Current Report |
| Sr No | Compliance requirement (regulations/circulars/ guidelines including specific clauses) | Regulation Name/ SEBI Circular number | Regulation Number/ circular dated | Deviations | Action taken by | Name of Other Regulatory Body | Type of Action (Advisory/Clarification/Fine/Show Cause Notice/ Warning, etc.) | Details of other action taken | Details of violation | Fine Amount | Observations/remarks of the practising Company Secretary, if any | Management Response | Remarks |
| 1 | Regulation 17 (1) (a)
and 17 (1)(b) of SEBI
(Listing Obligations
and Disclosure
Requirement) 2015 | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Regulation 17(1) (a)and (b) | No woman director is
appointed.
Further, half of the
board of listed entity
do not comprise of
Independent
Director | Other Regulatory Body | No Action Taken by any Regulatory Body | Other | No Action Taken by any Regulatory Body | No woman director is
appointed.
Further, half of the
board of listed entity do
not comprise of
Independent Director | | The Default for appointing
woman director and
Independent Director on the
board is waived by NCLT order
No.3638/2018 dated April 26,
2019.
Further, since exemption of
appointment of Independent
Director and Woman Director
are availed by the listed entity
as mentioned above, they have
not complied with the following
regulations:
a) Regulation 18-Composition
of Audit Committee
b) Regulation 19-Composition
of Nomination and
Remuneration committee
c) Regulation 20-Composition
of Stakeholders
Relationship Committee
d) Regulation 25: Obligations
with respect to
Independent Directors | The listed entity has been
granted exemption by NCLT
vide its Order No. 3638/2018
dated April 26, 2019 from
appointment of
Independent and Woman
Director which is still
subsisting. The Stock
Exchanges have been
informed about the same. | |
| 2 | Regulation 21 of
SEBI (Listing
Obligations and
Disclosure
Requirement) 2015 | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Regulation 21 | Risk Management
Committee was
required to be
constituted.
The said regulations
are applicable to the
listed entity due to
high value debt | Other Regulatory Body | No Action Taken by any Regulatory Body | Other | No Action Taken by any Regulatory Body | Risk Management
Committee was
required to be
constituted. | | Risk Management Committee is
required to be constituted only
on account of High Value Debt
Listed Entity and not as Equity
Listed Entity, since it does not
fall within Top 1000 Companies | The NCDs issued by the
Company are no longer to be
serviced by the Company
pursuant to the Moratorium
Order issued by the National
Company Law Appellate
Tribunal on October 15,
2018. The Payments to all
the Creditors including NCD
holders will be made as per
the resolution plan of IL&FS
group companies including
the Company, where upon
final distribution of funds will
be made to the Creditors
including NCD holders.
In view thereof, the
provisions of this regulation
may not apply.
In addition, the new Board of
IL&FS appointed by the
Union of India effective
October 1, 2018 implements
certain key initiative to
protect the interest of the
stakeholders of IL&FS group
in order to mitigate the risk
faced by the companies. | |
| 3 | Regulation 23(9) of
SEBI (Listing
Obligations and Disclosure
Requirement) 2015 | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Regulation 23 (9) | The said disclosures
for the
half year ended 31st March, 2023 and
30th September,
2023 were not
submitted to the
Stock Exchange | Other Regulatory Body | No Action Taken by any Regulatory Body | Other | No Action Taken by any Regulatory Body | The said disclosures
for the half year ended
31st March, 2023 and
30th September, 2023 were not submitted to
the Stock Exchange | | Under Section 130 of the
Companies Act, the NCLT
passed an order, dated January
1, 2019, directing the Company to re- open and recast the
financial accounts for FY 2013-
14 to FY 2017-
18. The recasted financial
statements were then filed with
NCLT. The Hon’ble NCLT vide its
order pronounced on June 28,
2024 and August 9, 2024, has
taken on record the re-opened
and re-casted standalone
financial statements of the
Company for FY 2013-14 to FY
2017-18.
Subsequently, a petition was
filed by the Company before
the NCLT on January 9, 2024
seeking approval for
undertaking voluntarily revision
of the financial statements for
FY 2018-2019 and FY 2019-2020
to give impact arising from
recasted financial statements.
The Hon’ble NCLT vide order
dated March 7, 2025 has
approved the revision of the
financial statements for FY
2018-2019 and FY 2019-2020.
In view the same, the Company
was not able to prepare the
financial statements from FY
2019-20 onwards | Pursuant to an application
filed by Union of India under
Section 130 of the
Companies Act, the NCLT passed an order, dated
January 1, 2019, permitting
re- opening and recasting of
the financial accounts of the
Company for FY 2013-14 to
FY 2017-18. The recasted
financial statements were
then filed with NCLT. In view
thereof, the Hon’ble NCLT
vide its order pronounced on
June 28, 2024 and August 9,
2024, has taken on record
the re-opened and re-casted
standalone financial
statements of the Company
for FY 2013-14 to FY 2017-
18.
