Integrated Filing-Governance



General information about company

Scrip Code 000000
NSE Symbol SUNLITE
MSEI Symbol NOTLISTED'
ISIN INE0U2N01013
Name of the entity Sunlite Recycling Industries Limited
Date of start of financial year 01-Apr-2024
Date of end of financial year 31-Mar-2025
Reporting Quarter Yearly
Date of Quarter Ending 31-Mar-2025
Type of company SME
Whether Annexure I (Part A) of the SEBI Circular dated December 31, 2024 related to Compliance Report on Corporate Governance is applicable to the entity? No
Reason For Part A Of Annexure ICompliance Report On Corporate Governance Is Not Applicable To The Entity NOT APPLICABLE
Whether Annexure I (Part B) of the SEBI Circular dated December 31, 2024 related to Investor Grievance Redressal Report is Applicable to the entity? Yes
Whether Annexure I (Part C) of the SEBI Circular dated December 31, 2024 related to Disclosure of Acquisition of Shares or Voting Rights in Unlisted Companies is Applicable to the entity? No
Reason For Part C Of Annexure I Disclosure Of Acquisition Of Shares OrVotingRightsInUnlistedCompaniesIsNotApplicableToTheEntity NOT APPLICABLE
Whether Annexure I (Part D) of the SEBI Circular dated December 31, 2024 related to Disclosure of Imposition of Fine or Penalty is Applicable to the entity? Yes
Whether Annexure I (Part E) of the SEBI Circular dated December 31, 2024 related to Disclosure of Updates to Ongoing Tax Litigations or Disputes is Applicable to the entity? Yes
Whether Annexure I (Part F) of the SEBI Circular dated December 31, 2024 related to Disclosure Of Loans / Guarantees / Comfort Letters / Securities Etc. is Applicable to the entity? No
Reason For Part F Of Annexure I Disclosure Of Loans Or Guarantees Or Comfort Letters Or Securities Etc Is Not Applicable To The Entity NOT APPLICABLE
Risk management committee
Market Capitalisation as per immediate previous Financial Year
Is SCORE ID Available ? Yes
SCORE Registration ID coms02034
Reason For No SCORE ID
Type of Submission Original
Remarks (website dissemination)



Annexure I
Annexure I to be submitted by listed entity on quarterly basis
I. Composition of Board of Directors
Disclosure of notes on composition of board of directors explanatory
Whether the listed entity has a Regular Chairperson
Whether Chairperson is related to MD or CEO Disqualification of Directors under section 164 of the Companies Act, 2013
Sr Title (Mr / Ms) Name of the Director PAN DIN Category 1 of directors Category 2 of directors Category 3 of directors Date of Birth Whether the director is disqualified? Start Date of disqualification End Date of disqualification Details of disqualification Current status Whether special resolution passed? [Refer Reg. 17(1A) of Listing Regulations] Date of passing special resolution Initial Date of appointment Date of Re-appointment Date of cessation Tenure of director (in months) No of Directorship in listed entities including this listed entity (Refer Regulation 17A of Listing Regulations) No of Independent Directorship in listed entities including this listed entity [with reference to proviso to regulation 17A(1) & 17A(2)] Number of memberships in Audit/ Stakeholder Committee(s) including this listed entity (Refer Regulation 26(1) of Listing Regulations) No of post of Chairperson in Audit/ Stakeholder Committee held in listed entities including this listed entity (Refer Regulation 26(1) of Listing Regulations) Reason for Cessation Notes for not providing PAN Notes for not providing DIN



Annexure 1

II. Composition of Committees
Disclosure of notes on composition of committees explanatory



Audit Committee Details
Whether the Audit Committee has a Regular Chairperson
Sr DIN Number Name of Committee members Category 1 of directors Category 2 of directors Date of Appointment Date of Cessation Remarks



Nomination and remuneration committee
Whether the Nomination and remuneration committee has a Regular Chairperson
Sr DIN Number Name of Committee members Category 1 of directors Category 2 of directors Date of Appointment Date of Cessation Remarks



Stakeholders Relationship Committee
Whether the Stakeholders Relationship Committee has a Regular Chairperson
Sr DIN Number Name of Committee members Category 1 of directors Category 2 of directors Date of Appointment Date of Cessation Remarks



