Sharp Investments Ltd — Updates, 27-05-2025: Company Update

SHARP INVESTMENTS LIMITED

Regd. Office: 14, N.S. Road, 2™ Floor, Kolkata - 700001

CIN: L65993WBI1977PLC031241

Phone: 033-40055190

Email: smn1098@rediffmail.com, Website: www sharpinve: tsitd.c

Dated: May 26, 2025

To, To,

BSE Limited The Company Secretary & Listing

| Phiroze Jeejeebhoy Towers Department,

Dalal Street The Calcutta Stock Exchange Limited,

Mumbai - 400001 7, Lyons Range,

| Scrip code:538212 Kolkata - 700001

[ Scrip code:29293

Dear Sir,

Sub: Submission of Annual Secretarial Compliance Report for the F.Y, 2024-25

Pursuant to Regulation 24A of SEBI (Listing Obligations and Disclosure

Requirements) Regulations, 2015, please find enclosed the Annual Secretarial

Compliance Report for the year ended on 31st March, 2025 issued by Puja Pujari &

Associates, Practicing Company Secretaries.

This is for your information and records.

Thanking you

Yours faithfully,

For Sharp Investments Ltd

Sharp Investments

=N

“Wanaging Director

Sagar Mal Nahata

(Managing Director)

DIN: 00307611

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PUJA PUJARI

SR

ASSOCIATES

A

Rishra, BLAD, Iné Fisor, Riwhes. WS.71120)

SECRETARIAL COMPLIANCE REPORT OF SHARP INVESTMENTS

LIMITED FOR THE YEAR ENDED 31%" MARCH, 2025

I. Puja Pujari, Proprietor of Puja Pujari & Associates Practicing Company Secretary have

examined:

(a) all the documents and records made available to us and explanation provided by

Sharp Investments Limited (‘the listed entity") having CIN:

L65993WB1977PLC031241 and registered office at 14, N.S. Road, 2™ fioor,

Kolkata - 700001,

(b) the filings/ submissions made by the listed entity to the stock exchanges,

(c) website of the listed entity,

(d) any other document/ filing, as may be relevant, which has been relied upon to make

this certification,

for fl.m' year ended 31% March, 2025 ("Review Period”) in respect of compliance with the

provisions of:

(a) the Securities and Exchange Board of India Act, 1992 (“SEBI Act’) and the

Regulations, circulars, guidelines issued thereunder; and

(b) the Securities Contracts (Regulation) Act, 1956 (*SCRA"), rules made thereunder

and the Regulations, circulars, guidelines issued thereunder by the Securities and

Exchange Board of India (“SEBI");

The specific Regulations, whose provisions and the circulars/ guidelines issued thereunder,

have been examined, include:-

(a) Securiies and Exchange Board of India (Listing Obligations and Disclosure

Requirements) Regulations, 2015;

(b) Securities and Exchange Board of India (Issue of Capital and Disclosure

Requirements) Regulations, 2018;

(¢) Securities and Exchange Board of India (Substantial Acquisition of Shares and

Takeovers) Regulations, 2011;

(d) Securities and Exchange Board of India (Buyback of Securities) Regulations, 2018

~ Not applicable during the period undr review

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BS\EUJA PUJARI She

(e) Securities and Exchange Board of India (Share Based Employee Benefits) Regulations.

2014 - Not applicable during the period under review

(f) Securities and Exchange Board of India (Issue and Listing of Debt Securities) Regulations,

2008 - Not applicable during the period under review

(9) Securities and Exchange Board of India (Issue and Listing of Non-Convertible and

Redeemable Preference Shares) Regulations, 2013 — Not applicable during the period

under review

(h) Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015,

(i) Securities and Exchange Board of India (Depositories and Participant) Regulations, 2018;

and Circulars/Guidelines issued thereunder;

and based on the above examination, | hereby report that, during the Review period:

| hereby report that, during the Review Period:

a) The listed entity has complied with the provisions of the above Regulations and Circulars/

Guidelines issued thereunder, except in respect of matters specified below -

|'sr. | Compliance

| No. | Requirement

(Regulations/

circulars/

guidelines

including

| specific | |ctause)

NIL

b) The listed entity has taken the following actions to comply with the observations made in

previous reports:

Page | 2

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“S‘PUJA PUJARI Rl

&

I ; ol Rishrs, BL-AD. Ind Floor Rishes, WB-71220)

st. | Compliance | Regul | D Fine :::/«m nag

[ ik | Remarks | Respo | (Regulations! | Circul e o

| circulars! ar o

| guidelines | No.

‘ 3 9 including R

[C"!‘_"_)_ Secretary

NIL

c) the compliance status of the listed entity is appended as below:

Sr. [ Particulars Compliance | Observations/

No Status

Remarks of the |

(Yes/No/NA) | PCS*

Secretarial Standards:

[ | The compliances of the listed entity are

in Yes ‘ | | accordance with the applicable

Secretarial

;Slandards (SS) issued by the Institute of

| Company Secretaries India (ICS1), as notified

| [by the Central Government under section

118(10) of the Companies Act, 2013 and

| mandatorily applicable.