Subsequently, a petition was
filed by the Company before
the NCLT on January 9, 2024
seeking approval for
undertaking voluntarily
revision of the financial
statements for FY 2018-2019
and FY 2019-2020 to give
impact arising from recasted
financial statements. The
Hon’ble NCLT vide order
dated March 7, 2025 has
approved the revision of the
financial statements for FY 2018-2019 and FY 2019-
2020. Accordingly, the
Company will now be taking
up the preparation of the
financial results for the same
and comply with the
requirement of the
Regulations in this regard | |
| 4 | Regulation 24 (1) of
SEBI (Listing
Obligations and
Disclosure
Requirement) 2015 | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Regulation 24 (1) | Appointment of
Independent
Directors on
the board of
of Unlisted material
Subsidiaries | Other Regulatory Body | No Action Taken by any Regulatory Body | Other | No Action Taken by any Regulatory Body | Appointment of
Independent
Directors on
the board of
of Unlisted material
Subsidiaries | | Based on the audited
consolidated financial
statements for the year ended
31st March 2018, there were no
material subsidiaries of the
listed entity requiring
appointment of Independent
Directors.
Subsequent thereto the listed
entity has not
prepared/approved the
consolidated financial
statements for the subsequent
financials years for reasons
stated in Sl No. 3 above. In view
of the above position, we are
unable to identify material
subsidiaries of the listed entity | The same as stated in
observations of PCS. Further,
pursuant to the NCLT Order
dated April 26, 2019 which is
valid and subsisting as on
date, the requirement of
appointment of
Independent Directors has
been waived. | |
| 5 | Regulation 29(1)(a)
and 50 (1) (c) of SEBI
(Listing Obligations
and Disclosure
Requirement) 2015 | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Regulation 29(1)(a) | Since the financial
results for the all the
quarters for the FY
2023-24 were not
placed before the
board for approval
hence the said
intimation was not
given to designated
stock exchanges | Other Regulatory Body | No Action Taken by any Regulatory Body | Other | No Action Taken by any Regulatory Body | Prior intimation was not
given to designated
stock exchanges with
respect proposal for
considering financial
results viz. quarterly,
half yearly, or annual. | | For the reasons stated herein
above at Sr. No.3, the listed
entity has not complied with
the said regulation | For the reasons stated
herein above at Sr. No.3, the
listed entity was unable to
comply with this regulation | |
| 6 | Regulation 33, 52
read with 54 of SEBI
(Listing Obligations
and Disclosure
Requirement) 2015 | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Regulation 33, 52 read with 54 | The listed entity has
not complied with
the regulations with
respect to submitting
the financials results
to the Stock
Exchange for all the
Quarter’s as well as
audited financial
statements for the
year ended March
31, 2025
Further, along with
the financials results,
listed entity has not
submitted the
additional
disclosures or details
as required to be
submitted alongwith the results/financial
statements under
the said regulations | Stock Exchange | | Fine | | The listed entity has not
complied with the
regulations with respect
to submitting the
financials results and
other additional
disclosures to the Stock
Exchange for all the
Quarter’s as well as
audited financial
statements for the year
ended March 31, 2025 | 4103450 | For the reasons stated herein
above at Sr. No.3, the listed
entity has not complied with
the said regulation | For the reasons stated
herein above at Sr. No.3, the
listed entity was unable to
comply with this regulation | |
| 7 | Regulation 34 and
53 of SEBI (Listing
Obligations and
Disclosure
Requirement) 2015 | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Regulation 34 and 53 | The listed entity has
not complied with
the regulation | Stock Exchange | | Fine | | The listed entity has not
complied with the
regulation | 198240 | For the reasons stated herein
above at Sr. No.3, the listed
entity has not complied with
the said regulation | For the reasons stated
herein above at Sr. No.3, the
listed entity was unable to
comply with this regulation | |
| 8 | As per Regulation 46
& 62(b) of SEBI
(Listing Obligation &
Disclosure
Requirements)
regulations, 2015 | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Regulation 46 (2)(l) & Regulation 62(b) | The listed entity has
not uploaded
following details on
its website:
I. Financial
information
including.
(i) notice of meeting
of the board of
directors where
financial results shall
be discussed; (ii)
financial results (iii)
complete copy of the
annual report. | Other Regulatory Body | No Action Taken by any Regulatory Body | Other | No Action Taken by any Regulatory Body | The listed entity has not
uploaded following
details on its website:
I. Financial
information
including.
