|
To,
The Members,
Kapil Raj Finance Limited
Your Directors are pleased to present their 40th Annual Report of the Company on the
Business and operations of the Company and the accounts for the Financial Year ended March
31,2026.
1) FINANCIAL HIGHLIGHTS:
(Rupees in Lakhs)
Particulars |
F.Y. 2025-2026 |
F.Y. 2024-2025 |
| Revenue from Operations |
- |
- |
| Other Income |
80.45 |
19.00 |
| Less: Total Expenses |
25.49 |
20.12 |
| Less: Exceptional Items |
- |
- |
| Profit / (Loss) Before Tax |
54.96 |
(1.12) |
| Less: Current Tax/Deferred Tax |
13.83 |
0.28 |
| Profit / (Loss) After Tax |
41.12 |
(0.84) |
2) STATE OF THE COMPANY'S AFFAIRS:
Financial Results:
During the year under review, the Company has earned total income of INR 80.45 Lakhs as
against the previous year income of INR 19 Lakhs & the Company has earned Net Profit
of INR 41.12 Lakhs in the Financial Year 2025-2026 as against loss of INR 0.84 Lakhs in
the Financial Year 2024-2025.
3) DIVIDEND:
During the financial year under review, the Board has not recommended any dividend.
Pursuant to the provisions of Regulation 43A of the SEBI (Listing Obligations and
Disclosure Requirements) Regulations, 2015, the top 1000 listed entities based on
market capitalization (as on March 31 of every financial year) are required to formulate a
Dividend Distribution Policy, which must be disclosed on the website of the listed entity,
along with a web link provided in their Annual Reports.
This requirement is not applicable to the Company, as it does not fall within
the list of top 1000 listed companies based on market capitalization as on March
31,2026, as per the data provided by BSE.
4) CHANGE IN NATURE OF BUSINESS:
During the financial year under review, there is no change in the nature of business of
the Company.
5) CAPITAL STRUCTURE:
i.Authorised Share Capital
The Authorised Share Capital of the Company as on financial year ended on March 31,2026
is INR 11,00,00,000 crores (Indian Rupees Eleven Crore Only) divided into 11,00,00,000
(Eleven Crore) Equity Shares having face value of INR 1/- (Indian Rupee One) Each (Equity
Shares).
ii. Issued, subscribed and paid-up share capital
The issued share capital of the Company as on financial year ended on March 31, 2026 is
INR 10,94,00,000/- (Indian Rupees Ten Crores ninety-four lakhs only) divided into
10,94,00,000 (Ten Crore ninety four lakhs) Equity shares of INR 1/- each.
The subscribed and paid-up capital of the Company as on financial year ended on March
31, 2026 is INR 10,94,00,000/- (Indian Rupees Ten Crores ninety-four lakhs only) divided
into 10,94,00,000 (Ten Crore ninety four lakhs) Equity shares of INR 1/- each.
iii. Equity shares with differential rights and sweat equity shares
During the financial year under review, the Company has neither issued sweat equity
shares nor issued equity shares with differential rights as to dividend, voting or
otherwise.
iv. Listing on Stock Exchanges
The Equity Shares of the Company are listed on BSE Limited (BSE). Further,
trading in the Equity Shares was not suspended on the Stock Exchanges during the financial
year under review.
6) AMOUNT PROPOSED TO BE TRANSFERRED TO RESERVES:
During the financial year under review, the Company has not transferred any amount to
the reserves apart from the profit.
7) STATEMENT OF DEVIATION OR VARIATION:
The disclosure requirements pertaining to any deviation or variation in connection with
the terms of a public issue, rights issue, or preferential issue, as specified under
applicable regulations, are not applicable to the Company. This is because the Company has
not issued any shares or other securities during the financial year under review.
8) TRANSFER TO INVESTOR EDUCATION AND PROTECTION FUND:
In accordance with the provisions of Sections 124 and 125 of the Companies Act, 2013
and Investor Education and Protection Fund (Accounting, Audit, Transfer and Refund) Rules,
2016 (IEPF Rules), dividend of a company which remain unpaid or unclaimed for
a period of seven years from the date of transfer to the unpaid Dividend account shall be
transferred by the company to the Investor Education and Protection Fund
(IEPF).
