DIRECTORS' REPORT

Your Directors have pleasure in presenting their 17th Annual Report of Elfin Agro India Limited (“the Company”) on
business and operations along with the audited financial statements for the financial year (“FY”) ended, March 31,
2026.

1. NATURE OF BUSINESS

The Company is primarily engaged in the manufacturing of a range of food products, including Chakki Atta (high-fibre
whole wheat flour), R Atta (refined whole wheat flour), Tandoori Atta (special-purpose flour), Sooji (semolina), Maida
(refined wheat flour), and Yellow Mustard Oil

During the financial year 2025-26, there was no change in the nature of the Company’s business activities, and it
continued to operate in the same line of business as in the previous financial year.

2. FINANCIAL PERFORMANCE

3. STATE OF COMPANY’S AFFAIRS

During the financial year under review, the revenue from operations of the Company for the financial year ended
31 March 2026 was ^17,677.68 lakh, as compared to ^14,586.34 lakh in the previous financial year, representing
a growth of 21.19%. The Profit After Tax (PAT) for the financial year ended 31 March 2026 was ^576.98 lakh, as
compared to ^503.03 lakh in the previous financial year, reflecting a growth of 14.70%.
During the financial year under review, there was no change in the nature of the business of the Company. The
Company continued to be engaged in the business of manufacturing and processing of flour and allied products.

4. DIVIDEND

Your Board has decided to plough back the earnings in the growth of business and for this reason, have decided,
not to recommend any Dividend for the year under review.

Pursuant to Regulation 43A(2) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations,
2015, the Board notes that the requirement to have a Dividend Distribution Policy does not apply to the Company
as the said regulation is applicable only to the top five hundred listed entities based on market capitalisation. The
Company, being outside the scope of such threshold, is not required to formulate or publish a Dividend
Distribution Policy under Regulation 43A(2). Accordingly, no separate Dividend Distribution Policy has been
adopted by the Company at this time.

5. ANNUAL RETURN AS PROVIDED UNDER SECTION 92

Draft Annual Returns of the Company is available on the Company’s
Website:http://www.elfinagroindia.com/downloads/Draft-Annual-Return-2025-26.pdf

6. CHANGE IN STATUS AND LISTING OF THE COMPANY

During the financial year under review, the Company achieved a significant milestone by getting its equity shares
listed on the BSE SME Platform on March 12, 2026. The listing of the Company marks a major step towards
enhanced transparency, improved corporate governance, and broader access to capital markets.

The Board believes that the listing will further strengthen the Company’s growth trajectory, enhance stakeholder
confidence, and provide greater visibility in the industry.

7. TRANSFER TO RESERVES

The closing balance of the retained earnings of the Company for FY 25 -2026 after all appropriation and adjustments
was 1247.83 Lakhs.

8. SHARE CAPITAL

During the financial year the Authorised Share Capital of the Company is Rs. 10,00,00,000/- (Rupees Ten Crores
only) divided into 2,00,00,000 (Two Crore) Equity Shares of face value Rs. 5/- (Rs. Five Only) rank pari-passu in
all respect.

Pursuant to the Initial Public Offer of Equity Shares by the Company, the Board of Directors, in their meeting held
on 10th March, 2026, has allotted 53,25,000 (Fifty Three Lakh Twenty Five Thousand) Equity Shares Rs. 5/-
(Rupees Five Only) each at price of Rs. 47/- (Rupees Forty Seven Only) per Equity Share (Including a share
premium of Rs. 42/- (Rupees Forty-Two Only) Per Equity Share to the successful allottees, whose list have been
finalized by the Company, the Registrar to the issue and merchant banker in consultation with Bombay Stock
Exchange (BSE).

The Paid-up share capital of the company as on 31 March, 2026 is Rs. 9,71,25,000/-(Rupees Nine Crores Seventy
One Lakhs and Twenty Five Thousand Only) divided into 1,94,25,000 Equity Shares of Rs. 5/- each.

A. BUY BACK OF SECURITIES:

The Company has not bought back any of its securities during the year under review.

B. SWEAT EQUITY:

The Company has not issued any Sweat Equity Shares during the year under review.

C. BONUS SHARES:

The Company has not issued any Bonus Shares during the year under review.

