limits prescribed thereunder.

10. Prohibitions of insider Trading:

The listed entity is in compliance with Regulation 3(5) & 3(6)

Yes

Nil

SEBI (Prohibition of Insider Trading) Regulations, 2015.

11.

Actions taken by SEBI or Stock Exchange(s), if any:

No

BSE & NSE

imposed fine of

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SANTOSH KUMAR PRADHAN

COMPANY SECRETARIES

No Action has been taken against the listed entity/ its

Rs.

5,900/-

on

promoters/directors/subsidiaries either by SEBI or by Stock

the

Listed

Exchanges (including under the Standard Operating

Entity

as

procedures issued by SEBI through various circulars) under

mentioned

SEBI Regulations and circulars/guidelines issued thereunder

under Clause I

except as provided under separate paragraph herein.

(a) above.

12.

Additional Non- compliance, if any:

No additional non-compliance observed for any SEBI Yes

Nil

regulation/circular/guidance note etc.

For Santosh Kumar Pradhan

Place: GhaziabadCompany Secretaries

Date: 27.05.2024

Santosh Kumar Pradhan

Proprietor

C. P. No. : 7647

FCS No. F6973

P.R. No. 1388/2021

UDIN: F006973F000462439

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