p) Accounting for Provisions, Contingent Liabilities and Contingent Assets:

Provisions are recognized when the Company has a present obligation (legal or constructive) as a result of a past event, it
is probable that an outflow of resources embodying economic benefits will be required to settle the obligation and a reliable
estimate can be made of the amount of the obligation. The expense relating to a provision is presented in the statement of
profit or loss net of any reimbursement. If the effect of the time value of money is material, provisions are discounted using
a current pre-tax rate that reflects, when appropriate, the risks specific to the liability. When discounting is used, the increase
in the provision due to the passage of time is recognized as a finance cost.

A contingent liability is disclosed when:

(a) a possible obligation that arises from past events and whose existence will be confirmed only by the occurrence or non¬

occurrence of one or more uncertain future events not wholly within the control of the Company; or

(b) a present obligation that arises from past events but is not recognized because:

(i) it is not probable that an outflow of resources embodying economic benefits will be required to
settle the obligation; or

(ii) the amount of the obligation cannot be measured with sufficient reliability.

A contingent asset is disclosed, when there is a possible asset that arises from past events and whose existence will be

confirmed only by the occurrence or non-occurrence of one or more uncertain future events not wholly within the control

of the Company.

Contingent liabilities and assets are not recognized but are disclosed in notes.

NOTES ON ACCOUNTS:

1. COMMITMENTS:

Estimated amount of Contracts remaining to be executed on capital account-Rs. NIL (Rs. NIL)

2. CONTINGENT LIABILITIES:

A. No provision has been made for:

a. Outstanding effective Bank Guarantees and Counter Guarantees given by the Company Rs. NIL (PY Rs.40,17,112/-.

b. Outstanding Letter of Credit Rs. -NIL- (PY Rs. NIL)

c. VAT / Sales Tax liability for various years in respect of which the Company has filed appeals with higher authority
amounts to Rs.5,16,45,541/-. Most of the demands have been stayed by concerned authorities and the Company is
confident to get relief. Further, Cases which have been awarded in favor of the Company against which department
has filed appeals /revision petition amounts to Rs.10,64,73.573/.

d. Excise/Service tax cases pending with various statutory authorities being disputed principal amount Rs.7,67,29,699/-.
The Company is Confident to get relief and chances of any liability is very remote.

e. GST cases pending with various statutory authorities being disputed principal amount Rs. 3,40,33,408. In some cases,
appeals/writ have been filed and demands are stayed. Company is further evaluating legal options and is confident of
getting the demands set aside in such matters.

f. Civil/Recovery suits and Labour cases pending against the Company not acknowledged as debt -Rs.12,78,48,416/-
(Rs.12,48,10,916/-).

g. As per Sales Agreement between GAIL and Company for Gas, GAIL has been raising demand in relation to annual
take or pay deficiency which the Company has disputed on numerous occasions. After representation by the company,
a Settlement Advisory Committee (“SAC”) has been appointed under the GAIL Conciliation Rules 2010 with mutual
consent of both parties to settle the disputes. Reconciliation proceedings are at final stages of conclusion. The company
is quite confident to get the dispute settled, and liability, if any, arises may not have material effect on the financial
position of the Company.

B. Income Tax and Sales Tax Assessments:

Company has disputed following orders and filed Appeals before the appropriate appellate authorities. The company is

quite confident to get the additions / demands dismissed.

a) Assessing officer (TDS) has imposed penalty and late fees towards delay in TDS deposited and
late fees for issuance of relevant forms during FY 2013-14 and raised demand of Rs.11,84,600/-

b) Assessing officer passed order u/s 147 r.w.s. 144B of Income Tax Act with addition of Rs.10,20,31,713/ was made
in matter relating to AY 2013-14. Further the amount of the addition has been adjusted with carry forwarded losses
by the AO.

c) Assessing officer passed order u/s 143(3) of Income Tax Act with addition of Rs.1,67,86,560/ was made in matter
relating to AY 2019-20. Further the amount of the addition has been adjusted with carry forwarded losses by the
AO.

d) Assessing officer passed order u/s 143(3) of Income Tax Act with addition of Rs.45,62,369/- was made in matter
relating to AY 2021-22 and raised demand of Rs.14,23,459/-. However, company has filed application for
rectification of the order for adjustment of the addition amount with carry forward losses of the company.