D. RIGHTS ISSUE

The Company has not issued any Rights Issue during the year under review.

E. EMPLOYEES STOCK OPTION PLAN:

The Company has not provided any Stock Option Scheme to the employees.

9. CREDIT RATING

As company has not availed any credit facility requiring credit rating. Hence, the company did not obtain credit
rating.

10. TRANSFER OF SHARES / AMOUNT TO IEPF

During the year under review, the Company had not transferred any amount or Shares to the Investor Education
and Protection Fund.

11. INTERNAL FINANCE CONTROL SYSTEMS AND THEIR ADEQUACY

The Company has in place adequate Internal Finance control systems commensurate with the size, scale, and
nature of its business operations. These controls are designed to ensure the safeguarding of assets, prevention
and detection of frauds and errors, accuracy and completeness of accounting records, and timely preparation of
reliable financial information.

The Company continuously reviews its internal control mechanisms with a view to strengthening operational
efficiency, ensuring compliance with applicable laws and regulations, and promoting effective risk
management practices.

During the financial year under review, the Board of Directors appointed an Internal Auditor to review and
monitor the adequacy and effectiveness of the internal Finance control systems and processes of the Company.
The observations and recommendations of the Internal Auditor will be reviewed by the Audit committee &
Board and appropriate corrective actions will be taken, wherever considered necessary.

12. PARTICULARS OF CONTRACTS OR ARRANGEMENTS WITH RELATED PARTIES

During the Financial Year 2025-26, the Company entered into transactions with related parties in the ordinary
course of business and on an arm's length basis. Certain related party transactions undertaken during the year
qualified as Material Related Party Transactions in terms of the applicable provisions of the Companies Act,
2013 and the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, as amended.

The Policy on Related Party Transactions as approved by the Board is available on the Company's website
http://www.elfinagroindia.com/downloads/Related-party-transactions-policy.pdf.

The particulars of contracts or arrangements with related parties referred to in Section 188(1) of the Companies
Act, 2013, in the prescribed Form AOC-2, are annexed to this Report as Annexure-I. Details of related party
transactions are also disclosed in the notes forming part of the Financial Statements in the Note No. 29.

13. DIRECTORS AND KEY MANAGERIAL PERSONNEL

The Board of Directors comprises distinguished professionals of proven integrity and competence, who provide
strategic direction, guidance and leadership to the Company.

As on March 31, 2026, the Board of Directors of the Company comprised of Five Directors with an optimum
balance of Executive and Non-Executive Directors, including One Women Director. Of these, three Directors
were Non-Executive Directors, two of whom were Independent Directors.

Pursuant to the provisions of Section 203 of the Companies Act, 2013, the Key Managerial Personnels (KMPs)
is duly constituted as follows:-

There was no change in the composition of the Board of Directors and Key Managerial Personnel during FY
2025-26.

Mr. Vimal Kumar Daga, (DIN: 07953851) Whole Time Director of the Company is retires by rotation and
being eligible offers himself for re-appointment. A resolution seeking Members’ approval for his re¬
appointment along with other required details forms part of the Notice of this AGM.

During the year under review, the Non-Executive Directors of the Company had no pecuniary relationship or
transactions with the Company, other than sitting fees, commission and reimbursement of expenses, if any.

14. DECLARATIONS GIVEN BY INDEPENDENT DIRECTORS

All the Independent Directors of the Company have given their declaration under Section 149 (7) of the
Companies Act, 2013 along with Rules framed thereunder, confirming that they are in compliance with the
criteria as laid down in the said Section for being an Independent Director of the Company. Further, there has
been no change in the circumstances which may affect their status as Independent Director during the year.

The Statement of Declaration of Independence from Independent Directors that they meet the criteria of
independence as provided in sub-section (6) of Section 149 of the Companies Act, 2013 and the relevant rules
and Regulation 16(1)(b) of SEBI LODR Regulations has been obtained from the Independent Directors and the
Board has taken on record the same. Further the Independent Directors have also declared that in the event of
expiry of their registration with the Data bank, they shall take the necessary steps to renew their registration in
accordance with the applicable provisions of the Companies Act 2013 read with rules made thereunder.

