EL CID Investments Ltd — Updates, 30-05-2025: Company Update

ELCID INVESTMENTS LIMITED

CIN: L65990MH1981PLC025770

Registered office: 414 Shah Nahar (Worli) Industrial Estate ‘B’ Wing Dr E Moses Rd

Worli Mumbai - 400018

Tel: 022-66625602 Fax: 022-66625605

E-mail: vakilgroup@gmail.com website: www.elcidinvestments.com

May 30, 2025

To,

Dept. of Corporate Services,

BSE Limited,

Phiroze Jeejeebhoy Towers,

Dalal Street, Mumbai – 400 001

Scrip Code: 503681

Dear Sir,

Sub: Annual Secretarial Compliance Report for the financial year ended March 31, 2025

Pursuant to Regulation 24A of the SEBI (Listing Obligation and Disclosure Requirements)

Regulation, 2015, read with the recent circular(s) issued by the SEBI/Stock Exchanges from time

to time, , please find enclosed the Annual Secretarial Compliance Report furnished by M/s

Ruchi Kotak & Associates, Practicing Company Secretaries (C.P.10484), for the financial year

ended March 31, 2025.

You are requested to take the same on your record.

Thanking You,

Yours Faithfully,

For Elcid Investments Limited,

_________________

Ayush Dolani

Company Secretary & Compliance Officer

Encl.: as above

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RUCHI KOTAK & ASSOCIATES

Company Secretaries

Off: 405 Thacker Tower, Plot No 86

Sector 17, Vashi, Navi Mumbai– 400 703, Maharashtra

email: ruchikotak@gmail.com

Secretarial Compliance Report of Elcid Investments Limited for the financial year ended 31st March 2025

We M/s. Ruchi Kotak & Associates, Practicing Company Secretaries, have examined:

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

Limited (“the listed entity”),

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

(c) website of the listed entity,

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

for the year ended 31st March 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) Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations,

2015;

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

2018;(Not applicable during the review period)

(c) Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations,

2011;

(d) Securities and Exchange Board of India (Buyback of Securities) Regulations, 2018; (Not Applicable

during the review period)

(e) Securities and Exchange Board of India (Share Based Employee Benefits and Sweat Equity) Regulations,

2021; ; (Not Applicable during the review period)

(f) Securities and Exchange Board of India (Issue and Listing of Debt Securities) Regulations, 2008; ; (Not

Applicable during the review period)

(g) Securities and Exchange Board of India (Issue and Listing of Non-Convertible Securities) Regulations,

2021; ; (Not Applicable during the review period)

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

(i) The Securities and Exchange Board of India (Depository & Participants) Regulations, 2018

and circulars/ guidelines issued thereunder and based on above examination hereby report that during the review

period:

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RUCHI KOTAK & ASSOCIATES

Company Secretaries

Off: 405 Thacker Tower, Plot No 86

Sector 17, Vashi, Navi Mumbai– 400 703, Maharashtra

email: ruchikotak@gmail.com

(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.

No.

Com-

pliance

Require-

ment

(Regu-

lations/

circulars/

guide- lines

including

specific

clause)

Regu-

lation/

Circular

No.

Deviation

s

Action

Taken by

Type of

Action

Details of Vio-

lation

Fine

Amount

Obser-

vations/

Re- marks

of the

Prac-

ticing

Compa- ny

Sec- retary

Man- age-

ment Re-

sponse

Re-

mark

s

1 Regulation

33 of SEBI

(LODR)

Regulations

2015 for the

period

ended June

30,2024

Regulatio

n 33 of

SEBI

(LODR)

Regulatio

ns, 2015

Consolid

ated

Results -

Limited

Review

not

submitte

d for

Consolid

ated

Financial

Result

(Auditor

Report

Submitte

d instead

of

Limited

Review

Report)

for

Quarter

Ended -

June

2024

- - - - Consolidated

Results -

Limited Review

not submitted

for

Consolidated

Financial Result

(Auditor Report

Submitted

instead of

Limited Review

Report) for

Quarter Ended -

June 2024

Nil Consolidat

ed Limited

Review

Report

from the

auditors

was missed

out and

partial

submission

was made

to Bombay

Stock

Exchange

Company

resubmitt

ed the

corrected

Standalon

e &

Consolida

ted

Financial

results

with

limited

review

report of

the

auditor

which was

missed out

inadverte

ntly on

29th

August

2024.