Annexure 1
III. Meeting of Board of Directors
Disclosure of notes on meeting of board of directors explanatory
Sr Date(s) of meeting (Enter dates of Previous quarter and Current quarter in chronological order) Maximum gap between any two consecutive (in number of days) Notes for not providing Date Whether requirement of Quorum met (Yes/No) Total Number of Directors as on date of the meeting Number of Directors present* (All directors including Independent Director) No. of Independent Directors attending the meeting*



Annexure 1
IV. Meeting of Committees
Disclosure of notes on meeting of committees explanatory
Sr Name of Committee Date(s) of meeting (Enter dates of Previous quarter and Current quarter in chronological order) Maximum gap between any two consecutive (in number of days) Name of other committee Reson for not providing date Whether requirement of Quorum met (Yes/No) Total Number of Directors in the Committee as on date of the meeting Number of Directors Present (All Directors including Independent Director) No. of Independent Directors attending the meeting* No. of members attending the meeting (other than Board of Directors)



Annexure 1
VI. Affirmations
Sr Subject Compliance status (Yes/No)
1 The composition of Board of Directors is in terms of SEBI (Listing obligations and disclosure requirements) Regulations, 2015
2 The composition of the following committees is in terms of SEBI(Listing obligations and disclosure requirements) Regulations, 2015 a. Audit Committee
3 The composition of the following committees is in terms of SEBI(Listing obligations and disclosure requirements) Regulations, 2015. b. Nomination & remuneration committee
4 The composition of the following committees is in terms of SEBI(Listing obligations and disclosure requirements) Regulations, 2015. c. Stakeholders relationship committee
5 The composition of the following committees is in terms of SEBI(Listing obligations and disclosure requirements) Regulations, 2015. d. Risk management committee (applicable to the top 1000 listed entities)
6 The committee members have been made aware of their powers, role and responsibilities as specified in SEBI (Listing obligations and disclosure requirements) Regulations, 2015.
7 The meetings of the board of directors and the above committees have been conducted in the manner as specified in SEBI (Listing obligations and disclosure requirements) Regulations, 2015
8 This report and/or the report submitted in the previous quarter has been placed before Board of Directors.
9 Any comments/observations/advice of Board of Directors may be mentioned here:



Annexure 1
Sr Subject Compliance status
1 Name of signatory
2 Designation



Details of Cyber security incidence
Whether as per Regulation 27(2)(ba) of SEBI (LODR) Regulations, 2015 there has been cyber security incidents or breaches or loss of data or documents during the quarter
Other details of cyber security incidence or breaches or loss of data event
Number of cyber security incidence or breaches or loss of data event occurred during the quarter
Sr Date of the event Brief details of the event



Annexure II to be submitted by listed entity at the end of the financial year (for the whole of financial year)
I. Disclosure on website in terms of LODR Regulation
Sr Item Compliance status (Yes/No/NA) If status is No details of non-compliance may be given here. Web address
1.1 Details of business
1.2 Memorandum of Association and Articles of Association
1.3 Brief profile of board of directors including directorship and full time positions in body corporates
2 Terms and conditions of appointment of independent directors
3 Composition of various committees of board of directors
4 Code of conduct of board of directors and senior management personnel
5 Details of establishment of vigil mechanism or whistle blower policy
6 Criteria of making payments to non-executive directors
7 Policy on dealing with related party transactions
8 Policy for determining material subsidiaries
9 Details of familiarization programmes imparted to independent directors
10 Contact information of the designated officials of the listed entity who are responsible for assisting and handling investor grievances
11 Email address for grievance redressal and other relevant details
12 Financial results
13 Shareholding pattern
14 Details of agreements entered into with the media companies and/or their associates
15.1 Schedule of analyst or institutional investor meet and presentation prepared by listed entity for analyst or institutional investor meet
15.2 Audio or video recordings and transcripts of post earnings/quarterly calls
16 New name and the old name of the listed entity
17 Advertisements as per regulation 47 (1)
18 Credit rating or revision in credit rating obtained
19 Separate audited financial statements of each subsidiary of the listed entity
20 Secretarial compliance report
21 Materiality policy as per regulation 30 (4)
22 Disclosure of contact details of KMP who are authorized for the purpose of determining materiality as required under regulation 30(5)
23 Disclosures under regulation 30(8)
24 Statements of deviation(s) or variations(s) as specified in regulation 32
25 Dividend distribution policy as specified in regulation 43A (1)
26.1 Annual return as provided under section 92 of the Companies Act 2013
26.2 Employee benefit scheme documents framed in terms of SEBI (SBEB) regulations 2021
27 Confirmation that the above disclosures are in a separate section as specified in regulation 46(2)
28 Compliance with regulation 46(3) with respect to accuracy of disclosures on the website and timely updation
29 Disclosure of notes on website in terms of Listing Regulations explanatory