15. MEETING OF INDEPENDENT DIRECTOR

Pursuant to the provisions of Schedule IV of the Companies Act, 2013 and the applicable provisions of the SEBI
(Listing Obligations and Disclosure Requirements) Regulations, 2015, the Independent Directors of the
Company met separately during the financial year on 17th February, 2026 without the attendance of Non¬
Independent Directors and members of the management
The Independent Directors, inter alia, reviewed and evaluated.

• The performance of Non-Independent Directors and the Board as a whole;

• Taking into account the views of executive directors and non-executive directors;

Assessed the quality, quantity and timeliness of flow of information between the Company's management and the
Board that is necessary for the Board to effectively and reasonably perform its duties.

The Independent Directors expressed satisfaction with the overall functioning of the Board and its Committees
and the effectiveness of the governance framework of the Company.

16. FAMILIARISATION PROGRAMME FOR INDEPENDENT DIRECTORS

Pursuant to the requirements of Regulation 25(7) of the SEBI (Listing Obligations and Disclosure Requirements)
Regulations, 2015, the Company has adopted a Familiarisation Programme for Independent Directors with an aim
to familiarize them with the Company, its business operations, industry environment, regulatory framework,
organizational structure, business model, risk management systems, internal control processes, roles, rights and
responsibilities of Independent Directors.

The Independent Directors are regularly updated on changes in the business environment, applicable laws and
regulations, corporate governance practices, risk management framework, and the Company's operations and
performance through presentations made at Board and Committee Meetings.

The details of the Familiarization Programme imparted to Independent Directors during the financial year and
the web link thereto are available on the website of the Company at:

http://www.elfinagroindia.com/downloads/Familiarization-Programme-For-Independent-Directors.pdf.

17. BOARD MEETINGS

The Directors of the Company met at regular intervals with the gap between two meetings not exceeding 120
days to take a view of the Company’s policies and strategies apart from the Board matters. The notices of the
Board meetings are given well in advance to all the Directors of the Company.

The Board of Directors of the Company met 15 times during the year in respect of which proper notices were
given and the proceedings were properly recorded, signed and maintained in the Minutes Book kept by the
company for the purpose. Details of the same are as follows:

GENERAL MEETING

During the Financial year under review, the following General Meetings were held, the details of which are
given as under:

BOARD COMMITTEE

The company constituted four committees as per the Companies Act, 2013 read with SEBI (Listing Obligations and
Disclosure Requirements) Regulations, 2015, in order to fulfil the conditions specified for listing its shares with the
Stock Exchange. The committees constituted by the Board are:

a) . Audit Committee : During the financial year under review, all recommendations made by the Audit Committee
were accepted by the Board of Directors.

b) . Nomination Remuneration Committee

c) . Stakeholders Relationship Committee

d) . Corporate Social Responsibility Committee

The Composition and meeting held during the year are annexed as Annexure II.

18. RISK MANAGEMENT POLICY

The management has taken all necessary steps to identify the elements of risks, if any. The management has
implemented an effective and meaningful system to safeguard the assets of the company. The Board periodically
review the business plan at regular intervals and develop the Risk Management Strategy which shall encompass
laying down guiding principles on proactive planning for identifying, analyzing and mitigating all the material risks,
both external and internal viz. Environmental, Business, Operational, Financial and others.

The key risks and concerns affecting the Company's business are discussed in detail in the Management Discussion
and Analysis Report, which forms part of this Annual Report.

19. POLICY ON VIGIL MECHANISM & WHISTLE BLOWER

Pursuant to the provisions of Section 177(9) of the Companies Act, 2013 read with Rule 7 of the Companies
(Meetings of its Board and its Powers) Rules, 2014 and Regulation 22 of SEBI Listing Regulations, the Company
has an established Policy on Vigil Mechanism for Directors / Employees and other stakeholders of the Company to
report concerns about unethical behaviors, actual or suspected fraud, or violation of the Company's Code of conduct

or ethics policy. The policy also provides a direct access to the Chairman of the Audit Committee to make protective
disclosures to the management about the grievances or violation of the Company's code of conduct.

