SIGNIFICANT ACCOUNTING POLICIES

1. Basis of Preparation of Financial statements :

The Financial Statements have been brpared in accordance with generally accepted accounting principles in India ('Indian GAAP) under the historical cost convention on an accrual basis, except interest on debtors and other claims receivable, which are accounted for on receipt/payment basis, in compliance with all material aspects of the Accounting Standards (AS) notified under section 133 of The Companies Act, 2013 (The Act) read with Rule 7 of the Companies (Accounts) Rules, 2014. The accounting policies have been consistently applied by the company and are consistent with those used in the brvious year, unless otherwise mentioned in the notes.

2. Use of Estimates:

The brsentation of financial statements requires estimates and assumptions to be made that affect the reported amount of assets and liabilities on the date of the financial statements and the reported amount of revenues and expenses during die reporting period. Difference between the actual results and the estimates are recognized in the period in which the results are known /materialised.

3. Fixed Assets, Intangible Assets and Debrciation:

(i) (a) Fixed assets are stated at cost of acquisition or construction less debrciation. All cost relating to the acquisition & installation are capitalized.

(b) Addition in Fixed assets is stated at cost net of VAT and Cenvat credit, Custom duty (where applicable). All cost relating to acquisition and installation of fixed asset are capitalized.

(c) Agricultural land is shown at cost price.

(ii) Till the year ended 31 March 2014, Schedule XIV to the Companies Act, 1956, brscribed requirements concerning debrciation of fixed assets. From the current year, Schedule XIV has been replaced by Schedule II to the Companies Act, 2013. The applicability of Schedule II has resulted in the following changes related to debrciation of fixed assets. Unless stated otherwise, the impact mentioned for the current year is likely to hold good for future years also.

(a) Useful lives/ debrciation rates

Till the year ended 31 March 2014, debrciation rates brscribed under Schedule XIV were treated as minimum rates and the company was not allowed to charge debrciation at lower rates even if such lower rates were justified by the estimated useful life of the asset Schedule It to the Companies Act 2013 brscribes useful fives for fixed assets which, in many cases, are different from fives brscribed under the erstwhile Schedule XIV. However, Schedule II allows companies to use higher/ lower useful lives and residual values if such useful lives and residual values can be technically supported and justification for difference is disclosed in the financial statements.

Considering the applicability of Schedule II, the management has re-estimated useful lives and residual values of all its fixed assets. The management believes that debrdation rates currently used fairly reflect its estimate of the useful lives and residual values of fixed assets, though these rates in certain cases are different from lives brscribed under Schedule II. Hence, this change in accounting policy did not have any material impact on financial statements of the company.

(b) Accounting for additional debrciation on account of revaluation of assets

On 31 March 1993, the company revalued all its land and buildings existing as on that date. The year ended 31 March 2014, the Guidance Note on Treatment of Reserve Created on Revaluation of Fixed Assets issued by the ICAI allowed companies to transfer an amount equivalent to the additional debrciation arising due to upward revaluation of fixed assets from revaluation reserve to the statement of profit and loss. Accordingly, the company was transferring an amount equivalent to additional debrciation arising due to upward revaluation of building from revaluation reserve to the statement of profit and loss. In contrast, Schedule II to the Companies Act 2013 applicable from the current year, states that debrciable amount of an asset is the cost of an asset or other amount substituted for cost. Hence, in case of revalued assets, debrdation computed on the revalued amount needs to be charged to the statement of profit and loss, without any recoupment from revaluation reserve. Consequently, to comply with the Schedule II requirement the company has discontinued the practice of recouping the impact of additional debrdation from revaluation reserve. The management has decided to apply the revised accounting policy prospectively from accounting periods commencing on or after 1 April 2014.

Had the company continued its earlier policy of recouping the additional debrdation arising due to upward revaluation of fixed assets from revaluation assets, profits for the current year would have been on higher side. However, the change in accounting policy did not have any impact on reserves and surplus as at 31 March 2015.

