Pavna Industries : Draft letter of offer (Draft Offer Document filed with SEBI)

THIS IS A PUBLIC ANNOUNCEMENT FOR INFORMATION PURPOSES ONLY. THIS IS NOT A PROSPECTUS ANNOUNCEMENT AND DOES NOT CONSTITUTE AN INVITATION OR OFFER TO ACQUIRE, PURCHASE OR SUBSCRIBE TO SECURITIES. NOT FOR RELEASE, PUBLICATION OR DISTRIBUTION, DIRECTLY OR INDIRECTLY OUTSIDE INDIA.

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PAVNA INDUSTRIES LIMITED

Our Company was incorporated as 'Pavna Locks Private Limited', as a private limited company, in accordance with the provisions of the Companies Act, 1956, pursuant to a certificate of incorporation dated April 19, 1994 issued by the RoC. Subsequently, our Company was converted into a publ ic limited company and the name of our Company was changed to 'Pavna Locks Limited' and a fresh certificate of incorporation on November 13, 2000 was issued by the RoC. Thereafter, name of our Company was changed to 'Pavna Zadi Security Systems Limited' and a fresh certificate of incorporation dated November 17, 2000 was issued to our Company by the RoC. Thereafter, name of our Company was changed to 'Pavna Industries Limited' and a fresh certificate of incorporation dated May 21, 2019 was issued to our Company by the RoC.

Registered and Corporate Office: Vimlanchal, Hari Nagar, Aligarh, 202 001, Uttar Pradesh, India

Tel: [phone]; E-mail: [e-mail]; Website:www.pavna.in

Contact Person: Charu Singh, Company Secretary and Compliance Officer;

Corporate Identification Number: L34109UP1994PLC016359

OUR PROMOTERS: SWAPNIL JAIN AND ASHA JAIN

FOR PRIVATE CIRCULATION TO THE ELIGIBLE EQUITY SHAREHOLDERS OF PAVNA INDUSTRIES LIMITED (THE "COMPANY" OR THE

"ISSUER") ONLY

ISSUE OF UPTO 48,72,000 EQUITY SHARES OF FACE VALUE ₹ 10 EACH ("RIGHTS EQUITY SHARES") OF OUR COMPANY FOR CASH AT A PRICE OF

• [●] PER EQUITY SHARE (INCLUDING A SHARE PREMIUM OF ₹ [●] PER EQUITY SHARE) (THE "ISSUE PRICE"), AGGREGATING UPTO ₹ [●] LAKHS ON A RIGHTS BASIS TO THE EXISTING EQUITY SHAREHOLDERS OF OUR COMPANY IN THE RATIO OF [●] RIGHTS EQUITY SHARE(S) FOR EVERY [●] FULLY PAID-UP EQUITY SHARE(S) HELD BY THE EXISTING EQUITY SHAREHOLDERS ON THE RECORD DATE, THAT IS ON [●] (THE "ISSUE").
  THE ISSUE PRICE FOR THE RIGHTS EQUITY SHARES IS [●] TIMES OF THE VALUE OF THE EQUITY SHARES. FOR FURTHER DETAILS, PLEASE
  REFER TO THE CHAPTER TITLED "TERMS OF THE ISSUE" ON PAGE 218 OF THIS DRAFT LETTER OF OFFER.

Potential Bidders may note that the Company has, in consultation with the relevant stakeholders, decided to make certain updation in the sections titled "Summary of this Draft Letter of Offer", "Objects of the Issue" and "Risk Factors". Accordingly, the Draft Letter of Offer (DLOF), including the sections titled "Summary of this Draft Letter of Offer" on page 19, "Risk Factors" on pages 27, 28, 29, 36 and 38 and "Objects of the Issue" on pages 56-64 of the DLOF shall stand updated. Potential Bidders may note that in order to assist the Bidders to get a complete understanding of the updated information, the relevant portions of the DLOF updated as mentioned above have been included in this Addendum.

