Action Construction Equipments Ltd. - AGM Information 2025

Corporate & Registered Office

Action Construction Equipment Limited

Dudhola Link Road, Dudhola, Distt. Palwal-121102, Haryana, India

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Date: August 05, 2025

To,

The Manager Listing BSE Limited Scrip Code: 532762 5[th] Floor, P.J. Towers, Dalal Street, Mumbai-400 001

The Manager Listing National Stock Exchange of India Ltd CM Quote: ACE Exchange Plaza, Bandra Kurla Complex, Bandra(E), Mumbai-400 051

Subject: Annual Report 2024-25 and notice convening 31[st] Annual General Meeting ("AGM") of the Company.

Dear Sir/Madam,

This is to inform you that the 31[st] Annual General Meeting (AGM) of the Company will be held on Friday, August 29, 2025 at 12:00 Noon through Video Conferencing (“VC”)/Other Audio Visual Means (“OAVM”) in compliance with the relevant circulars issued by the Ministry of Corporate Affairs and the Securities and Exchange Board of India.

Pursuant to Regulation 34(1) of Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 ("Listing Regulations"), the Annual Report of the Company along with the Notice of AGM for the financial year 2024-25 being sent through electronic mode to the members of the Company is attached.

The Notice of AGM along with the Annual Report for the financial year 2024-25 is also being made available on the website of the Company at www.ace-cranes.com in investor relations section.

This is for your information and records please.

Thanking you

For Action Construction Equipment Limited

ANIL KUMAR Digitally signed by ANIL KUMAR DN: c=IN, o=Personal, postalCode=121006, st=Haryana, serialNumber=C69127D248F7209479CFD1ACBF291CC10ED601A979BF6BCB944845F16BE31B0C, cn=ANIL KUMAR Date: 2025.08.05 16:45:37 +05'30'

Anil Kumar Company Secretary

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Corporate Office: Phone: +91-1275-280111 (50 Lines), Fax: +91-1275-280133, E-mail: [email protected] Mktg. H.Q. : 4th Floor, Pinnacle, Surajkund, Faridabad, NCR-121009, Phone: +91-129-4550000 (100 Lines), Fax: +91-129-4550022, Email: [email protected] Customer Care No.:1800 1800 004 (Toll Free), CIN: L74899HR1995PLC053860, Website: www.ace-cranes.com

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ACTION CONSTrUCTION EQUIpMENT LIMITED

Regd. Office: Dudhola Link Road, Dudhola, Distt. Palwal-121102, Haryana Email:[email protected], Phone:01275-280111, Fax:01275-280133, CIN:L74899HR1995PLC053860, Website:www.ace-cranes.com

NOTICE OF ThE ANNUAL GENErAL MEETING

NOTICE is hereby given that the Thirty First (31 [st] ) Annual General Meeting (AGM) of the Members of Action Construction Equipment Limited (“Company”) will be held on Friday, August 29, 2025 at 12:00 Noon (IST) through Video Conferencing (“VC”)/Other Audio Visual Means (“OAVM”), to transact the following businesses. The deemed venue of AGM shall be the registered office of the Company.

OrDINArY BUSINESS:

1. To receive, consider and adopt:

(a) The audited standalone financial statement of the Company for the financial year ended March 31, 2025 and report of Board of Directors and Auditors’ thereon; and
(b) The audited consolidated financial statement of the Company for the financial year ended March 31, 2025 and report of Auditors’ thereon.

and, in this regard, to consider and if thought fit, to pass, with or without modification(s), the following resolution(s) as an Ordinary Resolution(s):

(a) “rESOLVED ThAT the audited standalone financial statement of the Company for the financial year ended March 31, 2025 and the report of Board of Directors and Auditors thereon, as circulated to the Members, be and are hereby considered and adopted.”
(b) “rESOLVED FUrThEr ThAT the audited consolidated financial statement of the Company for the financial year ended March 31, 2025 and the report of Auditors thereon, as circulated to the Members, be and hereby considered and adopted.”

2. To declare a final dividend of ` 2.00 i.e. (100%) per equity share for the Financial Year ended March 31, 2025 and in this regard, to consider and if thought fit, to pass, with or without modification(s), the following resolution as an Ordinary :

Resolution

“rESOLVED ThAT a dividend at the rate of 2.00/- i.e. (100%) per equity share of face value of 2/- (Rupees Two) each fully paid-up of the Company, as recommended by the Board of Directors, be and is hereby declared for the financial year ended March 31, 2025 and the same be paid out of the profits of the Company.”

3. To appoint Mrs. Surbhi Garg (DIN: 01558782) who retires by rotation as Director and in this regard, to consider and if thought fit, to pass, with or without modification(s), the following resolution as an Ordinary Resolution:

“rESOLVED ThAT in accordance with the provisions of Section 152 and other applicable provisions of the Companies Act, 2013, Mrs. Surbhi Garg (DIN: 01558782), who retires by rotation at this meeting, be and is hereby appointed as a Director of the Company.”

SpECIAL BUSINESS:

4. To ratify the remuneration of the Cost Auditors for the financial year ending March 31, 2026 and in this regard, if thought fit, to pass with or without modification(s) the following resolution as an Ordinary Resolution:

“rESOLVED ThAT pursuant to the provisions of section 148 and other applicable provisions, if any, of the Companies Act, 2013 read with the Companies (Audit and Auditors) Rules, 2014 (including any statutory modification(s) or re-enactment(s) thereof, for the time being in force, the remuneration of `1,75,000 (Rupees One Lakh Seventy Five Thousand only) plus applicable taxes inclusive of all out of pocket expenses, approved by the Board of Directors, to be paid to M/s Vandana Bansal & Associates, Cost Accountants (Firm Registration No: 100203), appointed by the Board of Directors of the Company, to conduct the audit of cost records of the Company for the financial year ending March 31, 2026, be and is hereby ratified.”

“rESOLVED FUrThEr ThAT the Board of Directors be and is hereby authorized to perform and execute and to do all such acts, deeds, things, and matters as may be deemed necessary, proper or expedient and for the matters connected herewith or incidental hereto.”

5. To appoint & fix remuneration of Secretarial Auditors of the Company and in this regard if thought fit, to pass, with or without modification(s), the following Resolution as an Ordinary Resolution:

“rESOLVED ThAT pursurant to the provisions of Section 204 and other applicable provisions, if any, of the Act, read with Rule 9 of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014, and in accordance with the

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Annual Report 2024-25

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provisions of Regulation 24A & other applicable provisions of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“SEBI Listing Regulations”) read with Circulars issued thereunder from time to time M/s Vasisht & Associates, Company Secretaries (Unique Identification No: S2019HR654700) (a peer reviewed Company Secretary in practice and submit his consent to act as Secretarial Auditor of the Company) be and is hereby appointed as Secretarial Auditors of the Company for a period of 5 (five) consecutive years to hold office from the conclusion of this AGM till the conclusion of AGM to be held in calender year 2030 (April 1, 2025 to March 31, 2030) (‘the Term’) with the power to the Board (‘Board’ which term shall be deemed to include any Committee thereof) to determine their remuneration.”

“rESOLVED FUrThEr ThAT approval of the Members is hereby accorded to the Board to avail or to obtain from the Secretarial Auditor, such other services or certificates or reports which the Secretarial Auditor may be eligible to provide or issue under the applicable laws at a remuneration or fees to be determined by the Board.”

“rESOLVED FUrThEr ThAT the Board be and is hereby authorized to do all such acts, deeds, matters and things as may be considered necessary, desirable or expedient including filing requisite forms/submission of documents with any authority and to give effect to this resolution and for matters connected therewith or incidental thereto.”

6. re-appointment of Mr. Shriniwas Vashisht (DIN: 06572418) as a Non-Executive Independent Director of the Company and in this regard, to consider and if thought fit, to pass with or without modification(s), the following resolution as a Special Resolution:

“rESOLVED ThAT pursuant to the provisions of Sections 149, 150, 152 and any other applicable provisions of the Companies Act, 2013 and the rules made thereunder (including any statutory modification(s) or re-enactment thereof for the time being in force) read with Schedule IV to the Companies Act, 2013 and pursuant to the Regulation 16(1)(b), 17 and other applicable provision of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015, and Article of Association of the Company the consent of the members be and is hereby accorded to re-appoint Mr. Shriniwas Vashisht (DIN: 06572418) who has submitted a declaration that he meets the criteria for independence as provided in Section 149(6) of the Act and in respect of whom, the Company has received a notice in writing under section 160 of the Act from a member proposing his candidature for the office of Director, as a Non-Executive Independent Director of the Company to hold office for a second term of five consecutive years w.e.f September 24, 2025 to September 23, 2030 and whose office shall not be

liable to retire by rotation.”

“rESOLVED FUrThEr ThAT pursuant to the provisions of section 197(5) read with rules made thereunder and SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 and other applicable sections, provisions and rules of the Companies Act, 2013, the consent of the members be and is hereby accorded to pay sitting fees per meeting to Mr. Shriniwas Vashisht (DIN: 06572418) as paid to the other Independent Directors for attending the meeting of the Board and its Committee.”

“rESOLVED FUrThEr ThAT Mr. Vijay Agarwal, Chairman & Managing Director, Mr. Sorab Agarwal, Whole Time Director, Mr. Rajan Luthra, Chief Financial Officer and Mr. Anil Kumar, Company Secretary of the Company be and is hereby severally authorized to do all acts, deeds and things including filing of requisite forms and returns etc. and take steps as may be deemed necessary, proper or expedient to give effect to this Resolution and matters incidental thereto.”

7. re-appointment of Dr. Jagan Nath Chamber (DIN: 08841478) as a Non-Executive Independent Director of the Company and in this regard, to consider and if thought fit, to pass with or without modification(s), the following resolution as a Special Resolution

“rESOLVED ThAT pursuant to the provisions of Sections 149, 150, 152 and any other applicable provisions of the Companies Act, 2013 and the rules made thereunder (including any statutory modification(s) or re-enactment thereof for the time being in force) read with Schedule IV to the Companies Act, 2013 and pursuant to the Regulation 16(1)(b), 17 and other applicable provision of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015, Article of Association of the Company and subject to the approval of Central Government or any authority/ agency/board, if any, the consent of the members be and is hereby accorded to re-appoint Dr. Jagan Nath Chamber (DIN: 08841478) who has submitted a declaration that he meets the criteria for independence as provided in Section 149(6) of the Act and in respect of whom, the Company has received a notice in writing under section 160 of the Act from a member proposing his candidature for the office of Director, as a NonExecutive Independent Director of the Company to hold office for a second term of five consecutive years w.e.f. November 06, 2025 to November 05, 2030 and whose office shall not be liable to retire by rotation.”

