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Niraj Cement Structurals Limited Capital/Financing Update 2025

May 15, 2025

63425_rns_2025-05-15_64d53c2b-b843-40d5-9b30-0661dc491ced.pdf

Capital/Financing Update

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Dated: 15[th] May, 2025

To,

The Corporate Relations Department.
BSE Limited
Phiroze Jeejeebhoy Towers,
Dalal Street,
Mumbai-400001
Script Code: 532986
National Stock Exchange of India Limited
Exchange Plaza
Bandra Kurla Complex,
Bandra East
Mumbai 400 051
Script Symbol : NIRAJ

Dear Sir/Madam

Sub: - : Monitoring Agency Report for the quarter ended 31[st] March, 2025

Pursuant to Regulation 32(6) of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, read with Regulation 173A of SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2018, please find enclosed Monitoring Agency Report for the quarter ended 31[st] March, 2025, issued by CARE Ratings Limited, the Monitoring Agency appointed to monitor the utilization of proceeds of Preferential Issue of Equity Shares and Warrants of the Company.

You are requested to take the above on your record.

Thanking you,

Yours Faithfully,

For Niraj Cement Structurals Limited

Digitally signed by ANIL ANIL ANANT JHA ANANT JHA Date: 2025.05.15 23:45:05 +05'30'

Anil Anant Jha

Company Secretary & Compliance Officer ACS 66063

CIN: L26940MH1998PLC114307 HEAD OFFICE: Unit No. 820 to 825, Commercial Building, Wadhwa, Dukes Horizon, ST Road, Nr. R K Studio, D G Patil Road, Mumbai - 400088 Tel.: 66027100 Fax: 25518736 E-mail: [email protected] Website: www.niraj.co.in

Monitoring Agency Report

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No. CARE/HO/GEN/2025-26/1058

The Board of Directors Niraj Cement Structurals Limited

Unit No. 820 to 825, Commercial Building, Wadhwa, Dukes Horizon, ST Road, Nr. R K Studio, D G Patil Road, Mumbai - 400088.

May 15, 2025

Dear Sir/Ma’am,

- Monitoring Agency Report for the quarter ended March 31, 2025 in relation to the Preferential Issue of Niraj Cement Structurals Limited (“the Company”)

We write in our capacity of Monitoring Agency for the Preferential Issue for the amount aggregating to Rs. 103.56 crore of the Company and refer to our duties cast under regulation 162A of the Securities & Exchange Board of India (Issue of Capital & Disclosure Requirements) Regulations.

In this connection, we are enclosing the Monitoring Agency Report for the quarter ended March 31, 2025, as per aforesaid SEBI Regulations and Monitoring Agency Agreement dated December 19, 2024.

Request you to kindly take the same on records.

Thanking you,

Yours faithfully,

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Darshan Shah

Assistant Director

[email protected]

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Monitoring Agency Report

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Report of the Monitoring Agency

Name of the issuer: Niraj Cement Structurals Limited For quarter ended: March 31, 2025

Name of the Monitoring Agency: CARE Ratings Limited

(a) Deviation from the objects: Yes. The company has provided inter-corporate deposits (ICD) and classified as ‘General Corporate Purposes’ (GCP). Lending in the form of ICDs does not form part of the definition of GCP given in the Offer Document. Further, the company has parked unutilized proceeds in equity via Portfolio Management Services (PMS) which is not in line with the interim use of proceeds as per the Offer document.

(b) Range of Deviation: Up to 10% (Considering ICD utilization)

Declaration:

We declare that this report provides an objective view of the utilization of the issue proceeds in relation to the objects of the issue based on the information provided by the Issuer and information obtained from sources believed by it to be accurate and reliable. The MA does not perform an audit and undertakes no independent verification of any information/ certifications/ statements it receives. This Report is not intended to create any legally binding obligations on the MA which accepts no responsibility, whatsoever, for loss or damage from the use of the said information. The views and opinions expressed herein do not constitute the opinion of MA to deal in any security of the Issuer in any manner whatsoever. Nothing mentioned in this report is intended to or should be construed as creating a fiduciary relationship between the MA and any issuer or between the agency and any user of this report. The MA and its affiliates also do not act as an expert as defined under Section 2(38) of the Companies Act, 2013.

The MA or its affiliates may have credit rating or other commercial transactions with the entity to which the report pertains and may receive separate compensation for its ratings and certain credit related analyses. We confirm that there is no conflict of interest in such relationship/interest while monitoring and reporting the utilization of the issue proceeds by the issuer, or while undertaking credit rating or other commercial transactions with the entity.