In terms of the foregoing provisions of the Companies Act, 2013, there is no dividend
which remains outstanding or remains to be paid and required to be paid and required to be
transferred to the IEPF by the Company during the year under review.
1) BUY-BACK OF SHARES:
During the financial year under review no shares were bought back by the Company.
2) DISCLOSURES WITH RESPECT TO DEMAT SUSPENSE ACCOUNT/ UNCLAIMED SUSPENSE AC COUNT:
The details regarding the unclaimed shares, if any, are mentioned in the Corporate
Governance Report.
3) EMPLOYEE STOCK OPTION SCHEME (ESOP):
The Company has not introduced or implemented any Employee Stock Option Scheme during
the financial year under review.
Accordingly, the provisions relating to ESOP are not applicable to the Company.
4) HUMAN RESOURCES:
The Company's employees continue to be among one of its most valued stakeholders. We
remain committed to attracting, developing, and retaining top talent. Our efforts are
focused on fostering a collaborative, transparent, and participative organizational
culture, while recognizing and rewarding merit and consistent high performance. We believe
that empowering our people is critical to driving long-term success and organizational
resilience.
The details with respect to the remuneration of directors and employees as required
under Section 197 of the Act and Rule 5(1) of the Companies (Appointment and Remuneration
ofManagerial Personnel) Rules, 2014 is annexed as Annexure - II.
5) CORPORATE SOCIAL RESPONSIBILITY (CSR) POLICY:
The provisions relating to Corporate Social Responsibility (CSR) are not
applicable to the Company, as the Company is not exceeding the prescribed threshold under
Section 135 of the Companies Act, 2013, read with the Companies (Corporate Social
Responsibility Policy) Rules, 2014, during the relevant financial year.
6) RISK MANAGEMENT POLICY:
Pursuant to the applicable provisions the Company has a well-defined risk management
framework in place including identification therein of elements of risk. The Company has
established procedures to periodically place before the Audit Committee and the Board; the
risk assessment procedures and minimization procedures being followed by the Company and
steps taken by it to mitigate these risks.
7) VIGIL MECHANISM /WHISTLE BLOWER POLICY FOR DIRECTORS AND EMPLOYEES:
The Company is firmly committed to upholding the highest standards of integrity,
transparency, and ethical conduct in all its business practices.
In pursuit of this commitment, a Vigil Mechanism and Whistle Blower Policy (the
Policy) has been established in accordance with the Act and Regulation 22 of the
SEBI Listing Regulations. The Policy provides a secure and confidential channel for
employees, directors, and stakeholders to report any suspected misconduct, unethical
behavior, fraud, or violations of the Company's Code of Conduct for employees without fear
of retaliation.
It also ensures direct access to the Chairperson of the Audit Committee, reinforcing
independence and oversight.
Employees and other stakeholders are encouraged to report actual or suspected
reportable matters as per the Policy. All reportable matters are objectively reviewed and
investigated by an independent investigation team. Outcomes and actions taken are reported
to the whistleblower committee and Audit Committee on a periodic basis.
The Company affirms that no individual has been denied access to the Chairperson of the
Audit Committee under this Policy.
During the financial year under review, no reportable matters were investigated. The
Vigil Mechanism and Whistle Blower Policy is also available on the website of the Company
at https://www.kapilraifinanceltd.com/policies.html
8) DISCLOSURE UNDER THE SEXUAL HARASSMENT OF WOMEN AT WORKPLACE (PREVENTION,
PROHIBITION AND REDRESSAL) ACT, 2013
The Company is committed to provide a safe and conducive work environment to all its
employees and associates It is the continuous endeavour of the Management of the Company
to create and provide an environment to all its employees that is free from discrimination
and harassment including sexual harassment.
The Company has in place a Policy on Prevention of Sexual Harassment in line with the
requirements of The Sexual Harassment of Women at the Workplace (Prevention, Prohibition
and Redressal) Act, 2013 (POSH Act). All the employees (permanent,
contractual, temporary, trainees) are covered under this policy.