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Action Construction Equipment Limited

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and is hereby accorded to pay sitting fees per meeting to Dr. Jagan Nath Chamber (DIN: 08841478) as paid to the other Independent Directors for attending the meeting of the Board and its Committee.”

“rESOLVED FUrThEr ThAT Pursuant to Regulation 17 (1A) of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 and the applicable provision of the Companies Act 2013 read with rules made thereunder, the consent of the members of the Company be and is hereby accorded for continuation of employment of Dr. Jagan Nath Chamber as a Non-Executive Independent Director of the Company even after attaining the age of 75 years on May 15, 2029 during tenure ending on November 06, 2030."

“rESOLVED FUrThEr ThAT Mr. Vijay Agarwal, Chairman & Managing Director, Mr. Sorab Agarwal, Whole Time Director,

Mr. Rajan Luthra, Chief Financial Officer and Mr. Anil Kumar, Company Secretary of the Company be and is hereby severally authorized to do all acts, deeds and things including filing of requisite forms and returns etc. and take steps as may be deemed necessary, proper or expedient to give effect to this Resolution and matters incidental thereto.”

By Order of the Board of Director For Action Construction Equipment Limited

place: Faridabad Date: May 26, 2025 Registered office: Dudhola Link Road, Sd/- Dudhola, Distt. Palwal-121102, HR Anil kumar CIN : L74899HR1995PLC053860 Company Secretary Email : [email protected] M. No. ACS: 37791

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NOTES:

1. The Ministry of Corporate Affairs (“MCA”) has vide its circular no. 14/2020 dated April 08, 2020, 20/2020 dated May 05, 2020, 2/2021 dated January 13, 2021, 19/2021 dated December 08, 2021, 21/2021 dated December 14, 2021, 2/2022 dated May 05, 2022, 10/2022 dated December 28, 2022, 09/2023 dated September 25, 2023 and 09/2024 dated September 19, 2024, (collectively referred to as “MCA Circulars”) permitted convening the Annual General Meeting (“AGM” or “e-AGM”) through video conferencing (‘VC’) or other Audio Visual Means (‘OAVM’) without the physical presence of the Members of the Company at a common venue. In accordance with MCA Circulars, provisions of the Companies Act 2013 (“Act”) and the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“Listing Regulations”), the AGM of the Company is being held through VC/ OAVM. The deemed venue for the AGM shall be the Registered Office of the Company.

2. 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 08, 2020, April 13, 2020, May 05, 2020 and January 13, 2021, May 05, 2022, December 28, 2022, September 25, 2023 and September 19, 2024, the Company is providing facility of remote e-voting to its Members in respect of the business to be transacted at the AGM. For this purpose, the Company has entered into an agreement with National Securities Depository Limited (NSDL) 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 NSDL.

3. As per the provisions under the MCA and SEBI Circulars, Members attending the 31 [st] AGM through VC/OAVM shall be counted for the purpose of reckoning the quorum under Section 103 of the Companies Act, 2013.

4. The Explanatory Statement pursuant to Section 102(1) of the Companies Act, 2013, (“Act”) which sets out details relating to Special Businesses at the Meeting, is annexed hereto and forms part of this notice. All documents referred to in the accompanying Notice and the Explanatory Statement shall be available for inspection electronically. Members seeking to inspect such documents can send an email to [email protected].

5. As the 31 [st] AGM is being held through VC/OAVM, the route map is not annexed to this Notice.

6. As per the Companies Act, 2013, a Member entitled to attend and vote at the AGM is entitled to appoint a proxy to attend and vote on his/her behalf. Since the 31 [st] AGM is being held through VC/OAVM as per the MCA Circulars, physical

attendance of Members has been dispensed with. Accordingly, the facility for appointment of proxies by the Members will not be made available for the 31 [st] AGM and hence the Proxy Form and Attendance Slip are not annexed to this Notice.

7. In compliance with the aforesaid MCA Circulars and SEBI circular no. SEBI/HO/CFD/CFD-PoD-2/P/CIR/2024/133 dated October 03, 2024, Notice of the AGM along with the Annual Report 2024-25 is being sent only through electronic mode to those members whose email addresses are registered with the RTA/ Depositories. Members may note that the Notice and Annual Report will also be available on the Company’s website www.ace-cranes.com, websites of the Stock Exchanges i.e. BSE Limited and National Stock Exchange of India Limited at www. bseindia.com and www.nseindia.com respectively, and on the website of NSDL at www.evoting.nsdl.com. Further the letter are being sent to the shareholders whose E-mail address are not registered contaning the link of the Annual Report of financial year 2024-25 along with completion of KYC requirement.

8. The Institutional/Corporate members intending to attend the AGM through authorised representatives are requested to send to Company/Scrutinizer a certified true copy of the Board Resolution /Authority letter etc(PDF/ JPG format) authorising their representative to attend the AGM through VC/ OAVM and vote on their behalf by an email through its registered email address to [email protected] with a copy marked to [email protected].

9. 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 at the meeting.

10. The details of the Directors retiring by rotation and seeking appointment/ reappointment at the 31 [st] AGM are provided in Annexure-I of this Notice. The Company has received the requisite consents/declarations for the appointment/reappointment under the Companies Act, 2013 and the rules made thereunder.

11. In order to enable the Company to comply with MCA/ SEBI Circulars and to participate in the green initiative in Corporate Governance, members are requested to register their email addresses in respect of shares held in electronic form with their Depository Participant(s) and in respect of shares held in physical form by sending duly filled and signed form ISR-1 available on Company’s Website at https://www. ace-cranes. com/public/front/pdf/Form-ISR-1.pdf and to the registrar and Share Transfer Agent of the Company – Skyline Financial Services private Limited , D-153A , 1st Floor, Okhla Industrial Area, Phase-I, New Delhi - 110020, Phone: 011- 26812682, 011-26812683, Email: [email protected].

12. For receiving all communication (including Annual Report) from the Company electronically:

(a) Members holding shares in physical mode and who have not registered/ updated their e-mail address with the Company are requested to register/ update the same in

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accordance with procedure mentioned in point no. 11.

(b) Members holding shares in dematerialized mode are requested to register/update their e-mail address with their respective Depository Participant.

13. Pursuant to SEBI (LODR) Regulations, 2015 and such other provisions as may be applicable, the Board of Directors had fixed Friday, August 22, 2025 as cut-off date for determining the Members who shall be entitled to vote through remote e-voting or e-voting at the AGM. A member who is not a member as on the cut-off date shall treat this notice for information purpose only.

14. Members holding shares in electronic mode:

(a) are requested to submit their PAN and bank account details to their respective DPs with whom they are maintaining their demat accounts.
(b) are advised to contact their respective DPs for registering the nomination.
(c) are requested to register/update their e-mail address with their respective DPs for receiving all communications from the Company electronically any changes effected by DPs will be automatically reflected in the recorded maintained by the depositiries.

15. Non-Resident Indian members are requested to inform about the following immediately to the Company or RTA/respective DPs, as the case may be immediately of:

(a) Change in their residential status on return to India for permanent settlement.
(b) Particulars of their bank account maintained in India with complete name, branch, account type, account number and address of the bank with pin code number, if not furnished earlier.

16. (a) In compliance of SEBI Circular dated June 10, 2024, read with SEBI Master Circular for RTA dated May 07, 2024, the security holders holding securities in physical form are hereby advised to update/register their PAN, Choice of Nomination, Contact Details (i.e. postal address with PIN and mobile no.), Bank Account Details and Specimen Signatures.

  - Further, any grievances/services request shall be entertained by RTA/Company only after furnishing PAN and KYC Details. Further, any payment including dividends, interest (if any) in respect of folios, where PAN or KYC details are not updated, shall be made only through electronic mode.

(b) Online Dispute Resolution (ODR) Portal is introduced by SEBI vide its Master Circular SEBI/ HO/OIAE/OIAE_IAD- 1/P/ CIR/2023/145 dated August 11, 2023, which is in addition to the existing SCORES 2.0 portal which can be utilized by the investors and the Company for dispute resolution.

Please note that the investors are advised to initiate dispute resolution through the ODR portal only if the Company

does not resolve the issue itself or it is not resolved through SCORES 2.0 portal link for the same is https://smartodr.in/ login.

17. To enable compliance with TDS requirement on Dividend, Members are requested to complete and/ or update their Residential Status, PAN, Category as per the Income Tax Act, 1961 with their Depository Participants or in case shares are held in physical form, with the RTA by submitting form ISR-1 as mentioned in point no. 11 above.

18. Due dates of transferring unclaimed and/ or unpaid dividend declared by the Company for the financial year 2017-18, and thereafter to Investor Education and Protection Fund Authority (“IEPF”):

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----- Start of picture text -----

Last Date for claiming
S.N. Financial Year
unpaid dividend
1 Final Dividend 2017-18 31.10.2025
2 Final Dividend 2018-19 31.10.2026
3 Final Dividend 2019-20 21.04.2027
4 Interim Dividend 2020-21 10.10.2028
5 Final Dividend 2021-22 27.10.2029
6 Final Dividend 2022-23 02.10.2030
7 Final Dividend 2023-24 04.10.2031
----- End of picture text -----

Members who have not encashed the dividend warrants so far in respect of the aforesaid periods, are requested to make their claim well in advance of the above due dates. Members are requested to check the details of unclaimed dividend amount, if any, on the Company’s website at link https://www. ace-cranes.com/home/unclaimed-dividend-IEPF.

Members may please note that the unclaimed dividend in respect of the financial year 2017-18 must be claimed by the concerned members on or before October 31, 2025, failing which it will be transferred to the Investor Education & Protection Fund Authority, in accordance with the relevant provisions of the Investor Education and Protection Fund Authority (Accounting, Audit, Transfer and Refund) Rules, 2016 (“IEPF Rules”). Members are requested to write to Company/ Skyline, for claiming unclaimed dividend at E-mail [email protected].