Annexure II
II. Annual Affirmations
Sr Particulars Regulation Number Compliance status (Yes/No/NA) If status is No details of non-compliance may be given here.
1 Independent director(s) have been appointed in terms of specified criteria of independence and/or eligibility 16(1)(b)
2 Board Composition 17(1), 17(1A) & 17(1C), 17(1D) & 17(1E)
3 Meeting Of Board Of Directors 17(2)
4 Quorum of board meeting 17(2A)
5 Review of Compliance Reports 17(3)
6 Plans for orderly succession for appointments 17(4)
7 Code of Conduct 17(5)
8 Fees/compensation 17(6)
9 Minimum Information 17(7)
10 Compliance Certificate 17(8)
11 Risk Assessment & Management 17(9)
12 Performance Evaluation of Independent Directors 17(10)
13 Recommendation of Board 17(11)
14 Maximum number of Directorships 17A
15 Composition of Audit Committee 18(1)
16 Meeting of Audit Committee 18(2)
17 Role of Audit Committee and information to be reviewed by the audit committee 18(3)
18 Composition of nomination & remuneration committee 19(1) & (2)
19 Quorum of Nomination and Remuneration Committee meeting 19(2A)
20 Meeting of Nomination and Remuneration Committee 19(3A)
21 Role of Nomination and Remuneration Committee 19(4)
22 Composition of Stakeholder Relationship Committee 20(1), 20(2) & 20(2A)
23 Meeting of Stakeholders Relationship Committee 20(3A)
24 Role of Stakeholders Relationship Committee 20(4)
25 Composition and role of risk management committee 21(1),(2),(3),(4)
26 Meeting of Risk Management Committee 21(3A)
27 Quorum of Risk Management Committee meeting 21(3B)
28 Gap between the meetings of the Risk Management Committee 21(3C)
29 Vigil Mechanism 22
30 Policy for related party Transaction 23(1), (1A), (5), (6), & (8)
31 Prior or Omnibus approval of Audit Committee for all related party transactions 23(2), (3)
32 Approval for material related party transactions 23(4)
33 Disclosure of related party transactions on consolidated basis 23(9)
34 Composition of Board of Directors of unlisted material Subsidiary 24(1)
35 Other Corporate Governance requirements with respect to subsidiary of listed entity 24(2),(3),(4),(5) & (6)
36 Alternate Director to Independent Director 25(1)
37 Maximum Tenure 25(2)
38 Appointment, Re-appointment or removal of an Independent Director through special resolution or the alternate mechanism 25(2A)
39 Meeting of independent directors 25(3) & (4)
40 Familiarization of independent directors 25(7)
41 Declaration from Independent Director 25(8) & (9)
42 Directors and Officers insurance 25(10)
43 Confirmation with respect to appointment of Independent Directors who resigned from the listed entity 25(11)
44 Memberships in Committees 26(1)
45 Affirmation with compliance to code of conduct from members of Board of Directors and Senior management personnel 26(3)
46 Policy with respect to Obligations of directors and senior management 26(2) & 26(5)
47 Approval of the Board and shareholders for compensation or profit sharing in connection with dealings in the securities of the listed entity 26(6)
48 Vacancies in respect Key Managerial Personnel 26A(1) & 26A(2), 26A(3)
Any other information to be provided - Add Notes