During the financial year ended on March 31, 2026, the Company conducted virtual
training sessions for employees to build awareness about the Policy and the provisions of
the POSH Act. Your Company has complied with the provisions relating to constitution of
Internal Complaints Committee under the POSH Act for dealing with the complaint, if any,
relating to sexual harassment of women at workplace.
Details of sexual harassment complaints received and resolved during the financial year
under review are given below:
Number of complaints received/filed during the financial year: 0
Number of complaints disposed off during the financial year: 0
Number of cases pending for more than ninety days: 0
Number of complaints pending as on the end of the financial year: 0
9) SUBSIDIARY(IES) AND ASSOCIATE COMPANY(IES)
The Company is not having any Subsidiary, Associates and Joint Ventures as on financial
year ended 31st March, 2026.
10) DIRECTORS AND KEY MANAGERIAL PERSONNEL ('KMP')
i. Appointment / re-appointment or resignation of Director(s)/KMP
During the financial year under review, there was no change in Board of Directors / KMP
of the Company. Accordingly, the Board of directors / KMP as on closure of financial year
are as follows:
S No. |
Name of Director/KMP |
Designation |
| 1. |
Mr. Amit Balkrishna Ghume |
Managing Director |
| 2. |
Ms. Santosh Rani |
Whole-time Director |
| 3. |
Mr. Punith D Putharan |
Non-Executive Non-Independent Director |
| 4. |
Ms. Jalpa Kalpesh Darji |
Non-Executive Non-Independent Director |
| 5. |
Mr. Dipesh Dinkar Kambli |
Independent Director |
| 6. |
Ms. Gursharandeep Kaur |
Independent Director |
| 7. |
Ms. Preeti Kakkar |
Company Secretary and Compliance Officer |
| 8. |
Ms. Santosh Rani |
Chief Financial Officer |
However, the following individuals were appointed / ceased subsequent to the closure of
Financial Year 2025- 2026:
S No. |
Name of Director/KMP |
Designation |
Date of Appointment |
Date of Cessation |
| 1. |
Ms. Preeti Kakkar |
Company Secretary and Complia nce Officer |
- |
15.06.2026 |
| 2. |
Mr. Harit Anand |
Additional Director |
29.07.2026 |
- |
| 3. |
Mr. Arun Kumar Pandey |
Additional Director |
26.08.2026 |
- |
| 4. |
Mr. Manoj Kumar |
Additional Director |
26.08.2026 |
- |
| 5. |
Mr. Punith D Putharan |
Non-Executive Non- Independent Director |
- |
26.08.2026 |
| 6. |
Ms. Jalpa Kalpesh Darji |
Non-Executive Non- Independent Director |
- |
26.08.2026 |
| 7. |
Ms. Santosh Rani |
Whole-time Director |
- |
21.09.2026 |
ii. Declarations from Independent Director(s)
The Independent Directors have confirmed that:
they meet the criteria of Independence laid down under the Act and SEBI Listing
Regulations;
they have complied with the code for Independent Directors prescribed under
Schedule IV to the Act;
they have registered themselves with the Independent Director's databank
maintained by the Indian Institute of Corporate Affairs;
they are not aware of any circumstance or situation, which exists or may be
reasonably anticipated, that could impair or impact their ability to discharge their
duties with an objective independent judgment and without any external influence;
they have not been associated with any material supplier, service provider, or
customer of the Company;
they have not been partner, proprietor, or employee of the Company's Statutory
Audit firm during the preceding Financial Year;
they have not been affiliated with any legal or consulting firm that has or had
business transactions with the Company, its subsidiaries, or associate companies,
amounting to 10% or more of the gross turnover of such firm; and
apart from receiving Director's remuneration (including sitting fees), there
have not been any material pecuniary relationship or transactions with the Company, its
subsidiaries or associate companies, or their directors, during the three immediately
preceding Financial Years or during the current financial year exceeding the limits
specified under the Act and SEBI Listing Regulations.
Further, the Company confirms that neither the Independent Director nor their relative
as defined under the Act, were employed, in an executive capacity by the Company, its
Subsidiaries, or Associate Companies during the preceding Financial Year.