The above changes are to be read in conjunction with the DLOF and accordingly their references in the DLOF stand amended pursuant to this Addendum. The information in this Addendum supplements the DLOF and updates the information in the DLOF, as applicable. Please note that the information included in the DLOF, including to the extent stated in this Addendum, will be suitably updated, as may be applicable in the Letter of Offer, as and when filed with the RoC, the SEBI and the Stock Exchanges. Investors should read the Letter of Offer as and when filed with the RoC, the SEBI and the Stock Exchanges before making an investment decision in the Offer. All capitalized terms used in this Addendum shall, unless the context otherwise requires, have the meaning ascribed to them in the Letter of Offer.

The Rights Entitlements and the Rights Equity Shares have not been and will not be registered under the Securities Act or the securities laws of any state of the United States and may not be offered or sold in the United States of America or the territories or possessions thereof ("United States"), except in a transaction not subject to, or exempt from, the registration requirements of the United States Securities Act of 1933 ("Securities Act") and applicable state securities laws. The offering to which this Draft Letter of Offer relates is not, and under no circumstances is to be construed as, an offering of any Rights Equity Shares or Rights Entitlement for sale in the United States or as a solicitation therein of an offer to b uy any of the Rights Equity Shares or Rights Entitlement. There is no intention to register any portion of the Issue or any of the securities described herein in the United States or to conduct a public offering of securities in the United States.

This Addendum shall be made available to the public for comments, if any, for a period of at least 21 days, from the date of such filing with SEBI and will be available on their website www.sebi.gov.in, the websites of the Stock Exchanges i.e., www.nseindia.comand www.bseindia.com, the website of our Company at www.pavna.in and the website of the Lead Manager to the Issue, i.e., PNB Investment Services Limited at www.pnbisl.com

	On behalf of Pavna Industries Limited
Place: Aligarh	Sd/-
Date: May 13, 2024	Swapnil Jain
	Managing Director
LEAD MANAGER TO THE ISSUE	REGISTRAR TO THE ISSUE

PNB Investment Services Limited	Link Intime India Private Limited
PNB Pragati Towers, 2nd Floor,	C-101, 1st Floor, 247 Park,
Plot No. C-9,G-Block, Bandra Kurla Complex,	L.B. S. Marg, Vikhroli (West)
Bandra (E), Mumbai - 400 051	Mumbai 400 083
Maharashtra, India
Maharashtra, India
Tel: [phone]
Tel: [phone]
E-mail: [e-mail]
Email: [e-mail]
Website: www.pnbisl.com
Website: www.linkintime.co.in
Contact Person: Srinath Nair/ Shivani Tapadia
Investor grievance e-mail: [e-mail]
Investor grievance e-mail:[e-mail]
Contact Person: Shanti Gopalkrishnan
SEBI Registration No.: INM000011617
	SEBI Registration No.: INR000004058
	BID/ ISSUE PROGRAMME
ISSUE OPENS ON	LAST DATE FOR RECEIVING REQUESTS FOR		ISSUE CLOSES ON
	APPLICATION FORMS
[●]	[●]		[●]
	1

CONTENTS
SUMMARY OF THIS DRAFT LETTER OF OFFER	3
RISK FACTORS	4
OBJECTS OF THE ISSUE	7
DECLARATION	18

2

SUMMARY OF THIS DRAFT LETTER OF OFFER

1. The sub-paragraph titled "Objects of the Issue" on page 19 of the Draft Letter of Offer shall be replaced in the Letter of Offer by the sub-paragraph below:
   Objects of the Issue
   The Net Proceeds are proposed to be used in the manner set out in the following table:

	(₹ in lakhs)
Particulars	Amount
Repayment and/or prepayment, in part or full of certain of	10,929.42
our outstanding borrowings availed by our Company and
Subsidiaries
Funding incremental working capital requirements of our	1,400.00
Company
General corporate purpose	[●]
Net Proceeds*	[●]

For further details, please see chapter titled "Objects of the Issue" beginning on page 56 of this Draft Letter of Offer.