The Policy on Vigil Mechanism is available on the website of the Company at:

https://www.elfinagroindia.com/downloads/Whistle-blower-policv.pdf

20. NOMINATION AND REMUNERATION POLICY

Pursuant to the provisions of Section 178 of the Companies Act, 2013 and applicable provisions of the SEBI (Listing
Obligations and Disclosure Requirements) Regulations, 2015, the Board of Directors has, on the recommendation of
the Nomination and Remuneration Committee, adopted a Nomination and Remuneration Policy.

The Policy lays down the criteria for appointment, qualification, positive attributes and independence of Directors,
Key Managerial Personnel and Senior Management Personnel. The Policy also provides for a framework relating to
remuneration payable to Directors, Key Managerial Personnel and Senior Management Personnel and seeks to ensure
that the level and composition of remuneration is reasonable and sufficient to attract, retain and motivate persons of
the quality required to successfully run the Company.

The Nomination and Remuneration Policy is available on the website of the Company at:
https://elfinagroindia.com/downloads/Nomination-and-remuneration-policy.pdf

21. CORPORATE SOCIAL RESPONSIBILITY

Corporate Social Responsibility (CSR) is an initiative brought in by the Ministry of Corporate Affairs whereby every
company having net worth of rupees 500 Crores or more, or turnover of rupees 1000 Crores or more or a net profit
of rupees 5 Crores or more during the immediately preceeding financial year is mandated to serve the society by
contributing at least 2% of the average net profits of the Company made during the three immediately preceeding
financial years in various CSR activities as defined in Schedule VII of the Companies Act, 2013.

The Company has duly constituted a Corporate Social Responsibility Committee as required under Section 135 (1)
of the Companies Act, 2013 and the relevant rules made thereunder and the Board has approved a policy Corporate
Social Responsibility which is available in the website of the Company
https://elfinagroindia.com/downloads/Nomination-and-remuneration-policy.pdf The Annual Report on your
Company’s CSR activities is appended as “Annexure-III” to the Board’s Report.

22. POLICIES

The Board of Directors of the Company have from time to time framed and approved various Policies in pursuance
of the Companies Act, 2013 and the Listing Agreement/ SEBI (LODR) Regulations, 2015. These Policies and Codes
are reviewed by the Board and are updated, if required. The following policies have been framed and are published
in the Company's website

1. Internal Posh Policy

2. Code for Fair Disclosure of Unpublished Price Sensitive Information

3. Code of Conduct & Appointment of Independent Directors

4. Code of Conduct for Directors & Senior Management

5. Code of Conduct Regulate Monitor and Report Trading by Designated Persons and their Immediate
Relatives

6. Corporate Social Responsibility Policy

7. Criteria for Making Payments to Non-Executive Directors

8. Familiarization Programme for Independent Directors

9. Insider Trading Policy

10. Nomination and Remuneration Policy

11. Policy and Procedure for Inquiry in Case of Leak or Suspected Leak of Unpublished Price Sensitive
Information

12. Policy for Determination of Materiality of Events

13. Policy for Determining Material Subsidiaries

14. Policy for Preservation of Documents Archival Policy of Website

15. Policy on Identification of Group Companies Material Creditors and Material Litigations

16. Related Party Transactions Policy

17. Whistle Blower Policy

WEBSITE DISCLOSURES

In compliance with the applicable provisions of the Companies Act, 2013 and SEBI (Listing Obligations and
Disclosure Requirements) Regulations, 2015, the Company maintains a functional website
www.elfinagroindia.comcontaining details of its business activities, financial information, statutory disclosures,
policies, codes, notices, annual reports and other investor-related information.

The Investor Relations section of the website contains all disclosures required under the applicable provisions of the
Companies Act, 2013 and SEBI (LODR) Regulations, 2015.

23. DIRECTORS’ RESPONSIBILITY STATEMENT AS REQUIRED UNDER SECTION 134 (5) OF
THE COMPANIES ACT, 2013

Pursuant to Section 134(5) of the Companies Act, 2013, the Board of Directors hereby confirms that:

(a) In the preparation of the annual accounts, the applicable accounting standards had been followed along with
proper explanation relating to material departures;

(b) The directors had selected such accounting policies and applied them consistently and made judgments and
estimates that are reasonable and prudent so as to give a true and fair view of the state of affairs of the company at
the end of the financial year and of the profit and loss of the company for that period;

(c) The directors had taken proper and sufficient care for the maintenance of adequate accounting records in
accordance with the provisions of this Act for safeguarding the assets of the company and for preventing and
detecting fraud and other irregularities;

(d) The directors had prepared the annual accounts on a going concern basis; and

(e) The directors, had laid down internal financial controls to be followed by the company and that such internal
financial controls are adequate and were operating effectively.