)>2 Adoption _and timely updation of the

: =t Policies:

|« Al applicable policies under SEBI Yes

| Regulations are adopted with the

| approval of board of directors of the

listed entities

* Al the policies are in conformity with Yes

SEBI Regulations and have been

reviewed & updated on time, as per

| the regulations/circularsiguidelines |

issued by SEBI

Page | 3

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AT B LT e sy RS VRSt

V “S\PUJA PUJARI

9 TIO0TSH4A0Y

PRottion@gman Lom

Rishes, BLAS. Ind Flonr. Riahrs. WH.71220)

3 " Maintenance and di: ures on Website:

* The Listed entity is maintaining a

functional website

+ Timely dissemination of the

documents/ information under a

separate section on the website

* Web-links provided in annual

corporate governance reports under

Regulation 27(2) are accurate and

specific which redirects to the relevant |

document(s)/section of the website

Yes

Yes

Yes

4

5

| Disqualification of Director:

None of the Director(s) of the Company is/are

disqualified under Section 164 of Companies

Act, 2013 as confirmed by the listed entity.

| Details_related to Subsidiaries of listed

i entities have been examined w.r.t.:

’ a) Identification of material subsidiary

companies

b) Disclosure requirement of material as

| well as other subsidiaries

(

Yes

N.A.

Yes

TPmservatlon of Documents:

| The listed entity is preserving and

| maintaining records as prescribed under

| SEBI Regulations and disposal of records as

| per Policy of Preservation of Documents and

Archival policy prescribed under SEBI LODR

Regulations, 2015.

Yes

Performance Eval :

The listed entity has conducted performance

evaluation of the Board, Independent

| Directors and the Committees at the start of

Yes

| During the period

under review

Company does not

have any material

:sgbfldlary\

Page | 4

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“S’ PUJA PUJARI

91 7980285409

P corpaohation@gmail corm

Rishen, BUAS, 20d Finor Mishes, W-11220)

every financial year/during the finandial'year

as prescribed in SEBI Regulations.

a) The listed entity has obtained prior

approval of Audit Committee for all

related party transactions; or

b) The listed entity has provided detailed

reasons along with confirmation

whether the transactions were

subsequently approved / ratified /

rejected by the Audit Committee, in

case no prior approval has been

obtained.

Yes Prior approval

taken for all related

party transactions

NA.

9 [ Disclosure of events or information:

The listed entity has provided all the required

disclosure(s) under Regulation 30 along with

Schedule Il of SEBI LODR Regulations,

2015 within the time [imits prescribed

thereunder.

| 10| Prohibition of Insider Trading:

| The listed entity is in compliance with

| Regulation 3(5) & 3(6) SEBI (Prohibition of

| Insider Trading) Regulations, 2015.

|11 [Actions _ta |_or Stock

| Exchange(s), if any:

No action(s) has been taken against the

listed entity / its promoters / directors /

subsidiaries either by SEBI or by Stock

Exchanges (including under the Standard

| Operating Procedures issued by SEBI

| through various circulars) under SEBI

| Regulations and circulars / guidelines issued

thereunder except as provided under

| separate paragraph herein (**).

No | As informed by the

Management, no

Actions were taken |

against the |

Companylits

promoters/directors

Isubsidiaries either |

by SEBI or by BSE

under SEBI |

Regulations and

Page | 5

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/

/ “S@UJA PUJARI

A s e

91 TIR0IS8409

Pes corprolution@grnel com

Rishra. BLAS 704 Floor Righes WH-11270)

u____

circulars/guidelines

issued there under

[durlng the period

| under review

12 Resignation of statutory audi 2

i T al

In case of resignation of statutory auditor Yes M/s Beriwal &

from the listed entity or any of its material

subsidiaries during the financial year, the

listed entty and / or its material

subsidiary(ies) has / have complied with

| paragraph 6.1 and 6.2 of section V-D of

chapter V of the Master Circular on

compliance with the provisions of the LODR

Regulations by listed entities,

| Associates (FRN:

| 327762E) were

| appointed as

statutory auditors

| during the year.

|

13 Additional Non-compliances, if any:

No additional non-compliance observed for

any SEBI regulation/circulariguidance note

etc

No non - | No additional non -

compliances ‘ compliances were |

observed observed during |

the period under | review.

“Observations /Remarks by PCS are mandatory if the Compliance status is provided as ‘No' or 'NA'

Assumption and limitation of scope and review:

1. Compliance of the applicable laws and ensuring the authenticity of documents and

information furnished, are the responsibilities of the management of the listed entity

2. Our responsibility is to report based upon our examination of relevant documents and

information. This is neither an audit nor an expression of opinion.

3. We have not verified the correctness and appropriateness of financial records and books of

account of the listed entity.

Page | 6

NW

e

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I e —

fls PUJA PUJARI =

Mishin, BL-AS. Ind Fioar. Rishes, WB.71220)

‘u—

4. This report is solely for the intended purpose of compliance in terms of Regulation

24A (2) of the SEBI (LODR) Regulations, 2015 and is neither an assurance as to the

future viability of the fisted entity nor of the efficacy or effectiveness with which the

management has conducted the affairs of the listed entity.

Date: May 28, 2025

Place: Kolkata Puja Pujari & Associates

Puja Pujari

(Proprietor)

M. No. F13102

COP No. 20171

Peer Review Cert. No. 3636/2023

UDIN: F013102G000430442

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