KUSHAL LIMITED€¦ · Kushal Limited (Formerly known as Kushal Tradelink Limited) CIN.: L74110GJ2000PLC037472 Registered Office Plot No. 43, B/S Navneet Prakashan, Sukhramnagar,

KUSHAL LIMITED

ANNUAL REPORT

2019-20

CORPORATE INFORMATION

Kushal Limited

(Formerly known as Kushal Tradelink

Limited)

CIN.: L74110GJ2000PLC037472

Registered Office

Plot No. 43, B/S Navneet

Prakashan, Sukhramnagar,

Gomtipur,

Ahmedabad-23, Gujarat,

Tel.: +91-79-26408027

Web.: www.kushallimited.com

Board of Directors Mr. Sandeep Agrawal- Chairman and Managing Director

Mr. Manoj Agrawal- Director

Mr. Kushal Agrawal- Director

Mr. Anil Soni- Independent Director

Mr. Dharmendra Bhuchhada - Independent Director

Mrs. Kavita Tejaskumar Shah- Independent Director

Company Secretary & Compliance Officer CS Shivangi Shah

Chief Financial Officer Mr. Jitendra Yadav

Statutory Auditor M/s S. V. Sojitra & Co.

Chartered Accountants

407, Silver Square Complex, Opp Dipak School, Nikol,

Ahmedabad-382350

Tel.: +91-9909928736

Secretarial Auditor M S Buchasia & Associates

Company Secretaries

306, Gala Mart, Nr. Sobo Centre, Before Safal Parisar, S

Bopal Main Road, South Bopal, Bopal, Ahmedabad-

380058

Tel.: +91-9327916394

Registrar & Share Transfer Agent Bigshare Services Private Limited

Mumbai Branch:

1st Floor, Bharat Tin Works Building, Opp. Vasant Oasis,

Makwana Road, Marol, Andheri (East), Mumbai,

Maharashtra, 400059

Tel No.: +91 – 22 – 40430200 / 62638200

Fax No.: +91 – 22 – 28475207 / 62638299

Web.: www.bigshareonline.com

Ahmedabad Branch:

A/802, Samudra Complex, Near Klassic Gold, Girish

Cold Drink, C.G Road, Ahmedabad, Gujarat-380009

Tel.: +91-79-40024135

Web.: www.bigshareonline.com

BOARD COMMITTEES

AUDIT COMMITTEE

Mr. Anil Soni - Chairman

Mrs. Kavita Shah - Member

Mr. Dharmendra Bhuchhada – Member

Mr. Kushal Agrawal - Member

NOMINATION AND REMUNERATION COMMITTEE

Mrs. Kavita Shah - Chairman

Mr. Dharmendra Bhuchhada – Member

Mr. Anil Soni - Member

STAKEHOLDER RELATIONSHIP COMMITTEE

Mr. Dharmendra Bhuchhada - Chairman

Mr. Anil Soni - Member

Mr. Manoj Agrawal – Member

CORPORATE SOCIAL RESPONSIBILITY COMMITTEE

Mr. Dharmendra Bhuchhada - Chairman

Mr. Kushal Agrawal - Member

Mr. Sandeep Agrawal – Member

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CIN: L74110GJ2000PLC037472

Reg. Office: Plot No.43/ B/S Navneet Prakashan Sukharamnagar, Gomatipur, Ahmedabad-380023

Gujarat. Phone: 079-22772991 Email: [email protected] Website: www.kushallimited.com

NOTICE OF ANNUAL GENERAL MEETING

Notice is hereby given that the Twentieth (20th) Annual General Meeting (AGM) of the Members of Kushal

Limited will be held on Thursday, December 31, 2020, at 11.00 A.M. at IST through Vedio Conferenceing

(“VC”) /Other Audio Visual Means (“OAVM”) to transact the following business:

ORDINARY BUSINESS:

1. Adoption of Financial Statements

To consider and adopt the Audited Standalone and Consolidated Financial Statements of the Company

for the financial year ended March 31, 2020 including the Audited Balance Sheet as on March 31, 2020,

the statement of Profit & Loss and the Cash Flow Statement for the year ended on that date, along with

the reports of the Board of Directors and Auditors thereon, by passing of following resolutions as:

“RESOLVED THAT the Audited Standalone and Consolidated Financial Statement of the Company for

the financial year ended March 31, 2020 including the Audited Balance Sheet as on March 31, 2020, the

statement of Profit & Loss and the Cash Flow Statement for the year ended on that date and the reports

of the Board of Directors and Auditors thereon, as laid before this meeting, be and are hereby received,

considered and adopted.”

2. Appointment of Mr. Manoj Agrawal as a Director liable to retire by rotation

To appoint Mr. Manoj Agrawal (DIN: 00225494) who retires by rotation, and being eligible, offers

himself for reappointment.

“RESOLVED THAT pursuant to provisions of Section 152 and other applicable provisions of the

Companies Act, 2013, the approval of the shareholders of the Company be and is hereby accorded to the

reappointment of Mr. Manoj Agrawal (DIN: 00225494) as a Director, who is liable to retire by rotation.”

By the order of Board

For Kushal Limited

SD/- Sandeep Agrawal

Chairman and Managing Director

DIN: 00239648

Date: December 08, 2020

Place: Ahmedabad

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NOTES:

1. In view of the continuing COVID-19 pandemic, the 20th AGM will be held on Thursday, 31st December, 2020

at 11.00p.m. through Video Conferencing (VC)/Other Audio Visual Means (OAVM), in compliance with the

applicable provisions of the Companies Act, 2013 read with MCA General Circular no. 14/2020, dated 8th

April, 2020, MCA General Circular no. 17/2020, dated 13th April, 2020; MCA General Circular No. 20/2020

dated 5th May, 2020and MCA General Circular No. 22/2020 dated 15th June, 2020 and in compliance with

the provisions of the Companies Act, 2013 (“Act”) and SEBI(Listing Obligations and Disclosure

Requirements)Regulations, 2015.The deemed venue for the 20thAGM shall be the Registered Office of the

Company. Annual Report will not be sent in physical form.

2. In view of the massive outbreak of the COVID-19 pandemic, social distancing is to be a pre-requisite and

since this AGM is being held through VC / OAVM, pursuant to MCA Circulars, physical attendance of the

Members has been dispensed with. Hence, Members have to attend and participate in the ensuing AGM

through VC/OAVM. Accordingly, the facility for appointment of proxies by the Members will not be available

for the AGM. Hence the Proxy Form, Attendance Slip and Route Map are not annexed to this Notice.

However, the Body Corporates are entitled to appoint authorized representatives to attend the AGM

through VC/OAVM and participate there at and cast their votes through e-voting.

3. Members of the Company under the category of Institutional Investors are encouraged to attend and vote at

the AGM through VC. Body Corporates whose Authorised Representatives are intending to attend the

Meeting through VC/ OAVM are requested to send to the Company on their email Id :

[email protected] , a certified copy of the Board Resolution/authorization letter authorising their representative to attend and vote on their behalf at the Meeting and through E-voting.

4. In compliance with the aforesaid MCA Circulars and SEBI Circular No.

SEBI/HO/CFD/CMD1/CIR/P/2020/79 dated 12thMay, 2020, Notice of the AGM along with the Annual

Report is being sent only through electronic mode to those Members whose email addresses are registered

with the Company/Depositories. Members may note that the Notice and Annual Report will also be

available on the Company’s website www.kushallimited.com, website of stock exchanges i.e. National Stock

Exchange of India Limited at www.nseindia.comthat of Central Depository Services (India) Limited

(“CDSL”), www.evotingindia.com.

5. Members attending the AGM through VC / OAVM shall be counted for the purpose of reckoning the quorum

under Section 103 of the Act.

6. In case of joint holders attending the Meeting, only such joint holder who is higher in the order of names

will be entitled to vote.

7. PROCESS FOR THOSE SHAREHOLDERS WHOSE EMAIL ADDRESSES ARE NOT REGISTERED WITH THE

DEPOSITORIES FOR OBTAINING LOGIN CREDENTIALS FOR E-VOTING FOR THE RESOLUTIONS

PROPOSED IN THIS NOTICE:

(i) For Physical shareholders- please provide necessary details like Folio No., Name of shareholder,

scanned copy of the share certificate (front and back), PAN (self-attested scanned copy of PAN card),

AADHAR (self- attested scanned copy of Aadhar Card) by email to RTA Email id:

[email protected].

(ii) For Demat shareholders -, Members holding Shares in Demat mode can get their E-mail IDs registered

with their respective DPs or by E-mail to [email protected]

(iii) The RTA shall co-ordinate with CDSL and provide the login credentials to the above mentioned

shareholders.

8. The Members can join the AGM in the VC/OAVM mode 15 minutes before and after the scheduled time of

the commencement of the Meeting by following the procedure mentioned in the Notice. Instructions and

other information for members for attending the AGM through VC/OAVM are given in this Notice under

Note No. 28.

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9. As the Annual General Meeting of the Company is held through Video Conferencing/OAVM, we therefore

request the members to submit questions in advance relating to the business specified in this Notice of

AGM on the email ID [email protected].

10. The Register of Members and Share Transfer Books will remain closed from 25th December, 2020 to 31st

Decemer, 2020 (both days inclusive) for the purpose of Annual General Meeting (AGM).

11. Members holding shares in the dematerialized mode are requested to intimate all changes with respect to

their bank details, ECS mandate, nomination, power of attorney, change of address, change in name, etc, to

their Depository Participant (DP). These changes will be automatically reflected in the Company’s records,

which will help the Company to provide efficient and better service to the Members. Members holding

shares in physical form are requested to intimate the changes to the Registrar & Share Transfer Agents of

the Company (RTA). Members are also advised to not leave their demat account(s) dormant for long.