3

RISK FACTORS

1. The Risk Factor 7 included in the section titled 'Risk Factors' on page 27 in the Letter of Offer shall be updated as follows:
   In addition to the existing indebtedness our Company or our Subsidiaries, may incur further indebtedness during the course of business. We cannot assure that our Company or our Subsidiaries would be able to service the existing and/ or additional indebtedness.
   As on September 30, 2023, the total fund based indebtedness of our Company is ₹ 10,097.07 lakhs and our Subsidiaries is ₹ 1,042.25 lakhs. One of the Objects for the Issue is repayment or prepayment of certain secured loans availed by our Company Subsidiaries for which part of Net Proceeds will be utilized by our Company. The details of the loans identified to be repaid or prepaid using the Net Proceeds by our Company have been disclosed in the section titled "Objects of the Issue" on page 57 of this Draft Letter of Offer.
   In addition to the indebtedness for the existing operations, our Company or our Subsidiaries may incur further indebtedness during the course of their business. We cannot assure you that our Company or our Subsidiaries will be able to obtain further loans at favourable terms. Increased borrowings, if any, may adversely affect our debt-equity ratio and our ability to borrow at competitive rates. In addition, we cannot assure you that the budgeting of our working capital requirements for a particular year will be accurate. There may be situations where we may under-budget our working capital requirements, which may lead to delays in arranging additional working capital requirements, loss of reputation, levy of liquidated damages and can cause an adverse effect on our cash flows.
   Any failure to service the indebtedness of our Company or our Subsidiary or otherwise perform our obligations under our financing agreements entered with our lenders or which may be entered into by our Company or our Subsidiary, could trigger cross default provisions, penalties, acceleration of repayment of amounts due under such facilities which may cause an adverse effect on our business, financial condition and results of operations.
2. The Risk Factor 8 included in the section titled 'Risk Factors' on page 28 in the Letter of Offer shall be updated as follows:
   Unsecured loans of ₹ 1,118.32 lakhs taken by us from some of our related parties can be recalled at any time.
   Our Company and some of our Subsidiaries have availed unsecured loans which may be recalled by the lenders at any time. As on September 30, 2023, the unsecured loans of our Company and its Subsidiaries that may be recalled at any time by the lenders aggregated to ₹ 1,118.32 lakhs. In the event that any lender seeks repayment of any such loan, we would need to find alternative sources of financing, which may not be available on commercially reasonable terms, or at all. One of the Objects for the Issue is repayment or prepayment of certain secured loans availed by our Company and Subsidiaries for which part of Net Proceeds will be utilized. The details of the loans identified to be repaid or prepaid using the Net Proceeds by our Company and/or our Subsidiaries have been disclosed in the section titled "Objects of the Issue" on page 57 of this Draft Letter of Offer.
   We may not have adequate working capital to undertake new projects or complete the ongoing projects, and, as a result, any such demand by the lenders may affect our business, cash flows, financial condition and results of operations. Further, in respect of such unsecured loans, no proper agreement has been executed between the parties.
3. The Risk Factor 9 included in the section titled 'Risk Factors' on page 28 in the Letter of Offer shall be updated as follows:
   The agreements executed by our Company and our Subsidiaries with lenders for financial arrangements contain restrictive covenants for certain activities and if we or our Subsidiaries are unable to get their approval, it might restrict our scope of activities and impede our growth plans.

4

Our Company and our Subsidiaries have entered into agreements for our borrowings with certain lenders. These borrowings include secured fund based and non-fund based facilities. One of the Objects for the Issue is repayment or prepayment of certain secured loans availed by our Company and/or Subsidiaries for which part of Net Proceeds will be utilized.

The details of the loans identified to be repaid or prepaid using the Net Proceeds by our Company and/or our Subsidiaries have been disclosed in the section titled "Objects of the Issue" on page 57 of this Draft Letter of Offer.

These agreements entered by our Company and our Subsidiaries include restrictive covenants which mandate certain restrictions in terms of our business operations such as change in capital structure, formulation of any scheme of amalgamation or reconstruction, declaring dividends, further expansion of business, granting loans to directors, repaying unsecured loans/inter corporate deposits availed from Promoters and third parties, undertake guarantee obligations on behalf of any other borrower including subsidiaries, which require our Company and our Subsidiaries to obtain prior approval of the lenders for any of the above activities. We cannot assure you that our lenders will provide us or our Subsidiaries with these approvals in the future.

