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MODULEX CONSTRUCTION TECHNOLOGIES LIMITED — Regulatory Filings 2026
May 27, 2026
62866_rns_2026-05-27_31e08315-62d9-4d6c-a251-52d6a5fd1552.pdf
Regulatory Filings
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MODULEX Modern Method of Construction
27th May, 2026
Ref.: MCTL/2026-27/BSE-069
To,
The Manager,
Department of Corporate Services,
BSE Limited,
P J Towers,
Dalal Street, Fort,
Mumbai – 400 001.
Security ID: MODULEX
Scrip Code: 504273
Dear Sir/Madam,
Sub: Annual Secretarial Compliance Report for the Financial Year ended 31st March, 2026 as per Regulation 24A of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015.
Dear Sir/Madam,
Pursuant to Regulation 24A of SEBI (Listing Obligations and Disclosure Requirement) Regulations, 2015, Please find enclosed herewith the Annual Secretarial Compliance Report from Mr. Hitesh J. Gupta, Practicing Company Secretary for the Financial Year ended 31st March, 2026.
Please take the same on your record.
Thanking you,
For Modulex Construction Technologies Limited
BHOOMI
MEWADA
Digitally signed
by BHOOMI
MEWADA
Date: 2026.05.27
13:34:52 +05'30'
Bhoomi Mewada
Company Secretary and Compliance Officer
Encl: As above
Modulex Construction Technologies Limited t/a Modulex
CIN: L25999PN1973PLC182679
Registered Office: A-82, MIDC Industrial Estate, Indapur – 413 132, Maharashtra
BSE Security Code: 504273 BSE Security ID: MODULEX
Website - www.modulex.in Email - [email protected] Contact - Tel: +91 2111 299200
CS HITESH J. GUPTA B.COM, ACS
PRACTICING COMPANY SECRETARY
MOBILE: +91 9619454784
EMAIL: [email protected]
Secretarial Compliance Report of Modulex Construction Technologies Limited (CIN: L25999PN1973PLC182679) for the financial year ended as on 31st March, 2026
[Under Regulation 24A of Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015]
I, Hitesh J. Gupta, Practicing Company Secretary have examined:
a) all the documents and record made available to us and explanation provided by Modulex Construction Technologies Limited (hereinafter referred ‘the listed entity’),
b) the filings/submissions made by the listed entity to the stock exchanges,
c) website of the listed entity,
d) any other document/filing, as may be relevant, which has been relied upon to make this Report.
for the financial year ended as on 31st March, 2026 (“Review Period”) in respect of compliance with the provisions of:
a) the Securities and Exchange Board of India Act, 1992 (“SEBI Act”) and the Regulations, circulars, guidelines issued thereunder and
b) the Securities Contracts (Regulation) Act, 1956 (“SCRA”), rules made thereunder and the Regulations, circulars, guidelines, issued thereunder by the SEBI.
The specific Regulations, whose provisions and the circulars/guidelines issued thereunder, have been examined, include:
a) Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015;
b) Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018;
c) Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011;
d) Securities and Exchange Board of India (Buyback of Securities) Regulations, 2018; Not Applicable as the Company has not bought back/proposed to buy-back any of its securities during the financial year ended 31st March, 2026 under review;
Regd. Off. – B/701, Astor Place Building, Sector No. 3, Charkop, Kandivali West, Mumbai – 400067
HITESH JAGDAMKUMAR GUPTA
Digitally signed by HITESH JAGDAMKUMAR GUPTA
Date: 2026.05.26 16:22:49
+05'30'
CS HITESH J. GUPTA B.COM, ACS
PRACTICING COMPANY SECRETARY
MOBILE: +91 9619454784
EMAIL: [email protected]
e) Securities and Exchange Board of India (Share Based Employee Benefits and Sweat Equity) Regulations, 2021; Not applicable as the Company has not issued shares to the employee during the financial year ended 31st March, 2026 under review;
f) Securities and Exchange Board of India (Issue and Listing of Non-Convertible Securities) Regulations, 2021 - Not Applicable as the Company has not issued or listed any Non-Convertible Securities during the financial year ended as on 31st March, 2026 under review;
g) Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015;
h) Other Regulations as applicable.