Periodic statement of holdings should be obtained from the concerned Depository Participant and

holdings should be verified from time to time.

12. Pursuant to the requirement of Regulation 26(4) and 36(3) of the Securities and Exchange Board of India

(Listing Obligations and Disclosure Requirements) Regulations, 2015 and Secretarial Standard 2 issued by

The Institute of Company Secretaries of India, the brief profile/particulars of the Directors of the Company

seeking their appointment or re-appointment at the Annual General Meeting (AGM) are stated at the end

of the Explanatory Statement annexed hereto.

13. The Securities and Exchange Board of India (SEBI) has mandated the submission of Permanent Account

Number (PAN) by every participant in securities market. Members holding shares in electronic form are,

therefore, requested to submit the PAN to their DPs with whom they are maintaining their demat accounts

and members holding shares in physical form to the Company / RTA.

14. The members are requested to intimate to the Company, queries, if any, at least 10 days before the date of

the meeting to enable the management to keep the required information available at the meeting.

15. The Shareholders holding Shares in Physical form are advised to get their shares dematerialized as no

physical shares can be traded in the Stock Exchanges in terms of SEBI and Stock Exchange guidelines.

16. This is to bring to the notice of the Shareholders that as per SEBI Notification, the request for effecting

transfer of securities held in Physical form (except in case of transmission or transposition) would not be

entertained and shall not be processed by the Company/ RTA of the Company w.e.f. 1st April, 2019. Hence,

Shareholders are advised to get their physical shares dematerialized.

17. Pursuant to Section 72 of the Companies Act, 2013, members holding shares in physical form may file

nomination in the prescribed Form SH-13 and for cancellation / variation in nomination in the prescribed

Form SH-14 with the Company’s RTA. In respect of shares held in electronic / demat form, the nomination

form may be filed with the respective Depository Participant.

18. Members who wish to inspect the Register of Directors and Key Managerial Personnel and their

shareholding maintained under section 170 of Companies Act, 2013 and Register of Contracts or

arrangements in which directors are interested maintained under section 189 of the Companies Act, 2013

and Relevant documents referred to in this Notice of AGM and explanatory statement on the date of AGM

in electronic mode can send an email to [email protected].

19. The business set out in the Notice will be transacted through electronic voting system and the Company is

providing facility for voting by electronic means. Instructions and other information relating to e-voting

are given in this Notice under Note No. 27 & 29.

20. Members of the Company holding shares either in physical form or in Dematerialized form as on Ben pos date i.e. 4th December, 2020 will receive Annual Report for the financial year 2019-20 through electronic

mode only.

21. Members are requested to notify any changes in their address to the Company’s Registrar & Share

Transfer Agent, Bigshare Services Private Limited ,Mumbai Branch:1st Floor, Bharat Tin Works Building ,

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a. For CDSL: 16 digits Beneficiary ID

b. For NSDL: 8 Character DP ID followed by 8 Digits Client ID

c. Members holding shares in Physical Form should enter Folio

Opp Vasant Oasis,Makwana Road, Marol, Andheri(east)Mumbai,Maharastra-400059

Email id: [email protected]

22. Members are requested to quote their Folio No. or DP ID/ Client ID, in case shares are in physical /

dematerialized form, as the case may be, in all correspondence with the Company / Registrar and Share

Transfer Agent.

23. To support the “Green Initiative”, Members who have not registered their e-mail addresses so far, are

requested to register their e-mail address with the Registrar & Share Transfer Agents of the Company for

receiving all communication including Annual Report, Notices, Circulars, etc. from the Company

electronically.

VOTING THROUGH ELECTRONIC MEANS

24. Pursuant to the provisions of Section 108 of the Companies Act, 2013 read with Rule 20 of the Companies

(Management and Administration) Rules, 2014 (as amended) and Regulation 44 of SEBI (Listing

Obligations & Disclosure Requirements) Regulations 2015 (as amended), and MCA Circulars dated April 8,

2020, April 13, 2020 and May 5, 2020 the Company is providing facility of remote e-voting to its Members

in respect of the business set out in the Notice above may be transacted at the AGM. For this purpose, the

Company has entered into an agreement with Central Depository Services (India) Limited (CDSL) for

facilitating voting through electronic means, as the authorized e-Voting’s agency. The facility of casting

votes by a member using remote e-voting as well as the e-voting system on the date of the AGM will be

provided by CDSL.

25. The Members can join the AGM in the VC/OAVM mode 15 minutes before and after the scheduled time of

the commencement of the Meeting by following the procedure mentioned in the Notice. The facility of

participation at the AGM through VC/OAVM will be made available to at least 1000 members on first come

first served basis. This will not include large Shareholders (Shareholders holding 2% or more

shareholding), Promoters, Institutional Investors, Directors, Key Managerial Personnel, the Chairpersons

of the Audit Committee, Nomination and Remuneration Committee and Stakeholders Relationship

Committee, Auditors etc. who are allowed to attend the AGM without restriction on account of first come

first served basis.

26. THE INTRUCTIONS FOR SHAREHOLDERS FOR REMOTE E-VOTING ARE AS UNDER: (i) The remote e-voting period begins on at 9.00 a.m. on 28th December, 2020 and ends at 5:00 p.m. on

30th December, 2020. During this period shareholders’ of the Company, holding shares either in

physical form or in dematerialized form, as on the cut-off date i.e. 24th December, 2020 may cast their

vote electronically (i.e. by remote e-voting). The remote e-voting module shall be disabled by CDSL for

voting thereafter. Once the vote on a resolution is cast by the Member, the Member shall not be

allowed to change it subsequently or cast the vote again.

(ii) Shareholders who have already voted prior to the meeting date would not be entitled to vote at the

meeting venue. (iii) The shareholders should log on to the e-voting website www.evotingindia.com. (iv) Click on “Shareholders” module.

(v) Now, fill up the following details in the appropriate boxes. (iv) Next enter the Image Verification as displayed and Click on Login.

(v) If you are holding shares in demat form and had logged on to www.evotingindia.com and voted on an

earlier e-voting of any company, then your existing password is to be used.

User

ID

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(viii) If you are a first time user follow the steps given below:

For Members holding shares in Demat Form and Physical Form

PAN Enter your 10 digit alpha-numeric *PAN issued by Income Tax

Department (Applicable for both demat shareholders as well as

physical shareholders)

Members who have not updated their PAN with the Company /

Depository Participant are requested to use the sequence

number which is printed on Postal Ballot / Attendance Slip /

communicated by mail indicated in the PAN field.

Dividend

Bank

Details

OR Date

of Birth

(DOB)

Enter the Dividend Bank Details or Date of Birth (in dd/mm/yyyy

format) as recorded in your demat account or in the company

records in order to login.

If both the details are not recorded with the depository or

company please enter the member id / folio number in the

Dividend Bank details field as mentioned in instruction (v).

(ix) After entering these details appropriately, click on “SUBMIT” tab.

(x) Members holding shares in physical form will then directly reach the Company selection screen.

However, shareholders holding shares in demat form will now reach ‘Password Creation’ menu

wherein they are required to mandatorily enter their login password in the new password field.

Kindly note that this password is to be also used by the demat holders for voting for resolutions of any

other company on which they are eligible to vote, provided that company opts for e-voting through

CDSL platform. It is strongly recommended not to share your password with any other person and

take utmost care to keep your password confidential.

(xi) For Members holding shares in physical form, the details can be used only for e-voting on the

resolutions contained in this Notice.

(xii) Click on the EVSN for KUSHAL LIMITED on which you choose to vote.

(xiii) On the voting page, you will see “RESOLUTION DESCRIPTION” and against the same option “YES/NO”

for voting. Select the option YES or NO as desired. The option YES implies that you assent to the

Resolution and option NO implies that you dissent to the Resolution.

(xiv) Click on the “RESOLUTIONS FILE LINK” if you wish to view the entire Resolution details.

(xv) After selecting the resolution you have decided to vote on, click on “SUBMIT”. A confirmation box will

be displayed. If you wish to confirm your vote, click on “OK”, else to change your vote, click on

“CANCEL” and accordingly modify your vote.

(xvi) Once you “CONFIRM” your vote on the resolution, you will not be allowed to modify your vote.

(XVII) You can also take a print of the votes cast by clicking on “Click here to print”

option on the Voting page. (xviii)If a demat account holder has forgotten the login

password then Enter the User ID and the image verification code and click on Forgot

Password & enter the details as prompted by the system.

(xix) Shareholders can also use Mobile app - “m - Voting” for e voting. m - Voting app is available on Apple,

Android and Windows based Mobile. Shareholders may log in to m - Voting using their e voting

credentials to vote for the company resolution(s).Please follow the instructions as prompted by the

mobile app while Remote Voting on your mobile.

(xx) Note for Non – Individual Members and Custodians:

- Non-Individual Members (i.e. other than Individuals, HUF, NRI etc.) and Custodian are required

to log on to www.evotingindia.com and register themselves as Corporates.

- A scanned copy of the Registration Form bearing the stamp and sign of the entity should be

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emailed to [email protected].

- After receiving the login details, a compliance user should be created using the admin login and

password. The Compliance user would be able to link the account(s) for which they wish to

vote on.

- The list of accounts should be mailed to [email protected] and on approval of

the accounts they would be able to cast their vote.