Further, some of the financing arrangements include covenants which mandate our Company and our Subsidiaries to maintain total outside liabilities and total net worth up to a certain limit and certain other liquidity ratios. A default under one of these financing agreements may also result in cross-defaults under other financing agreements and result in the outstanding amounts under such financing agreements becoming due and payable immediately. This might have an adverse effect on our cash flows, business, results of operations and financial condition.

1. The Risk Factor 12 included in the section titled 'Risk Factors' on page 29 in the Letter of Offer shall be updated as follows:
   We have in past entered into related party transactions and we may continue to do so in the future.
   As of September 30, 2023, we have entered into several related party transactions with our Promoters, our Subsidiaries relating to our operations. In addition, we have in the past also entered into transactions with other related parties. For further details, please see the section titled "Financial Information" at page 137 of this Draft Letter of Offer.
   While we believe that all our related party transactions have been conducted on an arm's length basis and in compliance with applicable provisions of Companies Act, 2013 and SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, we cannot assure you that we may not have achieved more favourable terms had such transactions been entered into with unrelated parties. There can be no assurance that such transactions, individually or taken together, will not have an adverse effect on our business, prospects, results of operations and financial condition, including because of potential conflicts of interest or otherwise. In addition, our business and growth prospects may decline if we cannot benefit from our relationships with them in the future.
2. The Risk Factor 27 included in the section titled 'Risk Factors' on page 36 shall be updated as follows:
   Inability to obtain sufficient funding in the future could result in the delay or abandonment of our expansion and diversification strategies and may have a material adverse effect on our business and results of operations.
   Our Company and our Subsidiaries have entered into agreements for our borrowings with certain lenders. These borrowings include secured fund based and non-fund based facilities.
   One of the Objects for the Issue is repayment or prepayment of certain secured loans availed by our Company and/or Subsidiaries for which part of Net Proceeds will be utilized. The details of the loans identified to be repaid or prepaid using the Net Proceeds by our Company and/or our Subsidiaries have been disclosed in the section titled "Objects of the Issue" on page 57 of this Draft Letter of Offer.

5

Our future expansion and diversification plans are dependent on various circumstances, including business developments, new businesses, products or investment opportunities or unforeseen contingencies. We may require additional external funding to meet our expenditure plans related to expansion and diversification plans, including borrowings or sale of equity or debt securities. An inability to obtain sufficient funding in the future could result in the delay or abandonment of our expansion and diversification strategies. In addition, if we raise additional funds through incurrence of debt, our interest and debt repayment obligations will increase, and we may be subject to additional covenants, which could limit our ability to access cash flow from operations and/or other means of financing. Our ability to arrange financing and the costs of such financing are dependent on numerous factors, including general economic and capital market conditions, credit availability from banks, investor confidence, the continued participation with OEMs and increase in sales of our products and other laws that are conducive to our raising capital in this manner. We cannot assure that we will be able to raise adequate financing to fund future capital requirements on acceptable terms, in time or at all. Any failure to obtain sufficient funding could result in the delay or abandonment of our development and expansion plans and would have a material adverse effect on our results of operations and financial condition.

1. The Risk Factor 34 included in the section titled 'Risk Factors' on page 38 in the Letter of Offer shall be updated as follows:
   As the securities of our Company are listed on Stock Exchanges in India, our Company is subject to certain obligations and reporting requirements under the SEBI Listing Regulations. Any non- compliances/delay in complying with such obligations and reporting requirements may render us liable to prosecution and/or penalties.
   The Equity Shares of our Company are listed on BSE and NSE, therefore we are subject to the obligations and reporting requirements prescribed under the SEBI Listing Regulations. There have been instances in the past wherein, our Company has failed to comply with the requirements of the SEBI Listing Regulations in a timely manner. As on the date of this Draft Letter of Offer, the details pertaining to actions initiated by Stock Exchanges including penalty/ fine imposed upon our Company by Stock Exchanges are as follows:

Sr.		Particulars		Amount of	Date on which	Status
No.					fine/	fine/penalty was
					penalty	imposed and name
					(₹ in lakhs)	of stock exchange
1.	Non-compliance	of	Regulation	0.50	December 14, 2021	Penalty paid
	33	of the	SEBI LODR		(NSE)
	Regulations
2.	Non-compliance	of	Regulation	0.56	November 21, 2023	Penalty paid
	17	(1A) of the SEBI LODR		(NSE)
	Regulations
3.	Non-compliance	of	Regulation	0.56	November 21, 2023	Penalty paid
	17	(1A) of the SEBI LODR		(NSE)
	Regulations

For further details, see "Outstanding Litigation and Material Developments" on page 206.