(i) notice of meeting of
the board of directors
where financial results
shall be discussed; (ii)
financial results (iii)
complete copy of the
annual report. | | For the reasons stated herein
above at Sr. No.3, the listed
entity has not complied with
the said regulation | For the reasons stated
herein above at Sr. No.3, the
listed entity was unable to
comply with this regulation | |
| 9 | Regulation 47(1)(b)
& 52(8) of SEBI
(Listing Obligations and Disclosure
Requirement) 2015
Regulations, 2015 | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Regulation 47(1)(b) & 52(8) | The listed entity has
not published the
financial results for
all the Quarters as the same as well as
financial results for
the year ended 31st
March, 2025. | Other Regulatory Body | No Action Taken by any Regulatory Body | Other | No Action Taken by any Regulatory Body | The listed entity has not
published the financial
results for all the
Quarters as the same as well as financial results
for the year ended 31st
March, 2025 as the
same were not placed
before the Board of the
listed entity for their
approval. | | For the reasons stated herein
above at Sr. No.3, the listed
entity has not complied with
the said regulation | For the reasons stated
herein above at Sr. No.3, the
listed entity has not complied with the said
regulation. | |
| 10 | Regulation 54 of of
SEBI (Listing
Obligations and
Disclosure
Requirement) 2015 | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Regulation 54 | The listed entity has
not maintained
hundred per cent
security cover or
higher security cover
sufficient to
discharge the
principal amount
and the interest
thereon
at all times for the
non-convertible debt
securities issued.
Further, since the
results have not been
approved and
intimated to Stock
exchanges, the
disclosures with
respect to security
coverage have not
been complied with. | Other Regulatory Body | No Action Taken by any Regulatory Body | Other | No Action Taken by any Regulatory Body | The listed entity has not
maintained hundred per
cent security cover or
higher security cover
sufficient to discharge
the principal amount
and the interest thereon
at all times for the nonconvertible
debt
securities issued.
Further, since the
results have not been
approved and intimated
to Stock exchanges, the
disclosures with respect
to security coverage
have not been complied
with | | The listed entity has not
maintained hundred per cent
security cover or higher security
cover sufficient to discharge the
principal amount and the
interest thereon at all times for
the non-convertible debt
securities issued.
Further, since the results have
not been approved and
intimated to Stock exchanges,
the disclosures with respect to
security coverage have not
been complied with. | Post the Moratorium Order
issued by the National
Company Law Appellate
Tribunal on October 15,
2018, all the NCDs issued by
the Company stand
defaulted as the payments
for settlement of dues of all
the creditors of the
Company will be made as per
the resolution plan by way of
distribution of proceeds to
be received.
Further as explained in point
3, the Financials of the
Company are not being
prepared and therefore the
required information could
not be submitted.
The Stock Exchanges have
been kept informed of this
with reasons from time to
time. | |
| 11 | Regulation 61(1) of
SEBI (Listing
Obligation &
Disclosure
Requirements)
Regulations, 2015-
The listed entity
shall ensure timely
payment of interest
The listed entity
shall ensure timely
redemption
payment.
The listed entity
shall ensure timely
payment of dividend
of non-convertible
redeemable
preference share | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Regulation
61(1) | The listed entity has
not paid interest on
Non-Convertible
Debentures due for
the financial year
ended 31st March,
2025.
The listed entity has
not redeemed the
Non - Convertible
Debentures failing
due during the F.Y
2024-25.
The listed entity has
not paid dividend on
Cumulative Non-
Convertible
redeemable
preference shares in
the F.Y 2024-25.
The listed entity has
not redeemed
Cumulative Non-
Convertible
Redeemable
Preference Shares in
the F.Y 2024-25. | Other Regulatory Body | No Action Taken by any Regulatory Body | Other | No Action Taken by any Regulatory Body | The listed entity has not
paid interest on Non-
Convertible Debentures
due for the financial
year ended 31st March,
2025.
The listed entity has not
redeemed the Non -
Convertible Debentures
failing due during the FY
2024-25.
The listed entity has not
paid dividend on
Cumulative Non-
Convertible redeemable
preference shares in the
financial year 2024-25.
The listed entity has not
redeemed Cumulative
Non-Convertible
Redeemable
Preference Shares in the
financial year 2024-25. | | During the year under review,
the listed entity, has made the
payments to all the NCD’s
holders as a part of Interim
Distribution process, and the
same has been intimated to
Stock exchanges.
Further the default intimation
has also been given to stock
exchanges. | During the year under
review, the listed entity, has
made the payments to all the
NCD’s holders as a part of
Interim Distribution process,
and the same has been
intimated to Stock
exchanges. | |
Previous Report |
| Sr No | Compliance requirement (regulations/circulars/ guidelines including specific clauses) | Regulation Name/ SEBI Circular number* | Regulation Number/ circular dated | Deviations | Actions taken by | Name of Other Regulatory Body | Type of Action (Advisory/Clarification/Fine/Show Cause Notice/ Warning, etc.) | Details of other action taken | Details of violation | Fine Amount | Observations of the practicing Company secretary in the previous reports | Observations made in the secretarial compliance report for the year ended.(the years are to be mentioned) | Comments of the practicing company secretary on the actions taken by the listed entity. | Remedial actions, if any, taken by the listed entity | Management Response | Remarks |
| 1 | Regulation 17 (1) (a) and
17 (1)(b) of SEBI (Listing
Obligations and
Disclosure Requirement)
2015 | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Regulation 17 (1) (a) and
17 (1)(b) | No woman director is
appointed. | Other Regulatory Body | No Action Taken by any Regulatory Body | Other | No Action Taken by any Regulatory Body | No woman director is
appointed.