e) Assessing officer passed order u/s 143(3) of Income Tax Act with addition of Rs.7,76,289/- was made in matter
relating to AY 2022-23 and raised demand of Rs.2,42,202/-. However, company has filed application for
rectification of the order for adjustment of the addition amount with carry forward losses of the company.

f) Income Tax department has filed appeal with Income Tax Appellate Tribunal for AY 2017-18 in matter of addition
Rs.5,78,26,377/- made by AO which were deleted by CIT-Appeal and allowed the Appeal in favor of Company.

g) Company has disputed these orders and filed Appeals before the appropriate appellate authorities. The company is
quite confident to get the additions / demands dismissed. Additional liability, if any, in respect of pending
assessments / appeals of Income Tax, compounding application, would be provided for on completion of assessments
/ disposal of appeals/ applications.

h) Any additional demand, if any, in view of fines, penalty and interest in respect of others matters above, as would be
known only on outcome / conclusion of such matters and have not been considered.

3. SEGMENTAL REPORTING:

The business activity of the company falls within one broad segment viz Steel. Hence the disclosure requirement of
Accounting Standard (Ind-AS 108) of “Segment Reporting” issued by the Institute of Chartered Accounts of India is not
given.

4. FOREIGN CURRENCY TRANSACTIONS:

Expenditure in Foreign Currency:

a. Raw material purchase (CIF) Rs.27,99,00,589/ (PY Rs. 58,54,21,625/-)

b. Capital Goods (CIF) - Rs. 64,76,985/- (PY Rs. NIL)

c. Stores Purchased (CIF)- Rs. 79,08,506/- (PY Rs.1,10,60,294/-)

5. PAYMENT TO AUDITORS:

a. Audit Fee - Rs.4,00,000/- (PY Rs.4,00,000)

b. Certification Fees - Rs.2,00,000/- (PY Rs. 92,000)

6. Sundry debtors, advances, creditors & other liabilities include inter parties transfers and are subject to confirmation and
consequent adjustments. In the opinion of the Board of Directors, the current assets and loans & advances except doubtful in
nature would realize at least the amount at which these are stated in the Balance Sheet. For doubtful debts, the Board of
Directors is very much hopeful for their recovery. Therefore, no provision during the year has been made.

7. Interest / Penalty, if any on delayed payments of statutory dues (Excise, GST, PF/ESI etc.) will be provided for as and when
ascertained / determined by the concerned authority.

8. The MSME status of creditors is not in knowledge of the Company as per available records even after adequate efforts.

9. The Company during the period under report adopted direct charging method to manufacture the products from billets in
order to save on net energy costs (power & fuel) /yield/ other expenses etc.

10. During the year Company has availed working capital facilities and TL from Kotak Mahindra Bank Ltd to meet its working
capital requirements. Further the Company is exploring various other financing options with prospective Lenders to meet
additional working capital and long term financial requirements of the company including reduction in costs of borrowings.

11. EARNINGS PER SHARE (EPS):

Basic EPS is calculated by dividing the profit or loss attributable to equity shareholders of the Group by the weighted average
number of equity shares outstanding during the year.

Diluted earnings per share are computed by dividing the profit after tax as adjusted for dividend, interest and other charges
to expense or income (net of any attributable taxes) relating to the dilutive potential equity shares considered for deriving
basic earnings per share and the weighted average number of equity shares which could have been issued on conversion of
all dilutive potential equity shares.

18. Surety given for others, amount not ascertained as company has not maintained any such records.

19. Company have not paid any dividend on nun cumulative Preference Shares during the year.

20. Company has purchased second hand vehicles during the year and registration of three vehicles are yet to get transferred in
name of the Company however applicable depreciation is charged on the same.

21. The amount of Stores consumed during the financial year includes the value of stores issued for repair and maintenance.

22. Previous year figures have been regrouped or recast wherever necessary.

As per our Report of even date
For M. Lal & Co.

Chartered Accountants

Firm Registration Number: 016069C

Sd/- Sd/- Sd/-

Abhishek Verma Mahesh Pareek M.L. Agrawal

Director Managing Director Proprietor

DIN-08104325 DIN-00174146 M. No. 011148

UDIN: 25011148BMIXTC9932

Sd/- Sd/-

Shobhita Singh Rajeev Kumar

Company Secretary CFO

Place: New Delhi
Dated: 30.05.2025