(f) The directors had devised proper systems to ensure compliance with the provisions of all applicable laws and that
such systems were adequate and operating effectively.

24. DISCLOSURE OF PARTICULARS OF LOANS/ADVANCES/INVESTMENTS OUTSTANDING
DURING THE FINANCIAL YEAR

The Company has not given any loans and advances to any other body corporate and associates as specified under
Section 186 of the Companies Act, 2013 during the financial year 2025-26.

The details of the investments made by the Company and guarantees provided by the Company are given in the notes
to the financial statements.

25. PENALTIES / PUNISHMENT/ COMPOUNDING OF OFFENCES

During the financial year 2025-26, no penalties have been imposed on the company by any regulatory authorities.

26. PUBLIC DEPOSITS

The Company has not accepted any deposit from the public within the meaning of Chapter V of the Companies Act
2013 during the year ended 31st March 2026.

27. CONSERVATION OF ENERGY, TECHNOLOGY ABSORPTION AND FOREIGN EXCHANGE
EARNINGS AND OUTGO

The information pertaining to conservation of Energy, Technology Absorption, Foreign Exchange Earnings and
outgo as required under Section 134(3)(m) of the Companies Act, 2013 read with Rule 8 (3) of the Companies
(Accounts) Rules, 2014 is annexed to this Report as “Annexure-IV”.

28. ANNUAL PERFORMANCE EVALUATION

Pursuant to the provisions of the Companies Act, 2013 and the applicable provisions of SEBI (Listing Obligations
and Disclosure Requirements) Regulations, 2015, the Board has carried out an annual evaluation of its own
performance, the performance of individual Directors, Committees of the Board. The criteria is broadly based on the
Guidance Note on Board Evaluation issued by the SEBI.

The evaluation process was conducted in a structured manner covering various aspects of the Board’s functioning,
composition of the Board and its Committees, experience and competencies, performance of specific duties and
obligations, governance issues and effectiveness of the Board and its Committees.

The performance of each of the non-independent directors was also evaluated by the Independent Directors at
separate meeting held of Independent Directors of the Company.

The performance evaluation of Independent Directors was carried out by the entire Board, excluding the Director
being evaluated. The Board expressed satisfaction with the overall functioning and effectiveness of the Board, its
Committees and individual Directors.

The Board and the Nomination and Remuneration Committee (“NRC”) reviewed the performance of individual
directors on the basis of criteria such as contribution of the individual director to the Board and Committee meetings
like preparedness on the issues to be discussed, meaningful and constructive contribution and inputs in meetings, etc.

The overall outcome of the Board evaluation process was positive and the Directors expressed satisfaction with the
performance and effectiveness of the Board, its Committees and Individual Directors.

29. BUSINESS RESPONSIBILITY AND SUSTAINABILITY REPORT (BRSR)

In terms of Regulation 34(2)(f) of SEBI (Listing Obligations and Disclosure Requirements)Regulations, 2015,
submission of a Business Responsibility and Sustainability Report (BRSR) is applicable to the top 1,000 listed
entities (by market capitalization) as on March 31 of every financial year. As the Company is listed on the SME
Platform of BSE and does not fall within the top 1,000 listed entities, the provisions relating to BRSR are not
applicable to the Company.

30. HUMAN RESOURCE DEVELOPMENT

The Company seeks to nurture a mutually beneficial relationship with its employees. This relationship is
characterized by the Investment which the company makes in its employees by providing challenging roles and
assignment opportunities for personal growth, relevant and timely performance support, training and an enabling
environment. The company seeks to create a workplace which combines achievement orientation with care for
employees. The Company lists “people” as one of its stated core values.

Further details relating to the Company's human resources and employee initiatives are provided in the Management
Discussion and Analysis Report, which forms part of this Annual Report.