19. Members wishing to claim dividend that remain unclaimed are requested to correspond with the Registrar and shares transfer agent (RTA) on [email protected] or the Company Secretary of the Company on [email protected]. Members are requested to note that as per section 124 of the Companies Act, 2013 and applicable rules, dividends that are not claimed within seven years from the date of transfer to the Company’s unpaid dividend account, will be transferred to the Investor Education and Protection Fund (IEPF) and shares on which dividend remains unclaimed for seven consecutive years will also be transferred to the IEPF.

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20. The Company has transferred the unpaid or unclaimed dividends up to FY 2016-17 to the Investor Education and Protection Fund (IEPF) established by the Central Government. The Company has uploaded the details of unpaid and unclaimed dividend amounts on the website of the Company at www.ace-cranes.com in the Investors Relation section.

Attention of the members is drawn to the provisions of Section 124(6) of the Act which require a company to transfer in the name of IEPF Authority all shares in respect of which dividend has not been paid or claimed for 7 (seven) consecutive years or more. In accordance with the aforesaid provision of the Act read with the Investor Education and Protection Fund Authority (Accounting, Audit, Transfer and Refund) Rules, 2016, as amended from time to time, the Company has already transferred all shares alongwith unclaimed dividend in respect of which dividend (declared up to FY 2016-17) has not been paid or claimed by the members for 7 (seven) consecutive years or more, to IEPF Authority.

Members may note that shares as well as unclaimed dividend transferred to IEPF can be claimed back concered members/ investors are advised to visit the website of www.iepf.gov.in or contact RTA for the process of lodging claimed for refund of shares and / or dividend from IEPF.

21. Section 72 of the Act and Rule 19 of the Companies (Share Capital & Debenture) Rules, 2014 has extended the nomination facility to individual shareholders holding shares in physical form. Shareholders are requested to avail the above facility by submitting prescribed Nomination Form SH-13 to the Company/ RTA. This form is also available on the Company’s website at link https://www.ace-cranes.com/public/front/ pdf/Form-No-SH-13.pdf.

22. Please send all correspondence including requests for transfer/ transmission of shares, change of address & dividend etc. to Skyline Financial Services Private Limited, D-153A, 1st Floor, Okhla Industrial Area, Phase-I, New Delhi-110020, Phone: 011-26812682, 011-26812683, Email: [email protected].

23. The Register of Members and the Share Transfer books of the Company will remain closed from Friday, August 15, 2025 to Friday August 29, 2025 (both days inclusive) for the purpose of payment of dividend.

24. The Board in their meeting held on May 26, 2025 has recommended dividend of ` 2.00 i.e. (100%) per equity share for the financial year ended March 31, 2025. The payment of dividend is subject to the approval of the shareholders at the ensuing Annual General Meeting of the Company and is proposed to be paid/or dispatched within 30 days from date of ensuing Annual General Meeting.

The record date for the purpose of dividend will be August 14, 2025.

25. The dividend after deduction of tax at source, if declared at

the AGM, would be paid/ dispatched to those persons or their mandates:

(a) Whose names appear as beneficial owners as at the end of the business hours on August 14, 2025 in the list of beneficial owners to be furnished by National Securities Depository Limited (NSDL) and Central Depository Services (India) Limited (CDSL) in respect of the shares held in electronic mode; and
(b) Whose names appear as members in the Register of Members of the Company/ RTA after giving effect to valid share transmission/ transposition in physical form lodged with the Company on or before August 14, 2025 .

26. Effective from April 01, 2020 dividend income is taxable in the hands of the shareholders, hence Company is required to deduct tax at source (“TDS”) from dividend paid to the Shareholders at prescribed rates in the Income Tax Act, 1961 (“the IT Act”). Communication on TDS on Dividend Distribution appended to this notice as Annexure - II.

27. The Securities and Exchange Board of India (“SEBI”) has made it mandatory for all companies to use the bank account details of investors furnished by the Depositories/ available with the RTA for payment of dividend through National Electronic Clearing Services (“NECS”) to the investors, wherever NECS and bank details are available. In the absence of NECS facilities, the Company will print the bank account details, if available, on the payment instrument for distribution of dividend. The Company will not entertain any direct request from members holding shares in electronic mode for deletion/ change in such bank account details. Further, instruction if any, already given by them in respect of shares held in physical form will not be automatically applicable to shares held in electronic mode. Members who wish to change such bank account details are therefore requested to advise their Depository Participant about such change, with complete details of bank account. In case the shares are held in physical form, please send NECS form, so as to reach on or before the record date fixed for payment of dividend to RTA. Dividend warrants/demand drafts will be dispatched to the registered address of the shareholders who have not updated their bank account details in compliance of circulars/notifications issued by the SEBI/Stock Exchanges.

28. Member(s) of the Company who are holding shares in physical form and have multiple accounts in identical name(s) or are holding more than one share certificate in the same name under different Ledger Folio(s) are requested to apply for consolidation of such folio(s).

29. In accordance with the proviso to Regulation 40(1) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, effective from April 1, 2019, except in case of transmission and transportation transfers of securities of the Company shall not be processed unless the securities are held in the dematerialized form with a depository. Accordingly, shareholders holding equity shares in physical form are urged

328 Action Construction Equipment Limited

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to have their shares dematerialized so as to be able to freely transfer them and participate in corporate actions.

30. The Register of Directors and Key Managerial Personnel and their shareholding maintained under Section 170 of the Act, the Register of Contracts or arrangements in which directors are interested, maintained under Section 189 of the Act and the relevant documents referred to in the Notice and Annual Report will be available for inspection electronically by the members of the Company during the AGM. All other documents referred to in the Notice and Annual Report will also be available for electronic inspection without payment of any fee by the members from the date of circulation of this notice up to the date of AGM i.e. August 29, 2025. Members seeking to inspect such documents can send an email to cs@ ace-cranes.com.

31. In term of section 152 of the Act, Mrs. Surbhi Garg retire by rotation at this Meeting and being eligible, offer herself for re-appointment. The Board of Directors of the Company recommends her re-appointment. Mrs. Surbhi Garg is interested in the resolution set out at item no. 3 of the notice. Mr. Vijay Agarwal, Chairman & Managing Director, Mrs. Mona Agarwal, Executive Director, Mr. Sorab Agarwal, Executive Director being related to Mrs. Surbhi Garg may be deemed to be interested in the resolution set out at item No. 3 of the notice. The other relatives of Mrs. Surbhi Garg may be deemed to be interested in the resolution set out at item no. 3 of the notice, to the extent of their shareholding interest, if any, in the Company.

Save and except the above, none of the other Directors/ Key Managerial Personnel of the Company/their relatives are in any way concerned or interested, financially or otherwise, in the aforementioned resolution.

32. A certificate from the Secretarial Auditors of the Company certifying that the Company’s Employee Stock Option Scheme are being implemented in accordance with the SEBI (Share Based Employee Benefits and Sweat Equity) Regulations, 2021 (“SEBI (SBEB & SE) Regulations”), as amended from time to time and in accordance with the resolutions passed at the general meeting(s) will be available electronically for inspection by the members during the AGM.

33. Voting through electronic means:

Pursuant to the provisions of Section 108 of the Act read with Rule 20 of the Companies (Management and Administration) Rules, 2014, and Regulation 44 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, (including any statutory modification(s) or re-enactment(s) thereof, for the time being in force), the Company is pleased to provide its members the facility to exercise their right to vote on resolutions proposed to be considered at the 31 [st] AGM by electronic means and the business may be transacted through e-voting Services (“remote e-Voting”).

The members who have cast their votes by Remote e-Voting prior to the AGM may also participate in the AGM through VC/ OAVM via link provided in their login id's but shall not be entitled to cast their vote again.

ThE INSTrUCTIONS FOr MEMBErS FOr rEMOTE E-VOTING AND JOINING ANNUAL GENERAL MEETING ARE AS UNDEr:

The remote e-voting period begins on Monday, August 25, 2025 at 09:00 A.M. and ends on Thursday, August 28, 2025 at 05:00 p.M. The remote e-voting module shall be disabled by NSDL for voting thereafter. The Members, whose names appear in the Register of Members / Beneficial Owners as on the cut-off date i.e. Friday, August 22, 2025 may cast their vote electronically. The voting right of shareholders shall be in proportion to their share in the paid-up equity share capital of the Company as on the cut- off date, i.e. Friday, August 22, 2025 .

The How do I vote electronically using NSDL e-Voting system? way to vote electronically on NSDL e-Voting system consists of “Two Steps” which are mentioned below:

Step 1: Access to NSDL e-Voting system

(a) Login method for e-Voting and joining virtual meeting for Individual shareholders holding securities in demat mode.
In terms of SEBI circular dated December 9, 2020 on e-Voting facility provided by Listed Companies, Individual shareholders holding securities in demat mode are allowed to vote through their demat account maintained with Depositories and Depository Participants. Shareholders are advised to update their mobile number and email Id in their demat accounts in order to access e-Voting facility. Login method for Individual shareholders holding securities in demat mode is given below:
Type of shareLogin Method holders Individu1 Existing IDeAS user can visit the e-Services website of al ShareNSDL Viz. https://eservices.nsdl. com either on a Personal holders Computer or on a mobile. On the e-Services home page Holding click on the “Beneficial Owner” icon under “Login” which securiis available under ‘IDeAS’ section, this will prompt you to ties in enter your existing User ID and Password. After successful demat authentication, you will be able to see e-Voting services mode under Value added services. Click on “Access to e-Voting” with under e-Voting services and you will be able to see NSDL e-Voting page. Click on company name or e-Voting service provider i.e. NSDL and you will be re-directed to e-Voting website of NSDL for casting your vote during the remote e-Voting period or joining virtual meeting & voting during the meeting.
1. If you are not registered for IDeAS e-Services, option to register is available at https:// eservices. nsdl.com. Select “register Online for IDeAS portal” or click at https:// eservices.nsdl.com/SecureWeb/ IdeasDirectReg.jsp.

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Visit the e-Voting website of NSDL. Open web browser by typing the following URL:https://www.evoting. nsdl. com/ either on a Personal Computer or on a mobile. Once the home page of e-Voting system is launched, click on the icon “Login” which is available under ‘Shareholder/ Member’ section. A new screen will open. You will have to enter your User ID (i.e. your sixteen digit demat account number hold with NSDL), Password/OTP and a Verification Code as shown on the screen. After successful authentication, you will be redirected to NSDL Depository site wherein you can see e-Voting page. Click on company name or e-Voting service provider i.e. NSDL and you will be redirected to e-Voting website of NSDL for casting your vote during the remote e-Voting period or joining virtual meeting & voting during the meeting.
Shareholders/Members can also download NSDL Mobile App “NSDL Speede” facility by scanning the QR code mentioned below for seamless voting experience.

