Annual Report 2021 22

2021-22

CORPORATE
contents BOARD OF DIRECTORS
Notice 1-13 Sh. Rajinder Kumar Garg, Chairman

Board’s Report 14-28 Sh. Dheeraj Garg, Managing Director
Business Responsibility Report 29-34 Sh. Andra Veetil Unnikrishnan, Dy. Managing Director
Secretarial Auditors’ Report 35-39 Sh. Manohar Lal Jain, Executive Director
Corporate Governance Report 40-62 Sh. Sanjay Garg, Non-Executive Director
Management Discussion & Analysis 63-68 Sh. Sanjay Surajprakash Sahni, Nominee Director
Independent Auditors’ Report 69-75 Sh. Surinder Singh Virdi, Independent Director
Balance Sheet 76 Sh. Shashi Bhushan Gupta, Independent Director
Statement of Profit & Loss 77 Sh. Ajit Singh Chatha, Independent Director
Cash Flow Statement 78 Sh. Virander Kumar Arya, Independent Director
Notes on Accounts 79-107 Smt. Deva Bharathi Reddy, Independent Director
Sh. Siddharth Bansal, Independent Director
REGISTERED OFFICE COMPANY SECRETARY
Village Somalheri/Lehli, Sh. Shaman Jindal

P.O. Dappar, Tehsil Derabassi,
Distt. S.A.S. Nagar (Mohali) Punjab CHIEF FINANCIAL OFFICER
PIN: 140506
Sh. Naveen Sorot
WORKS BANKERS/ INSTITUTIONS
i. Village Somalheri/Lehli, Axis Bank Ltd.

P.O. Dappar, Tehsil Derabassi, DBS Bank India Ltd.
Distt. S.A.S. Nagar (Mohali) Punjab-140506 Export-Import Bank of India
ii. Plot No. A-10, SIPCOT, Industrial Growth Centre, Federal Bank Ltd.
Vallam Village, Sriperumbudur, Tamil Nadu, 602105 HDFC Bank Ltd.
iii. Plot No. 733, 734, 735, 747 ICICI Bank Ltd.
Mouza Jojobera, P.O. & P.S. Chhota Govindpur, IDFC First Bank Ltd.
East Singhbhum District Jamshedpur, Jharkhand, 831015 Punjab National Bank
iv. Plot No. 77, 78, 136B, 394, Tata Capital Financial Services Ltd.
Village - Martoli/Tejpura, Taluka - Jotana, Yes Bank Ltd.
District - Mehsana, Gujarat, India, 384430 Mahindra & Mahindra Financial Services Ltd.
v. Village - Muria, P. O - Kolabira Thana No. – 150 Autotrac Finance Limited
District Seraikela - Kharsawan, Jharkhand, 833220 IndusInd Bank Ltd.
RBL Bank Ltd.
Axis Finance Ltd.
HEAD OFFICE STATUTORY AUDITORS

SCO 49-50, Sector 26, Madhya Marg, M/s AKR & Associates
Chandigarh-160 019 Chartered Accountants
SCO 51, 2nd Floor, Chandigarh Citi Centre,
REGISTRAR AND TRANSFER AGENT VIP Road, Zirakpur -140603 (Punjab)
Link Intime India Pvt. Ltd.
Noble Heights, 1st Floor, Plot No. NH-2, SECRETARIAL AUDITORS
LSC Near Savitri Market, C-1 Block, Janakpuri,
New Delhi-110058 M/s S.K. Sikka & Associates
COST AUDITORS
M/s Aggarwal Vimal & Associates
STEEL STRIPS WHEELS LIMITED
(CIN: L27107PB1985PLC006159)
Regd. Office: Village Somalheri/Lehli P.O. Dappar,
Tehsil Derabassi, Distt. S.A.S Nagar Mohali (Punjab) 140506
Phone: +91- 172-2793112, Fax: +91-172-2794834
Email: [email protected], Website: www.sswlindia.com
NOTICE
Notice is hereby given that the 36th (thirty sixth) Annual General Meeting of the Members of Steel Strips Wheels Limited (“Company”) will be
held as scheduled below:
Day & Date : Friday, 30th day of September, 2022
Time : 11.00 A. M.
Venue : Company’s Registered Office at
Village Somalheri/ Lehli, P.O. Dappar,
Tehsil Derabassi, Distt. S.A.S Nagar, Mohali (Punjab) 140506
ORDINARY BUSINESS:
1. To receive, consider and adopt the Audited Standalone Financial Statements of the Company for the financial year ended March
31, 2022 together with the Reports of the Board of Directors and Auditors thereon.
2. To declare a dividend on Equity Shares for the financial year 2021-22.
3. To appoint a Director in place of Sh. Dheeraj Garg (DIN: 00034926), who retires by rotation and being eligible, offers himself for re-
appointment.
4. To appoint a Director in place of Sh. Sanjay Garg (DIN: 00030956), who retires by rotation and being eligible, offers himself for re-
appointment.
5. To re-appoint statutory auditors for the second term of 5 (five) years and to fix their remuneration and in this regard to consider and if
thought fit, to pass the following resolution as an Ordinary Resolution:
“RESOLVED THAT pursuant to the provisions of Section 139, 142 and all other applicable provisions, if any, of the Companies
Act, 2013 read with the Companies (Audit and Auditors) Rules, 2014 (including any statutory modification(s) or amendment(s) or
re-enactment(s) thereof, for the time being in force), and pursuant to the recommendation of the Audit Committee and the Board of
Directors of the Company, M/s AKR & Associates, Chartered Accountants (ICAI Firm Registration No. 021179N), be and is hereby
re-appointed as statutory auditors of the Company to hold office for a second term of 5 (five) consecutive years from the conclusion of
this 36th Annual General Meeting till the conclusion of the 41st Annual General Meeting of the Company to be held in the year 2027, at
such remuneration plus applicable taxes, out of pocket expenses, travelling expenses, etc; as may be mutually agreed between the
Board of Directors of the Company and the Auditors.
RESOLVED FURTHER THAT the Board of Directors of the Company (including any committee thereof) be and is hereby authorized
to do all such acts, deeds, matters and things and to take all such steps as may be required in this connection including seeking all
necessary approvals to give effect to this Resolution and to settle any questions, difficulties or doubts that may arise in this regard.”
SPECIAL BUSINESS:
6. To consider and if thought fit, to pass with or without modification(s), the following resolution as an Ordinary Resolution:
“RESOLVED THAT pursuant to the provisions of section 148 and other applicable provisions, if any, of the Companies Act, 2013
(“Act”) read with the Companies (Audit and Auditors) Rules, 2014 (including any statutory modification(s) or amendment(s) or re-
enactment(s) thereof for the time being in force), the consent of the members be and is hereby accorded to ratify the remuneration
amounting to Rs. 50,000/- (Rupees Fifty Thousand Only) (plus applicable taxes and reimbursement of out of pocket expenses)
payable to M/s Aggarwal Vimal & Associates, Cost Accountants (Firm Registration No. 000350), who have been appointed as Cost
Auditors of the Company, by the Board of Directors based on the recommendation of the Audit Committee, to conduct the audit of the
cost records of the Company for the financial year ending March 31, 2023.
RESOLVED FURTHER THAT the Board of Directors of the Company (including any committee thereof) be and is hereby authorized
to do all such acts, deeds, matters and things and to take all such steps as may be required in this connection including seeking all
necessary approvals to give effect to this Resolution and to settle any questions, difficulties or doubts that may arise in this regard.”
7. To consider and if thought fit, to pass with or without modification(s), if any, the following Resolution as an Ordinary Resolution:
“RESOLVED THAT pursuant to the provisions of section 61, 64 and other applicable provisions, if any, of the Companies Act, 2013
(“Act”) read with relevant rules framed thereunder (including any statutory modification (s) or amendment (s) or re-enactment (s)
thereof for the time being in force), relevant provisions of Memorandum of Association and Articles of Association of the Company and
subject to such permission(s), sanction(s) and approval(s), if any, as may be required from any regulatory authority (ies) concerned in
this respect, approval of the members be and is hereby accorded to sub-divide each equity share of the Company having face value of
Rs. 5/- into 5 (Five) equity shares having face value of Re. 1/- each fully paid-up with effect from record date to be fixed by the Board
of Directors for this purpose.
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RESOLVED FURTHER THAT on sub-division, 5 (Five) equity shares of face value of Re. 1/- each be issued in lieu of existing 1 (One)
equity share of face value of Rs. 5/- each, subject to the terms of Memorandum and Articles of Association of the Company and shall
rank pari-passu in all respect, with the existing fully paid up equity shares of Rs. 5/- each of the Company.
RESOLVED FURTHER THAT upon sub-division of the equity shares, the share certificate(s) in respect of the existing equity shares
of face value of Rs. 5/- each held in physical form shall be deemed to have been automatically cancelled and be of no effect on and
from the record date and the Company may without requiring the members to surrender the existing share certificate(s), shall issue
new share certificate(s) of the Company, in lieu of such existing issued share certificate(s), and in case of equity shares held in
dematerialised form, the sub-divided equity shares shall be credited to the beneficiary accounts of the members with their respective
depository participants, in lieu of the existing credits representing the equity shares of the Company before sub-division.
RESOLVED FURTHER THAT the Board of Directors be and is hereby authorised to make appropriate adjustments due to the sub-
division of equity shares as aforesaid, to the stock options which have been granted or to be granted to the employees of the
Company under its “Steel Strips Wheels Limited-Employee Stock Option Scheme, 2016” and “Steel Strips Wheels Limited-Employee
Stock Option Scheme, 2021” (hereinafter referred to as “ESOS 2016” and “ESOS 2021” respectively), such that the number of all
outstanding stock options (vested but not exercised and unvested stock options), the number of stock options available for future
grant(s) with effect from the record date and the exercise price thereof shall be proportionately adjusted.
RESOLVED FURTHER THAT for the purpose of giving effect to the aforesaid resolution, the Board of Directors be and is hereby
authorized to fix record date and to take such steps as may be necessary for obtaining approvals, statutory, contractual or otherwise,
in relation to the sub-division of equity shares as aforesaid and to execute all deeds, applications, documents, writings, undertakings
and other declarations for submission with stock exchanges, Registrar of Companies (ROC), Registrar & Share Transfer Agent (RTA),
depositories and/or any other regulatory or statutory authority (ies) that may be required, on behalf of the company and to do all such
acts, matters and things as the Board of Directors may, in its absolute discretion, deem necessary, expedient or desirable including to
settle any questions, doubts or difficulties that may arise in this respect without requiring to obtain any further approval of the members
of the Company to the end and intent that they shall be deemed to have given their approval thereto and for matters connected
therewith or incidental thereto expressly by the authority of this resolution.”
8. To consider and if thought fit, to pass with or without modification(s), if any, the following Resolution as an Ordinary Resolution:
“RESOLVED THAT pursuant to provisions of sections 13, 61 and other applicable provisions of the Companies Act, 2013 (“Act”) read
with relevant rules framed thereunder (including any statutory amendment (s) or modification (s) or re-enactment (s) thereof for the
time being in force) and subject to such approvals as may be necessary and subject to the approval of sub-division of equity shares
by the members, consent of the members of the Company be and is hereby accorded to alter and substitute the existing Clause V of
the Memorandum of Association of the Company with the following new Clause V:
V. The Authorised Share Capital of the Company is Rs. 3640.00 Lacs (Rupees Three Thousand Six Hundred Forty Lacs only)
divided into 190,000,000 (Nineteen Crore) equity shares of face value of Re. 1/- each and 12,00,000 (Twelve Lacs) Optionally
Convertible Preference Shares of Rs. 145/- each, cumulative or non-cumulative.
RESOLVED FURTHER THAT for the purpose of giving effect to the aforesaid resolution, the Board of Directors be and is hereby
authorised to do all such acts, deeds, matters and things as the Board may, in its absolute discretion, deem necessary, expedient or
desirable including to settle any questions, doubts or difficulties that may arise in this respect without requiring to obtain any further
approval of the members of the Company to the end and intent that they shall be deemed to have given their approval thereto and for
matters connected therewith or incidental thereto expressly by the authority of this resolution.”
By Order of the Board of Directors
Place: Chandigarh Shaman Jindal

Date: 02.09.2022 Company Secretary
M. No. A15397
NOTES:
1. The Explanatory Statement pursuant to the provisions of Section 102 of the Companies Act, 2013 (“Act”) read with relevant rules made
thereunder, Secretarial Standards on General Meetings (SS-2) and Regulation 36 of the SEBI (Listing Obligations and Disclosure
Requirements) Regulations, 2015 (“SEBI Listing Regulations”) setting out material facts concerning the ordinary and special businesses
with respect to Item No(s). 5 to 8 above, to be transacted at the Meeting is annexed hereto. The relevant details of Directors seeking
re-appointment at this Annual General Meeting (“AGM”) of the Company are also annexed to the notice.
2. PURSUANT TO THE PROVISIONS OF THE ACT, A MEMBER ENTITLED TO ATTEND AND VOTE AT THE AGM IS ENTITLED TO
APPOINT A PROXY TO ATTEND AND VOTE ON A POLL INSTEAD OF HIMSELF/ HERSELF AND THE PROXY SO APPOINTED
NEED NOT BE A MEMBER OF THE COMPANY. THE INSTRUMENT OF PROXY IN ORDER TO BE EFFECTIVE, MUST BE
DEPOSITED AT THE REGISTERED OFFICE OF THE COMPANY, DULY COMPLETED AND SIGNED, NOT LESS THAN 48
HOURS BEFORE THE COMMENCEMENT OF THE AGM. A PROXY FORM FOR THE AGM IS ENCLOSED.
A PERSON CAN ACT AS A PROXY ON BEHALF OF THE MEMBERS NOT EXCEEDING FIFTY AND HOLDING IN THE
AGGREGATE NOT MORE THAN TEN PERCENT OF THE TOTAL SHARE CAPITAL OF THE COMPANY CARRYING VOTING
RIGHTS. A MEMBER HOLDING MORE THAN TEN PERCENT OF THE TOTAL SHARE CAPITAL OF THE COMPANY CARRYING
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VOTING RIGHTS MAY APPOINT A SINGLE PERSON AS PROXY AND SUCH PERSON SHALL NOT ACT AS A PROXY FOR ANY
OTHER PERSON OR SHAREHOLDER.
DURING THE PERIOD BEGINNING 24 HOURS BEFORE THE TIME FIXED FOR THE COMMENCEMENT OF THE MEETING
AND ENDING WITH THE CONCLUSION OF THE MEETING, A MEMBER WOULD BE ENTITLED TO INSPECT THE PROXIES
LODGED AT ANY TIME DURING THE BUSINESS HOURS OF THE COMPANY, PROVIDED THAT NOT LESS THAN THREE DAYS
OF NOTICE IN WRITING IS GIVEN TO THE COMPANY.
3. Institutional / Corporate Members intending to send their authorized representatives to attend the meeting are requested to send to
the Company, a certified true copy of the Board Resolution authorizing their representative (s) to attend and vote on their behalf at the
meeting.
4. Members / proxies / authorized representatives should bring the duly filled Attendance Slip enclosed herewith to attend the meeting.
Route map of the venue of the Meeting (including prominent land mark) is annexed to the notice.
5. In case of joint holders attending the meeting, only such joint holder who is higher in the order of the names will be entitled to vote at
the meeting.
6. Book Closure and Dividend:
i. The Register of Members and Share Transfer Books of the Company will remain closed from 24.09.2022 to 30.09.2022 (both
days inclusive) for the purpose of AGM and for determining the names of members entitled to dividend, if declared at this
AGM.
ii. The dividend, as recommended by the Board of Directors, if declared at this AGM will be paid within a period of 30 days from the
date of declaration, to those members whose name will appear on the register of members/depository records as at the closing
hours of business on 23.09.2022.
iii. Pursuant to the amendments introduced in the Income-tax Act, 1961 vide Finance Act, 2020, dividend income is taxable in the
hands of the shareholders/members w.e.f. 01.04.2020. The Company shall, therefore, be required to deduct TDS/ Withholding
Tax (TDS/ WHT) at the time of payment of dividend at the applicable tax rates. The rates of TDS/ WHT would depend upon the
category and residential status of the shareholder as briefed hereunder:
A. Tax on Dividend to Resident Shareholders
I. Tax on dividend to Resident Individual Shareholders
a) Tax shall not be deducted on payment of dividend to Resident Individual Shareholder, if the total amount of dividend payable
during the financial year does not exceed Rs. 5,000/-.
b) Tax to be deducted on payment of dividend to Resident Individual shareholder, if the total amount of dividend payable during the
financial year exceeds Rs. 5,000/-:
Category of shareholder Applicable tax rate Documents required to be submitted

Resident individual shareholders with PAN 10% PAN to be updated with Depository Participant / RTA
Resident individual shareholders without PAN / invalid PAN 20% NA
c) Resident Individual Shareholders, desires to avail exemption from deduction of tax on payment of dividend exceeding
Rs. 5,000/- during the financial year:
Resident Individual shareholders with PAN:-
a) For individuals with no tax liability on total income Copy of self-attested PAN & Declaration in Form 15G
Nil
b) For individuals above the age of 60 years with no tax Copy of self-attested PAN & Declaration in Form 15H
liability on total income
II. Tax on dividend to Resident Non-Individual Shareholders
Tax on dividend payable during the financial year to Resident Non-Individual Shareholders shall be deducted either @ 10% or lower
rates. They can avail exemption from TDS by submission of following documents:
Mutual Fund specified under Section 10(23D) of the Nil Copy of self-attested PAN & Certificate of registration
Income Tax Act, 1961 (the Act) with SEBI
Declaration under Section 10(23D) of the Income Tax

Act, 1961
An Insurance Company exempted under Section 194 of Nil Copy of self-attested PAN &
the Act Certificate of registration with Insurance Regulatory
and Development Authority (IRDA)/ LIC/ GIC
Declaration qualifying as Insurer as per Section 2(7A)

of the Insurance Act, 1938
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Alternate Investment Fund (AIF established in India) Nil Copy of self-attested PAN & registration certificates
for either Category I or Category II AIF as per SEBI
Regulations
Declaration under Section 10(23FBA) of the Act for

exemption
Other Non-Individual shareholders Nil Copy of self-attested PAN
Declaration along with self-attested copy of documentary

evidence supporting the exemption
Shareholders who have submitted order u/s 197 of the As per order Copy of self-attested PAN
Income Tax Act, 1961
Lower/NIL withholding tax certificate for the FY 2022-23
obtained from tax authority to be submitted to claim the
lower tax rates
B. Tax on Dividend to Non-Resident Shareholders
TDS/WHT on payment of dividend during the financial year to Non-Resident Shareholders shall be as follows:
Non-resident shareholders shall be taxed @ 20% plus applicable surcharge and cess on the dividend payable during the financial year. They
can avail beneficial rates under tax treaty between India and their country of residence, subject to submission of necessary documents i.e.
No Permanent Establishment and Beneficial Ownership Declaration, Tax Residency Certificate, Form 10F, any other document which may
be required to avail the tax treaty benefits.
Format for submission of various declarations mentioned above are made available on the website of the Company and the shareholders
are requested to provide signed declarations to the Company at SCO 49-50, Sector- 26, Madhya Marg, Chandigarh, 160019 or to the RTA
of the Company viz. Link Intime India Pvt. Ltd., Noble Heights 1st Floor, Plot No. NH-2, C-1 Block, LSC Near Savitri Market, Janakpuri, New
Delhi – 110058, Tel: 011-49411000 e-mail ID: [email protected] on or before 30.09.2022 (date of AGM).
C. SPECIAL PROVISIONS OF SECTION 206AB OF THE ACT
(For non-filers of tax return - For resident shareholders and selected non-resident shareholders)
The Finance Act, 2021 has inter alia inserted the provisions of Section 206AB of the Act which introduced special provisions for TDS in
respect of non-filers of income-tax return with effect from July 1, 2021. The term ‘specified person’ is defined in sub-section (3) of Section
206AB and covers the persons who meet the following conditions:
• A person who has not furnished the return of income for the assessment year relevant to the previous year immediately preceding
the financial year in which tax is required to be deducted, for which the time limit for furnishing the return of income under sub-
section (1) of section 139 has expired; and
• The aggregate of tax deducted at source and tax collected at source in his case is rupees fifty thousand or more in the said
previous year.
TDS is required to be deducted at higher of following rates in case of payments to specified persons:
- twice the rate specified in the relevant provision of the Act; or
- twice the rate or rates in force; or
- the rate of 5%
As per the provisions of newly introduced Section 206AB the verification as required under this section will be done by the Company from
the Income Tax portal and applicable tax will be deducted. The decision of the Company in this respect will be final and for any refund of tax
the shareholder has to file the return of income and claim tax refund.
Members holding shares under multiple accounts under different status / category and single PAN, may note that, higher of the tax as
applicable to the status in which shares held under a PAN will be considered on their entire holding in different accounts. In case of joint
shareholding, the shareholder named first in the Register of Members is required to furnish the requisite documents for claiming any
applicable beneficial tax rate.
Members may note that in case the tax on said dividend is deducted at a higher rate in absence of timely receipt, or insufficiency/incomplete/
incorrectness of the aforementioned details/documents from you, an option is available to you to file the return of income as per the Act and
claim an appropriate refund, if eligible.
No claim shall lie against the Company for such taxes deducted.
7. Updation of mandate for receiving dividend directly in bank account through Electronic Clearing System or any other means
in a timely manner:
Shares held in physical form: In order to receive dividend in a timely manner in future, Members holding shares in physical form
who have not updated their mandate for receiving the dividends directly in their bank accounts through Electronic Clearing Service
or any other means (“Electronic Bank Mandate”), can register their Electronic Bank Mandate to receive dividends directly into their
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bank account electronically or any other means, by sending scanned copy of the following details/ documents by email to reach the
Company’s RTA at email address [email protected].
a) Form ISR-1 along with supporting documents as follows. The said form is available on the company’s website at https://sswlindia.
com/wp-content/themes/sswl/assets/docs/Form-ISR-1.pdf and at RTA’s website at https://web.linkintime.co.in/KYC-downloads.
html
b) Cancelled cheque in original, bearing the name of the Member or first holder, in case shares are held jointly; In case name of
the holder is not available on the cheque, kindly submit the following documents:
i) Cancelled cheque in original
ii) Bank attested legible copy of the first page of the Bank Passbook/Bank Statement bearing the names of the account
holders, address, same bank account number and type as on the cheque leaf and full address of the bank branch.
c) self-attested scanned copy of the PAN Card; and
d) self-attested scanned copy of any document (such as Aadhar Card, Driving Licence, Election Identity Card, Passport) in support
of the address of the Member as registered with the Company.
Shares held in electronic form: Members holding shares in electronic form may note that the bank particulars registered against
their respective depository accounts will be used by the Company for payment of dividend. The Company or its Registrar and Transfer
Agents cannot act on any request received directly from the members holding shares in electronic form for any change of bank
particulars or bank mandates. Such changes are to be advised only to the Depository Participant of the members. Accordingly, the
Members holding shares in demat form are requested to update their Electronic Bank Mandate with their respective DPs.
8. The Company has sent individual letters to all the Members holding shares of the Company in physical form for furnishing their PAN,
KYC details and Nominations pursuant to SEBI circular No. SEBI/HO/MIRSD/MIRSD_RTAMB/P/CIR/2021/655 dated November 3,
2021 in Form ISR-1. The Form ISR-1 is also available on the website of the Company at https://sswlindia.com/wp-content/themes/
sswl/assets/docs/Form-ISR-1.pdf. Attention of the Members holding shares of the Company in physical form is invited to go through
and submit the said Form ISR-1.
9. SEBI vide its Circular no. SEBI/HO/MIRSD/MIRSD_RTAMB/P/CIR/2022/8 dated January 25, 2022 has mandated the listed companies
to issue securities in dematerialised form only while processing certain prescribed service requests viz. Issue of duplicate securities
certificate, claim from unclaimed suspense account; Renewal/Exchange of securities; Endorsement; Sub-division/ Splitting of securities
certificate; consolidation of securities certificate/ folios; Transmission and Transpositions. Accordingly, the members are requested to
make service request by submitting a duly filled and signed Form No. ISR-4, the format of which is available on the Company’s
website at https://sswlindia.com/wp-content/themes/sswl/assets/docs/Form-ISR-4.pdf under the Investor Service Request tab and
on the website of RTA- Link Intime India Private Limited at https://linkintime.co.in/. Members are requested to note that any service
request would only be processed after the folio is KYC Compliant.
10. SEBI vide its Gazette Notification no. SEBI/LADNRO/GN/2022/66 dated January 24, 2022 has mandated that all requests for transfer
of securities including transmission and transposition requests shall be processed only in dematerialised form. In view of the same
and to eliminate all risks associated with physical shares and avail various benefits of dematerialisation, the members are advised to
dematerialise their holdings.
11. Members are requested to intimate changes, if any, pertaining to their name, postal address, e-mail address, telephone/mobile
numbers, PAN, registering of nomination, power of attorney registration, Bank Mandate details, etc., to their DPs in case the shares
are held in electronic form and to the RTA at [email protected] in case the shares are held in physical form, in prescribed Form
ISR-1 and other forms pursuant to SEBI Circular No. SEBI/HO/MIRSD/MIRSD_RTAMB/P/CIR/2021/655 dated November 3, 2021.
Further, Members may note that SEBI has mandated the submission of PAN by every participant in securities market.
Nomination Facility: As per the provisions of Section 72 of the Act, the facility for making nomination is available for the Members
in respect of the shares held by them. Members who have not yet registered their nomination are requested to register the same by
submitting Form No. SH-13. If a Member desires to opt out or cancel the earlier nomination and record a fresh nomination, he/she may
submit the same in Form No. ISR-3 or Form No. SH-14, as the case may be. The said forms are available on the Company’s website
at https://sswlindia.com/investor/ under the Investor Service Request Tab. Members are requested to submit the said form (s) to their
respective DP, in case the shares are held in electronic form and to Company’s RTA in case the shares are held in physical form.
12. Electronic copy of the Annual Report for Financial Year 2021-22 and Notice of the AGM are uploaded on the Company’s website at
www.sswlindia.com and is being sent to all the members whose email IDs are registered with the Company/Depository Participant(s)/
RTA unless any member has requested for a physical copy of the report. For members who have not registered their email address,
physical copies of the Annual Report for FY 2021-22 and Notice of the AGM are being sent by the permitted mode.
Both the Annual Report and Notice of AGM are available on the website of BSE Limited (BSE) and the National Stock Exchange of
India Limited (NSE) at www.bseindia.com and www.nseindia.com, respectively. Further, Notice of the AGM is also available on the
website of Link Intime India Private Limited (LIIPL) at www.linkintime.co.in, the agency engaged for providing remote e-voting facility
at the AGM.
The physical copies of the aforesaid documents will also be available at the Company’s Registered Office for inspection during normal
business hours (9.00 am to 5.00 pm) on working days.
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Members who have not registered their e-mail addresses so far are requested to register their e-mail addresses with Registrar and
Share Transfer Agents of the Company/ Depository Participant (s), for receiving all communication including Annual Report, Notices,
Circulars, etc. from the Company electronically.
13. As per Regulation 40 of the SEBI Listing Regulations, as amended, securities of the listed companies can be transferred only in
dematerialized form with effect from April 1, 2019, except in case of request received for transmission or transposition and re-lodged
transfers of securities. Further, SEBI vide its circular no. SEBI/HO/MIRSD/RTAMB/CIR /P/2020/236 dated December 2, 2020 had fixed
March 31, 2021 as the cut-off date for re-lodgement of transfer deeds and the shares that are re-lodged for transfer shall be issued
only in demat mode. In view of this and to eliminate all risks associated with physical shares and for ease of portfolio management,
Members holding shares in physical form are requested to consider converting their holdings to dematerialized form.
Members may contact the Company’s RTA, M/s Link Intime India Pvt. Limited, at Noble Heights 1st floor, Plot No. NH-2, C-1 Block,
LSC Near Savitri Market, Janakpuri, New Delhi 110058 e-mail - [email protected] for assistance in this regard.
14. To prevent fraudulent transactions, Members are advised to exercise due diligence and notify the Company of any change in address
or demise of any Member as soon as possible. Members are also advised to not leave their demat account(s) dormant for long.
Periodic statement of holdings should be obtained from the concerned Depository Participant and holdings should be verified from
time to time.
15. The Company is maintaining the “INVESTORS SERVICE CELL” at its Head Office at SCO 49-50, Sector 26, Madhya Marg, Chandigarh
160019.
16. Members having any queries relating to Annual Report are requested to send their queries at least seven days before the date of the
Meeting.
17. Members can inspect the register of directors and key managerial personnel and their shareholding, required to be maintained under
Section 170 of the Act, and register of contracts or arrangements in which the directors are interested, to be maintained under Section
189 of the Act, during the course of the meeting at the venue.
18. Pursuant to applicable provisions of the Act, read with the Investor Education and Protection Fund Authority (Accounting, Audit,
Transfer and Refund) Rules, 2016 (Rules), all unpaid or unclaimed dividends are required to be transferred by the Company to the
Investor Education and Protection Fund (IEPF) established by the Central Government, after completion of seven years from the date
of transfer to Unclaimed Dividend Account of the Company. Further, according to the Rules, the shares in respect of which dividend
has not been paid or claimed by the shareholders for seven consecutive years or more shall also be transferred to the de-mat account
of the IEPF Authority. The said requirement does not apply to shares in respect of which there is a specific order of Court, Tribunal or
Statutory Authority, restraining transfer of the shares.
In view of this, Members are requested to claim their dividends from the Company, within the stipulated timeline. The Members, whose
unclaimed dividends/shares have been transferred to IEPF, may claim the same by making an online application to the IEPF Authority
in web Form No. IEPF-5 available on www.iepf.gov.in. For details, please refer to Corporate Governance Report which is a part of this
report.
During the year under review, the Company had sent individual notices and also advertised in the newspapers i.e. both national
(English) and local (Punjabi) seeking action from the shareholders who have not claimed their dividends for seven consecutive years
or more. Accordingly, the Company had transferred an amount of Rs. 4,74,171.00 of unpaid/unclaimed dividend for the financial year
2013-14 and 28,154 shares to the IEPF authority. The voting rights on these shares shall remain frozen till the shareholder claims
those shares from IEPF authority.
19. The cut-off date for the purpose of determining the Members eligible for participation in remote e-voting (e-voting from a place other
than venue of the AGM) and voting at the AGM is 23.09.2022. Please note that the Members can opt for only one mode of voting
i.e., either by voting at the meeting or remote e-voting. If Members opt for remote e-voting, then they should not vote at the Meeting.
However, once e-voting on a resolution is cast by a Member, such Member is not permitted to change it subsequently or cast the vote
again. Members who have cast their vote by remote e-voting prior to the date of the Meeting can attend the Meeting and participate
in the Meeting but shall not be entitled to cast their vote again.
20. Voting through electronic means
Pursuant to the provisions of Section 108 of the Act read with Rule 20 of the Companies (Management and Administration) Rules,
2014 as amended from time to time and Regulation 44 of the SEBI Listing Regulations, as amended from time to time, the Company
is pleased to provide members, a facility to exercise their right to vote on the resolutions proposed to be passed in the 36th AGM by
electronic means through remote e-voting services provided by Link Intime India Private Limited (LIIPL) through their e-voting website
“InstaVOTE”. It may be noted that this e-voting facility is optional. Since the Company is providing the facility of remote e-voting to the
shareholders, there shall be no voting by show of hands at the said meeting.
The instructions to Members for voting electronically are as under:
a. The remote e-voting period begins on 27.09.2022 at 9.00 a.m. and will end on 29.09.2022 at 5.00 p.m. During this period
shareholders of the Company, holding shares either in physical form or in dematerialized form, as on the cut-off date i.e.
23.09.2022, may cast their vote electronically. The remote e-voting module shall be disabled by LIIPL for voting thereafter.
6
The members are requested to note that once vote on a resolution is cast electronically, he shall not be allowed to change it
subsequently or cast vote again.
b. The voting rights of members shall be in proportion to their shares in the paid-up equity share capital of the Company as on cut-
off date. A person, whose name is recorded in the Register of Members or in the Register of Beneficial Owners maintained by
the depositories as on the cut-off date only shall be entitled to avail the facility of remote e-Voting as well as voting at the meeting
through ballot paper/ any other means.
c. Further, pursuant to SEBI circular dated December 9, 2020 on e-Voting facility provided by Listed Companies, Individual
shareholders holding securities in demat mode can also vote through their demat account maintained with Depositories and
Depository Participants.
Shareholders are advised to update their mobile number and email Id in their demat accounts to access e-Voting facility.
Login method for Individual shareholders holding securities in demat mode/ physical mode is given below:
Type of shareholders Login Method

Individual Shareholders • Existing IDeAS user can visit the e-Services website of NSDL viz. https://eservices.nsdl.com either on a
holding securities in personal computer or on a mobile. On the e-Services home page click on the “Beneficial Owner” icon under
demat mode with NSDL “Login” which is available under ‘IDeAS’ section, this will prompt you to enter your existing User ID and
Password. After successful authentication, you will be able to see e-Voting services under Value added
services. Click on “Access to e-Voting” under e-Voting services and you will be able to see e-Voting page.
Click on company name or e-Voting service provider name i.e. LINKINTIME and you will be re-directed to
“InstaVote” website for casting your vote during the remote e-Voting period.
• If you are not registered for IDeAS e-Services, option to register is available at https://eservices.nsdl.
com. Select “Register Online for IDeAS Portal” or click at https://eservices.nsdl.com/SecureWeb/
IdeasDirectReg.jsp
• Visit the e-Voting website of NSDL. Open web browser by typing the following URL: https://eservices.nsdl.
com either on a personal computer or on a mobile. Once the home page of e-Voting system is launched,
click on the icon “Login” which is available under ‘Shareholder/Member’ section. A new screen will open. You
will have to enter your User ID (i.e. your sixteen-digit demat account number hold with NSDL), Password/
OTP and a Verification Code as shown on the screen. After successful authentication, you will be redirected
to NSDL Depository site wherein you can see e-Voting page. Click on company name or e-Voting service
provider name i.e. LINKINTIME and you will be redirected to “InstaVote” website for casting your vote during
the remote e-Voting period.
• Shareholders/Members can also download NSDL Mobile App “NSDL Speede”
Individual Shareholders • Existing users who have opted for Easi / Easiest, can login through their user id and password. Option will
holding securities in be made available to reach e-Voting page without any further authentication. The URL for users to login
demat mode with CDSL to Easi / Easiest are https://web.cdslindia.com/myeasi/home/login or www.cdslindia.com and click on New
System Myeasi.
• After successful login of Easi/Easiest the user will be able to see the E-Voting Menu. The Menu will have
links of e-Voting service provider i.e. LINKINTIME. Click on LINKINTIME and you will be redirected to
• If the user is not registered for Easi/Easiest, option to register is available at https://web.cdslindia.com/
myeasi/Registration/EasiRegistration.
• Alternatively, the user can directly access e-Voting page by providing demat account number and PAN No.
from a link in www.cdslindia.com home page. The system will authenticate the user by sending OTP on
registered Mobile & Email as recorded in the demat Account. After successful authentication, user will be
provided links for the respective ESP i.e. LINKINTIME. Click on LINKINTIME and you will be redirected to
Individual Shareholders • You can also login using the login credentials of your demat account through your Depository Participant
(holding securities in registered with NSDL/CDSL for e-Voting facility.
demat mode) & login
• Upon logging in, you will be able to see e-Voting option. Click on e-Voting option, you will be redirected to
through their depository
NSDL/CDSL Depository site after successful authentication, wherein you can see e-Voting feature. Click on
participants
company name or e-Voting service provider name i.e. LINKINTIME and you will be redirected to “InstaVote”
website for casting your vote during the remote e-Voting period.
7
Individual Shareholders 1. Open the internet browser and launch the URL: https://instavote.linkintime.co.in
holding securities in
2. Click on “Sign Up” under ‘SHARE HOLDER’ tab and register with your following details: -
Physical mode/ Non-
Individual Shareholders A. User ID:
holding securities in Shareholders holding shares in physical form shall provide Event No. + Folio Number registered with
demat mode & e-voting the Company. Shareholders holding shares in NSDL demat account shall provide 8 Character DP ID
service Provider is followed by 8 Digit Client ID; Shareholders holding shares in CDSL demat account shall provide 16 Digit
LINKINTIME. Beneficiary ID.
B. PAN: Enter your 10-digit Permanent Account Number (PAN) (Shareholders who have not updated their
PAN with the Depository Participant (DP)/ Company shall use the sequence number provided to you,
if applicable.
C. DOB/DOI: Enter the Date of Birth (DOB) / Date of Incorporation (DOI) (As recorded with your DP /
Company - in DD/MM/YYYY format)
D. Bank Account Number: Enter your Bank Account Number (last four digits), as recorded with your DP/
Company.
*Shareholders holding shares in physical form but have not recorded ‘C’ and ‘D’, shall provide their Folio
number in ‘D’ above
*Shareholders holding shares in NSDL form, shall provide ‘D’ above
► Set the password of your choice (The password should contain minimum 8 characters, at least one special
Character (@!#$&*), at least one numeral, at least one alphabet and at least one capital letter).
► Click “confirm” (Your password is now generated).
3. Click on ‘Login’ under ‘SHARE HOLDER’ tab.
4. Enter your User ID, Password and Image Verification (CAPTCHA) Code and click on ‘Submit’.
Cast your vote electronically:
1. After successful login, you will be able to see the notification for e-voting. Select ‘View’ icon.
2. E-voting page will appear.
3. Refer the Resolution description and cast your vote by selecting your desired option ‘Favour / Against’ (If you
wish to view the entire Resolution details, click on the ‘View Resolution’ file link).
4. After selecting the desired option i.e. Favour/Against, click on ‘Submit’. A confirmation box will be displayed. If
you wish to confirm your vote, click on ‘Yes’, else to change your vote, click on ‘No’ and accordingly modify
your vote.
d. Process to be followed if shareholders have forgotten password
i. If Individual Shareholders holding securities in Physical mode, have forgotten the USER ID [Login ID] or Password or
both then the shareholder can use the “Forgot Password” option available on the e-Voting website of Link Intime: https://
instavote.linkintime.co.in
• Click on ‘Login’ under ‘SHARE HOLDER’ tab and further Click ‘forgot password?’
• Enter User ID, select Mode and Enter Image Verification (CAPTCHA) Code and Click on ‘Submit’.
 In case shareholders/ members is having valid email address, Password will be sent to his / her registered e-mail
address.
 Shareholders/ members can set the password of his/her choice by providing the information about the particulars of the
Security Question and Answer, PAN, DOB/DOI, Bank Account Number (last four digits) etc. as mentioned above.
 The password should contain minimum 8 characters, at least one special character (@!#$&*), at least one numeral, at
least one alphabet and at least one capital letter.
User ID for Shareholders holding shares in Physical Form (i.e. Share Certificate): Your User ID is Event No. + Folio
Number registered with the Company.
ii. If the Individual Shareholders holding securities in demat mode with NSDL/ CDSL have forgotten the password, they need
to follow the steps as below:
Shareholders who are unable to retrieve User ID/ Password are advised to use Forget User ID and Forget Password option
available at abovementioned depository/ depository participants’ website.
e. HELPDESK FOR SHAREHOLDERS
I. Helpdesk for Individual Shareholders holding securities in demat mode:
In case Individual shareholders/ members holding securities in demat mode have any technical issues related to login
through Depository i.e. NSDL/ CDSL, they may contact the respective helpdesk given below:
8
Login type Helpdesk details
Individual Shareholders holding Members facing any technical issue in login can contact NSDL helpdesk by sending a
securities in demat mode with NSDL request at [email protected] or call at toll free no.: 1800 1020 990 and 1800 22 44 30.
Individual Shareholders holding Members facing any technical issue in login can contact CDSL helpdesk by sending a request
securities in demat mode with CDSL at [email protected] or contact at 022- 23058738 or 022- 23058542-43.
ii. Helpdesk for Individual Shareholders holding securities in physical mode/ Institutional shareholders & evoting service Provider
is LINKINTIME.
In case shareholders/members holding securities in physical mode/Institutional shareholders have any queries regarding
e-voting or facing any technical issue in login may contact Link Intime “INSTAVOTE” helpdesk by sending a request at
[email protected] or contact on: - Tel: 022 – 4918 6000.
f. General Guidelines for shareholders:
I. Institutional shareholders (i.e. other than Individuals, HUF, NRI etc.) and Custodians are required to log on to the e-Voting
system of LIIPL: https://instavote.linkintime.co.in and register themselves as ‘Custodian / Mutual Fund / Corporate Body’.
They are also required to upload a scanned certified true copy of the board resolution /authority letter/power of attorney
etc. together with attested specimen signature of the duly authorised representative(s) in PDF format in the ‘Custodian /
Mutual Fund / Corporate Body’ login for the Scrutinizer to verify the same.
II. During the voting period, shareholders can login any number of times till they have voted on the resolution(s) for a
particular “Event”.
III. Shareholders holding multiple folios/demat account shall choose the voting process separately for each of the folios/demat
account.
IV. Any person, who acquires shares of the Company and become Member of the Company after dispatch of the Notice and
holding shares as on the cut-off date i.e. 23.09.2022, may follow the same instructions as mentioned above for remote
e-voting. The Voting rights of the members shall be in proportion to their shares in the paid up capital of the
Company as on the cut off date i.e. 23.09.2022. A person whose name is recorded in the Register of members or
in the Register of Beneficial owners maintained by the Depositories as on the cut off date only shall be entitled to
avail the facility of remote e-voting as well as voting at the said meeting. A person who is not a Member as on the
cut off date should treat this Notice for information purposes only.
V. It is strongly recommended not to share your password with any other person and take utmost care to keep your password
confidential.
VI. For shareholders/ members holding shares in physical form, the details can be used only for voting on the resolutions
contained in this Notice.
21. The Board of Directors has appointed Mr. Sushil Kumar Sikka, Practicing Company Secretary (Membership No. 4241 and C.P. No.
3582) proprietor of M/s S.K. Sikka & Associates, as the Scrutinizer to scrutinize the voting and remote e-voting process in a fair and
transparent manner. He has communicated his willingness to be appointed and will be available for same purpose.
The Scrutinizer shall immediately after the conclusion of voting at the AGM, first count the votes cast at the meeting, thereafter unblock
the votes cast through remote e-voting in the presence of at least two witnesses (who shall not be in the employment of the Company).
Thereafter, Scrutinizer shall give a consolidated report, specifying the total votes cast in favour or against, if any, within forty-eight
hours of conclusion of the meeting, which is within the time stipulated under the applicable laws, to the Chairman or any director or
the person authorized by him in writing who shall countersign the same.
The Chairman or any Director or the person authorized by him in writing shall declare the result of the voting forthwith. The results
declared along with the Scrutinizer’s Report shall be available on the Company’s website www.sswlindia.com and on the website of
the LIIPL immediately after the results is declared by the Chairman and shall also be communicated to the Stock Exchanges i.e. BSE
Limited (BSE) and The National Stock Exchange of India Limited (NSE) where the shares of the Company are listed.
Subject to the receipt of requisite number of votes, the resolutions shall be deemed to be passed on the date of AGM i.e.
30.09.2022.
22. All documents referred to in the accompanying Notice and the Explanatory Statement shall be open for inspection at the Registered
Office (i.e. Village Somalheri/ Lehli, P.O. Dappar, Tehsil Derabassi, Distt. Mohali, Punjab) and Head office (i.e. SCO 49-50, Sector
26, Madhya Marg, Chandigarh) of the Company during normal business hours (9.00 am to 5.00 pm) on all working days up to and
including the date of AGM of the Company.

