ABC India Ltd. — Audit Report / Information 2020

May 25, 2020

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Date: 25.05.2020
The Secretary,	The Secretary,
The Calcutta Stock Exchange Ltd.	BSE Limited
7, Lyons Range,	Phiroze Jeejeebhoy Towers,
Kolkata — 700 001	Dalal Street,
	Mumbai — 400 001
Code No. - 10011146	Scrip Code : 539043

Dear Sirs,

Reg: Submission of Secretarial Compliance Report from Practicing Company Secretary under Regulation 24A of the Securities and Exchange Board of India (LODR) Regulations, 2015, for the year ended on March 31, 2020

As per requirements of Regulation 24A of SEBI (Listing Obligations and Disclosure Requirements), Regulations, 2015, we are sending herewith a copy of the Report issued by Mr. Santosh Kumar Tibrewalla, Practicing Company Secretary for the year ended on 31.03.2020.

Please acknowledge the receipt of the above.

Thanking You,

Yours faithfully,

For ABC India Ltd.

Sd/- Sanjay Agarwal Company Secretary & Compliance Officer

Encl: As above

Secretarial Compliance Report of ABC India Limited for the year ended 31" March, 2020

[Under regulation 24A of SEBI (Listing Obligations and Disclosure Requirements), Regulations, 2015]

I, Santosh Kumar Tibrewalla, Practising Company Secretary have examined:

• a. all the documents and records made available to me and explanation provided by M/s. ABC India Limited having its registered Office at P-10, New C.LT Road, Kolkata - 700073 ('the Company"'),
• b. the filings/ submissions made by the Company to the Stock Exchanges,
• © website ofthe Company,
• d. any other document/ filing, as may be relevant, which has been relied upon to make this certification,

for the financial year ended 31% March, 2020 in respect ofcompliance with the provisions of :

• 1. the Securities and Exchange Board of India Act, 1992 ("SEBI Act') and the Regulations, circulars, guidelines issued thereunder; and
• Ul. the Securities Contracts (Regulation) Act, 1956 ("SCRA"), rules made thereunder and the Regulations, circulars, guidelines issued thereunder by the Securities and Exchange Board of India ("SEBI');
• lil. The Depositories Act, 1996 and the Regulations and Bye-laws framed thereunder;
• Iv. Foreign Exchange Management Act, 1999 and the rules and regulations made thereunder to the extent of Foreign Direct Investment, Overseas Direct Investment and External Commercial Borrowings.

The specific Regulations, whose provisions and the circulars/ guidelines issued thereunder, have been examined, include:

• 1. Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015;
• ii. Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018;
• iil. Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011;
• IV. Securities and Exchange Board of India (Buyback of Securities) Regulations, 2018;
• V. The Securities and Exchange Board of India (Delisting ofEquity Shares)Regulations, 2009;

• Vi. The Securities and Exchange Board of India (Employee Stock Option Scheme and Employee Stock Purchase Scheme) Guidelines, 1999 and the Securities and Exchange Board of India (Share Based Employee Benefits) Regulations, 2014;

• Vil. Securities and Exchange Board of India (Issue and Listing of Debt Securities) Regulations, 2008;

• Viil. Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015;
• 1X. 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; and circulars/ guidelines issued thereunder.

Exchange Board Debt Securities and and Securities) India (Issue Listing of of
Regulations, 2008; Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015; Exchange Board The (Registrars Share Securities and and India Issue an of to 1993 regarding the Companies Act and dealing with Transfer Agents) Regulations, client; and circulars/ guidelines issued thereunder.
and based on the above examination, I hereby report that, during the period reviewed: The Company has complied with the provisions of the above Regulations and circulars/ guidelines issued thereunder, except in respect of matters specified below:
Sr. No	(Regulations/	Compliance Requirement circulars	Deviations	Observations/ Remarks the of
	/guidelines clause)	_includingspecific		Company Practicing Secretary
			Not Applicable
The The	Company has examination of those records, following are	maintained proper of actions details the aforesaid Acts/ Regulations and circulars/ guidelines issued thereunder:	under records the taken against the	above provisions of the Regulations and circulars/ guidelines issued thereunder in so far as it appears from my Company/ promoters/ its Directors/ material subsidiaries either by SEBI or by Stock Exchanges (including under the Standard Operating Procedures issued by SEBI through various circulars) under the

• The Company has maintained proper records under the provisions of the above Regulations and circulars/ guidelines issued thereunder in so far as it appears from my examination of those records,
• c. The following are the details of actions taken against the Company/ its promoters/ Directors/ material subsidiaries either by SEBI or by Stock Exchanges (including under the Standard Operating Procedures issued by SEBI through various circulars) under the aforesaid Acts/ Regulations and circulars/ guidelines issued thereunder:

Sr. No	Actiontaken by	Details violation		of Details taken warningletter, debarment, etc.	of E.g.	action fines,	Observations/remarks thePracticing Secretary, if any.	of Company
No such event reported to us

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

previous reports:	The listed entity has taken the following actions to comply with the observations made in
Sr. Observations No the Practicing in_ Company Secretary in previous reports (The years	of Observations made secretarial by the compliance the for the year ended are be to mentioned)	Actions the listed the report entity, if any	taken Comments of Practicing Company Secretary on the actions taken by the listed entity

Not Applicable

Place: Kolkata

SANTOSH Drury KUMAR TIBREWALLA Date: 20.05.2020 Date: 2020.05.20 TIBREWALLA 14:06:46 +05'30'

Name: Santosh Kumar Tibrewalla

FCS No. : 3811

CP No. : 3982

UDIN: F003811B000261145