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Individual 1. Users who have opted for CDSL Easi / Easiest Shareholdfacility, can login through their existing user id and ers holding password. Option will be made available to reach securities in e-Voting page without any further authentication. demat mode The users to login Easi /Easiest are requested to with CDSL visit CDSL website www. cdslindia.com and click on login icon & New System Myeasi Tab and then user your existing my easi username & password.
After successful login the Easi / Easiest user will be able to see the e-Voting option for eligible companies where the evoting is in progress as per the information provided by company. On clicking the evoting option, the user will be able to see e-Voting page of the e-Voting service provider for casting your vote during the remote e-Voting period or joining virtual meeting & voting during the meeting. Additionally, there is also links provided to access the system of all e-Voting Service Providers, so that the user can visit the e-Voting service providers’ website directly.
If the user is not registered for Easi/Easiest, option to register is available at CDSL website www. cdslindia. com and click on login & New System Myeasi Tab and then click on registration option.
Alternatively, the user can directly access e-Voting page by providing Demat Account Number and PAN No. from a e-Voting link available on www.cdslindia. com home page. The system will authenticate the user by sending OTP on registered Mobile & Email as recorded in the Demat Account. After successful authentication, user will be able to see the e-Voting option where the evoting is in progress and also able to directly access the system of all e-Voting Service Providers.

Individual You can also login using the login credentials of your share holders demat account through your Depository Participant (holding registered with NSDL/CDSL for e-Voting facility. upon securities logging in, you will be able to see e-Voting option. Click in demat on e-Voting option, you will be redirected to NSDL/ mode) Login CDSL Depository site after successful authentication, through their wherein you can see e-Voting feature. Click on depository company name or e-Voting service provider i.e. NSDL participants and you will be redirected to e-Voting website of NSDL for casting your vote during the remote e-Voting period or joining virtual meeting & voting during the meeting.

Important note: Members who are unable to retrieve User ID/ Password are advised to use Forget User ID and Forget Password option available at above mentioned website.

Helpdesk for individuals shareholders holding securities in demat form for any technical issue related to login through depositry i.e. NSDL or CDSL are;

Login type helpdesk details

Individual ShareMembers facing any technical issue in holders holding login can contact NSDL helpdesk by sendsecurities in demat ing a request at [email protected] or call mode with NSDL. at 022-4886 7000

Individual ShareMembers facing any technical issue holders holding in login can contact CDSL helpdesk by securities in demat sending a request at helpdesk.evoting@ mode with CDSL. cdslindia.com or contact at toll free no. 1800-21-09911

(b) Login Method for e-Voting and joining virtual meeting for shareholders other than Individual shareholders holding securities in demat mode and shareholders holding securities in physical mode.

How to Log-in to NSDL e-Voting website?

1. Visit the e-Voting website of NSDL. Open web browser by typing the following URL: https://www.evoting.nsdl.com either on a Personal Computer or on a mobile.

2. Once the home page of e-Voting system is launched, click

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on the icon “Login” which is available under ‘Shareholder/ Member’ section.

3. A new screen will open. You will have to enter your User ID, your Password/OTP and a Verification Code as shown on the screen. Alternatively, if you are registered for NSDL e-services i.e. IDEAS, you can log-in at https://eservices.nsdl.com with your existing IDEAS login. Once you log-in to NSDL eservices after using your log-in credentials, click on e-Voting and you can proceed to Step 2 i.e. Cast your vote electronically.

4. Your User ID details are given below:

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----- Start of picture text -----

Manner of holding shares
i.e. Demat (NSDL or CDSL) Your User ID is:
or physical
(a) For Members who hold 8 Character DP ID followed by 8
shares in demat account Digit Client ID
with NSDL. For example if your DP ID
is IN300 and Client ID is
12 then your user ID is
IN30012**.
(b) For Members who hold 16 Digit Beneficiary ID For example
shares in demat account if your Beneficiary ID is
with CDSL. 12** then your user
ID is 12**
(c) For Members holding EVEN Number followed by Folio
shares in Physical Form. Number registered with the
Company
For example if folio number is
001 and EVEN is 101456 then
user ID is 101456001
----- End of picture text -----**

5. Password details for shareholders other than individual shareholders are given below:

(a) If you are already registered for e-Voting, then you can use your existing password to login and cast your vote.
(b) If you are using NSDL e-Voting system for the first time, you will need to retrieve the ‘initial password’ which was communicated to you. Once you retrieve your ‘initial password’, you need to enter the ‘initial password’ and the system will force you to change your password.
(c) How to retrieve your ‘initial password’?
- (i) If your email ID is registered in your demat account or with the company, your ‘initial password’ is communicated to you on your email ID. Trace the email sent to you from NSDL from your mailbox. Open the email and open the attachment i.e. a. pdf file. Open the pdf file. The password to open the pdf file is your 8 digit client ID for NSDL account, last 8 digits of client ID for CDSL account or folio number for shares held in physical form. The pdf file contains your ‘User ID’ and your ‘initial password’.
- (ii) If your email ID is not registered, please follow steps mentioned below in process for those s hareholders whose email ids are not registered.

6. If you are unable to retrieve or have not received the “Initial password” or have forgotten your password:

(a) Click on “Forgot User Details/Password?”(If you are holding shares in your demat account with NSDL or CDSL) option available on www.evoting.nsdl.com
(b) Physical User Reset Password?”(If you are holding shares in physical mode) option available on www. evoting.nsdl. com
(c) If you are still unable to get the password by aforesaid two options, you can send a request at evoting@nsdl. com mentioning your demat account number/folio number, your PAN, your name and your registered address etc.
(d) Members can also use the OTP (One Time Password) based login for casting the votes on the e-Voting system of NSDL.

7. After entering your password, tick on Agree to “Terms and Conditions” by selecting on the check box.

8. Now, you will have to click on “Login” button.

9. After you click on the “Login” button, Home page of e-Voting will open.

Step 2: Cast your vote electronically and join Annual General Meeting on NSDL e-Voting system.
- how to cast your vote electronically and join Annual General Meeting on NSDL e-Voting system?
(a) After successful login at Step 1, you will be able to see all the companies “EVEN” in which you are holding shares and whose voting cycle and General Meeting is currently in active status.
(b) Select “EVENs” of company for which you wish to cast your vote during the remote e-Voting period and casting your vote during the Annual General Meeting. For joining virtual meeting, you need to click on “VC/ OAVM” link placed under “Join Meeting”.
(c) Now you are ready for e-Voting as the Voting page opens.
(d) Cast your vote by selecting appropriate options i.e. assent or dissent, verify/modify the number of shares for which you wish to cast your vote and click on “Submit” and also “Confirm” when prompted.
( e) Upon confirmation, the message “Vote cast successfully” will be displayed.
(f) You can also take the printout of the votes cast by you by clicking on the print option on the confirmation page.
(g) Once you confirm your vote on the resolution, you will not be allowed to modify your vote.

General Guidelines for shareholders

(a) Institutional shareholders (i.e. other than individuals, HUF, NRI etc.) are required to send scanned copy (PDF/

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JPG Format) of the relevant Board Resolution/ Authority letter etc. with attested specimen signature of the duly authorized signatory(ies) who are authorized to vote, to the Scrutinizer by e-mail to cs@vasishtassociates. com with a copy marked to [email protected] and cs@ace- cranes.com.

(b) It is strongly recommended not to share your password with any other person and take utmost care to keep your password confidential. Login to the e-voting website will be disabled upon five unsuccessful attempts to key in the correct password. In such an event, you will need to go through the “Forgot User Details/Password?” or “Physical User Reset Password?” option available on www.evoting. nsdl.com to reset the password.
(c) In case of any queries, you may refer the Frequently Asked Questions (FAQs) for Shareholders and e-voting user manual for Shareholders available at the download section of www.evoting.nsdl.com or call on toll free no.: 022-48867000 and 022-24997000 or send a request to at [email protected].

process for those shareholders whose email ids are not registered with the depositories for procuring user id and password and registration of e mail ids for e-voting for the resolutions set out in this notice:

(a) In case shares are held in physical mode please provide 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 [email protected].
(b) In case shares are held in demat mode, please provide DPIDCLID (16 digit DPID + CLID or 16 digit beneficiary ID), Name, client master or copy of Consolidated Account statement, PAN (self attested scanned copy of PAN card), AADHAR (self attested scanned copy of Aadhar Card) to [email protected]. If you are an Individual shareholders holding securities in demat mode, you are requested to refer to the login method explained at step 1 (A) i.e. Login method for e-Voting and joining virtual meeting for Individual shareholders holding securities in demat mode.
(c) Alternatively shareholder/members may send a request to [email protected] for procuring user id and password for e-voting by providing above mentioned documents.
(d) In terms of SEBI circular dated December 9, 2020 on e-Voting facility provided by Listed Companies, Individual shareholders holding securities in demat mode are allowed to vote through their demat account maintained with Depositories and Depository Participants. Shareholders are required to update their mobile number and email ID correctly in their demat account in order to access e-Voting facility.

ThE INSTrUCTIONS FOr MEMBErS FOr e-VOTING ON ThE DAY OF ThE AGM ArE AS UNDEr:-

(a) The procedure for e-Voting on the day of the AGM is same

as the instructions mentioned above for remote e-voting.

(b) Only those Members/ shareholders, who will be 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 in the AGM.
(c) Members 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.
(d) The details of the person who may be contacted for any grievances connected with the facility for e-Voting on the day of the AGM shall be the same person mentioned for Remote e-voting.