Annexure II
III. Affirmations
Sr Particulars Compliance status (Yes/No/NA)
1 The Listed Entity has approved Material Subsidiary Policy and the Corporate Governance requirements with respect to subsidiary of Listed Entity have been complied $intratedCg.get("CG_YN_$!integratedFillingMasterDto.cgMasterVO.affirmation_Ann2")
Any other information to be provided



Annexure II
1 Name of signatory
2 Designation



Additional Half yearly Disclosure
Any Other Information for Disclosure of Loans / Guarantees / Comfort Letters / Securities Etc.
I. Disclosure of Loans/ guarantees/comfort letters /securities etc.refer note below
(A)Any loan or any other form of debt advanced by the listed entity directly or indirectly to
Entity Aggregate amount advanced during six months Balance outstanding at the end of six months
Promoter or any other entity controlled by them
Promoter Group or any other entity controlled by them
Directors (including relatives) or any other entity controlled by them
KMPs or any other entity controlled by them
(B) Any guarantee / comfort letter (by whatever name called) provided by the listed entity directly or indirectly, in connection with any loan(s) or any other form of debt availed By
Entity Type (guarantee, comfort letter etc.) Aggregate amount of issuance during six months Balance outstanding at the end of six months(taking into account any invocation)
Promoter or any other entity controlled by them
Promoter Group or any other entity controlled by them
Directors (including relatives) or any other entity controlled by them
KMPs or any other entity controlled by them
(C) Any security provided by the listed entity directly or indirectly, in connection with any loan(s) or any other form of debt availed by
Entity Type of security (cash, shares etc.) Aggregate value of security provided during six months Balance outstanding at the end of six months
Promoter or any other entity controlled by them
Promoter Group or any other entity controlled by them
Directors (including relatives) or any other entity controlled by them
KMPs or any other entity controlled by them
(D) Additional Information
II. Affirmations
Affirmations Compliance Status Company Remarks
All loans (or other form of debt), guarantees, comfort letters (by whatever name called) or securities in connection with any loan(s) (or other form of debt) given directly or indirectly by the listed entity to promoter(s), promoter group, director(s) (including their relatives), key managerial personnel (including their relatives) or any entity controlled by them are in the economic interest of the company. $intratedCg.get("CG_YN_$!integratedFillingMasterDto.cgMasterVO.anx4aAffirmComplStatus")
Name
Designation
Place
Date



Signatory Details
Name of signatory
Designation of person
Place
Date


Investor Grievance Details
No. of investor complaints pending at the beginning of Quarter 0
No. of investor complaints received during the Quarter 0
No. of investor complaints disposed off during the Quarter 0
No. of investor complaints those remaining unresolved at the end of the Quarter 0


Disclosure of Acquisition of Shares or Voting Rights in Unlisted Companies-
The details of acquisition of shares or voting rights in unlisted companies during the quarter in terms of sub-para 1 of para A of Part A of Schedule III are given below
Any Other Information for Disclosure of Acquisition of Shares or Voting Rights in Unlisted Companies
Sr. No. Name of the unlisted company in which shares or voting rights have been acquired Date of acquisition Aggregate holding (% shares or voting rights) as at the end of the previous quarter % shares or voting rights acquired during the quarter Aggregate holding (% shares or voting rights) as at the end of the quarter