and circulars/guidelines issued thereunder;
and based on the above examination, I hereby report that, during the Review Period:
a) The listed entity has complied with the provisions of the above Regulations and circulars/guidelines issued thereunder, except in respect of matters specified below:
| Sr. No | Compliance Requirement (Regulations/ circulars/ guidelines including specific clause) | Regulation/ Circular No. | Deviations | Action Taken by | Type of Action | Details of Violati on | Fine Amount | Observations/ Remarks of the Practicing Company Secretary | Management Response | Remarks |
|---|---|---|---|---|---|---|---|---|---|---|
| N.A. |
HITESH
JAGDAMKUMA
R GUPTA
Digitally signed by
HITESH JAGDAMKUMAR
GUPTA
Date: 2026.05.26 16:23:08
+05'30'
Regd. Off. - B/701, Astor Place Building, Sector No. 3, Charkop, Kandivali West, Mumbai - 400067
CS
MOBILE: +91 9619454784
CS HITESH J. GUPTA B.COM, ACS
PRACTICING COMPANY SECRETARY
EMAIL: [email protected]
b) The listed entity has taken the following actions to comply with the observations made in previous reports:
| Sr. No. | Observations/Remarks of the Practicing Company Secretary (PCS) in the previous reports) | Observations made in the Secretarial Compliance report for the year ended March 31, 2025 | Compliance Requirement (Regulations/circulars/guidelines including specific clause) | Details of violation / Deviations and actions taken /penalty imposed, if any, on the listed entity | Remedial actions, if any, taken by the listed entity | Comments of the PCS on the actions taken by the listed entity |
|---|---|---|---|---|---|---|
| 1. | Late submission of report by 36 days | Late submission of report by 36 days | Regulation 33 of SEBI LODR | Late submission of report by 36 days | ||
| March 2024 | ||||||
| BSE levied SOP Fines | ||||||
| Rs. 1,80,000/- | The Company has submitted all the results on time except the Q4 as on 31st March, 2024. | Company has duly paid the fine imposed by BSE. |
HITESH JAGDAMKUMAR GUPTA
Digitally signed by HITESH JAGDAMKUMAR GUPTA
Date: 2026.05.26 16:24:06 +05'30'
Regd. Off. - B/701, Astor Place Building, Sector No. 3, Charkop, Kandivali West, Mumbai - 400067
CS
CS HITESH J. GUPTA B.COM, ACS
PRACTICING COMPANY SECRETARY
MOBILE: +91 9619454784
EMAIL: [email protected]
c) Compliances related to resignation of statutory auditors from listed entities and their material subsidiaries as per SEBI Circular CIR/CFD/CMD1/114/2019 dated 18th October, 2019:
| Sr. No | Particulars | Compliance Status (Yes / No / NA) | Observations / remarks by the Practicing Company Secretary |
|---|---|---|---|
| 1. | Compliances with the following conditions while appointing / re-appointing an auditor | ||
| i. If the auditor has resigned within 45 days from the end of a quarter of a financial year, the auditor before such resignation, has issued the limited review / audit report for such quarter; or | |||
| ii. If the auditor has resigned after 45 days from the end of a quarter of a financial year, the auditor before such resignation, has issued the limited review/ audit report for such quarter as well as the next quarter; | |||
| iii. If the auditor has signed the limited review/ audit report for the first three quarters of a financial year, the auditor before such resignation, has issued the limited review/ audit report for the last quarter of such financial year as well as the audit report for such financial year. | NA | No such event has occurred during the reporting period. Hence, the same is not applicable. | |
| No such event has occurred during the reporting period. Hence, the same is not applicable | |||
| No such event has occurred during the reporting period. Hence, the same is not applicable |
Regd. Off. - B/701, Astor Place Building, Sector No. 3, Charkop, Kandivali West, Mumbai - 400067
HITESH
JAGDAMKUM
AR GUPTA
Digitally signed by
HITESH JAGDAMKUMAR
GUPTA
Date:2020.05.26
16:24:29 +05'30'
CS
CS HITESH J. GUPTA B.COM, ACS
PRACTICING COMPANY SECRETARY
MOBILE: +91 9619454784
EMAIL: [email protected]
| 2. | Other conditions relating to resignation of statutory auditor | ||
|---|---|---|---|
| i. Reporting of concerns by Auditor with respect to the listed entity / its material subsidiary to the Audit Committee: | |||
| a. In case of any concern with the management of the listed entity / material subsidiary such as non-availability of information / non-cooperation by the management which has hampered the audit process, the auditor has approached the Chairman of the Audit Committee of the listed entity and the Audit Committee shall receive such concern directly and immediately without specifically waiting for the quarterly Audit Committee meetings. | |||
| b. In case the auditor proposes to resign, all concerns with respect to the proposed resignation, along with relevant documents has been brought to the notice of the Audit Committee. In cases where the proposed resignation is due to non-receipt of information / explanation from the company, the auditor has informed the Audit Committee the details of information / explanation sought and not provided by the management, as applicable. | |||
| c. The Audit Committee / Board of Directors, as the case may be, deliberated on the matter on | NA | No such event has occurred during the reporting period. Hence, the same is not applicable. | |
| NA | No such event has occurred during the reporting period. Hence, the same is not applicable. | ||
| NA | No such event has occurred during the reporting period. Hence, |
Regd. Off. – B/701, Astor Place Building, Sector No. 3, Charkop, Kandivali West, Mumbai – 400067
HITESH
JAGDAMKUMAR
GUPTA
Digitally signed by HITESH
JAGDAMKUMAR GUPTA
Date: 2026.05.26 16:24:52
+05'30'
CS
CS HITESH J. GUPTA B.COM, ACS
PRACTICING COMPANY SECRETARY
MOBILE: +91 9619454784
EMAIL: [email protected]
receipt of such information from the auditor relating to the proposal to resign as mentioned above and communicate its views to the management and the auditor.