Further, half of the
board of listed entity
do not comprise of
Independent Director. | | The Default for appointing
woman director and
Independent Director on the
board is waived by NCLT
order No.3638/2018 dated
April 26, 2019.
Further, since exemption of
appointment of Independent
Director and Woman
Director are availed by the
listed entity as mentioned
above, they have not
complied with the following
regulations:
a) Regulation 18-
Composition of Audit
Committee
b) Regulation 19-
Composition of
Nomination and
Remuneration
committee
c) Regulation 20-
Composition of Stakeholders
Relationship Committee
Regulation 25: Obligations
with respect to Independent
Directors | 31st March, 2024 | The listed entity has been
granted exemption by
NCLT vide its Order No.
3638/2018 dated April 26,
2019 from appointment of
Independent and Woman
Director which is still
subsisting. The Stock
Exchanges have been
informed about the same. | The listed entity has been
granted exemption by NCLT
vide its Order No. 3638/2018
dated April 26, 2019 from
appointment of Independent
and Woman Director which is
still subsisting. The Stock
Exchanges have been informed
about the same. | The listed entity has been
granted exemption by NCLT
vide its Order No. 3638/2018
dated April 26, 2019 from
appointment of Independent
and Woman Director which is
still subsisting. The Stock
Exchanges have been informed
about the same. | |
| 2 | Regulation 21 of SEBI
(Listing Obligations and
Disclosure Requirement)
2015. | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Regulation 21 | Risk Management
Committee was
required to be
constituted. | Other Regulatory Body | No Action Taken by any Regulatory Body | Other | No Action Taken by any Regulatory Body | Risk Management
Committee was
required to be
constituted. | | Risk Management
Committee is required to be
constituted only on account
of High Value Debt Listed
Entity and not as Equity
Listed Entity, since it does not
fall within Top 1000
Companies. | 31st March, 2024 | The payments to all the
Creditors including NCD
holders will be made as per
the resolution plan of IL&FS
group companies including
the Company, where upon
final distribution of funds
will be made to the
Creditors including NCD
holders. In addition, the
new Board of IL&FS
appointed by the Union of
India effective October 1,
2018 implements certain
key initiative to protect the
interest of the stakeholders
of IL&FS group in order to
mitigate the risk faced by
the companies | The NCDs issued by the
Company are no longer to be
serviced by the Company
pursuant to the Moratorium
Order issued by the National
Company Law Appellate
Tribunal on October 15, 2018.
The payments to all the
Creditors including NCD holders
will be made as per the
resolution plan of IL&FS group
companies including the
Company, where upon final
distribution of funds will be
made to the Creditors including
NCD holders.
In view thereof, the provisions
of this regulation may not
apply.
In addition, the new Board of
IL&FS appointed by the Union
of India effective October 1,
2018 implements certain key
initiative to protect the interest
of the stakeholders of IL&FS
group in order to mitigate the
risk faced by the companies | The NCDs issued by the
Company are no longer to be
serviced by the Company
pursuant to the Moratorium
Order issued by the National
Company Law Appellate
Tribunal on October 15, 2018.
The payments to all the
Creditors including NCD holders
will be made as per the
resolution plan of IL&FS group
companies including the
Company, where upon final
distribution of funds will be
made to the Creditors including
NCD holders.
In view thereof, the provisions
of this regulation may not
apply.
In addition, the new Board of
IL&FS appointed by the Union
of India effective October 1,
2018 implements certain key
initiative to protect the interest
of the stakeholders of IL&FS
group in order to mitigate the
risk faced by the companies | |
| 3 | Regulation 23(9) of SEBI
(Listing Obligations and
Disclosure Requirement)
2015. | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Regulation 23(9) | The disclosures for the
half year ended 31st
March, 2023 and 30th
September, 2023 were
not submitted to the
Stock Exchange | Other Regulatory Body | No Action Taken by any Regulatory Body | Other | No Action Taken by any Regulatory Body | The disclosures for the
half year ended 31st
March, 2023 and 30th
September, 2023 were
not submitted to the
Stock Exchange | | The disclosures for the half
year ended 31st March, 2023
and 30th September, 2023
were not submitted to the
Stock Exchange. | 31st March, 2024 | Under Section 130 of the
Companies Act, the NCLT
passed an order, dated
January 1, 2019, directing
the Company to re- open
and recast the financial
accounts for FY 2013-14 to
FY 2017-18. The recasted
financial statements were
then filed with NCLT. The
Hon’ble NCLT vide its order
pronounced on June 28,
2024 and August 9, 2024,
has taken on record the reopened
and re-casted
standalone financial
statements of the
Company for FY 2013-14 to
FY 2017-18.