- A scanned copy of the Board Resolution and Power of Attorney (POA) which they have issued in

favour of the Custodian, if any, should be uploaded in PDF format in the system for the

scrutinizer to verify the same.

- Alternatively Non Individual shareholders are required to send the relevant Board Resolution/

Authority letter etc. together with attested specimen signature of the duly authorized signatory

who are authorized to vote, to the Scrutinizer and to the Company at the email address viz;

[email protected] (designated email address by company), if they have voted from

individual tab & not uploaded same in the CDSL e-voting system for the scrutinizer to verify the

same.

27. INSTRUCTIONS FOR MEMBERS FOR ATTENDING THE AGM THROUGH VC/OAVM ARE AS UNDER:

(i) Members will be provided with a facility to attend the AGM through VC/OAVM through the CDSL e-

Voting system. Members may access the same at https://www.evotingindia.com under

shareholders/members login by using the remote e-voting credentials. The link for VC/OAVM will be

available in shareholder/members login where the EVSN of Company will be displayed.

(ii) Members/Shareholders are encouraged to join the Meeting through Laptops / IPads for better

experience.

(iii) Members who are desirous of attending the AGM through VC/OAVM and whose email IDs are not

registered with the RTA of the Company/DP, may get their email IDs registered as per the instructions

provided in point No. 8 of this Notice.

(iv) Members may attend the AGM, by following the invitation link sent to their registered email ID.

Members will be able to locate Meeting ID / Password / and JOIN MEETING tab. By Clicking on JOIN

MEETING they will be redirected to Meeting Room via browser or by running Temporary Application.

In order to join the Meeting, follow the step and provide the required details (mentioned above –

Meeting Id/Password/Email Address) and Join the Meeting.

(v) Further members will be required to allow Camera and use Internet with a good speed to avoid any

disturbance during the meeting.

(vi) Please note that Participants Connecting from Mobile Devices or Tablets or through Laptop

connecting via Mobile Hotspot may experience Audio/Video loss due to fluctuation in their respective

network. It is therefore recommended to use Stable Wi-Fi or LAN Connection to mitigate any kind of

aforesaid glitches.

(vii) Members who would like to express their views/ask questions during the meeting may register

themselves as a speaker by sending their request in advance atleast 10 days prior to meeting

mentioning their name, demat account number/folio number, email id, mobile number at (company

email id). The shareholders who do not wish to speak during the AGM but have queries may send their

queries in advance 10 days prior to meeting mentioning their name, demat account number/folio

number, email id, mobile number at [email protected]. These queries will be replied by the

Company suitably by email.

(viii) Those members/shareholders who have registered themselves as a speaker will only be allowed to

express their views/ask questions during the meeting.

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28. INSTRUCTIONS FOR MEMBERS FOR E-VOTING DURING THE AGM ARE AS UNDER:-

(i) The procedure for e-Voting on the day of the AGM is same as the instructions mentioned above for

Remote e- voting.

(ii) Only those members/shareholders, who are present in the AGM through VC/OAVM facility and have

not casted their vote on the Resolutions through remote e-Voting and are otherwise not barred from

doing so, shall be eligible to vote through e-Voting system available during the AGM.

(iii) If any Votes are cast by the members/shareholders through the e-voting available during the AGM

and if the same members/shareholders have not participated in the meeting through VC/OAVM

facility, then the votes cast by such members/shareholders shall be considered invalid as the facility

of e-voting during the meeting is available only to the shareholders attending the meeting.

(iv) Members/Shareholders who have voted through Remote e-Voting will be eligible to attend the AGM.

However, they will not be eligible to vote at the AGM. In case any Member who had voted through

Remote E-voting, casts his vote again at the E- Voting provided during the AGM, then the Votes cast

during the AGM through E-voting shall be considered as Invalid.

If you have any queries or issues regarding attending AGM & e-Voting, you may refer the Frequently Asked

Questions (“FAQs”) and e-voting manual available at www.evotingindia.com, under help section or write

an email to [email protected]

29. Mr. Yash Mehta , Proprietor, M/s. Yash Mehta & Associates, Company Secretaries, Ahmedabad

(COP:16535)has been appointed as the Scrutinizer to scrutinize the remote e-voting & e-voting process in a

fair and transparent manner.

30. The Results declared alongwith the report of the Scrutinizer shall be placed on the website of the Company

and on the website of CDSL after the declaration of result by the Chairman or a person authorized by him in

writing. The results shall also be communicated to the Stock Exchange viz. National Stock Exchange of India

Limited.

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DETAILS OF DIRECTOR SEEKING

APPOINTMENT / REAPPOINTMENT

Manoj Agrawal (DIN:00225494)

Nature: Re-appointment

Date of Birth: 07-08-1991

Mr. Manoj Agrawal (aged 55) joined the Company on November 14, 2016 as an Additional (Executive)

Director and subsequently regularized on September 30, 2017 by passing of resolution by shareholder At

17th Annual General Meeting. Mr. Agrawal joined the family business and has played a key role in

implementing international best practices & processes, financial management and optimizing business

procedures, especially in manufacturing .

Directorship held in other public Companies: Not Applicable

Membership/ Chairmanship of Committees in other Companies: - Not Applicable

No of Shares held in the Company as on date: 21374510

DIRECTOR’S REPORT To The Members, The Board of Directors are pleased to present the Company’s 20th Annual Report along with the Audited

Financial Statements for the Financial Year ended March 31, 2020.

FINANCIAL RESULTS

The Company’s financial performance for the year ended March 31, 2020 is summarized below:

1. FINANCIAL SUMMARY

(₹In Lakhs)

2019-20 2018-19

Revenue from operations 18055.95 35828.92

Other income (net) 249.77 292.66

Total Revenue (A) 18305.73 36121.58

Total Expenses (B) 26347.21 34696.87

Profit Before tax (PBT) (A-B) (8041.49) 1424.71

Less Provision for Current Tax (including earlier year)

NIL 56.27

Less: Deferred Tax Provision NIL 37.80

Profit After Tax (PAT) (8041.49) 1330.65

Earnings per share (₹ 2/- each) a). Basic b). Diluted

-3.25 -2.39

0.54 0.40

2. MATERIAL CHANGES AND

COMMITMENTS AFFECTING THE

FINANCIAL POSITION OF THE

COMPANY OCCURRED BETWEEN THE

END OF THE FINANCIAL YEAR AND

DATE OF THE REPORT

No material changes and commitments affecting

the financial position of the Company occurred

between the end of the financial year to which

these Financial Statements relate and on the date

of this report. Further, during the financial year

under report, no significant or material orders have

been passed by any of the regulators or courts or

tribunals impacting the going concern status and

operations of the company in future.

3. CHANGE IN THE NATURE OF

BUSINESS

There was no change in the nature of business

during the year under review.

4. PERFORMANCE OF THE COMPANY

During this year your Company has achieved a

turnover on Basis of ₹18305.73 Lakhs as against

₹36121.58 Lakhs in the previous year. Your

Company posted a Loss of ₹8041.49 Lakhs (before

Tax) as against profit of ₹ 1424.71 Lakhs (before

Tax) in the previous year. While Loss after Tax

(PAT) for the Financial Year 2019-20 was ₹ 8041.49

Lakhs as against Profit after Tax (PAT) of ₹ 1424.71

Lakhs in the previous year.

5. MANAGEMENT DISCUSSION AND

ANALYSIS

The Management Discussion and Analysis Report as stipulated under the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 forms part of this Annual Report.

6. DIVIDEND

Your Directors regret their inability to recommend dividend for the financial year 2019-20.

7. APPROVAL OF SCHEME OF

AMALGAMATION No Scheme has been proposed during the year under review. The company has filed Application with Hon’ble NCLT seeking various prayers for appropriate direction regarding revocation of order approving the Resolution Plan submitted for Rainbow Papers Limited.

8. DISCONTINUATION OF EDUCATION

DIVISION

Your Company had discontinued education

division started in the name and style of

“HUGS ‘n’ CUDDLES” and “Joyjumperz”

w.e.f August 06, 2019, as it was not found

viable to continue the said division.

9. LISTING ON STOCK EXCHANGES

As on March 31, 2020, the equity shares of the company were listed on BSE Limited. The company has paid the annual listing fees for the financial year ending on March 31, 2020 within time.

10. TRANSFER TO RESERVES No amounts are transferred to reserves.

11. PARTICULARS OF LOANS,

GUARANTEES AND INVESTMENTS As on March 31, 2020, there were no outstanding loans or guarantees covered under the provisions of Section 186 of the Act. The details of changes in the Loans, Guarantees and Investments covered under the provisions of Section 186 of the Act are given in the notes to the Financial Statements.

12. DEPOSITS FROM PUBLIC The Company has not accepted any deposits from public falling within the ambit of Section 73 of the Companies Act, 2013(hereinafter referred to as the

‘Act’), and the Companies (Acceptance of Deposits) Rules, 2014.

13. EQUITY SHARE CAPITAL

During the financial year under report, under Resolution plan 69387230 shares were issued at to secured financial creditors of Rainbow Papers limited. Company has yet not received listing approval.

14. DIRECTORS AND KEY MANAGERIAL

PERSONNEL

Resignations:

• CS Shivangi Shah resigned as the Company Secretary and Compliance officer of the company with effect from June 12, 2020 due to personal reasons at the meeting of the Board of Directors of the Company.

Declaration by Independent Directors

All the Independent Directors have submitted their declarations that they meet the criteria of independence as laid down under Section 149(6) of the Companies Act, 2013 and Regulation 16(1)(b) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015.