ii. Disclaimer in case of non-receipt of information:
The auditor has provided an appropriate disclaimer in its audit report, which is in accordance with the Standards of Auditing as specified by ICAI / NFRA, in case where the listed entity/ its material subsidiary has not provided information as required by the auditor.
| 3 | The listed entity / its material subsidiary has obtained information from the Auditor upon resignation, in the format as specified in Annexure- A in SEBI Circular CIR/CFD/CMD1/114/2019 dated 18th October, 2019. | NA | No such event has occurred during the reporting period. Hence, the same is not applicable. |
|---|---|---|---|
ADDITIONAL DISCLOSURES:
- On the basis of Circular No. 20230316-1 dated 16th March 2023, the following are the Additional affirmations:
| Sr. No | Particulars | Compliance Status (Yes/No/ NA) | Observations/Remarks by PCS* |
|---|---|---|---|
| 1. | Secretarial Standards: | ||
| The compliances of the listed entity are in accordance with the applicable Secretarial Standards (SS) issued by the | Yes | NA |
Regd. Off. - B/701, Astor Place Building, Sector No. 3, Charkop, Kandivali West, Mumbai - 400067
HITESH JAGDAMKUMAR
Gupta
Digitally signed by HITESH JAGDAMKUMAR GUPTA
Date: 2026.05.26 16:23:06
+05'30'
CS
CS HITESH J. GUPTA B.COM, ACS
PRACTICING COMPANY SECRETARY
MOBILE: +91 9619454784
EMAIL: [email protected]
| Sr. No | Particulars | Compliance Status (Yes/No/NA) | Observations/Remarks by PCS* |
|---|---|---|---|
| Institute of Company Secretaries of India (ICSI). | |||
| 2. | Adoption and timely updation of the Policies: | ||
| • All applicable policies under SEBI Regulations are adopted with the approval of board of directors of the listed entities. | |||
| • All the policies are in conformity with SEBI Regulations and have been reviewed & updated on time, as per the regulations/circulars/guidelines issued by SEBI. | Yes | NA | |
| 3. | Maintenance and disclosures on Website: | ||
| • The Listed entity is maintaining a functional website | |||
| • Timely dissemination of the documents/information under separate section on the website | |||
| • Web-links provided in annual corporate governance reports under Regulation 27(2) are accurate and specific which re-directs to the relevant documents(s)/section of the website | Yes | NA | |
| 4. | Disqualification of Director(s): | ||
| None of the director(s) of the listed entity is/are disqualified under Section 164 of Companies Act, 2013 as confirmed by the listed entity. | Yes | NA |
Regd. Off. – B/701, Astor Place Building, Sector No. 3, Charkop, Kandivali West, Mumbai – 400067
HITESH
JAGDAMKUMAR
GUPTA
Digitally signed by HITESH
JAGDAMKUMAR GUPTA
Date: 2026.05.26 16:25:26
+05'30'
CS
CS HITESH J. GUPTA B.COM, ACS
PRACTICING COMPANY SECRETARY
MOBILE: +91 9619454784
EMAIL: [email protected]
| Sr. No | Particulars | Compliance Status (Yes/No/NA) | Observations/Remarks by PCS* |
|---|---|---|---|
| 5. | Details related to subsidiaries of listed entities have been examined w.r.t.: (a) Identification of material subsidiary companies (b) Disclosure requirement of material as well as other subsidiaries. | Yes | NA |
| 6. | Preservation of Documents: The listed entity is preserving and maintaining records as prescribed under SEBI Regulations and disposal of records as per Policy of Preservation of Documents and Archival policy prescribed under SEBI LODR Regulations, 2015. | Yes | NA |
| 7. | Performance Evaluation: The listed entity has conducted performance evaluation of the Board, Independent Directors and the Committees at the start of every financial year/during the financial year as prescribed in SEBI Regulations. | Yes | NA |
| 8. | Related Party Transactions: (a) The listed entity has obtained prior approval of Audit Committee for all Related party transactions (b) In case no prior approval obtained, the listed entity shall provide detailed reasons along with confirmation whether the transactions were subsequently approved/ratified/rejected by the Audit committee | Yes | NA |