Subsequently, a petition
was filed by the Company
before the NCLT on January
9, 2024 seeking approval
for undertaking voluntarily
revision of the financial
statements for FY 2018-
2019 and FY 2019-2020 to
give impact arising from
recasted financial
statements. The Hon’ble
NCLT vide order dated
March 7, 2025 has approved the revision of
the financial statements for
FY 2018-2019 and FY 2019-
2020. In view the same, the
Company was not able to
prepare the financial
statements from FY 2019-
20 onwards | Pursuant to an application filed
by Union of India under Section
130 of the Companies Act, the
NCLT passed an order, dated
January 1, 2019, permitting reopening
and recasting of the
financial accounts of the
Company for FY 2013-14 to FY
2017-18. The recasted financial
statements were then filed with
NCLT. In view thereof, the
Hon’ble NCLT vide its order
pronounced on June 28, 2024
and August 9, 2024, has taken
on record the re-opened and recasted
standalone financial
statements of the Company for
FY 2013-14 to FY 2017-18.
Subsequently, a petition was
filed by the Company before
the NCLT on January 9, 2024
seeking approval for
undertaking voluntarily revision
of the financial statements for
FY 2018-2019 and FY 2019-2020
to give impact arising from
recasted financial statements.
The Hon’ble NCLT vide order
dated March 7, 2025 has
approved the revision of the
financial statements for FY
2018-2019 and FY 2019-2020. Accordingly, the Company will
now be taking up the
preparation of the financial
results for the same and comply
with the requirement of the
Regulations in this regard. | Pursuant to an application filed
by Union of India under Section
130 of the Companies Act, the
NCLT passed an order, dated
January 1, 2019, permitting reopening
and recasting of the
financial accounts of the
Company for FY 2013-14 to FY
2017-18. The recasted financial
statements were then filed with
NCLT. In view thereof, the
Hon’ble NCLT vide its order
pronounced on June 28, 2024
and August 9, 2024, has taken
on record the re-opened and recasted
standalone financial
statements of the Company for
FY 2013-14 to FY 2017-18.
Subsequently, a petition was
filed by the Company before
the NCLT on January 9, 2024
seeking approval for
undertaking voluntarily revision
of the financial statements for
FY 2018-2019 and FY 2019-2020
to give impact arising from
recasted financial statements.
The Hon’ble NCLT vide order
dated March 7, 2025 has
approved the revision of the
financial statements for FY
2018-2019 and FY 2019-2020. Accordingly, the Company will
now be taking up the
preparation of the financial
results for the same and comply
with the requirement of the
Regulations in this regard. | |
| 4 | Regulation 24 (1) of SEBI
(Listing Obligations and
Disclosure Requirement)
2015 | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Regulation 24 | Appointment of
Independent Directors
on the board of
of Unlisted material
Subsidiaries | Other Regulatory Body | No Action Taken by any Regulatory Body | Other | No Action Taken by any Regulatory Body | Appointment of
Independent Directors
on the board of
of Unlisted material
Subsidiaries | | Appointment of Independent
Directors on the board of
of Unlisted material
Subsidiaries | 31st March, 2024 | Based on the audited
consolidated financial
statements for the year
ended 31st March 2018,
there were no material
subsidiaries of the listed
entity requiring
appointment of
Independent Directors.
Subsequent thereto the
listed entity has not
prepared/approved the
consolidated financial
statements for the
subsequent financials years
for reasons stated in Sl No.
3 above. In view of the
above position we are
unable to identify material
subsidiaries of the listed
entity. | Based on the audited
consolidated financial
statements for the year ended
31st March 2018, there were no
material subsidiaries of the
listed entity requiring
appointment of Independent
Directors.
Subsequent thereto the Listed
entity has not
prepared/approved the
consolidated financial
statements for the subsequent
financials years for reasons
stated in Sl No. 3 above. In view
of the above position we are
unable to identify material
subsidiaries of the listed entity. | Based on the audited
consolidated financial
statements for the year ended
31st March 2018, there were no
material subsidiaries of the
listed entity requiring
appointment of Independent
Directors.
Subsequent thereto the Listed
entity has not
prepared/approved the
consolidated financial
statements for the subsequent
financials years for reasons
stated in Sl No. 3 above. In view
of the above position we are
unable to identify material
subsidiaries of the listed entity. | |
| 5 | Regulation 29(1)(a) and
50 (1) (c) of SEBI (Listing
Obligations and
Disclosure Requirement)
2015 | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Regulation 29(1)(a) and
50 (1) (c) | Prior intimation was
not given to
designated stock
exchanges with
respect proposal for
considering financial
results viz. quarterly,
half yearly, or annual | Other Regulatory Body | No Action Taken by any Regulatory Body | Other | No Action Taken by any Regulatory Body | Prior intimation was
not given to
designated stock
exchanges with
respect proposal for
considering financial
results viz. quarterly,
half yearly, or annual | | Prior intimation was not
given to designated stock
exchanges with respect
proposal for considering
financial results viz.