(c) Debrdation on assets costing less than 5,000/-

Till year ended 31 March 2014, to comply with the requirements of Schedule XIV to the Companies Act, 1956, the company was charging 100% debrdation on assets costing less than 5,000/- in the year of purchase. However, Schedule II to the Companies Act 2013, applicable from the current year, does not recognize such practice. Hence, to comply with the requirement of Schedule II to the Companies Act, 2013, the company has changed its accounting policy for debrdations of assets costing less than 5,000/-. As per the revised policy, the company is debrciations  such assets over their useful life as assessed by the management. The management has decided to apply the revised accounting policy prospectively from accounting periods commending on or after 1 April 2014.

The change in accounting for debrciation of assets costing less than 5,000/- did not have any material impact on financial statements of the company for the current year.

 (iii) Fixed assets acquired in exchange or in part exchange for another asset are recorded at the net book value of the assets given up, adjusted for any balancing payment or receipt of cash or other consideration.

(iv) Capital Assets under erection/instatiation/construction are reflected in the Balance sheet as "Capital Work in Progress".

4. Purchases: Purchase of all Raw materials, Aluminium wire Rods, glassine paper, packing material, Oil & Lubricants, Gas Cylinder, production, mechanical & Electrical stores, Polythene and polyester film & paper are accounted for on basic price & CST. Cenvat and VAT paid on purchase of above items are shown as Cenvat recoverable & VAT recoverable and the same is to be adjusted against the Excise/Sales Tax liabilities.

5. Investments: Short term investments are stated at cost or market price, whichever is tower.

Long term Investments are stated at cost. Provision for diminution in the value of long-term investments is made only if such a decline is other than temporary in the opinion of the management.

Inventories & Other Current Assets:

Inventories as taken and certified by the management are valued as under:

(a) Raw materials, dyes &Chemicals Packing material, Polyester Rim, Paper and Polythene :At cost excluding cenvat credit and VAT.

(b) Production, Electrical, and Mechanical and consumable store & spares :At cost excluding Genvat, Service Tax & VAT

(c) Oil & lubricants :At cost excluding excise duty except HSD.

(d) Work in process :At estimated cost (valued as certified by the management.)

(e) Aluminium wire rods :

At cost or market price whichever is lower.

(f) Scrap & rejected goods

At net realizable value determined by management.

(g) Finished goods

: Valuation of finished goods manufactured but not cleared from excise bonded warehouse up to the end of the year is at cost or market price, whichever is lower inclusive of Excise Duty. (Cost price estimated by deducting approx 9.44% from the selling price).

(h) Stock at port & in transit

At Selling price

(i) Stock in transit/ware house(Purchase)

At purchase price including clearing expenses, custom duty paid and incidental expenses thereto.

(j) DEPB licences Purchased

At cost.

(k) Gas Cylinder

At cost

(1) Returned Material outside factory

At Estimated Net Realizable Value (certified by management).

(m) Export Goods in Transit

At sale invoice value including freight thereof.

Note: The cost of raw materials, dyes, chemicals, packing material, oil & lubricant and consumable stores are arrived at on first in first out method and in the case of basic raw material, freight inward expenses have also been considered.

7. Expenditure:

(a) All other expenses are accounted for on accrual basis and consumption of stores has been taken on actual consumption.

(b) Power unit generated from Enercon wind power plant which has been wheeled for captive consumption after adjusting wheeling charges @ 10% of the energy fed into grid to RVPNL Discom(s) is accounted on effective tariff rate in power bill and simultaneously such figure was also reflected in other income.

8. Employee Benefits:

(a) Defined contribution plans : The Company's contribution to provident fund and employee state insurance are considered as defined contribution plans and are charged as an expense as they fall due based on the amount of contribution required to . be made.

(b) Defined benefit plans : (a) Gratuity payable to employees is provided on the basis of brmium paid under group fatuity scheme with Life Insurance Corporation of India.

(b) Provision for Leave encashment has been made on accrual basis on leave un-availed as on 31.03.2015.

(c) Service awards have been adjusted/accounted on the basis of completed months of service provided by employees.

(c) Short-term employee benefits : Short term employee benefits are recognized as an expense at the undiscounted amount in the statement of profit and loss for the year in which the related service is rendered.