M. No. A15397
9
EXPLANATORY STATEMENT PURSUANT TO SECTION 102 OF THE COMPANIES ACT, 2013 (“ACT”), SECRETARIAL STANDARDS
ON GENERAL MEETINGS (SS-2) AND REGULATION 36 OF THE SEBI (LISTING OBLIGATIONS AND DISCLOSURE REQUIREMENTS)
REGULATIONS, 2015 (“SEBI LISTING REGULATIONS”)
ITEM NO. 5
M/s AKR & Associates, Chartered Accountants (ICAI Firm Registration No. 021179N), were appointed as statutory auditors of the Company
at the 31st AGM of the Company held on September 28, 2017 for a period of 5 (five) years, until the conclusion of the 36th AGM of the
Company to be held in the year 2022.
As per the provisions of the Section 139 (2) of Companies Act, 2013 read with the Companies (Audit and Auditors) Rules, 2014, and other
applicable provisions, the Company can appoint or re-appoint an audit firm as statutory auditors for not more than two (2) terms of five
(5) consecutive years each. Accordingly, M/s AKR & Associates is eligible to be re-appointed as the statutory auditors of the Company for
second term of five (5) consecutive years.
Considering M/s AKR & Associates’ experience, expertise & performance as statutory auditors of the Company during their present tenure,
the Audit Committee of the Company, after due deliberations and discussions, recommended to the Board, the re-appointment of M/s AKR
& Associates as statutory auditors of the Company for a second term of 5 (five) consecutive years to hold office from the conclusion of this
36th AGM till the conclusion of the 41st AGM of the Company to be held in the year 2027.
Based on recommendations of the Audit Committee, the Board of Directors at its meeting held on 02.09.2022, have approved the re-
appointment of M/s AKR & Associates, as the statutory auditors of the Company for a second term of 5 (five) consecutive years i.e. from
the conclusion of this 36th AGM till the conclusion of 41st AGM of the Company to be held in the year 2027. The Board of Directors on the
recommendation of Audit Committee may alter and vary the terms and conditions of appointment, including remuneration, in such manner
and to such extent as may be mutually agreed with the statutory auditors. The re-appointment is subject to approval of the shareholders of
the Company.
As required under the SEBI Listing Regulations, M/s AKR & Associates holds a valid certificate issued by the Peer Review Board of ICAI.
M/s AKR & Associates have given their consent for their re-appointment as Statutory Auditors of the Company and have issued a certificate
confirming that their re-appointment, if made, will be within the limits prescribed under the provisions of Section 139 read with Section 141
of the Companies Act, 2013 (‘the Act’) and the rules made thereunder.
The Board recommends the Resolution set forth in Item No. 5 for the approval of the Members.
None of the Director (s) and Key Managerial Personnel of the Company and their respective relatives is concerned or interested, financially
or otherwise, in the resolution set out at Item No. 5 of the Notice.
ITEM NO. 6
The Board of Directors of the Company, on the recommendation of the Audit Committee, has approved the appointment of M/s. Aggarwal
Vimal & Associates, Cost Accountants having Firm Registration Number: 000350, as Cost Auditors to conduct the audit of the cost records
relating to Hot Rolling Mill (HRM division) of the Company for the financial year ending 31.03.2023 at a remuneration of Rs. 50,000/- (Rupees
Fifty Thousand Only) (plus applicable taxes and reimbursement of out of pocket expenses).
In accordance with the provisions of Section 148 of the Act read with the Companies (Audit and Auditors) Rules, 2014 (including any
statutory amendment (s) or modification(s) or re-enactment(s) thereof for the time being in force), the remuneration payable to the Cost
Auditors is required to be ratified by the Members of the Company.
Accordingly, consent of the members is sought for passing an Ordinary Resolution as set out in the Item No. 6 of the Notice for ratification of
the remuneration payable to the Cost Auditors for conducting the audit of the cost records of the Company for the financial year 2022-23.
None of the Director (s) and Key Managerial Personnel of the Company and their respective relatives is concerned or interested, financially
or otherwise, in the resolution set out at Item No. 6 of the Notice.
ITEM NO. 7 & 8
The Company’s equity shares are listed and being traded on the BSE Limited (BSE) and the National Stock Exchange of India Limited
(NSE). In order to provide enhanced liquidity to the Company’s shares in the stock market through widening the shareholder base and
with a view to encourage the participation of small investors by making equity shares of the Company affordable, the Board of Directors at
its meeting held on 19.07.2022 has approved to sub-divide each equity share of the Company having present face value of Rs. 5/- each
into 5 (Five) equity shares of face value of Re. 1/- each, subject to the approval of shareholders and all concerned Regulatory/Statutory
Authority(ies), as applicable. The record date for the aforesaid sub-division of equity shares will be fixed by the Board of Directors after the
approval of the shareholders is obtained.
The sub-division of equity shares would, inter alia, require appropriate adjustments with respect to the stock options of the Company under
its stock option schemes i.e. “Steel Strips Wheels Limited- Employee Stock Option Scheme, 2016” and “Steel Strips Wheels Limited-
Employee Stock Option Scheme, 2021” (hereinafter referred to as “ESOS 2016” and “ESOS 2021” respectively), such that the number of all
outstanding stock options (vested but not exercised and unvested stock options), the number of stock options available for future grant(s)
with effect from the record date and the exercise price thereof shall be proportionately adjusted.
10
The sub-division of equity shares proposed hereunder business Item no. 7 of this Notice shall also require consequential amendment to the
existing Clause V of the Memorandum of Association of the Company and hence, the Board of Directors recommends the resolutions set
out at Item no. 7 & 8 of the accompanying notice for the approval of the shareholders by way of Ordinary Resolutions.
The Memorandum of Association depicting the proposed alteration is available for inspection by the members at the Registered Office of the
Company during working hours except on holidays till the conclusion of this AGM.
None of the Director (s) and Key Managerial Personnel of the Company and their respective relatives are concerned or interested, financially
or otherwise, in the resolutions set out at Item No. 7 & 8 of the Notice.

M. No. A15397
11
Annexure I
DETAILS OF DIRECTORS SEEKING RE-APPOINTMENT AT THE ANNUAL GENERAL MEETING
Name of Director and DIN Sh. Dheeraj Garg Sh. Sanjay Garg
(DIN: 00034926) (DIN: 00030956)
Date of Birth & Age 50 years (11.05.1972) 53 years (09.09.1968)
Qualification B.S (Finance) CWA, Bachelors of Law
Nationality Indian Indian
Brief Resume/ Experience Sh. Dheeraj Garg has been associated with Sh. Sanjay Garg, a Cost and Works Accountant and
(including Expertise in Company for more than 25 years. He was first a Law Graduate, is a well-qualified and experienced
specific functional areas) appointed as an Executive Director on 29.04.1993 professional. He has held various Managerial/
and then elevated as the Managing Director of the Advisory positions in Steel Strips Group.
Company. He belongs to the promoter category
He possesses appropriate skills, experience and
of the company. His leadership and the valuable
knowledge in various functional areas mainly Legal,
guidance, has contributed immensely to the growth
Corporate Strategies, Business Management
of the company which is evident from the financial
and other disciplines related to the Company’s
results thereof. Over the years, he has been able to
business.
build a highly motivated and effective management
team, which has fully aligned and focused priorities.
He has vast experience in finance, Corporate
Strategy and Business Management.
Terms and Conditions The Shareholders of the Company in their AGM held As per the resolution passed by the Shareholders
of Appointment/ Re- on 30.09.2020 had approved the re - appointment of the company in their AGM held on 30.09.2020,
appointment of Sh. Dheeraj Garg as Managing Director of Sh. Sanjay Garg, was appointed as a Non-Executive
the Company for a period of three years w.e.f. Director of the company w.e.f. 24.08.2020 liable to
01.06.2020 liable to retire by rotation. Further, his retire by rotation.
remuneration was revised and approved by the
shareholders in their AGM held on 30.09.2021.
Remuneration last drawn Rs. 1452.46 lakhs. Paid sitting fees for attending Board Meetings
(including sitting fee if any) during FY 2021-22. For more details, please refer
For more details, please refer Corporate Governance
Corporate Governance Report section of the Annual
Report section of the Annual Report 2021-22.
Report 2021-22.
Remuneration proposed to As per existing terms and conditions. As per Nomination and Remuneration Policy of the
be paid Company.
Date of First Appointment on 29.04.1993 24.08.2020
the Board
Shareholding in the 9280456 equity shares as on 31.03.2022. 350 equity shares as on 31.03.2022.
Company
In addition to this, 550 shares (0.001%) are standing
in the name of his HUF.
Relationship with other Sh. Dheeraj Garg is related to Sh. Rajinder Kumar He is not related to any other director/ Key
Director/Key Managerial Garg, Chairman & Non-Executive Director of the Managerial Personnel of the Company.
Personnel Company.
Number of meetings of the Please refer Corporate Governance Report section Please refer Corporate Governance Report section
Board attended during the of the Annual Report 2021-22. of the Annual Report 2021-22.
financial year
Directorships held in other • Indian Acrylics Ltd. • SAB Industries Limited
companies • Steel Strips Infrastructures Limited
• Malwa Chemtex Udyog Ltd
• Indlon Chemicals Limited
• Munak International Pvt Ltd
• Chandigarh Aircraft Management Services
Private Limited
• Munak Financiers Private Limited
• SAB Udyog Limited
• S J Mercantile Private Limited
• Steel Strips Holdings Private Limited
• Munak Investments Pvt Ltd
• Indian Acrylics Investments Ltd
• Steel Strips Mercantile Private Limited
• S S Credits Pvt Ltd
• Malwa Holdings Pvt Ltd
• Sab Developers Private Limited
12
Memberships/ Indian Acrylics Ltd.: - 1. SAB Industries Limited: -
chairmanships of • Stakeholders Relationship Committee
committees of other • Audit Committee (Member) (Member)
companies • Finance Committee (Member)
• Stakeholders Relationship Committee
(Member) • Secretarial Committee (Chairman)
• Corporate Social Responsibility Committee • Allotment Committee (Member)
(Member)
• Finance Committee (Member) 2. SAB Udyog Limited
• Secretarial Committee (Chairman) • Audit Committee (Chairman)
• Risk Management Committee (Member)
3. Steel Strips Infrastructure Limited
• Finance Committee (Member)
• Secretarial Committee (Chairman)
Listed Entities from which Nil Sh. Sanjay Garg has not resigned as a director from
the director has resigned as any listed entity in the past 3 years. However, he
Director in past 3 years held the position of whole time director in a listed
entity i.e. Steel Strips Limited (SSL) which was
amalgamated into SAB Industries Limited w.e.f.
19.10.2021.
13
BOARD’S
To
The Members,
Your Directors take pleasure in presenting the 36th (thirty sixth) Annual Report on the business and operations of the Company together with
audited financial statements for the financial year ended March 31, 2022.
FINANCIAL HIGHLIGHTS
(Rs. in Millions)
S. No. Particulars 2021-22 2020-21
A) Revenue from Operations 35599.53 17494.15
B) Other Income 130.27 163.18
C) Total Income (A+B) 35729.80 17657.33
D) Total Expenditures (excl. Finance Cost, depreciation and amortization) 31071.71 15456.61
E) Profit before interest, depreciation and amortization 4658.09 2200.72
F) Interest & Financial Charges 854.21 839.31
G) Depreciation and amortization 768.70 723.11
H) Profit before tax and Exceptional Item 3035.18 638.30
I) Exceptional Item 0.00 0.01
J) Profit before tax 3035.18 638.29
K) Tax expense
Current tax 893.45 45.35
Deferred tax 84.35 100.44
Prior year tax adjustments 2.74 -
L) Profit after tax 2054.64 492.50
M) Other Comprehensive Income (Net of Tax) (25.73) 0.98
N) Total Comprehensive Income for the period (L+M) 2028.91 493.48
Financial Performance
The Financial Year (FY) 2021-22 remained a highly volatile and challenging year for the entire world economy as the world witnessed the
severe second wave of COVID-19 owing to widespread lockdowns across the globe induced by the deadly second wave followed by a third
wave though its intensity was not that grave and ended with rising geo-political tensions between Russia and Ukraine.
The Indian Automobile Industry also witnessed some volatility at the beginning of FY 2021-22 as the domestic economic growth was
temporarily dented in by the second wave of COVID-19. This combined with continuing supply chain disruptions, escalating geo-political
trade tensions, mounting oil and commodity prices and inflationary pressures and overall volatility that came as a storm which consequently
dragged the growth prospects of economy as whole. However, widening reach of vaccines, pent up demand and timely fiscal and monetary
policy measures helped the Indian economy to withstand the challenges and there was a strong bounce back in economic activity.
Despite the overall volatility, your company effectively managed to perform well during the year under review with improved capacity
utilization and recorded significant growth in sales volume.
Amidst this scenario, the total income for the year under review increased by 102.35% to Rs. 35729.80 million as compared to
Rs. 17657.33 million in FY 2020-21.
In terms of number of wheels, the Company has achieved sale of 17.89 million wheel rims during the FY 2021-22 against sale of
13.36 million wheel rims during the FY 2020-21, showing an increase of 33.91%.
The Earnings Before Interest, Depreciation and Tax (EBIDTA) increased by 111.66 % to Rs. 4658.09 million in FY 2021-22 from
Rs. 2200.72 million in FY 2020-21.
The Depreciation and other amortization have increased to Rs. 768.70 million in FY 2021-22 from Rs. 723.11 million in FY 2020-21.
Profit before tax during the year under review has increased to Rs. 3035.18 million from Rs. 638.29 million in FY 2020-21 recording an
increase of 375.51%. The profit after tax (before comprehensive income) have also increased to Rs. 2054.64 million from Rs. 492.50 million,
showing an increase of 317.19%.
transfer TO reserves
Your Company proposes to transfer an amount of Rs. 492.50 million to the General Reserve out of the amount available for appropriation.
DIVIDEND DISTRIBUTION POLICY
In terms of Regulation 43A of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015,
(“SEBI Listing Regulations”) the Board of Directors (Board) of the Company formulated and adopted the Dividend Distribution Policy. The same
is available on the Company’s website at http://sswlindia.com/wp-content/themes/sswl/assets/docs/Dividend-Distribution-Policy.pdf .
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DIVIDEND
In line with the Dividend Distribution Policy of the Company, the Board of Directors at its meeting held on 13.05.2022, has recommended a final
dividend of Rs. 3.75 per equity share (i.e. 75%) of face value of Rs. 5/- each {previous year Rs. 2.00 per equity share (i.e. 20%) of face value
of Rs. 10/- each} for the FY 2021-22. The dividend proposal is subject to the approval of shareholders at the ensuing Annual General Meeting
(AGM) of the Company. The total cash outflow on account of proposed dividend, if approved by the shareholders for the current year will amount
to Rs. 117.38 million (previous year Rs. 31.22 million), which represent 5.71% of the Profit After Tax earned during the year.
Pursuant to the Finance Act, 2020, dividend income is taxable in the hands of the shareholders effective from 01.04.2020 and the Company
is required to deduct tax at source from dividend paid to the shareholders at prescribed rates as per the Income Tax Act, 1961.
The Register of Members and Share Transfer Books of the Company will remain closed from 24.09.2022 to 30.09.2022 (both days inclusive)
for the purpose of payment of the dividend and AGM for the financial year ended March 31, 2022.
SHARE CAPITAL
During the year under review, the Board of Directors at its meeting held on 03.09.2021 approved sub-division of equity shares of the
Company and the same was approved by the shareholders of the Company at their 35th AGM held on 30.09.2021 pursuant to which 1 (one)
equity share of face value of Rs. 10/- each of the Company was sub-divided into 2 (two) equity shares of face value of Rs. 5/- each with effect
from 22.11.2021 (record date for sub-division).
The Issued and Paid-up Equity Share Capital of the Company is Rs. 15,60,94,700/- (divided into 31218940 equity shares of Rs. 5/- each)
as on 31.03.2022.
Besides above, the Company has allotted 83700 equity shares of Rs. 5/- each on 10.06.2022 upon exercise of options by the employees
of the Company under “Steel Strips Wheels Limited-Employee Stock Option Scheme, 2016” (“ESOS 2016”) at an exercise price of
Rs. 100/- each. Consequent to the allotment of aforesaid shares, the Issued and Paid-up Equity Share Capital of the Company increased
from Rs. 15,60,94,700/- (divided into 31218940 equity shares of Rs. 5/- each) to Rs. 15,65,13,200/- (divided into 31302640 equity shares of
Rs. 5/- each) as on the date of this report.
Further, during the year under review, the Company has not issued shares with differential voting rights and sweat equity shares.
ALTERATION OF MEMORANDUM OF ASSOCIATION (MOA) AND ADOPTION OF NEW SET OF ARTICLES OF ASSOCIATION (AOA)
During the year under review, the Capital clause of the Memorandum of Association was altered in order to take effect of the sub-division
on the equity share capital of the company. The same was duly approved by the Board of Directors and shareholders at their respective
meetings held on 03.09.2021 and 30.09.2021.
Further, during the year under review, the company has also adopted a new set of Articles of Association (“AOA”) (in substitution of the
existing Articles of Association) so as to make it consistent and align it with the provisions of the Companies Act, 2013. The same was duly
approved by the Board of Directors and shareholders at their respective meetings held on 06.09.2021 and 30.09.2021.
EMPLOYEE STOCK OPTION SCHEME
During the year under review, there was one on-going Employee Stock Option Scheme titled as “Steel Strips Wheels Limited – Employee
Stock Option Scheme, 2016” (“ESOS 2016”) and a new scheme titled as “Steel Strips Wheels Limited – Employee Stock Option Scheme,
2021” (“ESOS 2021”) was introduced. However, no options were granted under the said schemes during the year under review.
Pursuant to the aforesaid sub-division of equity shares of the Company and with effect from 22.11.2021 (record date for sub-division),
appropriate adjustments were made to the number of all outstanding stock options (vested but not exercised and unvested stock options),
the number of stock options available for future grant(s) and the exercise price thereof, in such a manner that each such stock option shall
stand double and the respective exercise price for each such stock option shall be half of the exercise price fixed at the time of grant of such
options or as specified in the scheme.
Further, there were no material changes in the ongoing employee stock option schemes of the Company i.e. “ESOS 2016” and “ESOS 2021”
and the said schemes are in compliance with SEBI (Share Based Employee Benefits and Sweat Equity) Regulations, 2021 {SEBI (SBEB &
SE Regulations, 2021} including any amendment (s) thereof. The necessary disclosure as stipulated under Regulation 14 read with Part F of
Schedule I of the SEBI (SBEB & SE) Regulations, 2021 with regard to “ESOS 2016” and “ESOS 2021” have been uploaded on the website
of the Company under the web-link: https://sswlindia.com/investors/sswl-disclosure-regarding-esos/
The Company has received a certificate from the Secretarial Auditors of the Company that the aforesaid schemes i.e. “ESOS 2016” and
“ESOS 2021” have been implemented in accordance with the SEBI (SBEB & SE) Regulations, 2021 and in accordance with the resolution
passed by the members in their AGM(s) held on 30.09.2016 and 30.09.2021, respectively. The certificate would be placed at the ensuing
AGM for inspection by members.
FURTHER SUB-DIVISION OF EQUITY SHARES OF THE COMPANY
On 19.07.2022, the Board of Directors of the Company, in order to enhance the liquidity in the capital market, to widen shareholder base and
to make the shares more affordable to small investors, considered and approved the proposal for sub-division of its existing 1 (one) equity
share of the Company having face value of Rs. 5/- each into 5 (Five) equity shares of the Company having face value of Re. 1/- each, subject
to the approval of the Shareholders of the Company in the ensuing AGM and other necessary approvals.
Further, there will be consequential amendments in the Capital Clause of the Memorandum of Association (MOA) of the Company subject
to approval of the Shareholders of the Company at the ensuing AGM. The said proposal forms part of the Notice of this 36th AGM for your
approval.
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The proposed sub-division of equity shares would also require appropriate adjustments with respect to the stock options of the Company
under its employee stock option schemes “ESOS 2016” and “ESOS 2021”, such that the number of all outstanding stock options (vested but
not exercised and unvested stock options), the number of stock options available for future grant(s) with effect from the record date and the
exercise price thereof shall be adjusted appropriately in line with the face value of shares after sub-division, if approved by the members of
the Company in the ensuing AGM of the Company.
BIDDING UNDER INSOLVENCY AND BANKRUPTCY CODE, 2016
Your Company bid for acquisition of AMW Autocomponent Limited (AACL), a company engaged in manufacturing of Steel Wheel Rims
catering to Passenger Vehicles/ Truck and Tractor Segment, which was undergoing Corporate Insolvency Resolution Process (CIRP). The
Company under consideration owns a state of art wheel rims plant with capability to address domestic as well export requirements and
completely supplements the existing steel wheel business of your Company. This acquisition will not only provide your Company with a ready
operating capacity but will also save on time and efforts required to put up a green field project.
On September 21, 2021, your Company was declared as the successful resolution applicant by the Committee of Creditors of AACL under
the CIRP process of the Insolvency and Bankruptcy Code, 2016 and received a letter of Intent from the Resolution Professional of AACL.
The Company has unconditionally accepted the terms of the letter of intent and the closing of the transaction shall be subject to obtaining
necessary regulatory approvals, including from the National Company Law Tribunal.
NATURE OF BUSINESS
During the year under review, there has been no change in the nature of business of the Company.
CORPORATE GOVERNANCE
The Company is firmly committed to the principles of good corporate governance and believes that statutory compliances and transparency
are necessary to enhance the shareholder value. A separate section on Corporate Governance and a certificate from the Company’s
Statutory Auditors, confirming compliance with the conditions of Corporate Governance as stipulated under SEBI Listing Regulations is
included and forms an integral part of this Annual Report.
Management Discussion and Analysis
Management Discussion and Analysis Report for the year under review, as stipulated under Regulation 34 of the SEBI Listing Regulations
is presented in a separate section forming part of this Annual Report.
HEALTH, SAFETY AND ENVIRONMENT PROTECTION
The Company has complied with all the applicable Health & Safety standards, Environment Laws and Labour Laws and has been taking all
necessary measures to protect the environment and provide workers a safe working environment. The Company is committed for continual
improvement in Health & Safety as well as Environmental protection by involving all the employees.
Significant emphasis was also laid towards raising awareness on health and wellness of employees through annual medical check-ups and
awareness sessions and webinar on ‘Health & Well-Being’.
Employees have been encouraged to practice safety in all their activities in and out of Company premises. Continuous safety training is
conducted at all levels and special emphasis is given to implementation of safety work standards.
Further, due to the ongoing pandemic COVID-19, several measures for the safety of the employees like sanitization of the office premises,
factory premises, body temperature checks, social distancing, enhanced safety and hygiene norms at offices, COVID vaccination drive for
employees at all plant locations, etc. have been undertaken by your Company. In order to ensure the smooth working of the Company during
the lockdown period and also to ensure the safety of its employees, the Company has given the facility to work from home.
HUMAN RESOURCES DEVELOPMENT
The Company has continuously adopted structures that help in attracting best external talent and promote internal talent to take higher
roles and responsibilities. The Company’s people centric focus is providing an open work environment fostering continuous improvement
and development among the employees of the Company. The Company provides a holistic environment where employees get opportunities
to realize their potential. The Company’s performance driven culture helps and motivates employees to excel in their respective areas
and progress within the organization. The Company has a structured appraisal system based on key result areas (KRAs) for employees
belonging to Manager and above category.
DISCLOSURE AS PER SEXUAL HARASSMENT OF WOMEN AT WORKPLACE (PREVENTION, PROHIBITION AND
REDRESSAL) ACT, 2013
The Company has zero tolerance towards sexual harassment at workplace and has adopted a policy on prevention, prohibition and redressal
of sexual harassment at workplace in line with the provisions of the Sexual Harassment of Women at Workplace (Prevention, Prohibition
and Redressal) Act, 2013 and the Rules made thereunder. Internal Complaints Committee (ICC) has been constituted to redress complaints
received regarding sexual harassment. The policy is gender neutral and all employees (permanent, contractual, temporary trainees) are
covered under this policy.
The Company has complied with provisions relating to the constitution of Internal Complaints Committee under the Sexual Harassment of
Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.
During the year under review, the Company has not received any complaint on sexual harassment.
DETAILS OF DIRECTORS AND KEY MANAGERIAL PERSONNEL
The Board of Directors consists of optimum number of Executive and Non- Executive Directors including Independent Directors who have
wide and varied experience in the field of business, finance, education, industry, commerce and administration. The Independent Directors
provide their declarations confirming that they meet the criteria of independence as prescribed under the Companies Act, 2013 (Act) and
SEBI Listing Regulations.
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Retirement by Rotation
Pursuant to the provisions of Section 152 of the Companies Act, 2013, and Rules framed thereunder (including any amendment thereof),
Sh. Dheeraj Garg, Managing Director and Sh. Sanjay Garg, Non-executive Director of the Company shall retire by rotation at the ensuing
AGM and being eligible, offer themselves for re-appointment. The Board recommends their re- appointment for your approval.
Appointment/ Re-appointment of Director
Pursuant to the provisions of the Companies Act, 2013, SEBI Listing Regulations and upon recommendation of Nomination and Remuneration
Committee, the Board of Directors of the Company approved the appointment of Sh. Siddharth Bansal (DIN: 02909820) as an additional
director (Non-Executive and Independent Director) of the Company to hold office w.e.f. 09.11.2020 till the conclusion of the 35th AGM of
the Company. Further, on the recommendation of the Nomination and Remuneration Committee, the Board of directors of the Company
in its meeting held on 03.09.2021, had approved to regularize the appointment of Sh. Siddharth Bansal, as a Non-Executive Independent
Director of the Company to hold office for a period commencing from 09.11.2020 to 30.09.2025, not liable to retire by rotation, subject to the
approval of members of the Company in the 35th AGM. Subsequently, the said appointment was approved by the members in 35th AGM of
the Company held on 30.09.2021.
Further, during the year under review, the shareholders had approved the re-appointment and continuation of directorship of Sh. Rajinder
Kumar Garg, Chairman and Non-Executive Director, by passing special resolution in their AGM held on 30.09.2021 as required under the
SEBI Listing Regulations.
Key Managerial Personnel
During the year under review, there were no changes to the Key Managerial Personnel of the Company.
Accordingly, pursuant to the provisions of Section 203 of the Companies Act, 2013, the Key Managerial Personnel (KMP) of the Company as
on 31.03.2022 are Sh. Dheeraj Garg, Managing Director, Sh. Andra Veetil Unnikrishnan, Deputy Managing Director, Sh. Manohar Lal Jain,
Executive Director, Sh. Naveen Sorot, Chief Financial Officer (CFO) and Sh. Shaman Jindal, Company Secretary of the Company.
DETAILS OF COMPANIES WHICH HAVE BECOME OR ceased TO BE ITS SUBSIDIARIES, JOINT VENTURES OR ASSOCIATE
COMPANIES DURING THE YEAR
The Company is not having any Subsidiary Company, Joint Venture Company or Associate Company.
DEPOSITS FROM PUBLIC
The Company has not accepted any deposits from public within the meaning of Section 73 and 74 of the Companies Act, 2013 and Rules
framed thereunder (including any amendments thereof) during the financial year 2021-22 and, as such, no amount on account of principal
or interest on deposit from public was outstanding as on the date of this report.
SIGNIFICANT AND MATERIAL ORDERS PASSED BY THE REGULATORS OR COURTS OR TRIBUNALS IMPACTING THE GOING
CONCERN STATUS AND COMPANY’S OPERATIONS IN FUTURE
There were no significant and material orders passed by the Regulators or Courts or Tribunals impacting the going concern status and
Company’s operations in future.
CREDIT RATING
The details pertaining to credit ratings obtained by the Company during the financial year are provided in the Corporate Governance Report,
which forms part of this Annual Report.
Internal financial controlS
The Board has adopted the policies and procedures for ensuring the orderly and efficient conduct of its business, including adherence to the
Company’s policies, the safeguarding of its assets, the prevention and detection of frauds and errors, the accuracy and completeness of the
accounting records, and the timely preparation of reliable financial information(s).
INTERNAL CONTROL SYSTEMS
The Company has adequate internal control procedures commensurate with its size and nature of business. These internal policies ensure
efficient use and protection of the assets and resources, compliances with policies and statutes and ensure reliability as well as promptness
of financial and operational reports.
To enhance effective internal control system, the Company has laid down following measures:
• The Company’s Books of accounts are maintained in SAP and transactions are executed through SAP (ERP) setups to ensure
correctness/effectiveness of all transactions integrity and reliable reporting.
• Adherence to accounting policies.
• The Company has in place a well-defined Whistle Blower Policy/Vigil Mechanism.
• Compliance of secretarial functions is ensured by way of secretarial audit.
• Internal Audit is being done for providing assistance in improvising financial control framework.
• The Company has adequate risk management policy.
• Code of Conduct and other policies.
• Physical verification of inventory/stock (stock audit).
Audit committee and other committes of the board
The details pertaining to composition of Audit Committee and other committees of the Board constituted by the Board of Directors of the
Company as per the provisions of the Companies Act, 2013 and SEBI Listing Regulations are provided in the Corporate Governance Report
which forms part of this Annual Report.
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VIGIL MECHANISM / WHIStle BLOWER POLICY
In compliance with the requirements under Section 177(9) & (10) of the Companies Act, 2013 and in accordance with Regulation 22 of SEBI
Listing Regulations, the Company has adopted a policy named “Vigil Mechanism and Whistle Blower Policy”. The further details pertaining
to Vigil Mechanism and Whistle Blower Policy of the Company is available in the Corporate Governance Report, which forms part of this
Report. This Policy is also available on the Company’s website at http://sswlindia.com/wp-content/themes/sswl/assets/docs/whistleblower.
pdf.
NUMBER OF Meetings of the board
During the year, six (6) Board Meetings were convened and held, details of which are provided in the Corporate Governance Report, which
forms part of this Annual Report. The intervening gap between the meetings was within the period prescribed under the Companies Act,
2013 and SEBI Listing Regulations i.e. interval between two meetings did not exceed 120 days. The Company has complied with Secretarial
Standards on the meeting of Board of Directors.
DIRECTORS’ RESPONSIBILITY STATEMENT
Pursuant to the requirement of Section 134 (5) of the Companies Act, 2013 and based on the representations, information and explanations
received from the management, and after due enquiry, the Directors of the Company hereby confirm that:
• in the preparation of the annual accounts for the financial year 2021-22, the applicable accounting standards have been followed and
there are no material departures;
• they have selected such accounting policies and applied them consistently and made judgements and estimates that are reasonable
and prudent so as to give a true and fair view of the state of affairs of the Company at the end of the financial year and of the profit of
the Company for the financial year 2021-22;
• they 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;
• they have prepared the annual accounts on a going concern basis;
• they have laid down internal financial controls to be followed by the Company and that such internal financial controls are adequate
and operating effectively; and
• they have devised proper systems to ensure compliance with the provisions of all applicable laws and that such systems were
adequate and operating effectively.
DECLARATION BY INDEPENDENT DIRECTORS
All Independent Directors of the Company have submitted their declaration in accordance with Section 149(7) of the Companies Act,
2013 and Regulation 25(8) of SEBI Listing Regulations that they meet the criteria of Independence as provided in Section 149(6) of the
Companies Act, 2013 and Regulation 16(1)(b) of SEBI Listing Regulations and that they are independent of the management.
The Board is of the opinion that during the financial year 2021-22, there has been no change in the circumstances which may affect their
status as Independent Directors of the Company and Board is satisfied that all the Independent Directors of the Company hold highest
standards of integrity and possess requisite expertise and experience (including proficiency in terms of Section 150(1) of the Companies
Act, 2013 and applicable rules thereunder) required to fulfill their duties as Independent Directors.
In terms of Section 150 of the Companies Act, 2013 read with Rule 6 of the Companies (Appointment and Qualification of Directors) Rules,
2014, as amended, all the Independent Directors of the Company have confirmed that they have registered themselves with the databank
maintained by the Indian Institute of Corporate Affairs, Manesar (“IICA”). The Independent Directors are also required to undertake online
proficiency self-assessment test conducted by the IICA within a period of 2 (two) years from the date of inclusion of their names in the data
bank, unless they meet the criteria specified for exemption.
Sh. Virander Kumar Arya, Smt. Deva Bharathi Reddy and Sh. Siddharth Bansal have passed the said online proficiency self-assessment
test and rest of the Independent Directors are exempt from the requirement to undertake the said test.
POLICY ON DIRECTORS’ APPOINTMENT AND REMUNERATION
The Company’s policy on Directors’ appointment and remuneration including criteria for determining qualifications, positive attributes,
independence of a director and other matters provided under Section 178(3) of the Companies Act, 2013 is available on the website of the
Company under the link http://sswlindia.com/wp-content/themes/sswl/assets/docs/nomination.pdf. The salient features of the policy are set
out in the Corporate Governance Report which forms the part of this Annual Report.
DETAILS IN RESPECT OF FRAUDS REPORTED BY AUDITORS OTHER THAN THOSE WHICH ARE REPORTABLE TO CENTRAL
GOVERNMENT
During the year under review, the statutory auditors, the secretarial auditors and cost auditors of the Company have not reported any offence
involving fraud which is being or has been committed against the Company by its officers or employees to the Audit Committee or to the
Board of Directors or to the Central Government under section 143(12) of the Companies Act, 2013 and Rules framed thereunder.
STATUTORY AUDITORS AND THEIR REPORT
Members of the Company at their 31st AGM held on 28.09.2017, approved the appointment of M/s AKR & Associates, Chartered
Accountants (ICAI Firm Registration Number 021179N), as the statutory auditors of the Company for a period of five consecutive years
commencing from the conclusion of the 31st AGM held on 28.09.2017 until the conclusion of 36th AGM of the Company to be held in the
year 2022.
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In terms of the provisions of the Companies Act, 2013, an audit firm acting as the statutory auditor of a company is eligible to be appointed as
statutory auditors for two terms of five years each. The first term of M/s AKR & Associates as statutory auditors of the Company expires at the
conclusion of the 36th AGM of the Company. Considering M/s AKR & Associates’ experience, expertise & performance as statutory auditors
of the Company during their present tenure, the Audit Committee of the Company, after due deliberations and discussions, recommended
to the Board, the re-appointment of M/s AKR & Associates, Chartered Accountants (ICAI Firm Registration Number 021179N) as statutory
auditors of the Company to hold office for a second term of 5 (five) consecutive years from the conclusion of the 36th AGM till the conclusion
of the 41st AGM of the Company to be held in the year 2027.
Based on recommendations of the Audit Committee, the Board of Directors at its meeting held on 02.09.2022 has approved the re-
appointment of M/s AKR & Associates, as the statutory auditors of the Company for a second term of 5 (five) consecutive years i.e. from the
conclusion of the 36th AGM till the conclusion of 41st AGM of the Company to be held in the year 2027, at such remuneration plus applicable
taxes, out of pocket expenses, travelling expenses, etc; as may be mutually agreed between the Board of Directors of the Company and the
Auditors. The said re-appointment is subject to approval of the shareholders of the Company.
As required under the SEBI Listing Regulations, M/s AKR & Associates holds a valid certificate issued by the Peer Review Board of ICAI.
M/s AKR & Associates have given their consent for their re-appointment as Statutory Auditors of the Company and have issued a certificate
confirming that their re-appointment, if made, will be within the limits prescribed under the provisions of section 139 read with section 141 of
the Companies Act, 2013 (‘the Act’) and the rules made thereunder.
The above proposal forms part of the Notice of this 36th AGM for your approval.
Auditors’ Report is self-explanatory and does not contains any qualification, reservations or adverse remarks or disclaimers in their report for
the financial year ended 31.03.2022, and therefore, needs no comments and forms part of this Annual Report. The board of directors places
on record its sincere appreciation for the valuable services rendered by M/s AKR & Associates.
SECRETARIAL AUDITOR
Pursuant to the provisions of Section 204 of the Companies Act, 2013 and Companies (Appointment and Remuneration of Managerial
Personnel) Rules, 2014, the Company has appointed Sh. Sushil Kumar Sikka, a practicing Company Secretary (Membership No. 4241 and
CP No. 3582), proprietor of M/s S. K. Sikka & Associates, to undertake the Secretarial Audit of the Company. The Secretarial Audit Report
for financial year 2021-22 is annexed herewith the Board’s Report as an Annexure-I. There were no qualifications, reservations or adverse
remarks in the Secretarial Audit Report of the Company.
ANNUAL SECRETARIAL COMPLIANCE REPORT
The Company has undertaken an audit for the financial year 2021-22 pursuant to SEBI Circular No. CIR/CFD/CMD/I/27/2019 dated
08.02.2019 for all applicable compliances as per the SEBI Listing Regulations and Circular/ Guidelines issued thereunder. The Annual
Secretarial Compliance Report has been submitted to the Stock Exchanges within 60 days of the end of the financial year 2021-22 and is
also annexed herewith the Board’s Report as an Annexure-II.
SECRETARIAL STANDARDS
During the year under review, the Company has complied with the provisions of the applicable Secretarial Standards issued by the Institute
of Companies Secretaries of India. The Company has devised proper systems to ensure compliance with the provisions of all applicable
Secretarial Standards issued by the Institute of Company Secretaries of India and such systems are adequate and operating effectively.
MAINTENANCE OF COST RECORDS AND AUDIT THEREOF
In terms of Section 148 of the Companies Act, 2013 read with relevant rules made thereunder, the Company is required to maintain cost
records only for its HRM division (i.e. Hot Rolling Mills) and have the audit of its cost records conducted by a Cost Accountant. Accordingly,
cost records have been prepared and maintained by the Company as required under Section 148(1) of the Act for the said division. The
Board had appointed M/s Aggarwal Vimal & Associates, Cost Accountants having Firm Registration No: 000350 as cost auditors to conduct
the audit of the cost records relating to HRM Division of the Company for the financial year ending 31.03.2022.
The Cost Auditor has forwarded the Cost Audit Report for the financial year 2021-22 to the Board of Directors of the Company on 02.09.2022
and the said audit report shall be filed with Ministry of Corporate Affairs within the stipulated time limit as prescribed under the Companies
Act, 2013 and relevant rules frame thereunder.
The Board of Directors on the recommendation of the Audit Committee, has appointed M/s Aggarwal Vimal & Associates, Cost Accountants
having Firm Registration No: 000350 as cost auditors to conduct the audit of the cost records relating to HRM Division of the Company for
the financial year ending 31.03.2023. The remuneration has been approved by the Board of directors based on recommendation of the Audit
Committee. The requisite resolution for ratification of remuneration of Cost Auditors is subject to approval of Members of the Company at the
ensuing AGM. The Cost Auditors have certified that their appointment is within the limits of Section 141(3)(g) of the Act and that they are not
disqualified from appointment within the meaning of the said Act.
PARTICULARS OF LOANS, GUARANTEES Or INVESTMENTS
There have been no loans, guarantees and investments made by the Company under Section 186 of the Companies Act, 2013 and Rules
framed thereunder (including any amendments thereof) and Schedule V of the SEBI Listing Regulations during the financial year 2021 - 22.
THE DETAILS OF APPLICATION MADE OR ANY PROCEEDING PENDING UNDER THE INSOLVENCY AND BANKRUPTCY
CODE, 2016 (31 OF 2016) DURING THE FINANCIAL YEAR 2021-22
There is no application made or any proceeding pending under the Insolvency and Bankruptcy Code, 2016 (31 of 2016) during the financial
year 2021-22.
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THE 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 DURING THE FINANCIAL YEAR 2021-22
Not applicable during the financial year under review.
PARTICULARS OF CONTRACTS OR ARRANGEMENT WITH RELATED PARTIES
All contracts / arrangements / transactions entered into by the Company during the financial year with related parties were in the ordinary
course of business and on an arm’s length basis. There were no materially significant related party transactions made by the Company
with Promoters, Directors and Key Managerial Personnel which may have a potential conflict with the interest of the Company at large. The
related party transactions undertaken by the Company during the year under review were in compliance with the provisions set out in the
Companies Act, 2013 read with the rules issued thereunder and Regulation 23 of the SEBI Listing Regulations. Since all the related party
transactions that were entered into during the financial year were on an arm’s length basis and were in the ordinary course of business, no
details are required to be provided in Form AOC-2 prescribed under clause (h) of sub-section (3) of section 134 of the Act and Rule 8(2) of
the Companies (Accounts) Rules, 2014.
All related party transactions were placed before the Audit Committee for their prior approval in accordance with the requirements of the
applicable provisions of the Act and SEBI Listing Regulations. The Audit Committee, during the financial year 2021-22, has approved related
party transactions along with granting omnibus approval in line with the policy of the Company on materiality of Related Party Transactions
and dealing with related party transactions and the applicable provisions of the Act read with the Rules issued thereunder and the SEBI
Listing Regulations (including any statutory modification (s) or re-enactment (s) thereof for the time being in force). The transactions entered
into pursuant to such approval were placed periodically before the Audit Committee.
The policy on materiality of related party transactions and dealing with related party transactions as approved and adopted by the Board is
uploaded on the website of the Company under the link http://sswlindia.com/wp-content/themes/sswl/assets/docs/relatedpartytransaction.pdf.
Disclosure as required under (IND AS 24) has been made in Note 41 of the Notes to the financial statements.
None of the Directors has any pecuniary relationships or transactions vis-à-vis the Company except remuneration and sitting fees.
Material Changes and commitment, AFFECTING THE FINANCIAL POSITION OF THE COMPANY WHICH HAVE
OCCURRED BETWEEN THE END OF FINANCIAL YEAR 2021-22 AND THE date of THIS REPORT
No material changes and commitment, affecting the financial position of the Company has occurred between the end of the financial year
2021-22 of the Company and the date of this report.
THE CONSERVATION OF ENERGY, TECHNOLOGY ABSORPTION, FOREIGN EXCHANGE EARNINGS AND OUTGO
A statement giving details of conservation of energy/technology absorption and foreign exchange earnings and outgo in terms of Section
134(3)(m) of the Companies Act, 2013 read with Rule 8 (3) of the Companies (Accounts) Rules, 2014, forms part of this report and is
annexed herewith as Annexure A.
Business Risk Management
Pursuant to the requirement of Regulation 21 of SEBI Listing Regulations, your Company has constituted a Risk Management Committee to
frame, implement and monitor the risk management plan for the Company. The Committee is responsible for reviewing the risk management
plan and ensuring its effectiveness.
The Risk Management Committee of the Company has been entrusted by the Board with the responsibility of reviewing the risk management
process in the Company and ensuring that the risks are brought within acceptable limits. The details of the Committee and its terms of
reference are set up in the Corporate Governance Report forming part of this Report.
Major risks identified by the businesses and functions are systematically addressed through mitigating actions on a continuing basis.
Your Company has developed and implemented a Risk Management Policy which is approved by the Board. The Risk Management Policy,
inter alia, includes identification of risks, including cyber security and related risks which in the opinion of the Board may threaten the
existence of the Company and its mitigation plans which have been covered in the Management Discussion and Analysis, which forms part
of this Report.
CORPORATE SOCIAL RESPONSIBILITY INITIATIVES
In compliance to Section 135 and in consonance with Schedule VII of the Companies Act, 2013, and Rules framed thereunder (including
any amendment(s) thereof), the Company has constituted a Corporate Social Responsibility Committee and also framed a Corporate Social
Responsibility Policy and the same is uploaded on the website of the Company under the link https://sswlindia.com/wp-content/themes/sswl/
assets/docs/csr-policy.pdf.
The Annual Report on CSR activities in terms of Section 135 of the Act and the Rules framed thereunder, including a brief outline of the
Company’s CSR Policy, is annexed to this Report as Annexure B.
BOARD EVALUATION
In compliance with the provisions of the Companies Act, 2013, the SEBI Listing Regulations and Guidance note on Board evaluation issued
by SEBI, the Nomination and Remuneration Committee of the Board of Directors of the Company has carried out a formal annual evaluation
of the Board, its committees and individual directors. Further, the Board of Directors have also carried out the evaluation of the Board as a
whole, its committees, Chairman of the Board and all the Individual and Independent Directors on the Board.
20
The performance evaluation of the Board and its committees was made after seeking inputs from all the directors of the Company on the
basis of effectiveness of board processes, information and functioning, degree of fulfillment of key responsibilities towards stakeholders,
governance issues, effectiveness of control system in identifying material risks and reporting of material violations of policies and law,
Board/Committees structure, composition and role clarity, experience and competencies, establishment and delineation of responsibilities to
committees, frequency of meetings, circulation of agenda of the meetings, recording of minutes, adherence to law, Board/Committee culture
and dynamics, quality of relationship between Board members and the Management, efficacy of communication with external stakeholders,
etc.
The Board and the Nomination and Remuneration Committee (NRC) of the Company evaluated the performance of individual directors
(including independent directors) based on criteria such as qualifications, experience, knowledge and competency, fulfillment of functions
and integrity including adherence to Code of Conduct and Code of Independent Directors of the Company, safeguarding of the Confidential
information and of interest of Whistle Blowers under Vigil Mechanism, compliance with policies and disclosures of interest and fulfillment
of other obligations imposed by the law, contribution and initiative, availability, attendance, participation and ability to function as a team,
commitment, independence, independent views and judgement and guidance/support to management outside board, etc.
A separate meeting of the Independent Directors (“Annual ID meeting”) was convened on 21.03.2022, which reviewed the performance
of the Board (as a whole), the non-independent directors and the Chairman and the quality, quantity and timeliness of flow of information
between the Company, Management and the Board, that is necessary for the Board to effectively and reasonably perform their duties. Post
the Annual ID meeting, the collective feedback of each of the Independent Directors was discussed by the Chairman of the Nomination and
Remuneration Committee with the Board’s Chairman covering performance of the Board as a whole; performance of the Non-Independent
Directors and performance of the Board’s Chairman.
FAMILIARIZATION PROGRAMME FOR INDEPENDENT DIRECTORS
The Company has practice of conducting familiarization program of the Independent Directors as detailed in the Corporate Governance
Report which forms part of this Report.
ANNUAL RETURN
In accordance with Section 92(3) & 134(3)(a) of the Companies Act, 2013, the Annual Return of the Company for the financial year 2021-22
in form MGT-7 is available on the website of the Company at https://sswlindia.com/investors/annual-return-and-extract-of-annual-return/
PARTICULARS OF REMUNERATION OF DIRCTORS/KMP’s/EMPLOYEES
The information required under Section 197(12) of the Companies Act, 2013 read with Rule 5(1) of the Companies (Appointment and
Remuneration of Managerial Personnel) Rules, 2014 is annexed as Annexure C to this report. The statement containing particulars of
employees as required under Section 197(12) of the Act read with Rule 5(2) and 5(3) of the Companies (Appointment and Remuneration of
Managerial Personnel) Rules, 2014, is provided in a separate annexure forming part of this report. Further, the report and the accounts are
being sent to the members excluding the aforesaid annexure. In terms of Section 136(1) of the Act, the said annexure is open for inspection
at the Registered Office of the Company and has been uploaded on the website of the Company at www.sswlindia.com. Any shareholder
interested in obtaining a copy of the same may write to the Company Secretary.
Business Responsibility REPORT (“BRR”)
In compliance with Regulation 34 of the SEBI (Listing Obligations and Disclosure Requirements), 2015, the Business Responsibility Report
for the year ended 31.03.2022, describing the initiatives taken by the Company from an environmental, social and governance perspective,
forms part of this Annual Report as Annexure-D.
INSURANCE
All properties and insurable interests of your Company including building and plant & machinery are adequately insured.
INDUSTRIAL RELATIONS WITH THE PERSONNEL OF THE COMPANY
The industrial relations scenario continued to be largely positive across all the manufacturing locations and the Company has continued to
maintain cordial and harmonious relations with its employees at all levels. As a result of it, the Company is thriving to achieve growth and
greater heights in the times to come.
ACKNOWLEDGEMENT
The Board of Directors wish to place on record their appreciation for the continued co-operation, the Company received from various
departments of the Central and State Government, Bankers, Financial Institutions, Dealers and Suppliers. The Board also wishes to place
on record its gratitude to the valued customers, members and investing public for their continued support and confidence reposed in the
Company. It also acknowledges and appreciates the commitment, dedication and contribution made by the employees at all levels towards
growth of the Company in all fields.
For and on behalf of the Board
Date: 02.09.2022 (Rajinder Kumar Garg)