Our Company endeavours to comply with all such obligations/reporting requirements, there may be non- disclosures/delayed/erroneous disclosures and/or any other violations which might have been committed by us, and the same may result into Stock Exchanges and/or SEBI imposing penalties, issuing warnings and show cause notices against us and/or taking actions as provided under the SEBI Act and Rules and Regulations made there under and applicable SEBI Circulars. Any such adverse regulatory action or development could affect our business reputation, divert management attention, and result in a material adverse effect on our business prospects and financial performance and on the trading price of the Equity Shares.

6

Particulars

Repayment and/or prepayment, in part or full, of certain of our outstanding borrowings availed by our Company and/or Subsidiaries

Funding incremental working capital requirements of our Company

General corporate purpose

OBJECTS OF THE ISSUE

1. The section titled 'Objects of the Offer' included on pages 56-64 of the Draft Letter of Offer shall be replaced in the Letter of Offer as follows:

The Net Proceeds from the Issue are proposed to be utilised by our Company towards funding for the following objects:

1. Repayment and/or pre-payment, in full or in part, of certain borrowings availed by our Company and/or Subsidiaries;
2. Funding the incremental working capital requirements of our Company; and
3. General corporate purposes.

(Collectively, referred to herein as the "Objects").

The main objects and objects incidental or ancillary to the main objects as stated in the Memorandum of Association enable our Company to undertake (i) its existing activities; (ii) to undertake the activities for which borrowings were availed and which are proposed to be repaid or prepaid from the Net Proceeds.

Net Proceeds

The details of the Net Proceeds are summarized in the table below:

	(in ₹ lakhs)
Particulars	Estimated Amount
Gross proceeds*	[●]
Less: Issue related expenses	[●]
Net Proceeds#	[●]

*Assuming full subscription in the Issue and subject to finalization of the Basis of Allotment and to be adjusted per the Rights Entitlement ratio.

#To be finalized upon determination of the Issue Price and updated in the Letter of Offer. The amount utilized for general corporate purposes shall not exceed 25% of the Gross Proceeds.

Requirement of Funds and Utilisation of Net Proceeds

The Net Proceeds are proposed to be utilized in accordance with the details provided hereunder:

(in ₹ lakhs)

Amount

10,929.42

1,400.00

[●]

Net Proceeds*[●] *To be finalized upon determination of the Issue Price and updated in the Letter of Offer. The amount utilized for general corporate purposes shall not exceed 25% of the Gross Proceeds.

Deployment of funds and schedule of implementation

We propose to deploy the Net Proceeds for the aforesaid purposes in accordance with the estimated schedule of implementation and deployment of funds set forth in the table below.

				(in ₹ lakhs)
		Amount to be		Year wise break-up of
Particulars		funded from Net		the expenditure
		Proceeds		Fiscal 2025
Repayment and/or prepayment, in part or full, of certain of
our borrowings availed by our Company and/or	10,929.42	10,929.42
Subsidiaries

7

		Amount to be		Year wise break-up of
Particulars		funded from Net		the expenditure
		Proceeds		Fiscal 2025
Funding incremental working capital requirements of our	1,400.00	1,400.00
Company
General Corporate Purpose*		[●]	[●]
Net Proceeds*		[●]	[●]

*To be finalized upon determination of the Issue Price and updated in the Letter of Offer. The amount utilized for general corporate purposes shall not exceed 25% of the Gross Proceeds.