Accordingly, based on the declarations received from all Independent Directors, the
Board has confirmed that, in their opinion, independent directors of the Company are
persons of integrity, possess relevant expertise and experience and fulfil the conditions
specified in the Act and SEBI Listing Regulations and are independent of the management.
iii. Company's policy on Directors' appointment and remuneration including criteria for
determining qualifications positive attributes, independence of a Director and other
matters
The Nomination and Remuneration Policy (NRC Policy) has been developed in
accordance with Section 178 of the Act and Regulation 19 of the SEBI Listing Regulations.
It establishes a structured framework for the nomination, evaluation, and remuneration of
the Company's Directors and senior management personnel of the Company. The core objective
of the NRC Policy is to attract, retain, and reward most qualified and skilled talent
capable of driving long-term growth and success of the Company.
During the financial year under review, there were no changes made to the NRC Policy.
iv. Familiarisation Programme for Independent Directors:
The Familiarisation programs aims to provide insight to the Independent Directors to
understand the business of the Company. Upon induction, the Independent Directors are
familiarized with their roles, rights and responsibilities.
All the Directors of the company are updated as and when required, of their role,
rights, responsibilities under applicable provisions of the Companies Act, 2013 and the
SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 as amended from
time to time, Secretarial Standards, nature of industry in which the Company operates,
business model of the Company, etc. The Company holds Board and the Committee Meetings
from time to time.
The Board of Directors has complete access to the information within the Company. The
Independent Directors have the freedom to interact with the Company's management.
Directors are also informed of the various developments in the Company through various
modes of communications. All efforts are made to ensure that the Directors are fully aware
of the current state of affairs of the Company and the Industry in which it operates.
The details of familiarization programme undertaken have been uploaded on the Company's
website https://www.kapilrajfinanceltd.com/policies.html
11) NUMBER OF MEETINGS OF THE BOARD
During the financial year under review, the Board of Directors met 06 (Six) times. The
details of the Board Meetings and the attendance of the Directors thereat are provided in
the Corporate Governance Report forming part of this Annual Report.
The Company has complied with the provisions of the Companies Act, 2013 regarding the
maximum interval between two consecutive Board Meetings.
12) PERFORMANCE EVALUATION OF BOARD
In accordance with the provisions of the Act and the SEBI Listing Regulations, the
Company has implemented a formal, structured, and transparent process for the annual
evaluation of the performance of the Board as a whole, its various committees, the
chairperson of the Board, and individual directors, including independent directors.
The Nomination and Remuneration Committee (NRC), in consultation with the
Board, defined the evaluation framework and criteria, which focus on both qualitative and
quantitative aspects of governance. Key parameters used in the evaluation included:
Composition and diversity of the Board and its committees;
Clarity of roles and responsibilities;
Quality, timeliness, and adequacy of information shared with the Board;
Effectiveness of the Board's decision -making processes and strategic inputs;
Performance of the Chairperson in leading the Board;
Active participation and contribution of individual directors;
Functioning of committees in discharging their responsibilities effectively; and
Compliance with applicable regulatory requirements.
In compliance with Section 149(8) of the Act read with Schedule IV and Regulation 17 of
the SEBI Listing Regulations, the performance evaluation of independent directors was
carried out. This evaluation was based on parameters laid out by the NRC in line with the
Company's policy for evaluation of the performance of the board of directors, which is
available on the Company's website and can be accessed at
https://www.kapilraifinanceltd.com/policies.html.
13) NON-EXECUTIVE DIRECTOR'S COMPENSATION AND DISCLOSURES
None of the Independent or Non-Executive Directors has any pecuniary relationship or
transaction with the Company which, in the judgment of the Board, may affect their
independence as on 31st March, 2026.
14) COMMITTEES OF THE BOARD
As on the financial year ended March 31,2026, the Board has three (3) committees
constituted in compliance with the applicable provisions of the Act and SEBI Listing
Regulations, as given below:
i. Audit Committee;
ii. Nomination and Remuneration Committee;
iii. Stakeholders Relationship Committee
A detailed note on the composition of the committees and other mandatory details is
provided in the Corporate Governance Report forming part of this Annual Report.