quarterly, half yearly, or
annual. | 31st March, 2024 | For the reasons stated
herein above at Sr. No.3,
the listed entity has not
complied with the said
regulation | For the reasons stated herein
above at Sr. No.3, the listed
entity has not complied with
the said regulation | For the reasons stated herein
above at Sr. No.3, the listed
entity has not complied with
the said regulation | |
| 6 | Regulation 33, 52(4) &
52(7) read with 54 (2),
54(3) of SEBI (Listing
Obligations and
Disclosure Requirement)
2015 | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Regulation 33, 52(4) &
52(7) read with 54 (2),
54(3) | The listed entity has
not complied with the
regulation with
respect to intimating
the same to the Stock
Exchange for the
Quarter ended 30th
June, 2023, 30th
September, 2023 and
31st December, 2023.
Further the audited
financial statements
for the year ended 31st
March, 2024 were also
not submitted. | Stock Exchange | | Fine | | The listed entity has
not complied with the
regulation with
respect to intimating
the same to the Stock
Exchange for the
Quarter ended 30th
June, 2023, 30th
September, 2023 and
31st December, 2023.
Further the audited
financial statements
for the year ended 31st
March, 2024 were also
not submitted. | 2131080 | The listed entity has not
complied with the regulation
with respect to intimating
the same to the Stock
Exchange for the Quarter
ended 30th June, 2023, 30th
September, 2023 and 31st
December, 2023. Further the
audited financial statements
for the year ended 31st
March, 2024 were also not
submitted. | 31st March, 2024 | For the reasons stated
herein above at Sr. No.3,
the listed entity has not
complied with the said
regulation. | For the reasons stated herein
above at Sr. No.3, the listed
entity has not complied with
the said regulation | For the reasons stated herein
above at Sr. No.3, the listed
entity has not complied with
the said regulation | |
| 7 | Regulation 34 and 53 of
SEBI (Listing Obligations
and Disclosure
Requirement) 2015 | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Regulation 34 and 53 | The listed entity has
not complied with the
regulation. | Stock Exchange | | Fine | | The listed entity has
not complied with the
regulation. | 538080 | The listed entity has not
complied with the regulation. | 31st March, 2024 | For the reasons stated
herein above at Sr. No.3,
the listed entity has not
complied with the said
regulation. | For the reasons stated herein
above at Sr. No.3, the listed
entity has not complied with
the said regulation. | For the reasons stated herein
above at Sr. No.3, the listed
entity has not complied with
the said regulation. | |
| 8 | Regulation 47(1)(b) &
52(8) of SEBI (Listing
Obligations and
Disclosure Requirement)
2015
Regulations, 2015
the listed entity shall
publish the financial
results as specified in
Regulation 33, along
with the modified
opinion(s) or
reservation(s), if any
expressed by the
statutory auditor. | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Regulation 47(1)(b) &
52(8) | The listed entity has
not published the
financial results for all
the Quarters as the
same as well as
financial results for the
year ended 31st March,
2024 as the same were
not placed before the
Board of the listed
entity for their
approval. | Other Regulatory Body | No Action Taken by any Regulatory Body | Other | No Action Taken by any Regulatory Body | The listed entity has
not published the
financial results for all
the Quarters as the
same as well as
financial results for the
year ended 31st March,
2024 as the same were
not placed before the
Board of the listed
entity for their
approval. | | The listed entity has not
published the financial
results for all the Quarters as
the same as well as financial
results for the year ended
31st March, 2024 as the same
were not placed before the
Board of the listed entity for
their approval. | 31st March, 2024 | For the reasons stated
herein above at Sr. No.3,
the listed entity has not
complied with the said
regulation. | For the reasons stated herein
above at Sr. No.3, the listed
entity has not complied with
the said regulation. | For the reasons stated herein
above at Sr. No.3, the listed
entity has not complied with
the said regulation. | |
| 9 | Regulation 61(1) of SEBI
(Listing Obligation &
Disclosure
Requirements)
Regulations, 2015-
The listed entity shall
ensure timely payment
of interest
The listed entity shall
ensure timely
redemption payment.
The listed entity shall
ensure timely payment
of dividend of non convertible redeemable
preference share | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Regulation 61(1) | Regulation 61(1) of
SEBI (Listing Obligation
& Disclosure
Requirements)
Regulations, 2015-
The listed entity shall
ensure timely
payment of interest
The listed entity shall
ensure timely
redemption payment.
The listed entity shall
ensure timely
payment of dividend
of non-convertible redeemable
preference share
Preference Shares due
for the period 1st April
2023 to 31st March,
2024. | Other Regulatory Body | No Action Taken by any Regulatory Body | Other | No Action Taken by any Regulatory Body | Regulation 61(1) of
SEBI (Listing Obligation
& Disclosure
Requirements)
Regulations, 2015-
The listed entity shall
ensure timely
payment of interest
The listed entity shall
ensure timely
redemption payment.
