School Marg, W. E. A., Karol Bagh, Delhi - 110 005 · Company Secretaries SECRETARIAL COMPLIANCE...

KAPIL RAJ FINANCE LIMITED CIN : L65929DL1985PLC022788

July 30, 2020

To,

The BSE Limited

Phiroze Jeejeebhoy Towers

Dalal Street,

Mumbai- 400 001

Sub: Annual Secretarial Compliance Report for the year ended March 31, 2020

under Regulation 24A of SEBI ( Listing Obligation & Disclosure Requirements),

2015 read with SEBI circular No. CIR/CFD/CMD1/27/2019 dated February 08, 2019.

Dear Sir/Madam,

Pursuant to Regulation 24A of SEBI (Listing Obligation & Disclosure Requirements),

2015 read with SEBI circular No. CIR/CFD/CMD1/27/2019 dated February 08, 2019; we

are enclosing herewith Annual Secretarial Compliance Report for the year ended March

31, 2020 issued by M/s. Amit R. Dadheech & Associates, Practicing Company Secretary,

Mumbai.

Kindly take this on your records and acknowledge the same.

For Kapil Raj Finance Limited

KAPIL RAJ FINANCE LIMITED sania: A DOL

Meehir Doshi DIRECTOR DIRECTOR DIN: 08536239

Regd. Office ; 8/33, III Floor, Satbhrava School Marg, W. E. A., Karol Bagh, Delhi - 110 005 Admn. Office : 204-B, Platinum Mall, Jawahar Road, Ghatkopar (East), Mumbai - 400 077 T : 91-22-6127 5175 » W : www.kapilrajfinanceltd.com + E : kapilrajfin@gmail.com

A\ Omit R. Dadheech 5 Associates Company Secretaries

SECRETARIAL COMPLIANCE REPORT OF KAPIL RAJ FINANCE LTD FOR THE

FINANCIAL YEAR ENDED MARCH 31, 2020

To,

Kapil Raj Finance Ltd., (CIN: L65929DL1985PLC022788)

23-B, First Floor, Chirag Delhi,

Opposite Satrang Bhawan,

New Delhi - 110017

We, Amit R. Dadheech & Associates, Practicing Company Secretary, have examined:

a) all the documents and records made available to us and explanation provided by Kapil Raj Finance Ltd. (“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 certification,

for the year ended March 31, 2020 (“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 Securities and

Exchange Board of India (“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; (Not Applicable to the Company during the financial year under review)

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 to the Company during the financial year under review)

e) Securities and Exchange Board of India (Share Based Employee Benefits) Regulations,

2014; (Not Applicable to the Company during the financial year under review)

f) Securities and Exchange Board of India (Issue and Listing of Debt Securities)

Regulations, 2008; (Not Applicable to the Company during the financial year under review)

g) Securities and Exchange Board of India (Issue and Listing of Non- Convertible and Redeemable Preference Shares) Regulations, 2013; (Not Applicable to the Company during the financial year under review)

h) Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations,

2015;

and circulars/ guidelines issued thereunder; and based on the above examination,

Mumbai-400 053. | Add, : B-15/16, Sth Floor, Shri Siddhivinayak Plaza, Next to T-Series Business Park, Off New Link Road, Andheri (W),

ona Mob. r91-9484944943 144 © E-mail: info@amitrdadheech.com « Web. : www.amitrdadheech.com

A\ Ait Fe Company Secretaries

We 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:-

Compliance Requirement Deviations Observations/ Remarks of the Sr. | (Regulations/ circulars / Practicing Company No guidelines including Secretary

specific clause)

1. | As per Regulation 46 of |The Website of the | The Website of the Company

SEBI (LODR) Reg. 2015 | Company is not updated | is not updated as per the

the listed entity shall | as specified in Regulation | provisions of Regulation 46 of maintain a functional | 46 of Listing Regulations, | Listing Regulations, 2015 website containing the | 2015

basic information about the listed entity.

b) The listed entity has maintained proper records under the provisions of the above

Regulations and circulars/ guidelines issued thereunder insofar as it appears from our examination of those records.

c) The following are the details of actions taken against the listed entity/ its promoters/

directors/ material subsidiaries either by SEBI or by Stock Exchanges (including under

the Standard Operating Procedures issued by SEBI through various circulars) under the

aforesaid Acts/ Regulations and circulars/ guidelines issued thereunder:

Sr. |Action taken by | Details of, Details of action taken | Observations/ INo. violation E.g. fines, warning | remarks of the

letter, debarment, etc. Practicing

Company

Secretary, if any.

1. [MSEI Limited [Non Compliance | Imposition of penalty for]The Company has with the | non appointment of | filed a reply to the

provisions of | whole time Company| letter received by Regulation 6 of | Secretary for the quarter] stock exchange for

SEBI (Listing | ended March 31, 2019] seeking the waiver

Obligation and | vide letter dated May 14,] of the penalty Disclosure 2019 imposed on_ the Requirement) Company.

Regulation, 2015

1. [MSEI Limited [Non Compliance | Imposing of penalty of Rs.|The Company is

with the | 1,13,280/- for default in] taking the

provision of SEBI | compliances with the] necessary steps to

(Listing provisions of SEBI| find out the non Obligation and | (Listing Obligation and| compliances, if any

Off. Add, : B-15/16, 5th Floor, Shri Siddhivinayak Plaza, Next to T-Series Business Park, Off

Mob, : +91-9484941943 / 44 « E-mail : info@amitrdadheech.com « We

New Link Road, Andheri (W), Mumbai-400 053.

b. : www.amitrdadheech.com

JAA Lint Re Dedbowch § Aasoints Company Secretaries

Disclosure Disclosure Requirement) | and take necessary

Requirement) Regulation, 2015 actions in this Regulation, 2015 regard.

d) The listed entity has taken the following actions to comply with the observations made

in previous reports: Not Applicable

For Amit R. Dadheech & Associates

Amit R. Dadheech Sa 3A ACS No. 22889, COP No. 8952

Date: July 30, 2020

Place: Mumbai

UDIN: A022889B000531188

Mumbai-400 053. | Add, : B-15/16, Sth Floor, Shri Siddhivinayak Plaza, Next to T-Series Business Park, Off New Link Road, Andheri (W),

On. AaB Mob. r91-9484944943 144 © E-mail: info@amitrdadheech.com « Web. : www.amitrdadheech.com