Place: Chandigarh Chairman
DIN: 00034827
21
ANNEXURE-A
Particulars of Energy Conservation, Technology Absorption and Foreign Exchange Earnings and Outgo required under Section
134 of the Companies Act, 2013 read with the Companies (Accounts) Rules, 2014
A. Conservation of Energy
(i) Steps taken or impact on conservation of energy
As an ongoing strategy to adopt Environmental, Social & Governance (ESG) goals as central theme for your company,
the Company has decided to move aggressively towards adoption of Natural Resources saving across all our plants. The
company has taken targets to conserve a minimum 20% of water consumption by improving recyclability of water. Utilizing
efficient water usage will help in achieving the target of 20% reduction. The company has appointed an external agency
approved by TUV for assessing the ESG impact being created by the Company and how to counter its impact by productive
strategy to reduce carbon emission. The Company will assess the study and will take targets to reduce carbon foot prints by
a minimum 10% in FY 2022-23.
Implementation of Polycarbonate sheets across all the plants to reduce daylight usage in all plants will conserve 2-3% of fossil
fuel consumption. We are constantly implementing VFD on most motors in our manufacturing capacities to reduce energy
consumption. Solar path light implementation was taken in FY 2021-22 as trials and it will be horizontally deployed in all plants
post successful trials.
(ii) Steps taken by the Company for utilizing alternate sources of energy
Your company has taken aggressive targets to convert 75% of its power demand to renewable sources by FY 2024-25 which
stands currently at 20% in FY 2021-22. We have initiated projects worth 8MW in Solar and wind power energy to convert from
fossil fuel energy. We expect all of them to be on stream in FY 2022-23 to move towards the ESG goal. We also expect to get
into Solar and Wind energy PPA with renewable energy giants to further reduce reliance on Fossil fuel based energy supplies.
(iii) The Capital investment on energy conservation equipments
The company is investing heavily for moving towards renewable energy sources and has committed to invest Rs. 22 to 25 crores
in FY 2021-22 to FY 2022-23 for getting close to 8MW of Power conversion to renewable sources. All the capacity will come on
stream by FY 2022-23 end. Additionally, up to Rs. 2.00 crores is committed towards rain water harvesting and water recycling.
B. Technology Absorption
(i) The efforts made towards technology absorption:
The company is investing towards reducing the component weights in wheels and will be introducing Flow Forming technology
to optimize 5-8% weights. This will cut carbon emission via reduction of material consumption.
The Company has a Govt. of India approved R & D Centre.
The Company has made efforts towards: -
- Design and development of new wheel rims
- Design and development of new dies and tools
(ii) The benefits derived as a result of the above
- Better yield
- Better performance of products
- Reduced cost of products
- Reduction in process wastages
- Better productivity
- Value addition to customers by way of reduced weight of the wheel rims, leading to better fuel efficiency.
(iii) Details of imported technology (imported during the last three years)
(a) The details of the technology imported
Not applicable as the Company has not imported any technology during the last three years including FY 2021-22.
22
(b) The year of import
Not Applicable
(c) Whether the technology been fully absorbed
Not Applicable
(d) If not fully absorbed, areas where absorption has not taken place and the reasons thereof;
Not applicable
(iv) The expenditure incurred on Research and Development
(Rs. In lakhs)
Particulars Year ended 31.03.2022 Year ended 31.03.2021

Capital 2459.28 57.16
Recurring 817.90 640.24
Total 3277.18 697.40
Total R&D Expenditure as a percentage of Turnover 0.92% 0.40%
C. FOREIGN EXCHANGE EARNINGS AND OUTGO

(Rs. In lakhs)
Particulars Year ended 31.03.2022 Year ended 31.03.2021

The Foreign exchange earned in terms of actual inflows during 82734.78 24789.59
the year
The Foreign exchange outgo during the year in terms of actual 42201.93 18120.54
outflows

DIN: 00034827
23
ANNEXURE-B
ANNUAL REPORT ON CORPORATE SOCIAL RESPONSIBILITY (CSR) ACTIVITIES

1. Brief outline on CSR Policy of the Company
The Company believes in corporate excellence and social welfare. This corporate philosophy is the force for integrating Corporate
Social Responsibility (CSR) into Company’s values, culture, operation and business decisions at all levels of the organization. Being
a responsible corporate citizen, the Company has a value system of giving back to society and improving the quality of life of
communities and the surrounding environment.
The Company believes that the corporate strategy which embraces social developments as an integral part of the business activities
ensures long term sustainability of business enterprises. With this belief, the Company is committed to conduct its business in a
socially responsible, ethical and environment friendly manner and to continuously work towards improving quality of life of the local
communities in its operational areas.
As part of CSR initiatives, the Company, during the financial year 2021-22, had amongst other activities, undertook projects in the
areas of promotion of education, construction of modern Anganwadi Centres, providing special life skills to mentally challenged
children, sanitation and cleanliness, healthcare facilities including preventive healthcare, providing artificial aid & limbs to differently
abled, rural & slum area development, ensuring environment sustainability, eliminating hunger, providing support for livelihood to
underprivileged women, reduction of inequalities faced by socially and economically backward groups and spent Rs. 142.11 lakhs on
these CSR programmes towards its CSR obligation for FY 2021-22. The aforesaid CSR initiatives were in accordance with Schedule
VII of the Companies Act, 2013 and Company’s CSR policy & CSR Annual Action Plan.
The Company’s CSR policy has been amended by the Board of Directors in its meeting held on 07.05.2021 to keep in line with the
amended laws and the same has been uploaded on the website of the Company under the web-link: https://sswlindia.com/wp-content/
themes/sswl/assets/docs/csr-policy.pdf.
2. Composition of CSR Committee:
S. No. Name of Director Designation/ Nature of Directorship Number of Number of meetings

meetings of CSR of CSR Committee
Committee held attended during the
during the year year
1. Sh. Surinder Singh Virdi Chairman, Non-Executive Independent 5 5
Director
2. Sh. Virander Kumar Arya Member, Independent Non-Executive 5 5
Director
3. Sh. Manohar Lal Jain Member, Executive Director 5 5
4. Sh. Andra Veetil Unnikrishnan Member, Deputy Managing Director 5 5
3. Provide the web-link where Composition of CSR Committee, CSR Policy and CSR Projects approved by the board are
disclosed on the website of the company:
1. Composition of the CSR committee shared http://sswlindia.com/wp-content/themes/sswl/assets/docs/composition_of_

above and is available on the Company’s various_commitees_ofthe_Board_01.10.2019.pdf
website on:
2. CSR Policy http://sswlindia.com/wp-content/themes/sswl/assets/docs/csr-policy.pdf
3. CSR projects/ programmes: https://sswlindia.com/investors/CSR/
4. Provide the details of Impact assessment of CSR projects carried out in pursuance of sub-rule (3) of rule 8 of the Companies
(Corporate Social Responsibility Policy) Rules, 2014, if applicable (attach the report): Not Applicable
5. Details of the amount available for set off in pursuance of sub-rule (3) of rule 7 of the Companies (Corporate Social Responsibility
Policy) Rules, 2014 and amount required for set off for the financial year, if any: Not Applicable
6. Average net profit of the company as per section 135(5): Rs. 6795.86 lakhs
7. (a) Two percent of average net profit of the company as per section 135(5): Rs. 135.92 lakhs
(b) Surplus arising out of the CSR projects or programmes or activities of the previous financial years: NIL
(c) Amount required to be set off for the financial year, if any: NIL
(d) Total CSR obligation for the financial year (7a+7b- 7c): Rs. 135.92 lakhs
24
8. (a) CSR amount spent or unspent for the financial year: FY 2021-22
Total Amount Spent for Amount Unspent (Rs. In lakhs)
the Financial Year (Rs. Total Amount transferred to Unspent CSR Amount transferred to any fund specified under Schedule VII
In lakhs) Account as per section 135(6) as per second proviso to section 135(5)
Amount Date of transfer Name of the Fund Amount Date of transfer
142.11 - - - - -
(b) Details of CSR amount spent against ongoing projects for the financial year: FY 2021-22
(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11)
S.No. Name Item from Local Location of the Project Amount Amount Amount Mode of Mode of
of the the list of area project duration allocated spent transferred to Implementation- Implementation
Project activities (Yes/ for the in the Unspent CSR Direct (Yes/No) -Through
in No) project (in current Account for the Implementing
Schedule Rs.) financial project as per Agency
VII to the State District (in lakhs) Year (in Section 135(6) Name CSR
Act Rs.) (in Rs.) Registration
(in lakhs) (in lakhs) number
NIL
(c) Details of CSR amount spent against other than ongoing projects for the financial year 2021-22:
(1) (2) (3) (4) (5) (6) (7) (8)
S. Name of the Project Item from Local Location of the project Amount Mode of Mode of Implementation
No. the list of area spent Implementation –Through Implementing
activities in (Yes/ for the – Direct (Yes/ Agency
Schedule No) project (in No)
VII to the State District Rs.) (in Name CSR Registration
Act lakhs) number
1. Promotion of education by Item No. (ii) Yes Punjab Sangrur 68.14 Both Hansraj CSR00002756
strengthening government Trust
schools & helping poor
students by providing
financial assistance
2. Promotion of education Item No. (ii) Yes Punjab SAS Nagar 19.01 Yes NA
by way of construction
of modern Anganwadi
Centers
3 Providing help to the Item No. (ii) Yes Chandigarh Chandigarh 1.37 Yes NA
mentally challenged
children in getting special
life skills education to make
them self-dependable and
able to manage the real
life situations at home, in
the community and at work
place
4. Providing access to Item No. (ii) Yes Punjab SAS Nagar 2.35 Yes NA
education to Orphan
Children who lost their
parents due to Covid-19
5. Running informal Item No. (ii) Yes Jharkhand East 2.36 Yes NA
learning Centre for Tribal Singhbhum
Community
6. Strengthening Community Item No. (i) Yes Punjab SAS Nagar 14.13 Yes NA
Health Centre at Lalru,
Punjab by providing
essential medical
machineries, equipments
and other items to deal
with Covid-19 & other
health problems
7. Emergency Medical Item No. (i) Yes Chandigarh Chandigarh 4.50 Yes NA
Support to needy patients Haryana Ambala
8. Support to Government Item No. (i) Yes Jharkhand East 4.76 Yes NA
Hospitals during Covid-19 Singhbhum
9. Providing Fitness Item No. (i) Yes Punjab Sangrur 1.18 No Hansraj CSR00002756
equipment for public use Trust
25
10. Providing food items Item No. (i) Yes Chandigarh Chandigarh 0.19 Yes NA
to migrant workers to
eradicate hunger emerged
due to Covid-19 Pandemic
11. Providing Artificial Limbs & Item No. (iii) Yes Punjab SAS Nagar 0.74 No Bharat Vikas CSR00012263
Aid to differently abled to Parishad
support their livelihood Charitable
Trust
12. Ensuring environment Item No. (iv) Yes Punjab Sangrur 16.58 Both Hansraj Trust CSR00002756
sustainability through
developing & maintaining
green park & cleaning Jharkhand East
activities Singhbhum
13. Self-Business Start-up Item No. (iii) Yes Punjab SAS Nagar 0.50 Yes NA
Support to underprivileged
women
Total 135.81
(d) Amount spent in Administrative Overheads: Rs. 6.30 lakhs
(e) Amount spent on Impact Assessment, if applicable: Nil
(f) Total amount spent for the Financial Year (2021-22) (8b+8c+8d+8e) : Rs. 142.11 lakhs
(g) Excess amount for set off, if any: Rs. 6.19 lakhs
S. NO. Particulars Amount (in Rs.)

(i) Two percent of average net profit of the company as per section 135(5) Rs. 135.92 lakhs
(ii) Total amount spent for the Financial Year Rs. 142.11 lakhs
(iii) Excess amount spent for the financial year [(ii)-(i)] Rs. 6.19 lakhs
(iv) Surplus arising out of the CSR projects or programmes or activities of the previous financial years, if any Nil
(v) Amount available for set off in succeeding financial years [(iii)-(iv)] Rs. 6.19 lakhs
9. (a) Details of Unspent CSR amount for the preceding three financial years:
S. NO. Preceding Financial Amount transferred to Amount spent Amount transferred to any fund Amount
Year Unspent CSR Account in the reporting specified under Schedule VII as per remaining to
under section 135 (6) Financial Year section 135(6), if any be spent in
(in Rs.) (in Lakhs) (in Rs.) (in Lakhs) Name of Amount Date of succeeding
the Fund (in Rs) transfer financial years
(in Lakhs) (in Rs.) (in Lakhs)
1. 2020-21 109.49 85.59 Not Applicable 23.90
2. 2019-20 26.84 26.84 Not Applicable 0.00
3. 2018-19 Not Applicable
TOTAL 136.33 112.43 Not Applicable 23.90
(b) Details of CSR amount spent in the financial year for ongoing projects of the preceding financial year : FY 2019-20
(1) (2) (3) (4) (5) (6) (7) (8) (9)
S. Project ID Name of the Project Financial Project Total Amount spent Cumulative Status of
No. Year in duration amount on the project amount spent the project
which the (in allocated for in the reporting at the end –Completed
project was years) the project Financial Year of reporting /Ongoing
commenced (in Rs.) (in Rs.) Financial Year
(in Lakhs) (in Lakhs) (in Rs.) (in Lakhs)
1. CSR /SSWL/ For the promotion of 2019-20 3 124.00 18.30 124.00 Completed
2019-20/001 Education by renovation
& Modernization of
Schools etc.
2. CSR /SSWL/ Park Development & 2019-20 3 7.97 0.51 7.97 Completed
2019-20/002 maintenance
3. CSR /SSWL/ Safe Drinking water- 2019-20 3 1.20 0.42 1.20 Completed
2019-20/003 Water to Villagers
4. CSR /SSWL/ Financial Assistance/ Fee 2019-20 3 20.80 3.98 20.80 Completed
2019-20/004 payment of the needy
students
5. CSR /SSWL/ CSR activities in 2019-20 3 2.00 1.87 2.00 Completed
2019-20/006 Urmal Village (Rural
Development Project)
26
6. CSR /SSWL/ Welfare of youth, drug 2019-20 3 2.00 1.00 2.00 Completed
2019-20/007 eradication and socio
economic development.
7. CSR /SSWL/ Promotion of Health 2019-20 3 4.00 0.76 4.00 Completed
2019-20/008
TOTAL 161.97 26.84 161.97
Details of CSR amount spent in the financial year for ongoing projects of the preceding financial year: FY 2020-21
(1) (2) (3) (4) (5) (6) (7) (8) (9)
S. No. Project ID Name of the Project Financial Year Project Total amount Amount Cumulative Status of
in which the duration allocated for spent on the amount spent the project
project was (in the project project in at the end –Completed /
commenced years) (in Rs.) the reporting of reporting Ongoing
(in Lakhs) Financial Financial Year
Year (in Rs.) (in Rs.)
(in Lakhs) (in Lakhs)
1. FY31.03.2021_1 Strengthening 2020-21 2 40.22 38.61 40.22 Completed
Government Health
Infrastructure and
Needy Community
by providing
essentialities to fight
against Covid-19
2. FY31.03.2021_2 Empowering Slum 2020-21 3 16.74 10.37 16.74 Completed
Community by
providing them
basic essentialities
i.e. health, food,
electricity and health,
Hygiene & sanitation
3. FY31.03.2021_3 Ensuring 2020-21 3 29.03 12.42 26.45 Ongoing
Environment
Sustainability
through Awareness
Generation &
Cleanliness activities
4. FY31.03.2021_4 Installation of CCTV 2020-21 2 2.99 2.99 2.99 Completed
Cameras to minimize
the risk of road
accidents
5. FY31.03.2021_5 Promotion of 2020-21 3 41.52 20.20 20.20 Ongoing
education by way of
Strengthening most
needy government
schools
6. FY31.03.2021_6 Emergency Medical 2020-21 2 1.00 1.00 1.00 Completed
Support
Total 131.50 85.59 107.60
10. In case of creation or acquisition of capital asset, furnish the details relating to the asset so created or acquired through CSR
spent in the financial year (asset-wise details) :
a) Date of creation or acquisition of the capital asset(s) : NA
b) Amount of CSR spent for creation or acquisition of capital asset : NA
c) Details of the entity or public authority or beneficiary under whose name such capital asset is registered, their address etc.: NA
d) Provide details of the capital asset(s) created or acquired including complete address and location of the capital asset : NA
11. Specify the reason(s), if the company has failed to spend two per cent of the average net profit as per section 135(5): NA
Date: 02.09.2022 (Sh. Dheeraj Garg) (Sh. Surinder Singh Virdi)

Place: Chandigarh Managing Director Chairman, CSR Committee
27
ANNEXURE-C
PARTICULARS OF REMUNERATION
The information required under Section 197 of the Companies Act, 2013 and the Rule 5 (1) of Companies (Appointment and Remuneration
of the Managerial Personnel) Rules, 2014, in respect of employees of the Company, is as follows: -
(a) The ratio of the remuneration of each director to the median remuneration of the employees of the Company for the financial
year;
Executive Directors Ratio of Median Remuneration

Sh. Dheeraj Garg 454.42
Sh. Andra Veetil Unnikrishnan 29.15
Sh. Manohar Lal Jain 20.54
Note: The Non-Executive Directors of the Company are entitled to sitting fee only for attending Board Meetings and Audit Committee
Meetings as per the statutory provisions. The details of remuneration of Non-Executive Directors are provided in Corporate Governance
Report. The ratio of remuneration and percentage increase for Non-Executive Director’s remuneration is therefore not considered for
the above said purpose.
(b) The percentage increase in remuneration of each Director, Chief Financial Officer, Chief Executive Officer, Company Secretary
or Manager, if any, in the financial year;
Name of Person % increase in remuneration

Sh. Dheeraj Garg (MD) 235.48
Sh. Andra Veetil Unnikrishnan (DMD) 64.31
Sh. Manohar Lal Jain (ED) 45.80
Sh. Naveen Sorot (CFO)* N.A
Sh. Shaman Jindal (CS) 58.88
Note: *Sh. Naveen Sorot was appointed as Chief Financial Officer w.e.f 16.09.2020. Percentage increase in remuneration for FY
2021-22 over FY 2020-21 is not comparable since the remuneration is only for part of the FY 2020-21, hence not stated above.
(c) The percentage increase in the median remuneration of employees in the financial year
3.74%
(d) The number of permanent employees on the rolls of Company:
As on 31.03.2022 the Company had 2304 permanent employees on the rolls of the Company.
(e) Average percentile increase already made in the salaries of employees other than the managerial personnel in the last
financial year and its comparison with the percentile increase in the managerial remuneration and justification thereof and
point out if there are any exceptional circumstances for increase in the managerial remuneration
Average increase in remuneration is 12.76% for employees other than Managerial Personnel and 201.35% for Managerial Personnel.
Sh. Dheeraj Garg, Managing Director was also paid commission @ 5% of net profits of the Company calculated as per section 198
of the Act (including fixed remuneration) for the FY 2021-22. The remuneration of employees and Managerial Personnel is decided
based on the individual performance, Company’s overall performance, inflation, prevailing industry trends and benchmark.
(f) Affirmation that the remuneration is as per the remuneration policy of the Company
The Company affirms that remuneration is as per the Nomination and Remuneration policy of the Company.

DIN: 00034827
28
ANNEXURE-D
Pursuant to Regulation 34(2)(f) of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations,
2015, the Directors present the Business Responsibility Report of the Company for the financial year ended on March 31, 2022
SECTION A: GENERAL INFORMATION ABOUT THE COMPANY
1 Corporate Identity Number (CIN) of the Company L27107PB1985PLC006159

2 Name of the Company Steel Strips Wheels Limited
3 Registered Address Village Somalheri/ Lehli P.O. Dappar Tehsil Derabassi, District S.A.S Nagar
(Mohali), Punjab-140506
4 Website www.sswlindia.com
5 E-mail ID [email protected]
[email protected]
6 Financial Year Reported 01.04.2021 to 31.03.2022
7 Sector(s) that the Company is engaged in (industrial Manufacture of Wheel Rims
activity code-wise) (Auto Parts and Equipment Industry)
NIC Code: 29301
8 List three key products/services that the Company The company is engaged in the business of manufacturing of Steel Wheel
manufactures/provides (as in balance sheet) Rims and Alloy Wheel Rims which are used in automotive vehicles. Its
product range comprises of Steel Wheel Rims for Passenger Cars,
Multi Utility Vehicle, Tractors, Light Commercial Vehicle (LCV), Heavy
Commercial Vehicle (HCV) and Off The Road (OTR) vehicle. Alloy wheels
are mainly for passenger cars.
9 Total number of locations where business activity is
undertaken by the Company: -
(a) Number of International Locations NIL

(b) Number of National Locations 7 (including Registered office, Head office, Branch offices and manufacturing
units) and 16 warehouses
10 Markets served by the Company –Local/ State/National/ We serve all the markets - Local, State, National or International
International
SECTION B: FINANCIAL DETAILS OF THE COMPANY (AS ON 31.03.2022)
Paid-up Capital INR 1560.95 lakhs

Total Turnover (sale of products) INR 357298.00 lakhs (including other income)
Total Profit after taxes INR 20546.41 lakhs
Total Spending on Corporate Social Responsibility (CSR) as 0.69% (as a percentage of profit after tax pertaining to FY 2021-22).
percentage of profit after tax (%)
List of activities in which expenditure on CSR has been Education and Skilling, Healthcare including preventive healthcare,
incurred: Sanitation and Ensuring environment sustainability, Empowerment of
persons with disability.
Annual Report on Company’s CSR projects/programmes is attached as

‘Annexure B’ to the Directors’ Report.
SECTION C: OTHER DETAILS
1. Does the Company have any Subsidiary Company / Companies?
No
2. Do the Subsidiary Company/Companies participate in the BR Initiatives of the parent company? If yes, then indicate the
number of such subsidiary company(s).
Not applicable
3. Do any other entity/entities (e.g. suppliers, distributors etc.) that the Company does business with, participate in the BR
initiatives of the Company? If yes, then indicate the percentage of such entity/ entities? [Less than 30%, 30-60%, More than
60%].
No other entity with which our Company does business with, participates in the BR initiatives of the Company.
29
SECTION D: BR INFORMATION
1. Details of Director responsible for BR :
a) Details of the Director responsible for implementation of the BR Policy/Policies
Sr. No. Particulars Details

1. DIN 00034591
2. Name Sh. Manohar Lal Jain
3. Designation Executive Director
b) Details of the BR head:
Sr. No. Particulars Details

1. DIN NA
2. Name Sh. Naveen Sorot
3. Designation Chief Financial Officer
4. Telephone Number 0172-2793112
5. E-mail ID [email protected]
2. Principle wise (as per NVGs) BR Policy/policies
The National Voluntary Guidelines (NVGs) on Social, Environmental and Economic Responsibilities of Business released by the
Ministry of Corporate Affairs has adopted nine areas of Business Responsibility which are as follows:
Principle 1:(P1) Business should conduct and govern themselves with Ethics, Transparency and Accountability.
Principle 2:(P2) Businesses should provide goods and services that are safe and contribute to sustainability throughout their life
cycle.
Principle 3:(P3) Businesses should promote the well-being of all employees.
Principle 4:(P4) Businesses should respect the interests of and be responsive towards all stakeholders, especially those who are
disadvantaged, vulnerable and marginalized.
Principle 5:(P5) Businesses should respect and promote human rights.
Principle 6:(P6) Business should respect, protect and make efforts to restore the environment.
Principle 7:(P7) Businesses, when engaged in influencing public and regulatory policy, should do so in a responsible manner.
Principle 8:(P8) Businesses should support inclusive growth and equitable development.
Principle 9:(P9) Businesses should engage with and provide value to their customers and consumers in a responsible manner.
(a) Details of compliance [Reply in Y/N]:
S. Questions P1 P2 P3 P4 P5 P6 P7* P8 P9
No.
1 Do you have a policy/ policies for Yes Yes Yes Yes Yes Yes Yes* Yes Yes
2 Has the policy being formulated in consultation with Yes Yes Yes Yes Yes Yes Yes* Yes Yes
the relevant stakeholders.
3 Does the policy conform to any national/ international Yes. Policies have been developed considering relevant national &
standards? If yes, specify? international standards and meet national regulatory requirements
such as Companies Act, 2013, SEBI Listing Regulations and
various other statutes as may be applicable to the Company.
4 Has the policy being approved by the Board? Yes. The policies are approved by the Board and signed by the MD
If yes, has it been signed by MD/ owner/ CEO/ of the company.
appropriate Board Director?
5 Does the company have a specified committee While a few of the policies mandate requirement of a Board
of the Board/ Director/ Official to oversee the Committee, the rest of them are monitored by the management
implementation of the policy? team.
6 Indicate the link for the policy to be viewed online. Link to the policies, which are available on the website at
http://sswlindia.com/investor/
7 Has the policy been formally communicated to all Yes. The policies are communicated to internal stakeholders and
relevant internal and external stakeholders? are available on the company’s internal network. If required, the
policies are also shared with our external stakeholders and are
published on the company’s website.
8 Does the company have in-house structure to Yes.
implement the policy/policies?
30
S. Questions P1 P2 P3 P4 P5 P6 P7* P8 P9
No.
9 Does the company have a grievance redressal Yes.
mechanism related to the policy/policies to address
stakeholders’ grievances related to policy/policies?
10 Has the company carried out independent audit/ The company has internal mechanism to evaluate the policies.
evaluation of the working of this policy by an internal However, no independent audit has been carried out by any
or external agency? external agency.
* Considering the nature of the Company’s business, these principles have limited applicability. The Company complies with Regulations
governing its operations and has taken initiatives to promote inclusive growth and environmental sustainability.
b) If answer to the questions at serial number 1 against any principle, is “No”, please explain why:
N.A.
3. Governance related to BR
a) Indicate the frequency with which the Board of Directors, Committee of the Board or CEO assesses the BR performance
of the Company. Within 3 months, 3-6 months, annually, more than 1 year.
The Board of Directors reviews the BR performance of the Company on an annual basis.
b) Does the Company publish BR or sustainability Report? What is the hyperlink for viewing this report? How frequently
it is published?
The Company publishes BR report. It is annexed as Annexure D to the Board’s Report which forms part of the Annual Report
and is available on the Company’s website:- www.sswlindia.com.
SECTION E: PRINCIPLE-WISE PERFORMANCE
Principle 1: Business should conduct and govern themselves with Ethics, Transparency and Accountability
(i) Does the policy relating to ethics, bribery and corruption cover only the Company? Yes/No.
No.
Does it extend to the Group/ Joint Ventures/ Suppliers/Contractors/NGOs/Others?
Yes. The Company has adopted a Code of conduct applicable to the Board of Directors, Senior Management Personnel and employees
of the Company as well. The Code requires the Directors, Senior Management Personnel and other employees of the Company to
act honestly, ethically and with integrity. The company also has a Whistle Blower Policy approved by the Board and is applicable to all
employees of the Company.
(ii) How many stakeholder complaints have been received in the past financial year and what percentage was satisfactorily resolved by
management? If so, provide details thereof.
The Vigil Mechanism Policy serves as a mechanism for its Directors and Employees to report any genuine concerns about unethical
behaviour, actual or suspected fraud or violation of the Code of Conduct. No complaints were received during the FY 2021-22. No
Complaint was outstanding as on March 31, 2022. In addition to this there are no complaints received during the year relating to ethics,
bribery or corruption from any stakeholders.
Details relating to shareholders’ complaints are provided in Corporate Governance Report, which forms part of this Annual Report.
Principle 2: Businesses should provide goods and services that are safe and contribute to sustainability throughout their life cycle
(i) List three products or services whose design has incorporated social or environmental concerns, risks and/ or opportunities
The Company is growing and continuously improving its products to meet customer requirements. The Company is committed to be
an environmental friendly organization and has a dedicated environmental policy across all its plants.
The Company is engaged in the business of manufacturing Steel Wheel Rims and Alloy Wheel Rims which are used in automotive
vehicles whose design has incorporated social or environmental concerns, risks and opportunities.
(ii) For each such product, provide the following details in respect of resource use (energy, water, raw material etc.) per unit of product
(optional):
The Company endeavours to reduce energy consumption by efficient planning & usage of available equipment/ infrastructure and
resources and by taking substantive energy conservation measures all across the Plants by using LED lights, reduction in air leakages
and optimization of compressor usage.
During the year, the company has taken aggressive targets to convert 75% of its power demand to renewable sources by FY 2024-25
which stands currently at 20% in FY 2021-22. We have initiated projects worth 8MW in Solar and wind power energy to convert from
fossil fuel energy. We expect all of them to be on stream in FY 2022-23 to move towards the ESG goal. We also expect to get into
Solar and Wind energy PPA with renewable energy giants to further reduce reliance on Fossil fuel based energy supplies.
31
In addition to above, the Company always takes efforts for reduction in power & water consumption, reduce CO2 emissions, recycle
Hydraulic Oil & Cutting Oil, hazardous waste reduction, paper consumption reduction, efficient use of raw material (steel) by using
technologically advanced software and recycling & reusing of Aluminum scrap and swarf in a major portion by directly using in
foundry.
(iii) Does the company have procedures in place for sustainable sourcing (including transportation)? If yes, what percentage of your inputs
was sourced sustainably? Also, provide details thereof, in about 50 words or so.
Yes. The Company has well established set of procedures for selection and evaluation of suppliers. It has identified the regional
vendors for different components/ materials based on QCDDS (Quality, Cost, Development, Deliver & Services) criteria. The company’s
procurement of material and goods are done by centralized procurement team. The procedure laid down in this regard endeavor to
protect the environment and various stakeholders.
• Optimized transportation of incoming material and returnable packaging / bio-degradable material packaging solutions for
incoming and inter-plant transfers.
• Partner with Government approved agencies in dealing with storage, handling and disposal of hazardous chemicals.
(iv) Has the company taken any steps to procure goods and services from local and small producers, including communities surrounding
their place of work? If yes, what steps have been taken to improve their capacity and capability of local and small vendors?
Yes, the Company procures goods and services from MSME’s (Micro, Small and Medium Enterprises) including communities
surrounding our place of work. The Company endeavors to source goods and services from local producers at competitive terms,
covering quality, cost and delivery.
Further, the Company assesses their capability on a regular basis and provides technical assistance through our engineering team
to improve their capability and quality wherever required. The Company continuously sources a variety of products and services that
include:
a) Purchase of Product stores.
b) Indigenization of spare parts for machines
c) Outsourcing of manufacturing processes (e.g., part machining, tool building etc.)
d) Machinery for construction and plant engineering.
(v) Does the company have a mechanism to recycle products and waste and the percentage of recycling of products and waste (separately
as 10%)?
The Company has a mechanism for continuously recycling products and waste. Wheels are typically transported using returnable
/ reusable materials and are often used for several years. However, when wooden / corrugated packing materials are used, they
are recycled. The value of such items may be 5%. Domestic waste water in STP is treated and reused for gardening and toilet use.
Thinner from paint sludge is extracted and reused for spray gun washing in paint plants (<5%). Steel Scraps generated are being sold
to casting industries, re-rollers and to other industries as an input into their processes. Aluminum scrap is being sent to smelting unit
and is recycled into Aluminum ingots/billets for further use within our factories.
Principle 3: Businesses should promote the well-being of all employees.
1. Please indicate the Total number of employees: 2304 (on payroll of the Company)
2. Please indicate the Total number of employees hired on temporary / contractual / casual basis: 4367
3. Please indicate the Number of permanent women employees: 26
4. Please indicate the Number of permanent employees with disabilities: 5
5. Do you have an employee association that is recognized by management? : Yes
6. What percentage of your permanent employees is members of this recognized employee association? 29.86%
7. Please indicate the Number of complaints relating to child labour, forced labour, involuntary labour, sexual harassment in the last
financial year and pending, as on the end of the financial year:
S. No Category No. of complaints filed No. of complaints pending as
during the financial year on end of the financial year
1 Child labour / forced labour / involuntary labour Nil Nil
2 Sexual harassment Nil Nil
3 Discriminatory employment Nil Nil
8. What percentage of your under mentioned employees were given safety & skill upgradation training in the last year?
(a) Permanent Employees: 100%
(b) Permanent Women Employees: 100%
(c) Casual/Temporary/Contractual employees: 100%
(d) Employees with Disabilities: 100%
32
Principle 4: Business should respect the interests of, and be responsive towards all stakeholders, especially those who are
disadvantaged, vulnerable and marginalized
(i) Has the company mapped its internal and external stakeholders?
Yes. The Company has mapped its internal and external stakeholders.
(ii) Out of the above, has the company identified the disadvantaged, vulnerable and marginalized stakeholders?
Yes.
(iii) Are there any special initiatives taken by the Company to engage with the disadvantaged, vulnerable and marginalised stakeholders?
If so, provide details thereof, in about 50 words or so.
Yes. The Company is carrying out various welfare activities for the disadvantaged, vulnerable and marginalized stakeholders through
its CSR programmes as we understand that inclusivity is paramount to a responsible business and collective growth of disadvantaged
sections of society. Taking this into account, the Company has taken initiatives to provide artificial limbs/aids to physically disabled
people, contributed to SOREM school for the welfare of the mentally challenged children, provided help to the underprivileged women
to start their own business.
Principle 5: Businesses should respect and promote human rights
(i) Does the policy of the company on human rights cover only the company or extend to the Group/Joint Ventures/ Suppliers/ Contractors
/ NGOs/ Others?
The Company has a Code of Conduct for business and ethics and a Policy of sexual harassment of employees and vigil mechanism
policy which covers aspects ensuring human rights of its employees. Adherence is expected from any person dealing with the
Company.
(ii) How many stakeholder complaints have been received in the past financial year and what percent was satisfactorily resolved by the
management?
No complaints were received pertaining to human rights violation during the reporting period.
Principle 6: Business should respect, protect, and make efforts to restore environment
(i) Does the policy related to Principle 6 cover only the Company or extends to the Group / Joint Ventures /Suppliers / Contractors / NGOs
/ others?
The Company has built sustainable business practices through standardized systems. As a part of this, it encourages all employees
and partners of the Company to participate in protecting the environment.
(ii) Does the company have strategies/ initiatives to address global environmental issues such as climate change, global warming, etc.?
Y/N. If yes, please give hyperlink for webpage etc.
Yes, being in the manufacturing business, the Company has mechanisms in place to ensure compliance with the applicable
environmental laws. The Company is committed to be an environmental friendly organization and has a dedicated environmental
policy across all its business units. As an example, an initiative to reduce and control the pollution level, there is usage of Natural Gas
as a fuel for furnace heating instead of Furnace oil.
(iii) Does the company identify and assess potential environmental risks? Y/N
Yes
(iv) Does the company have any project related to Clean Development Mechanism? If so, provide details thereof. Also, if Yes, whether any
environmental compliance report is filed?
The Company is committed to using renewable resources to operate its facilities. The company is using wind energy in its Tamil Nadu
plant. All the Units of the Company have filed environmental compliance reports as per the requirement of applicable environmental
laws.
(v) Has the company undertaken any other initiatives on – clean technology, energy efficiency, renewable energy, etc. Y/N. If yes, please
give hyperlink for web page etc.
Yes, the Company is committed to manufacturing products and offer services in a way that ensures entitlement of all to a clean
environment. (please refer to clause (ii) of Principle 2 as stated above).
(vi) Are the Emissions/Waste generated by the company within the permissible limits given by CPCB/SPCB for the financial year being
reported?
Yes.
(vii) Number of show cause/ legal notices received from CPCB/SPCB which are pending (i.e., not resolved to satisfaction) as on end of
Financial Year.
At the end of the Financial Year 2021-22, no show cause/legal notice from State or Central Pollution Control board is pending.
33
Principle 7: Businesses, when engaged in influencing public and regulatory policy, should do so in a responsible manner
(i) Is your company a member of any trade and chamber or association? If Yes, Name only those major ones that your business deals
with.
Automotive Components Manufacturers of Association (ACMA)
(ii) Have you advocated / lobbied through above associations for the advancement or improvement of public good? Yes / No; if yes specify
the broad areas (drop box: Governance and administration, Economic Reforms, Inclusive Development Policies, Energy security,
Water, Food Security, Sustainable Business Principles, Others)
Presently the company is carrying out activities on advancement or improvement of public good, both, directly.
Principle 8: Businesses should support inclusive growth and equitable development
(i) Does the company have specified programmes/ initiatives/projects in pursuit of the policy related to Principle 8? If yes details
thereof.
The Company strongly believes in the true spirit of giving back to the society a certain percentage of the profits. The Company has a
well-defined CSR policy which is in line with the provisions of the Companies Act, 2013 and relevant rules framed thereunder. The CSR
initiatives of the Company aim towards inclusive development of the communities largely around the vicinity of its plants and registered
office and at the same time ensure environmental protection through a range of structured interventions in the areas of Promotion of
education, sanitation and cleanliness, healthcare including preventive health care, rural development & slum development, ensuring
environment sustainability, contribution to society for rehabilitation of mentally challenged students, reduction of inequalities faced by
socially and economically backward groups and eradication of hunger and poverty.
The detailed report on the Company’s CSR programmes/projects is annexed as ‘Annexure- B’ to the Director’s Report which forms
part of the Annual Report.
(ii) Are the programmes/projects undertaken through in-house team/own foundation/ external NGO/Government structures/any other
organization?
The CSR programmes/projects are carried out directly by the Company through in-house CSR teams and also through engaging
various implementing agency (ies).
(iii) Have you done any impact assessment of your initiative?
The Company does quarterly review of CSR initiatives augmented with frequent field visits.
(iv) What is your company’s direct contribution to community development projects- Amount in INR and the details of the projects
undertaken?
The Company has spent Rs. 142.11 lakhs on the CSR Activities towards its CSR obligation for the financial year 2021-22. The detailed
report on the Company’s CSR programmes/projects along with details of CSR expenditure incurred during the year is annexed as
‘Annexure- B’ to the Director’s Report which forms part of the Annual Report.
(v) Have you taken steps to ensure that this community development initiative is successfully adopted by the community? Please explain
in 50 words, or so.
The Company endeavours to make attempts to ensure that projects continue and sustain within communities beyond our
interactions. The Communities are involved right from the stage of project identification till its implementation and smooth
running thereof with due interaction with the beneficiaries and their Parents, Panchayats, Government Authorities.
The feedback from the stakeholders are analyzed and accordingly various actions are prioritized.
Principle 9: Businesses should engage with and provide value to their customers and consumers in a responsible manner
(i) What percentage of customer complaints/consumer cases are pending as on the end of financial year?
NIL
(ii) Does the company display product information on the product label, over and above what is mandated as per local laws? Yes/ No/
N.A. / Remarks
The Company displays product information on the product label to the extent mandated as per local laws.
(iii) Is there any case filed by any stakeholder against the company regarding unfair trade practices, irresponsible advertising and/or anti-
competitive behavior during the last five years and pending as on end of financial year? If so, provide details thereof, in about 50 words
or so.
None.
(iv) Did your company carry out any consumer survey/consumer satisfaction trends?
Yes.
34
Annexure I
FORM NO. MR-3
SECRETARIAL AUDIT REPORT
FOR THE FINANCIAL YEAR ENDED ON MARCH 31, 2022
[Pursuant to Section 204(1) of the Companies Act, 2013 and Rule 9 of the Companies
(Appointment and Remuneration of Managerial Personnel) Rules, 2014]
To,
The Members,
Steel Strips Wheels Limited
I have conducted the secretarial audit of the compliance of applicable statutory provisions and the adherence to good corporate practices
by Steel Strips Wheels Limited (hereinafter called the “Company”). Secretarial Audit was conducted in a manner that provided me a
reasonable basis for evaluating the corporate conducts/ statutory compliances and expressing my opinion thereon.
Based on my verification of Company’s books, papers, minute books, forms and returns filed and other records maintained by the Company
and also the information provided by the Company, its officers, agents and authorized representatives during the conduct of secretarial audit,
the explanations and clarifications given to me and the representations made by the Management and considering the relaxations granted
by the Ministry of Corporate Affairs and Securities and Exchange Board of India warranted due to the spread of the COVID-19 pandemic, I
hereby report that in my opinion, the Company has, during the audit period covering the financial year ended March 31, 2022, complied with
the statutory provisions listed hereunder and also that the Company has proper Board processes and compliance mechanism in place to the
extent, in the manner and subject to other reporting made hereinafter.
I have examined the books, papers, minute books, forms and returns filed and other records maintained by the Company for the financial
year ended on March 31, 2022 according to the provisions of:
1) The Companies Act, 2013 (the Act) and the rules made thereunder;
2) The Securities Contracts (Regulation) Act, 1956 (‘SCRA’) and the rules made thereunder;
3) The Depositories Act, 1996 and the Regulations and bye-laws framed thereunder;
4) Foreign Exchange Management Act, 1999 and the rules and regulations made thereunder to the extent of Foreign Direct Investment,
Overseas Direct Investment and External Commercial Borrowings;
5) The following Regulations and Guidelines prescribed under the Securities and Exchange Board of India Act, 1992 (‘SEBI Act’): -
a) The Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011;
b) The Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015;
c) The Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2009 (now, The
Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018);
d) The Securities and Exchange Board of India (Registrars to an Issue and Share Transfer Agents) Regulations, 1993 regarding
the Companies Act and dealing with client;
e) The Securities and Exchange Board of India (Share Based Employee Benefits) Regulations, 2014 (now The Securities and
Exchange Board of India (Share Based Employee Benefits and Sweat equity) Regulations, 2021);
f) The Securities and Exchange Board of India (Issue and Listing of Debt Securities) Regulations, 2008; (Not applicable to the
Company during the audit period)
g) The Securities and Exchange Board of India (Delisting of Equity Shares) Regulations, 2009; (Not applicable to the Company
during the audit period) and
h) The Securities and Exchange Board of India (Buyback of Securities) Regulations, 1998 and The Securities and Exchange Board
of India (Buyback of Securities) Regulations, 2018; (Not applicable to the Company during the audit period)
6) The Company has complied with the following laws applicable specifically to the Company:
a) The Petroleum Act 1934/Petroleum Rules 1976, Amendment: 2002,2018
b) Hazardous Waste (Management & Handling) Rules 1989 and the Amendment Rules, 2003
c) The Bio Medical Waste (Management & Amp; Handling) Rules 1998, Amendment Rules, 2003, 2016, 2018
d) Environment Protection Act, 1986 and other Environmental laws.
e) The Air (Prevention and Control of Pollution) Act, 1981
f) The Water (Prevention and Control of Pollution) Act, 1974
g) The Factories Act, 1948, The Payment of Wages Act, 1936, The Minimum Wages Act, 1948, The Payment of Bonus Act, 1965,
The Employees Compensation Act, 1923 etc. and rules framed thereunder.
35
I have also examined compliance with the applicable clauses of the following:
(i) Secretarial Standards issued by The Institute of Company Secretaries of India with respect to Board and General Meetings.
(ii) The Listing Agreements entered into by the Company with BSE Limited and The National Stock Exchange of India Limited (NSE)
and Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 (SEBI Listing
Regulations).
During the period under review the Company has complied with the provisions of the Act, Rules, Regulations, Guidelines, Standards, etc.
mentioned above.
I further report that
The Board of Directors (BOD) of the Company is duly constituted with proper balance of Executive Directors, Non-Executive Directors and
Independent Directors. The changes in the composition of the Board of Directors that took place during the period under review were carried
out in compliance with provisions of the Act.
Adequate notice has been given to all the Directors to schedule the board meetings during the financial year under review, agenda and
detailed notes on agenda were sent at least seven days in advance for meetings other than those held at shorter notice, and a system exists
for seeking and obtaining further information and clarifications on the agenda items before the meeting and for meaningful participation at
the meeting.
As per the minutes of the meetings, all decisions at the Board and Committee Meetings, as represented by management, were taken
unanimously.
I further report that there are adequate systems and processes in the Company commensurate with the size and operations of the
Company to monitor and ensure compliance with applicable laws, rules, regulations and guidelines.
I further report that during the audit period there were following specific events / actions having major bearing on the Company’s affairs
in pursuance of the above referred laws, rules, regulations, guidelines and standards etc. and the Company has duly complied with all
applicable laws/rules/regulations with respect to the following:
(i) The BOD and the Shareholders of the Company at their respective meetings held on September 3, 2021 and September 30, 2021,
have approved the sub-division of Company’s existing 1 (One) equity share of face value of Rs.10/- each into 2 (Two) equity shares
of face value of Rs. 5/- each. The sub-division of shares was made effective from November 22, 2021 (Record Date);
(ii) The BOD and the Shareholders of the Company at their respective meetings held on September 3, 2021 and September 30, 2021
have approved the alteration of the Capital Clause of Memorandum of Association of the Company pursuant to the sub-division of
Equity Shares;
(iii) The BOD and the Shareholders of the Company at their respective meetings held on September 6, 2021 and September 30, 2021,
have approved the adoption of a new set of Articles of Association (AOA) of the Company in line with the Companies Act, 2013;
(iv) The BOD and the Shareholders of the Company at their respective meetings held on September 3, 2021 and September 30, 2021,
have approved to introduce and implement “Steel Strips Wheels Limited- Employee Stock Option Scheme 2021” (“ESOS 2021”) to
create, issue, offer and grant Stock Options to Employees of the Company exercisable into equal number of equity shares under
section 62 (1)(b) of Companies Act, 2013.
I further report that during the audit period, there were no instances of:
(i) Public / Rights / Preferential issue of shares /debentures / sweat equity.
(ii) Redemption / buy-back of securities.
(iii) Major decisions taken by the members in pursuance to section 180 of the Companies Act, 2013
(iv) Merger / amalgamation / reconstruction etc.
(v) Foreign technical collaborations.
Note: This report is to be read with our letter of even date which is annexed as ‘Annexure A’ and forms an integral part of this report.
For S. K. SIKKA & ASSOCIATES

Company Secretaries
Place: Chandigarh (Sushil Kumar Sikka)

FCS 4241
CP 3582
UDIN: F004241D000893351
36
Annexure A
To,
The Members,
My report of even date is to be read along with this letter.