We have submitted the report herewith in line with the format prescribed by SEBI, capturing our comments, where applicable. There are certain sections of the report under the title “Comments of the Board of Directors”, that shall be captured by the Issuer’s Management / Audit Committee of the Board of Directors subsequent to the MA submitting their report to the issuer and before dissemination of the report through stock exchanges. These sections have not been reviewed by the MA, and the MA takes no responsibility for such comments of the issuer’s Management/Board.

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Signature: Name of the Authorized Signatory: Darshan Shah Designation of Authorized person/Signing Authority: Assistant Director

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1) Issuer Details:

Name of the issuer : Niraj Cement Structurals Limited Name of the promoter : Gulshan Chopra, Pooja Chopra, Aishwarya Chopra, Siddhant Chopra Industry/sector to which it belongs : Construction – Civil Construction

2) Issue Details

Issue Period : Equity Shares; December 17, 2024, to December 31, 2024, and Convertible Warrants; January 01, 2025, to March 21, 2025 Type of issue (public/rights) : Preferential Issue Type of specified securities : Convertible Warrants and Equity Shares IPO Grading, if any : Not Applicable Issue size (in crore) : Rs. 103.56 crore

3) Details of the arrangement made to ensure the monitoring of issue proceeds:

Source of information / certifications considered by Comments of the Comments of the Particulars Reply Monitoring Agency for Monitoring Agency Board of Directors preparation of report The company has provided inter-corporate We respectfully submit that all relevant and deposits (ICD) and classified as ‘General requisite documents including Board Resolution Corporate Purposes’ (GCP). Lending in the pertaining to the Inter-Corporate Deposit (ICD) form of ICDs does not form part of the have already been duly furnished by us. In light definition of GCP given in the Offer of the same, we do not concur with the Document. Further, the company has observations made by the agency in its report. parked unutilized proceeds in equity via We hereby request that our submissions be duly Portfolio Management Services (PMS) acknowledged and taken on record, and that the Offer document, CA Whether all utilization is as per the which is not in line with the interim use of comments made be re-evaluated in view of the No certificate, Bank statement, disclosures in the Offer Document? proceeds as per the Offer document. Such documentation and explanations already Management Confirmation investment in equity is exposed to market provided. risks. As outlined in the Company’s Offer Document Utilization of proceeds towards objects _page no. 9 clause C*_ , the Board of Directors is was routed from Monitoring Account to empowered to utilize the Company’s funds at current account. The current account their discretion, in accordance with applicable statement was submitted by the company laws. In line with this authorization, the Board, wherein classification of the transactions at its meeting held on February 11, 2025, towards the objects was given by the approved the deployment of funds through

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Particulars Reply Source of information /
certifications considered by
Monitoring Agency for
preparation of report
Comments of the
Monitoring Agency
Comments of the
Board of Directors
management. Inter-Corporate
Loans
and
investments.
Pursuant to this approval, the Company has
extended funds in the form of secured Inter-
Corporate Deposits (ICDs) to the vendors, for
bona fide business purposes. These ICDs are
fully secured by PDC’s and BG’s, significantly
mitigating credit risk and ensuring the safety and
timely recoverability of the deployed funds with
significant returns which is beneficial in the
interest of investors and Company. The primary
objective of these ICDs is to support vendors in
the procurement of raw materials and other
essential inputs required for the Company’s
operations. This initiative helps maintain an
uninterrupted supply chain and supports the
efficient functioning of production and service
cycles, aligning with the Company’s broader
operational goals.
Further, the Company had temporarily deployed
its unutilized funds through SEBI-registered
Portfolio Management Services (PMS) entities
as part of its interim treasury strategy. These
investments were made under the fiduciary
discretion of professional portfolio managers,
with the objective of optimizing returns while
maintaining
liquidity
and
capital
safety.
Although
the
Offer
Document
and
the
resolution passed by the Board primarily refer to
the deployment of idle funds in conventional
liquid instruments such as fixed deposits and
other securities, they do not explicitly restrict
investments
in
equity
or
market-linked