9. Borrowing Costs :

Borrowing costs that are attributable to the acquisition or construction of qualifying assets are capitalized as part of the cost of such assets. A qualifying asset is one that necessarily takes substantial period of time to get ready for intended use. Ail other borrowing costs are charged to revenue.

10. Revenue Recognition:

(a) Sales are inclusive of Cenvat but are net of Sales returns, Shortages and other discounts & rebates but excluding value of recoveries made for insurance, freight and packing forwarding expenses, which have been shown in the invoice value and are adjusted in the respective heads.

(b) Discount and rebates on sales is accounted for as and when settled.

(c) Export sales are accounted for, on the basis of exchange rate of LEO Date (Let Export Order) of transactions and recognized as and when Risk & Rewards are transferred.

(d) Revenue from investment is accounted on sale/disposal of such investments.

(e) Export Incentive: (i) Revenue from DEPB Licenses is recognized when the licenses are sold / utilized and are shown as other incomes, (ii) Revenue of duty drawback has been accounted on accrual basis.

(f) Units generated on Eoercon wind power plant has been accounted on the basis of effective tariff rate m respective month Units generated on Suzlon wind power plant has been accounted at contract price on accrual basis.

(g) Interest receivable from Trade Receivables and dividend from investments are accounted on receipt basis.

(h) The Company has purchased DEPB Licenses from market at discounts and the same has been shown as Discounts received on purchase of DEPB in other income.

11. Transaction in Foreign Currencies (Other than for fixed assets):

(a) Transactions denominated in foreign currencies are normally recorded at the exchange rate brvailing at the time of the transaction. Gain/Loss arising out of fluctuation in between transaction date and realization date are recognized in profit & loss account

(b) All foreign currency Monetary items at the year-end which not covered by foreign exchange contracts are translated at year-end rates.

(c) Foreign Exchange Gain/Loss of buyer's credit taken from foreign bank has been recognized at the date of transaction and recognized in profit & loss account.

12. Impairment of Assets:

All  assets other than inventory, investment or deferred tax assets are reviewed for Impairment  circumstances indicate that the carrying amount may not be recoverable. Assets whose carrying amount exceeds their recoverable amount will be written down to recoverable amount. An impairment loss is charged to the Profit and Loss Account in the year in which an asset is identified as impaired.

13. Cenvat, Service Tax & VAT :

The value of Cenvat, Service Tax and VAT credit benefits eligible on raw materials, other eligible inputs, production stores and capital goods is considered for the clearances of finished goods

14. Accounting of Taxes on Income :

Provision for current tax is made after taking into consideration benefits admissible under the provisions of the Income Tax Act, 1961.

Deferred tax resulting from "Timing Differences'' between book and taxable profit is accounted for using the tax rates and laws that have been enacted or substantively enacted as on the balance sheet date. The deferred tax asset is recognized and carried forward only to the extent that there is a reasonable certainty that the asset will be realized in future.

15. Contingent Liabilities :

The company is not providing for contingent liabilities in the account since the ultimate outcome thereof cannot be determined on the date of balance sheet. However, notes on every contingent liabilities exist on the date of balance sheet are given in notes to accounts. Contingent assets are neither recognized nor disclosed in the balance sheet.

16. Earnings Per Share:

Basic and diluted earning per share are computed by dividing the net profit after tax attributable to equity shareholders for the year, with the weighted number of equity shares outstanding during the year.

17. Lease:

Lease rentals under an operating lease, are recognized as an expenses in the statement of Profit & Loss Account on a straight line basis over the lease term. Lease Income from Operating lease is recognized in Profit & Loss Account on a Straight line basis over the Lease Term.

18. Accounting of Financial Instruments:

The Premium or Discount arose due to difference between spot and forward rate on Forward Exchange Contracts, which are taken to hedge foreign currency risk of an existing asset/liability, is recognized over the period of contract. Premium/ discount on the above FEC for the expired period is booked as income/ expenditure in the statement of profit & toss and for unexpired period as on balance sheet date are shown as Financial Asset & Liability & Amount receivable and payable under the Forward Exchange Contract is booked as liabilities and assets accordance with Accounting Standard-31 and the same has also been subsequently recognized as per Accounting Standard-11.