1. Maintenance of Secretarial record is the responsibility of the management of the Company. My responsibility is to express as opinion
on these secretarial records based on my audit.
2. I have followed the audit practices and process as were appropriate to obtain reasonable assurance about the correctness of the
contents of the secretarial records. The verification was done on test basis to ensure that correct facts are reflected in secretarial
records. I believe that the processes and practices, I followed provide a reasonable basis for my opinion.
3. I have not verified the correctness and appropriateness of financial records and Books of Accounts of the Company.
4. Wherever required, I have obtained the Management representation about the compliance of laws, rules and regulations and
happening of events etc.
5. The compliance of the provisions of Corporate and other applicable laws, Rules, Regulations, standards is the responsibility of
management. My examination was limited to the verification of procedures on test basis.
6. The Secretarial Audit report is neither an assurance as to the future viability of the Company nor of the efficacy or effectiveness with
which the management has conducted the affairs of the Company.
(Sushil Kumar Sikka)

Place: Chandigarh Company Secretary
Date: 02.09.2022 FCS 4241
CP 3582
37
Annexure- II
SECRETARIAL COMPLIANCE REPORT FOR THE FINANCIAL YEAR ENDED 31ST MARCH, 2022
[Pursuant to SEBI Circular No. CIR/CFD/CMD1/27/2019 Dt. 8th February, 2019]
I, Sushil Kumar Sikka, Proprietor of S. K. Sikka & Associates, have examined:
(a) all the documents and records made available to us and explanation provided by Steel Strips Wheels Limited (“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 31st March, 2022 (“Review Period”) in respect of compliance with the provisions of:
(e) The Securities and Exchange Board of India Act, 1992 (“SEBI Act”) and the Regulations, circulars, guidelines issued thereunder;
and
(f) 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;
(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 Audit Period)
(e) Securities and Exchange Board of India (Share Based Employee Benefits & Sweat Equity) Regulations, 2021 {erstwhile
Securities and Exchange Board of India (Share Based Employee Benefits) Regulations, 2014};
(f) Securities and Exchange Board of India (Issue and Listing of Debt Securities) Regulations, 2008 and Securities and Exchange
Board of India (Issue and Listing of Non-Convertible Securities) Regulations, 2021; (Not Applicable to the Company during
the Audit Period)
(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 Audit Period)
(h) Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015;
(i) other regulations as applicable from time to time;
and circulars/guidelines issued thereunder;
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 :-
S. No. Compliance Requirement (Regulations/ Deviations Observations/Remarks of the Practicing

circulars / guidelines including specific clause) Company Secretary
NIL
(b) The listed entity has maintained proper records under the provisions of the above Regulations and circulars/ guidelines issued
thereunder in so far as it appears from my 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:
S. No. Action taken by Details of violation Details of action taken e.g. fines, Observations/ remarks of the
warning letter, debarment, etc. Practicing Company Secretary, if any.
NIL
Further no action has been taken against the promoters/directors/material subsidiaries either by SEBI or by Stock Exchanges (including
under the Standard Operating Procedures issued by SESI through various circulars) under the aforesaid Acts/Regulations and circulars/
guidelines issued thereunder
38
(a) The listed entity has taken the following actions to comply with the observations made in previous reports:
S. No. Observations of the Practicing Observations made in the Actions taken by the listed Comments of the
Company Secretary in the secretarial compliance entity, if any Practicing Company
previous reports report for the year ended Secretary on the
(the years are to be actions taken by the
mentioned) listed entity
1. Regulation 17(1) of SEBI (LODR) The observation was made As informed in my previous report The matter stands
Regulations, 2015 in the Annual Secretarial for the FY ending 31.03.2021, closed as on end of FY
Compliance report for the the Company had appointed an 2021-22.
- One Independent Director was year ended 31.03.2021 Independent Director on the Board
required to be appointed to make w.e.f. 09.11.2020 and hence, the
the composition of the Board of board Composition was corrected
Directors in conformity with SEBI in accordance with the SEBI
Listing Regulations. Listing Regulations and duly paid
fines imposed by BSE and NSE.
Further, BSE and NSE had denied

the Company’s request for waiver
of said fine.
Place: Chandigarh (Sushil Kumar Sikka)

Date: 26.05.2022 FCS No.: 4241
C P No.: 3582
UDIN: F004241D000393542
39
CORPORATE
COMPANY’S PHILOSOPHY ON CODE OF GOVERNANCE

Effective Corporate Governance practices constitute the strong foundation on which successful commercial enterprises are built to last. The
Company’s philosophy in relation to Corporate Governance is to ensure transparent disclosures and reporting that conforms fully to laws,
regulations and guidelines and to promote ethical conduct throughout the organization with the primary objective of enhancing stakeholders’
value while being a responsible corporate citizen. The Company has always thrived towards building trust with shareholders, employees,
customers, suppliers, regulators, and other stakeholders based on the principles of good Corporate Governance.
The Company has adopted SSWL’s Code of Conduct for its employees, officers and Directors. In addition, the Company’s Independent
Directors adhere to “Code for Independent Directors” provided in Schedule IV of the Companies Act, 2013 (“the Act”) which suitably incorporates
the duties and responsibilities of Independent Directors as laid down in the Act. The Company’s corporate governance philosophy has been
further strengthened through Code of Conduct for Prevention of Insider Trading and the Code of Practices and Procedures for fair disclosure
of Unpublished Price Sensitive Information (UPSI).
The Company is in compliance with the requirements stipulated under Regulations 17 to 27, clauses (b) to (i) and (t) of Regulation 46(2) and
para C, D & E of Schedule V of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations,
2015 (“SEBI Listing Regulations”), as applicable, with regard to Corporate Governance. This report is to be read with Board’s Report and all
its annexures for more clarity on Corporate Governance practices of the Company.
Board of Directors
The Board of Directors (“Board”) of the Company is entrusted with the ultimate responsibility of the management, formulations of policies,
devising corporate strategy, general affairs, direction and performance of the Company, ensuring compliances of all applicable laws of the
land in letter as well as in spirit and long term success of business as a whole. The Board has been vested with requisite powers, authorities
and duties. The Board consists of optimum combination of Executive, Non- Executive and Independent Directors including Woman Director
who have wide and varied experience in the field of business, finance, education, industry, commerce and administration.
(i) Composition and Category of the Directors: The Composition of the Board of the Company is in conformity with Regulation 17 of
SEBI Listing Regulations read with Section 149 of the Act. As on 31.03.2022, the Company’s Board consisted of twelve (12) directors.
Of the twelve directors, three (3) (i.e. 25%) are Executive Directors (one ED belonging to promoter category) and two (2) (i.e. 17%)
are Non-Executive - Non Independent Directors out of which one (1) is Non-Executive Chairman belonging to promoter category.
Remaining seven (7) (i.e. 58%) are Non-Executive Directors of which, six (6) are Independent Directors (including one Woman
Independent Director) and one (1) is Nominee Director [Nominated by Tata Steel Limited (Equity Investor)].
(ii) None of the Director is a Director in more than 10 public limited companies (as specified in section 165 of the Act) and Director in more
than 7 listed entities (as specified in Regulation 17A of the SEBI Listing Regulations) or acts as an Independent Director (including
any alternate directorships) in more than 7 listed companies and none of the Whole Time Director/Managing Director of the Company
serves as an Independent Director in any listed entity (as specified in Regulation 17A of the SEBI Listing Regulations). Further, none
of the Directors on the Board is a Member of more than 10 Committees and Chairperson of more than 5 Committees (considering
only Audit and Stakeholders’ Relationship Committee as specified in Regulation 26(1)(b) of the SEBI Listing Regulations), across
all the public limited companies in which he/she is a Director. Necessary disclosures regarding committee positions in other public
companies as on 31.03.2022 have been made by the directors.
(iii) Independent Directors are Non-Executive Directors as defined under Regulation 16(1)(b) of SEBI Listing Regulations, read with
Section 149 (6) of the Act along with rules framed thereunder. In terms of Regulation 25(8) of SEBI Listing Regulations, all the
Independent Directors have declared that they meet the criteria of Independence as provided in Regulation 16(1) (b) of SEBI Listing
Regulations and have also confirmed that 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. The maximum tenure of the Independent Directors is in compliance with the Act and Rules framed thereunder and
clarifications/circulars issued by the Ministry of Corporate Affairs in this regard from time to time. Based on the declarations received
from the Independent Directors, the Board of Directors has confirmed that they meet the criteria of independence as mentioned
under Regulation 16(1)(b) of the SEBI Listing Regulations read with Section 149 (6) of the Act and that they are independent of the
management. Further, in terms of Section 150 of the Act read with Rule 6 of the Companies (Appointment & Qualification of Directors)
Rules, 2014, all the Independent Directors of the Company have confirmed that they have enrolled themselves in the Independent
Directors databank maintained with the Indian Institute of Corporate Affairs.
(iv) Sh. Rajinder Kumar Garg (Chairman & Non-Executive Director) is father of Sh. Dheeraj Garg (Managing Director), hence related to
each other and belong to the promoter category. None of the other directors of the Company are in any way related to each other.
(v) Six (6) Board Meetings were held during the year and gap between two meetings did not exceed one hundred twenty days (120)
as stipulated under Regulation 17(2) of SEBI Listing Regulations, Secretarial Standards and under the Act. The said six (6) board
40
meetings were held on 07.05.2021, 12.07.2021, 03.09.2021, 06.09.2021, 22.10.2021 and 24.01.2022. The necessary quorum was
present at all the meetings and in case of any exigency/urgency, resolutions were passed by circulation.
(vi) The names and categories of the Directors on the Board, DIN, their attendance at Board Meetings held during the year under review and
at the last Annual General Meeting (“AGM”), name of other listed entities in which he/she is a director and the number of Directorships
and Committee Chairmanships / Memberships held by them in other Public Companies as on 31.03.2022 are given herein below.
Other Directorships do not include directorships of Private Limited Companies, Foreign Companies, and Companies registered under
Section 8 of the Act. For the purpose of determination of the limit of the Board Committees, Chairmanships/ Memberships of the Audit
and Stakeholders Relationship Committee has been considered as per Regulation 26(1)(b) of SEBI Listing Regulations.
Name of Category No. of Board Whether No. of Directorships No. of Committee Directorships in other
Director, meetings attended last in other Public positions held Listed entity (Category of
Designation & attended AGM held on companies in other public Directorship)
DIN during the 30-09-2021 companies
FY 2021-22 Chairman Member Chairman Member
*Sh. Rajinder Non–Executive 6 No 2 1 - - 1. Indian Acrylics Limited

Kumar Garg Director (Managing Director) -
(Chairman) (Promoter) Promoter
DIN: 2. Sab Industries Limited
00034827 (Chairman, Non-
Executive Director) -
Promoter
3. Steel Strips
Infrastructures Limited
(Chairman, Non-
Executive Director) -
Promoter
Sh. Dheeraj Executive 4 Yes - 1 - 2 Indian Acrylics Limited

Garg (Managing Director (Whole time Director,
Director) (Promoter) Additional MD)
DIN: 00034926
Sh. Andra Veetil Whole Time 6 Yes - - - - -
Unnikrishnan Director
(Deputy
Managing
Director)
DIN: 02498195
Sh. Manohar Lal Whole Time 6 Yes - 3 - - -
Jain Director
(Executive
Director)
DIN: 00034591
*Sh. Sanjay Garg Non–Executive 4 No - 6 - 2 1. SAB Industries Limited
(Director) Non- (Executive Director,
DIN: 00030956 Independent Managing Director)
Director 2. Steel Strips
(Executive Director,
Managing Director)
Sh. Sanjay Nominee of Tata 2 No - - - - -
Surajprakash Steel Ltd (equity
Sahni investor),
(Director) Non–Executive
DIN: 08263029 Director
Sh. Virander Independent 5 Yes - - - - -
Kumar Arya Non–Executive
(Director) Director
DIN: 00751005
**Sh. Ajit Singh Independent 5 Yes - 1 1 1 Indian Acrylics Ltd.
Chatha Non–Executive (Independent, Non-
(Director) Director executive Director)
DIN: 02289613
41
Name of Category No. of Board Whether No. of Directorships No. of Committee Directorships in other
Director, meetings attended last in other Public positions held Listed entity (Category of
Designation & attended AGM held on companies in other public Directorship)
DIN during the 30-09-2021 companies
FY 2021-22 Chairman Member Chairman Member
Sh. Shashi Independent 5 No - 2 - - Indian Acrylics Limited

Bhushan Gupta Non–Executive (Independent, Non-
DIN: 00154404
*Sh. Surinder Independent 3 No - 3 3 1 1. SAB Industries Limited
Singh Virdi Non–Executive (Independent, Non-
DIN: 00035408 2. Steel Strips
(Independent, Non-
executive Director)
Smt. Deva Independent 5 No - 1 - - Indian Acrylics Limited
Bharathi Reddy Non–Executive (Independent, Non-
DIN: 08763741
Sh. Siddharth Independent 4 No - - - - -
Bansal Non–Executive
(Director) Director
DIN: 02909820
Note: *Sh. Rajinder Kumar Garg, Sh. Sanjay Garg & Sh. Surinder Singh Virdi were holding Directorships in an another listed entity i.e. Steel
Strips Ltd. (SSL) (a promoter group Company). However, w.e.f. 19.10.2021, SSL was amalgamated into SAB Industries Ltd., hence not
considered in the above table.
**Sh. Ajit Singh Chatha had resigned from the position of Independent Director from Monte Carlo Fashions Ltd. (Listed Entity) w.e.f.
31.03.2022, hence not considered in his directorship as on end of the year under review.
(vii) During the financial year 2021-22, information as specified in Part A of Schedule II of the SEBI Listing Regulations, has been placed
before the Board of Directors for its discussion and consideration.
(viii) The Board periodically reviews compliance reports pertaining to all laws applicable to the Company as required under Regulation
17(3) of the SEBI Listing Regulations. Necessary steps are taken to rectify instances of non-compliances, if any.
(ix) The Board has satisfied itself that plans are in place for orderly succession for appointment to the Board of Directors and Senior
Management.
(x) Details of number of equity shares of the Company held by the Directors (Executive and Non Executive) as on 31.03.2022 are given
below:
(a) Executive Directors
Name of the Director Designation No. of Shares held Percentage

Sh. Dheeraj Garg Managing Director 9280456 29.73
Sh. Andra Veetil Unnikrishnan Deputy Managing Director 0 0.00
Sh. Manohar Lal Jain Executive Director 40606 0.13
(b) Non-Executive Directors
Name of the Director Designation No. of Shares held Percentage

Sh. Rajinder Kumar Garg Chairman, Non-Executive Director 585142 1.87
Sh. Virander Kumar Arya Independent, Non-Executive Director 500 0.002
Sh. Sanjay Garg* Non-Executive Director 350 0.001
*In addition to the above mentioned 350 shares held by Sh. Sanjay Garg, Non-Executive Director of the Company, 550 shares
(0.001 %) are also held in the name of his HUF.
Note:
(i) Apart from receiving directors sitting fees and dividend declared by the Company on the shares held, if any, none of the Non-
Executive or Independent Directors has any other material pecuniary relationship or transaction with the Company.
(ii) The Executive Directors and/or Non-Executive Directors of the Company do not hold any convertible securities/ instruments of
the Company. However, during the financial year 2020-21, the Company had granted 3000 stock options convertible into equal
number of equity shares to Sh. Andra Veetil Unnikrishnan, Deputy Managing Director of the company under “Steel Strips Wheels
Limited- Employee Stock Option Scheme, 2016” (ESOS 2016).
42
(xi) The Board has identified the following skills/expertise/ competencies fundamental for the effective functioning of the Company which
are currently available with the Board:
Skills & Description Sh. Sh. Sh. Sh. Sh. *Sh. Sh. Sh. Ajit Sh. Sh. Smt. Sh.
Rajinder Dheeraj Manohar A.V. Sanjay Siddharth V. K. Singh Shashi Surinder Deva Sanjay
K Garg Garg Lal Jain Unnikri Suraj Bansal Arya Chatha Bhushan Singh Bharathi Garg
shnan Prakash Gupta Virdi Reddy
Sahni
Global
Business
Understanding of global
business dynamics,
√ √ √ √ √ √ - √ √ √ - √
across various
geographical markets,
industry verticals and
regulatory jurisdictions.
Strategy and
Planning
Appreciation of long-
term trends, strategic
choices and experience √ √ √ √ √ √ √ √ √ √ √ √
in guiding and leading
management teams
to make decisions in
uncertain environments.
Governance and
Regulatory Oversight
Experience in
developing governance
practices, serving
the best interests
of all stakeholders,
maintaining board √ √ √ √ √ √ √ √ √ √ √ √
and management
accountability,
building long-term
effective stakeholder
engagements and
driving corporate ethics
and values.
Sales and Marketing
Exposure
Developing strategies to
protect and grow brand
equity and distribution
reach.
Understanding evolution
in channels and
√ √ - √ √ √ - - - - - √
strategies required to
protect and grow
the business and its
potential to recommend
plans to leverage the
developments
effectively for growth
and efficiency.
43
Financial Experience
and Risk Oversight
Evaluating the financial
viability of various
strategic proposals,
review of capital √ √ √ √ √ √ √ √ √ √ - √
budgets, financial
results / statements,
risks associated with
the business and the
minimization procedure
Note: *Sh. Siddharth Bansal was appointed as the Non-Executive Independent Director of the Company w.e.f. 09.11.2020 and subsequently,
his appointment was approved by the shareholders in the Annual General Meeting held on 30.09.2021.
Selection and appointment of New Directors on the Board
Considering the requirements of the skill-sets on the Board, eminent persons having an independent standing in their respective field/
profession and who can effectively contribute to the Company’s business and policy decisions are considered by the Nomination and
Remuneration Committee for appointment of new Directors on the Board. The number of directorships and memberships in various
committees of other companies by such persons is also considered.
Selection criteria of Board Members
The Board of Directors is collectively responsible for selection of a member on the Board. The Nomination and Remuneration Committee of
the Company follows defined criteria for identifying, screening, recruiting and recommending candidates for selection as a Director on the
Board. The criteria for appointment to the Board include:
• Composition of the Board, which is commensurate with the size of the Company, its portfolio, geographical spread and its status as a
listed Company;
• Desired age and diversity on the Board;
• Size of the Board with optimal balance of skills and experience and balance of Executive and Non-Executive Directors consistent with
the requirements of law;
• Professional qualifications, expertise and experience in specific area of business;
• Balance of skills and expertise in view of the objectives and activities of the Company;
• Avoidance of any present or potential conflict of interest;
• Availability of time and other commitments for proper performance of duties;
• Personal characteristics being in line with the Company’s values, such as integrity, honesty, transparency, leadership skills, pioneering
mindset.
Familiarisation program of Independent Directors
The Independent Directors of Company are eminent personalities having wide experience in the field of business, finance, education,
industry, commerce and administration. Their presence on the Board has been advantageous and fruitful in taking business decisions. As
required under Regulation 46 of the SEBI Listing Regulations, the terms and conditions of appointment of independent directors including
their role, responsibility and duties are disclosed on the Company’s website at http://sswlindia.com/wp-content/themes/sswl/assets/docs/
terms_conditions.pdf.
When a new Independent Director comes on the Board of the Company, a meeting is arranged with the Chairman, Managing Director,
Deputy Managing Director, Executive Director, Chief Financial Officer and Company Secretary of the Company to brief him/her about the
Company, nature of the industries in which the Company operates, its businesses, key customers, business module wise performance, the
salient features of the industries to which the Company supplies its goods and other relevant information.
A newly appointed Independent Director is provided with an appointment letter incorporating the role, rights, duties and responsibilities,
remuneration and performance evaluation process, insurance cover and obligations on disclosures, as may be applicable to them. They are
also provided with copy of latest Annual Report, the SSWL Code of Conduct, the SSWL Code of Conduct for Prevention of Insider Trading,
Code for Independent Directors provided in Schedule IV of the Companies Act, 2013.
The Directors get an opportunity to visit Company’s plants, where plant heads apprise them of the operational and sustainability aspects of
the plants to enable them to have full understanding on the activities of the Company and initiatives taken on safety and quality etc.
During Board Meetings/Audit Committee Meetings, Directors are also informed about business performance, operations, market share,
financial parameters, working capital management, fund flows, major litigation, compliances, CSR activities, regulatory scenario etc.
Directors are also informed on the various developments in the Company through e-mail (s) and other modes by the Chairman/Managing
Director/Deputy Managing Director/Company Secretary.
The details of the familiarization programme of the Independent Directors are available on Company’s website at https://sswlindia.com/
investors/familiarisation-programme-for-independent-directors/
44
CONFIRMATION THAT THE INDEPENDENT DIRECTORS FULFILLS THE CONDITION AND ARE INDEPENDENT of THE
management
In the opinion of the Board, all the Independent Directors appointed in the Board have fulfilled all the necessary conditions and criteria as
enumerated under Regulation 16(1)(b) of the SEBI Listing Regulations and have provided their declaration in relation to their independence
as required under Regulation 25(8) of the SEBI Listing Regulations. All the Independent Directors are independent of the management and
are not related to any members of the Board. The Company has taken Directors and Officers Insurance (‘D and O Insurance’) for all its
Independent Directors, as mandated under regulation 25(10) of the SEBI Listing Regulations.
DETAILED REASON FOR THE RESIGNATION OF AN INDEPENDENT DIRECTOR BEFORE THE EXPIRY OF HIS/HER TENURE
ALONG WITH CONFIRMATION THAT THERE ARE NO MATERIAL REASONS OTHER THAN THOSE PROVIDED
During the year under review, none of the Independent Directors of the Company had resigned from the Board of the Company before the
expiry of their respective tenure(s).
COMMITTEES OF THE BOARD
There are nine (9) committees of the Board of Directors of the Company as on 31.03.2022 which comprises five (5) statutory committees and
four (4) other committees that have been constituted after considering the needs of the Company, the details of which are as follows:
I. AUDIT COMMITTEE
The Audit Committee (AC) of the Company is constituted in line with the provisions of Regulation 18 of SEBI Listing Regulations read
with Section 177 of the Act and Rules framed thereunder (including any amendment thereof).
The terms of reference of AC are as per relevant guidelines, legislations, acts and regulations. The primary objective of the AC is
to monitor and provide effective supervision of the management’s financial reporting process with a view to ensure accurate, timely
and proper disclosures and transparency, recommendation for appointment, remuneration and terms of appointment of auditors of
the company, reviewing, with the management, the annual financial statements and Auditor’s Report thereon and quarterly financial
statements before submission to the Board for approval and to review the adequacy of internal control systems and functions etc.
The AC is empowered, pursuant to its terms of reference and its role, inter alia, includes the following:
(i) Overseeing the Company’s financial reporting process and the disclosure of its financial information to ensure that the financial
statement is correct, sufficient and credible;
(ii) Recommending to the Board, the appointment, remuneration and terms of appointment of auditors of the Company;
(iii) Approval of payment to statutory auditors for any other services rendered by the statutory auditors;
(iv) Reviewing, with the management, the annual financial statements and auditor’s report thereon before submission to the board
for approval, with particular reference to:
a) Matters required being included in the director’s responsibility statement to be included in the board’s report in terms of
clause(c) of sub-section (3) of Section 134 of the Companies Act, 2013;
b) Changes, if any, in accounting policies and practices and reasons for the same;
c) Major accounting entries involving estimates based on the exercise of judgment by management;
d) Significant adjustments made in the financial statements arising out of audit findings;
e) Compliance with listing and other legal requirements relating to financial statements;
f) Disclosure of any related party transaction;
g) Modified opinion(s) in the draft audit report.
(v) Reviewing, with the management, the quarterly financial statements before submission to the board for approval;
(vi) Reviewing, with the management, the statement of uses/application of funds raised through an issue (public issue, rights issue,
preferential issue, etc.), the statement of funds utilized for purposes other than those stated in the offer document/prospectus/
notice and the report submitted by the monitoring agency monitoring the utilisation of proceeds of a public or rights issue, and
making appropriate recommendations to the board to take up steps in this matter;
(vii) Reviewing and monitoring the auditor’s independence and performance, and effectiveness of audit process;
(viii) Approval or any subsequent modification of transactions of the listed entity with related parties;
(ix) Scrutiny of inter-corporate loans and investments;
(x) Valuation of undertakings or assets of the listed entity, wherever it is necessary;
(xi) Evaluation of internal financial controls and risk management systems;
(xii) Reviewing, with the management, performance of statutory and internal auditors, and adequacy of the internal control systems;
(xiii) Reviewing the adequacy of internal audit function, if any, including the structure of the internal audit department, staffing and
seniority of the official heading the department, reporting structure coverage and frequency of internal audit;
45
(xiv) Discussion with internal auditors of any significant findings and follow up there on;
(xv) Reviewing the findings of any internal investigations by the internal auditors into matters where there is suspected fraud or
irregularity or a failure of internal control systems of a material nature and reporting the matter to the board;
(xvi) Discussion with statutory auditors before the audit commences, about the nature and scope of audit as well as post-audit
discussion to ascertain any area of concern;
(xvii) To look into the reasons for substantial defaults in the payment to the depositors, debenture holders, shareholders (in case of
non-payment of declared dividends) and creditors;
(xviii) To review the functioning of the whistle blower mechanism;
(xix) Approval of appointment of chief financial officer after assessing the qualifications, experience and background, etc. of the
candidate;
(xx) Carrying out any other function as is mentioned in the terms of reference of the Audit Committee.
(xxi) Reviewing management discussion and analysis of financial condition and results of operations;
(xxii) Reviewing statement of significant related party transactions (as defined by the audit committee), submitted by management;
(xxiii) Reviewing management letters / letters of internal control weaknesses issued by the statutory auditors;
(xxiv) Reviewing internal audit reports relating to internal control weaknesses;
(xxv) Reviewing the appointment, removal and terms of remuneration of the chief internal auditor shall be subject to review by the
audit committee;
(xxvi) Reviewing statement of deviations:
a) Quarterly statement of deviation(s) including report of monitoring agency, if applicable, submitted to stock exchange(s) in
terms of Regulation 32(1).
b) Annual statement of funds utilized for purposes other than those stated in the offer document/prospectus/notice in terms
of Regulation 32(7).
During the year under review, five (5) AC meetings were held and the intervening gap between two consecutive meetings did not exceed
one hundred and twenty (120) days. The dates on which the said meetings were held are 07.05.2021, 12.07.2021, 03.09.2021, 22.10.2021
and 24.01.2022. Necessary quorum was present at all the meetings.
The composition of the AC and number of meetings attended by the members during the year are given below:
Name of Chairperson & Members Category Meetings Attended

Sh. Ajit Singh Chatha, Chairman Independent Non–Executive Director 5
Sh. Shashi Bhushan Gupta, Member Independent Non–Executive Director 4
Sh. Virander Kumar Arya, Member Independent Non- Executive Director 5
Sh. Manohar Lal Jain, Member Non Independent Executive Director 5
Sh. Shaman Jindal, Company Secretary acts as the Secretary of Audit Committee.
The previous Annual General Meeting of the Company was held on 30.09.2021 and was attended by Sh. Ajit Singh Chatha, Chairman of
AC.
II. NOMINATION AND REMUNERATION COMMITTEE
The Nomination and Remuneration Committee (NRC) of the Company is constituted in line with the provisions of Regulation 19 of SEBI
Listing Regulations, read with Section 178 of the Act and Rules framed thereunder.
The Board of Directors in its meeting held on 13.05.2022 has amended the terms of reference of the NRC in line with the SEBI Listing
Regulations, as amended, which includes the following: -
(i) Formulation of the criteria for determining qualifications, positive attributes and independence of a director and recommend to the
Board of Directors a policy relating to the remuneration of the directors, key managerial personnel and other employees;
(ii) For every appointment of an independent director, the Nomination and Remuneration Committee shall evaluate the balance of skills,
knowledge and experience on the Board and on the basis of such evaluation, prepare a description of the role and capabilities
required of an independent director. The person recommended to the Board for appointment as an independent director shall have
the capabilities identified in such description. For the purpose of identifying suitable candidates, the Committee may:
a) use the services of an external agencies, if required;
b) consider candidates from a wide range of backgrounds, having due regard to diversity; and
c) consider the time commitments of the candidates.
(iii) Formulation of criteria for evaluation of performance of Independent Directors and the Board of Directors;
(iv) Specify the manner for effective evaluation of performance of Board, it’s committees and individual directors to be carried out either
by the Board, by the NRC or by an independent external agency and review its implementation and compliance;
46
(v) Devising a policy on diversity of board of directors;
(vi) Identifying persons who are qualified to become directors and who may be appointed in senior management in accordance with the
criteria laid down, and recommend to the Board of Directors their appointment and removal;
(vii) Whether to extend or continue the term of appointment of the independent director, on the basis of report of performance evaluation
of independent directors.
(viii) Recommend to the board, all remuneration, in whatever form, payable to senior management.
(ix) Carrying out any other function as is mandated by the Board from time to time and/or enforced by any statutory notification, amendment
or modification, as may be applicable.
As per the criteria laid down in the Nomination and Remuneration Policy of the Company, the NRC has carried out the evaluation of
performance of Board, it’s committees and individual directors. Further the Board of Directors have also carried out the evaluation of the
Board as a whole, its committees, Chairman of the Board and all the Individual and Independent Directors on the Board. The details of which
are given in Board’s Report that forms part of this Annual Report.
During the year under review, three (3) meetings of NRC were held, i.e. on 20.04.2021, 01.07.2021, and 16.08.2021. Necessary quorum
was present at all the meetings.
The composition of the NRC and number of meetings attended by the members during the year are given below:
Name of Chairperson & Members Category Meetings attended

Sh. Ajit Singh Chatha, Chairman Independent, Non-Executive Director 3
Sh. Surinder Singh Virdi, Member Independent, Non-Executive Director 3
Sh. Virander Kumar Arya, Member Independent, Non-Executive Director 3
Sh. Shaman Jindal, Company Secretary acts as the Secretary of Nomination & Remuneration Committee.
NRC.
Performance evaluation criteria for Independent Directors
The NRC evaluates the performance of Independent Directors on the basis of the following criteria:
• Qualifications
• Experience
• Knowledge and Competency
• Fulfillment of functions and integrity including adherence to Code of Conduct and Code of Independent Directors of the Company,
safeguarding of the Confidential information and of interest of Whistle Blowers under Vigil Mechanism, compliance with policies and
disclosures of interest and fulfillment of other obligations imposed by the Law
• Contribution and Initiative
• Availability, attendance, participation and ability to function as a team
• Commitment
• Independence
• Independent views and judgement and Guidance/support to Management outside board
On the basis of the report of the performance evaluation of Independent Directors, the NRC determines whether to extend or continue the
terms of appointment of Independent Directors.
Nomination and Remuneration Policy:
The Nomination and Remuneration Policy (“Policy”) is formulated by the NRC and approved by the Board of Directors of the Company. The
Policy of the Company as duly amended has been uploaded on the website of the Company under the web link http://sswlindia.com/wp-
content/themes/sswl/assets/docs/nomination.pdf
The Policy of the Company is designed to create a high performance culture. It enables the Company to attract, retain and motivate
employees to achieve results. The guiding principle of the Policy is that the level and composition of remuneration shall be reasonable and
sufficient to attract, retain and motivate Directors, Key Managerial Personnel and Senior Management.
NRC determines and recommends to the Board for approval, individual remuneration packages for Executive Directors, KMPs and Senior
Management of the Company on the basis of the scope of their duties, the role and nature of responsibilities, the level of skill, knowledge and
experience of individual, their performance, business performance and practices in comparable companies, having due regard to financial
and commercial health of the company as well as prevailing laws and regulations/other guidelines.
Remuneration may comprise of fixed component only or combination of both fixed and variable component. Fixed component may include
salary, allowances, perquisites and other statutory/non-statutory benefits. The NRC may in its discretion structure any portion of remuneration
to link rewards to corporate and individual performance, fulfillment of specified improvement targets or the attainment of certain financial or
other objectives set by the Board. The amount payable is determined by the NRC, based on performance against pre-determined financial
and non-financial metrics.
47
Remuneration to Managing Director of the Company may comprise both fixed as well as variable components including commission by way
of certain percentage on Net profit of the Company as calculated under Section 198 of the Act.
REMUNERATION OF DIRECTORS
(i) Remuneration to Managing Director and Executive Director
During the financial year 2021-22, the Company has paid remuneration by way of salary, benefits, perquisites and allowances (fixed
component) and commission @ 5% on Net Profit of the company as calculated under Section 198 of the Act, inclusive of fixed component
of the salary (variable component) to its Managing Director.
The Company pays remuneration to its Executive Directors by way of salary, benefits, perquisites and allowances (fixed component only).
Annual Increments are decided by the NRC within the salary scale approved by the members of the Company and on the basis of the
performance of the Managing Director and Executive Directors, business performance and practices in comparable companies, having due
regard to financial and commercial health of the company as well as prevailing laws and regulations/other guidelines.
Details of Remuneration paid to Managing Director (MD), Deputy Managing Director (Dy. MD) and Executive Director (ED) during
the financial year 2021-22:
(Rs. in lakhs)
Particulars Sh. Dheeraj Garg, MD Sh. Andra Veetil Sh. Manohar Lal Jain, ED
Unnikrishnan, (Dy. MD), ED
Basic Salary 480.00 41.76 42.60
House Rent Allowance Nil 14.62 14.91
Special Allowance Nil 15.00 2.87

Medical allowance Nil Nil 0.15
Reimbursement of Medical expenses Nil 0.09 Nil
Perquisites Nil Nil Nil
Contribution to Provident Fund 57.60 5.01 5.11
Commission 914.86 Nil Nil
Stock Options Nil 16.68 Nil
Total 1452.46 93.16 65.64
Date of Original appointment 29/04/1993 01/01/2009 01/08/2013
Date of Appointment/Re-appointment 01/06/2020 01/01/2019 01/07/2020
Tenure Up to 31/05/2023 31/12/2023 30/06/2023
(ii) Remuneration to Non-Executive Directors
The Non- Executive Directors are entitled to get sitting fees for attending the Board Meeting and Audit Committee Meeting. Sitting fees to the
Non-Executive Directors for attending each Board Meeting was Rs. 20,000/- and for attending each Audit Committee Meeting, the sitting fee
was Rs. 10,000/-. The Company also reimburses the out of pocket expenses incurred by Directors for attending the meetings.
There has been no pecuniary relationship or transactions except the entitlement to the dividend declared by the company on the shares held
by them, if any, and/or the payment of sitting fees to the Non-Executive Directors for attending the Board and Audit Committee Meetings of
the Company during the year under review.
Further, on the recommendation of NRC at its meeting held on 20.04.2022, the Board of Directors at its meeting held on 13.05.2022 had
approved to enhance the sitting fees to be paid to Non-Executive Directors for attending each Board Meeting from existing amount of
Rs. 20000/- to Rs. 50000/-. The sitting fees for attending each Audit Committee meeting remains unchanged as Rs. 10000/-.
Details of sitting fee paid to the Non-Executive Directors during the financial year 2021-22 are as follows:-
Name of Director Dates on which Board Meetings were held Sitting fee
(in Rs.)
07.05. 2021 12.07. 2021 03.09.2021 06.09.2021 22.10. 2021 24.01.2022
Sh. Rajinder Kumar Garg √ √ √ √ √ √ 1,20,000

Sh. Sanjay Garg √ √ - - √ √ 80,000
Smt. Deva Bharathi Reddy √ √ - √ √ √ 1,00,000
Sh. Virander Kumar Arya √ √ √ - √ √ 1,00,000
Sh. Ajit Singh Chatha √ √ √ - √ √ 1,00,000
Sh. Shashi Bhushan Gupta √ √ - √ √ √ 1,00,000
Sh. Surinder Singh Virdi √ - √ - √ - 60,000
Sh. Siddharth Bansal √ √ - √ √ - 80,000
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Name of Directors Dates on which Audit Committee Meetings were held Sitting fee
07.05.2021 12.07.2021 03.09.2021 22.10.2021 24.01.2022 (in Rs.)
Sh. Ajit Singh Chatha √ √ √ √ √ 50,000
Sh. Virander Kumar Arya √ √ √ √ √ 50,000
Sh. Shashi Bhushan Gupta √ √ - √ √ 40,000
Sh. Sanjay Surajprakash Sahni, a Non Executive Director of the Company, nominated by Tata Steel Limited (Equity Investor), is not entitled
to get any sitting fee for attending the Board Meeting of the Company, as per the policy of Tata Steel Limited.
Service Contracts, notice period, severance fees:
Sh. Dheeraj Garg was re-appointed as Managing Director from 01.06.2020 till 31.05.2023, is liable to retire by rotation and his status
continues.
Sh. Andra Veetil Unnikrishnan was re-appointed as an Executive Director (Deputy Managing Director) for a term beginning from 01.01.2019
till 31.12.2023 is liable to retire by rotation and his status continues.
Sh. Manohar Lal Jain was re-appointed as an Executive Director from 01.07.2020 till 30.06.2023, is liable to retire by rotation and his status
continues.
The appointment of Managing Director and Executive Director/Whole-time Director(s) is governed by the Articles of Association of the
Company, the resolutions passed by the Board of Directors and members/ shareholders of the Company.
Services of the Managing Director and Executive Director may be terminated by either party by giving one month notice. There is no
provision for payment of severance fee.
Notice period/severance fee is not applicable to Non-Executive/ Independent Directors of the Company.
Details of Stock Options issued/granted to the Directors:
During the year under review, the Company has not issued/granted stock options to any of its Executive Directors/ Independent/Nominee/
Non-Executive Directors.
III. STAKEHOLDERS RELATIONSHIP COMMITTEE
The Stakeholders’ Relationship Committee (SRC) is constituted in line with the provisions of Regulation 20 of SEBI Listing Regulations read
with Section 178 of the Act and Rules framed thereunder (including any amendments thereof).
The broad terms of reference of the SRC are as under:
(i) To consider and resolve the grievances of the security holders of the Company including complaints related to transfer/transmission
of shares, non-receipt of annual report, non-receipt of declared dividends, issue of new/duplicate certificates, general meetings etc.;
(ii) To review measures taken for effective exercise of voting rights by shareholders;
(iii) To review adherence to the service standards adopted by the Company in respect of various services being rendered by the Registrar
& Share Transfer Agent;
(iv) To review the measures and initiatives taken by the Company for reducing the quantum of unclaimed dividends and ensuring timely
receipt of dividend warrants/annual reports/statutory notices by the shareholders of the Company.
During the year, one meeting of SRC was held on 20.04.2021 and necessary quorum was present at the said Committee meeting.
The composition of the SRC and number of meetings attended by the members during the year are given below:
Name of Chairperson & Members Category Meetings attended
Sh. Ajit Singh Chatha, Chairman Independent, Non-Executive Director 1
Sh. Manohar Lal Jain, Member Non-Independent, Executive Director 1
Sh. Shaman Jindal, Company Secretary acts as the Secretary of Stakeholders’ Relationship Committee.
SRC.
The Company addresses all complaints, suggestions and grievances expeditiously and replies are sent/ issues resolved usually within 15
days unless there is a dispute or other legal constraint.
(i) Name, Designation, Address & E-mail of Compliance Officer:
Sh. Manohar Lal Jain, Executive Director
Sh. Shaman Jindal, Company Secretary
Corporate Office: S C O 49-50, Sector – 26, Madhya Marg, Chandigarh.
Telephone No. 0172- 2793112, 2792385
E-mail: [email protected]
[email protected]
49
(ii) Detail of shareholder’s complaints received and redressed:
Opening Balance Received during the year Resolved during the year Closing Balance
NIL 18 18 NIL
Compliance Certificates
In compliance to the provisions of Regulation 40(9) of the SEBI Listing Regulations as amended by the SEBI (Listing Obligations and
Disclosure Requirements) (Second Amendment) Regulations, 2021 (w.e.f. 05.05.2021), a yearly certificate has been issued as on March 31,
2022 by a Company Secretary in Practice, certifying due compliance of share transfer formalities by the Company. Further, the Company has
filed a copy of the said certificate simultaneously with the Stock Exchanges under Regulation 40(10) of the SEBI Listing Regulations.
Further, the compliance certificate under Regulation 7(3) of the SEBI Listing Regulations as amended by the SEBI (Listing Obligations
and Disclosure Requirements) (Second Amendment) Regulations, 2021 (w.e.f. 05.05.2021), duly signed by the compliance officer of the
Company and the authorized representative of the share transfer agent, confirming that all activities in relation to share transfer facility are
maintained by Registrar and Share Transfer Agent, registered with the Securities and Exchange Board of India, has been filed with the Stock
Exchanges on annual basis.
IV. Corporate Social Responsibility (CSR) Committee
Corporate Social Responsibility Committee (CSR) is constituted in concurrence with the provisions of Section 135 of the Companies Act,
2013 and rules framed thereunder.
Terms of reference of the CSR Committee includes:
• to formulate and recommend to the Board, a CSR Policy which shall indicate the activities to be undertaken by the company in areas
or subject specified in Schedule VII of the Companies Act, 2013;
• to recommend the amount of expenditure to be incurred on CSR activities;
• to monitor CSR Policy of the Company from time to time;
• discharge such duties and functions as indicated in the section 135 of the Companies Act, 2013 and Rules made thereunder from time
to time and such other functions as may be delegated to the Committee by the Board from time to time.
During the year under review, the CSR policy was amended in line with Companies (Corporate Social Responsibility Policy) Amendment
Rules, 2021 effective from 22nd January, 2021. Accordingly, the CSR Policy of the Company as duly amended has been uploaded on the
website of the Company under the web link https://sswlindia.com/wp-content/themes/sswl/assets/docs/csr-policy.pdf and the areas and
amount of expenditure incurred by the Company on CSR projects or programs during the financial year 2021-22 has been updated and is
available on the website of the Company.
During the year, five (5) meetings of CSR Committee were held, i.e. on 20.04.2021, 14.05.2021, 01.07.2021, 01.10.2021 and 03.01.2022.
Necessary quorum was present at all the CSR Committee meetings.
The Composition of the CSR Committee and details of the meetings attended by its members are given below: -

Sh. Surinder Singh Virdi, Chairman Independent, Non-Executive Director 5
Sh. Andra Veetil Unnikrishnan, Member Non Independent, Executive Director 5
Sh. Manohar Lal Jain, Member Non Independent, Executive Director 5
Sh. Shaman Jindal, Company Secretary acts as the Secretary of Corporate Social Responsibility Committee.
V. RISK MANAGEMENT COMMITTEE
The Company recognizes that Risk Management is an integral part of good management practice. Risk Management is an essential
element in achieving business goals and deriving benefits from market opportunities. Risk Management is attempting to identify and then
manage threats that could severely impact or bring down the organization. Generally, this involves reviewing operations of the organization,
identifying potential threats to the organization and the likelihood of their occurrence, and then taking appropriate actions to address the
most likely threats.
The Company has duly constituted a Risk Management Committee (RMC) in concurrence with the provisions of Regulation 21 of the SEBI
Listing Regulations. The Board of Directors in its meeting held on 12.07.2021 has amended the terms of reference of the RMC in line with
SEBI (Listing Obligations and Disclosure Requirements) (Second Amendment) Regulations, 2021 which includes the following:
• To formulate a detailed risk management policy which shall include:
a) A framework for identification of internal and external risks specifically faced by the listed entity, in particular including financial,
operational, sectoral, sustainability (particularly, ESG related risks), information, cyber security risks or any other risk as may be
determined by the Committee.
b) Measures for risk mitigation including systems and processes for internal control of identified risks.
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c) Business continuity plan.
• To ensure that appropriate methodology, processes and systems are in place to monitor and evaluate risks associated with the
business of the Company;
• To monitor and oversee implementation of the risk management policy, including evaluating the adequacy of risk management
systems;
• To periodically review the risk management policy, at least once in two years, including by considering the changing industry dynamics
and evolving complexity;
• To keep the board of directors informed about the nature and content of its discussions, recommendations and actions to be taken;
• The appointment, removal and terms of remuneration of the Chief Risk Officer (if any) shall be subject to review by the Risk Management
Committee.
Also, the RMC shall coordinate its activities with other committees, in instances where there is any overlap with activities of such committees,
as per the framework laid down by the board of directors.
During the year two (2) meetings of RMC were held i.e. on 05.07.2021 & 01.01.2022 and the intervening gap between the two consecutive
meetings did not exceed one hundred and eighty (180) days. Necessary quorum was present at the said meetings.
The Composition of the RMC and details of the meetings attended by its members are given below: -

Sh. Shashi Bhushan Gupta, Chairman Independent, Non- Executive Director 2
Sh. Shaman Jindal, Company Secretary acts as a Company Secretary of the Risk Management Committee.
VI. EMPLOYEE COMPENSATION COMMITTEE
The Company has constituted Employee Compensation Committee (ECC) to formulate detailed terms and conditions of the ESOP plan
which, inter alia includes:
i. The quantum of options to be offered and granted per employee and in aggregate under ESOS Scheme(s) to employee;
ii. The conditions under which options may vest in employees and may lapse in case of termination of employment for misconduct;
iii. The exercise period within which the employee can exercise the options and that options would lapse on failure to exercise the same
within the exercise period;
iv. The specified time period within which the employee shall exercise the vested options in the event of termination or resignation of an
employee;
v. The right of an employee to exercise all the options vested in him at one time or at various points of time within the exercise period;
vi. The procedure for making fair and reasonable adjustment to the entitlement including adjustment to the number of options and to
the exercise price in case of corporate actions such as rights issues, bonus issues, split or sub-division, merger, sale of division and
others;
vii. The grant, vesting and exercise of options in case of employees who are on long leave;
viii. The procedure for funding the exercise of options;
ix. Any other matter, which may be relevant for administration of ESOS schemes from time to time.
During the year, two (2) meetings of ECC were held i.e. on 18.08.2021 and 30.11.2021. Further, necessary quorum was present at both the
meetings.
The Composition of the ECC and details of the meetings attended by its members are given below: -