Our fund requirements and proposed deployment of the Net Proceeds are based on our internal management estimates as per our business plan based on current circumstances of our business prevailing market conditions. Further, such fund requirements and proposed deployment of funds have not been appraised by any bank or financial institution or any other independent agency. We may need to revise our estimates from time to time in light of various factors such as changes in costs, our financial condition, business and strategy or external circumstances such as market conditions, the economic conditions, changing regulatory policies, prevailing competitive environment, interest or exchange rate fluctuations, which may not be in our control. This may entail rescheduling the proposed utilisation of the Net Proceeds and changing the allocation of funds from our planned allocation at the discretion of our management, in accordance with applicable laws. In the event that the estimated utilization out of the Net Proceeds in a Fiscal is not met (in part or full), such unutilised amount shall be utilised in the succeeding Fiscal(s), as determined by our Company, in accordance with applicable law.

In case we require additional capital towards meeting the objects of the Fresh Issue, our Company may explore arrange of options including utilising internal accruals and availing additional debt from existing and/or future lenders. We believe that such alternate arrangements would be available to fund any such shortfalls. If the actual utilisation towards any of the objects is lower than the proposed deployment, such balance will be used for funding future growth opportunities, and/or towards funding any of the other existing objects (if required), and/or general corporate purposes within the permissible limit in accordance with applicable law.

Means of finance

The funding requirements mentioned above are based on the internal management estimates of our Company and have not been appraised by any bank, financial institution or any other external agency. They are based on current circumstances of our business and our Company may have to revise its estimates from time to time on account of various factors beyond its control, such as market conditions, competitive environment, and interest or exchange rate fluctuations. Consequently, the funding requirements of our Company and deployment schedules are subject to revision in the future at the discretion of our management, subject to applicable law. If additional funds are required for the purposes as mentioned above, such requirement may be met through internal accruals, additional capital infusion, debt arrangements or any combination of them, subject to compliance with applicable laws. Further, depending on the funding requirements of our Company and subject to market and other considerations, our Company may increase the size of the Issue by 20% as disclosed in this Draft Letter of Offer in accordance with the SEBI ICDR Regulations and other applicable laws. Since our Company is not proposing to fund any specific project from the Net Proceeds, the requirement to make firm arrangements of finance through verifiable means towards 75% of the stated means of finance for such project proposed to be funded from the Net Proceeds is not applicable.

Details of the Objects

1. Repayment or prepayment, in full or in part, of all or a portion of certain outstanding borrowings availed by our Company and/or Subsidiaries from banks and financial institutions

We have entered into various financing arrangements from time to time, with various lenders. As on January 20,

2024, we had total sanctioned limit of borrowings of ₹ 12,727.13 lakhs and has utilized ₹ 10,929.42 lakhs. Our Company proposes to utilise an estimated amount of up to ₹ 10,929.42 lakhs from the Net Proceeds towards pre- payment or scheduled repayment of all or a portion of the outstanding borrowings availed by us. We may repay or refinance certain loans set out in the table below, prior to filing of the Letter of Offer. In such a situation, we may utilise the Net Proceeds for part or full repayment of any such additional loan or loans obtained to refinance any of our existing loans. We may choose to repay or pre-pay certain borrowings availed by our Company and/or

8

Subsidiaries, other than those identified in the table below, which may include additional borrowings we may avail after the filing of this Draft Letter of Offer. Given the nature of these borrowings and the terms of repayment/pre-payment, the aggregate outstanding borrowing amounts may vary from time to time. In light of the above, at the time of filing the Letter of Offer, the table below shall be suitably updated to reflect the revised amounts or loans as the case may be which have been availed by us. In the event our Board deems appropriate, the amount allocated for estimated schedule of deployment of Net Proceeds in a particular fiscal may be repaid/ pre-paid in part or full by us in the subsequent fiscal in compliance with applicable laws. The selection of borrowings proposed to be repaid/prepaid by us shall be based on various factors including (i) any conditions attached to the borrowings restricting our ability to prepay the borrowings and time taken to fulfil such requirements, (ii) levy of any prepayment penalties and the quantum thereof, (iii) other commercial considerations including, among others, the interest rate on the loan facility, the amount of the loan outstanding and the remaining tenor of the loan, (iv) receipt of consents for prepayment or waiver from any conditions attached to such prepayment from our lenders and (v) provisions of any law, rules, regulations governing such borrowings. Further, we have obtained written consents from our lenders for undertaking the Offer. We believe that such repayment or prepayment will help reduce our outstanding indebtedness and our debt-equity ratio and enable utilization of our internal accruals for further investment in business growth. We may avail further loans after the date of this Draft Letter of Offer and/or draw down further funds under existing loans. In addition, we believe that the strength of our balance sheet and our leverage capacity will further improve, which shall enable us to raise further capital in the future at competitive rates to fund potential business development opportunities and plans to grow and expand our business in the coming years.