31. DISCLOSURES UNDER SEXUAL HARASSMENT OF WOMEN AT WORKPLACE
(PREVENTION, PROHIBITION & REDRESSAL) ACT, 2013:

The Company has in place a Policy on prevention of Sexual Harassment, in accordance with the requirements of the
Sexual Harassment of Women at workplace (Prevention, Prohibition and Redressal) Act, 2013. All women
employees are covered under this policy. The Company has complied with the provisions relating to the constitution
of Internal Complaints Committee under the Sexual Harassment of Women at Workplace (Prevention, Prohibition
and Redressal) Act, 2013 (POSH). Internal Committees (“ICs”) have been constituted in accordance with the
requirements of the POSH Act.

The company had not received any Complaints under Sexual Harassment of Women at Workplace (Prevention,
Prohibition & Redressal) Act, 2013 during the financial year 2025-2026.

32. MATERNITY BENEFIT

The Company is committed to providing a supportive and inclusive work environment for its employees. During the
financial year under review, the Company complied with the provisions of the Maternity Benefit Act, 1961, as amended
from time to time. Eligible women employees are entitled to maternity benefits in accordance with the applicable
provisions of the Act and the Company's policies. The Company continues to promote employee welfare and gender
diversity by ensuring compliance with all statutory requirements relating to maternity benefits.

33. PREVENTION OF INSIDER TRADING

The Company has adopted a code for prevention of insider trading with a view to regulate trading and securities by
the Directors and designated employees of the Company. The code requires preclearance for dealing in the
Company’s securities and prohibits the purchase or sale of Company’s Securities while in possession of unpublished
price sensitive information and during the period when the trading window is closed. The company maintains a
structured digital database called “PIT Archive” software wherein the details of all the designated persons are being
captured in compliance with Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations,
2015.

34. DECLARATION OF COMPLIANCE WITH CODE OF CONDUCT

The Company has adopted a Code of Conduct applicable to the Directors and Senior Management Personnel. The
Company believes in conducting its affairs in a fair, transparent and ethical manner. All the Directors and Senior
Management Personnel have affirmed compliance with the Code of Conduct for the Financial Year ended March 31,
2026. The Code of Conduct is available on the website of the Company at:
http://www.elfinagroindia.com/downloads/Code-of-conduct-for-directors-and-senior-management.pdf

35. PARTICULARS OF EMPLOYEES

The ratio of the remuneration of each director to the median of employees’ remuneration as per 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 to this Report as “Annexure-V”.

During the year, no employee received remuneration exceeding ^1,02,00,000/- (Rupees One Crore Two Lakhs Only)
per annum and/or ^8,50,000/- (Rupees Eight Lakhs Fifty Thousand Only) per month. Accordingly, the disclosure
required under Rule 5(2) of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014
is not applicable.

Further, there were no employees who were employed throughout the financial year or for any part thereof outside
India, not being directors or relatives of directors, and drawing remuneration in excess of the amount prescribed
under Rule 5(3) of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014.
Accordingly, the prescribed statement is not required to be circulated to the members or annexed to this Annual
Report.

36. MANAGEMENT DISCUSSION AND ANALYSIS REPORT

Management Discussion and Analysis for the year, as required under SEBI (Listing Obligations and Disclosure
Requirements) Regulations, 2015, is presented in a separate section forming part of the Annual Report as “Annexure -
VI”.

37. Auditors

? INTERNAL AUDITORS

Section 138 of the Companies Act, 2013 read with Rule 13 of the Companies (Accounts) Rules, 2014 and based on
the recommendations made by the Audit Committee M/s. Jindal Kulwal & Associates Chartered Accountants,
Bhilwara has been appointed as the Internal Auditors for carrying out the Internal Audit of the company for the FY
2025-26 & FY 2026-27.

? STATUTORY AUDITORS

Pursuant to Section 139 of the Companies Act, 2013 read with its relevant Rules made thereunder M/s Deepak Agal
& Company (Firm Registration Number 019684C), Chartered Accountants, was appointed as the Statutory Auditor of
the company at the 15th Annual General Meeting held on 21st September, 2024 to hold such office till the conclusion
of 19th Annual General Meeting ought to be held in the year 2028.