Sh. Surinder Singh Virdi, Chairman Independent, Non- Executive Director 2
Sh. Virander Kumar Arya, Member Independent, Non- Executive Director 2
Sh. Shashi Bhushan Gupta, Member Independent, Non- Executive Director 2
Sh. Shaman Jindal, Company Secretary acts as the Secretary of Employee Compensation Committee.
VII. SHARE TRANSFER COMMITTEE
The Share Transfer Committee (STC) approves and expedites the process of share transfers, issue of share certificate pursuant to
duplicate/remat/renewal requests as and when received by the company. The STC met ten (10) times during the year i.e. on 08.06.2021,
15.07.2021, 16.08.2021, 14.10.2021, 22.10.2021, 08.11.2021, 12.11.2021, 22.11.2021, 30.11.2021 and 25.03.2022. The necessary
quorum was present at all the meetings. No transfer of shares and no request for de-mat of shares is pending. All the shares received
for transfer have been transferred within the time period prescribed. The composition of STC and details of the meeting attended by its
members are given below: -
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Sh. Virander Kumar Arya, Chairman Independent, Non–Executive Director 10
Sh. Manohar Lal Jain, Member Non-Independent, Executive Director 10
Sh. Andra Veetil Unnikrishnan, Member Non-Independent, Executive Director 10
Sh. Shaman Jindal, Company Secretary acts as a Secretary of the Share Transfer Committee.
VIII. FINANCE COMMITTEE
The Board of Directors of the Company has constituted a Finance Committee (FC) and delegated its below mentioned powers to the FC:
i) to borrow funds, not exceeding Rs. 2000.00 crores and also to create security on the assets of the Company;
ii) to open, close and authorize various officials of the Company to operate various bank accounts (Current/Cash Credit) of the Company;
iii) to manage exchange rate and interest rate exposures of the Company through entering into transactions with various banks such as
Foreign Exchange Cash, Tom, Spot and Forward Contracts, Currency Swaps including Cross-Currency Swaps, Interest Rate Swaps
and Forward Rate Agreements, Permitted/Structured derivative products and any other Product which is permitted under the extant
regulatory guidelines by RBI.
During the year, twelve (12) meetings of the FC were held i.e. on 20.04.2021, 19.05.2021, 21.05.2021, 27.05.2021, 24.06.2021, 08.07.2021,
21.09.2021, 11.10.2021, 18.10.2021, 29.11.2021, 20.12.2021, and 31.12.2021. Necessary quorum was present at all the Finance Committee
Meetings.
The composition of the FC and details of the meetings attended by its members are given below:

Sh. Dheeraj Garg, Chairman Non Independent, Executive Director 12
The Board of Directors of the Company at its meeting held on 13.05.2022 has duly re-constituted the Finance Committee with immediate
effect with following members: -
Name of Chairperson & Members Category

Sh. Andra Veetil Unnikrishnan, Chairman Non Independent, Executive Director
Sh. Manohar Lal Jain, Member Non Independent, Executive Director
Sh. Sanjay Garg, Member Non Independent, Non-Executive Director
Sh. Shaman Jindal, the Company Secretary acts as the Secretary of Finance Committee.
IX. ALLOTMENT COMMITTEE
The Company has an Allotment Committee of the Board of Directors of the Company for allotment of shares to the employees of the
Company who have exercised the stock options granted to them under Employee Stock Option Scheme(s) of the Company.
During the year, no meeting of the Allotment Committee was held.
The composition of the Allotment Committee is given below:
Name of Chairperson & Members Category

Sh. Dheeraj Garg, Chairman Non Independent, Executive Director
Sh. Surinder Singh Virdi, Member Independent, Non–Executive Director
Sh. Virander Kumar Arya, Member Independent, Non–Executive Director
Sh. Shaman Jindal, the Company Secretary acts as the Secretary of Allotment Committee.
Independent Directors Meeting
Independent Directors are regularly updated on performance of the business of the Company, strategy going forward and new initiatives
being taken/proposed to be taken by the Company. The Independent Directors i.e. Sh. Ajit Singh Chatha, Sh. Surinder Singh Virdi,
Sh. Shashi Bhushan Gupta, Sh. Virander Kumar Arya, Sh. Siddharth Bansal and Smt. Deva Bharathi Reddy met on 21.03.2022 without the
attendance of Non-Independent Directors and members of Management of the Company and inter alia:
• reviewed the performance of Non-Independent Directors and the Board of Directors as a whole;
• reviewed the performance of the Chairperson of the Company, taking into account the views of Executive Directors and Non- Executive
Directors; and
• assessed the quality, quantity and timeliness of flow of information between the management of the company and the Board of
Directors that is necessary for the Board of directors to effectively and reasonably perform their duties.
52
GENERAL BODY MEETINGS
 GENERAL MEETING
(a) Annual General Meeting (“AGM”)
Date and venue of last three Annual General Meetings:
Details of Meeting Date of Meeting Time of Meeting Venue of Meeting
(Financial year)
33rd Annual General Meeting 30.09.2019 11.00 A.M Village Somalheri/Lehli, P. O. Dappar, Tehsil Derabassi, Distt.
(2018-19) S.A.S, Nagar Mohali, Punjab, 140506
34th Annual General Meeting 30.09.2020 3.30 P.M AGM was held through Video Conferencing (VC) /Other Audio
(2019-20) Visual Means (OAVM) at the deemed venue i.e. the Registered
Office of the Company at Village Somalheri/Lehli P.O. Dappar,
Tehsil Derabassi, Distt. S.A.S, Nagar Mohali, Punjab, 140506
35th Annual General Meeting 30.09.2021 11.00 A.M Village Somalheri/Lehli, P. O. Dappar, Tehsil Derabassi, Distt.
(2020-21) S.A.S, Nagar Mohali, Punjab, 140506
(b) Extraordinary General Meeting (EGM)
No extraordinary general meeting of the members of the Company was held during the financial year 2021-22.
(c) Special Resolution passed in the previous three Annual General Meetings
At the AGM held on 30.09.2021, five (5) special resolutions were passed as follows:
(i) To approve the continuation of Directorship of Sh. Rajinder Kumar Garg (DIN: 00034827), as Chairman and Non-Executive Director
of the Company.
(ii) To approve revision in the remuneration of Sh. Dheeraj Garg (DIN: 00034926), Managing Director of the Company
(iii) To approve revision in the remuneration of Sh. Manohar Lal Jain (DIN: 00034591), Executive Director of the Company
(iv) To approve to introduce and implement “Steel Strips Wheels Limited- Employee Stock Option Scheme 2021” (“ESOS 2021”) to create,
issue, offer and grant Stock Options to Employees of the Company exercisable into equal number of equity shares
(v) To adopt new set of Articles of Association of the Company containing regulations in conformity with the Companies Act, 2013
At the AGM held on 30.09.2020, two (2) special resolutions were passed as follows:
(i) To re-appoint Sh. Dheeraj Garg, (DIN: 00034926), as Managing Director of the Company for a period of 3 years w.e.f 01.06.2020
(ii) To re-appoint Sh. Manohar Lal Jain (DIN:00034591) as Executive Director of the Company for a period of 3 years w.e.f 01.07.2020
At the AGM held on 30.09.2019, two special resolutions were passed as follows:
(i) To appoint Sh. Ajit Singh Chatha (DIN: 02289613) as Non-Executive Independent Director of the Company for a period of 5 years
w.e.f 01.10.2019
(ii) To appoint Sh. Surinder Singh Virdi (DIN: 00035408) as Non-Executive Independent Director of the Company for a period of 5 years
w.e.f 01.10.2019
 Postal Ballot
(a) No Postal Ballot was conducted during the financial year 2021-22.
(b) None of the business proposed to be transacted at the ensuing AGM requires passing of the special resolution through postal ballot.
MEANS OF COMMUNICATION
The Company recognizes the importance of two-way communication with Shareholders and of giving a balanced reporting of results and
progress. Timely disclosure of consistent, comparable, relevant and reliable information on corporate financial performance is at the core of
good governance. Towards this end, major steps taken are as under:
Financial Results: The quarterly, half-yearly and yearly financial results of the company are generally published in two newspapers i.e.
‘Financial Express’ & ‘Desh Sewak’ and are also submitted to the stock exchanges within the statutory time period from the conclusion of the
Board Meeting(s) at which these are considered and approved.
Other Information: The Company discloses to the stock exchanges, all information required to be disclosed under Regulation 30 read with
Part ‘A’ and Part ‘B’ of Schedule III of the SEBI Listing Regulations including material information having a bearing on the performance/
operations of the Company and other price sensitive information. All information is filed electronically on the online portal of BSE Limited –
Corporate Compliance & Listing Centre (BSE Listing Centre) and on the online portals of National Stock Exchange of India Limited – NSE’s
Electronic Application Processing System (NEAPS) and NSE’s Digital Exchange Platform.
Website: The Company’s website https://sswlindia.com/ contains a separate section “Investors” where information for shareholders is
available. The Quarterly/Annual Financial Results, annual reports, analysts presentations, investor forms, stock exchange information,
shareholding pattern, corporate governance, corporate benefits, polices, investors’ contact details, updated credit ratings, etc., are posted on
the website in addition to the information stipulated under Regulation 46 of the Securities and Exchange Board of India (Listing Obligations
and Disclosure Requirements) Regulations, 2015.
Analyst/Institutional Investors Presentations: All the official news released and presentations made to analysts/institutional investors,
submitted by the Company to the stock exchanges are also displayed on the website of the Company. Further, the audio recordings and
53
transcripts of post earnings/quarterly calls are also submitted to the stock exchanges and uploaded on the website of the Company with
effect from 01.04.2022 in accordance with SEBI Listing Regulations.
GENERAL SHAREHOLDER INFORMATION
(i) Annual General Meeting for FY 2021-22
Date 30.09.2022
Time 11:00 A.M.
Mode & Venue Through Physical Mode At the Registered Office i.e. Village Somalheri/ Lehli,
P.O. Dappar, Teh. Derabassi, Distt. S.A.S. Nagar (Mohali), Punjab-140506
(ii) Financial Year 1st April to 31st March
(iii) Year Ending 31.03.2022
(iv) Financial Calendar (tentative) for Results for
Quarter ending June 2022 3rd week of July, 2022
Quarter ending September 2022 3rd week of October, 2022
Quarter ending December 2022 3rd week of January, 2023
Quarter ending March 2023 3rd week of May, 2023
(v) Book Closure date 24.09.2022 to 30.09.2022 (both days inclusive)
(vi) Dividend Payment date On or before 30.10.2022 (Subject to the approval of shareholders)
(vii) Name and Address of Stock Exchange at which (a) BSE Ltd. (BSE), Department of Corporate Services, Phiroze Jeejeebhoy
Company’s securities are Listed Towers, Dalal Street, Mumbai-400001
(b) National Stock Exchange of India Limited (NSE), Exchange Plaza, Plot
No. C/1, G Block, Bandra-Kurla Complex, Bandra (E), Mumbai-400051
(viii) Listing fee The Company has paid listing fees to both the aforesaid stock exchanges
and there is no outstanding payment as on date.
(ix) Stock Code
BSE Ltd. (BSE) 513262
National Stock Exchange of India Limited (NSE) SSWL
(x) ISIN No. of the Company’s shares in De-mat form INE802C01025 (with NSDL and CDSL)
(xi) Stock Market Price Data
Market Price Data: Monthly High and Low quotations on BSE Ltd. (BSE) and the National Stock Exchange of India Limited (NSE)
during each month in last financial year were as under:
BSE Limited (BSE) National Stock Exchange of India Limited (NSE)
Actual Re-stated Actual Re-stated
Month High (Rs.) Low (Rs.) High (Rs.) Low (Rs.) High (Rs.) Low (Rs.) High (Rs.) Low (Rs.)
April, 2021 758.00 644.90 379.00 322.45 753.50 645.00 376.75 322.50
May, 2021 830.00 625.00 415.00 312.50 830.00 694.85 415.00 347.43
June, 2021 860.10 726.70 430.05 363.35 862.00 725.00 431.00 362.50
July, 2021 1383.35 841.00 691.68 420.50 1375.20 840.35 687.60 420.18
August, 2021 1968.00 1368.45 984.00 684.23 1958.40 1370.00 979.20 685.00
September, 2021 1990.00 1640.00 995.00 820.00 1940.00 1670.00 970.00 835.00
October, 2021 1945.00 1705.10 972.50 852.55 1928.00 1700.00 964.00 850.00
November, 2021* 1884.80 741.85 942.40 741.85 1875.00 738.15 937.50 738.15
December, 2021* 917.00 710.00 917.00 710.00 917.35 704.00 917.35 704.00
January, 2022* 891.15 678.60 891.15 678.60 895.00 676.70 895.00 676.70
February, 2022* 825.75 690.00 825.75 690.00 823.75 702.35 823.75 702.35
March, 2022* 845.75 716.10 845.75 716.10 847.00 716.10 847.00 716.10
*Each equity share of the Company of face value Rs. 10/- has been sub-divided into two (2) equity shares of Rs. 5/- each w.e.f. 22.11.2021
(the record date for sub-division)
(xii) Performance of Share price of the Company in comparison to the BSE Sensex and NSE-Nifty 50:

Note: Each Equity Share of face value of Rs. 10/- of the Company has been sub divided into two (2) Equity Shares of Rs. 5/- each w.e.f
22.11.2021 and therefore, for meaningful comparison, the prices of Equity Shares traded at face value of Rs. 10/- has been restated to Rs.
5/-.
54
(xiii) The Company’s shares were not suspended from trading during the financial year under review.
(xiv) Registrar and Share Transfer Agents
Name and address: Link Intime India Pvt. Ltd.
Noble Heights 1st Floor,
Plot No. NH-2, C-1 Block,
LSC Near Savitri Market, Janakpuri,
New Delhi - 110058
Phone Number : 011-49411000, 41410592, 93, 94

Fax : 011-41410591
Email : [email protected]
Website : www.linkintime.co.in
(xv) Place for Acceptance of documents:
Documents will be accepted at:
(i) Link Intime India Pvt. Ltd.,
Noble Heights 1st Floor,
Plot No. NH-2, C-1 Block,
New Delhi – 110058
(ii) Steel Strips Wheels Limited, SCO 49-50, Sector 26, Madhya Marg, Chandigarh- 160019
(xvi) Share Transfer System
Trading in equity shares of the Company through recognized stock exchanges is permitted only in dematerialised form. Request for
transmission/dematerialisation of shares in physical form is normally processed within 12 to 15 days from the date of receipt if the documents
are complete in all respect.
As per Regulation 40 of SEBI Listing Regulations, as amended, securities of listed companies can be transferred only in dematerialised
form with effect from 1st April, 2019, except in case of request received for transmission or transposition and re-lodged transfers of securities.
Further, SEBI vide its circular no. SEBI/HO/MIRSD/RTAMB/CIR/P/2020/236 dated December 2, 2020 had fixed March 31, 2021 as the cut-
off date for re-lodgement of transfer deeds and the shares that are re-lodged for transfer shall be issued only in demat mode.
Further, SEBI vide its Circular No. SEBI/HO/MIRSD/MIRSD_RTAMB/P/CIR/2022/8 dated 25th January, 2022, has mandated all listed
companies to issue securities in dematerialized form only, while processing the service request of issue of duplicate securities certificate,
claim from Unclaimed Suspense Account, renewal/ exchange of securities certificate, endorsement, sub-division/splitting of securities
certificate, consolidation of securities certificates/folios, transmission and transposition. The manner and process of making application as
per the revised framework and operational guidelines thereto is available on the website of the RTA at https://linkintime.co.in/home-KYC.html
and the Company at http://sswlindia.com/investor/.
In view of the same and to eliminate all risks associated with physical shares and for ease of portfolio management, members holding shares
in physical form are advised to consider converting their holdings to dematerialised form. The Shareholders are accordingly requested to get
in touch with any Depository Participant having registration with SEBI to open a Demat account to seek guidance in the demat procedure.
Also members can contact the Company or RTA, for assistance in this regard.
Updation of PAN, KYC and Nomination details
SEBI vide its Circular No. SEBI/HO/MIRSD/MIRSD_RTAMB/P/CIR/2021/655 dated 3rd November, 2021 has mandated furnishing of PAN,
email address, mobile number, bank account details and nomination by holders of physical securities. Further SEBI has also instructed RTAs
to freeze folios on or after 1st April, 2023 wherein PAN, KYC details and Nomination are not available. The shareholders are requested to
update their details with Company/RTA by submitting form ISR-1 which is available on website of the Company at https://sswlindia.com/wp-
content/themes/sswl/assets/docs/Form-ISR-1.pdf.
The Company has sent individual letters to all the shareholders holding shares in physical form to furnish their PAN, KYC and Nomination
details. The relevant circular(s) and necessary forms in this regard have been made available on the website of the Company at http://
sswlindia.com/investor/ under the head ‘Investor Service Request’ and RTA’s website at https://linkintime.co.in/home-KYC.html. Members
are advised to register/update their details with the Company/RTA, in compliance with the said circular for smooth processing of their service
requests.
(xvii) Distribution of Shareholding
(a) Class-wise Distribution of Equity Shares as on 31.03.2022
Shares/Debentures Holding of Nominal Value Number of Shares % age of Total
Up to 500 2137910 6.85
501 - 1000 663554 2.13
1001 - 2000 627662 2.01
2001 - 3000 343608 1.10
3001 - 4000 173065 0.55
4001 - 5000 197826 0.63
5001 - 10000 515740 1.65
10001 and above 26559575 85.08
Total 31218940 100.00
55
(b) Shareholding Pattern as on 31.03.2022
S. No Particulars No. of Shares Percentage

1. Promoter and Promoter Group 19594804 62.77
2. Mutual Funds/UTI/Financial Institutions, Banks & Foreign Institutional 182326 0.58
Investors/Foreign Portfolio Investor/Alternative Investment Fund
3. Foreign Bodies Corporate 1700000 5.45
Indian Body Corporate 3624565 11.61
4. Individuals 5299168 16.97
5. Any other:
Non Residents 208184 0.67
Clearing Members 30075 0.10
HUF 155989 0.50
Trust 156 0.00
IEPF 413288 1.32
LLP 10385 0.03
Total 31218940 100.00
(xviii) Dematerialization of Shares and Liquidity
As on 31.03.2022, there were 27094 shareholders of the Company. Out of these 25529 shareholders were holding 30802514 (98.67%)
equity shares in the dematerialized form and rest of them i.e. 1565 shareholders were holding 416426 (1.33%) equity shares in
physical form. The non-promoters holding as on 31.03.2022 is 37.23% and the stock is liquid.
The Company’s scrip forms part of the compulsory demat segment for all investors and can only be traded in dematerialized form.
The Company has established connectivity with both the depositories viz. National Securities Depository Limited (NSDL) and Central
Depository Services (India) Limited (CDSL) through its Registrar and Share Transfer Agent i.e. M/s Link Intime India Private Limited
(LIIPL). The Company had also appointed LIIPL as common Agency to look after dematerialization of shares as well as for physical
transfer of shares.
(xix) Outstanding GDR/ADR or warrants or any convertible instruments, conversion date and likely impact on equity
As on 31.03.2022, the Company has no outstanding GDR/ADR or any other convertible instruments.
(xx) Corporate Identification No. : L27107PB1985PLC006159

(xxi) Plant Location : (a) Village Somalheri/ Lehli, P.O. Dappar, Tehsil Derabassi, District Mohali, Punjab, 140506
(b) Plot No. A-10, SIPCOT Industrial Growth Centre, Oragadam,
Vallam Village, Sriperumbudur, Tamil Nadu 602105
(c) Plot No. 733, 734,735, 747
Mouza Jojobera, P. O. & P. S. Chhota Govindpur East Singhbhum,
District Jamshedpur, Jharkhand, 831015
(d) Plot No. 77,78,136B,394, Village- Martoli/ Tejpura, Taluka – Jotana,
Dist. – Mehsana, Gujarat, India, 384430
(e) Village-Muria, P.O.- Kolabira Thana No.-150 Dist. Saraikela- Kharsawan, Jharkhand, 833220
(xxii) Address for Correspondence:
To the Registrar & Share Transfer Agents To the Company (Corporate Office)
Link Intime India Pvt. Ltd. Steel Strips Wheels Limited
Noble Heights 1st Floor, S.C.O 49-50, Sector 26, Madhya Marg,
Plot No. NH-2, C-1 Block, Chandigarh-160019
New Delhi - 110058 Phone No.: 0172- 2793112
Phone Number : 011-49411000, 41410592,93,94 Email ID : [email protected]
Fax Number : 011-41410591 : [email protected]
Email : [email protected] Contact Person : Sh. Manohar Lal Jain

Contact Persons : Sh. Swapan Kumar Naskar Sh. Shaman Jindal
(xxiii) The Company during the financial year 2021-22 obtained credit rating from India Ratings and Research Pvt. Ltd. (Ind-Ra) (a
100% owned subsidiary of Fitch Group) for credit facilities, the details of which are as follows:
Instrument Type Ratings by India Ratings and Research

Fund Based Working Capital Limits IND A-/Positive/IND A2+
Term Loans IND A-/Positive
Non-Fund Based Working Capital Limits IND A-/Positive/IND A2+
Proposed non-fund based working capital Limits IND A-/Positive/IND A2+
56
It has upgraded the Company’s Long Term Issuer Rating to ‘IND A-’ from ‘IND BBB+’ and the outlook is positive. The same is also
available on the Company’s website at https://sswlindia.com/investor/. The rating reflects the Company’s dominant market position in
India, long track record of successful operations, strong corporate governance practices, financial flexibility and conservative financial
policies.
DISCLOSURES
(i) Related Party Transactions
All contracts/arrangements/transactions entered into by the Company with related parties during the financial year 2021-22, were
in the ordinary course of business and on an arm’s length basis. The related party transactions undertaken by the company were
in compliance with the provisions set out in the Act, read with the rules issued thereunder and Regulation 23 of the SEBI Listing
Regulations. The details of the related party transactions are set out in the Notes to Financial Statement forming part of this Annual
Report.
During the financial year 2021-22, the Audit Committee has approved related party transactions along with granting omnibus approval
valid for a period not exceeding one year in line with the policy of the Company on materiality of Related Party Transactions and
dealing with related party transactions and the applicable provisions of the Act, read with the Rules issued thereunder and the SEBI
Listing Regulations (including any statutory modification (s) or re-enactment (s) thereof for the time being in force).
The Audit Committee reviews on a quarterly basis the detail of related party transactions entered into by the company pursuant to the
omnibus approval given. The Company had not entered into any materially significant related party transaction and none of the related
party transactions entered into have any potential conflict with the interest of the Company. The Policy on materiality of Related Party
Transactions and also on dealing with such Related Party Transactions as approved by the board of directors has been uploaded on
the Company’s website at https://sswlindia.com/wp-content/themes/sswl/assets/docs/relatedpartytransaction.pdf.
As per the SEBI Listing Regulations, the Company has also submitted the disclosures of Related Party transactions to the Stock
Exchanges in the prescribed format and also published it on the website of the Company.
(ii) No penalties, strictures were imposed on the Company by Stock Exchanges or SEBI, or any other statutory authority, on any matter
related to capital markets, during the last three years.
(iii) The Company has established the Vigil Mechanism/Whistle Blower Policy of the Company in line with the Section 177(9) & (10) of the
Act and in accordance with Regulation 22 of SEBI Listing Regulations and other applicable SEBI Regulations, enabling employees to
report insider trading violations as well as reporting of instances of leak of Unpublished Price Sensitive Information and has established
the necessary vigil mechanism for directors and employees to report their genuine concerns. No personnel have been denied access
to the audit committee. This mechanism provides for adequate safeguards against victimization of director (s) /employee (s) or any
other person, who avail the said mechanism and also provides for direct access to the Chairman of the audit committee in exceptional
cases. The policy with the name and address of the Chairman of the Audit Committee has been communicated to the employees by
uploading the same on the website of the Company. The employees can directly contact the Chairman of the Audit Committee on the
email address as mentioned in the ‘Vigil Mechanism/Whistle Blower Policy’ uploaded on the Company’s website at https://sswlindia.
com/wp-content/themes/sswl/assets/docs/whistleblower.pdf. During the financial year 2021-22, the Company has not received any
instances of genuine concerns from Directors or employees.
(iv) In accordance with the SEBI Circular dated February 8, 2019 read with Regulation 24A of the SEBI Listing Regulations, the Company
has obtained an Annual Secretarial Compliance Report from M/s. S.K Sikka & Associates, Practicing Company Secretaries, confirming
compliances with all applicable SEBI Regulations, Circulars and Guidelines for the year ended March 31, 2022.
(v) The Company has complied with all the mandatory requirements specified in Regulations 17 to 27 and clauses (b) to (i) and (t) of
Regulation 46(2) of the SEBI Listing Regulations.
(vi) The Company has complied with all the mandatory requirements as applicable to it along with the compliance with the requirements
of Part C (sub paras 2 to 10) of Schedule V of the SEBI Listing Regulations.
(vii) Details of adoption of the non-mandatory requirement as specified in Part E of Schedule II:
(a) The Non-Executive Chairman of the company has been provided a Chairman’s office at the corporate office of the Company at
Company’s expenses and also allowed reimbursement of expenses incurred in performance of his duty.
(b) During the year under review, there is no audit qualification on the Company’s financial statement. The Company continues to
adopt best practice to ensure regime of financial statements with unmodified audit opinion.
(c) The Internal Auditor of the Company has direct access to the Audit Committee and presents his internal audit report to the Audit
Committee.
(viii) The Senior Management of the Company have made disclosures to the Board of Directors confirming that no material, financial and
commercial transactions, have been entered into by them with the Company, where they have personal interest, which could have
potential conflict of interest with the Company at large.
(ix) The Company has not adopted any alternative accounting treatment prescribed differently from the Accounting Standard (AS)/ Indian
Accounting Standard (IND AS) laid down by the Institute of Chartered Accountants of India (ICAI) in preparation of its financial
statements.
57
(x) Risk Management: The Company has Risk Management Committee for the risk assessment and to decide on minimization
procedures. These procedures are periodically reviewed by the Risk Management Committee to ensure that executive management
controls risk through means of a properly defined framework.
(xi) Disclosure on Commodity Price Risk or Foreign Exchange Risk and Hedging Activities:
The Company is in the business of manufacture of wheel rims. Steel and Aluminum being the primary raw material is the key to
Company’s profitability. Presently the Company imports some of the raw material and that impacts the profitability due to adverse
currency movement. The Company is already taking steps to indigenize the imported raw material by developing it with Indian vendors
and de-risking the business model.
As regards foreign exchange risk, a significant portion of the Company’s inflows and outflows are in foreign currency, the exchange
rate fluctuations between the Indian rupee and the foreign currency affects the company’s results of operation. Therefore, keeping
in view the position of rupee vis-à-vis foreign currency, the Company has been assertive in taking forward cover for exports and
imports.
The Company regularly informs the Board of Directors about the risk assessment, if any, along with recommendations to reduce the risk.
Exposure of the listed entity to commodity and commodity risks faced by the entity throughout the year:
a. Total exposure of the listed entity to commodities in INR:
The Value of total inventory held by the Company for Raw Material, Work in Progress and Finished Goods (including stock in
trade) as on 31.03.2022 was Rs. 528.60 crores.
b. Exposure of the listed entity to various commodities:
Commodity Exposures in INR Exposures in qty % of such exposure hedged through commodity derivatives
Name (Crores) towards (MT) terms towards Domestic Market International Market TOTAL
(Inventory as the Particular the Particular
OTC EXCHANGE OTC EXCHANGE
on 31.03.2022) Commodity Commodity
Raw Material 398.59 55194.54 NIL NIL NIL NIL NIL
Work in Progress 54.38 6420.40 NIL NIL NIL NIL NIL
Finished Goods 68.88 7357.08 NIL NIL NIL NIL NIL
Scrap 6.75 1228.43 NIL NIL NIL NIL NIL
Misc. Stocks 0.00 0.00 NIL NIL NIL NIL NIL
c. Commodity risks faced by the listed entity during the year and how they have been managed:
The commodity prices are determined through basic supply and demand factors in the marketplace. However, Company is fairly
insulated from any impact of adverse move in commodity prices due to provision of clean pass through of price fluctuations
to our customers. Further one of the key supplier of the main commodity that we consume (Steel) also happens to be our
stakeholder thereby alleviating any risk with respect to availability of raw material.
(xii) During the year, the Company has not raised any funds through preferential allotment or qualified institutional placement as specified
under regulation 32(7A) of the SEBI Listing Regulations.
(xiii) A certificate has been received by the Company from M/s S.K. Sikka and Associates, Practicing Company Secretaries, that none
of the Directors on the Board of the Company has been debarred or disqualified from being appointed or continuing as directors of
companies by the Securities and Exchange Board of India, Ministry of Corporate Affairs or any such statutory authority(ies). (Annexed
herewith as part of report)
(xiv) There have been no instances in the Company, where the board has not accepted any recommendation of any committee of the board
which is mandatorily required, during the financial year 2021-22.
(xv) M/s AKR & Associates, Chartered Accountants (ICAI Firm Registration No. 021179N) have been appointed as the Statutory Auditors
of the Company. The particulars of payment of Statutory Auditors’ fees for carrying out audit of the financial year 2021-22, is given
below:
(Rs. In Lakhs)
Particulars Amount
Statutory Audit Fee 7.00
Tax Audit Fee 2.00
Certificate charges 2.00
(xvi) The Company has zero tolerance for sexual harassment at workplace and has adopted a policy on prevention, prohibition and
redressal of sexual harassment at workplace in line with the provisions of Sexual Harassment of Women at Workplace (Prevention,
Prohibition and Redressal) Act, 2013 and the Rules framed there under. An Internal Complaints Committee (ICC) has been set up to
redress complaints received regarding sexual harassment. All employees (permanent, contractual, temporary trainees) are covered
under this policy. The Company has complied with provisions relating to the constitution of Internal Complaints Committee under the
Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.
During the financial year 2021-22, the Company has not received any complaint on sexual harassment.
58
Code of Conduct
The Board of Directors has laid down Code of Conduct (“Code”) for all board members and senior management personnel of the Company.
The said Code incorporated the duties of directors including independent directors as laid down in the Act and is available on the website of
the Company under the link https://sswlindia.com/wp-content/themes/sswl/assets/docs/code_conduct.pdf .
All board members and senior management personnel have affirmed the compliance with the Code applicable to them during the year ended
on 31.03.2022. The Annual Report of the Company contains a Declaration by the Managing Director in terms of SEBI Listing Regulations,
based on the affirmations received from the board members and senior management personnel.
INSIDER TRADING
The Company has in place a Code of Conduct for Prevention of Insider Trading (Code of Conduct to Regulate Monitor and Report Trading by
Designated Persons) and a Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information in accordance
with SEBI (Prohibition of Insider Trading) Regulations, 2015 (“Regulations”). The said codes were amended to keep in line with the
amendments to SEBI Regulations as notified by SEBI and are uploaded on the website of the Company.
Web link for Code of Conduct for Prevention of Insider Trading is:
https://sswlindia.com/wp-content/themes/sswl/assets/docs/code_insider_trading.pdf
Web link for Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information is https://sswlindia.com/wp-
content/themes/sswl/assets/docs/code_unpublished_price.pdf.
The Code of Conduct for Prevention of Insider Trading lays down guidelines advising the management, staff and other connected persons,
and procedures to be followed and disclosures to be made by them while dealing with the shares of the company and cautioning them of
the consequences of violations.
Pursuant to the amendments made by SEBI in the said Regulations, the Company has also adopted a Policy for Procedure of Inquiry in
Case of Leak of Unpublished Price Sensitive Information (“UPSI”). The policy is formulated to maintain ethical standards in dealing with
sensitive information of the Company by persons who have access to UPSI. The rationale of the policy is to strengthen the internal control
systems to ensure that the UPSI is not communicated to any person except in accordance with the Insider Trading Regulations. The Policy
also provides an investigation procedure in case of leak/suspected leak of UPSI.
RECONCILATION OF SHARE CAPITAL AUDIT
The Statutory Auditor of the Company carried out a Reconciliation of Share Capital Audit to reconcile the total admitted equity share capital
with the National Securities Depository Limited (NSDL) and the Central Depository Services (India) Limited (CDSL) (collectively referred
to as ‘Depositories’) and the total issued and listed equity share capital. The audit report confirms that the total issued and paid up capital
is in agreement with the total number of shares in physical form and dematerialized form held with NSDL and CDSL. The said Audit Report
was disseminated to the stock exchanges on quarterly basis well within the stipulated time limit as prescribed in this regard.
Submission of quarterly compliance report on Corporate Governance
The Company has submitted quarterly compliance report on corporate governance, duly signed by the Company Secretary/Compliance
Officer of the Company, to both the stock exchanges i.e. BSE and NSE wherein the shares of the Company are listed and was also placed
before the Board of Directors of the Company.
CEO and CFO Certification
As required under Regulation 17(8) read with Part B of Schedule II of the SEBI Listing Regulations, the Managing Director, Deputy Managing
Director & Chief Financial Officer of the Company have given appropriate certifications for the financial year 2021-22 and the same was
placed before the Board of Directors of the Company in its meeting held on 13.05.2022.
CONSTITUENTS OF RELATED PARTIES
Following named Companies, Individuals and HUF constitute the related parties:
Promoter Group Companies:
Indian Acrylics Limited, SAB Industries Limited, Steel Strips Infrastructure Limited, Steel Strips Industries Limited (earlier known as Steel
Strips Leasing Limited), Indlon Chemicals Limited, SAB Developers Pvt. Ltd., Malwa Chemtex Udyog Limited, SAB Udyog Limited, Steel
Strips Mercantile Pvt. Limited, Indian Acrylics Investments Limited, Munak International Pvt. Limited, Steel Strips Financiers Pvt. Limited,
S.S. Credits Pvt. Limited, Malwa Holdings Pvt. Limited, S.J. Mercantile Pvt. Limited, Munak Investments Pvt. Limited, Steel Strips Holdings
Pvt. Limited, Munak Financiers Pvt. Limited, Chandigarh Developers Pvt. Ltd., DHG Marketing Pvt. Ltd. and Chandigarh Aircraft Management
Services Pvt. Limited.
One of the group companies Steel Strips Limited, has been amalgamated into SAB Industries Limited w.e.f. 19.10.2021.
Promoters Individuals:
Sh. Rajinder Kumar Garg, Sh. Dheeraj Garg, Smt. Sunena Garg and Ms. Priya Garg.
Hindu Undivided Family (HUF):
R. K. Garg & Sons (HUF)
Trust:
Hans Raj Trust
59
TRANSFER OF UNCLAIMED DIVIDEND/SHARES TO INVESTOR EDUCATION AND PROTECTION FUND (IEPF)
The Company has been paying dividend regularly from the last twenty four years (except for the year 2008-09 & 2019-20), starting from
the year 1996-97. Some amount of the dividend remain unpaid or unclaimed in the “Unpaid Dividend Accounts” being maintained by the
Company with HDFC Bank and Yes Bank Ltd.
Pursuant to applicable provisions of the Act, read with the Investor Education and Protection Fund Authority (Accounting, Audit, Transfer and
Refund) Rules, 2016 (Rules), all unpaid or unclaimed dividends are required to be transferred by the Company to the Investor Education
and Protection Fund (IEPF) established by the Central Government, after completion of seven years from the date of transfer to Unclaimed
Dividend Account of the Company. Further, according to the Rules, the shares in respect of which dividend has not been paid or claimed
by the shareholders for seven consecutive years or more shall also be transferred to the de-mat account of the IEPF Authority. The said
requirement does not apply to shares in respect of which there is a specific order of Court, Tribunal or Statutory Authority, restraining transfer
of the shares.
During the year under review, the Company had sent individual notices and also advertised in the newspapers i.e. both national (English) and
local (Punjabi) seeking action from the shareholders who have not claimed their dividends for seven consecutive years or more. Accordingly,
the Company had transferred an amount of Rs. 4,74,171.00 of unpaid/unclaimed dividend for the financial year 2013-14 and 28,154 shares
to the IEPF authority. The voting rights on these shares shall remain frozen till the shareholder claims those shares from IEPF authority.
Shareholders/claimants whose shares, unclaimed dividend, have been transferred to the IEPF De-mat Account or the Fund, as the case may
be, may claim the shares or apply for refund by making an application to the IEPF Authority in Form IEPF-5 (available on http://www.iepf.
gov.in) from time to time. The detailed procedure to claim the shares/unpaid dividend from the IEPF Authority is also available on Company’s
website at https://sswlindia.com/wp-content/themes/sswl/assets/docs/Procedure_for_claiming_shares_from_IEPF_Authority.pdf.
The Shareholders/claimant can file only one consolidated claim in a financial year as per the rules. The Company has appointed a Nodal
Officer under the provisions of the act and IEPF Rules, 2016 the details of which are available on the website of the Company under the
link:
https://sswlindia.com/wp-content/themes/sswl/assets/docs/particulars-of-nodal-officer.pdf.
During the financial year 2022-23, the company would be transferring unpaid or unclaimed dividend amount for the financial year 2014-15
and 2015-16 (Interim Dividend) within 30 days from the due date of transferring the amount to IEPF i.e. 05.11.2022 & 28.11.2022 respectively.
Further, the Company is also required to transfer the shares in respect of which dividends have not claimed for seven consecutive years from
the Financial Year 2014- 15, to the demat account of the IEPF Authority. The Company has also given individual intimations to concerned
shareholders indicating that such shares shall be transferred to IEPF Authority and also advertised in the newspapers seeking action from
said shareholders. Accordingly, the concerned members are requested to claim the unclaimed dividend for FY 2014-15 and FY 2015-16
(Interim Dividend) on or before 31.10.2022 and 20.11.2022, respectively.
The details of unpaid dividend for the FY 2014-15 & onwards and the details of shares/ shareholders against which dividends is unclaimed
for seven consecutive years from the FY 2014- 15 & FY 2015-16 (Interim Dividend) are provided on the website of the Company at
www.sswlindia.com under the Investors tab.
The shareholders are requested to verify their records and claim their unclaimed dividends for the past years, if not claimed.
Details of Nodal Officer
The details of the nodal officer appointed by the Company under the provisions of the act and IEPF Rules, 2016 are given below and the
same is disseminated on the website of the Company www.sswlindia.com.
Name of the Company Secretary designated as Nodal Officer Sh. Shaman Jindal
Phone No. 0172-2793112
Mobile No. 7009876354
Email ID [email protected]
Address SCO 49-50, Sector-26, Madhya Marg, Chandigarh-160019
AUDITOR’S CERTIFICATE ON COMPLIANCE OF CONDITIONS OF CORPORATE GOVERNANCE
Auditor’s Certificate on compliance of conditions of Corporate Governance is enclosed herewith and forms part of this report.
For and on behalf of the Board of Directors
Rajinder Kumar Garg

Date: 02.09.2022 Chairman
Place: Chandigarh DIN: 00034827
60
AUDITORS’ CERTIFICATE ON CORPORATE GOVERNANCE
To,
The Members of
We have examined the compliance of the conditions of Corporate Governance by Steel Strips Wheels Limited (hereinafter referred to as “the
Company”) for the year ended on 31.03.2022, as stipulated in Regulations 17 to 27, clauses (b) to (i) and (t) of Regulation 46(2) and para
C, D and E of Schedule V of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“SEBI Listing Regulations”).
The Compliance of conditions of Corporate Governance is the responsibility of the Management. Our examination was limited to the
review of procedures and implementation thereof, as adopted by the Company for ensuring the compliance with conditions of Corporate
Governance. It is neither an audit nor an expression of opinion on the financial statements of the Company.
In our opinion and to the best of our information and according to the explanations given to us, and the representations made by directors
and the management, we certify that the Company has complied with the conditions of Corporate Governance as stipulated in the above
mentioned SEBI Listing Regulations, as applicable, for the financial year ended 31.03.2022.
We further state that such compliance is neither an assurance as to the future viability of the Company nor of the efficiency or effectiveness
with which the management has conducted the affairs of the Company.
For AKR & Associates

Date: 02.09.2022 Chartered Accountants
Place: Chandigarh Firm Registration No: 021179N
Sd/-
(Kailash Kumar)
Partner
M. No. 505972
UDIN: 22505972AQPWAJ7330
Declaration regarding compliance by the Board Members and Senior Management Personnel with
Company’s Code of Conduct
This is to confirm that the Company has adopted the Code of Conduct for all the Board members and Senior Management of the Company
which is available on the website of the Company at https://sswlindia.com/investor/.
I confirm that the Company has in respect of the financial year ended 31.03.2022, received from its Board members as well as Senior
Management Personnel, a declaration of compliance with the code of conduct as applicable to them.
For Steel Strips Wheels Limited
Sd/-
Dated: 02.09.2022 (Dheeraj Garg)
Place: Chandigarh Managing Director
DIN: 00034926
61
CERTIFICATE OF NON-DISQUALIFICATION OF DIRECTORS
Pursuant to the provisions of Regulation 34(3) and Schedule V Para C Clause (10) (i) of the SEBI (Listing Obligations and Disclosure
Requirements) Regulations, 2015)
To
The Members,
I have examined the relevant registers, records, forms, returns and disclosures received from the Directors of Steel Strips Wheels Limited
having CIN: L27107PB1985PLC006159 and having registered office at Village Somalheri/Lehli P.O. Dappar, Tehsil Derabassi, Distt. S.A.S
Nagar, Mohali (Punjab), 140506 (hereinafter referred to as ‘the Company’), produced before me by the Company for the purpose of issuing
this Certificate, in accordance with Regulation 34(3) read with Schedule V Para-C Sub-clause 10 (i) of the Securities and Exchange Board
of India (Listing Obligations and Disclosure Requirements) Regulations, 2015.
In my opinion and to the best of my information and according to the verifications (including Directors Identification Number (‘DIN’) status
at the portal www.mca.gov.in) as considered necessary and explanations furnished to me by the Company & its officers and considering
the relaxations granted by the Ministry of Corporate Affairs and Securities and Exchange Board of India warranted due to the spread of the
COVID-19 pandemic, I hereby certify that none of the Directors on the Board of the Company as stated below for the year ended 31st March,
2022, have been debarred or disqualified from being appointed or continuing as Directors of companies by the Securities and Exchange
Board of India (‘SEBI’), Ministry of Corporate Affairs (‘MCA’) or any such statutory authority(ies).
Sr. No. Name of Director DIN

1. Mr. Rajinder Kumar Garg 00034827
2. Mr. Dheeraj Garg 00034926
3. Mr. Andra Veetil Unnikrishnan 02498195
4. Mr. Manohar Lal Jain 00034591
5. Mr. Sanjay Garg 00030956
6. Mr. Sanjay Surajprakash Sahni 08263029
7. Mr. Virander Kumar Arya 00751005
8. Mr. Ajit Singh Chatha 02289613
9. Mr. Surinder Singh Virdi 00035408
10. Mr. Shashi Bhushan Gupta 00154404
11. Mrs. Deva Bharathi Reddy 08763741
12. Mr. Siddharth Bansal 02909820
Ensuring the eligibility for the appointment/continuity of every Director on the Board is the responsibility of the management of the Company.
My responsibility is to express an opinion on these based on my verification. This certificate is neither an assurance as to the future viability
of the Company nor of the efficiency or effectiveness with which the management has conducted the affairs of the Company.
For S. K. SIKKA & ASSOCIATES

Company Secretaries
Sd/-
Date: 02.09.2022 (Sushil Kumar Sikka)
Place: Chandigarh Proprietor
FCS 4241, CP No.: - 3582
UDIN: F004241D000893338
62
management
The Indian economy grew 8.7% in FY 2021-22, with the Gross Domestic Product (GDP) expanding 4.1% in the March quarter from a
year ago. The GDP growth for FY 2021-22 takes the economy above its pre-pandemic level and is an improvement after contracting
6.6% in FY 2020-21. But the January-March quarter expansion was the weakest in the previous fiscal year. It is lesser than the
5.4% growth seen during the December quarter of FY 2021-22. At the same time, the 4.1% growth in March quarter of FY 2021-22
is an expansion over the meagre 1.6% growth seen during the fourth quarter of FY 2020-21.
Strong Comeback post COVID Shock for Automobile Sector
Impacted by supply-side challenges, total automobile dispatches during the last financial year fell 6% in all segments, dragged down
by lower sales of two-wheelers and entry-level cars amid rising vehicle and fuel costs. As per the data released by the SIAM, two-
wheeler sales fell by 11% to 1,34,66,412 units with scooter sales falling 10.55% to 40,09,076 units and motorcycle sales dropping
10.30% to 89,84,186 units. In March, the two-wheeler sales nosedived 21% to 11,84,210 units as motorcycle and scooter sales
declined by 21% each to 7,86,479 units and 3,60,082 units, respectively. During the year, passenger vehicle sales during FY 2021-
22 stood at 30,69,499 units, up 13.20% from 27,11,457 units a year ago, mainly driven by a 40% growth in sales of utility vehicles.
The Commercial Vehicles sales for the last year grew 26% to 7,16,566 units, while three-wheeler sales were up almost 19% to
2,60,995 units.
In April 2021 to March 2022, Passenger Vehicle Exports increased from 404,397 to 577,875 units, Commercial Vehicle Exports
increased from 50,334 to 92,297 units, Three Wheeler Exports increased from 393,001 to 499,730 units and Two Wheelers Exports
increased from 3,282,786 to 4,443,018 units in April 2021 to March 2022 over same period last year.
The year saw huge volatility in manufacturing due to supply side bottlenecks and the momentum for the next year seems solid on
the back of good order book along with order backlogs.
Automobile Sector Recovery post Covid has been solid and was backed by pent up demand. The below table indicates strong
momentum for many segment of automobiles to maintain growth momentum and reach very close to pre Covid peaks.
Total Vehicle Sales Trends