INSTrUCTIONS FOr MEMBErS FOr ATTENDING ThE AGM ThrOUGh VC/OAVM ArE AS UNDEr:

(a) Members will be provided with a facility to attend the AGM through VC/OAVM through the NSDL e-Voting system. Members may access by following the steps mentioned above for Access to NSDL e-Voting system. After successful login, you can see link of “VC/OAVM link” placed under “Join meeting” menu against company name. You are requested to click on VC/OAVM link placed under Join General Meeting menu. The link for VC/OAVM will be available in Shareholder/Member login where the EVEN of Company will be displayed. Please note that the members who do not have the User ID and Password for e-Voting or have forgotten the User ID and Password may retrieve the same by following the remote e-Voting instructions mentioned in the notice to avoid last minute rush.
(b) Members are encouraged to join the Meeting through Laptops for better experience.
(c) Further Members will be required to allow Camera and use Internet with a good speed to avoid any disturbance during the meeting.
(d) 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.
(e) Shareholders who would like to express their views/ have questions may send their questions in advance mentioning their name, demat account number/folio number, email id, mobile number at cs@ace-cranes. com. The same will be replied by the company suitably.

34. Facility of joining the AGM through VC/OAVM shall be available for 1000 members on first come first serve basis. However, participation of members holding 2% or more shares, Promoters and Institutional Investors, Directors, Key Managerial Personnel, Chairpersons of Audit Committee, Stakeholder Relationship Committee, Nomination and

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Remuneration Committee and Auditors are not restricted on first come first serve basis.

35. Any person, who acquires shares of the Company and becomes a member of the Company after dispatch of the Notice and holding shares as of the cut-off date i.e. Friday, August 22, 2025 may obtain the login ID and password by sending an email to [email protected] or admin@ skylinerta.com or [email protected] by mentioning their Folio No./DP ID and Client ID No.

36. M/s Vasisht & Associates, Company Secretaries having firm registration number (S2019HR654700) has been appointed as Scrutinizer to scrutinize the Remote e-Voting and e-voting at the AGM in a fair and transparent manner.

37. The Scrutinizer shall, after the conclusion of e-voting at the AGM, unblock the votes cast through Remote e-Voting and e-voting at AGM shall make, not later than 2 days of the conclusion of the AGM, a consolidated Scrutinizer’s Report of the total votes cast in favour or against, if any, to the Chairman of the Company or a person authorised by him in writing, who shall declare the result of the voting forthwith.

38. The results declared along with the Scrutinizer’s Report shall be placed on Company’s website www.ace-cranes.com and on the website of NSDL at https://www.evoting.nsdl.com after the declaration of result by the Chairman or a person authorised by him in writing. The results shall also be communicated to the Stock Exchanges where the shares of the Company are listed.

39. Members joining the meeting through VC/OAVM, who have not already cast their vote by means of remote e-voting, shall be able to exercise their right to vote through e-voting at the AGM. The Members who have cast their vote by remote e-voting prior to the AGM may also join the AGM through VC/ OAVM but shall not be entitled to cast their vote again.

40. Members who would like to express their views or ask questions during the AGM may register themselves as a speaker by sending their request from their registered email address mentioning their name, DP ID and Client ID / Folio Number, PAN, Mobile Number at [email protected] on or before August 27, 2025 . Those Members who have registered themselves as a speaker will only be allowed to express their

views/ask questions during the AGM. The Company reserves the right to restrict the number of speakers depending on the availability of time for the AGM.

41. Members who have not registered their e-mail address are requested to register the same in respect of shares held in electronic form with the Depository through their Depository Participant(s) and in respect of shares held in physical form by writing to the Company’s Registrar and Share Transfer Agent, Skyline Financial Services Private Limited, D-153A, 1st Floor, Okhla Industrial Area, Phase-I, New Delhi - 110020. Members may note that pursuant to the MCA and SEBI Circulars the Company has enabled a process for the limited purpose of receiving the Company’s Annual Report and notice for the Annual General Meeting (including remote e-voting instructions) electronically, and Members may temporarily send their email address at [email protected].

42. In case of any queries regarding the Annual Report or other matters if any, the Members may write to [email protected] to receive an email response.

43. To prevent fraudulent transactions, members are advised to exercise due diligence and notify the Company of any change in address or demise of any member as soon as possible. Members are also advised not to 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.

44. Members seeking any information on the accounts are requested to write to the Company at least Ten days in advance so as to enable the Management to keep the information ready, in reply to the same at the Annual General Meeting.

By Order of the Board of Director For Action Construction Equipment Limited

place: Faridabad Sd/Date: May 26, 2025 Anil kumar Registered office: Dudhola Link Road, Company Secretary Dudhola, Distt. Palwal-121102, HR M. No. ACS: 37791

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EXpLANATOrY STATEMENT UNDEr SECTION 102 OF ThE COMpANIES ACT, 2013 READ WITH SEBI (LODR) REGULATIONS, 2015.

ITEM NO. 4

In accordance with the provisions of Section 148 of the Companies Act, 2013 read with the rules made thereunder, the Company is required to have the audit of its cost records conducted by a cost accountant in practice and the remuneration payable to the Cost Auditors as recommended by the Audit Committee and approved by the Board of Directors has to be ratified by the members of the Company.

The Board on the recommendation of the Audit Committee, has approved the re-appointment and remuneration of M/s Vandana Bansal & Associates, Cost Accountants, (Firm registration No: 100203), to conduct the audit of the cost records of the Company in respect of the applicable products for the financial year ending March 31, 2026 at an annual remuneration of ` 1,75,000 (Rupees One Lakh Seventy Five Thousand Only) plus applicable taxes inclusive of all out of pocket expenses subject to the deduction of applicable taxes.

M/s Vandana Bansal & Associates have furnished a certificate regarding their eligibility and consent for re-appointment as Cost Auditors of the Company. They have experience in the field of cost audit of various listed and unlisted entities.

Accordingly, consent of the members is sought for passing an Ordinary Resolution as set out at item no. 4 of the Notice for ratification of the remuneration payable to the Cost Auditors for the financial year ending March 31, 2026.

None of the Directors / Key Managerial Personnel of the Company/ their relatives is/are, in anyway, concerned or interested, financially or otherwise, in the resolution set out at item no. 4 of the Notice.

The Board recommends the Ordinary Resolution set out at item no. 4 of the notice for approval by the members.

ITEM NO. 5

In terms of the provisions of Section 204 and other applicable provisions, if any, of the Act, read with Rule 9 of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014, and in accordance with the provisions of Regulation 24A and other applicable provisions, if any, of the SEBI Listing Regulations, every listed entity is required to undertake Secretarial Audit by a Peer Reviewed Secretarial Auditors who shall be appointed by the Members of the Company, on the recommendation of the Board of Directors, for a period of five (5) consecutive years.

Accordingly, based on the recommendations of the Audit Committee, the Board of Directors, at its AGM held on May 26, 2025, subject to the approval of member of the Company, approved the appointment of M/s Vasisht & Associates, Practicing Company Secretaries (Firm Registration No. S2019HR654700), as the Secretarial Auditors of the Company, for a term of five (5) consecutive years, to hold the office of the Secretarial Auditors, effective from the conclusion of this meeting until the conclusion of the AGM to be held in the calendar year 2030.

M/s Vasisht & Associates, had consented to their appointment as the Secretarial Auditors of the Company and have confirmed that they fulfil the criteria as specified in clause (a) of Regulation 24A(1A) of SEBI Listing Regulations including the test of independence and have further confirmed that they have not incurred any of disqualifications as specified by the Securities and Exchange Board of India.

M/s Vasisht & Associates (VA) is a professional services firm specializing in secretarial compliance for both Indian and Foreign clients. As a part of Lawgical Professionals LLP, VA manages the secretarial function across its client base. The firm was founded by Mr. Shobhit Vasisht. VA offers a comprehensive range of services including Secretarial Compliance, Corporate Restructuring, Legal Advisory, Secretarial Audits, Insolvency and Bankruptcy Advisory, Securities Laws & Domestic and Global Business Setup, ESOPs, Trademark, Due Diligence, and other Corporate Advisory Services. Its clientele includes listed and unlisted companies, multinational corporations, and various Central Public Sector Enterprises (CPSEs) operating across multiple locations in India.

The Proposed remuneration to be paid to M/s Vasisht & Associates, for the financial year 2025-26 is ` 1,75,000 (one lakh seventy five thousand) plus out of pocket expenses and applicable taxes. For the subsequent years, the Board of Directors will decide the remuneration based on recommendation of the Audit Committee.

Accordingly, consent of the members is sought for approval of the aforesaid appointment of the Secretarial Auditors.

None of the Directors and/ or Key Managerial Personnel of the Company and/ or their relatives are, in any way, concerned or interested, financially or otherwise, in the resolution set out at Item No. 5 of the Notice.

Basis the rationale and justification provided above the Board recommends Ordinary Resolution as set out at Item No. 5 of the Notice for approval of Members.

ITEM NO. 6.

Pursuant to the provision of the Companies Act, 2013 read with rules made their under and listing Regulations, Members of the Company have appointed Mr. Shriniwas Vashisht (DIN: 06572418) as a Non-Executive Independent Director of the Company in their 26 [th] Annual General Meeting (AGM) held on September 24, 2020 for first term of five consecutive years w.e.f. September 24, 2020 to September 23, 2025 and his current term will expire on September 23, 2025.

Section 149 of the Companies Act, 2013 (‘the Act’) and provisions of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements), Regulations 2015, as amended (“Listing Regulations”) inter alia prescribe that an Independent Director of a company shall meet the criteria of independence as provided in Section 149(6) of the Act. Section 149(10) of the Act provides that an independent director can hold office for a term up to five consecutive years on the Board and shall be eligible for reappointment on passing of a Special Resolution by the Company.

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Nomination and Remuneration committee (NRC) on the basis of performance evaluation, has recommended the re-appointment of Mr. Shriniwas Vashisht (DIN: 06572418) as a Non-Executive Independent Director of the Company.

Based on recommendation of Nomination and Remuneration Committee and in terms of the provisions of Sections 149, 150, 152 read with Schedule IV and any other applicable provisions of the Act and SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, as amended, the Board of Directors at its meeting held on May 26, 2025 recommended for the approval of the members, for the re-appointment of Mr. Shriniwas Vashisht (DIN: 06572418) as a Non-Executive Independent Director of the Company for second term of five consecutive years from September 24, 2025 to September 23, 2030 and not liable to retire by rotation.

He has also given his consent to act as Director of the Company, if so re-appointed by the members.

The Company has also received requisite notice in writing from a member proposing the re-appointment of Mr. Shriniwas Vashisht for the office of Director of the Company.