15) AUDITORS AND AUDITOR'S REPORTS
i) Statutory Auditors
Pursuant to the provisions of Section 139 of the Act read with rules framed thereunder
M/s GAMS & Associates LLP, Chartered Accountants were appointed as the statutory
auditors of the Company for a term of 5 consecutive years to hold office from the
conclusion of 34th AGM of the Company till the conclusion of 40th AGM of the Company.
GAMS & Associates has given an unmodified opinion and has not given any
qualification or reservation or adverse remark or disclaimer in their audit report on the
financial statements of the Company for the financial year ended on March 31,2026.
ii) Secretarial Auditors
In terms of the provisions of Section 204 of the Companies Act, 2013 read with
Regulation 24A of the SEBI Listing Regulations, M/s. Neeraj Jindal & Associates,
Practicing Company Secretary, were appointed as Secretarial Auditors of the Company for a
term of 5 (five) consecutive years starting from April 1,2025 and ending on March 31,
2030. However, owing to other professional preoccupations he tendered his resignation with
effect from 21.08.2026, resulting in Casual vacancy.
Consequently, to fill the casual vacancy, the Board of Directors in their meeting held
on 21.09.2026, based on the recommendation of the Audit Committee, has appointed M/s Ankit
Singhal and Associates (FRN: S2019DE697200) as Secretarial Auditors of the Company to fill
the casual vacancy for the financial year 2025- 26, and has further recommended to the
Members their appointment for a term of 5 (five) consecutive financial years from the
financial year 2026-27 to the financial year 2030-31 in terms of Regulation 24A(1) of the
SEBI Listing Regulations.
M/s Ankit Singhal & Associates on their appointment have confirmed that:
their appointment is within the limits laid down under the guidelines of
Institute of Company Secretaries of India (ICSI);
they are not disqualified from continuing as Secretarial Auditors under Section
204 of the Act, Company Secretaries Act, 1980, SEBI Listing Regulations and Securities and
Exchange Board of India circulars;
they hold a valid peer review certificate issued by the ICSI.
The Secretarial Audit Report issued for the financial year ended on March 31, 2026 is
annexed as Annexure-I. Further, the Secretarial Auditors report doesn't contain any
qualification or reservation requiring explanation or adverse remark.
The Company has submitted the Annual Secretarial Compliance Report with BSE in
compliance with Regulation 24A of the SEBI Listing Regulations.
iii) Cost Auditor
During the Financial Year 2025-2026, the Company is not required to maintain cost
records, therefore the requirement of appointing Cost Auditor is not applicable on the
Company.
16) INTERNAL FINANCIAL CONTROLS AND THEIR ADEQUACY
Internal financial controls are an integral part of the Company's risk and governance
framework, addressing financial and operational risks to ensure the orderly and efficient
conduct of its business. This includes adherence to Company policies, safeguarding of
assets, prevention and detection of fraud and errors, accuracy and completeness of
accounting records, and the timely preparation of reliable financial information.
The Company has implemented an adequate internal financial control system over
financial reporting. This system ensures that all transactions are authorized, recorded
and reported correctly in a timely manner, providing reliable financial information and
complying with applicable accounting standards, commensurate with the size and volume of
the Company's business.
Key internal financial controls have been documented, automated wherever possible and
embedded in respective business processes. Assurance to the Board on the effectiveness of
internal financial controls is obtained through three lines of defense:
(a) Management reviews and self-assessments;
(b) Continuous controls monitoring by the Governance, Risk and Compliance Function; and
(c) Independent design and operational testing by the Statutory and Secretarial
Auditors.
The Company is of the opinion that the internal financial controls were adequate and
operating effectively during the financial year under review. Furthermore, these internal
financial controls were tested by the Statutory Auditors, who reported no material
weaknesses or significant deficiencies in their design or operation.