Domestic Trends are very encouraging and we expect the momentum to carry in FY 2022-23 to post stronger growth for all segment
of vehicles. PV segment seems to outperform and may surpass the all-time highs in FY 2022-23 backed by very strong consumer
demand.
Domestic Vehicle Sales Trends

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Sswl Key Growth Drivers Post Covid
Post COVID, SSWL worked extensively on China plus one philosophy and marked many global territories to record highest ever
exports revenue for the company. SSWL went on aggressive development plan to further push for global market share in Steel
& Aluminum wheel industry to make this shift permanent. The exports went up around 3X in FY 2021-22 with larger mind space
captured by SSWL in FY 2021-22. We expect with entry of alloy wheel exports we will be able to continue this journey in coming
years. SSWL reports highest ever Alloy wheel segment sales in FY 2021-22 with the help of strong customer belief in SSWL
development capabilities. We expect to work closely with customers and ensure strong growth momentum in coming years for alloy
wheel segment.
SSWL expects to maintain double digit revenue growth with its focus on all segments of automobiles in FY 2022-23. The Company
is committed towards reduction of long term liabilities with the help of consistent double digit EBIDTA margins. Company is keeping
strong focus on ROC and other return ratios to ensure financial matrix improvement.
Industry Outlook
The Automobile sector is expected to a very strong growth in FY 2022-23 on a weaker base and very strong consumer demand
in all segments. Post Covid there is a strong pent-up demand in all segments and we expect the industry to maintain very strong
volume growth.
We expect PV segment to report more than 12% Growth in FY 2022-23 with order back log supporting the demand. Supply chain
bottlenecks will remain most important factors for manufacturing.
Commercial vehicle segment is expected to grow more than 15-18% in FY 2022-23 with very strong government infrastructure
spend and base line capex returning for the sector. The sector still remains well below FY 2018-19 peak performance but slowly
gathering pace to catchup some lost ground.
2 & 3 wheelers are bearing strong demand slowdown current for past few years with cost of ownership increasing every year. The
industry has reached almost a decade low for the segment and we expect the industry will try to stabilize around the current output
levels and will turn the corner for better perspective in FY 2022-23. We expect the industry to report in 5-7% volume growth in
FY 2022-23. Stronger farm income and normalcy in rains will also help to attain the growth.
Export Outlook
Exports again remain robust and it seems that India is catching up with the world with the help of Make in India initiative catching
strong undercurrent.
Export Sales Trends

We expect Indian automobile makers making all attempts to improve global market share and continue to gain momentum for higher
exports in FY 2022-23. Major thrust is being put on developing the alloy wheel segment export market and ensure it sails the similar
journey in line with Steel Wheels.
Opportunities
SSWL is looking to expand its presence in alloy wheel with global passenger car segment customer. In view of that we are expanding
the capacities also to cater the global demand. Globally Alloy wheel is very popular with more than 80 % wheel penetration. It gives
huge export opportunity to SSWL to imitate the steel wheel exports story. As an organization we are focusing on developing this
segment of market to become globally competitive and take market share. This segment of business has huge potential towards
value addition and bringing foreign exchange to the country. This remains top priority for SSWL to grow its alloy wheel presence in
coming 2-3 years.
Threats
The global economy is going through a rough patch with huge surge in commodity prices bringing in a log of Inflation in developed
world. This poses a larger risk for the global economy which may have its impact on Consumer demand due to decades high
64
Inflation. The global economic turmoil can pose a threat to Indian growth dynamics and can hit consumer sentiment. This can be a
probable threat for automotive market sentiment also.
Financial Performance with respect to Operational Performance
In FY 2021-22 Company achieved the highest ever topline as well bottom-line in its history. Revenue from operations stood at
Rs. 3559.95 crores in FY 2021-22 as compared to Rs. 1749.42 crores in FY 2020-21. The company witnessed growth across
all the segments it is operating in and outperformed the overall industry in terms of annual growth rate. The two key drivers for
the Company in FY 2021-22 were Exports which grew by 203% with overall Exports reaching the best ever figure of Rs. 829.00
crores and alloy wheels which grew by almost 109% to reach Rs. 704.00 crores for the year. The PAT for FY 2021-22 stood at
Rs. 205.46 crores vs Rs. 49.25 crores in FY 2020-21. Considering the stellar growth in PAT as well as cash accruals the Company
prepaid Rs. 122.00 crores of its term liability in FY 2021-22 and remain focused on optimally utilizing the accruals going forward
keeping the overall goal of deleveraging as well as maximizing Return on Capital. Further Company is working aggressively on
keeping the overall sales mix tilted towards EBITDA accretive businesses like Alloy Wheels and Exports.
Risk & Outlook
Steel & Aluminum is the primary raw material for the products of the company, and is a very significant part of the final product cost
of Steel & aluminum wheel. Rising steel & aluminum prices continue to be a reality and pose a challenge to inventory and financial
management for the company in this competitive auto component sector.
Factor of global growth has become a key linkage between economies and the consumer sentiment. Global growth is still limping
on weak wicket and manufacturing output is still shrinking for a large part of the globe. The world economies are making a base
after financial crisis and will keep the growth parameters for company in check as the cross border trade is suffering due to low
consumption. We are constantly de-risking ourselves by broadening our product reach and extending our reach to across the globe
to avoid geographical slowdown risk.
Top customer concentration is a risk as above 75% of revenues come from domestic market customers and company is increasing
its foot print in Export markets by catering to wide ranges of segment and customers. Company has ventured into alloy wheel
segment to improve the product category to de-risk itself from being only in steel wheel segment. Company is also moving ahead on
Alloy wheel market development to further de-risk the steel wheel dependency from Domestic and export customers.
Foreign currency movement also poses the risk towards the corporate performance as global currencies swings are extreme due
to various macro issues persisting in current environment. This may act as a headwind for some time to come till situation becomes
normal and volatility among global currency recedes to normalized levels. The Company is working aggressively to build larger
export to hedge the import currency risk.
To mitigate the risk, the Company continues to strive to improve its operational performance and develop new components, which
are technologically superior and have an edge over the competitors.
Return on Net Worth (PAT/Net Worth)
FY2022 FY2021 Detailed Explanation
13.70% 6.57% The Profit after Tax for financial year 2021-22 has been increased due to increase in
overall turnover mainly attributed to Company’s Export and Alloy Wheel sales which
has contributed to better profit margin.
Key Financial Ratios
Key Financial FY2022 FY2021 %Change Calculation formula Detailed Explanation in case
Ratio change is more than 25%
Debtors Turnover 27.42 36.50 -24.87% Average trade Receivables/Gross Revenue
days days from operations
Inventory 58.62 86.15 -31.95% Average Inventory/ Sale of Products in days
Turnover days days
Interest 2.87 1.09 163.36% Net profit after taxes + Non-cash operating
Coverage Ratio expenses+ finance cost / Debt service =
Finance cost+ Schedule Repayment (excluding
prepayment) Variation in Coverage, turnover and
other profitability ratios is primarily
Current Ratio 1.09 1.15 -5.66% Current Assets/Current Liabilities (excluding due to increase in turnover and
Current Maturities of Long term Debt) profitability during the year ended
Debt Equity Ratio 0.31 0.51 -38.72% Long Term Debt (excluding Current Maturities 31st March 2022.
of Long term Debt)/ Shareholder’s Equity
(excluding Revaluation reserve)
Operating Profit 10.93% 8.45% 29.35% Profit before tax before interest/Net Sales=Total
Margin (%) sales-sales return
Net Profit Margin 5.77% 2.82% 105.01% Net Profit/Net Sales= Total sales - sales return
(%)
65
SEGMENT REPORTING
The Company is primarily engaged in the business of manufacturing Steel Wheel Rims and Alloy Wheel Rims catering to different
segment of automobile industry. The inherent nature of activities is governed by the same set of risk and returns; hence these have
been grouped as a single segment. The said treatment is in accordance with the principle enunciated in the Accounting Standard
on Segment Reporting (AS 17).
RISKS & CONCERNS
The Company’s business is exposed to many internal and external risks and it has consequently put in place robust systems and
processes, along with appropriate review mechanisms to actively monitor, manage and mitigate these risks. Some of the key
existing and emerging risks affecting the Company are as follows:
Risks Type Key Risks Impact on SSWL Mitigation

Strategic Risk Global Economic Vehicle purchase across different Diversified product mix, segment mix
Scenario segment has strong correlations with and customer mix. Target newer market
GDP growth. The decision to purchase a segments which might provide counter-
passenger vehicle comes under customers’ cyclical support.
discretionary spending (Passenger Vehicle)
which is linked to their perception of business
outlook. Depressed economic outlook can
impact this spending and thereby constrain
the Company’s growth potential.
Long term growth Capacities utilization across all the plants Debottlenecking exercise across all the
dependent on of capacity are inching up gradually and with business facilities are being carried every quarter.
expansion environment turning favorable growth in Optimum scheduling of production across
long term will be dependent on Capacity different products thereby improving yield.
addition. Possibility of setting up new lines wherein
Company has project Management
expertise.
Operation Risk Supply chain disruption. The raw material (Steel & Aluminium) The Company maintains significant
accounts for 60-65% of the cost, poses integration of raw materials for its
a key risk as it may be subject to supply Operations. To achieve greater raw material
disruption and market price volatility. security, company enters into long term
MOU with suppliers.
Development of alternate sources for
uninterrupted supply of key raw material.
Employee Productivity Employee involvement and productivity is Company has strong commitment
and retention one of the key factors to be competitive in towards creating and providing safe
industry. Being a labour intensive sector working environment for its employee
employee welfare assumes significance. and stakeholders. Focused approach to
retain key talent through multiple initiatives
including providing cross functional access
and experience.
Focus on employee engagement:
Increased focus on offering learning

opportunities with allocation of funds for
training requirements.
Competition The Company faces competition in the The Company ensures close cooperation
business field it operates in. As a result, with its key customers on product
the Company is exposed to dual risk of development. It has implemented strict
either being displaced by existing or new product quality controls in order to reduce
competitors or its products being replaced by the likelihood of substitution. The company
product innovations and new technological remains ahead on technology front on light
features. Customer dissatisfaction on price, weighting the products to offer best in class
quality, delivery performance, and design products to its customer.
could lead to loss of market share.
66
Financial Risk Currency Volatility Volatility in currency exchange movements Board approved Currency hedging policies
resulting in transaction and translation and practices are in place.
exposure. Close monitoring of hedging strategy by
risk management committee.
Quarterly assessment of foreign exchange
exposure by Board.
Debt Burden The Company’s outstanding indebtedness Close monitoring of debt profile and
in an adverse environment can have continuous effort to bring the cost in line
significant impact on financial flexibility and with industry. Continuous effort to maintain
business as a whole. the impeccable credit history. Quarterly
review of financial leverage and efforts are
on to move towards industry benchmark.
Credit Rating Failure to maintain credit ratings could Regular exchange of information and
adversely affect cost of funds. updates with agency. Focused approach to
work on areas of improvement and to build
upon areas of strength. Close monitoring of
triggers highlighted in rating rationale.
Social costs SSWL’s assumptions while estimating A framework to manage social cost risks has
social cost like gratuity funding are subject been deployed to ensure that obligations
to capital market and actuarial risks and remain affordable and sustainable, whilst
any shortfall could put pressure on financial protecting the asset market exposure.
performance.
Credit Risk Customer default can pose a significant Systems are in place to assess the credit
challenge and impact the bottom line of the worthiness of new as well as existing
Company. customers.
Financial Fraud Financial fraud can challenge the reputation
Adequate Internal financial control system in
as well existence of the Company besides place. Adequate accounting records are in
denting the confidence on the systems in place to safeguard the assets of Company
place. and for preventing and detecting frauds.
Vigil Mechanism in place that provides
a formal mechanism for all Directors,
employees and vendors of the Company to
approach the Ethics Counselor/Chairman
of the Audit Committee of the Board and
make protective disclosures about the
unethical behavior, actual or suspected
fraud.
Legal Risk Regulatory environment & The Company is subject to numerous laws, The Company has policies, systems
compliance regulations and contractual commitments. and procedures in place with a strong
Any failure to comply with same may impact commitment from the Board and the
the Company adversely. Executive Committee towards compliance.
INTERNAL CONTROLS AND THEIR ADEQUACY

The Company has a robust internal control and audit system to provide adequate assurance regarding the effectiveness and
efficiency of its systems and operations. The controls are commensurate to the needs of the organization given its size and
complexity of operations. The standard operating procedures ensure compliance to local regulation and statutes as applicable to
the Company. The Company strictly ensures adherence to all internal control policies and procedures as well as compliance with
all regulatory guidelines.
DEVELOPMENT IN HUMAN RESOURCES
Though the second wave has impacted the supply chain in Q1 of FY 2021-22, all our plants have been functioning normally subject
to strict adherence to safety protocols mandated by the government/local authorities in order to contain the spread of COVID-19.
Post the easing of lockdown restrictions and widening reach of vaccines, there has been a focus on renewing and continuing
operations in a safe and sustainable manner. The workforce showed great resilience in the face of an unprecedented pandemic
demonstrating its ability to adapt to new circumstances. They ensured that your company was quickly on its way to normalcy and
well placed to exploit opportunities in favorable market conditions.
Furthermore, the Company has continuously adopted structures that help in attracting best external talent and promote internal
talent to take higher roles and responsibilities. The Company’s people centric focus is providing an open work environment fostering
67
continuous improvement and development among the employees of the Company. The Company provides a holistic environment
where employees get opportunities to realize their potential. The Company’s performance driven culture helps and motivates
employees to excel in their respective areas and progress within the organization. The Company has a structured appraisal system
based on key result areas (KRAs) for employees belonging to Manager and above category. As on 31.03.2022, the Company had
2304 permanent employees on the rolls of the Company.
DISCLAIMER
This report contains certain statements that the Company believes and may be considered as forward looking statements. These
forward looking statements may be identified by their use of words like ‘ plan’, ‘hope’, ‘will’, ‘expect’, ‘aim’ or such similar words or
phrases. All such statements are subject to risks and uncertainties which could cause actual results to vary materially from those
contemplated by the relevant forward looking statements.

DIN: 00034827
68
INDEPENDENT AUDITOR’S
To The Members of
Report on the Audit of the Standalone Financial Statements
1. Opinion
We have audited the accompanying standalone financial statements of Steel Strips Wheels Limited (“the Company”), which comprise
the Balance Sheet as at 31st March 2022, and the Statement of Profit and Loss (including Other Comprehensive Income), the Cash
Flow Statement and the Statement of Changes in Equity for the year then ended, and a summary of significant accounting policies
and other explanatory information.
In our opinion and to the best of our information and according to the explanations given to us, the aforesaid standalone financial
statements give the information required by the Companies Act, 2013 (“the Act”) in the manner so required and give a true and fair
view in conformity with the Indian Accounting Standards prescribed under section 133 of the Act read with the Companies (Indian
Accounting Standards) Rules, 2015, as amended, (“Ind AS”) and other accounting principles generally accepted in India, of the state
of affairs of the Company as at 31 March 2022, and its profit, total comprehensive income, its cash flows and the changes in equity
for the year ended on that date.
2. Basis for Opinion
We conducted our audit of the standalone financial statements in accordance with the Standards on Auditing specified under section
143(10) of the Act (SAs). Our responsibilities under those Standards are further described in the Auditor’s Responsibility for the Audit
of the Standalone Financial Statements section of our report. We are independent of the Company in accordance with the Code
of Ethics issued by the Institute of Chartered Accountants of India (ICAI) together with the ethical requirements that are relevant to
our audit of the standalone financial statements under the provisions of the Act and the Rules made there under, and we have fulfilled
our other ethical responsibilities in accordance with these requirements and the ICAI’s Code of Ethics. We believe that the audit
evidence obtained by us is sufficient and appropriate to provide a basis for our audit opinion on the standalone financial statements.
3. Key Audit Matters
Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the standalone
financial statements of the current period. These matters were addressed in the context of our audit of the standalone financial
statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters. We have
determined that there are no key audit matters to be communicated in our report.
4. Information other than the Financial Statements and Auditor’s Report Thereon
• The Company’s Board of Directors is responsible for the other information. The other information comprises the information
included in the Annual Report, but does not include the standalone financial statements and our auditor’s report thereon.
• Our opinion on the standalone financial statements does not cover the other information and we do not express any form of
assurance conclusion thereon.
• In connection with our audit of the standalone financial statements, our responsibility is to read the other information and, in
doing so, consider whether the other information is materially inconsistent with the standalone financial statements or our
knowledge obtained during the course of our audit or otherwise appears to be materially misstated.
• If, based on the work we have performed, we conclude that there is a material misstatement of this other information, we are
required to report that fact. We have nothing to report in this regard.
5. Management’s Responsibility for the Standalone Financial Statements
The Company’s Board of Directors is responsible for the matters stated in section 134(5) of the Act with respect to the
preparation of these standalone financial statements that give a true and fair view of the financial position, financial performance
including other comprehensive income, cash flows and changes in equity of the Company in accordance with the Ind AS and other
accounting principles generally accepted in India. This responsibility also includes 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 frauds and
other irregularities; selection and application of appropriate accounting policies; making judgments and estimates that are
reasonable and prudent; and design, implementation and maintenance of adequate internal financial controls, that were operating
effectively for ensuring the accuracy and completeness of the accounting records, relevant to the preparation and presentation of
the standalone financial statement that give a true and fair view and are free from material misstatement, whether due to fraud or
error.
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In preparing the standalone financial statements, management is responsible for assessing the Company’s ability to continue as a
going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless
management either intends to liquidate the Company or to cease operations, or has no realistic alternative but to do so.
Those Board of Directors are also responsible for overseeing the Company’s financial reporting process.
6. Auditor’s Responsibility for the Audit of the Standalone Financial Statements
Our objectives are to obtain reasonable assurance about whether the standalone financial statements as a whole are free from
material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion. Reasonable
assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with SAs will always detect
a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually
or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these
standalone financial statements.
As part of an audit in accordance with SAs, we exercise professional judgement and maintain professional skepticism throughout the
audit. We also:
• Identify and assess the risks of material misstatement of the standalone financial statements, whether due to fraud or error,
design and perform audit procedures responsive to those risks, and obtain audit evidence that is sufficient and appropriate
to provide a basis for our opinion. The risk of not detecting a material misstatement resulting from fraud is higher than for
one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of
internal control.
• Obtain an understanding of internal financial control relevant to the audit in order to design audit procedures that are appropriate
in the circumstances. Under section 143(3)(i) of the Act, we are also responsible for expressing our opinion on whether the
Company has adequate internal financial controls system in place and the operating effectiveness of such controls.
• Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and related
disclosures made by the management.
• Conclude on the appropriateness of management’s use of the going concern basis of accounting and, based on the audit
evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the
Company’s ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw
attention in our auditor’s report to the related disclosures in the standalone financial statements or, if such disclosures are
inadequate, to modify our opinion. Our conclusions are based on the audit evidence obtained up to the date of our auditor’s
report. However, future events or conditions may cause the Company to cease to continue as a going concern.
• Evaluate the overall presentation, structure and content of the standalone financial statements, including the disclosures, and
whether the standalone financial statements represent the underlying transactions and events in a manner that achieves fair
presentation.
Materiality is the magnitude of misstatements in the standalone financial statements that, individually or in aggregate, makes it
probable that the economic decisions of a reasonably knowledgeable user of the standalone financial statements may be influenced.
We consider quantitative materiality and qualitative factors in (i) planning the scope of our audit work and in evaluating the results of
our work; and (ii) to evaluate the effect of any identified misstatements in the standalone financial statements.
We communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit and
significant audit findings, including any significant deficiencies in internal control that we identify during our audit.
We also provide those charged with governance with a statement that we have complied with relevant ethical requirements regarding
independence, and to communicate with them all relationships and other matters that may reasonably be thought to bear on our
independence, and where applicable, related safeguards.
From the matters communicated with those charged with governance, we determine those matters that were of most significance
in the audit of the standalone financial statements of the current period and are therefore the key audit matters. We describe these
matters in our auditor’s report unless law or regulation precludes public disclosure about the matter or when, in extremely rare
circumstances, we determine that a matter should not be communicated in our report because the adverse consequences of doing
so would reasonably be expected to outweigh the public interest benefits of such communication.
7. Report on Other Legal and Regulatory Requirements
1. As required by the Companies (Auditor’s Report) Order, 2020 (“the Order”), issued by the Central Government of India in terms
of sub-section (11) of section 143 of the Companies Act, 2013, we give in the “Annexure A” to this report a statement on the
matters specified in paragraphs 3 and 4 of the Order, to the extent applicable.
2. As required by Section 143(3) of the Act, based on our audit we report that:
a) We have sought and obtained all the information and explanations which to the best of our knowledge and belief were
necessary for the purposes of our audit.
b) In our opinion, proper books of account as required by law have been kept by the Company so far as it appears from
our examination of those books.
c) The Balance Sheet, the Statement of Profit and Loss including Other Comprehensive Income, the Cash Flow Statement
and Statement of Changes in Equity dealt with by this Report are in agreement with the relevant books of account.
d) In our opinion, the aforesaid standalone financial statements comply with the Ind AS specified under Section 133
of the Act.
70
e) On the basis of the written representations received from the directors as on 31st March, 2022 taken on record by the
Board of Directors, none of the directors is disqualified as on 31st March, 2022 from being appointed as a director in
terms of Section 164(2) of the Act.
f) With respect to the adequacy of the internal financial controls over financial reporting of the Company and the
operating effectiveness of such controls, refer to our separate Report in “Annexure B”. Our report expresses
an unmodified opinion on the adequacy and operating effectiveness of the Company’s internal financial controls over
financial reporting.
g) With respect to the other matters to be included in the Auditor’s Report in accordance with the requirements of section
197(16) of the Act, as amended, In our opinion and to the best of our information and according to the explanations
given to us, the remuneration paid by the Company to its directors during the year is in accordance with the provisions
of section 197 of the Act.
h) With respect to the other matters to be included in the Auditor’s Report in accordance with Rule 11 of the Companies
(Audit and Auditors) Rules, 2014, as amended in our opinion and to the best of our information and according to the
explanations given to us:
i. The Company does not have any pending litigations which would impact its financial position.
ii. The Company did not have any long-term contracts including derivative contracts for which there were any
material foreseeable losses.
iii. There has been no delay in transferring amounts, required to be transferred, to the Investor Education and
Protection Fund by the Company
iv. (a) The Management has represented that, to the best of its knowledge and belief, no funds (which are material
either individually or in the aggregate) have been advanced or loaned or invested (either from borrowed funds
or share premium or any other sources or kind of funds) by the Company to or in any other person or entity,
including foreign entity (“Intermediaries”), with the understanding, whether recorded in writing or otherwise, that
the Intermediary shall, whether, directly or indirectly lend or invest in other persons or entities identified in any
manner whatsoever by or on behalf of the Company (“Ultimate Beneficiaries”) or provide any guarantee, security
or the like on behalf of the Ultimate Beneficiaries;
(b) The Management has represented, that, to the best of its knowledge and belief, no funds (which are material
either individually or in the aggregate) have been received by the Company from any person or entity, including
foreign entity (“Funding Parties”), with the understanding, whether recorded in writing or otherwise, that the
Company shall, whether, directly or indirectly, lend or invest in other persons or entities identified in any manner
whatsoever by or on behalf of the Funding Party (“Ultimate Beneficiaries”) or provide any guarantee, security or
the like on behalf of the Ultimate Beneficiaries;
(c) Based on the audit procedures that we have considered reasonable and appropriate in the circumstances,
nothing has come to our notice that has caused us to believe that the representations as provided
under (a) and (b) above, contain any material misstatement.
v. The final dividend declared and paid by the Company during the year in respect of the previous financial year is
in accordance with section 123 of the Act 2013 to the extent it applies to payment of dividend.
vi. The Board of Directors of the Company have proposed final dividend for the year which is subject to the approval
of the members at the ensuing Annual General Meeting. The dividend declared is in accordance with section 123
of the Act to the extent it applies to declaration of dividend.

Chartered Accountants
Firm’s Registration No.: 021179N
per Kailash Kumar

Partner
Membership No.: 505972
Place : Chandigarh
Date : 13.05.2022
UDIN: 22505972AJEHPU8110
UDIN DATED 18.05.2022
71
ANNEXURE A TO INDEPENDENT AUDITORS’ REPORT OF EVEN DATE ON THE STANDALONE FINANCIAL
STATEMENTS OF Steel Strips Wheels Limited FOR THE YEAR ENDED 31.03.2022
[Referred to in paragraph 7 under ‘Report on Other Legal and Regulatory Requirements’ in the Independent
Auditors’ Report]
i) a) A) T
he company has maintained proper records showing full particulars, including quantitative details and situation of property,
plant and equipment.
B) The company has maintained proper records showing full particulars of intangible assets.
b) All property, plant and equipment have not been physically verified by the management during the year but there is a regular
programme of verification which, in our opinion, is reasonable having regard to the size of the Company and the nature of its assets.
No material discrepancies were noticed on such verification.
c) According to the information and explanations given to us and on the basis of our examination of the records of the Company,
the title deeds of immovable properties (other than immovable properties where the Company is the lessee and the lease
agreements are duly executed in favour of the lessee) disclosed in the standalone financial statements are held in the name of
the Company.
d) The company has not revalued its property, plant and equipment (including right of use assets) or intangible assets or both during
the year.
e) According to the information and explanations given to us and on the basis of our examination of the records of the Company, there
are no proceedings initiated or pending against the Company for holding any benami property under the Prohibition of Benami
Property Transactions Act, 1988 and rules made thereunder.
ii) a) The inventories were physically verified by the management during the year at reasonable intervals. In our opinion and according
to the information and explanations given to us, the coverage and procedure of such verification by the management is appropriate
having regard to the size of the company and the nature of its operations. No discrepancies of 10% or more in aggregate of each
class of inventories were noticed on such physical verification of inventories when compared with the books of accounts.
b) The company has been sanctioned working capital limit in excess of five crore rupees in aggregate from banks/financial institutions on
the basis of the security of the current assets of the company. The quarterly returns/statements filed by the company with such
banks/ financial institutions are in agreement with the books of accounts of the company.
iii) During the year, the company has not made investments, provided any guarantee or security or granted any loans or advances in
the nature of loans, secured or unsecured to companies, firms, limited liability partnerships or any other parties hence clause 3(iii)
(a) to 3(iii) (f) is not applicable to the company.
iv) In our opinion and according to the information and explanations given to us, the Company has not either directly or indirectly,
granted any loan to any of its directors or to any other person in whom the director is interested, in accordance with the provisions
of section 185 of the Act and the Company has not made investments through more than two layers of investment companies in
accordance with the provisions of section 186 of the Act. Accordingly, provisions stated in paragraph 3(iv) of the Order are not
applicable to the Company.
v) In our opinion and according to the information and explanations given to us, the Company has not accepted any deposits from the
public within the meaning of Sections 73, 74, 75 and 76 of the Act and the rules framed there under.
vi) We have broadly reviewed the books of accounts maintained by the company pursuant to the Rules made by the Central Government
for the maintenance of cost records under sub section (1) of section 148 of the Act in respect of Company’s products and are of the
opinion that, prima facie, the prescribed accounts and records have been made and maintained. However, we have not made a
detailed examination of the cost records with the view to determine whether they are accurate and complete.
vii) a) According to the information and explanations given to us and the records of the Company examined by us, in our opinion,
undisputed statutory dues including goods and service tax, provident fund, employees’ state insurance, income-tax, sales-tax,
service tax, duty of customs, duty of excise, value added tax, cess have been regularly deposited by the company with appropriate
authorities in all cases during the year.
b) According to the information and explanation given to us and the records of the Company examined by us, there are no dues of
goods and service tax, income tax, customs duty, cess and any other statutory dues which have not been deposited on account of
any dispute.
viii) According to the information and explanations given to us, there are no transactions which are not accounted in the books of
account which have been surrendered or disclosed as income during the year in Tax Assessment of the Company. Also, there are
no previously unrecorded income which has been now recorded in the books of account. Hence, the provision stated in paragraph
3(viii) of the Order is not applicable to the Company.
ix) a) In our opinion and according to the information and explanations given to us, the Company has not defaulted in repayment of loans
or borrowings or in payment of interest thereon to any lender.
b) According to the information and explanations given to us and on the basis of our audit procedures, we report that the company has
not been declared wilful defaulter by any bank or financial institution or government or any government authority.
72
c) In our opinion and according to the information explanation provided to us, money raised by way of term loans during the year have
been applied for the purpose for which they were raised.
d) According to the information and explanations given to us and the procedures performed by us, and on an overall examination of
the financial statements of the company, we report that no funds raised on short term basis have been used for long term purposes
by the company.
e) The Company does not have any subsidiary, associate or joint venture, hence reporting under the clause (ix)(e) of the order is not
f) The Company does not have any subsidiary, associate or joint venture, hence reporting under the clause (ix)(f) of the order is not
x) a) The Company did not raise any money by way of initial public offer or further public offer (including debt instruments) during the
year. Accordingly, the provisions stated in paragraph 3 (x)(a) of the Order are not applicable to the Company.
b) According to the information and explanations given to us and on the basis of our examination of the records of the company,
the Company has not made any preferential allotment or private placement of shares or convertible debentures (fully, partially or
optionally convertible) during the year hence the clause 3(x)(b) of the Order is not applicable.
xi) a) During the course of our audit, examination of the books and records of the Company, carried out in accordance with the generally
accepted auditing practices in India, and according to the information and explanations given to us, we have neither come across
any instance of fraud by the Company nor on the Company.
b) We have not come across of any instance of fraud by the Company or on the Company during the course of audit of the standalone
financial statement for the year ended March 31, 2022, accordingly the provisions stated in paragraph (xi)(b) of the Order is not
c) As represented to us by the management, there are no whistle-blower complaints received by the Company during the year.
Accordingly, the provisions stated in paragraph (xi)(c) of the Order is not applicable to the company.
xii) In our opinion and according to the information and explanations given to us, the Company is not a Nidhi Company. Accordingly,
the provisions stated in paragraph 3(xii) (a) to (c) of the Order are not applicable to the Company.
xiii) The Company has entered into transactions with related parties in compliance with the provisions of section 177 and 188 of the Act.
The detail of such related party transactions have been disclosed in the financial statements as required under Indian accounting
standards (Ind AS) 24, Related Party Disclosures specified under Section 133 of the Act, read with Rule 7 of the Companies
(Accounts) Rule, 2014.
xiv) a) In our opinion and based on our examination, the company has an internal audit system commensurate with the size and nature
of its business.
b) We have considered the internal audit report of the company issued till date for the period under audit.
xv) According to the information and explanations given to us, in our opinion during the year the Company has not entered into non-
cash transactions with directors or persons connected with its directors and hence, provisions of section 192 of the Act are not
applicable to company. Accordingly, the provisions stated in paragraph 3(xv) of the Order are not applicable to the Company.
xvi) a) According to the information and explanations given to us, the provisions of section 45-IA of the Reserve Bank of India Act, 1934
are not applicable to the Company.
b) The Company is not engaged in any Non-Banking Financial or Housing Finance activities. Accordingly, the requirement to report
on clause 3 (xvi)(b) of the Order is not applicable to the Company.
c) The Company is not a Core Investment Company (CIC) as defined in the regulations made by the Reserve Bank of India. Accordingly,
clause 3(xvi)(c) of the Order is not applicable.
d) According to the information and explanations provided to us during the course of audit, the Group does not have any CIC.
Accordingly, the requirements of clause 3(xvi)(d) are not applicable.
xvii) Based on the overall review of standalone financial statements, the Company has not incurred cash losses in the current financial
year and in the immediately preceding financial year. Hence, the provisions stated in paragraph clause 3 (xvii) of the Order are not
xviii) There has been no resignation of the statutory auditors during the year and accordingly, requirement to report on Clause 3(xviii) of
the Order is not applicable to the Company.
xix) According to the information and explanations given to us and on the basis of the financial ratios, ageing and expected dates
of realisation of financial assets and payment of financial liabilities, other information accompanying the financial statements,
our knowledge of the Board of Directors and management plans and based on our examination of the evidence supporting the
assumptions, nothing has come to our attention, which causes us to believe that any material uncertainty exists as on the date of
the audit report that the Company is not capable of meeting its liabilities existing at the date of balance sheet as and when they
fall due within a period of one year from the balance sheet date. We, however, state that this is not an assurance as to the future
viability of the Company. We further state that our reporting is based on the facts up to the date of the audit report and we neither
give any guarantee nor any assurance that all liabilities falling due within a period of one year from the balance sheet date, will get
discharged by the Company as and when they fall due.
73
xx) a) There are no unspent amounts towards Corporate Social Responsibility (CSR) on other than ongoing projects requiring a transfer
to a Fund specified in Schedule VII to the Companies Act in compliance with second proviso to sub-section (5) of Section 135 of
the said Act. Accordingly, reporting under clause 3(xx)(a) of the Order is not applicable for the year.
b) There are no unspent amounts towards Corporate Social Responsibility (CSR) as at the end of financial year on ongoing projects
requiring a transfer to a Special account in compliance with Section 135 (6) of the Act and the Company has transferred unspent
Corporate Social Responsibility (CSR) amount as at the end of the previous financial year, to a Special account within a period of
30 days from the end of the said financial year in compliance with the provision of section 135(6) of the Act.
xxi) The reporting under clause 3(xxi) of the Order is not applicable in respect of audit of standalone financial statements. Accordingly,
no comment in respect of the said clause has been included in the report.

per Kailash Kumar

Partner
Membership No.: 505972
Place : Chandigarh
Date : 13.05.2022
74
Annexure B to Independent Auditor’s Report Referred to in paragraph 7 of our Report of even date
Report on the Internal Financial Controls under Clause (i) of sub-section 3 of Section 143 of the Act
1. We have audited the internal financial controls over financial reporting of Steel Strips Wheels Limited (“the Company”) as of March 31,
2022 in conjunction with our audit of the financial statements of the Company for the year ended on that date.
Management’s Responsibility for Internal Financial Controls
2. The Company’s management is responsible for establishing and maintaining internal financial controls based on the internal control
over financial reporting criteria established by the Company considering the essential components of internal control stated in the
Guidance Note on Audit of Internal Financial Controls over Financial Reporting issued by the Institute of Chartered Accountants of
India (ICAI). These responsibilities include the design, implementation and maintenance of adequate internal financial controls that
were operating effectively for ensuring the orderly and efficient conduct of its business, including adherence to company’s policies,
the safeguarding of its assets, the prevention and detection of frauds and errors, the accuracy and completeness of the accounting
records, and the timely preparation of reliable financial information, as required under the act.
Auditors’ Responsibility
3. Our responsibility is to express an opinion on the company’s internal financial control over financial reporting based on our audit. We
conducted our audit in accordance with the Guidance Note on audit of internal financial control over financial reporting (the “Guidance
Notes”) and the standards on auditing deemed to be prescribed under section 143(10) of the act to the extent applicable to an audit
of internal financial controls, both applicable to an audit of internal financial controls and both issued by the ICAI. Those standards
and the guidance notes require that we comply with ethical requirements and planned and performed the audit to obtain reasonable
assurance about whether adequate internal financial control over financial reporting was established and maintained and if such
controls operated effectively in all material respects.
4. Our audit involves performing procedures to obtain audit evidence about the adequacy of the internal financial controls system over
financial reporting and their operating effectiveness. Our audit of internal financial controls system over financial reporting included
obtaining an understanding of internal financial controls system over financial reporting, assessing the risks that material weakness
exists, and testing and evaluating the design and operating effectiveness of the internal control based on the assessed risk. The
procedures selected depend on the auditor’s judgement, including the assessment of the risks of material misstatements of the
financial statements, whether due to fraud or error.
5. We believe that the audit evidence we have obtained in our audits is sufficient and appropriate to provide a basis for our audit opinion
on the company’s internal financial controls system over financial reporting.
Meaning of Internal financial controls over financial reporting
6. A company’s internal financial controls over financial reporting is a process designed to provide reasonable assurance regarding the
reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted
accounting principles. A company’s internal financial controls over financial reporting includes those policies and procedures that
(1.) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of
the assets of the company (2.) provide reasonable assurance that transactions are recorded as necessary to permit preparation of
financial statements in accordance with generally accepted accounting principles, and that receipts and expenditure of the company
are being made only in accordance with authorization of management and directors of the company ; and (3.) provide reasonable
assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the company’s assets that could
have a material effect on the financial statements.
Inherent Limitation of Internal financial controls over financial reporting
7. Because of the Inherent limitation of internal financial controls over financial reporting, including the possibility of collusion or improper
management over-ride of controls, material misstatements due to error or fraud may occur and not be detected. Also, projection of any
evaluations of the internal financial controls over financial reporting to future periods are subject to the risk that the internal financial
controls over financial reporting may become inadequate because of changes in conditions, or that the degree of compliance with the
policies or procedures may deteriorate.
Opinion
8. In our opinion, the company has, in all material respects, an adequate internal financial controls over financial reporting and such
internal financial controls over financial reporting were operating effectively as at March 31st, 2022 based on the internal financial
controls over financial reporting criteria established by the company considering the essential components of internal control stated
in the guidance note on audit of internal financial controls over financial reporting issued by the Institute of Chartered Accountants of
India.

per Kailash Kumar

Partner Place : Chandigarh
Membership No.: 505972 Date : 13.05.2022
75
BALANCE SHEET
(All amounts ₹ in Lakhs, unless stated otherwise)

Particulars Note no. As at As at
31st March 2022 31st March 2021
ASSETS
Non-current assets
a) Property, plant and equipment 3 1,35,826.81 1,25,737.56
b) Capital work-in-progress 4 9,694.38 10,933.90
c) Other Intangible assets 5 134.98 180.26
d) Financial assets
i) Investments 6 19.40 19.40
ii) Loans 7 2,223.51 1,139.14
iii) Other Financial assets 8 791.20 906.56
e) Other non-current assets 9 1,012.06 3,672.60
Total Non-Current assets 1,49,702.34 1,42,589.42
Current assets
a) Inventories 10 64,698.69 49,647.90
b) Financial assets
i) Trade receivables 11 39,233.65 25,708.06
ii) Cash and Cash equivalents 12 2,320.42 2,791.83
iii)Bank balances other than above 13 3,470.55 2,527.75
iv) Loans 14 412.28 283.98
v) Other financial asset 15 0.05 54.18
c) Current tax assets (net) 16 - 230.58
d) Other current assets 17 10,321.06 13,840.62
Total Current assets 1,20,456.70 95,084.90
Total Assets 2,70,159.04 237,674.32
EQUITY AND LIABILITIES

a) Equity Share capital 18 1,560.95 1,560.95
b) Share Application Money pending allotment - -
c) Other equity 19 93,622.77 73,368.86
Total Equity 95,183.72 74,929.81
Non-current liabilities
a) Financial liabilities
i) Borrowings 20 27,925.43 37,978.07
ii) Others financial liabilities 21 7,505.16 8,014.74
b) Provisions 22 2,345.66 1,147.95
c) Deferred tax liabilities (Net) 23 17,064.15 16,371.29
Total Non-Current Liabilities 54,840.40 63,512.05
Current liabilities
a) Financial liabilities
i) Borrowings 24 49,864.42 55,745.86
ii) Trade and other payables
Total outstanding dues of micro enterprises and small enterprises 25 2,093.31 1,128.59
Total outstanding dues of creditors other than micro enterprises and small 63,819.18 40,095.09
enterprises
iii) other financial liabilities 26 - -
b) Current Tax Liabilities (Net) 27 182.11 -
c) Provisions 28 456.44 660.12
d) Other current liabilities 29 3,719.46 1,602.80
Total Current Liabilities 1,20,134.92 99,232.46
Total Equity and liabilities 2,70,159.04 2,37,674.32
The accompanying notes are an integral part of these financial statements (1-52)
As per our report of even date attached
Chartered Accountants Sanjay Garg Rajinder Kumar Garg
ICAI Firm Registration Number: 021179N Ajit Singh Chatha Chairman
Shashi Bhushan Gupta
Virander Kumar Arya Manohar lal Jain
Surinder Singh Virdi Executive Director
per Kailash Kumar Siddharth Bansal
Partner Deva Bharathi Reddy Naveen Sorot
Membership Number : 505972 Directors CFO
Place : Chandigarh Shaman Jindal

Date : 13th May 2022 Company Secretary
76
STATEMENT OF PROFIT & LOSS ACCOUNT

S. No. Particulars Notes Year Ended Year Ended
I Revenue from operations 30 3,55,995.34 1,74,941.53

II Other Income 31 1,302.66 1,631.81
Total income(I+II) 3,57,298.00 1,76,573.34
III Expenses
a Cost of materials consumed 32 2,22,164.98 1,08,236.99
b Change in inventories of finished goods, stock in trade and work -in- 33 (3,450.63) 1,670.88
progress
c Employee benefit expense 34 21,867.52 15,294.47
d Finance costs 35 8,542.09 8,393.14
e Depreciation and amortisation expense 36 7,686.99 7,231.13
f Other expenses 37 70,135.19 29,363.74
Total Expenses III (a to f) 3,26,946.14 1,70,190.35
IV Profit/(loss) before exceptional items and tax (I+II-III) 30,351.86 6,382.99

V Exceptional items 38 - 0.09
VI Profit/(loss) before tax after exceptional items(IV-V) 30,351.86 6,382.90
VII Tax expense: (refer note 51)
(1) Current tax 8,934.51 453.52
(2) Deferred tax 843.50 1,004.36
Prior years tax Adjustments 27.44 -
VIII Profit/(loss) for the period after Tax (VI-VII) 20,546.41 4,925.02
IX Other Comprehensive Income (257.30) 9.80
A (i) Items that will not be reclassified to profit or loss
-Re-measurement gains (losses) on defined benefit plans (395.81) 15.07
-Income tax relating to above items 138.51 (5.27)
X Total Comprehensive Income for the period (VIII+IX)(Comprising Profit/ 20,289.11 4,934.82
(Loss) and Other Comprehensive Income for the period)
XI Paid-up equity share capital (Face value of Rs 5 per share) 1,560.95 1,560.95
XII Earnings per equity share in Rs. (refer note 39)
(1) Basic (in ₹) 65.81 15.78
(2) Diluted (in ₹) 65.65 15.74

77
CASH FLOW STATEMENT

S. Particulars For Year Ended For Year Ended
No. 31st March 2022 31st March 2021
A. Cash Inflow/ (Outflow) from Operating activities
Profit before tax 30,094.56 6,392.70
Depreciation 7,686.99 7,231.13
(Profit)/ Loss on sale of assets (60.58) (72.51)
Interest received (1,079.41) (1,105.46)
Financial charges paid 8,542.09 15,089.09 8,393.14 14,446.30
Operating profit before working capital changes 45,183.65 20,839.00
Adjustment for
- (Increase)/ decrease in inventory (15,050.79) (16,717.28)
- (Increase)/ decrease in trade and other receivables (13,599.76) (5,610.37)
- ‘Non Current/Current Financial Liabilities and Assets provision 4,510.19 -
- Changes in Tax Provision (500.89) -
- Increase/ (decrease) in trade payables 24,688.81 47.56 19,860.51 (2,467.14)
Cash inflow from operating activities 45,231.21 18,371.86
Taxes paid 4,620.00 1,457.88
Net cash from / (used) in operating activities 40,611.21 16,913.98
B Cash flows from/ (used) in Investing Activities

Purchase of fixed assets (16,912.94) (5,626.63)
Sale of fixed assets 421.50 743.32
Profit on sale of investments / Assets 60.58 72.51
Interest received 1,079.41 1,105.46
Net cash from / (used) in investing activities (15,351.45) (3,705.34)
C Cash flows from/ (used) in Financing Activities

Proceeds from issue of equity shares incl premium - 1.98
Proceeds from long term borrowings 12,256.43 10,660.00
Proceeds(payment) from/(of)long term Provisions/Short Term Provisions / - 1,013.32
Change in Reserve/Change in Tax Provisions
Repayment of long term borrowings (net of fluctuation) (29,649.63) (10,436.26)
Changes in working capital loans/short term borrowings 1,459.10 (6,248.87)
(Increase)/Decrease in Long/short Term Loan and Advances - (3,656.36)
Dividend paid (312.19) -
Financial charges paid (8,542.09) (8,393.14)
Net cash from / (used) in financing activities (24,788.38) (17,059.33)
Net increase/(decrease) in cash and cash equivalents 471.38 (3,850.69)
Cash and cash equivalents as at April 1, 2021 5,319.59 9,170.28

Cash and cash equivalents as at March 31, 2022 5,790.97 5,319.59
AUDITORS’ CERTIFICATE
We have verified the attached Cash Flow Statement of M/s Steel Strips Wheels Limited derived from audited financial statements and the
books & records maintained by the Company for the year ended 31st March, 2022 and found the same in agreement therewith.