The Company has received declaration from him stating that he meets the criteria of Independence as prescribed under sub-section (6) of Section 149 of the Companies Act, 2013 and Regulation16(1) (b) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. He has informed that he is not disqualified under Section 164(2) of the Act.

Brief Profile of Mr. Shriniwas Vashisht:

Mr. Shriniwas Vashisht aged 69 was born and brought up at Sonepat (Haryana). He did his M.A (Public Admn.) from Punjab University, Chandigarh and L.L.B. from Delhi University. He joined Indian Police Service in the year 1981 and was allotted to Haryana cadre.

During his career in Indian Police Service, exceeding 34 years, Sh. Vashisht handled very challenging assignments including Director General of Police, Haryana from October 2012 to January 2015 and promoted professionalism and ethics in the force. He also remained posted as Director General, State Vigilance Bureau, Haryana and achieved significant results in eradication of corruption. He retired from IPS in November 2015. Sh. Vashisht has been decorated with Police Medal for Meritorious Service and President’s Police medal for Distinguished Service.

Expertise of Sh. Shriniwas Vashisht ranges from civil and criminal investigation, intelligence to counter terrorism and crowd control at the state and national level and managing police force of more than 50,000 men.

Post his retirement, he also served as Chief Governance Coordinator, Gurgaon and is currently advising corporates and late stage startups/founders on managing and reducing risk in large people organizations - both external (litigation, law enforcement)

and internal (criminal risk, screenings). He specializes in dealing with ongoing situations.

Mr. Shriniwas Vashisht does not hold by himself or for any other person on a beneficial basis, any shares in the Company i.e. Action Construction Equipment Limited.

In the opinion of the Board, Mr. Shriniwas Vashisht fulfils the conditions specified under Section 149 (6) of the Act, the Companies (Appointment and Qualification of Directors) Rules, 2014 and Regulation 16(1)(b) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 for his re-appointment for second term as an Independent Non-Executive Director of the Company and is independent of the management.

The Board of Directors is of the opinion that Mr. Shriniwas Vashisht is a person of integrity, possess relevant expertise and vast experience. Accordingly, it is felt that his background, experience and association as Independent directors would be beneficial and in the best interest of the Company.

The brief resume of his Directorships, nature of their expertise in functional areas, disclosure of relationships between Directors, Directorships and Memberships of Committees of the Board of Listed entities and shareholding as required under Regulation 36(3) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 as amended and secretarial standard on general meeting (SS-2) issued by ICSI of India is set out in this Notice as Annexure-I.

Based on the disclosures received from Mr. Shriniwas Vashisht, it is confirmed that he is neither related to any existing Director of the Company nor debarred from accessing the capital markets and/or restrained from holding any position/office of Director in a Company pursuant to any order of the Securities and Exchange Board of India or any other such authority.

In terms of Section 149 and other applicable provisions of the Act and Rules made thereunder, the approval of members is sought by way of an Special Resolution for the re-appointment of Mr. Shriniwas Vashisht as Independent Non-Executive Director of the Company to hold office for a Second term of five consecutive years years with effect from September 24, 2025 and whose office shall not be liable to retire by rotation.”

A copy of the draft letter for the appointment of Mr. Shriniwas Vashisht as an Independent Director setting out the terms and conditions would be available for inspection without any fee by the members at the registered office of the Company during normal business hours (9:00 am to 5:00 pm) on the working day except Saturday upto the date and including the date of the AGM.

Save and except Mr. Shriniwas Vashisht, Director and their relatives, are in a way concerned or interested financially or otherwise to the

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extent of their shareholding interest, if any, in the Company, none of the other Directors/ Key Managerial Personnel of the Company/ their relatives are concerned or interested, financially or otherwise, in the Special Resolution set out at Item No. 6 of the Notice.

The Board recommends the Special Resolution as set out at Item No. 6 of the Notice for approval of the members.

ITEM NO. 7

Pursuant to the provision of the Companies Act, 2013 read with rules made their under and listing Regulations, Members of the Company have appointed Dr. Jagan Nath Chamber (DIN: 08841478) as a NonExecutive Independent Director of the Company in their 27 [th] Annual General Meeting (AGM) held on September 03, 2021 for first term of five consecutive years w.e.f. November 06, 2020 to November 05, 2025 and his current term will expire on November 05, 2025.

Section 149 of the Companies Act, 2013 (‘the Act’) and provisions of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements), Regulations 2015, as amended (“Listing Regulations”) inter alia prescribe that an Independent Director of a company shall meet the criteria of independence as provided in Section 149(6) of the Act. Section 149(10) of the Act provides that an Independent Director can hold office for a term up to five consecutive years on the Board and shall be eligible for re-appointment on passing of a Special Resolution by the Company.

Nomination and Remuneration committee (NRC) on the basis of performance evaluation, has recommended the re-appointment of Dr. Jagan Nath Chamber (DIN: 08841478) as a Non-Executive Independent Director of the Company.

Based on recommendation of Nomination and Remuneration Committee and in terms of the provisions of Sections 149, 150, 152 read with Schedule IV and any other applicable provisions of the Act and SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, as amended, the Board of Directors at its meeting held on May 26, 2025 recommended for the approval of the members, for the re-appointment of Dr. Jagan Nath Chamber (DIN: 08841478) as a Non-Executive Independent Director of the Company for second term of five consecutive years from November 06, 2025 to November 05, 2030 and whose office shall not liable to retire by rotation.

He has also given his consent to act as Director of the Company, if so re-appointed by the members.

The Company has also received requisite notice in writing from a

member proposing the re-appointment of Dr. Jagan Nath Chamber for the office of Director of the Company.

As per Regulation 17(1A) of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, as amended, no listed entity shall appoint a person as a non-executive director who has attained the age of 75 (Seventy Five) years unless a Special Resolution is passed to that effect, in which case the explanatory statement annexed to the notice for such motion shall indicate the justification for appointing such a person.

Since, Dr. Jagan Nath Chamber will attain the age of 75 years on May 15, 2029 during his tenure ending on November 05, 2030 as Independent Director, needs to be approved by Special Resolution by the shareholders.

Pursuant to Regulation 17 (1A) of SEBI (Listing Obligations and Disclouser Requirements) Regulations, 2015 and the applicable provision of the Companies Act 2013 read with rules made thereunder, the consent of the members of the Company be and is hereby accorded for continuation of employment of Dr. Jagan Nath Chamber as a Non-Executive Independent Director of the Company even after attaining the age of 75 years on May 15, 2029 during tenure ending on November 05, 2030."

Brief Profile of Dr. Jagan Nath Chamber:

Dr. Jagan Nath Chamber aged 71 was born at Ludhiana. He did his MA English Literature from Government College Ludhiana and LLB from Delhi University. He was an IAS officer and got UP cadre.

He served as District Magistrate at few places like Mau, Moradabad and served the state government in different capacities like IG Registration and Stamps Commissioner, Commissioner Sales Tax, Transport Commissioner, IG Prisons, Secretary and Principle Secretary of the Departments of Industries, Home and Prisons, Sports and Youth, Agriculture and Horticulture, Food and Civil Supplies, etc. in the State of Uttar Pradesh and also as member Board of Revenue.

Also served in Government of India in the capacity of Joint Secretary, Additional Secretary and Secretary. He Retired from Government of India as Secretary. During the service he did his MBA from Europe and PhD from Kumao University and have undergone various training courses in the country and abroad including Alumni of Harvard University USA.

Dr. Jagan Nath Chamber does not hold by himself or for any other person on a beneficial basis, any shares in the Company i.e. Action Construction Equipment Limited.

In the opinion of the Board, Dr. Jagan Nath Chamber fulfills the conditions specified under Section 149 (6) of the Act, the Companies (Appointment and Qualification of Directors) Rules, 2014 and Regulation 16(1)(b) of the SEBI (Listing Obligations and

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Disclosure Requirements) Regulations, 2015 for his re-appointment for second term as an Independent Non-Executive Director of the Company and he is independent of the management.

The Board of Directors is of the opinion that Dr. Jagan Nath Chamber is a person of integrity; possess relevant expertise and vast experience. Accordingly, it is felt that his background, experience and association as Independent directors would be beneficial and in the best interest of the Company.

Based on the disclosures received from Dr. Jagan Nath Chamber, it is confirmed that he is neither related to any existing Director of the Company nor debarred from accessing the capital markets and/ or restrained from holding any position/ office of Director in a Company pursuant to any order of the Securities and Exchange Board of India or any other such authority.

In terms of Section 149 and other applicable provisions of the Act and Rules made thereunder, the approval of members is sought by way of an Special Resolution for the re-appointment of Dr. Jagan Nath Chamber as Independent Non-Executive Director of the Company to hold office for a Second term of five consecutive years effective from November 06, 2025 and whose office shall not be liable to retire by rotation.”

A copy of the draft letter for the appointment of Dr. Jagan Nath Chamber as an Independent Director setting out the terms and conditions would be available for inspection without any fee by the members at the registered office of the Company during normal business hours (9:00 am to 5:00 pm) on the working day except Saturday upto the date and including the date of the AGM.

Save and except Dr. Jagan Nath Chamber, Director and their relatives, to the extent of their shareholding interest, if any, in the Company, none of the other Directors/ Key Managerial Personnel of the Company/ their relatives are concerned or interested, financially or otherwise, in the Special Resolution set out at Item No. 7 of the Notice.

The Board recommends the Special Resolution as set out at Item No. 7 of the Notice for approval of the members.

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ANNEXUrE-I

Details of Directors retiring by rotation and seeking appointment/ reappointment as required under regulation 36 of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 and Secretarial Standards-2 on General Meetings.