17) DISCLOSURE WITH RESPECT TO THE COMPLIANCE OF THE PROVISIONS RELATING TO THE
MATERNITY BENEFIT ACT, 1961
The Company has an Equal Parental Leave Policy extended to both male and female
employees which is in compliance to the Maternity Benefit Act 1961.
This policy reflects our belief in shared parenting and our commitment to creating an
inclusive workplace. Beyond leave, we support employees through access to mental wellness
programs, professional counseling, and structured return-to-work programs that ease the
transition back to their roles with confidence. To further assist working parents, we
offer creche facilities or tie ups with day care facilities at our offices, ensuring peace
of mind and a better work-life balance.
18) PROHIBITION OF INSIDER TRADING
In terms of the provisions of the Securities and Exchange Board of India (Prohibition
of Insider Trading) Regulations, 2015, as amended (PIT Regulations), the Company has
adopted the revised Code of Conduct to Regulate, Monitor and Report Trading by Inside
rs (the Code).
The Code is applicable to all Directors, Designated persons and connected persons and
their immediate relatives, who have access to unpublished price sensitive information
relating to the Company. The Company has also formulated a code of practices and
procedures for Fair disclosure of Unpublished Price Sensitive Information (UPSI)
incompliance with the PIT Regulations.
The aforesaid Codes are posted on the Company's website at:
https://www.kapilraifinanceltd.com/policies.html.
19) STATEMENT REGARDING OPINION OF THE BOARD WITH REGARD TO INTEGRITY, EXPERTISE AND
EXPERIENCE (INCLUDING THE PROFICIENCY) OF THE INDEPENDENT DIRECTORS APPOINTED DURING THE
YEAR:
In the opinion of Board of Directors of the Company, Independent Directors on the Board
of Company hold highest standards of integrity and are highly qualified, recognized and
respected individuals in their respective fields. It's an optimum mix of expertise
(including financial expertise), leadership and professionalism.
20) CEO/CFO CERTIFICATION
As required under Regulation 17(8) of the SEBI (Listing Obligations and Disclosure
Requirements) Regulations, 2015 as amended from time to time, the Managing Director and
CFO of the Company have certified the accuracy of the Financial Statements and adequacy of
Internal Control Systems for financial reporting for the year ended 31st March, 2026. The
Certificate is annexed in Annexure-III.
21) DECLARATION REGARDING COMPLIANCE BY BOARD MEMBERS AND SENIOR
MANAGEMENT PERSONNEL WITH THE COMPANY'S CODE OF CONDUCT
The Code of conduct of the Company aims at ensuring consistent standards of conduct and
ethical business practices across the Company. This Code is reviewed on an annual basis
and the latest Code is available on the website of the Company at
https://www.kapilraifinanceltd.com/policies.html
Pursuant to the SEBI (Listing Obligations and Disclosure Requirements) Regulations,
2015 as amended from time to time, a confirmation from the Managing Director regarding
compliance with the code by all the Directors and senior management of the Company is
annexed in Annexure-IV.
22) CONSERVATION OF ENERGY, TECHNOLOGY ABSORPTION AND FOREIGN EXCHANGE EARNINGS AND
OUTGO:
The details of conservation of energy, technology absorption, foreign exchange earnings
and outgo are as follows:
A. Conservation of Energy
The steps taken or impact on conservation of energy:
The Company remains committed to energy conservation and the adoption of sustainable
business practices.
The steps taken by the Company for utilizing alternate sources of energy:
During the financial year under review, the Company did not undertake any specific
initiatives for utilizing alternate sources of energy. However, the Company remains
committed to exploring and adopting suitable alternate and renewable sources of energy,
wherever feasible and commercially viable.
The capital investment on energy conservation equipment:
During the financial year under review, the Company has not made any capital investment
in energy conservation equipment.
B. Technology absorption, Research and Development
The efforts made towards technology absorption:
During the financial year under review, the Company did not undertake any significant
initiatives towards technology absorption, adaptation or innovation. The Company continues
to evaluate and adopt appropriate technologies, wherever required, to improve operational
efficiency and productivity.
The benefits derived like product improvement, cost reduction, product
development or import substitution:
During the financial year under review, no significant benefits were derived in terms
of product improvement, cost reduction, product development or import substitution through
technology absorption.