During the year, the statutory auditors have confirmed that they satisfy the independent criteria required under
Companies Act, 2013.

? SECRETARIAL AUDITORS

Pursuant to Section 204 of the Companies Act, 2013 and the Companies (Appointment and Remuneration of
Managerial Personnel) Rules, 2014, the Company has appointed Ms. Sanjana Jain, Practicing Company Secretaries,
as the Secretarial Auditors of the Company in the Board Meeting held on 31st March 2026, for the FY 2025-26. The
Secretarial Audit Report issued by the Company’s Secretarial Auditor PCS Sanjana Jain is annexed and forms part of
this Report in “Annexure-VII”.

? COST AUDITORS

The provisions relating to maintenance of cost records under Section 148(1) of the Companies Act, 2013 and Cost
Audit were not applicable to the Company during the Financial Year 2025-26.

? STATUTORY AUDITOR’S REPORT AND SECRETARIAL AUDIT REPORT

The Statutory Auditor’s report and the Secretarial Audit report for the Financial Year 2025-26 does not contain any
qualifications, reservations, adverse remarks or disclaimer.

During the year under review, the Statutory Auditors and Secretarial Auditors of the Company have not reported any
fraud to the Audit Committee committed by its officers or employees as specified under Section 143(12) of the Act.

38. STATEMENT OF DEVIATION OR VARIATION

Pursuant to Regulation 32 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, the
Company confirms that there has been no deviation or variation in the utilization of proceeds from the funds raised

through preferential issue/public issue/nghts issue/QIP during the financial year. The Statement of Deviation or
Variation has been reviewed by the Audit Committee and submitted to the Stock Exchange(s).

39. DISCLOSURE OF ACCOUNTING TREATMENT

The Company has followed the Accounting Standards specified under the Companies (Accounts) Rules, 2014 (as
amended) to the extent applicable, in the preparation of the financial statements.

40. DETAILS IN RESPECT OF FRAUDS REPORTED BY AUDITORS UNDER SUB-SECTION (12) OF
SECTION 143 OTHER THAN THOSE WHICH ARE REPORTABLE TO THE CENTRAL GOVERNMENT

The Statutory Auditors have stated that, no fraud by the Company or no material fraud on the Company by its officers
and employees had been noticed or reported during the year.

41. DISCLOSURES WITH RESPECT TO DEMAT SUSPENSE ACCOUNT / UNCLAIMED SUSPENSE
ACCOUNT AS PER PARA F OF SCHEDULE V OF SEBI (LISTING OBLIGATIONS AND DISCLOSURE
REQUIREMENTS) REGULATIONS, 2015

42. DECLARATION BY THE CHIEF EXECUTIVE OFFICER STATING THAT THE MEMBERS OF BOARD
OF DIRECTORS AND SENIOR MANAGEMENT PERSONNEL HAVE AFFIRMED COMPLIANCE WITH
THE CODE OF CONDUCT OF BOARD OF DIRECTORS AND SENIOR MANAGEMENT:

The Company does not have a Chief Executive Officer (CEO). Accordingly, the declaration has been made by the
Managing Director and the Chief Financial Officer (CFO), confirming that the members of the Board of Directors and
the Senior Management Personnel have affirmed compliance with the Company's Code of Conduct for the financial year
ended 31 March 2026.

43. COMPANIES WHICH HAVE BECOME OR CEASED TO BE THE SUBSIDIARIES / JOINT VENTURES /
ASSOCIATE COMPANIES DURING THE YEAR

The Company does not have any Subsidiary, Joint ventures or Associate Company.

44. THE DETAILS OF APLICATION MADE OR ANY PROCEEDINGS PENDING UNDER THE
INSOLVENCY AND BANKRUPTCY CODE, 2016 (31 OF 2016) DURING THE YEAR.

Your Company confirms that no application against the Company has been filed or is pending under the Insolvency and
Bankruptcy Code 2016 during the year under review. Your Company further confirms there are no past applications or
proceedings under the Code.

45. DETAILS OF SIGNIFICANT AND MATERIAL ORDERS PASSED BY THE REGULATORS OR COURTS
OR TRIBUNALS IMPACTING THE GOING CONCERN STATUS AND COMPANY’S OPERATIONS IN
FUTURE

No significant and material orders were passed by the regulators or courts or tribunals which affect the going concern
status and future operation of the Company.