The listed entity shall
ensure timely
payment of dividend
of non-convertible redeemable
preference share
Preference Shares due
for the period 1st April
2023 to 31st March,
2024. | | The Listed entity has not paid
interest on Non-Convertible
Debentures due for the
period 1st April 2023 to 31st
March, 2024.
The Listed entity has not
redeemed the Non -
Convertible Debentures
failing due during the FY
2023-24.
The Listed entity has not paid
dividend on Cumulative Non-
Convertible redeemable
preference shares due for
the period 1st April 2023 to
31st March, 2024. The Listed entity has not
redeemed Cumulative Non-
Convertible Redeemable
Preference Shares due for
the period 1st April 2023 to
31st March, 2024. | 31st March, 2024 | During the year under
review, the listed entity, has
made the payments to all
the NCD’s holders as a part
of Interim Distribution
process, and the same has
been intimated to Stock
exchanges. | During the year under review,
the listed entity, has made the
payments to all the NCD’s
holders as a part of Interim
Distribution process, and the
same has been intimated to
Stock exchanges.
Further the default intimation
has also been given to stock
exchanges. | During the year under review,
the listed entity, has made the
payments to all the NCD’s
holders as a part of Interim
Distribution process, and the
same has been intimated to
Stock exchanges.
Further the default intimation
has also been given to stock
exchanges. | |
| 10 | As per Regulation 46 &
62(b) of SEBI (Listing
Obligation & Disclosure
Requirements)
regulations, 2015. | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | As per Regulation 46 &
62(b) | The listed entity has
not uploaded
following details on its
website:
I. Financial
information
including.
(i) notice of meeting of
the board of directors
where financial results
shall be discussed; (ii)
financial results (iii)
complete copy of the
annual report. | Other Regulatory Body | No Action Taken by any Regulatory Body | Other | No Action Taken by any Regulatory Body | The listed entity has
not uploaded
following details on its
website:
I. Financial
information
including.
(i) notice of meeting of
the board of directors
where financial results
shall be discussed; (ii)
financial results (iii)
complete copy of the
annual report. | | The listed entity has not
uploaded following details on
its website:
I. Financial information
including.
(i) notice of meeting of the
board of directors where
financial results shall be
discussed; (ii) financial
results (iii) complete copy of
the annual report. | 31st March, 2024 | For the reasons stated
herein above at Sr. No.3,
the listed entity has not
complied with the said
regulation. | For the reasons stated herein
above at Sr. No.3, the listed
entity has not complied with
the said regulation. | For the reasons stated herein
above at Sr. No.3, the listed
entity has not complied with
the said regulation. | |
| 11 | Regulation 54 of SEBI
(Listing Obligations and
Disclosure Requirement)
2015 | Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 | Regulation 54 | The listed entity has
not maintained
hundred per cent
security cover or
higher security cover
sufficient to discharge
the principal amount
and the interest
thereon at all times for
the non-convertible
debt securities issued.
Further, since the
results have not been
approved and
intimated to Stock
exchanges, the
disclosures with
respect to security
coverage have not
been complied with | Other Regulatory Body | No Action Taken by any Regulatory Body | Other | No Action Taken by any Regulatory Body | The listed entity has
not maintained
hundred per cent
security cover or
higher security cover
sufficient to discharge
the principal amount
and the interest
thereon at all times for
the non-convertible
debt securities issued.
Further, since the
results have not been
approved and
intimated to Stock
exchanges, the
disclosures with
respect to security
coverage have not
been complied with | | The listed entity has not
maintained hundred per cent
security cover or higher
security cover sufficient to
discharge the principal
amount and the interest
thereon at all times for the
non-convertible debt
securities issued.
Further, since the results
have not been approved and
intimated to Stock
exchanges, the disclosures
with respect to security
coverage have not been
complied with | 31st March, 2024 | Post the Moratorium Order
issued by the National
Company Law Appellate
Tribunal on October 15,
2018, all the NCDs issued
by the Company stand
defaulted as the payments
for settlement of dues of all
the creditors of the
Company will be made as
per the resolution plan by
way of distribution of
proceeds to be received.
Further as explained in
point 3, the Financials of
the Company are not being
prepared and therefore the
required information could
not be submitted.
The Stock Exchanges have
been kept informed of this
with reasons from time to
time. | The listed entity has not
maintained hundred per cent
security cover or higher security
cover sufficient to discharge the
principal amount and the
interest thereon at all times for
the non-convertible debt
securities issued.
Further, since the results have
not been approved and
intimated to Stock exchanges,
the disclosures with respect to
security coverage have not
been complied with. | The listed entity has not
maintained hundred per cent
security cover or higher security
cover sufficient to discharge the
principal amount and the
interest thereon at all times for
the non-convertible debt
securities issued.