In case of imported technology during the last three years reckoned from the
beginning of the financial year:
a) Details of technology imported: Not Applicable.
b) Year of import: Not Applicable
c) Whether the technology has been fully absorbed: Not Applicable
d) If not fully absorbed, areas where absorption has not taken place, and the reasons
thereof: Not
Applicable.
Expenditure incurred on Research & Development:
During the financial year under review, the Company has not incurred any expenditure
towards Research & Development activities.
C. Foreign exchange earnings and Outgo-
S No. |
Particulars |
Amount (In INR) |
| 1. |
The Foreign Exchange earned in the terms of actual inflows during the
year 2025-26 |
0 |
| 2. |
The Foreign Exchange outgo in terms of actual outflow during the year
2025- 2026 |
0 |
23) STATUTORY DISCLOSURES
i. Details in respect of frauds reported by auditors
During the financial year under review, pursuant to Section 143(12) of the Act, M/s.
GAMS & Associates LLP, Chartered Accountants, Statutory Auditors and M/s. Ankit
Singhal and Associates, Company Secretaries, Secretarial Auditors have not reported
any instance of fraud committed in the Company by its officers or employees to the audit
committee.
ii. Requirements for maintenance of cost records
During the financial year under review, requirement for maintenance of cost records as
specified by Central Government under Section 148 of the Act is not applicable on the
Company. Consequently, the appointment of a cost auditor is not required.
iii. Annual Return
The annual return of the Company as on the financial year ended on March 31,2026 in
terms of Section 92 and Section 134 of the Act is available on the website of the Company
at https://www.kapilraifinanceltd.com/annualreturn.html.
iv. Material changes and commitments, if any, affecting the financial position of the
Company which have occurred between the end of the financial year of the Company to which
the financial statements relate and the date of the report
No material changes and commitments affecting the financial position of the Company
have occurred between the end of March 31, 2026, to which the financial statements relate
and the date of the report except for the following:
v. Details of significant and material orders passed by the regulators or courts or
tribunals impacting the going concern status and Company's operations in future
No significant and material orders have been passed by the regulators or courts or
tribunals impacting the going concern status and Company's operations in future.
vi. Management Discussion and Analysis Report
In terms of the provisions of Regulation 34 of the SEBI Listing Regulations, Management
Discussion and Analysis Report is set out as a separate section under this Annual Report
as Annexure-V.
vii. Business Responsibility and Sustainability Report (BRSR)
Pursuant to Regulation 34(2)(f) of the SEBI (Listing Obligations and Disclosure
Requirements) Regulations, 2015, as amended from time to time, the top 1,000 listed
companies based on market capitalization (as on March 31 of the preceding financial year)
are required to submit a Business Responsibility and Sustainability Report (BRSR) in the
format prescribed by SEBI.
However, the Company does not fall within the top 1,000 listed entities based on market
capitalization as per the list published by BSE as on March 31,2026, and accordingly, the
requirement to submit the BRSR for the financial year 2025-2026 is not applicable to the
Company.
viii. Corporate Governance Report
The Company has complied with all applicable corporate governance requirements as
prescribed under the Act and SEBI Listing Regulations. Report on corporate governance is
set out as a separate section under this Annual Report as Annexure-VI.
ix. Transactions with related parties
During the financial year under review, the Company has not entered into any materially
significant related party transaction. Related party transactions entered into were
approved by the audit committee and the Board, from time to time and are disclosed in the
notes to accounts of the financial statements forming part of this Annual Report.
All transactions with related parties are in accordance with the RPT Policy. Further,
during the financial year under review, in terms of Section 188 of the Act, all
transactions entered into by the Company with its related parties were on arm's length
basis and ordinary course of business. Hence, disclosure under the prescribed form AOC-2
in terms of Section 134 of the Act is not required.
The policy on the materiality of related party transactions and dealings with related
party transactions is available at https://www.kapilraifinanceltd.com/policies.html
x. Deposits
The Company has not accepted any deposits from the public and no amount on account of
principal or interest on deposits from the public was outstanding as on March 31,2026.
