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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 : [email protected]

School Marg, W. E. A., Karol Bagh, Delhi - 110 005 · Company Secretaries SECRETARIAL COMPLIANCE REPORT OF KAPIL RAJ FINANCE LTD FOR THE FINANCIAL YEAR ENDED MARCH 31, 2020 To, Kapil

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Page 1: School Marg, W. E. A., Karol Bagh, Delhi - 110 005 · Company Secretaries SECRETARIAL COMPLIANCE REPORT OF KAPIL RAJ FINANCE LTD FOR THE FINANCIAL YEAR ENDED MARCH 31, 2020 To, Kapil

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 : [email protected]

Page 2: School Marg, W. E. A., Karol Bagh, Delhi - 110 005 · Company Secretaries SECRETARIAL COMPLIANCE REPORT OF KAPIL RAJ FINANCE LTD FOR THE FINANCIAL YEAR ENDED MARCH 31, 2020 To, Kapil

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: [email protected] « Web. : www.amitrdadheech.com

Page 3: School Marg, W. E. A., Karol Bagh, Delhi - 110 005 · Company Secretaries SECRETARIAL COMPLIANCE REPORT OF KAPIL RAJ FINANCE LTD FOR THE FINANCIAL YEAR ENDED MARCH 31, 2020 To, Kapil

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 : [email protected] « We

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

b. : www.amitrdadheech.com

Page 4: School Marg, W. E. A., Karol Bagh, Delhi - 110 005 · Company Secretaries SECRETARIAL COMPLIANCE REPORT OF KAPIL RAJ FINANCE LTD FOR THE FINANCIAL YEAR ENDED MARCH 31, 2020 To, Kapil

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: [email protected] « Web. : www.amitrdadheech.com