15. COMMITTEES OF THE BOARD

The details of various committees of Directors constituted under various provisions of Companies Act, 2013 and Rules made thereunder, their constitution, terms of reference and other details are provided in the Corporate Governance Report. Compositions of Board of Directors and various Committees of Directors are available on the Company’s website at www.kushallimited.com

16. NUMBER OF MEETINGS OF THE

BOARD AND COMMITTEES The number of meetings of the board and committees held during the year under review are as under:

• Eight Meetings of the Board of Directors were held during the year.

• Six meetings of the Audit committee were held during the year.

• Two meetings of the Nomination and Remuneration committee were held during the year.

• Two meetings of the Stakeholder Relationship Committee were held during the year.

• One meetings of the Corporate Social Responsibility committee were held during the year.

For details of the meetings of the board and committees, please refer to the Corporate Governance report which forms part of this Annual Report. The intervening gap of the board meetings and audit committee meetings were within the period as prescribed under the Companies Act, 2013.

17. BOARD EVALUATION

Pursuant to the provisions of the Act and SEBI Listing Regulations, read with the Guidance Note on Board Evaluation, the Board has carried out the annual performance evaluation of the Board as a whole, the Directors individually as well as the working of the Board and its Committees. The performance of the Board was evaluated by the Board after seeking inputs from all the Directors on the basis of criteria such as board composition and structure, effectiveness of board processes, information and functioning etc. The Board and the Nomination and Remuneration Committee reviewed the performance of individual directors on the basis of criteria such as contribution of individual director to the board and committee meetings like preparedness on matters to be discussed, constructive contribution and inputs in meetings etc. Further, in a separate meeting of independent directors, performance of non-independent directors, the Board as a whole and its Chairman was evaluated as stipulated under the SEBI Listing Regulations.

18. CONTRACTS OR ARRANGEMENTS

WITH RELATED PARTIES During the financial year ended 31st March 2020, all the contracts or arrangements or transactions entered into by the Company with the Related

Parties were in the ordinary course of business and on arm’s length basis and were in compliance with the applicable provisions of the Companies Act, 2013 and SEBI (Listing Obligations & Disclosure Requirements) Regulations, 2015.

Prior omnibus approval of the Audit Committee is obtained on a yearly basis for the transactions which are of a foreseen and repetitive nature. A statement giving details of all RPTs is placed before the Audit Committee for review on a quarterly basis.

There are no materially significant related party transactions entered into by the Company with its promoters, directors, key managerial personnel or other designated persons which may have a potential conflict with the interest of the Company at large.

As provided under section 134[3][h] of the Act and Rules made there under disclosure of particulars of material transactions with related parties entered into by the Company with related parties in FORM AOC 2 is annexed to this report as Annexure B.

Further, Transactions with related parties, as per the requirements of IND AS 24 are disclosed in the notes to financial statements.

The Board of Directors has adopted a policy on Related Party Transactions which has been uploaded on website of the Company:

(http://kushallimited.com/files/07-policy-of-

related-party-transactions-sc5a4dd71befe33.pdf)

19. SUBSIDIARY AND ASSOCIATE

COMPANIES

A separate section on the performance and financial position of each of the subsidiaries and associates companies in Form AOC-1 forms part of Board’s Report and same is appended as Annexure A. As per the SEBI Listing Regulations, a policy on material subsidiaries as approved by the Board of Directors may be accessed on the Company’s website:

(http://kushallimited.com/files/5-policy-for-

determining-material-subsidiary-

sc5a4dd68e8bca4.pdf)

20. CORPORATE SOCIAL

RESPONSIBILITY

Your Company recognizes the vital role played by society at large in its growth and development and strives to discharge its social responsibility as a corporate citizen. The key philosophy of all our Corporate Social Responsibility (CSR) initiatives is guided by our belief “Every Smile Counts ....” Our CSR projects focus on participatory and collaborative approach with the community. Over a period of last three years, your Company has emphasized CSR projects in the areas of Education, Healthcare, Women empowerment and Water and Sanitation. As per the provisions of Section 135 of the Companies Act, 2013 read with Companies (Corporate Social Responsibility Policy) Rules, 2014, a company, meeting the applicability threshold, needs to spend at least 2% of its average net profit for the immediately preceding three financial year on corporate social responsibility (CSR) activities. The areas for CSR activities are eradication of hunger and malnutrition, promoting education, art and culture, healthcare, destitute care and rehabilitation, environment sustainability, disaster relief and rural development projects. The details of CSR activities carried out by your Company during the year under review are set out in Annexure D forming part of this report. The Corporate Social Responsibility Policy as approved by the Board may be accessed on the Company’s website:

(http://kushallimited.com/files/10-policy-on-

corporate-social-responsibility-

sc5a587988cc3ef.pdf)

21. EXTRACT OF ANNUAL RETURN

In accordance with Section 134(3)(a) of the Companies Act, 2013, an extract of the annual return in the prescribe format is appended as Annexure F to the Board’s Report.

22. CORPORATE GOVERNANCE REPORT

A separate section on Corporate Governance practices followed by the Company, together with a certificate from the Company’s Auditors confirming compliance, forms a part of this Annual Report, as per SEBI (Listing Obligations & Disclosure Requirements), Regulations, 2015.

The Corporate Governance report as stipulated under the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 forms part of this Annual Report

23. POLICY ON DIRECTORS’

APPOINTMENT AND REMUNERATION

Matching the needs of company and enhancing the competencies of the board are the basis for the Nomination and Remuneration Committee to select a candidate for the appointment to the board.

The current policy is to have a balanced mix of executive and non-executive Directors to maintain the independence of the board, the Board of Directors comprise of 6 Directors out of which 3 are non-executive, including one women Director, which is one half of the total number of Directors.

The policy of the company on directors’ appointment, including criteria for determining qualification, positive attributes, independence of a director and other matters, as required under sub-section (3) of section 178 of the Companies Act 2013, is governed by the Nomination and Remuneration policy and other details are available on the company’s website:

(http://kushallimited.com/files/nomination-and-

remuneration-policy-sc5ad72419584fc.pdf)

We affirm that the remuneration paid to the Executive directors of the company is as per the Nomination, remuneration policy.

24. BOARD DIVERSITY

The board has adopted a Policy on Board diversity which sets out the approach to diversity of the board of directors. The Policy on Board diversity is available on the company’s website:

(https://www.kushallimited.com/files/policy-on-

board-diversity-sc5b727b86ca7bb.pdf)

25. WHISTLEBLOWER/VIGIL MECHANISM

Your Company has an effective Vigil Mechanism system which is embedded in its Code of Conduct. The Code of Conduct of your Company serves as a guide for daily business interactions, reflecting your Company’s standard for appropriate behavior and living corporate values.

The Whistle Blower Policy has been uploaded on the website of the Company

(https://www.kushallimited.com/files/whistle-

blower-policy-sc5b72817c54b63.pdf). The Company’s Whistle Blower Policy is the mechanism for directors and employees of the Company to report concerns about unethical behaviour, actual or suspected fraud or violation of the Company’s code of conduct, violations of legal or regulatory requirements, incorrect or misrepresentation in any financial statements and reports etc. The mechanism provides for adequate safeguards against victimization of those who avail the mechanism and also provides for direct access to the Chairman of Audit Committee in exceptional cases.

26. PREVENTION OF SEXUAL

HARASSMENT AT WORK PLACE The Company has zero tolerance towards sexual harassment at the workplace and has adopted a policy on prevention of sexual harassment policy in line with the requirements of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and the Rules thereunder. An Internal Compliance Committee has been set up to redress complaints received regarding sexual harassment. All employees (permanent, contractual, temporary, trainees) are covered under this policy. During the year under review, no complaint relating to sexual harassment has been received.

27. DIRECTORS’ RESPONSIBILITY

STATEMENT

Pursuant to Section 134(5) of the Companies Act, 2013, the board of directors, to the best of their knowledge and ability, confirm:

(a) that in the preparation of the annual accounts, the applicable accounting standards have been followed and no material departures have been made from the same;

(b) that appropriate accounting policies have been selected and applied consistently and have made judgments and estimates that are reasonable and

prudent so as to give a true and fair view of the state of affairs of the Company as at March 31, 2020 and of the profit and loss of the Company for the year ended March 31, 2020;

(c) that proper and sufficient care has been taken for the maintenance of adequate accounting records in accordance with the provisions of the Act, for safeguarding the assets of the Company and for preventing and detecting fraud and other irregularities;

(d) that the annual accounts has been prepared on a going concern basis;

(e) that proper internal financial controls were followed by the Company and that such internal financial controls are adequate and were operating effectively; and

(f) that proper systems have been devised to ensure compliance with the provisions of all applicable laws and that such systems were adequate and operating effectively.

28. AUDITORS

a). Statutory Auditors The Board of Director, based on the recommendation of the Audit Committee, at their meeting held on November 12, 2018 appointed M/s. S. V. Sojitra & Co., Chartered Accountants, Ahmedabad (FRN:139013W) as a Statutory Auditor of the Company to fill up causal Vacancy. Their appointment was subsequently approved by the shareholder at 18th Annual general Meeting held on December 10, 2018 pursuant to Section 139 of Companies Act 2013 for a period of 5 consecutive years from the conclusion of 18th Annual General Meeting of the Company till the conclusion of 23rd

Annual General meeting of the Company. The Company has received the consent from the M/s. S. V. Sojitra & Co., Chartered Accountants, Ahmedabad (FRN:139013W) and confirmation to the effect that they are not disqualified to be appointed as the Auditors of the Company in terms of the provisions of the Companies Act, 2013 and rules made thereunder.

b). Auditor’s Report

The report of the Statutory Auditor along with Notes to Accounts are enclosed to this report. The

observations made in the Auditors’ Report are self-explanatory and therefore do not call for any further comments.

c). Secretarial Auditor:

Pursuant to provisions of Section 204 of the Companies Act, 2013 read with rule 9 of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014, your Company engaged the services of M/S. M.S BUCHASIA & ASSOCIATES, Practising Company Secretaries, Ahmedabad (COP: 4156) to conduct the Secretarial Audit of the Company for the financial year ended March 31, 2020. The Secretarial Audit Report is awaited.