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Particulars Reply Source of information /
certifications considered by
Monitoring Agency for
preparation of report
Comments of the
Monitoring Agency
Comments of the
Board of Directors
instruments, provided such investments are
made through regulated and transparent
platforms. The PMS route, being governed by
SEBI regulations, offered a prudent and
compliant avenue for such interim deployment.
The portfolio was well-diversified across sectors
and asset classes to mitigate market risks, and
the investments were actively monitored to
ensure alignment with the Company’s liquidity
requirements and financial objectives. The funds
remained readily cashable and were structured
in a way that ensured they could be withdrawn
at short notice to meet project execution needs
or other operational commitments. In line with
evolving business priorities and with the
objective of deploying funds more directly into
core operational areas, the Company intends to
withdraw funds from its PMS. The proceeds
from these withdrawals will be utilized to meet
future business requirements, thereby ensuring
that the Company’s financial resources remain
aligned with its long-term growth strategy and
operational objectives.
All transactions are structured in line with
standard norms and comply with all the
applicable
statutory
and
regulatory
requirements, including the provisions of the
Companies Act,2013,wherever relevant.
Whether shareholder approval has been
obtained in case of material deviations#
from expenditures disclosed in the Offer
Document?
No CA
certificate*,
Management Confirmation
The company has provided inter-corporate
deposits (ICD) and same is classified as
‘General
Corporate
Purposes’
(GCP).
Lendingin the form of ICDs do not form
NIL

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Particulars Reply Source of information /
certifications considered by
Monitoring Agency for
preparation of report
Comments of the
Monitoring Agency
Comments of the
Board of Directors
part of the definition of GCP given in the
Offer Document.
Whether the means of finance for the
disclosed objects of the issue have
changed?
Yes Board
Resolution,
Bank
Statements
The issue was undersubscribed resulting in
a reduction of issue size from Rs. 132.77
crore to Rs. 103.56 crore. Board resolution
for revision in costs of the Objects has been
passed.
NIL
Is there any major deviation observed over
the earlier monitoringagencyreports?
No Not Applicable Not Applicable NIL
Whether
all
Government/statutory
approvals related to the object(s) have
been obtained?
Not
Ascertainable
Not Applicable Not Applicable NIL
Whether all arrangements pertaining to
technical assistance/collaboration are in
operation?
Not
Ascertainable
Not Applicable Not Applicable NIL
Are
there
any
favorable/unfavorable
events affecting the viability of these
object(s)?
Yes Board Resolution and Bank
Statements
Undersubscription in the issue may affect
the viability of the objects.
NIL
Is there any other relevant information
that may materially affect the decision
making of the investors?
Yes Bank
Statement,
and
Holding Statement
The company has invested unutilized
proceeds in equity via PMS which has an
unrealized loss of Rs. 0.54 crore.
Due to market fluctuations, the Company had an
unrealized loss of ₹0.54 crore as of March 31,
2025. However, this loss has since been
recovered. The Company intents to withdraw
the
entire
unutilized
amount
from
the
investment.

* The above details are verified with the help of CA certificate issued by Chaturvedi Sohan & Co. dated May 13, 2025

Where material deviation may be defined to mean:

a) Deviation in the objects or purposes for which the funds have been raised

b) Deviation in the amount of funds actually utilized by more than 10% of the amount projected in the offer documents.

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4) Details of objects to be monitored:

(i) Cost of objects –

Sr.
No
Item
Head
Source of information /
certifications considered by
Monitoring Agency for
preparation of report
Original cost
(as per the
Offer
Document)
in Rs. Crore
Comments of the Board of Directors Comments of the Board of Directors Comments of the Board of Directors
Revised
Cost
in Rs.
Crore
Comments of the
Monitoring Agency
Reason for cost
revision
Proposed
financing option
Particulars of -
firm
arrangements
made
1 Working
capital
requirements
CA
Certificate*,
Management
Certificate, Offer Document^, Board
Resolution for allotment and Board
Resolution for revision in cost
37.57 29.31 Board Resolution for revised
cost of objects considering
undersubscription
in
the
preferential issue
Due to under-subscription, the cost of the objects has
been proportionately reduced, in line with the disclosures
made in the Letter of Offer and the Board Resolution
2 To
meet
investment
in
subsidiary to mitigate any
business prospects
CA
Certificate*,
Management
Certificate, Offer Document^, Board
Resolution for allotment and Board
Resolution for revision in cost
62.00 48.37
3 General Corporate Purposes CA
Certificate*,
Management
Certificate, Offer Document^, Board
Resolution for allotment and Board
Resolution for revision in cost
33.19 25.88
Total 132.76 103.56

* The above details are verified by with the help of CA certificate issued by Chaturvedi Sohan & Co. dated May 13, 2025

^ Sourced from page 47 and page 56 of the Offer Document

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(ii) Progress in the objects –