78
Notes on Financial Statement for the year ended 31st March 2022.
1) CORPORATE INFORMATION
Steel Strips Wheels Limited (the Company) is a public limited Company registered in India under the Companies Act 2013 (Erstwhile
Companies Act 1956). Its Shares are listed on both Bombay stock Exchange and National Stock Exchange. The Company is a leading
manufacturer of Automotive Wheel rims.
These financial statements were approved and adopted by company’s board of directors in its meeting held on 13th May 2022.
2) SIGNIFICANT ACCOUNTING POLICIES
1) BASIS OF PREPARATION
1.1 Statement of Compliance
These financial statements have been prepared in accordance with Indian Accounting Standards (‘Ind AS’) notified under
section 133 of the Companies Act 2013 (the Act)(to the extent notified), read together with the Companies (Indian Accounting
Standards) Rules, 2015 and other relevant amendment rules issued thereafter.
Effective April 1, 2016, the company has adopted all the Ind As standards and the adoption was carried out in accordance with
Ind AS 101, “First Time Adoption of Indian Accounting Standards, with April 1, 2015 as the transition date. The transition was
carried out from Indian Accounting Principles generally accepted in India as prescribed under Section 133 of the Act, read with
Rule 7 of the Companies (Accounts) Rules, 2014 (IGAAP), which was the previous GAAP.
The accounting policies have been consistently applied by the Company and except for the changes in accounting policy
discussed more fully below, are consistent with those used in the previous year.
1.2 Basis of measurement
The Standalone financial statements have been prepared under the historical convention, on the accrual basis of accounting
except for certain financial instruments that are measured at fair value.
1.3 Use of estimates and judgements
The preparation of the financial statements in conformity with Ind AS requires management to make estimates, judgments
and assumptions that affect the application of accounting policies and the reported amounts of assets, liabilities, revenue and
expenses. Actual results may differ from these estimates.
2) REVENUE RECOGNITION
Revenue is recognized to the extent that it is probable that economic benefits will flow to the Company and the revenue can be
reliably measured.
A. SALE OF GOODS
Revenue from sale of goods is recognized when the significant risks and rewards of ownership in the goods are transferred to the
buyer of goods as per the terms of contracts, the Company retains no effective control of the goods transferred to a degree usually
associated with the ownership and no significant uncertainty exists regarding the amount of the consideration that will be derived
from the sale of goods. The Company collects GST on the behalf of the Government and therefore these are not economic benefits
flowing to the company. Hence they are excluded from Revenue.
Further Revenue is measured by the Company at the fair value of the consideration received/receivable from its customers and
in determining the transaction price for the sale of finished goods, the Company considers the effect of various factors such as
price differences and volume-based discounts, rebates and other promotion incentive schemes (“trade schemes”) provided to the
customers. Adequate provisions have been made for such price differences and trade schemes with a corresponding impact on
the revenue. Accordingly, revenue for the current year is net price differences, trade schemes, rebates, discounts, etc.
B. INTEREST INCOME
Interest income from a financial instrument is recognized when it is probable that the economic benefits will flow to the company
and the amount of income can be measured reliably using EIR method. EIR is the rate that exactly discounts the estimated future
cash payments or receipts over the expected life of the financial instrument or a shorter period, where appropriate, to the gross
carrying amount of the financial asset. When calculating the effective interest rate, the Company estimates the expected cash
flows by considering all the contractual terms of the financial instrument but does not consider the expected credit losses.
C. OTHER INCOME
(i) Dividend Income is recognized when the right to receive the payment is established, which is generally when shareholders
approve the dividend.
(ii) Revenue in respect of claims is recognized when no significant uncertainty exists with regard to the amount to be realized
and the ultimate collection thereof.
D. Duty drawback and export incentives
Income from duty drawback and export incentives is recognized on accrual basis.
3) Leasing
The Company has adopted Ind AS 116-Leases effective 1st April, 2019, using the modified retrospective method. The Company has
applied the standard to its leases with the cumulative impact recognized on the date of initial application (1st April, 2019). Accordingly,
previous period information has not been restated.
The Company’s lease asset classes primarily consist of leases for Land and Buildings. The Company assesses whether a contract is
or contains a lease, at inception of a contract. A contract is, or contains, a lease if the contract conveys the right to control the use of an
79
identified asset for a period of time in exchange for consideration. To assess whether a contract conveys the right to control the use of
an identified asset, the Company assesses whether:
(i) the contract involves the use of an identified asset
(ii) the Company has substantially all of the economic benefits from use of the asset through the period of the lease and
(iii) the Company has the right to direct the use of the asset.
At the date of commencement of the lease, the Company recognizes a right-of-use asset (“ROU”) and a corresponding lease
liability for all lease arrangements in which it is a lessee, except for leases with a term of twelve months or less (short term leases)
and leases of low value assets. For these short term and leases of low value assets, the Company recognizes the lease payments
as an operating expense on a straight-line basis over the term of the lease.
The right-of-use assets are initially recognized at cost, which comprises the initial amount of the lease liability adjusted for any lease
payments made at or prior to the commencement date of the lease plus any initial direct costs less any lease incentives. They are
subsequently measured at cost less accumulated depreciation and impairment losses, if any. Right-of-use assets are depreciated
from the commencement date on a straight-line basis over the shorter of the lease term and useful life of the underlying asset. The
lease liability is initially measured at the present value of the future lease payments. The lease payments are discounted using
the interest rate implicit in the lease or, if not readily determinable, using the incremental borrowing rates. The lease liability is
subsequently re-measured by increasing the carrying amount to reflect interest on the lease liability, reducing the carrying amount
to reflect the lease payments made. A lease liability is re-measured upon the occurrence of certain events such as a change in
the lease term or a change in an index or rate used to determine lease payments. The re-measurement normally also adjusts the
leased assets.
4) ACCOUNTING FOR TAXES ON INCOME
Tax expense comprises current and deferred tax. Current income-tax is measured at the amount expected to be paid to the tax
authorities in accordance with the Income-tax Act, 1961 enacted in India and tax laws prevailing in the respective tax jurisdictions where
the company operates. The tax rates and tax laws used to compute the amount are those that are enacted or substantively enacted, at
the reporting date.
Deferred income taxes reflect the impact of timing differences between taxable income and accounting income originating during the
current year and reversal of timing differences for the earlier years. Deferred tax is measured using the tax rates and the tax laws
enacted or substantively enacted at the reporting date.
Deferred tax liabilities are recognized for all taxable timing differences. Deferred tax assets are recognized for deductible timing
differences only to the extent that there is reasonable certainty that sufficient future taxable income will be available against which
such deferred tax assets can be realized. In situations where the company has unabsorbed depreciation or carry forward tax losses, all
deferred tax assets are recognized only if there is virtual certainty supported by convincing evidence that they can be realized against
future taxable profits.
At each reporting date, the Company re-assesses unrecognized deferred tax assets. It recognizes unrecognized deferred tax asset to
the extent that it has become reasonably certain or virtually certain, as the case may be, that sufficient future taxable income will be
available against which such deferred tax assets can be realized.
The carrying amount of deferred tax assets are reviewed at each reporting date. The Company writes-down the carrying amount of
deferred tax asset to the extent that it is no longer reasonably certain or virtually certain, as the case may be, that sufficient future
taxable income will be available against which deferred tax asset can be realized. Any such write-down is reversed to the extent that it
becomes reasonably certain or virtually certain, as the case may be, that sufficient future taxable income will be available.
Deferred tax assets and deferred tax liabilities are offset, if a legally enforceable right exists to set-off current tax assets against current
tax liabilities and the deferred tax assets and deferred taxes relate to the same taxable entity and the same taxation authority.
MAT credit is recognized as an asset only when and to the extent there is convincing evidence that the company will pay normal income
tax during the specified period. In the year in which the Minimum Alternative tax (MAT) credit becomes eligible to be recognized as
an asset in accordance with the recommendations contained in guidance Note issued by the Institute of Chartered Accountants of India,
the said asset is created by way of a credit to the profit and loss account and shown as MAT Credit Entitlement. The Company reviews
the same at each balance sheet date and writes down the carrying amount of MAT Credit Entitlement to the extent there is no longer
convincing evidence to the effect that Company will pay normal Income Tax during the specified period.
5) IMPAIRMENT OF NON FINANCIAL ASSETS
A. At each Balance Sheet date, the carrying amount of assets is tested based on internal/external factors, for impairment so as to
determine:
(i) The provision for impairment loss, if any; and
(ii) The reversal of impairment loss recognized in previous periods, if any,
B. Impairment loss is recognized when the carrying amount of an asset exceeds its recoverable amount. Recoverable amount is
determined:
(i) In the case of an individual asset, higher of the net selling price and the value in use.
(ii) In the case of a cash generating unit (a group of assets that generates identified, independent cash flows), at the higher of the
cash generating unit’s net selling price and the value in use.
(Value in use is determined as the present value of estimated future cash flows discounted to their present value at the
weighted average cost of Capital, from the continuing use of an asset and from its disposal at the end of its useful life).
Post impairment, depreciation is provided on the revised carrying value of the asset over its remaining useful life.
80
6) CASH AND CASH EQUIVALENTS
Cash and cash equivalents balances include cash in hand, fixed deposits, margin money deposits, earmarked balances with banks,
other bank balances such as dividend accounts, which have restrictions on repatriation, highly liquid investments with original maturities
of three months or less that are readily convertible to known amounts of cash and which are subject to an insignificant risk of change in
value.
7) INVENTORIES
Inventories are valued at cost or net realizable value, whichever is lower. The cost in respect of the various items of inventory is
computed as under:
a) In case of raw materials at weighted average cost plus direct expenses. The cost includes cost of purchase and other costs
incurred in bringing the inventories to their present location and condition.
b) In case of stores and spares at weighted average cost plus direct expenses. The cost includes cost of purchase and other costs
incurred in bringing the inventories to their present location and condition.
c) In case of work in progress at raw material cost plus conversion costs depending upon the stage of completion.
d) In case of finished goods at raw material cost plus conversion costs, packing cost, excise duty (if applicable) and other overheads
incurred to bring the goods to their present location and condition.
8) Financial Instrument
A financial instrument is any contract that gives rise to a financial asset of one entity and a financial liability or equity instrument of
another entity.
Initial recognition and measurement
On initial recognition, all the financial assets and liabilities are recognized at its fair value plus or minus, in the case of a financial asset
or financial liability not at fair value through profit or loss, transaction costs that are directly attributable to the acquisition or issue of the
financial asset or financial liability except trade receivables which are recognized at transaction price.
Subsequent measurement
Non-derivative financial instruments
(i) Financial assets carried at amortized cost
A financial asset is subsequently measured at amortized cost if it is held within a business model whose objective is to hold the
asset in order to collect contractual cash flows and the contractual terms of the financial asset give rise on specified dates to cash
flows that are solely payments of principal and interest on the principal amount outstanding.
(ii) Financial assets at fair value through other comprehensive income
A financial asset is subsequently measured at fair value through other comprehensive income if it is held within a business model
whose objective is achieved by both collecting contractual cash flows and selling financial assets and the contractual terms of the
financial asset give rise on specified dates to cash flows that are solely payments of principal and interest on the principal amount
outstanding.
(iii) Financial assets at fair value through profit or loss
A financial asset which is not classified in any of the above categories is subsequently measured at fair value through profit or
loss.
(iv) Financial liabilities
The financial liabilities are subsequently carried at amortized cost using the effective interest method. For trade and other payables
maturing within one year from the balance sheet date, the carrying amounts approximate fair value due to the short maturity of
these instruments.
Derivative financial instruments
The Company holds derivative financial instruments such as foreign exchange forward and option contracts to mitigate the risk of
changes in exchange rates on foreign currency exposures. The counterparty for these contracts is generally a bank.
Although the Company believes that these derivatives constitute hedges from an economic perspective, they may not qualify for hedge
accounting under Ind-AS 109, Financial Instruments. Any derivative that is either not designated a hedge, or is so designated but is
ineffective as per Ind-AS 109, is categorized as a financial asset or financial liability, at fair value through profit or loss.
Derivatives not designated as hedges are recognized initially at fair value and attributable transaction costs are recognized in the
statement of profit and loss when incurred. Subsequent to initial recognition, these derivatives are measured at fair value through profit
or loss and the resulting exchange gains or losses are included in statement of profit and loss. Assets/ liabilities in this category are
presented as current assets/current liabilities if they are either held for trading or are expected to be realized within 12 months after the
balance sheet date.
Equity Share Capital
(i) Equity shares
Equity shares issued by the Company are classified as equity. Incremental costs directly attributable to the issuance of new ordinary
shares are recognized as a deduction from equity, net of any tax effects.
De-recognition of financial instruments
A financial asset is derecognized when the contractual rights to the cash flows from the financial asset expire or it transfers the financial
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asset and the transfer qualifies for Derecognition under Ind-AS 109. A financial liability is derecognized when the obligation specified in
the contract is discharged or cancelled or expired.
Fair value measurement of financial instruments
The fair value of financial instruments is determined using the valuation techniques that are appropriate in the circumstances and for
which sufficient data are available to measure fair value, maximizing the use of relevant observable inputs and minimizing the use of
unobservable inputs.
Based on the three level fair value hierarchies, the methods used to determine the fair value of financial assets and liabilities include
quoted market price, discounted cash flow analysis and valuation certified by the external valuer.
In case of financial instruments where the carrying amount approximates fair value due to the short maturity of those instruments,
carrying amount is considered as fair value.
9) Property, plant and equipment(PPE)
Fixed assets are stated at original cost net of tax/duty credit availed, if any, less accumulated depreciation and cumulative impairment
and those which have been revaluated are stated at the values determined by the valuers less accumulated depreciation and cumulative
impairment. Cost of acquisition is inclusive of freight and other incidental expenses and interest on loan taken for the acquisition of
qualifying assets up to the date of commissioning of assets.
Subsequent expenditure related to PPE is capitalized only when it is probable that future economic benefits associated with these will
flow to the company and cost of the item can be measured reliably. All other expenses on existing fixed assets, including day to day
repair and maintenance expenditure and cost of replacing parts, are charged to the statement of profit and loss for the period during
which such expenses are incurred.
Gain or losses arising from de-recognition of fixed assets are measured as the difference between the net disposable proceeds and the
carrying amount of the asset and are recognized in the statement of profit and loss when the asset is derecognized.
The exchange differences arising on reporting of long term foreign currency monetary items at rates different from those at which they
were initially recorded during the period, or reported in previous financial statements, in so far as they relate to the acquisition of a
depreciable capital asset, have been added to or deducted from the cost of the asset and shall be depreciated over the balance useful
life of the asset.
Die Tooling, developed in-house, includes cost of material and other direct/ incidental expense on in-house development.
Tangible Assets not ready for the intended use on the date of the balance Sheet are disclosed as “capital work in progress”.
Transition to Ind AS
For transition to Ind AS, The Company has elected to continue with the carrying value of all of its PPE recognized as of 01 April, 2016
(transition date) measured as per the previous GAAP and use that carrying value as its deemed cost as of the transition date.
10) DEPRECIATION / AMORTIZATION ON TANGIBLE FIXED ASSETS
Depreciation is the systematic allocation of the depreciable amount of an asset over useful life. The depreciable amount of an asset is
the cost of an asset or other amount substituted for cost, less its residual value.
A. OWNED ASSETS
(i) Pursuant to applicability of Schedule II, of Companies Act 2013, with effect from 1st April 2014, Management has reassessed
the useful life of tangible assets based on the internal and external technical evaluation. The Depreciation on fixed assets is
provided on straight line method in accordance with applicable Schedule of the Companies Act, 2013.
(ii) Depreciation for addition to/deductions from, owned assets is calculated on pro-rata basis from the date of such addition or,
as the case may be, up to the date on which such asset has been sold, discarded, demolished or destroyed.
(iii) Residual values of assets have been considered at 5% of the original cost of the assets.
(iv) Difference of Exchange Rate fluctuation on imported plant and machineries procured out of long term foreign currency loans
is amortized over the residual life of relevant plant and machineries.
(v) Depreciation on assets carried at carrying amount as on 01.04.2014 and is depreciated as per Straight line method over the
remaining useful life of the assets. Further the assets whose remaining useful life are nil, has been recognized in the opening
balance of retained earnings. Refer the same as transitional provision
(vi) The depreciation calculation is based on the balance useful lives of assets and shift working. Depreciation on assets used
on double shift basis have been increase by 50% for that period and Depreciation on assets used in triple shift basis have be
calculated on the basis of 100% for that period, Except for assets in respect of which no extra shift depreciation is permitted
(indicated by NESD in Part C of the schedule).
(vii) Management has reassessed the useful life of plant and machineries based on the internal and external technical evaluation
which is higher than useful life prescribed under the act. The reassessed useful life is tabulated as:
Location Useful Life as per Average useful life Balance Avg. useful Life as on
Act (in Years) (in years) 01/04/2014
Dappar 15.00 23.85 17.11
Chennai 15.00 23.29 19.72
JSR 15.00 24.96 23.17
Seraikella 15.00 15.00 15.00
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B. LEASED ASSETS
The Company has adopted Ind AS 116 effective 1st April, 2019, using the modified retrospective method. The Company has applied
the standard to its leases with the cumulative impact recognized on the date of initial application (1st April, 2019). Accordingly,
previous period information has not been restated.
In the statement of profit and loss for the current year, operating lease expenses which were recognized as other expenses in
previous periods is now recognized as depreciation expense for the right-of-use asset and finance cost for interest accrued on
lease liability. The adoption of this standard did not have any significant impact on the profit for the year and earnings per share.
11) INTANGIBLE ASSETS AND AMORTIZATION
Intangible assets are stated at original cost net of tax/duty credit availed, if any, less accumulated amortization and cumulative
impairment. Intangible assets are recognized when it is probable that the future economic benefits are attributable to the asset will flow
to the enterprise and the cost of asset can be measured reliably. Intangible assets are amortized over their estimated useful life. The
estimated useful life of an identifiable intangible asset is based on number of factors including the effects of obsolescence etc.
Intangible Assets not ready for the intended use on the date of balance sheet are disclosed as “intangible assets under development”
12) Borrowings
Borrowings are initially recognized at fair value, net of transaction costs incurred. Borrowings are subsequently measured at amortized
cost. Any difference between the proceeds (net of transaction costs) and the redemption amount is recognized in profit or loss over
the period of the borrowings using the effective interest method. Fees paid on the establishment of loan facilities are recognized as
transaction costs of the loan to the extent that it is probable that some or all of the facility will be drawn down. In this case, the fee is
deferred until the draw down occurs. To the extent there is no evidence that it is probable that some or all of the facility will be drawn
down, the fee is capitalized as a prepayment for liquidity services and amortized over the period of the facility to which it relates.
Borrowings are removed from the balance sheet when the obligation specified in the contract is discharged, cancelled or expired.
The difference between the carrying amount of a financial liability that has been extinguished or transferred to another party and the
consideration paid, including any non-cash assets transferred or liabilities assumed, is recognized in profit or loss as other income or
finance costs.
Borrowings are classified as current liabilities unless the Company has an unconditional right to defer settlement of the liability for at
least 12 months after the reporting period.
13) BORROWING COST
Borrowing costs that are directly attributable to acquisition, construction or production of a qualifying asset are capitalized/ inventorized
as part of cost of such assets till such time the asset is ready for its intended use/or sale. Qualifying asset is one that necessarily takes
substantial period of time to get ready for its intended use.
All other borrowing costs are expensed in the period in which they are incurred.
14) Provision
Provisions are recognized when the company has a present obligation (legal or constructive) as a result of a past event, it is probable
that the company will be required to settle the obligation, and a reliable estimate can be made of the amount of the obligation.
The amount recognized as a provision is the best estimate of the consideration required to settle the present obligation at the end of
the reporting period, taking into account the risks and uncertainties surrounding the obligation. When a provision is measured using the
cash flows estimated to settle the present obligation, its carrying amount is the present value of those cash flows (when the effect of the
time value of money is material).
When some or all of the economic benefits required to settle a provision are expected to be recovered from a third party, a receivable
is recognized as an asset if it is virtually certain that reimbursement will be received and the amount of the receivable can be measured
reliably.
15) Contingent liabilities
Contingent liabilities are disclosed when there is a possible obligation arising from past events whose existence will be confirmed by
the occurrence or non-occurrence of one or more uncertain future events not wholly within the control of the Company or a present
obligation that arises from part events where it is not probable that an outflow of resources will be required to settle the obligation.
A contingent liability also arises in extremely rare cases where there is a liability that cannot be recognized because it cannot be
measured reliably.
16) Employee benefits
Short-term obligations
Liabilities for wages and salaries, including non-monetary benefits that are expected to be settled wholly within 12 months after the end
of the period in which the employees render the related service are recognized in respect of employees’ services up to the end of the
reporting period and are measured at the amounts expected to be paid when the liabilities are settled. The liabilities are presented as
current employee benefit obligations in the balance sheet.
Provident Fund & Employee State Insurance
Contribution towards provident fund and employee state insurance for employees is made to the regulatory authorities, where the
Company has no further obligations. Such benefits are classified as Defined Contribution Schemes as the Company does not carry any
further obligations, apart from the contributions made on a monthly basis.
83
Gratuity
The Company provides for gratuity, a defined benefit plan (the “Gratuity Plan”) covering eligible employees in accordance with the
Payment of Gratuity Act, 1972. The Gratuity Plan provides a lump sum payment to vested employees at retirement, death, incapacitation
or termination of employment, of an amount based on the respective employee’s salary and the tenure of employment. The gratuity plan
in Company is funded through annual contributions to Life Insurance Corporation of India (LIC) under its Company’s Gratuity Scheme
whereas others are not funded. The liability or asset recognized in the balance sheet in respect of defined benefit gratuity plans is the
present value of the defined benefit obligation at the end of the reporting period less the fair value of plan assets. The Company’s liability
is actuarially determined (using the Projected Unit Credit method) at the end of each year. The present value of the defined benefit
obligation is determined by discounting the estimated future cash outflows using interest rates of government bonds. Re-measurement
gains and losses arising from experience adjustments and changes in actuarial assumptions are charged or credited to equity in other
comprehensive income in the period in which they arise. They are included in retained earnings in the statement of changes in equity
and in the balance sheet. Past-service costs are recognized immediately in profit or loss.
Compensated Absences
Accumulated compensated absences, which are expected to be availed or encashed within 12 months from the end of the year end
are treated as short term employee benefits. The obligation towards the same is measured at the expected cost of accumulating
compensated absences as the additional amount expected to be paid as a result of the unused entitlement as at the year end.
Accumulated compensated absences, which are expected to be availed or encashed beyond 12 months from the end of the year end
are treated as other long term employee benefits. The Company’s liability is actuarially determined (using the Projected Unit Credit
method) at the end of each year. The present value of the defined benefit obligation is determined by discounting the estimated future
cash outflows using interest rates of government bonds. Actuarial gains and losses arising from experience adjustments and changes
in actuarial assumptions are recognized in profit or loss in the period in which they arise. Past-service costs are recognized immediately
in profit or loss.
17) Share-based payment arrangements
Equity-settled share-based payments to employees and others providing similar services are measured at the fair value of the equity
instruments at the grant date. The fair value determined at the grant date of the equity-settled share-based payments is expensed
on a straight-line basis over the vesting period, based on the Company’s estimate of equity instruments that will eventually vest, with
a corresponding increase in equity. At the end of each reporting period, the Company revises its estimate of the number of equity
instruments expected to vest. The impact of the revision of the original estimates, if any, is recognized in the statement of profit and
loss such that the cumulative expense reflects the revised estimate, with a corresponding adjustment to the equity settled share option
outstanding account. Equity-settled share-based payment transactions with parties other than employees are measured at the fair
value of the goods or services received, except where that fair value cannot be estimated reliably, in which case they are measured
at the fair value of the equity instruments granted, measured at the date the entity obtains the goods or the counterparty renders the
service. For cash-settled share-based payments, a liability is recognized for the goods or services acquired, measured initially at the
fair value of the liability. At the end of each reporting period until the liability is settled, and at the date of settlement, the fair value of the
liability is remeasured, with any changes in fair value recognized in profit or loss for the year.
18) TRANSACTIONS IN FOREIGN CURRENCY
A) Functional and Presentation currency
The functional currency of the Company is Indian Rupee. These financial statements are presented in Indian Rupee (rounded off
to lakhs).
B) Transaction and balances
The foreign currency transactions are recorded, on initial recognition in the functional currency, by applying to the foreign currency
amount the spot exchange rate between the functional currency and the foreign currency at the date of the transaction.
The foreign currency monetary items are translated using the closing rate at the end of each reporting period. Non-monetary
items that are measured in terms of historical cost in a foreign currency shall be translated using the exchange rate at the date
of the transaction. Exchange differences arising on the settlement of monetary items or on translating monetary items at rates
different from those at which they were translated on initial recognition during the period or in previous financial statements shall
be recognised in profit or loss in the period in which they arise.
Foreign exchange differences recorded as an adjustment to borrowing costs are presented in the statement of profit and loss,
within finance cost. All other foreign exchange gains and losses are presented in the statement of profit and loss on net basis.
19) SEGMENT REPORTING
Operating segments are reported in a manner consistent with the internal reporting to the Chief Operating Decision Maker “CODM” of
the Company. The CODM is responsible for allocating resources and assessing performance of the operating segment. The Company
has monthly review and forecasting procedure in place and CODM reviews the operations of the Company as a whole.
20) EARNING PER SHARE
Basic earnings per share are calculated by dividing the net profit or loss for the year attributable to equity shareholders (after deducting
attributable taxes and dividend on cumulative preference shares for the year) by the weighted average number of equity shares
outstanding during the year. Partly paid equity shares are treated as a fraction of an equity share to the extent that they were entitled
to participate in dividends relative to a fully paid equity share during the reporting period. The weighted average number of equity
shares outstanding during the period is adjusted for event of bonus issue/right issue etc; bonus element in a rights issue to existing
shareholders; share split; and reverse share split (consolidation of shares).
84
For the purpose of calculating diluted earnings per share, the net profit or loss for the period attributable to equity shareholders and the
weighted average number of shares outstanding during the period are adjusted for the effects of all dilutive potential equity shares.
21) Operating cycle
Based on the nature of products / activities of the Company and the normal time between acquisition of assets and their realization in
cash or cash equivalents, the Company has determined its operating cycle as 12 months for the purpose of classification of its assets
and liabilities as current and non-current.
22) SIGNIFICANT ACCOUNTING JUDGMENTS, ESTIMATES AND ASSUMPTIONS
In the process of applying the Company’s accounting policies, management has made the following estimates, assumptions and
judgments which have significant effect on the amounts recognized in the financial statement:
a) CONTINGENCIES
Judgment of the Management is required for estimating the possible outflow of resources, if any, in respect of contingencies/claim/
litigations against the Company as it is not possible to predict the outcome of pending matters with accuracy.
b) ALLOWANCE FOR UNCOLLECTED ACCOUNTS RECEIVABLE AND ADVANCES
Trade receivables do not carry any interest and are stated at their normal value as reduced by appropriate allowances for estimated
irrecoverable amounts. Individual trade receivables are written off when management deems them not collectible. Impairment is
made on ECL, which are the present value of the cash shortfall over the expected life of the financial assets.
c) DEFINED BENEFIT PLANS
The cost of the defined benefit plan and other post-employment benefits and the present value of such obligation are determined
using actuarial valuations. An actuarial valuation involves making various assumptions that may differ from actual developments in
future. These includes the determination of the discount rate, future salary increases, mortality rates and attrition rate. Due to the
complexities involved in the valuation and its long-term nature, a defined benefit obligation is highly sensitive to changes in these
assumptions. All assumptions are reviewed at each reporting date.
d) FAIR VALUE MEASUREMENT OF FINANCIAL INSTRUMENTS
When the fair values of financial assets and financial liabilities recorded in the balance sheet cannot be measured based on quoted
prices in active markets, their fair value is measured using valuation techniques including the Discounted Cash Flow (DCF) model.
The inputs to these models are taken from observable markets where possible, but where this is not feasible, a degree of judgment
is required in establishing fair values. Judgments include considerations of inputs such as liquidity risk, credit risk and volatility.
Changes in assumptions about these factors could affect the reported fair value of financial instruments.
AUDITORS’ REPORT
Certified in terms of our separate report of even date annexed.


85
Statement of Changes in Equity for the period ended 31 March 2022

(₹ In lacs)
A. Equity Share Capital
As at 31 March, 2020 1,558.97
Changes in equity share capital during the year 1.98
As at 31 March, 2021 1,560.95
Changes in equity share capital during the year -
As at 31 March, 2022 1,560.95
B. Other Equity
Reserve and surplus
PARTICULARS Share Securities Capital General Share Deferred Retained Total
Forefeiture premium Reserve Reserve Option Employee Earnings
Reserve reserve Outstanding Compen
sation
(a) Balance at 31 March, 2020 2,237.85 13,347.64 5,358.59 45,966.96 729.84 (529.52) 1,124.20 68,235.56
(i) Profit for the year - - - - - - 4,925.04 4,925.04

(ii) Other comprehensive income for - - - - - - 9.80 9.80
the year, net of income tax
(b) Total comprehensive income - - - - - - 4,934.84 4,934.84
for the year
Deductions during the year - -

(iii) Dividends including tax theron - - - - - - - -
(iv) Transfer to general reserve - - 2,381.34 - - (2,365.06) 16.28
(v) Shares issued/options - 182.69 - - (0.53) - - 182.16
excercised
(c) Balance at 31 March, 2021 2,237.85 13,530.33 5,358.59 48,348.30 729.31 (529.52) 3,693.98 73,368.84
(vi) Profit for the year - - - - - - 20,546.42 20,546.42

(vii) Other comprehensive income for - - - - - - (257.30) (257.30)
the year, net of income tax
(d) Total comprehensive income - - - - - - 20,289.12 20,289.12
for the year
Deductions during the year

(viii) Dividends including tax theron - - - - - - (312.19) (312.19)
(ix) Transfer to general reserve - - - 4,925.04 - - (4,925.05) (0.01)
(x) Shares issued/options excercised - - - - 277.00 - - 277.00
(e) As at 31 March, 2022 2,237.85 13,530.33 5,358.59 53,273.34 1006.31 (529.52) 18,745.86 93,622.76

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Summary of significant Standalone accounting policies and other explanatory information for the year ended 31st March 2022
Note-3 Property, plant and equipment

Particulars Freehold Leasehold Building Office Furniture Plant and Vehicle Total
land land equipments and fixtures machinery
Gross Carrying Value
Balance as at 31st March,2020 10,451.17 1,207.17 30,741.35 1,119.33 5,166.03 1,39,237.52 1,986.04 1,89,908.61
Additions 832.50 - 71.00 50.05 25.83 1,871.53 8.65 2,859.56
Disposals - - (17.29) (990.83) (73.06) (1,081.18)
Additions 10.25 5,511.20 72.15 107.30 12,343.45 - 18,044.35
Disposals - (5.73) - (19.74) (391.05) (4.98) (421.50)
Accumulated Depreciation
Balance as at 31st March,2020 - 163.98 5,705.98 780.53 3,264.75 48,321.87 1,199.02 59,436.13
Additions - 12.06 941.02 107.57 509.06 5,443.12 168.29 7,181.12
Disposals - - - - (16.24) (592.01) (59.70) (667.95)
Additions - 12.06 1,070.97 82.92 408.29 5,916.94 150.45 7,641.63
Disposals - - (0.36) - (17.39) (85.62) (4.73) (108.10)
Net carrying amount

Balance as at 31st March,2020 10,451.17 1,043.19 25,035.37 338.80 1,901.28 90,915.65 786.86 1,30,472.28
Notes:
1) The title deeds of all the immovable properties (other than properties where the Company is the lessee and the lease agreements are
duly executed in favour of the lessee), as disclosed in Note 3 on Property, plant and equipment and Note 5 on Other Intangible Assets
to the financial statements, are held in the name of the Company
2) Land for Oragadam plant in Chennai is obtained on 99 years of lease basis from State Industrial Promotion corporation of Tamilnadu
Limited(SIPCOT), a Government of Tamilnadu enterprises. The total cost of Lease hold land is amortised over a period of 99 years.
Accordingly a sum of Rs. 12.06 Lacs ( Previous year Rs. 12.06 Lacs) is amortised during the period.
3) There is no change in the carrying value of Assets on the account of Revaluation of Assets.
4) Capital expenditure incurred on R & D Centre
Particular FY 2021-22 FY 2020-21 FY 2019-20
Dappar Mehsana Dappar Mehsana Dappar Mehsana
Plant & Machinery R & D 558.16 811.64 - - 517.90 -
Data Processing Equipments-R&D - 21.27 - 40.45 - -
Die Tooling (R&D) 1,068.21 - 16.71 - 1,010.63 -
Total 1,626.37 832.91 16.71 40.45 1,528.52 -
Less: Transfer/adjustments - - - - (52.61) -
Total R&D Capital Expenditure 1,626.37 832.91 16.71 40.45 1,475.92 -
Revenue expenditure incurred on R & D Centre
Particular FY 2021-22 FY 2020-21 FY 2019-20
Dappar Mehsana Dappar Mehsana Dappar Mehsana
SALARIES, WAGES AND OTHER ALLOWANCES 620.07 170.62 484.49 134.36 568.92 129.83
POWER & FUEL 16.41 4.31 12.82 4.34 23.97 2.37
TRAVELLING AND CONVEYANCE 5.30 1.17 1.32 2.91 18.79 2.55
Total 641.79 176.11 498.63 141.61 611.67 134.75
Less: Salaries and wages Adjusted - - - - - -
Total R&D Revenue Expenditure 641.79 176.11 498.63 141.61 611.67 134.75
As at As at
Leases 31st March 2022 31st March 2021
a) Not later than one year 12.06 12.06
b) later than one year but not later than five years 48.24 48.24
c) later than five years 958.77 970.83
d) The company has used deemed cost exemption under Ind AS 101 as on the date of transition to Ind AS.
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Note-4 Capital Work-in-Progress
Particulars Amount
Balance as at 31st March,2020 5,280.33
Notes:
1) Ageing of Capital work in Progress is as below:
As on 31st March 2022
Less then More then 3
Particulars 1-2 Years 2-3 Years Total
1year Years
Capital work in Progress 2,288.88 7,405.49 - - 9,694.38
As on 31st March 2021

Less then More then 3
Particulars 1-2 Years 2-3 Years Total
1year Years
Capital work in Progress 10,933.90 - - - 10,933.90
There is no project lying in Capital work in progress which have been exceeded from its timeline of completion.
Note-5 Other Intangible Assets

Particulars As at
31st March 2022
Particulars Intangible Assets
Gross Carrying Value

Balance as at 31st March,2020 527.58
Additions 58.47
Disposals (8.46)
Additions (2.85)
Disposals -
Accumulated Depreciation
Additions 50.01
Disposals -
Additions 42.43
Disposals -
Net carrying amount

Note 6. Non-current investments
Particulars As at As at
OTHERS
Investment in Equity Shares 11.25 11.25

(Unquoted and valued at cost)
112,500 (Previous year 1,12,500) Equity Shares of
Rs. 10/- each of Nimbua Greenfield (Punjab) Limited.
81,534(Previous year 81,534) equity shares of 8.15 8.15

Rs. 10/- Each of Echanda Urja Pvt. Limited.
Grand Total 19.40 19.40
Aggregate amount of quoted investments - -

Aggregate amount of Un-quoted investments 19.40 19.40
88
Note 7. Loans
(Unsecured, considered good unless otherwise stated)
Advance recoverable in cash or kind 2,258.51 1,174.13
Less :- Provisions for Doubtful Advances( Other loan & advances) 35.00 35.00
2,223.51 1,139.14
1) The Company has entered into an agreement for purchase of land admeasuring 304 kanals approx at village Bir Farozari, Distt.
Panchkula, at cost of Rs. 133.00 Lacs for setting up an auto component unit. The Land has not yet been registered in the name of
Company. Pending the same, the advance of Rs. 35.00 Lacs paid by the Company has been shown as advances recoverable and being
under legal suit, a provision for the same has been made.
2) There are no outstanding loans/advances in nature of loan to promoters,key management personnel, Director Related party or other
officers of the Company.
Note:- 8. Other financial assets (non-current)

Security deposits 775.34 890.70
Income tax Refundable of earlier years 15.86 15.86
791.20 906.56
Note:- 9. Other non-current assets

Captial advances 880.65 3,539.60
Prepaid expenses 131.41 133.00
1,012.06 3,672.60
Note:-10 Inventories
(Valued at cost, unless otherwise stated)
a) Raw material
- Raw Material & Components in hand 25,922.30 22,103.97
- Raw Material & Components (in transit) 13,935.78 5,391.07
b) Work in Progress 5,439.90 4,095.86
c) Finished Goods 6,888.72 5,223.82
d) Stores & Spares 11,837.94 12,600.79
e) Scrap 674.06 232.37
64,698.69 49,647.90
Note:- 11 Trade receivables
Unsecured, considered good 39,233.65 25,708.07
Unsecured, considered doubtful 35.01 55.66
39,268.66 25,763.73
Less :- Provisions for Doubtful Debtors 35.01 55.66
39,233.65 25,708.06
Detail of Debtors ageing as below:
As at 31st March 2022
Trade recievable Unbilled Not Due Less then 6 6 months 1-2 Year 2-3 year Total
months -1year
a) Undisputed Considered good - 28,284.85 10,337.96 509.40 65.27 36.17 39,233.65
b) Undisputed Considered Doubtfull - - - - - 35.01 35.01
c) Disputed Considered good - - - - - - -
d)Disputed Considered Doubtfull - - - - - - -
Total - 28,284.85 10,337.96 509.40 65.27 71.18 39,268.66
Trade recievable Unbilled Not Due Less then 6 6 months 1-2 Year 2-3 year Total
months -1year
a) Undisputed Considered good - 18,386.52 6,996.46 150.49 140.50 34.09 25,708.06
b) Undisputed Considered Doubtfull - - - - - 55.66 55.66
c) Disputed Considered good - - - - - - -
d)Disputed Considered Doubtfull - - - - - - -
Total - 18,386.52 6,996.46 150.49 140.50 89.75 25,763.72
89
Note:- 12 Cash and bank balances

Balances with banks
-Current account 22.34 271.15
Cheques in hand 2,295.00 2,517.44
Cash in hand 3.08 3.24
2,320.42 2,791.83
Note:- 13. Other Bank Balances

Current Account-Funds for CSR activities 0.47 0.47
Unpaid dividend accounts 43.45 38.44
Fixed deposits maturing within 12 months 3,426.63 2,488.86
3,470.55 2,527.75
Note:- 14. Loans
Advances Recoverable in Cash or in Kind (Short Term) 412.28 283.98
412.28 283.98
Note:- 15. Other financial assets
Interest Accrued But Not Received 0.05 54.18
0.05 54.18
Note:-16. Current/Non-current tax assets/ liabilities (net)
Advance Tax/ Tax Deducted at Source - 230.58
- 230.58
Note:-17. Other current assets
MAT Credit Entitlement 6,675.08 10,254.09
Balance with Statutory Authorities 440.20 44.52
GST/VAT Recoverable 3,097.66 3,470.60
Prepaid Expenses 108.12 71.42
10,321.06 13,840.63
Less :- Provisions for Doubtful Advances - -
10,321.06 13,840.63
Note:- 18(a) Equity Share Capital
Authorised capital No. of Amount No. of Amount
shares shares
Equity Shares of Rs.5/-each (Previous Year Rs. 10/- each) [Refer Note 18(e)] 3,80,00,000 19,00,00,000 1,90,00,000 19,00,00,000
Preference shares of Rs. 145/- each Optionally Convertible cummulative or 12,00,000 17,40,00,000 12,00,000 17,40,00,000
Non Cummulative
Issued, subscribed and Fully paid up. No. of Amount No. of Amount
shares shares
Equity Shares of ₹ 5/- each (Previous Year Rs. 10/- each) [Refer Note 18(e)] 31218940 1,560.95 15609470 1,560.95
a) R
econciliation of the number of shares and amount outstanding at No. of Amount No. of Amount
the beginning and at the end of the reporting year shares shares
Equity shares at the beginning of the year 1,56,09,470 1,560.95 1,55,89,720 1,558.97
Add: Issued during the year - - 19,750 1.97
Add: Adjustment for sub-division of equity shares [Refer Note 18(e)] 1,56,09,470 - - -
Equity shares at the end of the year 3,12,18,940 1,560.95 1,56,09,470 1,560.95
b) Rights,Preferences and restrictions attached to shares

The Company has issued only one class of shares i.e. equity shares of Rs. 5/- per share (previous year Rs. 10/- per share). All equity
shares rank pari passu and carry equal rights with respect to voting and dividend. The dividend proposed by the board of Directors is
subject to the approval of the shareholders in the ensuing Annual General Meeting, except in the case of interim dividend.
In the event of liquidation of the Company, the holders of equity shares will be entitled to receive remaining assets of the Company, after
distribution of all preferential amounts. The distribution will be in proportion to the number of equity shares held by the shareholders.
90
c) Details of shareholders holding more than 5% shares in the Company [Refer Note 18(e)]
As at As at
No. of % holding No. of % holding
shares shares
MR. DHEERAJ GARG 9280456 29.73 4640228 29.73
SAB INDUSTRIES LIMITED 2648374 8.48 1324187 8.48
SAB UDYOG LIMITED 2285164 7.32 1142582 7.32
TATA STEEL LIMITED 2173944 6.96 1086972 6.96
SUMITOMO METAL INDUSTRIES LIMITED 1700000 5.45 850000 5.45
d) Share Reserved for Issue under Options outstanding as at the end of the year (refer note no. 47)
(e) P
ursuant to the approval of the shareholders at the 35th Annual General Meeting of the Company held on September 30, 2021, each
equity share of face value of Rs. 10/- per share was sub-divided into 2( two) equity shares of face value of Rs. 5/- per share, with effect
from the record date i.e., November 22, 2021.
(f) Details of Promoter’s shareholding in the Company
S. No. Name of Promoter As at March 31, 2022 As at March 31, 2021 % change
No. of % of total No. of % of total during
shares (FV shares of the shares (FV shares of the the year*
@RS. 5/- Company @RS. 10/- Company
each) each)
Individuals
1 Dheeraj Garg 9280456 29.73 4640228 29.73 0.00
2 R K Garg 585142 1.87 292571 1.87 0.00
3 Priya Garg 158524 0.51 79262 0.51 0.00
4 Sunena Garg 1600536 5.13 800268 5.13 0.00
TOTAL (A) 11624658 37.24 5812329 37.24 0.00
Promoter Body Corporate
1 SAB INDUSTRIES LIMITED 2648374 8.48 1324187 8.48 0.00
2 SAB UDYOG LIMITED 2285164 7.32 1142582 7.32 0.00
3 CHANDIGARH DEVELOPERS PRIVATE LTD 1138264 3.65 569132 3.65 0.00
4 DHG MARKETING PRIVATE LTD 1002188 3.21 501094 3.21 0.00
5 MALWA CHEMTEX UDYOG LTD 770000 2.47 385000 2.47 0.00
6 STEEL STRIPS FINANCIERS PVT LTD 40000 0.13 20000 0.13 0.00
7 MUNAK INTERNATIONAL PVT LTD 4500 0.01 2250 0.01 0.00
8 S S CREDITS (P) LTD 3200 0.01 1600 0.01 0.00
9 S J MERCANTILE PVT. LIMITED 2400 0.01 1200 0.01 0.00
10 MALWA HOLDINGS (P) LTD 800 0.00 400 0.00 0.00
11 MUNAK INVESTMENTS (P) LTD 800 0.00 400 0.00 0.00
12 MUNAK FINANCIERS PVT LTD 800 0.00 400 0.00 0.00
13 STEEL STRIPS LTD** 600 0.00 300 0.00 0.00
14 STEEL STRIPS HOLDINGS (P) LTD 240 0.00 120 0.00 0.00
15 CHANDIGARH AIRCRAFT MANAGEMENT 72816 0.23 36408 0.23 0.00
SERVICES PRIVATE LIMITED
16 INDIAN ACRYLICS LIMITED 0 0.00 0 0.00 0.00
17 STEEL STRIPS INFRASTRUCTURE LIMITED 0 0.00 0 0.00 0.00
18 INDLON CHEMICALS LIMITED 0 0.00 0 0.00 0.00
19 SAB DEVELOPERS PRIVATE LIMITED 0 0.00 0 0.00 0.00
20 STEEL STRIPS MERCANTILE PRIVATE LIMITED 0 0.00 0 0.00 0.00
21 INDIAN ACRYLICS INVESTMENTS LIMITED 0 0.00 0 0.00 0.00
22 STEEL STRIPS INDUSTRIES LIMTED 0 0.00 0 0.00 0.00
23 HANS RAJ TRUST 0 0.00 0 0.00 0.00
24 R.K. GARG AND SONS HUF 0 0.00 0 0.00 0.00
TOTAL (B) 7970146 25.53 3985073 25.53 0
TOTAL SHAREHOLDING (A+B) 19594804 62.77 9797402 62.77 0
Note: *During the FY 2021-22, the company had sub-divided its each equity share of face value of Rs. 10/- per share into 2( two) equity shares of face
value of Rs. 5/- per share, with effect from the record date i.e., November 22, 2021. Hence, the change in shareholding of promoters and promoter
group in point 18(f) at the end of the financial year is solely on account of sub-division.
** Steel Strips Ltd.(SSL) has been amalgamated into SAB Industries Ltd. Therefore SSL does not exist as on date. However the name of SSL has
been shown above because as per Company’s member register SSL is holding 300 shares (after sub division 600 shares) whereas SSL has sold
these shares long back and the purchaser did not lodge the same in his own name.
91
Note:- 19 Other Equity
Reserves & Surplus
Share Forfeiture Reserve 2,237.85 2,237.85
Assistance under PATSER Scheme 50.00 50.00
Capital Subsidy 27.95 27.95
Capital Revaluation Reserve 5,280.64 5,280.64
7,596.44 7,596.44
Securities Premium Reserve
As per Last Balance sheet 13,530.33 13,347.64
Addition during the Year - 182.69
Deduction during the Year - -
Closing Balance 13,530.33 13,530.33
Share Options Outstanding Account

Employee Stock Options Outstanding
As per Last Balance sheet 729.31 729.84
Addition during the Year 277.00 -
Deduction during the Year - 0.53
Closing Balance 1,006.31 729.31
Deferred Employee Compensation Expenses

As per Last Balance sheet (529.52) (529.52)
Addition during the Year - -
Deduction during the Year - -
Closing Balance (529.52) (529.52)
General Reserves
Opening Balance as per last Balance Sheet 48,348.29 45,966.96
Add : Additions during the year 4,925.04 2,381.34
Balance as at the year end 53,273.33 48,348.30
Retained Earnings
Opening Balance as per last Balance Sheet 3,694.00 1,124.21
Profit for the year 20,546.42 4,925.04
Remeasurement gain/(loss) on defined benefit plan - -
Other Comprehensive Income (257.30) 9.80
Dividends (including tax thereon) 312.19 -
Qualified Asset as per IND AS 116 (0.00) 17.85
Transfer to General Reserves 4,925.04 2,381.34
Appropriations - (1.57)
Balance as at the year end 18,745.88 3,694.00
Total 93,622.77 73,368.86
92
Note:- 20 Non-current Borrowings
(Refer note No: 46)
Secured
Rupee Term loans from banks 17,701.29 25,339.77
Foreign Currency Term Loans 5,724.14 7,896.91
Vehicle Loan from banks - 13.37
Loans from NBFC 4,500.00 3,481.48
Unsecured
Loans from NBFC - 1,246.55
Buyer Credit for Capital Goods - Long Term - -
27,925.42 37,978.07
Note:-21 Other Financial Liabilities
Payables for Capital Goods - Long Term 7,505.16 8,014.74