Further, since the results have
not been approved and
intimated to Stock exchanges,
the disclosures with respect to
security coverage have not
been complied with. | |
Affirmation |
| Sr No | Regulation | Compliance status (Yes/No/NA) | Observations /Remarks by PCS* |
| 1 | Secretarial Standards:
The compliances of the listed entity are in accordance with the applicable Secretarial Standards (SS) issued by the Institute of Company Secretaries India (ICSI) | Yes | The listed entity has complied
with the provisions of the
Secretarial Standards except
circulating the signed minutes. |
| 2 | Adoption and timely updation of the Policies |
| (a) | All applicable policies under SEBI Regulations are adopted
with the approval of board of directors of the listed entities | Yes | |
| (b) | All the policies are in conformity with SEBI Regulations and
has been reviewed & timely updated as per the
regulations/circulars/guidelines issued by SEBI | Yes | |
| 3 | Maintenance and disclosures on Website |
| (a) | The Listed entity is maintaining a functional website | Yes | |
| (b) | Timely dissemination of the documents/ information under
a separate section on the website | No | The listed entity has complied
with uploading of all the
information except for
uploading the financial results
for all quarters. In view
thereof, the listed entity is
unable to comply with
publishing of quarterly/half
yearly/ annual financial results
as on 31st March, 2025. |
| (c) | Web-links provided in annual corporate governance reports
under Regulation 27(2) are accurate and specific which re-directs to the relevant document(s)/ section of the website | Yes | |
| 4 | Disqualification of Director:
None of the Director of the Company are disqualified under
Section 164 of Companies Act, 2013 | Yes | |
| 5 | Details related to Subsidiaries of listed entities:
(a) Identification of material subsidiary companies
(b) Requirements with respect to disclosure of material as well as other subsidiaries | No | Based on the audited
consolidated financial
statements for the year ended
31st March 2018, there were no
material subsidiaries of the
listed entity. Subsequent
thereto the listed entity has
not prepared/approved the
consolidated financial
statements. In view of the
above position, we are unable
to identify material subsidiaries
of the listed entity. |
| 6 | Preservation of Documents:
The listed entity is preserving and maintaining records as prescribed under SEBI Regulations and disposal of records as per Policy of Preservation of Documents and Archival policy prescribed under SEBI LODR Regulations | Yes | |
| 7 | Performance Evaluation:
The listed entity has conducted performance evaluation of the
Board, Independent Directors and the Committees at the start
of every financial year as prescribed in SEBI Regulations | No | The requirement of appointing
Independent Director (ID) has
been dispensed by NCLT order
dated 26th April, 2019 for IL&FS
& group companies, including
the Company. In view thereof,
the process of performance
evaluation has not been
followed. However, an
application has been filed by
the IL&FS, with MCA and NCLT
seeking exemption from
applicability of the provisions
of Section 178 (2) of Act and
SEBI LODR Regulations 2015 |
| 8 | Related Party Transactions |
| (a) | The listed entity has obtained prior approval of Audit
Committee for all Related party transactions | Yes | |
| (b) | In case no prior approval obtained, the listed entity shall
provide detailed reasons along with confirmation whether
the transactions were subsequently
approved/ratified/rejected by the Audit committee | Yes | |
| 9 | Disclosure of events or information:
The listed entity has provided all the required disclosure(s) under Regulation 30 along with Schedule III of SEBI LODR Regulations within the time limits prescribed thereunder | Yes | |
| 10 | Prohibition of Insider Trading:
The listed entity is in compliance with Regulation 3(5) & 3(6)
SEBI (Prohibition of Insider Trading) Regulations, 2015 | Yes | |
| 11 | Actions taken by SEBI or Stock Exchange(s), if any:
No Actions taken against the listed entity/ its promoters/directors/ subsidiaries either by SEBI or by Stock Exchanges (including under the Standard Operating Procedures issued by SEBI through various circulars) under SEBI Regulations and circulars/ guidelines issued thereunder (or)
The actions taken against the listed entity/ its promoters/ directors/ subsidiaries either by SEBI or by Stock Exchanges are specified in the last column | Yes | Please refer Annexure-1 of pdf copy of Annual Secretarial Compliance Report uploaded on the website of Stock Exchange. |
| 12 | Resignation of statutory auditors from the listed entity or its material subsidiaries:
In case of resignation of statutory auditor from the listed entity or any of its material subsidiaries during the financial year, the listed entity and / or its material subsidiary(is) has / have complied with paragraph 6.1 and 6.2 of section V-D of chapter V of the Master Circular on compliance with the provisions of the LODR Regulations by listed entities | NA | None |
| 13 | No. additional non-compliances observed:
No. additional non-compliance observed for any of the SEBI regulation/circular/guidance note etc. except as reported above |
| 1 | No any additional non-compliance
observed for all SEBI
regulation/circular/guidance etc
except as reported in Annexure-2. | Yes | Please refer Annexure-2 of pdf copy of Annual Secretarial Compliance Report uploaded on the website of Stock Exchange. |