| 9. | Disclosure of events or information: The listed entity has provided all the required disclosure(s) under Regulation 30 along with Schedule III of SEBI LODR Regulations, 2015 within the time limits prescribed thereunder. | No | 1. The disclosure regarding the outcome of Board Meeting held on November 14, 2025 for |
Regd. Off. - B/701, Astor Place Building, Sector No. 3, Charkop, Kandivali West, Mumbai - 400067
HITESH
JAGDAMKUMAR
GUPTA
Digitally signed by HITESH
JAGDAMKUMAR GUPTA
Date: 2026.05.26 16:25:43
+05'30'
CS
CS HITESH J. GUPTA B.COM, ACS
PRACTICING COMPANY SECRETARY
MOBILE: +91 9619454784
EMAIL: [email protected]
| Sr. No | Particulars | Compliance Status (Yes/No/NA) | Observations/Remarks by PCS* |
|---|---|---|---|
| approval of financial results for the quarter and half year ended 30th September, 2025 and issuance of equity shares on preferential basis by swap of shares was given after a delay of 3 hours, exceeding the timeline prescribed under the applicable regulation. | |||
| 10. | Prohibition of Insider Trading: | ||
| The listed entity is in compliance with Regulation 3(5) & 3(6) of SEBI (Prohibition of Insider Trading) Regulations, 2015 | Yes | NA | |
| 11. | Actions taken by SEBI or Stock Exchange(s), if any: | ||
| No action(s) has been taken against the listed entity/ its promoters/ directors/ subsidiaries either by SEBI or by Stock Exchanges (including under the Standard Operating Procedures issued by SEBI through various circulars) under SEBI Regulations and circulars/ guidelines issued thereunder. | N.A. | ||
| 12. | Resignation of statutory auditors from the listed entity or its material subsidiaries: | ||
| In case of resignation of statutory auditor from the listed entity or any of its material subsidiaries during the financial year, the | N.A. | There were no instances of resignation of statutory auditors of the Company and/or its subsidiaries during the Review Period. |
Regd. Off. - B/701, Astor Place Building, Sector No. 3, Charkop, Kandivali West, Mumbai - 400067
HITESH
JAGDAMKUMAR
GUPTA
Digitally signed by HITESH
JAGDAMKUMAR GUPTA
Date: 2026.05.26 16:26:08
+05'30'
CS
CS HITESH J. GUPTA B.COM, ACS
PRACTICING COMPANY SECRETARY
MOBILE: +91 9619454784
EMAIL: [email protected]
| Sr. No | Particulars | Compliance Status (Yes/No/NA) | Observations/Remarks by PCS* |
|---|---|---|---|
| listed entity and / or its material subsidiary(ies) has / have complied with paragraph 6.1 and 6.2 of section V-D of chapter V of the Master Circular on compliance with the provisions of the LODR Regulations by listed entities. | |||
| 13. | Additional non-compliances, if any: | ||
| No additional non-compliances observed for any SEBI regulation/circular/guidance note etc. except as reported above. | N.A. | No non-compliance was observed. |
Assumptions & limitation of scope and review:
- Compliance of the applicable laws and ensuring the authenticity of documents and information furnished, are the responsibilities of the management of the listed entity.
- My responsibility is to report based upon our examination of relevant documents and information. This is neither an audit nor an expression of opinion.
- I have not verified the correctness and appropriateness of financial records and books of account of the listed entity.
- This report is solely for the intended purpose of compliance in terms of Regulation 24A (2) of the SEBI (LODR) Regulations, 2015 and is neither an assurance as to the future viability of the listed entity nor of the efficacy or effectiveness with which the management has conducted the affairs of the listed entity.
Place: Mumbai
Date: May 26, 2026
HITESH
JAGDAMKU
MAR GUPTA
Digitally signed by
HITESH JAGDAMKUMAR
GUPTA
Date: 2026.05.26
16:26:23 +05'30'
Hitesh J. Gupta
M No. A33684
CP No.12722
UDIN: A033684H000487654
PR No.: 1874/2022
Regd. Off. – B/701, Astor Place Building, Sector No. 3, Charkop, Kandivali West, Mumbai – 400067