- -

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RUCHI KOTAK & ASSOCIATES

Company Secretaries

Off: 405 Thacker Tower, Plot No 86

Sector 17, Vashi, Navi Mumbai– 400 703, Maharashtra

email: ruchikotak@gmail.com

2 Regulation

23 (9)

Non-

compliance

with

disclosure

of related

party

transacti

ons on

consolidate

d basis.

Regulatio

n 23 (9) of

SEBI

(LODR)

Regulatio

ns, 2015

Late

submissio

n by one

day of

XBRL

report on

related

party

transactio

ns for half

year

ended

30.09.202

4

Bombay

Stock

Exchange

Fine Levied Late submission

by one day of

XBRL report on

related party

transactions for

half year ended

30.09.2024

Rs.

5,900/-

- - Company

paid the

levied fine

of Rs.

5900/- on

17.12.2024

-

The listed entity has taken the following actions to comply with the observations made in previous reports:

Sr.

No.

Com-

pliance

Require-

ment

(Regu-

lations/

circulars/

guide- lines

including

specific

clause)

Regu-

lation/

Circular

No.

Deviations Action

Taken

by

Type of

Action

Details of

Viola- tion

Fine

Amount

Ob-

serva-

tions/

Re-

marks

of the

Prac-

ticing

Com-

pany

Secre-

tary

Man-

age-

ment Re-

sponse

Re-

marks

NIL

We hereby report that, during the Review Period the compliance status of the listed entity is appended as

below:

Sr. No. Particulars Compliance

Status(Yes/

No/NA)

Observations/

Remarks by

PCS*

1. Secretarial Standards:

The compliances of the listed entity are in accordance

with the applicable Secretarial Standards (SS) issued

by the Institute of Company Secretaries India (ICSI)

Yes

Nil

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RUCHI KOTAK & ASSOCIATES

Company Secretaries

Off: 405 Thacker Tower, Plot No 86

Sector 17, Vashi, Navi Mumbai– 400 703, Maharashtra

email: ruchikotak@gmail.com

2. Adoption and timely updation of the Policies:

⚫ All applicable policies under SEBI Regulations are

adopted with the approval of board of directors of

the listed entities.

⚫ All the policies are in conformity with SEBI

Regulations and have been reviewed & updated on

time, as per the regulations/circulars/guidelines

issued by SEBI

Yes

Yes

Nil

Nil

3. Maintenance and disclosures 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 re- directs to the

relevant document(s)/section of the website

Yes

Yes

Yes

Nil

Nil

Nil

4. 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.

Yes

Nil

5. Details related to Subsidiaries of listed entities have

been examined w.r.t.:

(a) Identification of material subsidiary companies

(b) Disclosure requirement of material as well as

other subsidiaries

Yes

Nil

6. Preservation 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

Yes

Nil

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RUCHI KOTAK & ASSOCIATES

Company Secretaries

Off: 405 Thacker Tower, Plot No 86

Sector 17, Vashi, Navi Mumbai– 400 703, Maharashtra

email: ruchikotak@gmail.com

Regulations, 2015.

7. Performance Evaluation:

The listed entity has conducted performance evaluation

of the Board, Independent Directors and the Committees

at the start of every financial year/during the financial

year as prescribed in SEBI Regulations.

Yes

Nil

8. Related Party Transactions:

(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

NA

Prior approval of

Audit Committee was

obtained.