7,505.16 8,014.74
Note:- 22 Provisions
Provision for Gratuity (refer note 43) 1,749.16 913.99
Provision for Leave Encashment 596.50 233.96
2,345.66 1,147.95
Note:-23 Deferred tax liabilities (net) (refer note 50)

Deferred tax liability arising on account of :
Depreciation and fixed assets 17,064.15 16,371.29
Deferred tax asset arising on account of :
Expenses debited in current year but allowed for tax purposes in following year - -
17,064.15 16,371.29
Note:-24 Current Borrowings
Secured
Loan repayable on demand
- Rupee demand Loans from Banks 20,382.85 23,544.99
- Loan against Fixed Deposits - 1,066.22
Foreign Currency Loan
- Buyers/Supliers Credit loan for Raw Material from Banks 19,967.85 11,923.62
Current maturities of long-term borrowings 9,513.72 16,854.28

Unsecured
From Banks
- Loan against Bills Receivables - 1,601.85
From Others
- NBFC - 754.92
49,864.42 55,745.86
Nature of Securities
Loan payable on Demand
I) 1st pari passu charge by way of hypothecation of entire current asset constituted of raw materials, stock in process, finished goods,
consumable stores, book debts, bills whether documentary or clean outstanding monies, receivables both present and future of the
company. The Company has filed quarterly returns or statements with the banks in lieu of the sanctioned working capital facilities, which are
in agreement with the books of accounts.
2nd pari-passu charge is on entire Fixed Assets of the company.
II) The Company do not have any charges or satisfaction of charges which is yet to be registered with ROC beyond the statutory period
Foreign Currency Loan
Buyer credit loans are secured by way of lien on non-funds based working capital limits and counter indemnity of the Company.
All secured loans are further secured by personal guarantee of Chairman and Managing Director of the Company.
93
Note:- 25 Trade payables

Micro, Small and Medium Enterprises 2,093.31 1,128.59
Others 63,819.18 40,095.08
65,912.49 41,223.68
I) Debit and credit balances in the accounts of suppliers and others are subject to confirmation and reconciliation.
II) Detail of amounts outstanding to Micro & Small Enterprises as defined under Micro, Small & Medium Enterprises Development Act
2006, based on available information with the Company is as under :
Principal amount due and remaining unpaid 175.18 1,128.59

Interest due on above and the unpaid interest - -
Interest Paid - -
Payment made beyond the appointed day during the year - -
Interest due and payable for the period of delay - -
Interest accrued and remaining unpaid - -
Amount of further interest remaing due and payable in succeding years - -
175.18 1,128.59
III) Ageing Schedule of Trade Payable is as below:

Particulars Not Due Less then 1 year 1-2 year 2-3 years More then 3 years Total
Undisputed MSME 1,919.37 173.93 - - - 2,093.31
Undisputed others 57,504.42 6,314.75 - - - 63,819.17
Disputed MSME - - - - - -
Disputed Others - - - - - -
Particulars Not Due Less then 1 year 1-2 year 2-3 years More then 3 years Total
Undisputed MSME 12.51 1,116.09 - - - 1,128.59
Undisputed others 24,563.55 15,531.53 - - - 40,095.08
Disputed MSME - - - - - -
Disputed Others - - - - - -
Note:- 26 Other financial liabilities

- -
Note:-27. Current/Non-current tax assets/ liabilities (net)
Advance income tax (net of prov.) 182.11 -

182.11 -
Note:- 28 Provisions
Provision for Employee benefits

i) Provision for Gratuity (refer note 43) 347.78 493.89
ii) Provision for Leave Encashment 108.66 166.23
456.44 660.12
Note:- 29 Other Current liabilities
Advances from customers 33.40 38.68

Due to directors 972.19 -
Government dues 699.24 176.12
Other Payable incl. (Employee related payables) 1,971.18 1,343.96
Unclaimed dividend 43.45 44.45
3,719.46 1,603.21
94
Note:- 30 Revenue from operations
Operating revenues
Sale of products
Export 82,947.44 27,008.94
Domestic 2,71,156.23 1,46,985.67
3,54,103.68 1,73,994.61
Other Operating revenue
Duty Draw back Income 1,693.57 770.30
Job Work Income 198.09 176.62
1,891.66 946.92
3,55,995.34 1,74,941.53
Note:- 31 Other Income

Interest income 1,079.41 1,105.46
Profit on disposal of fixed assets 60.58 72.51
Balances Written Back/ Off (Net) - -
Miscellaneous income 162.67 453.84
1,302.66 1,631.81
Note:- 32 Cost of materials consumed
Imported 48,980.00 17,442.73

Indigenous 1,73,184.98 90,794.26
2,22,164.98 1,08,236.99
Note:- 33 Change in inventories of finished goods, stock in trade and work -in-progress
Opening stock
Finished Goods 5,223.82 5,962.83
Scrap 232.37 203.65
Work-in-Progress 4,095.86 5,056.45
Less: Closing Stock
Finished Goods 6,888.72 5,223.82
Scrap 674.06 232.37
Work-in-Progress 5,439.90 4,095.86
(3,450.63) 1,670.88
Note:- 34. Employee benefit expense
Salaries, Wages, Bonus & Incentives etc.(Net) 19,930.08 13,968.05

Contribution to Provident and Other Funds 796.33 579.45
Workmen and Staff Welfare Expenses 512.73 465.52
Gratuity 351.38 142.70
Employee stock option scheme Share Expenses (refer note 47) 277.00 138.75
21,867.52 15,294.47
Note:- 35 Finance costs
a) Interest Expenses
i) Paid to Banks
- on Term Loan 3,811.94 3,560.34
- on Working Capital Loan 1,436.55 3,225.82
- on Foreign Currency Loan 247.71 363.14
- on Car Loan 1.90 3.93
ii) Interest Others 2,384.65 794.29
b) Other borrowing Charges 659.34 445.62
8,542.09 8,393.14
95
Note. 36 Depreciation and amortisation
Depreciation on
Property, plant and equipment 7,633.50 7,177.64
Intangible assets 53.49 53.49
7,686.99 7,231.13
Note:- 37 Other Expenses Year ended 31st Year Ended 31st

March 2022 March 2021
Store Spares Consumed :

-Imported 2,882.00 1,381.29
-Indigenous 21,815.94 9,569.97
Other Misc. Manufacturing Exp 4,740.41 1,592.85
Power, Electricity & Water Charges (Net)
-Manufacturing 8,200.36 5,307.93
-Others 18.89 11.37
Repair and Maintenance
-Plant & Machinery 930.42 447.11
-Repairs & Renewals 187.45 60.14
-Vehicle Running, Repair & Maintenance 60.79 36.80
Rent 650.93 481.48
Rates and Taxes 533.01 636.19
Insurance 503.04 396.49
Auditors’ Remuneration 11.00 11.00
Advertisement, Publicity and Sales Promotion 0.38 0.01
Travel & Conveyance
-Directors 38.09 17.43
-Others 716.85 513.70
Legal & Professional Charges 1,002.42 465.47
Bad debts Written Off 1.12 -
Balances Written Back/ Off (Net) 0.44 18.35
Director’s Sitting Fees 8.80 8.50
Managerial Remuneration incl. commission 914.88 534.68
Telephone & Communication Expenses 34.31 27.73
Business Promotion 46.96 34.82
Forwarding Expenses 24,481.47 6,682.12
Other Selling and Distribution Expenses 0.11 6.79
Rebates and Discounts - -
Loss/(Gain) on Foreign Exchange Fluctuation 20.28 8.30
Miscellaneous Expenses * 1,516.95 472.84
Total 69,317.30 28,723.50
* Miscellaneous Expenses includes expenses under the Corporate Social responsibilities 142.11 88.47
under Section 135 of Companies Act 2013(Refer Note no 45)
Miscellaneous Expenses also include political donations pursuant to section 182 of the Companies Act,2013
a) Shiromani Akali Dal (SAD) 10.00 -
Research and Development Expenses Year ended 31st Year Ended 31st
Salaries , Wages and other allowances 790.70 618.85

Power & Fuel 20.72 17.16
Travelling and Conveyance 6.47 4.23
817.89 640.24
Grand Total 70,135.19 29,363.74
96
Note:- 38 Exceptional items
Prior Period Expense (refer note 42) - 0.09
- 0.09
Payment to Auditors
As Auditor:
Audit fee 7.00 7.00
Tax audit fee 2.00 2.00
Certificate Charges 2.00 2.00
11.00 11.00
Note: 39 Earnings per share (EPS)

Earnings per share (EPS)
Basic
Net Profit as per profit and loss account 20,546.41 4,925.03
Weighted average number of equity shares outstanding during the year 3,12,18,940 31,218,940
Earning per Share- Basic 65.81 15.78
Diluted
Net Profit as per profit and loss account 20,546.41 4,925.03
Weighted average number of equity shares outstanding during the year 3,12,95,600 31,295,624
Earning per Share- Diluted 65.65 15.74
Nominal Value of Equity Share 5.00 5.00
Note: The basic and diluted earnings per share and number of shares used for computation of the EPS have been adjusted retroactively
to give effect to the sub division of shares from Rs 10/- face value to Rs 5/- face value.
Note:- 40 Contingent Liabilities (To the Extent not provided for)

A) CONTINGENT LIABILITES
Letter of Credit /Bank of Guarantee Outstanding for Import /Purchase of Raw materials, Spares 3,794.18 923.79
and Plant and Machinery
B) COMMITMENTS
Estimated amount of Contracts remaining to be executed on account of capital account and not 3,074.45 6,321.15
provided for (net of advances)
Note:- 41 Related party disclosure

1) Related Party Disclosure
a) Key Managerial Personnel Sh. Dheeraj Garg, (Managing Director)
Sh. A.V Unnikrishnan (Deputy Managing Director)
Sh. M.L. Jain (Executive Director)
Sh. Naveen Sorot (Chief Financial Officer)
Sh. Shaman Jindal ( Company Secretary)
b) Relatives of the KMP Sh. R.K Garg, (Chairman)
Smt. Sunena Garg
Ms. Priya Garg
c) Enterprises over which key management SAB Industries Limited, SAB Udyog Limited, Malwa Chemtex Udyog Ltd., Steel
personnel (KMP) are able to exercise significant Strips Financiers Pvt. Ltd., Munak International Pvt. Ltd., S.S. Credits Pvt. Ltd., S.J.
control Mercantile Pvt. Ltd (Earlier known as S.A. Holding Pvt. Ltd.), Malwa Holdings Pvt. Ltd.,
Munak Investment Pvt. Ltd., Steel Strips Holding Pvt. Ltd., Chandigarh Developers
Pvt. Limited, DHG Marketing Pvt. Ltd., Munak financiers P Ltd., Steel Strips Ltd. &
Steel Strips Infrastructre Limited, Hans Raj Trust,Chandigarh Aircraft Management
services Pvt Limited
97
Related Party Transactions Key management Relatives of Enterprises over Total for Total for
Personnel (KMP) KMP which KMP are able current Year Previous
to exercise significant 2021-22 Year 2020-21
influences
EXPENDITURE
Donation Paid - - 90.00 90.00 52.00
Rent Paid - - 40.69 40.69 31.99
Sitting Fee - 1.20 - 1.20 1.60
Remuneration incl. commission 1,704.97 - - 1,704.97 588.11
Dividend Paid 93.34 23.45 79.70 196.49 -
1,798.31 24.65 210.39 2,033.35 673.70
B. OUTSTANDING BALANCES Key management Relatives of Enterprises over Total Total

Personnel (KMP) KMP which KMP are able Outstanding Outstanding
to exercise significant as at 31st as at 31st
influences March 2022 March 2021
Rent - - 6.89 6.89 -
Sitting Fee - - - - -
Remuneration incl. commission 980.00 - - 980.00 -
Dividend - - - - -
980.00 - 6.89 986.89 -
Note:- 42. Prior period comprises of the following

Expenses
Sales tax demand - -
Freight and Others - 0.09
Total - 0.09
Note:- 43. Post Retirement Benefits Plans (Ind AS 19)

Defined Benefit Plan
The Company provides for gratuity for employees as per the Payment of Gratuity Act, 1972. Employees who are in continuous service for a
period of 5 years are eligible for gratuity. The amount of gratuity payable on retirement/termination is the employees last drawn basic salary
per month computed proportionately for 15 days salary multiplied for the number of years of service. For the funded plan the Company
makes contributions to recognised funds in India. The Companny does not fully fund the liability and maintains a target level of funding to
be maintained over a period of time based on estimations of expected gratuity payments.
(i) Changes in Defined Benefit Obligation
Present value obligation as at the start of the year 1,409.86 1,345.17
Interest cost 100.81 84.07
Current service cost 189.52 176.90
Actuarial loss/(Gains) - Experience Changes 456.87 (103.21)
Actuarial loss / (Gains)- on obligations
Benefits directly paid by employer (42.40) (44.75)
Benefits directly paid by trust (17.71) (48.32)
Present value obligation as at the end of the year 2,096.94 1,409.86
(ii) Change in fair value of plan assets

Fair value of plan assets as at the start of the year 1,022.45 858.65
Interst income on plan assets 73.10 53.67
Employer Contributions
Return on plan assets greater/(lesser) then discount Rates 8.34 3.46
Benefits paid 832.29 106.67
Fair value of plan assets as at the end of the year 1,936.18 1,022.45
98
(iii) Breakup of Actuarial gain/loss:

Actuarial (gain)/loss on arising from change in financial assumption - -
Actuarial (gain)/loss on arising from experience adjustment 456.87 (103.21)
Return on plan assets (greater)/less than discount rate (8.34) (3.46)
448.53 (106.67)
(iv) Net Asset / (Liability) recognised in the Balance Sheet
Present value obligation as at the end of the year (2,096.94) (1,409.86)

Fair value of plan assets as at the end of the year 1,936.18 1,022.45
Net Asset / (Liability) in the Balance Sheet (160.76) (387.41)
(v) Amount recognized in the statement of profit and loss
Current service cost 189.52 176.90

Interest cost 100.81 84.07
Interst income on plan assets assets (73.10) (53.67)
(Income)/Expense recognised in the statement of profit and loss 217.22 207.31
(vi) Remeasurements recognised in the statement of Other Comprehensive Income (OCI)
Changes in Financial Assumptions - -

Experience Adjustments 456.87 (103.21)
Return on plan assets (greater)/less than discount rate (8.34) (3.46)
Amount recognised in Other Comprehensive Income (448.53) 106.67
(vii) Actuarial assumptions
Discount Rate (p.a) 7.15% 6.25%

Salary Escalation Rate (p.a) 6.00% 5.00%
Attrition (At all ages) 10.00% 10.00%
Mortality Rate Indian Assured Indian Assured
Lives Mortality Lives Mortality
(2012-14) (2012-14)
(viii) Sensitivity analysis for gratuity liability

The sensitivity of the overall plan obligations to changes in the weighted key assumptions are:
Present value of obligation at the end of the year
Impact of the change in Discount rate (p.a)

Impact due to decrease of 1% 128.32 89.96
Impact due to increase of 1% (114.37) (79.82)
Impact of change in Salary Esclation rate (p.a)

Impact due to increase of 1% (99.10) 90.16
Impact due to decrease of 1% 109.36 (81.44)
Weighted average duration of defined plan obligation at the end of reporting period 5.79 Years 6.02 Years
99
Note:- 44. Segment Reporting

A) PRIMARY SEGMENT (BUSINESS SEGMENT)
A business segment is a distinguishable component of an enterprise that is engaged in providing an individual product or service or a
group of related products or services and that is subject to risks and returns that are different from those of other business segments.
The Company’s Operation predomintly comprise of only one segment i.e Automtive Wheels.In view of the same, separate segmental
information is not required to be given as per the requirements of IND AS 108 “Operating Segments”
B) SECONDARY SEGMENT (GEOGRAPHICAL SEGMENT)
The analysis of geographical segment is based on the geographical location of the customers. The Company operates primarily in India and
has presence in international markets as well. Its business is accordingly aligned geographically, catering to two markets. The Company
has considered domestic and exports markets as geographical segments and accordingly disclosed these as separate segments.
PARTICULARS As at As at
GROSS SALE REVENURE BY GEOGRAPHICAL SEGMENT

WITHIN INDIA 3,49,285.48 2,06,454.15
OUTSIDE INDIA 82,947.44 27,008.94
TOTAL 4,32,232.93 2,33,463.10
The Company has common fixed assets, other assets and liabilities for domestic as well as overseas market. Hence, separate figures for
assets and liabilities have not been furnished.
Note: 45. CORPORATE SOCIAL RESPONSIBILITY EXPENSES

As per the Companies Act, 2013, amount required to be spent by the Company on Corporate Social Responsibility (CSR) activities during
the year was Rs. 135.92 lakhs (FY 2020-21: Rs. 158.51 lakhs).
During the year ended 31.03.2022, in respect of CSR activities revenue expenditure incurred by the Company amounted to Rs.142.11
lakhs as against CSR liability of Rs. 135.92 lakhs. The amount spent relates to purpose other than construction or acquisition of any asset.
An amount of Rs. 6.19 lakhs spent by the Company in excess of the Company’s CSR obligation for the FY 2021-22, shall be available for
set off against the Company’s CSR obligation in accordance with the provisions of the Act.
During the year ended 31.03.2021, as per the provisions of the Act, the Company was required to spend an amount of Rs. 158.51 lakhs
towards its CSR obligation for the FY 2020-21 and an additional amount of Rs. 66.29 lakhs which remained unspent at the end of FY
2019-20 relating to the Company’s ongoing multi-year CSR projects. The company had spent an aggregate amount of Rs. 88.47 lakhs
(out of which Rs. 49.02 lakhs pertain to FY 2020-21 and Rs. 39.45 lakhs pertain to FY 2019-20) towards the CSR activities/ projects in the
financial year 2020-21 and the balance amount of Rs. 136.33 lakhs (out of which Rs. 109.49 lakhs pertain to FY 2020-21 and Rs. 26.84
lakhs pertain to FY 2019-20) remained unspent as on 31.03.2021. The said unspent amount was related to the ongoing multi-year projects
of the Company, the implementation of which was under process. Consequently, the said amount was deposited to the unspent CSR
account in April, 2021 as per the provisions of the Act. Out of the said amount of Rs. 136.33 lakhs, the Company had spent an amount of
Rs. 112.43 lakhs during the FY 2021-22. The remaining unspent amount relates to the ongoing projects of FY 2020-21 and shall be spent
within the time limit as prescribed under the Act.
During the year ended 31.03.2022, the Company had contributed an amount of Rs. 90.00 lakhs (FY 2020-21: Rs. 52.00 lakhs) to Hans Raj
Trust (a related party) for undertaking various CSR activities. However, during the year ended 31.03.2022, the trust had actually spent an
amount of Rs. 66.96 lakhs (FY 2020-21: Rs. 38.21 lakhs) for undertaking various CSR activities.
Nature of CSR activities undertaken by the Company:
The CSR initiatives of the Company aim towards inclusive development of the communities largely around the vicinity of its plants and
registered office and at the same time ensure environmental protection through a range of structured interventions in the areas of Promotion
of education, sanitation and cleanliness, healthcare including preventive health care, rural development & slum development, ensuring
environment sustainability, contribution to society for rehabilitation of mentally challenged students, reduction of inequalities faced by
socially and economically backward groups and eradication of hunger and poverty.
100
Note: 46. Securities and Terms of repayments for Secured Long term borrowings
1) Nature of Securities
a) Rupee Term Loans/ Foreign currency term loan/ NBFC
Term Loans from banks, financial institutions and others are secured / to be secured by equitable mortgage created/ to be created by
deposit of title deeds of the Company’s immovable properties for Dappar( In Punjab),Oragadam( In Chennai) & Seraikella(In Jharkhand)
in addition to the deed of hypothecation charging Company’s moveable properties, both present and future and second charge created /
to be created on raw materials, semi-finished goods, consumable stores, finished goods and book debts etc on paripassu basis. However
in regard to loan taken from HDFC Bank and EXIM Bank for Mehsana (Gujrat) project, the said loan will be secured (first charge) through
equitable mortgage by deposit of title deeds of the Company’s immovable properties situated at Mehsana (in Gujrat) and Second pari
passu charge on all other immovable properties , movable properties and current assets situated at Dappar( In Punjab),Oragadam( In
Chennai) unit, & Seraikella(In Jharkhand).
All secured loans are further secured by personal guarantee of Chairman & Director and/ or Managing Director of the Company.
B) Vehicle Loans are secured against the Hypothecation of Vehicle to Lender
2) Terms of Repayments
Maturity Profile of Secured Term Loans are as below :
Particulars 1st year 2nd year 3rd year 4th year 5th year
Term Loans - Current Year 9,500.40 9,011.64 9,509.13 5,561.20 3,100.18
Term Loans - Previous Year 16,854.28 13,492.45 8,927.98 8,826.99 4,991.48
3) Detail of Intrest Capitalized during the year As at As at

Intrest Capitalized during the year 29.94 325.94

Note 47. Employee stock option plan
Share Reserved for Issue under Options outstanding as at the end of the year on unissued share capital
As on 1st April, 2021, the company had an ongoing employee Stock Options scheme i.e Steel Strips Wheels Limited- Employee Stock
Option Scheme, 2016 (ESOS 2016) and a new scheme titled Steel Strips Wheels Limted- Employee Stock Option Scheme, 2021 (ESOS
2021) was approved by the shareholders of the Company in their 35th Annual General Meeting held on 30.09.2021.
1. Steel Strips Wheels Limited- Employee Stock Option Scheme, 2016 (ESOS 2016)
The Company has established an Employee Stock Option Scheme (ESOS) as “Steel Strips Wheels Limited Employee Stock Option Scheme
2016” (“ESOS 2016”) in accordance with the Securities and Exchange Board of India (Share Based Employee Benefits) Regulations, 2014
which was approved by the Board of Directors and subsequently by shareholders of the Company in their Annual General meeting held on
30.09.2016, authorizing the company to create, offer, issue and grant, in one or more tranches, up to 1,00,000 options to the employees
of the company. Pursuant to the terms of the said Scheme, the Company had granted 87350 options (26500 options were granted on
16.05.2017, 23300 options were granted on 08.01.2019 and 37550 options were granted on 15.03.2021) to employees of the Company.
Each option would entitle the holder thereof to subscribe one equity share of Rs. 10/- each at an exercise price of Rs. 200/- per share of
the company. As per the terms of the Scheme, all the options granted on any date shall vest not earlier than 1 (one) year and not later than
a maximum of 4 (four) years from the respective date of grant of options as may be determined by Employee Compensation Committee
(ECC). As decided by the ECC, the vesting period for the said 87350 options granted is one year from the respective date of grant. Exercise
period would commence from the date of vesting and will expire on completion of 5 years from the respective date of grant of options. During
the financial year, 2018-19, 24000 options and during the financial year 2020-21, 19750 options were exercised by the option holders and
consequently, equivalent number of shares have been allotted. Further, pursuant to the approval of the shareholders at the 35th Annual
General Meeting of the Company held on September 30, 2021, each equity share of face value of Rs. 10/- per share was sub-divided into
2( two) equity shares of face value of Rs. 5/- per share, with effect from the record date i.e., November 22, 2021. Accordingly, the number of
all outstanding stock options (vested but not exercised and unvested stock options), the number of stock options available for future grant(s)
with effect from the record date i.e. 22.11.2021 and the exercise price thereof was proportionately adjusted.
2. Steel Strips Wheels Limited- Employee Stock Option Scheme, 2021 (ESOS 2021)
During the year 2021-22, the Company had also introduced a fresh Employee Stock Option Scheme (ESOS) titled as “Steel Strips Wheels
Limited - Employee Stock Option Scheme, 2021” (“ESOS 2021”) in accordance with the Securities and Exchange Board of India (Share
Based Employee Benefits and Sweat Equity) Regulations, 2021 which was approved by the Board of Directors and subsequently by
shareholders of the Company in their Annual General Meeting held on 30.09.2021, authorizing the company to create, offer, issue and
grant, in one or more tranches, up to 10,00,000 options (adjusted figure post sub-division) to the employees of the company. No options
were granted under ESOS 2021 until 31.03.2022. As per the terms of the Scheme, all the options granted on any date shall vest not earlier
than 1 (one) year and not later than a maximum of 4 (four) years from the respective date of grant of options as may be determined by
Employee Compensation Committee (ECC) and each option would entitle the holder thereof to subscribe one equity share of Rs. 5/- each
at an exercise price as may be determined by the Employee Compensation Committee/ Board of Directors of the Company.

101
The Number and Weighted average exercise price of Stock Option are as follows:
Particulars ESOS 2016
Year ended 31st March 2022 Year ended 31st March 2021
Options Weighted average Options Weighted average
Exercise Price Exercise Price
Number Amount Number Amount
Outstanding at the Beginning of the year 43600 200 25800 200
Granted Options NIL NIL 37550 200
Forfeited during the year NIL NIL NIL NIl
Exercised during the year NIL NIL 19750 200
Expired during the year NIL NIL NIL NIL
Adjustment for sub-division of equity shares 43600 NIL NA NA
Outstanding at the end of year 87200 100* 43600 200
Exercisable at the end of the year 87200 100* 43600 200
Number of Equity shares of Rs 5 each fully paidup to be 87200 100* 43600 200
issued on exercise of option (Previous Year Rs. 10/- each)
Weighted Average share price in respect of options NA 505.55
excercised during the year
Weighted average remaining contractual life (in years) 5 years from 5 years from the 5 years from 5 years from the
the respective respective date of the respective respective date of
date of grant of grant of options date of grant grant of options.
options of options
*Weighted average exercise price has been adjusted for sub-division of equity shares.
Under ESOS 2021, the Company has not granted any options during the financial year 2021-22.
3. Impact of fair Valuation method on Net Profit under EPS
In March 2005, the Institutes of Chartered Accountants of India had issued a guidance note on “Accounting for Employees Share based
payments” applicable to Employee based share plan, the grant date in respect of which falls on or after April 1, 2005. The said guidance
notes requires the Pro-forma Disclosures of the impact of fair value method of accounting of Employee stock Compensation accounting in
the financial statements. Applying the fair value based method defined in the said guidance note the impact on the reported net profit and
earning per share would be as follows:
ESOS 2016 Method of valuation -Fair value method
The Company has calculated the employee compensation cost using the fair value method of accounting to account for the options granted
under “ESOS 2016”, therefore there will not be any impact on profits and EPS of the company.
4. Weighted Average fair value of options granted under ESOS 2016 during the year : NA (No additional options were granted during the year )
5. The fair Value of the Options, is estimated on the date of grant using the black- scholes model with the following significant assumptions.
Particulars ESOS 2016 ESOS 2016 ESOS 2016

( 2021-22) ( 2020-21) ( 2019-20)
Weighted average Risk free interest rates ( in %) 6.07%
Weighted average Expected life 5 years
No Options
Weighted average Volatility (in %) No Options were 35.88% were granted
granted during
Weighted average Dividend Yield (%) 0.28% during the
the financial
Weighted average Exercise price year 2021-22 Rs. 200.00 financial year
2019-20
The Price of the underline share in market at the time of Option grant Rs. 737.15
Weighted average Fair Value of the Options Rs. 581.57
Under ESOS 2021, the Company has not granted any options during the financial year 2021-22.
The volatility of the options is based on the historical volatility of the share price applicable to the total expected life of each option.
6. No Shares out of the issued , subscribed and paid up Share Capital were alloted as Bonus Shares in the last five years by capitalization
of Securities Premium Reserves.
7. No Shares out of the issued , subscribed and paid up Share Capital were alloted in the last five years pursuant to the various scheme
of amalgamation without payment being received in cash.
102
Note:- 48. Financial risk management objectives and policies

The Company’s principal financial liabilities comprise loans and borrowings, trade and other payables. The main purpose of these financial
liabilities is to finance the Company’s operations and to support its operations. The Company’s financial assets include loans, trade and
other receivables, and cash & cash equivalents that derive directly from its operations.
The Company is exposed to market risk, credit risk and liquidity risk. The company’s senior management oversees the management
of these risks. The company’s senior management is supported by a Business Risk Management committee that advises on financial
risks and the appropriate financial risk governance framework for the Company. This Business Risk Management committee provides
assurance to the Company’s senior management that the Company’s financial risk activities are governed by appropriate policies and
procedure and that financial risks are identified, measured and managed in accordance with the Company’s policies and risk objectives.
The Board of Directors reviews and agrees policies for managing each risk, which are summarised as below:
Market risk
a) Price Risk
Fluctuation in commodity price in global market affects directly and indirectly the price of raw material and components used by the Company
in its products. The key raw material for the Company’s business is HR Steel and Aluminium ingot. The Company has arrangements with
its major customers for passing on the price impact. The Company is also regularly taking initiatives like VA VE (value addition, value
engineering) to reduce its raw material costs to meet targets set up by its customers for cost downs.
b) Interest rate risk
Interest rate risk is the risk that the fair value or future cash flows of a financial instrument will fluctuate because of changes in market
interest rates. The Company’s exposure to the risk of changes in market interest rates relates primarily to the Company’s long term debt
obligations with floating interest rates. The Company is carrying its borrowings primarily at variable rate.
31 March 2022 31 March 2021
Variable rate borrowings 27,925.42 37,978.07
Fixed rate borrowings - -
Total Borrowings 27,925.42 37978.07
Interest rate sensitivity

For the Purpose of computing interest rate senstivity on the above borrwings, managemnet has estimated a reasonably possible change
in interest rate as 50bps based on current as well as expected economic conditions. This analysis is based on Long Term Risk exposures
outstanding at the reporting date and assumes that all other variables, in particular foreign currency exchange rates, remains constant. The
period and balances are not necessarily representative of the average amounts outstanding during the periods.
Impact on Profits
As at As at
31 March 2022 31 March 2021
50 bp decrease would Increase the profit before tax by 140 190
50 bp increase would decrease the profit before tax by (140) (190)
c) Foreign currency risks

The company tries to manage the foreign currency risk by attaining natural hedge. The copmany also does selective hedging to hedge its
risk associated with foreign currency and to address the timing difference in foreign currency collections & payments.
103
i) The derivative outstanding as at the reporting date is as follows:-
Category Wise Quantitative Data As at 31 March 2022
Amount in Foreign
Currency
(In Lacs)
Forward Contracts, Options
Forward Contract Against USD/INR (USD Sell) 234.80
Forward Contract Against EUR/USD (Euro Sell) 34.72
Forward Contract Against USD/NOK (USD Sell) 5.00
Forward Contract Against USD/CAD(USD Sell) 70.00
Forward Contract Against USD/JPY(USD Sell) 40.00
Forward Contract Against AUD/USD (USD Sell) 104.35
Forward Contract Against NZD/USD (USD Sell) 27.81
Forward Contract Against EUR/USD (Euro Buy) 170.00
Forward Contract Against USD/INR (USD Buy) -
Forward Contract Against GBP/USD (GBP Buy) 90.00
Forward Contract Against USD/CAD(USD Buy)) 30.00
Put & Call Options Against Export(AUD/USD) 55.00
Put & Call Options Against Export(EURO/USD) 80.00
Put & Call Options Against Export(USD/CAD) 140.00
Foreign Currency option contracts mature within 12 months
ii) Mark to market losses / (gain) on Forwards/Options

(Rs in Lacs)
As at 31 March 2022
Mark to Market losses/(gain) (826.07)
d) Credit risk
The credit risk is the risk of financial loss to the Company if a customer or counterparty to a financial instrument fails to meet its
contractual obligations towards the Company and arises principally from the Company’s receivables from customers and deposits with
banking institutions. The maximum amount of the credit exposure is equal to the carrying amounts of these receivables.
The Company has developed guidelines for the management of credit risk from trade receivables. The Company’s primary customers
are major Indian automobile manufacturers (OEMs) with good credit ratings. Non-OEM clientsare subjected to credit assessments as
a precautionary measure, and the adherence of all clients to paymentdue dates is monitored on an on-going basis, thereby practically
eliminating the risk of default. The Company has deposited liquid funds at various banking institutions. Primary banking institutions are
major Indian and foreign banks. In long term credit ratings these banking institutions are considered to be investment grade. Also, no
impairment loss has been recorded in respect of fixed deposits that are with recognised commercial banks and are not past due
Liquidity risk
The liquidity risk encompasses any risk that the Company cannot fully meet its financial obligations. To manage the liquidity risk, cash flow
forecasting is performed in the operating divisions of the Company and aggregated by Company finance. The Company’s finance monitors
rolling forecasts of the Company’s liquidity requirements to ensure it has sufficient cash to meet operational needs while maintaining
sufficient headroom in its undrawn committed borrowing facilities / overdraft facilities at all times so that the Company does not breach
borrowing limits or covenants (where applicable) on any of its borrowing facilities.
Year Ended March 31, 2022 Upto 1 Year Above 1 Years Total
Non - derivatives
Borrowings 49,864.42 27,932.15 77,796.57
Trade Paybles 65,912.49 - 65,912.49
Other Financial Liabilities - 7,510.45 7,510.45
Total Non Derivative Liabilities 1,15,776.91 35,442.60 1,51,219.51
104
Year Ended March 31, 2021 Upto 1 Year Above 1 Years Total
Non - derivatives
Borrowings 55,745.88 38,000.05 93,745.93
Trade Paybles 41,223.68 - 41,223.68
Other Financial Liabilities - 8,010.45 8,010.45
Total Non Derivative Liabilities 96,969.56 46,010.50 1,42,980.06
Year Ended March 31, 2020
Non - derivatives
Borrowings 45,660.23 44,205.56 89,865.79
Trade Paybles 21,363.17 - 21,363.17
Other Financial Liabilities 10,273.02 8,049.98 18,323.00
Total Non Derivative Liabilities 77,296.42 52,255.54 1,29,551.96
Note:- 49 Capital Management

a) Risk Management
The Company’s objectives when managing capital is to safeguard their ability to continue as a going concern, so that they
can continue to provide returns for shareholders and benefits for other stakeholders, and maintain an optimal capital structure to
reduce the cost of capital.Consistent with peers in the industry, the Company monitors NET Debt to EBITDA ratio i.e. Net debt (total
borrowings net of cash and cash equivalents) divided by EBITDA (Pro it before tax plus depreciation and amortization expense
plus finance costs).
The Company’s strategy is to ensure that the Net Debt to EBITDA is managed at an optimal level considering the above factors. The
Net Debt to EBITDA ratios were as follows:
As at As at
31 March 2022 31 March 2021
Net Debt 71,998.88 88,404.35
EBITDA 46,580.94 22,007.17
Net Debt/EBITDA 1.55 4.02
b) Loan covenants
Under the terms of the major borrowing facilities, the Company is required to comply with certain financial covenants and the Company has
complied with those covenants throughout the reporting period.
Note:- 50. Deferred tax balances (Net)
Deferred tax balances (Net) As at As at AS at
31 March 2022 31 March 2021 31 March 2020
(a) Deferred tax assets 785.52 766.07 4,182.38
(b) Deferred tax liabilities 17,849.74 17,137.36 19,535.03
(17,064.22) (16,371.29) (15,352.65)
The following is the analysis of deferred tax assets/(liabilities)
Recognised in profit and loss account and other comprehensive income
Deferred tax assets/(liabilities) in relation to: As at Credit /(charge) Credit /(charge) to As at

31 March 2021 to Profit or Loss Other Comprehensive 31 March 2022
Income
Property, plant and equipment (16,394.06) (450.18) - (16,844.25)
Intangible assets (25.65) (6.49) - (32.14)
Provision for Gratuity 49.77 (191.99) - (142.23)
Provision for Leave Encashment 32.68 (127.64) - (94.95)
Provision for Bonus (27.66) (74.59) - (102.25)
Provision for Doubtful Debt (0.00) 19.45 - 19.45
Security Deposit 5.20 - - 5.20
Payables for Capital Goods - Long Term (854.85) - - (854.85)
Recognized through OCI 9.41 - 138.51 147.92
Profit & Loss Ind AS Adj. 833.87 - - 833.87
(16,371.29) (831.44) 138.51 (17,064.22)
105
Deferred tax assets/(liabilities) in relation to: As at Credit /(charge) Credit /(charge) to As at

31 March 2020 to Profit or Loss Other Comprehensive 31 March 2021
Income
Property, plant and equipment (15,278.22) (1,115.84) - (16,394.06)
Intangible assets (25.65) - - (25.65)
Provision for Gratuity 48.80 0.97 - 49.77
Provision for Leave Encashment (21.07) 53.75 - 32.68
Provision for Bonus (84.42) 56.76 - (27.66)
Provision for Doubtful Debt (0.00) - - (0.00)
Security Deposit 5.20 - - 5.20
Payables for Capital Goods - Long Term (854.85) - - (854.85)
Recognized through OCI 14.68 - (5.27) 9.41
Profit & Loss Ind AS Adj. 842.88 (9.01) - 833.87
(15,352.65) (1,013.37) (5.27) (16,371.29)
Note:- 51. Income Tax Expenses

Reconciliation of tax liability on book profit vis-à-vis actual tax liability As at As at
31 March 2022 31 March 2021
Accounting profit before income tax 30,351.86 6,382.90
Tax at statutory income tax rate of 34.944% 10,606.15 2,230.44
Tax effect of the amounts not deductible for computing taxable income - -
Depreciation difference - 273.08
Disallowances 56.05 430.23
Deductions/Exemption (1,206.50) (1,398.33)
Unutilised tax credits - -
Acturial Valuation - -
Adjustment in capital gain under Income Tax Provision - -
Fair Valuation Gain on investments - -
MTM Gain on forex fluctuation - -
43B Disallowances 322.31 (58.53)
Provision for doubtful Debt - (19.01)
Others 27.44 -
Income Tax 9,805.45 1,457.88
106
Note:- 52. Financial Ratios are as below
Particular Numerator Denominator As at 31st As At 31st

Current Ratio Current Assets Current Liabilities (excluding 1.09 1.15

Current Maturities of Long
term Debt)
Debt Equity Ratio* Long Term Debt (excluding Shareholder’s Equity 0.31 0.51
Current Maturities of Long term (excluding Revaluation
Debt) reserve)
Debt Service Coverage ratio* Net profit after taxes Debt service = Finance 2.87 1.09
+ Non-cash operating expenses+ cost+ Schedule Repayment
finance cost (excluding prepayment)
Return on Equity Net Profit after taxes Average shareholder’s Equity 25.76% 7.34%
Ratio*
Inventory turnover Ratio (in Average Inventory Sale of Products in days 58.62 86.15
days)*
Trade Recievable ratio (in days) Average trade Recievable Gross Revenue from 27.42 36.50
operations
Trade Payable Turnover ratio (in Average trade Payable Total Expenses -Finance 68.04 82.71
Days) Cost-Depreciation-Employee
benefit expense
Net Capital Turnover ratio (in Working Capital (Current Assets- Net Sales=Total Sales-Sales 10.08 26.51
Days)* Current Liabilities (excluding return
Current Maturities of Long term
Debt))
Net Profit ratio* Net profit after taxes Net Sales=Total Sales-Sales 5.77% 2.82%
return
Return on Capital Employed* Profit before interest and taxes Capital Employed=Tangible 24.38% 9.51%
Net Worth +Long term Debt
including Current maturities of
Long term debt
* Variation in Coverage, turnover and other profitability ratios is primarily due to increase in turnover and profitability during the year ended
31st March 2022.
107
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108
Form No.MGT-11
Proxy form
[Pursuant to section 105(6) of the Companies Act, 2013 and rule 19(3) of the Companies (Management and Administration) Rules, 2014]
CIN : L27107PB1985PLC006159
Name of the Company : Steel Strips Wheels Limited
Registered Office : Village Somalheri / Lehli P.O. Dappar, Tehsil Derabassi, Distt. S.A.S Nagar Mohali (Punjab)-140506
Name of the Member(s):

Registered Address:
E-mail Id: Folio No /Client ID: DP ID:
I/We, being the member(s) of shares of the above named company, hereby appoint
Name: E-mail Id:

Address:
Signature , or failing him
Name : E-mail Id:

Address:
Signature , or failing him
as my/ our proxy to attend and vote (on a poll) for me/us and on my/our behalf at the 36th Annual General Meeting of the Company, to be
held on Friday, 30th day of September, 2022 at 11:00 A.M. at the Regd. Office of the Company at Village Somalheri/ Lehli, P.O. Dappar,
Tehsil Derabassi, Distt. S.A.S Nagar, Mohali (Punjab)- 140506, and any adjournment thereof in respect of such resolutions as are indicated
below:
Resolution Resolution(s)
No.
Ordinary Business
1. To receive, consider and adopt the Audited Standalone Financial Statements of the Company for the financial year ended
March 31, 2022 together with the Reports of the Board of Directors and the Auditors thereon (Ordinary Resolution)
2. To declare a dividend on Equity Shares for the financial year 2021-22 (Ordinary Resolution)
3. To appoint a Director in place of Sh. Dheeraj Garg (DIN: 00034926), who retires by rotation and being eligible, offers
himself for re-appointment (Ordinary Resolution)
4. To appoint a Director in place of Sh. Sanjay Garg (DIN: 00030956), who retires by rotation and being eligible, offers himself
for re-appointment (Ordinary Resolution)
5. To re-appoint M/s AKR & Associates, Chartered Accountants (ICAI Firm Registration No. 021179N) as Statutory Auditors
for the second term of 5 (five) years (Ordinary Resolution)
Special Business
6. To ratify the remuneration of Cost Auditors for the Financial Year 2022-23 (Ordinary Resolution)
7. To approve sub-division of 1 (One) Equity Share of face value of Rs. 5/- each into 5 (Five) Equity Shares of face value of
Re. 1/- each (Ordinary Resolution)
8. To approve alteration of Capital Clause of Memorandum of Association of the Company to effect the sub-division of equity
shares of the Company (Ordinary Resolution)
Affix
Revenue
Stamps
Signed this _____day of _____2022
Signature of Shareholder Signature of Proxy holder
Note:
1. This form of proxy in order to be effective should be duly completed and deposited at the Registered Office of the Company not less
than 48 hours before the commencement of the Meeting.
2. The proxy need not be a member of the company.
109
Courier/ Regd. Post
Location Map of Annual General Meeting

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110

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      

contents BOARD OF DIRECTORS

Notice 1-13 Sh. Rajinder Kumar Garg, Chairman

REGISTERED OFFICE COMPANY SECRETARY

Village Somalheri/Lehli, Sh. Shaman Jindal

WORKS BANKERS/ INSTITUTIONS

i. Village Somalheri/Lehli, Axis Bank Ltd.

HEAD OFFICE STATUTORY AUDITORS

By Order of the Board of Directors

Place: Chandigarh Shaman Jindal

Category of shareholder Applicable tax rate Documents required to be submitted

Declaration under Section 10(23D) of the Income Tax

Declaration qualifying as Insurer as per Section 2(7A)

Declaration under Section 10(23FBA) of the Act for

Declaration along with self-attested copy of documentary

Type of shareholders Login Method

By Order of the Board of Directors

Place: Chandigarh Shaman Jindal

By Order of the Board of Directors

Place: Chandigarh Shaman Jindal

Date: 02.09.2022 (Rajinder Kumar Garg)

Particulars Year ended 31.03.2022 Year ended 31.03.2021

C. FOREIGN EXCHANGE EARNINGS AND OUTGO

Particulars Year ended 31.03.2022 Year ended 31.03.2021

For and on behalf of the Board

Date: 02.09.2022 (Rajinder Kumar Garg)

ANNUAL REPORT ON CORPORATE SOCIAL RESPONSIBILITY (CSR) ACTIVITIES

S. No. Name of Director Designation/ Nature of Directorship Number of Number of meetings

1. Composition of the CSR committee shared http://sswlindia.com/wp-content/themes/sswl/assets/docs/composition_of_

S. NO. Particulars Amount (in Rs.)

Date: 02.09.2022 (Sh. Dheeraj Garg) (Sh. Surinder Singh Virdi)

Executive Directors Ratio of Median Remuneration

Name of Person % increase in remuneration

For and on behalf of the Board

Date: 02.09.2022 (Rajinder Kumar Garg)

1 Corporate Identity Number (CIN) of the Company L27107PB1985PLC006159

(a) Number of International Locations NIL

Paid-up Capital INR 1560.95 lakhs

Annual Report on Company’s CSR projects/programmes is attached as

Sr. No. Particulars Details

Sr. No. Particulars Details

For S. K. SIKKA & ASSOCIATES

Place: Chandigarh (Sushil Kumar Sikka)

My report of even date is to be read along with this letter.

(Sushil Kumar Sikka)

S. No. Compliance Requirement (Regulations/ Deviations Observations/Remarks of the Practicing

Further, BSE and NSE had denied

Place: Chandigarh (Sushil Kumar Sikka)

COMPANY’S PHILOSOPHY ON CODE OF GOVERNANCE

*Sh. Rajinder Non–Executive 6 No 2 1 - - 1. Indian Acrylics Limited

Sh. Dheeraj Executive 4 Yes - 1 - 2 Indian Acrylics Limited

Sh. Shashi Independent 5 No - 2 - - Indian Acrylics Limited

Name of the Director Designation No. of Shares held Percentage

Name of the Director Designation No. of Shares held Percentage

Name of Chairperson & Members Category Meetings Attended

Name of Chairperson & Members Category Meetings attended

Special Allowance Nil 15.00 2.87

Sh. Rajinder Kumar Garg √ √ √ √ √ √ 1,20,000

Name of Chairperson & Members Category Meetings Attended

Name of Chairperson & Members Category Meetings Attended