NOTES FORMING PART OF THE FINANCIAL STATEMENTS

1. CONTINGENT LIABILITIES AND COMMITMENTS NOT PROVIDED FOR:

(a) Guarantees given by bank in favour of buyers/suppliers, & Central Excise for Rs. 320.26 Lac (brvious tear Rs. 501.39 Lac)

(b) Letter of Credit of Rs. 3458.67 Lac (brvious year Rs. 1649.5 Lac) opened in favour of Raw Material Suppliers

(c) Estimated amount of contract remaining to be executed on capital account & not provided for Rs. 935.98 Lacs (brvious year Rs. 935.98 Lacs) against which advances given Rs.847.57 Lacs (brvious year Rs.826.76 Lacs)

(d) Personal Guarantee by the Managing Director and Whole Time Director have been given to IDBI bank Limited against working Capital facilities sanctioned to company.

(e) Uncompleted/reopened assessments of sales tax and income tax.

(f) Sort filed by NECtO-for Sum of Rs. 227085/- against which a sum of Rs.25,000/- has been deposited in the city Civil Court Ahmedabad.

•Matter pending since more than 15 years and company does not expect any liability

(g) Total Demand raised by commercial tax Department, Pali Rs. 546.40 Lacs for tax and Rs. 1765.91 Lacs for interest due thereon. Out of this Company has deposited Rs. 546.40 Lacs up to March 2014 and same has been debited to Profit & Loss Account. However Company has filed an appeal with Subrme Court for above Disputed Demand and Interest thereon. Honorable Subrme Court has granted stay for payment of interest

2. The lease deed regarding land at Jaisalmer where Enercon Make wind mill is installed has not been executed.

3. Balances of Trade Receivables, Trade Payables, Loans & Advances and Unsecured Loans as on 31.3.2015 are subject to reconciliation & confirmation by the parties.

4. Income Tax Assessment year 2012-13 & Sales tax assessment year 11-12 have been completed.

5. During the year the company has paid a sum of Rs. 2,35,902/-to LLC Of India towards brmium of key man insurance policy. This policy has been taken on 28th January 1995 for 25 years. Regarding this the company has taken the undertaking from Shri Pankaj P Shah, And Shri Abhay P Shah the director who are covered up under this policy, for non-claiming of end benefits of the policy on maturity.

6. (a) The company has entered into an agreement with Shreenivas Cotton Mills Limited on 19th day of Nov. 2010 to purchase a flat in World One Tower, Mumbai on a total consideration of Rs.9,23,97,834.00/- and in addition Rs.12 Lac will be paid on possession towards non refundable dub membership. The company has paid Rs. 8,47,56,930/- as per terms of agreement in advance. Registry of the above flat executed on 24th February,2014. The same has now been shown under capital work in progress including borrowing cost capitalized till 31.03.2015.

(b) Capitalization of Borrowing cost has not been determined during the year on Flat in World one tower at Mumbai as the same is near to completion and only possession of flat is pending.

7. Director remuneration: Salaries Rs. 24,60,000/-

8. (a) During the year, the Company has DEPB licenses face value of Rs. 25,50,74,493/- purchased for Rs. 24,85,72,572. The Difference between face value and purchase price has been treated as discount and shown under the head Other income. Out of total DEPB, DEPB in hand as at 31.03.15 is Rs. 2,36,69,620

(b) During the Year Company has received in Form of DEPB License Export incentive for Rs. 2,46,432/- booked as income under head other Operating Revenue Income.

(c) During the Year, Export incentive accrued for Rs.33,22,757/-shown as income under head Other Operating Revenue against Export made during the year. Out of this Rs. 13,21,624/- outstanding at the end of year.

9. (a) Company has installed one Wind Mill of 0.6 MW capacities at Soda Bandan District Jaisalmer with agreement with Rajastahn Rajya Vidhut Vitran Nigam Limited & other and Enercon Wind Form for wheeling of Energy for captive consumption. During the year 6,07,065 units Generated amounting to Rs. 41,35,586/-.