29. INTERNAL CONTROL SYSTEMS AND

THEIR ADEQUACY

Your Company has an effective Internal Control System to prevent fraud and misuse of Company’s resources and protect shareholders’ interest. These systems ensure that transactions are authorized, recorded and reported diligently, to safeguard the assets of the Company. Your Company has also established and maintained the Internal Financial Control to ensure the orderly and efficiently conduct of its business inter alia adherence to Company’s policies, the safeguarding of its assets, the prevention and detection of frauds and errors, the accuracy and completeness of the accounting records, and the timely preparation of reliable financial information, as required under the Companies Act, 2013.

30. SIGNIFICANT AND MATERIAL

ORDERS There are no significant and material orders passed by the regulators or courts or tribunals impacting the going concern status and Company’s operations in future.

31. PARTICULAR OF EMPLOYEES

The information pertaining to Section 197(12) read with Rule 5(1) of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014, as amended from time to time is annexed herewith as Annexure C. There is no employee drawing a salary exceeding the limit prescribed under Section 197(12) read with Rule 5 (2) of The Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014.

32. CONSERVATION OF ENERGY,

TECHNOLOGY ABSORPTION,

FOREIGN EXCHANGE EARNINGS

AND OUTGO: The information on conservation of energy, technology absorption and foreign exchange earnings and outgo as stipulated under Section 134(3)(m) of the Companies Act, 2013 read with Rule, 8 of The Companies (Accounts) Rules, 2014 are as under: A). Conservation of Energy: The operations of your Company involve low energy consumption. Adequate measures have, however, been taken to conserve energy by way of optimizing usage of power. B). Technology Absorption: In the Financial Year 2019-20, no specific technology involved in the business model of the company. C). Import of Technology:

The Company has not imported any technology during the year.

D). Foreign Exchange Earning & Out Go:

Particular 2019-20 2018-19

Total Foreign Exchange Outgo :

Value of import on

834905.27

5003436.88

CIF basis-Traded Goods

USD USD

Total Foreign Exchange Earned :

VALUE OF Export

on CIF basis-Traded

Goods

NIL

1553753.71 USD

33. ACKNOWLEDGEMENT Your Directors take this opportunity to express their gratitude to the various stakeholders – customers, shareholders, banks, dealers, vendors and other business partners for the continued cooperation and support extended by them during the year under review. Your Directors would also like to acknowledge the exceptional contribution and commitment from all the employees of the Company during the year under review. For and on Behalf of the Board

Sandeep Agrawal (Chairman and Managing Director) (DIN: 00239648) Place: Ahmedabad Date: December 08, 2020

ANNEXURE-A TO THE DIRECTOR’S REPORT

FORM AOC 1

(Pursuant to first proviso to sub-section (3) of section 129 read with rule 5 of Companies (Accounts) Rules, 2014)

Statement containing salient features of the financial statement of subsidiaries/associate

companies/joint ventures

PART “A”: SUBSIDIARIES

Notes: The following information shall be furnished at the end of the statement: 1. Names of subsidiaries which are yet to commence operations: None 2. Names of subsidiaries which have been disposed off during the year:

i. Kushal Integrated Industrial Park LLP – Wholly Owned Subsidiary LLP

PART “B”: ASSOCIATES AND JOINT VENTURES

Statement pursuant to Section 129 (3) of the Companies Act, 2013 related to Associate Companies

and Joint Ventures

Name of Associates/Joint Ventures

NOT APPLICABLE

Associate/Joint Venture

1. Latest audited Balance Sheet Date

2. Shares of Associate/Joint Ventures held by the company on the year end

i. No:

ii. Amount of Investment in Associates/Joint Venture

iii. Extend of Holding %

3. Description of how there is significant influence

4. Reason why the associate/joint venture is not consolidated

5. Networth attributable to Shareholding as per latest audited Balance Sheet

6. Profit / Loss for the year

i. Considered in Consolidation

ii. Not Considered in Consolidation

1. Names of associates or joint ventures which are yet to commence operations: NONE 2. Names of associates or joint ventures which have been liquidated or sold during the year: NONE For, S. V. Sojitra & Co.

For and on behalf of the Board of KUSHAL LIMITED

Sanjay V. Sojitra Manoj Agrawal Kushal Agrawal Proprietor Membership No. 135239 FRN NO. 139013W

Director (DIN: 00225494)

Director (DIN:03043294)

Place: Ahmedabad Date: December 08,2020

CS Shivangi Shah Company Secretary

Jitendra Yadav Chief Financial Officer

ANNEXURE-B TO THE DIRECTOR’S REPORT

AOC-2

(Pursuant to clause (h) of sub-section (3) of section 134 of the Act and Rule 8(2) of the Companies (Accounts) Rules, 2014)

Form for disclosure of particulars of contracts/arrangements entered into by the company with related parties referred to in sub-section (1) of section 188 of the Companies Act, 2013 including certain arm’s length transactions under third proviso thereto 1. Details of contracts or arrangements or transactions not at arm’s length basis: Kushal Limited has not entered into any contract or arrangement or transaction with its related parties which is not at arm’s length. 2. Details of material contracts or arrangement or transactions at arm’s length basis: None

For and on Behalf of the Board

Sandeep Agrawal

Place: Ahmedabad (Chairman and Managing Director) Date: December 08, 2020 (DIN: 00239648)

ANNEXURE-C TO THE DIRECTOR’S REPORT

PARTICULARS OF EMPLOYEES

1. DISCLOSURE OF REMUNERATION AS REQUIRED UNDER SECTION 197(12) OF THE COMPANIES ACT, 2013 READ WITH RULE 5(1) OF THE COMPANIES (APPOINTMENT AND REMUNERATION OF MANAGERIAL PERSONNEL) RULES, 2014

i). The ratio of the remuneration of each Director to the median remuneration of the employees of the Company for the Financial Year 2019-20 and the percentage increase in remuneration of each Director, Chief Financial Officer, Chief Executive Officer, Company Secretary or Manager, if any, in the Financial Year 2019-20:

Sr. no.

Name of Director/KMP and Designation

Remuneration Of Director/KMP for financial year 2019-20 (₹ in Lakhs)

% increase in Remuneration in the Financial Year 2019-20

Ratio of remuneration of each Director to median remuneration of employees

1. Mr. Sandeep Agrawal Chairman and Managing Director (DIN: 00239648)

18.00

-14.83% 16.98 times

2. Mr. Manoj Agrawal Executive Director (DIN: 00225494)

9.00

-28.22% 8.49 times

3. Kushal Agrawal (Executive Director) (DIN: 03043294)

6.00

NIL 5.66 times

4. Kavita Tejaskumar Shah Independent Director (DIN: 05295442)

0.98 N.A. 0.92 times

5. Dharmendra Bhuchhada Independent Director (DIN: 06468613)

1.17 N.A. 1.10 times

6. Anil Soni Independent Director (DIN: 07579989)

1.04 N.A. 0.98 times

7. Vimal Shah Chief Financial Officer

NIL*

N.A. NA

8. Khushboo Surana Company Secretary

NIL***

N.A. NA

9. Jitendra Yadav Chief Financial Officer

5.86**

N.A. NA

10. Shivangi Shah Company Secretary

3.93****

N.A. NA

*CA Vimal Shah resigned as Chief Financial Officer of the Company w.e.f February 28, 2019. **Jitendra Yadav appointed as Chief Financial Officer of the Company w.e.f March 01, 2019.

***CS Khushboo Surana resigned as Company Secretary and Compliance Officer of the Company w.e.f February 28, 2019. ****CS Shivangi Shah appointed as Company Secretary and Compliance officer of the Company w.e.f March 01, 2019. ii). The percentage increase in the median remuneration of employees in the Financial Year: The median remuneration of employees in the Financial Year 2019-20 has decreased by 59.31% as compared to the previous year. iii). The number of permanent employees on the rolls of Company: As on 31st March 2020, there were 21 permanent employees on the rolls of the company. vi). Average percentile increase already made in the salaries of employees other than the managerial personnel in the last Financial Year and its comparison with the percentile increase in the managerial remuneration and justification thereof and point out if there are any exceptional circumstances for increase in the managerial remuneration: Average decrease in remuneration in FY 2019-20 for Managerial Personnel: increment in salary of managerial Personnel is 13.63% (average). Average decrease in remuneration in FY 2019-20 for Non Managerial Personnel: 57.37% (Average percent) increment in salary of employees. v). Affirmation that the remuneration is as per the remuneration policy of the Company: It is hereby affirmed that the remuneration paid is as per the as per the remuneration Policy for Directors, Key Managerial Personnel and other Employees. 2. Disclosure under Rule (5)(2)(iii) of the Companies (Appointment And Remuneration Of Managerial

Personnel) Rules, 2014- Not Applicable For and on behalf of the Board Sandeep Agrawal Place: Ahmedabad (Chairman and Managing Director) Date: December 08,2020 (DIN: 00239648)