Sr.
No
Item
Head
Source of information /
certifications considered by
Monitoring Agency for
preparation of report
Amount as
proposed
in the Offer
Document
in Rs. Crore
Amount utilised in Rs. Crore Amount utilised in Rs. Crore Amount utilised in Rs. Crore Total
unutilised
i
Comments of the
Monitoring Agency
Comments of the Board
of Directors
Comments of the Board
of Directors
Revised
As at During Reasons for
idle funds
Proposed
course of
action
amount n
Cost
beginning the At the end
Rs. crore
in Rs.
Crore
of the
quarter in
Rs. Crore
quarter
in Rs.
Crore
of the
quarter in
Rs. Crore
1 Working
capital
requirements
CA
Certificate*,
Management
Certificate,
Offer Document^, Board
Resolution for allotment,
Board
Resolution
for
Revision in Cost of Objects
and
Vendor
Acknowledgement
Letter
and Invoices
37.57 29.31 8.00 18.57 26.57 2.74 Utilization of proceeds is
towards advance payment
for materials to vendor
Neelkanth
Infratech
Private Limited, payment
to supplier for materials
and
payment
to
construction
contractors
Force Construction Private
Limited
and
Omtech
Associates.
2 To meet investment
in
subsidiary
to
mitigate any business
prospects
CA
Certificate*,
Management
Certificate,
Offer Document^, Board
Resolution for allotment,
Loan
Agreement
and
Acknowledgement Receipt
and Board Resolution for
Revision in Cost of Objects
62.00 48.37 0.00 48.37 48.37 0.00 Utilization of proceeds is
towards
making
investment
in
its
subsidiaries i.e. Niraj Build
India Limited and Niraj
Consulting Group Limited
in the form of loans.
3 General
Corporate
Purposes
CA
Certificate*,
Management
Certificate,
Offer Document^, Board
Resolution for allotment,
Board
Resolution
for
Revision in Cost of Objects,
Loan Agreement and Inter-
corporate Deposit Receipt,
and Invoices
33.19 25.88 8.00 7.88 15.88 10.00 Utilization of proceeds is
towards advancing inter-
corporate deposits (Offer
document does not state
this as an object to the
issue)
to
Flightech
Solutions Private Limited
and Vajraa and Vayu Infra
ConsultingPrivate Limited,
As
outlined
in
the
Company’s
Offer
Document, the Board of
Directors is empowered to
utilize
the
Company’s
funds at its discretion, in
accordance
with
applicable laws. In line
with this authorization,

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Sr.
No
Item
Head
Source of information /
certifications considered by
Monitoring Agency for
preparation of report
Amount as
proposed
in the Offer
Document
in Rs. Crore
Amount utilised in Rs. Crore Amount utilised in Rs. Crore Amount utilised in Rs. Crore Total
unutilised
Comments of the
Monitoring Agency
Comments of the Board
of Directors
Comments of the Board
of Directors
Revised
As at During Reasons for
idle funds
Proposed
course of
action
amount in
R
Cost
beginning the At the end
s. crore
in Rs.
Crore
of the
quarter in
Rs. Crore
quarter
in Rs.
Crore
of the
quarter in
Rs. Crore
and
reimbursement
of
payments
made
to
vendors.
the Board, at its meeting
held on February 11, 2025,
approved the deployment
of funds through Inter-
Corporate
Loans
and
investments. Pursuant to
this
approval,
the
Company has extended
funds in the form of
secured
Inter-Corporate
Deposits (ICDs) to the
vendors, for bona fide
business purposes. These
ICDs are fully secured by
PDC’s
and
BG’s,
significantly
mitigating
credit risk and ensuring
the safety and timely
recoverability
of
the
deployed
funds
with
significant returns which is
beneficial in the interest of
investors and Company.
The primary objective of
these ICDs is to support
vendors
in
the
procurement
of
raw
materials
and
other
essential inputs required

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Sr.
No
Item
Head
Source of information /
certifications considered by
Monitoring Agency for
preparation of report
Amount as
proposed
in the Offer
Document
in Rs. Crore
Amount utilised in Rs. Crore Amount utilised in Rs. Crore Amount utilised in Rs. Crore Total
unutilised
Comments of the
Monitoring Agency
Comments of the Board
of Directors
Comments of the Board
of Directors
Revised
As at During Reasons for
idle funds
Proposed
course of
action
amount in
R
Cost
beginning the At the end
s. crore
in Rs.
Crore
of the
quarter in
Rs. Crore
quarter
in Rs.
Crore
of the
quarter in
Rs. Crore
for
the
Company’s
operations. This initiative
helps
maintain
an
uninterrupted
supply
chain and supports the
efficient functioning of
production and service
cycles, aligning with the
Company’s
broader
operationalgoals.
Total 132.76 103.56 16.00 74.82 90.82 12.74

* The above details are verified with the help of CA certificate issued by Chaturvedi Sohan & Co. dated May 13, 2025

^ Sourced from page 47 and page 56 of the Offer Document

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(iii) Deployment of unutilized proceeds:

Sr. No. Type of instrument and name of the entity
invested in
Amount invested
(Rs. Crore)
Maturity date Earning Return on
Investment (%)
Market Value as at the
end of quarter
(Rs. Crore)
1. ICICI Bank Monitoring Account 2.74 - - - 2.74
2. Portfolio Management Services (Invested equity)
– Motilal Oswal Financial Services
9.91$ - - - 9.37
3. Portfolio Management Services (Cash Balances) –
Motilal Oswal
0.09 0.09
Total 12.74 12.20
  • The above details are verified with the help of CA certificate issued by Chaturvedi Sohan & Co. dated May 13, 2025

$ The company has parked unutilized proceeds in Portfolio Management Services (PMS) which is not in line with the interim use of proceeds as per the Offer document. Board Comments: the Company had temporarily deployed its unutilized funds through SEBI-registered Portfolio Management Services (PMS) entities as part of its interim treasury strategy.

(iv) Delay in implementation of the object(s) –

Completion Date Completion Date Comments of the Board of Directors Comments of the Board of Directors
Delay (no. of
Objects As per the offer
Actual days/ months)
Reason of delay
Proposed course of action
document
Working capital requirements March 31, 2027 Ongoing Not Applicable NIL NIL
To meet investment in subsidiary to mitigate any
businessprospects
March 31, 2027 March 31, 2025 No delay NIL NIL
General Corporate Purposes March 31, 2027 Ongoing Not Applicable NIL NIL
  • ^ Sourced from page 47 and page 56 of the Offer Document

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5) Details of utilization of proceeds stated as General Corporate Purpose (GCP) amount in the offer document:

Source of information / certifications
Amount
Sr. No Item Head^ considered by Monitoring Agency for Comments of Monitoring Agency Comments of the Board of Directors
in Rs. Crore
preparation of report
1 Inter-corporate deposits 6.90 Bank Statement, Management Certificate,
CA Certificate, Loan agreement and Inter-
corporate deposit receipt letter
Utilization of proceeds is towards
advancing inter-corporate deposits
(ICDs) to Flightech Solutions Private
Limited and Vajraa and Vayu Infra
Consulting
Private
Limited,
and
reimbursement of payments made to
vendors.


NIL
2 Payment to vendors and
contractors

0.98
Bank Statement, Management Certificate,
CA Certificate, and Invoices.



NIL
Total 7.88

* The above details are verified with the help of CA certificate issued by Chaturvedi Sohan & Co. dated May 13, 2025

^ Section from the offer document related to GCP:

“Upto 25% of the issue proceeds will be allocated for general corporate purposes. This allocation may cover, among other things, addressing ongoing corporate needs and contingencies, funding the company's operational costs and issue related cost as determined by the Board of Directors at their discretion, and any other purposes permitted under applicable laws”

10

Disclaimers to MA report:

a) This Report is prepared by CARE Ratings Ltd (hereinafter referred to as “Monitoring Agency/MA” ). The MA has taken utmost care to ensure accuracy and objectivity while developing this Report based on the information provided by the Issuer and information obtained from sources believed by it to be accurate and reliable. The views and opinions expressed herein do not constitute the opinion of MA to deal in any security of the Issuer in any manner whatsoever.

b) This Report has to be seen in its entirety; the selective review of portions of the Report may lead to inaccurate assessments. For the purpose of this Report, MA has relied upon the information provided by the management /officials/ consultants of the Issuer and third-party sources like statutory auditors (or from peer reviewed CA firms) appointed by the Issuer believed by it to be accurate and reliable.

c) Nothing contained in this Report is capable or intended to create any legally binding obligations on the MA which accepts no responsibility, whatsoever, for loss or damage from the use of the said information. The MA is also not responsible for any errors in transmission and specifically states that it, or its directors, employees do not have any financial liabilities whatsoever to the users of this Report.

d) The MA and its affiliates do not act as a fiduciary. The MA and its affiliates also do not act as an expert to the extent defined under Section 2(38) of the Companies Act, 2013. While the MA has obtained information from sources it believes to be reliable, it does not perform an audit and undertakes no independent verification of any information/ certifications/ statements it receives from auditors (or from peer reviewed CA firms), lawyers, chartered engineers or other experts, and relies on in its reports.

e) The MA or its affiliates may have other commercial transactions with the entity to which the report pertains. As an example, the MA may rate the issuer or any debt instruments / facilities issued or proposed to be issued by the issuer that is subject matter of this report. The MA may receive separate compensation for its ratings and certain credit-related analyses, normally from issuers or underwriters of the instruments, facilities, securities or from obligors.