9. Disclosure of events or information:

The listed entity has provided all the required disclosure(s)

under Regulation 30 along with Schedule III of SEBI

LODR Regulations, 2015 within the time limits prescribed

thereunder.

Yes

Nil

10. Prohibition of Insider Trading:

The listed entity is in compliance with Regulation 3(5) &

3(6) SEBI (Prohibition of Insider Trading) Regulations,

2015.

Yes

Nil

11. Actions taken by SEBI 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.

No

1. Settlement Order

dated June 24, 2024

was passed by SEBI on

Company for alleged

violation of

Regulation 31 (1)(b)

of SEBI LODR 2015

read with SEBI

Circular ref no

CIR/CFD/CMD/13/2

015 dated 30

November 2015 read

with regulation

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RUCHI KOTAK & ASSOCIATES

Company Secretaries

Off: 405 Thacker Tower, Plot No 86

Sector 17, Vashi, Navi Mumbai– 400 703, Maharashtra

email: ruchikotak@gmail.com

2(1)(pp) of ICDR

Regulations and also

Regulation 3(5) read

with Regulation 3(6)

of SEBI (Prevention

of Insider Trading)

Regulations.

Settlement amount of

Rs. 17,31,510/- was

levied on the company.

2. Settlement Order

dated May 21, 2024, in

respect to the

Settlement application

filed by the Directors

themselves for alleged

violation of

Regulation 10(4)(c) of

Delisting Regulations

2021, Regulation

25(5) of SEBI

(LODR) Regulations,

2015, Regulation 4

(1)(g) of SEBI

(LODR), Regulations,

2015 r/w Section

166(2) and (3) of

Companies Act, 2013,

Regulation

4(2)(f)(iii)(3) and (6)

of SEBI (LODR)

Regulations, 2015.

Settlement amount of

Rs. 8,12,500/- was

levied each upon Mr.

Varun Vakil & Ms.

Amrita Vakil (being

present directors and 4

previous Directors of

the Company.)

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RUCHI KOTAK & ASSOCIATES

Company Secretaries

Off: 405 Thacker Tower, Plot No 86

Sector 17, Vashi, Navi Mumbai– 400 703, Maharashtra

email: ruchikotak@gmail.com

12. Resignation of statutory auditors from the listed entity or

its material subsidiaries: In case of resignation of

statutory auditor from the listed entity or any of its

material subsidiaries during the financial year, the listed

entity 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.

NA

No case of

resignation of

Statutory auditor from

the listed entity or its

material subsidiaries

during the review

period.

13. Additional non-compliances, if any:

No additional non-compliance observed for any SEBI

regulation/circular/guidance note etc.

NA

As on 31st March 2025

Board constitutes of 4

Directors. Company

falls in the list of top

2000 Companies as on

31.12.2024

We further, report that the listed entity is in compliance / not in compliance with the disclosure requirements of

Employee Benefit Scheme Documents in terms of regulation 46(2) (za) of the LODR Regulations. – Not

Applicable.

Assumptions & 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 certify 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 Accounts of

the listed entity.

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RUCHI KOTAK & ASSOCIATES

Company Secretaries

Off: 405 Thacker Tower, Plot No 86

Sector 17, Vashi, Navi Mumbai– 400 703, Maharashtra

email: ruchikotak@gmail.com

4. This Report is solely for the intended purpose of compliance in terms of Regulation 24A (2) of the SEBI

(Listing Obligations and Disclosure Requirements) Regulations, 2015 and is neither an assurance as to

the future viability of the listed entity nor of the efficacy or effectiveness with which the management has

conducted the affairs of the listed entity.

For Ruchi Kotak & Associates

(Ruchi Kotak)

Proprietor

FCS 9155 CP No. 10484

PR No. – 1666/2022

UDIN: F009155G000454600

Place: Navi Mumbai

Date: 28th May 2025

RUCHI RITESH

KOTAK

Digitally signed by

RUCHI RITESH KOTAK

Date: 2025.05.28

12:57:48 +05'30'

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