ANNEXURE-D TO THE DIRECTOR’S REPORT

ANNUAL REPORT ON CORPORATE

SOCIAL RESPONSIBILITY ACTIVITIES

1. A brief of the Company’s CSR Policy, including overview of projects or programmes proposed to be undertaken :

The Company believes to actively contribute to the social and economic development of the society in which the company operates. The company undertakes corporate social responsibility activities enumerated in schedule VII of the Companies Act, 2013 from time to time. In doing so it plans to build a better and sustainable way of life for the weaker sections and to contribute to the social development of the society in which the company operates. Our projects focus to remove the obstacles that are holding back people and the society, and giving the disadvantaged a fair opportunity at unlocking their true potential. All our CSR projects are selected and implemented in accordance with our CSR Policy. Our Vision is to advance the quality of life through our social commitments to help build healthy, sustainable, efficient and educated communities. The Company’s CSR policy can be accessed on.: www.kushallimited.com

2. The Composition of the CSR Committee.

The Corporate Social Responsibility Committee was constituted with the following members:

Name of the Director Category

Mr. Dharmendra Bhuchhada Chairman

Mr. Sandeep Agrawal Member

Mr. Kushal Agrawal Member

3. Average net profit of the company for last three financial years: ₹ 1263.73 Lakhs

4. Prescribed CSR Expenditure (two per cent. of the amount as in item 3 above): ₹ 25.27 Lakhs

5. Details of CSR spent during the financial year 2019-20. (a) Total amount spent for the financial year₹ 25.28 Lakhs (b) Amount unspent , if any-Nil

(c) Manner in which the amount spent during the financial year 2019-20 is as is detailed below (₹ in Lakhs)

Sr.no

CSR project or activity Identified.

Sector in which the Project is covered

Projects or programs (1) Local area or other (2) Specify the State and district where projects or programs was undertaken

Amount outlay (budget) project or programs wise

Amount spent on the projects or programs Sub-heads: (1) Direct expenditure on projects or programs (2)Overheads:

Cumulative expenditure Upto to the reporting period

Amount spent: Direct or through implementing agency

1 Contribution to Pushpa Tulsi Foundation

Various sectors covered by Schedule VII of the

Ahmedabad, Gujarat

15.28 15.28 15.28 Direct through Foundation

2 Contribution to Shree Monark Eduation Trust

Various sectors covered by Schedule VII of the

Ahmedabad, Gujarat

10.00 10.00 10.00 Direct

25.28 25.28 25.28

6. In case the company has failed to spend the two per cent of the average net profit of the last three financial years or any part thereof, the company shall provide the reasons for not spending the amount in its Board report. - NA

7. A responsibility statement of the CSR Committee that the implementation and monitoring of CSR Policy, is in compliance with CSR objectives and Policy of the company.

We hereby declare that implementation and monitoring of the CSR policy are in compliance with CSR objectives and policy of the Company. FOR KUSHAL LIMITED Mr. Dharmendra Bhuchhada Mr. Sandeep Agrawal (Chairman, CSR Committee) (Member and Managing Director) Place: Ahmedabad Date: December 08,2020

Form No.MR-3

SECRETARIAL AUDIT REPORT For the Financial Year ended 31.03.2020

[Pursuant to section 204(1) of the Companies Act, 2013 and Rule No.9 of the Companies

(Appointment and Remuneration Personnel) Rules, 2014]

To,

The Members,

KUSHAL LIMITED

CIN: L74110GJ2000PLC037472

(Formerly known as Kushal Tradelink Limited),

PLOT NO. 43 B/S NAVNEET PRAKASHAN SUKHRAMNAGAR,

GOMTIPUR AHMEDABAD GUJARAT 380023 INDIA

I have conducted the Secretarial Audit of the compliance of applicable statutory provisions and the

adherence to good corporate practices by Kushal Limited (Formerly Known as Kushal Tradelink

Limited), (herein after called the company). Secretarial Audit was conducted in a manner that

provided me a reasonable basis for evaluating the corporate conducts/statutory compliances and

expressing my opinion thereon.

Based on my verification of the Company’s books, papers, minute books, forms and returns filed and

other records maintained by the company and also the information provided by the Company, its

officers, agents and authorized representatives during the conduct of secretarial audit, I hereby

report that in my opinion, the company has, during the audit period covering the financial year

ended on 31st March, 2020, complied with the statutory provisions listed hereunder and also that the

Company has proper Board-processes and compliance-mechanism in place to the extent, in the

manner and subject to the reporting made hereinafter:

I have e-examined the books, papers, minute books, forms and returns filed and other records

maintained by the Company for the financial year ended on 31st March, 2020 according to the

provisions of:

i. The Companies Act, 2013 (‘the Act’) and the rules made there under;

ii. The Securities Contracts (Regulation) Act, 1956 (‘SCRA’) and the rules made there under;

iii. The Depositories Act, 1996 and the Regulations and Bye-laws framed there under;

iv. Foreign Exchange Management Act, 1999 and the rules and regulations made there under to the extent of Foreign Direct Investment and Overseas Direct Investment and External

commercial borrowing;

v. The following Regulations and Guidelines prescribed under the Securities and Exchange Board of India Act, 1992 (‘SEBI Act’):-

a) The Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011;

b) The Securities and Exchange Board of India (Prohibition of Insider Trading)

Regulations, 2015;

c) The Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018 ;

d) The Securities and Exchange Board of India (Share Based Employee Benefits)

Regulations, 2014; - Not Applicable on company during the Audit Period

e) The Securities and Exchange Board of India (Issue and Listing of Debt Securities)

Regulations, 2008; - Not Applicable to company during the Audit Period

f) The Securities and Exchange Board of India (Registrars to an Issue and Share Transfer

Agents) Regulations, 1993 regarding the Companies Act and dealing with client;

g) The Securities and Exchange Board of India (Delisting of Equity Shares) Regulations,

2009; - Not Applicable to company during the Audit Period

h) The Securities and Exchange Board of India (Buyback of Securities) Regulations, 2018; -Not Applicable to company during the Audit Period

vi. The management has identified and confirmed the following laws as specifically applicable to

the Company:-

a) The Employee’s Provident Fund & Miscellaneous Provisions Act, 1952

b) The Employees’ State Insurance Act, 1948

c) The Maternity Benefit Act, 1961

d) The Payment of Gratuity Act, 1972

e) The Workmen’s Compensation Act, 1923

f) Payment of Bonus Act,1965

I have also examined compliance with the applicable clauses of the following:

a) Secretarial Standards issued by The Institute of Company Secretaries of India; b) SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 and the

Listing Agreements entered into by the Company with BSE Limited.

During the period under review, the Company has complied with the provisions of the Act, Rules,

Regulations, Guidelines, Standards, etc. as mentioned above except following:-

1. The Bombay Stock Exchange has sought clarification from KUSHAL LIMITED on April 3, 2019

with reference to news appeared in www.dnaindia.com dated April 3, 2019 quoting "CGST

unearth Rs 88 crore tax evasion in KUSHAL LIMITED" under Compliance Requirement

Regulation 30 of SEBI LODR, 2015: It is observed that the intimation to stock exchange about

this material event was conveyed by the Company on 03.04.2019 i.e. the date when the

information made available to Compliance Officer and the CGST Officials arrested CMD Mr.

Sandeep Agrawal for the alleged offence on 01.04.2019. The Company replied to the Stock

Exchange vide Clarification Letter dated 03.04.2019 that the matter is sub judice and alleged

amount and the estimated impact on the listed entity is uncertain.

2. Bombay Stock Exchange Letter dated 11.06.2019 received via Email and further email dated

20.06.2019, regarding delay in furnishing prior intimation of meeting of Board of Directors as

per provisions of Regulation 29(2) and 29(3) of SEBI (Listing Obligation and Disclosure

Requirements) Regulation, 2015 for Raising of Funds through External Commercial Borrowing-

fine imposed - Fine imposed amounting to Rs. 10000/- + 18% GST vide Stock Exchange Letter

dated 11.06.2019 (Ref. No. LIST/COMP/536 170/Reg. 29(2) – May 2019/89/2019-20- It is

observed that the Company did not raise any fund by way of ECB and neither any Agreement

executed thereafter but it was one of the option which was discussed by the Board of Directors

for the purpose of making payment under resolution plan for the acquisition of stressed assets

of Rainbow Papers Ltd. The Company replied to the Stock Exchange vide Letter dated

21.06.2019 mentioning that once RBI permission is received, another Board Meeting will be

conducted for approval of issuance of ECBs, as per provisions of Regulation 29 and 30 of SEBI

(Listing Obligation and Disclosure Requirement) Regulations, 2015.

3. Bombay Stock Exchange Letter dated 17.06.2019 received via Email, regarding Late- Submission

of financial results for March 2019- Fine imposed amounting to Rs. 5000/- + 18% GST vide

Stock Exchange Letter dated 17.06.2019 (Ref. No. LIST/COMP/536 170/Reg. 33/99/2019-20- It

is observed that the company has submitted Financial Results within 30 minutes of conclusion

of Board Meeting. The Company has replied to the Stock Exchange vide Letter dated 18.06.2019

through E-mail.

I further report that

� The Board of Directors of the Company is duly constituted with proper balance of Executive Directors, Non-Executive Directors and Independent Directors. During the year under review,

there were no changes in the composition of the Board of Directors of Company.

� Adequate notice is given to all directors to schedule the Board Meetings, agenda and detailed notes on agenda were sent at least seven days in advance, and a system exists for seeking and

obtaining further information and clarifications on the agenda items before the meeting and

for meaningful participation at the meeting.