Disclosure of Imposition of Fine or Penalty
The details of imposition of fine or penalty during the quarter in terms of sub-para 20 of para A of Part A of Schedule III are given below:
Any Other Information for Disclosure of Imposition of Fine or Penalty For Para 3 of the tabel we herebb infomrmed that in continuation to our earlier intimation dated 04th March, 2025 to the Stock Exchange regarding the demand order passed by the Assistant Commissioner of State Tax, Ghatak-49, Nadiad, against the Show Cause Notice (SCN) in Form DRC-01 for the Financial Year 202021, which had initially demanded GST of Rs.6.70 lakhs, interest of Rs.5.30 lakhs, and penalty of Rs.0.47 lakhs, we wish to inform that the Company has now received a Rectification Order from the GST Department. As per the said Order, the demand has been fully withdrawn, and no tax, interest, or penalty is now payable vide Ratification Order dated 19/04/2025
Sr. No. Name of the authority Nature and details of the action(s) taken or order(s) passed Date of receipt of direction or order, including any ad interim or interim orders, or any other communication from the authority Details of the violation(s)/ contravention(s) committed or alleged to be committed Impact on financial, operation or other activities of the listed entity, quantifiable in monetary terms to the extent possible
1 National Stock Exchange of India Ltd Listing Fine fees for SOPE Reg. 6 Period 24-Dec-2024 20-Feb-2025 Delay in Appointment of Compiance Officer as per the (Listing Obligations and Disclosure Requirements) Regulations, 2015 and Fine of Rs. 0.09 lacs has been charged from the Exchange There has been no imact on Financial, Operation or other activitis of the Listed Entity
2 O/o Joint Commissioner, VADODARA-I, GST, Nadiad An adjudication order has been passed in terms of Section 74(9) of the Goods and Services Tax Act, 2017, 20-Feb-2025 an adjudication order has been passed in terms of Section 74(9) of the Goods and Services Tax Act, 2017, against SCN No. VAD-I/PRE/SCN/117/GR-J/2024-25, demanding GST of Rs. 836 Lacs, and penalty of Rs. 836 Lacs. There has been no imact on Financial, Operation or other activitis of the Listed Entity.The current status of the dispute remains the same as the Company has filed Appela with Appeal to Appellate Authority on 31.03.2025
3 Assistant Commissioner, Ghatak 49, GST, Nadiad Demand order has been passed by assistant commissioner of State Tax Ghatak-49 under Section 73 of GST Act, 2017 25-Feb-2025 Demand order has been passed by assistant commissioner of State Tax Ghatak-49 Nadiad against SCN (DRC-01) for F.Y. 20-21 demanding GST of Rs. 6.70 Lacs, Interest Rs. 5.30 Lacs and Penalty Rs. 0.47 lacs. There has been no imact on Financial, Operation or other activitis of the Listed Entity. The current status of the dispute remains the same as the Company has filed Ratifiction for Demand Order passed and it has been under consideration with GST Department.
4 Assistant Commissioner Ghatak 49 (Nadiad):Range -13:Division - 6:Gujarat Demand order has been passed by Assistant Commissioner Ghatak 49 (Nadiad):Range -13:Division - 6:Gujarat 28-Feb-2025 The demand order has been passed for Financial Year 2020–21. The demand relates to excess Input Tax Credit (ITC) claimed in GSTR-3B as compared to that reflected in GSTR-2A. GST (Tax): Rs.0.16 lakhs Interest: Rs. 0.12 lakhs Penalty: Rs. 0.20 lakhs Total Demand: Rs.0.48 lakhs The Company has reviewed the demand and agreed to accept the same. There has been no imact on Financial, Operation or other activitis of the Listed Entity


Disclosure of Updates to Ongoing Tax Litigations or Disputes
The updates on tax litigations or disputes in terms of sub-para 8 of para B of Part A of Schedule III read with corresponding provisions of Annexure 18 of the Master Circular are given below:

Any Other Information for Disclosure of Updates to Ongoing Tax Litigations or Disputes For Para 3 of the tabel we herebb infomrmed that in continuation to our earlier intimation dated 04th March, 2025 to the Stock Exchange regarding the demand order passed by the Assistant Commissioner of State Tax, Ghatak-49, Nadiad, against the Show Cause Notice (SCN) in Form DRC-01 for the Financial Year 202021, which had initially demanded GST of Rs.6.70 lakhs, interest of Rs.5.30 lakhs, and penalty of Rs.0.47 lakhs, we wish to inform that the Company has now received a Rectification Order from the GST Department. As per the said Order, the demand has been fully withdrawn, and no tax, interest, or penalty is now payable vide Ratification Order dated 19/04/2025
Sr. No. Name of the opposing party Date of initiation of the litigation / dispute Status of the litigation / dispute as per last disclosure Current status of the litigation / dispute
1 Assistant Commissioner of State of Tax (1) (Enforcement) Division-1, Ahmedabad EN FORCEMENT, DIVISTON-1, AHMEDABAD 28-Aug-2024 On August 8, 2024, the GST Department conducted proceedings under Section 67(2) at our factory located at Survey No. 270a & Plot No. 1, Survey No. 267, Chhatha Mile, Kheda, Dantali, Gujarat, India, 387350. Subsequently, based solely on a preliminary scrutiny and investigation, the Office has issued a Provisional Attachment Order under Section 83 of the Gujarat Goods and Services Tax Act, 2017, and against it the Company has filed objection against this order on September 4, 2024 The current status of the dispute remains the same as the Company has filed objections against the same.
2 O/o Joint Commissioner, VADODARA-I, GST, Nadiad 20-Feb-2025 an adjudication order has been passed in terms of Section 74(9) of the Goods and Services Tax Act, 2017, against SCN No. VAD-I/PRE/SCN/117/GR-J/2024-25, demanding GST of ₹ 836 Lacs, and penalty of ₹ 836 Lacs and against it the Company has filed objection against this order on September 4, 2024 The current status of the dispute remains the same as the Company has filed Appela with Appeal to Appellate Authority on 31-03-2025
3 Assistant Commissioner, Ghatak 49, GST, Nadiad 25-Feb-2025 Demand order has been passed by assistant commissioner of State Tax Ghatak-49 Nadiad against SCN (DRC-01) for F.Y. 20-21 demanding GST of Rs. 6.70 Lacs, Interest Rs. 5.30 Lacs and Penalty Rs. 0.47 lacs. and against it the Company has filed objection against this order on September 4, 2024 The current status of the dispute remains the same as the Company has filed Ratifiction for Demand Order passed and it has been under consideration with GST Department.
4 Income Tax Department 02-Mar-2025 Income Tax Department (“IT Department”) conducted search under the Income Tax Act, 1961 at the offices and manufacturing units of the Company and residential address of Mr. Nitin Kumar Heda- Managing Director, Mr. Prahladrai Ramdayal Heda-Whole Time Director, Mrs. Khushboo Manishkumar Heda- Director and Mr. Manish Kumar Heda - CFO from 27/02/2025 to 02/03/2025.As of date, no assessment order has been received by the Company in relation to the search.The Company has not received any written communication from the Income Tax Department to date regarding any violations or contraventions committed or alleged to have been committed As of date, no financial demand has been raised by the Income Tax Department. The Company is in the process of making necessary representations before the authorities for the release of the seized cash, considering that it is duly recorded in the books of accounts.
5 State Tax Officer Ghatak 49 (Nadiad):Range - 13:Division - 6:Gujarat 25-Aug-2024 Demand Order has been Issued for Differential tax liability on B2B Outward supply as per Outward Supply E-way bill data and GSTR-01 and claiming ITC in excess of what's showing in GSTR2A for FY 2019-20 under section 73. The current status of the dispute remains the same and the Company has filed an Appeal with Appellate Authority on 08-10-2024
6 Assistant Commissioner Jurisdiction: Ghatak 49 (Nadiad) , Range - 13 , Division - 6 , Gujarat 25-Oct-2024 Notice issued under Sec.74 for caliming Ineligible ITC from cancelled taxpayers, nongenuine and non-existent Taxpayers and return/ tax defaulters for FY 2020-21 (Ref No:ZD241024063299G) The current status of the dispute remains the same as the Company has filed reply against the same diagreeing with such demand.
7 State Tax Officer Ghatak 49 (Nadiad):Range - 13:Division - 6:Gujarat 15-Jan-2025 Demand Order has been passed for caliming Ineligible ITC from cancelled taxpayers, nongenuine and non-existent Taxpayers and return/ tax defaulters under section 74 in FY 2019-20 The current status of the dispute remains the same and the Company has filed an Appeal with Appellate Authority on 19-03-2025
8 Assistant Commissioner Ghatak 49 (Nadiad):Range -13:Division - 6:Gujarat 28-Feb-2025 The demand order has been passed for Financial Year 2020–21. The demand relates to excess Input Tax Credit (ITC) claimed in GSTR-3B as compared to that reflected in GSTR-2A. GST (Tax): Rs.0.16 lakhs Interest: Rs. 0.12 lakhs Penalty: Rs. 0.20 lakhs Total Demand: Rs.0.48 lakhs The Company has reviewed the demand and agreed to accept the same. The Comapany is agreed to pay Demand Order