(b) Company has installed one Wind Mill of 1.5MW capacities at Aakal, Jaisalmer with agreement with Jodhpur Vidhut Vitran Nigam Limited & Suzlon Suzlon Infrastructure Service Limited for generation power. During the year 2150335 units generated and sale to Jodhpur Vidhut Vitran Nigam Limited amounting to Rs. 88,16,375/-

10. (a) A Misappropriation / Fraud of FDR Deposit Comes to the knowledge of the Management during the year. Company has filed a complaint with Economic Offence Wing, Mumbai and FIR with Police station Nariman Point on 144)7.2014 against various parties including Dhanlaxmi Bank, Mumbai & their officials for Misappropriation of FDR's of Rs. 69 Crores given to Dhanlaxmi Bank Ltd., Branch. (Company has received Rs. 47.39 Crores from accused from the account of various parties against repayment of FDR's which shown under the head Short Term Borrowings.

(b) Company has not booked interest on these FDR's for Financial Year 2014-15 due to disputed matter and uncertainty. Company has also reversed the accrued interest on FDR's for Rs. 4,28,97,151/- which was booked as income in last year. Profit of Company reduced due to reversal of interest

(c) Company has not provided interest liability on Short Term Borrowing received from various dispute.

The matter is under investigation and pending with competent authority.

11. Company has taken a flat in Mumbai for a period of 99 years lease on monthly lease rent of Rs.2500/- which win be increased by 10% after the expiry of every 36 months from the date of agreement and company has deposited Rs.95,00,000/- as interest tree security deposit with right to purchase The property on further payment of Rs.5,00,000/- This lease agreement has not been registered. The unexpired period to said lease is 89 years.

12. Lease rent in respect of leasehold land for factory building and township are accounted for on accrual basis. The unexpired portion of said lease hold lands are 50 and 51 years respectively.

13. Consequent to the accounting standard for deferred tax the company has created total differed Tax Assets/ (Liability) of Rs.2282793.00 for the year ended 31st March 2015

14. The information in regards to SSI Units has been compiled in respect to parties to the extent to which they could be identified as SSI units on the basis of information available with the company.

15. (a) Bank balances are subject to bank reconciliations, (b) Balances of Fixed Deposits are subject to Note no. 16.

16. There is no agriculture produce from the Agriculture land.

17. Since the company does not have any subsidiary AS 21 is not applicable

18. SEGMENT REPORTING

Based on the guidance notes given in the accounting standard on Segment Reporting (AS 17) issued by the Institute of Chartered accountants of India the Company is single reportable segment company, engaged in the business of manufacture and sale of Aluminium Foil in the various form. As the Company operates in single primary segment, disclosure requirement is no applicable.

19. As on 31st March, 2015, foreign Exchange Contract of sale of $ is unexpired for $90972.38 booked @ Rs.62.43/-  with maturity date of 15-04-2015 and $ 290000booked @ Rs. 62.86/- with maturity date of 30.04.2015. Unallocated amount of Premium/discount of the unexpired period is shown under the current liabilities and simultaneously foreign currency monetary item payable is booked as EEC ($), shown under current liabilities and amount receivable in Rs. on maturity is shown as FEC (Rs.) under current assets. In accordance with accounting standard foreign monetary item has been subsequendy recognized at dosing rate of $ @ Rs.62.59/-

20. Work Roll for Rs. 816688/- shown capital WIP transferred to Repairing and consumables account in current year.
53. The figures of the brvious year have been regrouped and rearranged wherever necessary to make them comparative with brvious year figures as done by the management so as reconciled with the amended revised schedule VI.

In terms of our report attached.

For Sharma Ashok Kumar & Associates

Chartered Accountants

(CA Harish Agarwal)

Partner

M.No: 403262

FRN. 005848C

For and on behalf of the Board

P Abhay P Shah Whole Time Director

Pankaj P Shah Managing Director

Place: Pipalia Kalan

Date: May 30, 2015