� Majority decision is carried through while the dissenting members’ views are captured and recorded as part of the minutes.

I further report that there are adequate systems and processes in the company commensurate with

the size and operations of the company to monitor and ensure compliance with applicable laws, rules,

regulations and guidelines.

I further report that during the audit period:

1. Passed Board resolution for resignation of company secretary and compliance officer Shivangi Shah) result of which was declared on 13/06/2020.

2. During the year company has satisfied following charges filed CHG-4 on MCA

SRN Charge Id Charge

Holder Name

Date of

Creation

Date

of

Modifi

cation

Date of

Satisfaction Amount

R34020289 100162824 IVL FINANCE

LIMITED 28/02/2018 - 29/01/2020 117700000

R05296199 100227594

SHREE

SULPHURICS

PRIVATE

LIMITED

20/12/2018 - 11/10/2019 99000000

3. Passed board resolution for Discontinuation of the Education Division started in the'name

and style of “HUGS ‘n’ CUDDLES” and “joyjumperz” and result of which was declared on

august 07,2019

4. Passed board resolution for taking note on Resignation of M/s MJV & CO. as Internal auditor

a Result of same has been declared on September 03,2019 and for Appointment of M/s

Sameer Modi & co. [FRN no. 148555W) internal Auditor to fill Casual Vacancy.

5. Passed special resolution for Sale Registered Office of the Company situated at Plot no. 115,

Off C.G. Road, Navrangpura, Ahmedabad-380009, Gujarat , Member approval taken on 30th

September 2020. Disclosure in the terms of pursuant to the Regulation 30 of the SEBI

(Listing Obligations and Disclosure Requirements), Regulations, 2015 has been made on

January 01,2020

6. Company has changed its registered office address from KUSHAL HOUSE Plot No 115, Off

C.G. Road, Navrangpura Ahmedabad 380009 Gujarat to PLOT NO. 43 B/S NAVNEET

PRAKASHAN SUKHRAMNAGAR, GOMTIPUR AHMEDABAD GUJARAT 380023 INDIA. Result

of the same has been declared on January 18,2020

7. Sale/ Lease/ Transfer or otherwise Dispose-of Kheda Division of the Company situated at

725. Kheda Dholka Road, Nr. Kheda Industrial Park At. Po. Vasna Bujarg, Kheda, Gujarat

387560, for this board meeting held and result of the same has been declared on February

19, 2020 and the approval of the members of the Company through Postal Ballot/E-Voting

under Section 180(1) (a) of the Companies Act, 2013 taken and result of the same has been

declared on March 30,2020

8. Passed special resolution for Sale/transfer or dispose—off investments or shareholding of

the Company in Kushal Impex PTE LTD., Singapore, wholly owned subsidiary company.

Member approval taken on 30th September 2020. disclosure in the terms of pursuant to the

Regulation 30 of the SEBI (Listing Obligations and Disclosure Requirements), Regulations,

2015 has been made on March 25,2020 and revision made on July 2,2020.

9. Passed special resolution for Sale/transfer or dispose—off investments or shareholding of

the Company in Kashish Worlwide FZE, U.A.E., wholly owned subsidiary company, Member

approval taken on 30th September 2020. Disclosure in the terms of pursuant to the

Regulation 30 of the SEBI (Listing Obligations and Disclosure Requirements), Regulations,

2015 has been made on March 31,2020.

10. Sale of Bhavda Division of the Company situated at Block No. 663-664, N. H. No, 59 Kujad

Highway, Village: Bhavda, Ta. Daskroi, Dist. Ahmedabad-382433, Gujarat and Disclosure in

the terms of pursuant to the Regulation 30 of the SEBI (Listing Obligations and Disclosure

Requirements), Regulations, 2015 has been made on January 09,2020.

11. Sale of Bhuj Division of the Company situated at R.S. No. 202, Village- Nani Reladi. Taluka-

Bhuj. and Disclosure in the terms of pursuant to the Regulation 30 of the SEBI (Listing

Obligations and Disclosure Requirements), Regulations, 2015 has been made on January

11,2020.

12. Pursuant to Resolution Plan (Which inter-alia includes scheme of Amalgamation of Rainbow

Papers Limited into Kushal Limited) approved by Hon’ble NCLT Ahmedabad Bench vide its

order dated 27‘h February, 2019 under IBC, 2016 the Board of Directors of the Company has

approved allotment of 6,93,87,230 Equity Shares to the Secured Financial Creditors of

Rainbow Papers Limited at an issue price of Rs. 26.95 per equity share Consequent to the

aforesaid allotment, the paid-up equity share capital of the Company stands increased to rs.

63,38,25,380 divided into 31,69,12,690 Equity Shares( as listing approval for 6,93,87,236 to

BSE done and PAS-3 uploaded on MCA , but BSE asked to allot 6,93,87,230 for no –rounding

off provision so again revised PAS-3 filed)

For M. S. Buchasia & Associates

Practising Company Secretaries

Manish Buchasia

Proprietor

COP: 4156, FCS: 5843

Date: 10/12/2020

Place: Ahmedabad

Note: This Report is to be read with Our Letter of event date which is annexed as Annexure “A” and

forms an integral part of this report.

Annexure: “A”

To,

The Members,

KUSHAL LIMITED

CIN: L74110GJ2000PLC037472

(Formerly known as Kushal Tradelink Limited),

PLOT NO. 43 B/S NAVNEET PRAKASHAN SUKHRAMNAGAR,

GOMTIPUR AHMEDABAD GUJARAT 380023 INDIA

Secretarial Audit Report of event date, for the Financial Year 2019-20 is to be read along with this

Letter.

1. Maintenance of Secretarial Record is the responsibility of the management of the company. My responsibility is to express an opinion on Secretarial Records based on my Audit.

2. I have followed the audit practices and processes as were appropriate to obtain reasonable assurance about the correctness of the contents of the Secretarial Records. The verification was

done on test basis to ensure that correct facts are reflected in Secretarial records. I believe that

the processes and practices I followed provide a reasonable basis for my opinion.

3. I have not verified the correctness and appropriateness of financial records and books of accounts of the company.

4. Wherever required, I have obtained the Management Representation about the compliance of laws, rules and regulations and happening of events etc.

5. The compliance of the provisions of Corporate and other applicable laws, rules, regulations, standards is the responsibility of the management. My examination was limited to the verification

of the procedures on test basis.

6. The Secretarial Audit report is neither an assurance as to the future viability of the company nor of the efficacy or effectiveness with which the management has conducted the affairs of the

company.

7. The verification through physical checking is not possible due to covid -19, e- verification done.

8. Company secretary and compliance officer has resigned on JUNE,12 2020.

9. Newspaper advertisements for financial results of quarter ended September 2019 and December 2019 and March 2020 not done.

10. Intimation of board meeting on 18.01.2020 for shifting of registered office from KUSHAL HOUSE Plot No 115, Off C.G. Road, Navrangpura Ahmedabad 380009 Gujarat to PLOT NO. 43

B/S NAVNEET PRAKASHAN SUKHRAMNAGAR, GOMTIPUR AHMEDABAD GUJARAT 380023

INDIA not done.

11. Intimation of board meeting for Approval of Sale/ Lease/ Dispose – Of Kheda Division of the Company Pursuant to Section 180 (1) (A) of the Companies Act, 2013 not done.

For M. S. Buchasia & Associates

Practising Company Secretaries

Manish Buchasia

Proprietor

COP: 4156, FCS: 5843

Date: 10/12/2020

Place: Ahmedabad

ANNEXURE - F TO THE DIRECTOR’S REPORT

FORM MGT- 9

EXTRACT OF ANNUAL RETURN As on the Financial Year ended 31st March, 2020

[Pursuant to Section 92(3) of the Companies Act, 2013, and Rule 12(1) of the Companies (Management and Administration) Rules, 2014]

I. REGISTRATION AND OTHER DETAILS

Details Particular

CIN: L74110GJ2000PLC037472

Registration Date 03/03/2000 Name of the Company KUSHAL LIMITED

Category / Sub-Category of the Company

Company Limited by shares/Indian Non- Government Company.