Accordingly, disclosures related to deposits as required to be made under the Act are
not applicable to the Company.
xi. Particulars of loan and advances, guarantees and investments
The Company has not given any loans and advances or guarantees or security neither made
any investments as per the provisions of Section 186 of the Act
xii. Details of application made or any proceeding pending under the Insolvency and
Bankruptcy Code, 2016
There was no application made or any proceeding pending under the Insolvency &
Bankruptcy Code, 2016 against/ by the Company during the period under review.
xiii. Compliance with Secretarial Standards
During the financial year under review, the Company has complied with the applicable
provisions of the Secretarial Standard-1 and Secretarial Standard-2 issued by the
Institute of Company Secretaries of India and notified by the Ministry of Corporate
Affairs (MCA).
However, due to the non-availability of the requisite number of Directors, the Company
was unable to convene one Board Meeting and the requisite Committee Meetings during the
quarter ended March 2026. Further, the separate meeting of the Independent Directors, as
required under Schedule IV of the Companies Act, 2013, was also not convened during the
financial year.
Consequently, the interval between two consecutive Board Meetings and certain Committee
Meetings exceeded the prescribed limit of 120 days, resulting in non-compliance with the
applicable provisions of the Companies Act, 2013 and the SEBI (Listing Obligations and
Disclosure Requirements) Regulations, 2015. The non-convening of the Independent
Directors' Meeting also resulted in non -compliance with the applicable provisions of the
Companies Act, 2013.
The management has taken note of the aforesaid non-compliances and shall ensure strict
adherence to the applicable statutory requirements going forward.
xiv. Revision of Financial statements and Board Report
During the financial year under review, there were no revisions in the financial
statements and Board Report of the Company.
xv. Valuation done at the time of one- time settlement
During the financial year under review, disclosure w.r.t. details of difference between
amount of the valuation done at the time of one-time settlement and the valuation done
while taking loan from the banks or financial institutions along with the reasons thereof,
is not applicable.
24) DIRECTORS RESPONSIBILITY STATEMENT
In accordance with the provisions of Section 134 of the Act, Directors to the best of
their knowledge and belief confirm and state that:
a. In the preparation of the annual accounts for the financial year ended on March 31,
2026, the applicable accounting standards have been followed along with proper explanation
relating to material departures;
b. The Directors have selected such accounting policies and applied them consistently
and made judgments and estimates that are reasonable and prudent so as to give a true and
fair view of the state of affairs of the Company as at the end of the financial year March
31,2026 and of the profit or loss of the Company for that period;
c. The Directors have taken proper and sufficient care for the maintenance of adequate
accounting records in accordance with the provisions of the Act for safeguarding the
assets of the Company and for preventing and detecting fraud and other irregularities;
d. The directors have prepared the annual accounts on a going concern basis;
e. The directors have laid down internal financial controls to be followed by the
Company and that such internal financial controls are adequate and were operating
effectively; and
f. The directors have devised proper systems to ensure compliance with the provisions
of all applicable laws and that such systems were adequate and operating effectively.
25) CAUTIONARY STATEMENT
The Annual Report including those which relate to the Directors' Report, Management
Discussion and Analysis Report may contain certain statements on the Company's intent
expectations or forecasts that appear to be forward - looking within the meaning of
applicable securities law and regulations while actual outcomes may differ materially from
what is expressed herein.
The Company bears no obligations to update any such forward looking statement. Some of
the factors that could affect the Company's performance could be the demand and supply of
Company's product and services, Changes in Government regulations, tax laws, forex
volatility etc.
26) ACKNOWLEDGMENTS
The Board would also like to thank all stakeholders including but not limited to
shareholders, customers, delivery partners, restaurant partners and all other business
associates for their continuous support to the Company and their confidence in its
management. We look forward to their continuous support in the future.
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By the order of the Board |
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Kapil Raj Finance Limited |
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Sd/- |
Sd/- |
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Amit Balkrishna Ghume |
Harit Anand |
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Managing Director |
Director |
Date: 21.09.2026 |
DIN: 10428357 |
DIN: 11812939 |
Place: Delhi |
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