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----- Start of picture text -----

Name of Directors
Executive-Whole Time Director Non Executive-Independent Directors
Mr. Surbhi Garg Mr. Shriniwas Vashisht Dr. Jagan Nath Chamber
(Retire By Rotation) (Re-appointment) (Re-appointment)
DIN 01558782 06572418 08841478
Date of Birth (Age) 11.01.1978 (47) 08.11.1955 (69) 15.05.1954 (71)
Date of first
November 12, 2011 September 24, 2020 November 06, 2020
appointment on Board.
Qualification Undergraduate M.A. (Public Admn.) and L.L.B. M.A., LLB, (Retired IAS)
Relationship with Mr. Vijay Agarwal, Chairman & None None
Directors/ KMP Managing Director, Mrs. Mona
Agarwal and Mr. Sorab Agarwal,
Whole- Time Directors of the
Company are relatives under clause
77 of section 2 of Companies Act,
2013 read with rules thereof.
Experience/Expertise in Associated since 2011 with the Mr. Shriniwas Vashisht aged 69 was Dr. Jagan Nath Chamber aged 71
specific functional area Company as a Whole-Time Director born and brought up at Sonepat (Har- was born at Ludhiana. He did his MA
of the Company. She looks after the yana). He did his M.A (Public Admn.) English Literature from Government
Administration & HR functions of the from Punjab University, Chandigarh and College Ludhiana and LLB from Delhi
Company. Under her supervision, the L.L.B. from Delhi University. He joined University. He was an IAS officer and
Company’s administrative affairs are Indian Police Service in the year 1981 got UP cadre.
being handled in a skilled manner. and was allotted to Haryana cadre. He served as District Magistrate at
She has helped the Company to
few places like Mau, Moradabad
formulate effective Policies. During his career in Indian Police
and served the state government
Service, exceeding 34 years, Sh.
in different capacities like IG
Vashisht handled very challenging Registration and Stamps Commissioner,
assignments including Director General
Commissioner Sales Tax, Transport
of Police, Haryana from October
Commissioner, IG Prisons, Secretary and
2012 to January 2015 and promoted
Principle Secretary of the Departments
professionalism and ethics in the force.
of Industries, Home and Prisons, Sports
He also remained posted as Director and Youth, Agriculture and Horticulture,
General, State Vigilance Bureau, Food and Civil Supplies, etc. in the State
Haryana and achieved significant of Uttar Pradesh and also as member
results in eradication of corruption. Board of Revenue.
He retired from IPS in November 2015.
Also served in Government of India
Sh. Vashisht has been decorated with
Police Medal for Meritorious Service in the capacity of Joint Secretary,
and President’s Police medal for Additional Secretary and Secretary. He Retired from Government of India
Distinguished Service.
as Secretary. During the service he
Expertise of Sh. Shriniwas Vashisht did his MBA from Europe and PHD
ranges from civil and criminal inves- from Kumaun University and have
tigation, intelligence to counter ter- undergone various training courses
rorism and crowd control at the state in the country and abroad including
and national level and managing po- Alumni of Harvard University USA.
lice force of more than 50,000 men.
Post his retirement, he also served as
----- End of picture text -----

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----- Start of picture text -----

Chief Governance Coordinator, Gur-
gaon and is currently advising corpo-
rates and late stage startups/found-
ers on managing and reducing risk
in large people organizations - both
external (litigation, law enforcement)
and internal (criminal risk, screen-
ings). He specializes in dealing with
ongoing situations.
Terms and Conditions Retiring by rotation Refer Item No. 6 Refer Item No. 7
of appoint/re-appoint.
including remuneration (Refer Item No. 3)
Details of Remuneration 102.98 Lakhs3.20 Lakhs (sitting fees) 3.45 Lakhs (sitting fees) last drawn (FY-2024-25). Membership of the None  Nomination and Remuneration  Audit Committee Committees of Board of Committee  Corporate Social Responsibility Directors of Company.  Audit Committee Committee Directorship in other  VMS Equipment Pvt. Ltd. None  Jai Jinendra Promoters Pvt. Ltd. Companies including  Rotadrill India Pvt. Ltd.  Jai Bee Cee Daimonds LLP. listed Companies  Reachall India Pvt. Ltd.  Asia Consolidated Pvt. Ltd.  Asia Greens Ltd.  Asia Resorts Ltd. No. of Board Meetings Meeting held: 4 Meeting held: 4 Meeting held : 4 attended during the Meeting attended: 3 Meeting attended: 4 Meeting attended : 4 year. No. of shares held in 69,30,156 no. of equity shares of None None the Company. 2 each
Committee NIL NIL NIL
Memberships of other
Listed Companies
(includes only
Audit Committee
and Stakeholders
Relationship
Committee)
-
Skill and capabilities Being an Independent Directors of the Company, ethical and high standards of
required and the conduct is the utmost importance which help the Board to achieve a comprehensive
manner to meet such understanding of information as well as high standards of decision-making.
requirements Keeping in view the above requirement, Board is in the view that Mr. Shriniwaws
Vashisht and Dr. Jagan Nath Chamber are the persons of integrity, possess relevant
expertise and their Associations as Independent Directors would be beneficial and
in the best interest of the Company.
----- End of picture text -----

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ANNEXUrE II COMMUNICATION ON TAX DEDUCTION AT SOUrCE

(TDS) ON DIVIDEND DISTrIBUTION

Please take note of the below Tax Deduction at Source (TDS) provisions and information/document(s) requirements for each shareholder:

Section 1: For all Members – Details that should be completed and/ or updated, as applicable:- All Members are requested to ensure that the below details are completed and/ or updated, as applicable, in their respective Demat Account(s) maintained with the Depository Participant(s); or in case of shares held in physical form, with the Registrar & Transfer Agent (“RTA”) of the Company. Please note that these details as available on Record Date in the Register of Members/ Register of Beneficial Ownership will be relied upon by the Company, for the purpose of complying with the applicable TDS provisions.

i. Valid Permanent Account Number (PAN).
II. Residential status as per the Income Tax Act, 1961 i.e. Resident or Non- Resident for F.Y. 2025-26
III. Category of the Member:
(a) Mutual Fund
(b) Insurance Company
(c) Alternate Investment Fund ('AIF') Category I and II
(d) AIF Category III
(e) Government (Central/ State Government)
(f) Foreign Portfolio Investor (FPI)/ Foreign Institutional Investor (FII): Foreign Company
(g) FPI/ FII: Others (being Individual, Firm, Trust, AJP, etc.)
(h) Individual
(i) Hindu Undivided Family ('HUF')
(j) Firm
(k) Limited Liability Partnership ('LLP')
(l) Association of Persons ('AOP'), Body of individuals ('BOI') or Artificial Juridical Person ('AJP')
(m) Trust
(n) Domestic company
(o) Foreign company
IV. Email Address.
V. Address.

Section 2: TDS provisions and documents required, as applicable for relevant category of Members.

1. For resident Members:

(a) Mutual Funds: No TDS is required to be deducted as per section 196(iv) of the Income Tax Act, 1961 (“the IT Act”) subject to specified conditions. Self-attested copy of valid SEBI registration certificate needs to be submitted.
(b) Insurance Companies: No TDS is required to be deducted as per section 194 of the IT Act subject to specified conditions. Selfattested copy of valid IRDA registration certificate needs to be submitted.
(c) Category I and II Alternative Investment Fund: No TDS is required to be deducted as per section 197A (1F) of the IT Act subject to specified conditions. Self-attested copy of valid SEBI registration certificate needs to be submitted.
(d) recognised provident Funds: No TDS is required to be deducted as per Circular No.18/2017 subject to specified conditions. Selfattested copy of a valid order from Commissioner under Rule 3 of Part A of Fourth Schedule to the IT Act, or Self-attested valid documentary evidence (e.g. relevant copy of registration, notification, order, etc.) in support of the provident fund being established under a scheme framed under the Employees’ Provident Funds Act, 1952 needs to be submitted.
(e) Approved Superannuation Fund: No TDS is required to be deducted as per Circular No.18/2017 subject to specified conditions. Selfattested copy of valid approval granted by Commissioner under Rule 2 of Part B of Fourth Schedule to the IT Act needs to be submitted.

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(f) Approved Gratuity Fund: No TDS is required to be deducted as per Circular No.18/2017 subject to specified conditions. Self- attested copy of valid approval granted by Commissioner under Rule 2 of Part C of Fourth Schedule to the IT Act needs to be submitted.
(g) National Pension Scheme: No TDS is required to be deducted as per Sec 197A (1E) of the IT Act.
(h) Government (Central/ State): No TDS is required to be deducted as per Sec 196(i) of the IT Act.
(i) Business Trust: No TDS is required to be deducted as per Sec 194 of the IT Act. Self-attested copy of valid SEBI registration certificate
needs to be submitted.
(j) Any other entity entitled to exemption from TDS: Valid self-attested documentary evidence (e.g. relevant copy of registration, notification, order etc.) in support of the entity being entitled to exemption from TDS needs to be submitted.
(k) Other resident Members:
(i) TDS is required to be deducted at the rate of 10% u/s 194 of the IT Act.
(ii) No TDS is required to be deducted, if aggregate dividend distributed or likely to be distributed during the financial year to individual shareholder does not exceed ` 10,000.
(iii) No TDS is required to be deducted on furnishing of valid Form 15G (for individuals, with no tax liability on total income and income not exceeding maximum amount which is not chargeable to tax) or Form 15H (for individual above the age of 60 years with no tax liability on total income). (Format of Form 15G and Form 15H are available on website of Income Tax i.e. https:// www.incometaxindia.gov.in/forms/ incometax%20 rules/103120000000007845 pdf & https://www.incometaxindia. gov.in/ forms/ income-tax%20 rules/103120000000007846. pdf respectively).
(iv) TDS is required to be deducted at the rate prescribed in the lower tax withholding certificate issued u/s 197 of the Act, if such valid certificate is provided.
(v) TDS is required to be deducted at the rate of 20% u/s 206AA of the IT Act, 1961. If valid PAN of the shareholder is not available of the PAN has become inoperative.

2. For Non-resident Members:

(a) FPI and FII: TDS is required to be deducted at the rate of 20% (plus applicable surcharge and cess). Shareholder may be entitled to avail lower TDS rate as per Double Tax Avoidance Treaty (DTAA) between India and the country of tax residence of the shareholder, on furnishing the below specified documents:-
- i. Self-attested copy of PAN;
- ii. Self-attested copy of valid Tax Residency Certificate (TRC) obtained from the tax authorities of the country of which the shareholder is a resident;
- iii. Form 10F filed electronically on income tax e-portal and
- iv. Self-declaration on letter head of having no Permanent Establishment in India, Beneficial ownership of shares and eligibility to claim treaty benefits (as per Appendix 1 to this Communication).

In case the dividend is payable to ‘Specified Fund’ (category-III alternate investment fund) referred to in [Clause (c) of Explanation to Section 10(4D)], TDS rate would be 10% (plus applicable surcharge and cess). The reduced rate of TDS would be subject to the availability of requisite documents demonstrating that the person is covered under the aforesaid category of ‘Specified Fund’.