Address of the Registered Office and contact details

PLOT NO. 43 B/S NAVNEET PRAKASHAN SUKHRAMNAGAR, GOMTIPUR Ahmedabad Gujarat- 380023, Tel: 079-26408027; Email: [email protected], Website:www.kushallimited.com

Whether listed company Yes Name, address and contact details of Registrar and Transfer Agent, if any

Bigshare Services Private Limited, A-802, Samudra Complex, Off C G Road, Navrangpura ,Near Girish Cold Drinks Ahmedabad -380009 Tel No.: +91 – 079-40392570 Contact Person: Mr. Prem Kumar Email: [email protected] Website: www.bigshareonline.com

II. PRINCIPAL BUSINESS ACTIVITIES OF THE COMPANY

All the business activities contributing 10 % or more of the total turnover of the company shall be stated:

S. No. Name and Description of Main Products / Service

NIC Code of the Product/ Service

% to Total Turnover of the Company

1 Manufacture of paper and paper products 17014 96%

2 Merchandise trade 46696 4%

*As per National Industrial Classification 2008

III. SHARE HOLDING PATTERN (Equity Share Capital Breakup as Percentage of Total Equity)

i) Category-wise Share Holding

Category Code

Category of Shareholder

No. of Shares held at the beginning of the year (01/04/2019)

No. of Shares held at the end of the year (31/03/2020)

Demat Physical Total % of Total

Shares Demat Physical Total

% of Total

Shares

% Change during

the year

(I) (II) (III) (IV) (V) (VI) (VII) (VIII) (IX) (X) (XI)

A. Promoter and Promoter Group

(1) Indian

a) Individual/ HUF

156475610 - 156475610 65.95 162603060 - 162603060 65.69 (0.26)

b) Central Govt - - - - - - - - -

c) State Govt (s) - - - - - - - - -

d) Bodies Corporate

- - - - - - - - -

e) Banks / FI - - - - - - - - -

f) Any Other - - - - - - - - -

Sub-Total (A) (1):-

156475610 - 156475610 65.95 162603060 - 162603060 65.69 (0.26)

(2) Foreign

a) NRIs - Individuals

- - - - - - - - -

b) Other – Individuals

- - - - - - - - -

c) Bodies Corporate

- - - - - - - - -

d) Banks / FI - - - - - - - - -

e) Any Other - - - - - - - - -

Sub-Total (A) (2):-

- - - - - - - - -

Total Shareholding Of Promoter and Promoter Group (A) =(A)(1)+(A)(2)

156475610 - 156475610 65.95 162603060 - 162603060 65.69 (0.26)

B. Public Shareholding

1. Institutions

a) Mutual Funds - - - - - - - - -

b) Banks / FI - - - - 50 - 50 0.00 0.00 c) Central Govt - - - - - - - - - d) State Govt(s) - - - - - - - - -

e) Venture Capital Funds

- - - - - - - - -

f) Insurance Companies

- - - - - - - - -

g) FIIs 6 - 6 0.00 6 - 6 0.00 (0.00)

h) Foreign Venture Capital Funds

- - - - - - - - -

i) Others - - - - - - - - -

i). Foreign Portfolio Investor

57572 - 57572 0.02 1422 - 1422 0.00 (0.02)

SUB-TOTAL (B)(1):

57578 - 57578 0.02 1478 - 1478 0.00 (0.02)

2. NON-INSTITUTIONS

a) Bodies Corporates

7071019 - 7071019 2.98 3974520 - 3974520 1.61 (1.37)

b) Individuals

(i) Individuals holding nominal share capital Upto ₹ 1 Lakh

29969241 2 29969243 12.63 30264651 2 30264653 12.23 (0.40)

(ii) Individuals holding nominal share capital in

31634322 - 31634322 13.33 38663497 - 38663497 15.62 2.29

excess of ₹ 1 Lakh

c) Others

(i) HUF 8541201 - 8541201 3.60 8422519 - 8422519 3.40 (0.20)

(i) Trusts 2 - 2 0.00 2 - 2 0.00 0.00

(ii) Clearing Members

1435593 1435593 0.61 1507379 1507379 0.61 0.00

(iii) Non- Resident Indians (NRI)

600 - 600 0.00 - - - 0.00 (0.00)

(iv) Non- Resident Indians (Repatriation)

1755775

- 1755775

0.74 1485740 - 1485740 0.60 (0.14)

(v) Non- Resident Indians (Non- Repatriation)

325667 - 325667 0.14 602612 - 602612 0.24 0.11

d) Qualified Foreign Investor

- - - - - - - - -

Sub-total (B)(2):

80733420 2 80733422 34.03 84920920 2 84920922 34.31 0.28

Total Public Shareholding (B)=(B)(1)+ (B)(2)

80790998

2 80791000

34.05 84922398 2 84922400 34.31 0.26

C. Shares held by Custodians and against which Depository Receipts have been issued

- - - - - - - - -

a) Shares held By Custodians

- - - - - - - - -

(i) Promoter and Promoter Group

- - - - - - - - -

(ii) Public - - - - - - - - -

Sub Total (C)(1): (C)= (C)(1)

- - - - - - - - -

Grand Total (A+B+C)

237266608

2 237266610

100.00 247525458 2 247525460 100.00 -

ii) Shareholding of Promoters

Sr.No

Shareholder’s Name

Shareholding at the beginning of the year (01/04/2019)

Shareholding at the end of the year (31/03/2020)

Number of Shares

% of total

Shares of the

company

%of Shares Pledged

/encumbered to

total shares

Number of Shares

% of total

Shares of the

company

%of Shares Pledged

/Encumbered to

total shares

% Change in shareholding

during the year

1 SANGITA MANOJ AGRAWAL

0 0.00 0.00 10043600 4.06 0.00 4.0576

2 TULSIRAM CHIRANJILAL AGRAWAL (HUF) .

0 0.00 - 116550 0.05 - 0.0471

3 KOMAL SANDEEP AGRAWAL

2000000 0.84 - 2158000 0.87 - 0.0289

4 KAJAL MANOJ AGRAWAL

2000000 0.84 - 2000000 0.81 - (0.0349)

5 KARAN AGRAWAL 2000000 0.84 - 2487300 1.00 - 0.1620

6 KUSHAL AGRAWAL

2000000 0.84 - 2717420 1.10 - 0.2549

7 MAHENDRA TULSIRAM AGRAWAL HUF

2000000 0.84 - 2106375 0.85 - 0.0081

8 SANDEEP TULSIRAM AGRAWAL HUF

2000000 0.84 - 2063825 0.83 - (0.0091)

9 MANOJ TULSIRAM AGRAWAL HUF

2000000 0.84 - 2106375 0.85 - 0.0081

10 KASHISH SANDEEP AGRAWAL

2000000 0.84 - 2000000 0.81 - (0.0349)

11 KHUSHI MAHENDRA AGRAWAL

2000000 0.84 - 2000000 0.81 - (0.0349)

12 MAHENDRA TULSIRAM AGRAWAL

4000000 1.69 - 0 0.00 - (1.6859)

13 SUDHA MAHENDRA AGRAWAL

7236540 3.05 - 7661070 3.10 - 0.0451

14 SANGITA MANOJ AGRAWAL

8553600 3.61 - 0 0.00 - (3.6051)


8701600 3.67 - 20701600 8.36 - 4.6960


10000000 4.21 - 2000000 0.81 - (3.4067)

17 SANDEEP TULSIRAM AGRAWAL

13682400 5.77 - 13682400 5.53 - (0.2390)

18 MANOJ TULSIRAM AGRAWAL

20541600 8.66 - 21374510 8.64 - (0.0223)

19 PUSHPADEVI TULSIRAM AGRAWAL

21700220 9.15 - 21834385 8.82 - (0.3248)

20 NAMRATA SANDEEP AGRAWAL

44059650 18.57 - 45549650 18.40 - (0.1677)

Total 156475610 65.95 - 162603060 65.69 - (0.26)

iii) Change in Promoters’ Shareholding

Sr. No.

Name of the shareholder Shareholding at beginning of the financial year – April

01, 2019

Cumulative shareholding during the financial year

No. of shares

% of total no. of shares of the company

No. of shares

% of total no. of shares of the company

1 Namrata Sandeep Agrawal

At the beginning of the year 44059650 17.80 44059650 17.80 Allotted on May 3, 2019 under scheme

of amalgamation 1490000

0.60 45549650 18.40

At the end of the year 45549650 18.40

2 Mahendra Tulsiram Agrawal At the beginning of the year 22701600 9.17 22701600 9.17 At the end of the year 22701600 9.17

3 Pushpadevi Tulsiram Agrawal



0.05 21834385 8.82


4 Manoj Tulsiram Agrawal At the beginning of the year 20541600 8.30 20541600 8.30

Allotted on May 3, 2019 under scheme of amalgamation

832910

0.34 21374510 8.64


5 Sandeep Tulsiram Agrawal

At the beginning of the year 13682400 5.53 13682400 5.53


6 Sangita Manoj Agrawal



0.60 10043600 4.06


7 Sudha Mahendra Agrawal



424530

0.17 7661070 3.10


8 Manoj Tulsiram Agrawal (HUF)



106375

0.04 2106375 0.85


9 Sandeep Tulsiram Agrawal (HUF)



63825

0.03 2063825 0.83


10 Mahendra Tulsiram Agrawal (HUF)



106375

0.04 2106375 0.85


11 Kushal Manoj Agrawal



717420

0.29 2717420 1.10


12 Komal Sandeep Agrawal At the beginning of the year 2000000 0.81 2000000 0.81 Allotted on May 3, 2019 under scheme

of amalgamation 158000 0.06 2158000 0.87


13 Karan Mahendra Agrawal



487300 0.20 2487300 1.00


14 Kajal Manoj Agrawal At the beginning of the year 2000000 0.81 2000000 0.81


15 Kashish Sandeep Agrawal At the beginning of the year 2000000 0.81 2000000 0.81 At the end of the year 2000000 0.81

16 Khushi Mahendra Agrawal

At the beginning of the year 2000000 0.81 2000000 0.81 At the end of the year 2000000 0.81

17 Tulsiram Chiranjilal Agrawal (Huf) At the beginning of the year 0 0 0 0 Allotted on May 3, 2019 under scheme

of amalgamation 116550 0.05 116550 0.05


Shareholding Pattern of Top Ten Shareholders (other than Directors, Promoters and Holders of GDRs and ADRs):

Sr. No.

Name of the shareholder Shareholding at beginning of the financial year – April 01,

2019

Cumulative shareholding during the financial year

No. of shares % of total no. of shares of the company

No. of shares % of total no. of sha

KUSHAL LIMITED€¦ · Kushal Limited (Formerly known as Kushal Tradelink Limited) CIN.: L74110GJ2000PLC037472 Registered Office Plot No. 43, B/S Navneet Prakashan, Sukhramnagar,

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