46. MATERIAL CHANGES AND COMMITMENTS, IF ANY AFFECTING THE FINANCIAL POSITION OF
THE COMPANY OCCURRED BETWEEN THE END OF THE FINANCIAL YEAR TO WHICH THE
FINANCIAL STATEMENTS RELATES AND THE DATE OF THE REPORT

There have been no material changes and commitments affecting the financial position of the Company which have
occurred between the end of the financial year of the Company to which the financial statements relate and the date
of this Report.

47. SECRETARIAL STANDARDS

The Company has complied with all applicable Secretarial Standards in pursuant to the directions of Ministry of
Corporate Affairs, issued by the Institute of Company Secretaries of India during the year.

48. 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 THERE OF

During the Financial Year 2025-26, the Company has not made any one time settlement with its bankers from which
it has accepted any loan.

49. COMPLIANCE WITH SEBI (LISTING OBLIGATIONS AND DISCLOSURE REQUIREMENTS)
REGULATIONS, 2015

The Company's equity shares were listed on the SME Platform of BSE Limited during the financial year under review.
The Company has complied with all applicable provisions of the SEBI (Listing Obligations and Disclosure
Requirements) Regulations, 2015, as applicable to entities listed on the SME Platform.

The Company has also complied with the applicable SEBI circulars, guidelines and directions issued from time to time
and has submitted all requisite reports, returns and disclosures to the Stock Exchange within the prescribed timelines.

50. REGISTRAR AND SHARE TRANSFER AGENT

In compliance with the provisions of the Companies Act, 2013 and the SEBI (Listing Obligations and Disclosure
Requirements) Regulations, 2015, the Company has appointed a Registrar and Share Transfer Agent (RTA) to efficiently
handle all share-related services. The RTA is responsible for maintaining records of the shareholders, processing share
transfers, handling investor grievances, and facilitating various other investor-related services such as dematerialization,
issuance of duplicate share certificates, and transmission of shares.

The Company has appointed Cameo Corporate Services Limited as its Registrar and Share Transfer Agent. Shareholders
are advised to contact Cameo Corporate Services Limited for any assistance regarding share transfers, dematerialization,
or other related queries. The contact details of the RTA are provided below for the convenience of shareholders:
Cameo Corporate Services Limited
"Subramanian Building" 5^th floor , No. 1, Club House Road,

Chennai - 600 002

Telephone: 91-44-40020700 / 28460390
Email:cameomumbai@gmail.com

The Company ensures seamless coordination with the RTA to maintain high standards of investor servicing and
regulatory compliance.

51. SEBI COMPLAINTS REDRESS SYSTEM (SCORES)

Investors’ complaints are processed in a centralized web-based complaints redress system. The salient features of
this system are: Centralized database of all complaints, online upload of Action Taken Reports (ATRs) by
concerned companies and online viewing by investors of actions taken on the complaint and its current status. The
Company regularly redresses the complaints if any, on SCORES within stipulated time.

52. DESIGNATED EXCLUSIVE EMAIL-ID

The Company has designated the email-id: cs@elfinagroindia.com exclusively for investor servicing.

53. LISTING FEES:

The Company confirms that it has paid the Annual Listing Fees for the year 2025-26 & 2026-27 to BSE Limited,
Stock Exchange where the company’s shares are listed.

54. ACKNOWLEDGEMENTS AND APPRECIATION

The Board of Directors of the Company wishes to place on record their deep sense of gratitude to all the
Shareholders of the Company for their consistent support and continued faith reposed in the Company. The Board
also expresses its deep sense of appreciation to the various Central and State Government Departments, Bankers,
Organizations and Agencies, external Professionals associated with the Company for their help and co-operation
extended by them and last but not the least, to Employees at all levels for their hard work and commitment.

For and on behalf of the Board of Directors
ELFIN AGRO INDIA LIMITED

Sd/- Sd/-

Mr. Deepak Pal Daga Mr. Vimal Kumar Daga

Managing Director Whole Time Director

DIN: 05173273 DIN: 07953851

Date: 21/07/2026
Place: Bhilwara