(b) Any entity entitled to exemption from TDS: Valid self- attested documentary evidence (e.g. relevant copy of registration, notification, order, etc. by Indian tax authorities) in support of the entity being entitled to exemption from TDS needs to be submitted.
(c) Other non-resident Members:
i. TDS is required to be deducted at the rate of 20% (plus applicable surcharge and cess).
ii. Shareholder may be entitled to avail lower TDS rate as per Double Tax Avoidance Treaty (DTAA) between India and the country of tax residence of the shareholder, on furnishing the below specified documents:
a. Self attested copy of PAN;
b. Self-attested copy of valid Tax Residency Certificate (TRC) obtained from the tax authorities of the country of which the shareholder is a resident;
c. Form 10F filed electronically on income tax e-portal and

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d. Self-declaration on letter head of having no Permanent Establishment in India, Beneficial ownership of shares and eligibility to claim treaty benefits (as per Appendix-1 to this Communication).
iii. TDS is required to be deducted at the rate prescribed in valid lower tax withholding certificate issued u/s 197 of the IT Act, if such valid certificate is provided

Details and/ or documents as mentioned above in Section 1 and Section 2, as applicable to the Member, need to be sent, duly completed and signed, through registered email address of the Member with PAN being mentioned in the subject of the email to reach [email protected] & [email protected] by August 14, 2025. Please note that no communication in this regard, shall be accepted post, August 14, 2025.

Section 3: Other general information for the Members:-

i) For all self-attested documents, Members must mention on the document “certified true copy of the original” . For all documents being sent/ accepted by email, the Member undertakes to send the original document(s) on the request by the Company.
ii) In case, the dividend income is assessable to tax in the hands of a person other than the registered Member as on the Record Date, the registered Member is required to furnish a declaration containing the name, address, PAN of the person to whom TDS credit is to be given and reasons for giving credit to such person by August 14, 2025.
iii) TDS deduction certificate will be sent to the members registered email address in due course.
Application of TDS rate is subject to necessary due diligence and verification by the Company, of the shareholder details as available in register of Members on the Book Closure Date, documents, information available in public domain, etc. In case of ambiguous, incomplete or conflicting information, or the valid information/ documents not being provided, the Company will arrange to deduct tax at the maximum applicable rate.
iv) In the event of any income tax demand (including interest, penalty, etc.) arising from any misrepresentation, inaccuracy or omission of information provided/ to be provided by the Member(s), such Member(s) will be responsible to indemnify the Company and also, provide the Company with all information/documents and cooperation in any appellate proceedings.

Note:

Above communication on TDS sets out the provisions of law in a summary manner only and does not purport to be a complete analysis or listing of all potential tax consequences. Shareholders should consult with their own tax advisors for the tax provisions applicable to their particular circumstances.

342

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APPENDIX - 1

FOrMAT FOr DECLArATION FOr CLAIMING BENEFITS UNDEr DTAA

Action Construction Equipment Limited

Dudhola Link Road, Dudhola, Distt. Palwal-121102 Email ID: [email protected]

Subject : Declaration for eligibility to claim benefit under Double Taxation Agreement between Government of India and Government of ............................... (mention country of tax residency) (“DTAA”), as modified by Multilateral Instrument (“MLI”), if applicable.

With reference to above, I/We wish to declare as below:

I/ We,...............................(Full name of the shareholder), having permanent account number (PAN) under the Indian Income tax Act, .............................................................................. …................................................................ (mention PAN), and holding(mention number of shares held) number of shares of the Company under Demat Account number/ folio number ............................. as on the Record Date as specified in the notice of 31 [st] Annual General Meeting, am / are a tax resident of (country name) in terms of Article 4 of the DTAA as modified by MLI (if applicable) and do not qualify as a ‘resident’ of India under section 6 of the Indian Income-tax Act, 1961 (“the IT Act”). A copy of the valid tax residency certificate for…….(period), which is valid as on the Book Closure Date, is attached herewith.
I/We am/are eligible to be governed by the provisions of the DTAA as modified by MLI (if applicable), in respect of the dividend income and meet all the necessary conditions to claim treaty rate including but not limited to stratification of the "Principal Purpose Test" provided by such MLI.
I/We am/are the legal and beneficial owner of the dividend income to be received from the Company.
I/We do/ will not have a Permanent Establishment (“PE”) in India during April 01, 2025 to March 31, 2026 in terms of Article 5 of the DTAA as modified by MLI (if applicable) or a fixed base in India and the amounts paid/ payable to us, in any case, are not attributable to the PE or fixed base, if any, which may have got constituted otherwise.
I/We do not have a business connection in India according to the provision of section 9(1)(i) of the act and the amounts paid/payable to us, in any case, are not attributable to business operations, if any carried out in India.
I/We hereby confirm we do/will not have a place of effective management during the period in India and none of the key management and commercial decisions for the conduct of the business in substance are/will be made in India.

I/We hereby certify that the declarations made above are true and bonafide. In case in future, any of the declarations made above undergo a change, we undertake to promptly intimate you in writing of the said event. You may consider the above representations as subsisting unless intimated otherwise.

In the event of any income tax demand (including interest, penalty, etc.) arising from any misrepresentation, inaccuracy or omission of information provided by me, I/ We will be responsible to pay and indemnify such income tax demand (including interest, penalty, etc.) and provide the Company with all information/ documents that may be necessary and co- operate in any proceedings before any income tax/ appellate authority.

For..........................................Mention the name of the payee Authorised Signatory: Name of the person signing: Designation of the person signing: Contact No.: Contact Address: Email: Date: place:

343

Annual Report 2024-25

AI assistant

Action Construction Equipments Ltd. AGM Information 2025

63900_rns_2025-08-05_ff93467f-802e-436f-9cb5-e622efd45d61.pdf

Action Construction Equipment Limited

Date: August 05, 2025

Dear Sir/Madam,

For Action Construction Equipment Limited

ACTION CONSTrUCTION EQUIpMENT LIMITED

NOTICE OF ThE ANNUAL GENErAL MEETING

OrDINArY BUSINESS:

1. To receive, consider and adopt:

SpECIAL BUSINESS:

liable to retire by rotation.”

NOTES:

33. Voting through electronic means:

ThE INSTrUCTIONS FOr MEMBErS FOr rEMOTE E-VOTING AND JOINING ANNUAL GENERAL MEETING ARE AS UNDEr:

Step 1: Access to NSDL e-Voting system

Login type helpdesk details

How to Log-in to NSDL e-Voting website?

General Guidelines for shareholders

ThE INSTrUCTIONS FOr MEMBErS FOr e-VOTING ON ThE DAY OF ThE AGM ArE AS UNDEr:-

INSTrUCTIONS FOr MEMBErS FOr ATTENDING ThE AGM ThrOUGh VC/OAVM ArE AS UNDEr:

By Order of the Board of Director For Action Construction Equipment Limited

EXpLANATOrY STATEMENT UNDEr SECTION 102 OF ThE COMpANIES ACT, 2013 READ WITH SEBI (LODR) REGULATIONS, 2015.

ITEM NO. 4

ITEM NO. 5

ITEM NO. 6.

Brief Profile of Mr. Shriniwas Vashisht:

ITEM NO. 7

Brief Profile of Dr. Jagan Nath Chamber:

ANNEXUrE-I

ANNEXUrE II COMMUNICATION ON TAX DEDUCTION AT SOUrCE

(TDS) ON DIVIDEND DISTrIBUTION

Section 2: TDS provisions and documents required, as applicable for relevant category of Members.

1. For resident Members:

Note:

APPENDIX - 1

FOrMAT FOr DECLArATION FOr CLAIMING BENEFITS UNDEr DTAA

Action Construction Equipment Limited

Subject : Declaration for eligibility to claim benefit under Double Taxation Agreement between Government of India and Government of ............................... (mention country of tax residency) (“DTAA”), as modified by Multilateral Instrument (“MLI”), if applicable.

AI assistant

Action Construction Equipments Ltd. — AGM Information 2025

63900_rns_2025-08-05_ff93467f-802e-436f-9cb5-e622efd45d61.pdf

Action Construction Equipment Limited

Date: August 05, 2025

Dear Sir/Madam,

For Action Construction Equipment Limited

ACTION CONSTrUCTION EQUIpMENT LIMITED

NOTICE OF ThE ANNUAL GENErAL MEETING

OrDINArY BUSINESS:

1. To receive, consider and adopt:

SpECIAL BUSINESS:

liable to retire by rotation.”

NOTES:

33. Voting through electronic means:

ThE INSTrUCTIONS FOr MEMBErS FOr rEMOTE E-VOTING AND JOINING ANNUAL GENERAL MEETING ARE AS UNDEr:

Step 1: Access to NSDL e-Voting system

Login type helpdesk details

How to Log-in to NSDL e-Voting website?

General Guidelines for shareholders

ThE INSTrUCTIONS FOr MEMBErS FOr e-VOTING ON ThE DAY OF ThE AGM ArE AS UNDEr:-

INSTrUCTIONS FOr MEMBErS FOr ATTENDING ThE AGM ThrOUGh VC/OAVM ArE AS UNDEr:

By Order of the Board of Director For Action Construction Equipment Limited

EXpLANATOrY STATEMENT UNDEr SECTION 102 OF ThE COMpANIES ACT, 2013 READ WITH SEBI (LODR) REGULATIONS, 2015.

ITEM NO. 4

ITEM NO. 5

ITEM NO. 6.

Brief Profile of Mr. Shriniwas Vashisht:

ITEM NO. 7

Brief Profile of Dr. Jagan Nath Chamber:

ANNEXUrE-I

ANNEXUrE II COMMUNICATION ON TAX DEDUCTION AT SOUrCE

(TDS) ON DIVIDEND DISTrIBUTION

Section 2: TDS provisions and documents required, as applicable for relevant category of Members.

1. For resident Members:

Note:

APPENDIX - 1

FOrMAT FOr DECLArATION FOr CLAIMING BENEFITS UNDEr DTAA

Action Construction Equipment Limited

Subject : Declaration for eligibility to claim benefit under Double Taxation Agreement between Government of India and Government of ............................... (mention country of tax residency) (“DTAA”), as modified by Multilateral Instrument (“MLI”), if applicable.

More from Action Construction Equipments Ltd.

Action Construction Equipments Ltd. AGM Information 2025