The following table sets forth details of certain borrowings availed by us, which are outstanding as on January 20,

2024 out of which we may repay/prepay, all or a portion of, any or all of the borrowings, from the Net Proceeds:

9

				Name of Lender									Amount			Principle amount			Purpose for						Rate of			Pre-
				and Date of			Type of								outstanding as on					Tenure				p	aymen
	Sr.							Name of Borrower			sanctioned					which loan was					interest
			Sanction			borrowing	(2)						20	th	January 2024				(	months	)				t
																	(1)(2)
	No												(₹ in Lakhs)				(₹ in lakhs)(2)			obtained						(in %)		Penalty
1			HDFC Bank Ltd		Term Loan		Pavna Industries Limited	429.00				113.86		Working Capital	39		9.25		4%
	30/06/2021								Requirements
2			HDFC Bank Ltd		Term Loan		Pavna Industries Limited	609.60				102.64		Working Capital	35		9.02		4%
	30/06/2021								Requirements
3			HDFC Bank Ltd		Term Loan		Pavna Industries Limited	1,000.00				805.63		Working Capital	60		9.14		4%
	27/06/2023								Requirements
4			HDFC Bank Ltd		Term Loan		Pavna Industries Limited	1,200.00				1,141.90		Working Capital	60		9.18		4%
	27/02/2023								Requirements
				HDFC Bank Ltd		Working														Working Capital
5				Capital			Pavna Industries Limited	1,310.53				1,310.53		12		9.00		4%
	09/10/2023									Requirements
					Demand Loan
6			HDFC Bank Ltd		Cash Credit		Pavna Industries Limited	5,000.00				4,528.76		Working Capital	12		9.02		4%
	27/06/2023								Requirement
7			Bajaj Finance Ltd	Purchase Order		Pavna Industries Limited	2,000.00				2,000.00		Working Capital	12		8.50		2%
	27/03/2023			Facility							Requirement
8			HDFC Bank Ltd		Cash Credit		Pavna Auto Engineering	500.00				484.28		Working Capital	12		9.20		4%
	20/07/2023				Pvt Ltd					Requirement
9			HDFC Bank Ltd		Term Loan		Pavna Auto Engineering	19.00				11.78		Working Capital	14		9.19		4%
	20/07/2023				Pvt Ltd					Requirements
10			Bajaj Finance Ltd	Purchase Order		Pavna Auto Engineering	200.00				60.00		Working Capital	12		8.50		2%
	27/03/2023			Facility			Pvt Ltd					Requirements
11			HDFC Bank Ltd		Cash Credit		Pavna Marketing Pvt Ltd	350.00				319.22		Working Capital	12		8.80		2%
	08/12/2023								Requirements
12			HDFC Bank Ltd		Term Loan		Pavna Marketing Pvt Ltd	59.00				10.87		Working Capital	48		9.25		2%
	13/06/2020								Requirements
13			HDFC Bank Ltd		Cash Credit		Swapnil Switches Pvt Ltd	50					39.95		Working Capital	12		8.64		2%
	11/12/2023									Requirements
							TOTAL				12,727.13				10,929.42

1. In accordance with Clause 9(A)(2)(b) of Part A of Schedule VI of the SEBI ICDR Regulations which requires a certificate from the statutory auditor certifying the utilization of loan for the purpose availed, our Statutory Auditors have confirmed that the loans have been utilised for the purpose for which it was availed pursuant to certificate dated February 2, 2024.
2. As certified by the Statutory Auditors of the Company, vide their certificate dated February 2, 2024

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