SPACE INCUBATRICS TECHNOLOGIES LIMITED
Regd. Office: Pawan Puri, Muradnagar, Ghaziabad-201206 (U.P.)
CIN: L17100UP2016PLC084473
E-mail- spaceincubatrics@gmail.com, Web: www.spaceincubatrics.com, Phone: 01232- 261288
Date: 30.05.2025
To,
Dy. General Manager (Listing)
Department of Corporate Services
BSE Limited
PhirozeJeejeebhoy Towers,
Dalal Street, Mumbai-400 001
Scrip Code: 541890
Scrip ID: SPACEINCUBA
Sub: Annual Secretarial Compliance Report under Regulation 24A of Securities and Exchange
Board of India (Listing Obligations and Disclosures Requirements) Regulations, 2015.
Dear Sir,
Please find enclosed herewith Secretarial Compliance Report under Regulation 24A of SEBI (Listing
Obligations and Disclosure Requirements) Regulation, 2015 issued by Mrs. Sonia Rani, Practicing
Company Secretary, for the F.Y. ended 31/03/2025.
Please take the same on record.
Thanking You,
Sincerely yours,
For SPACE INCUBATRICS TECHNOLOGIES LIMITED
(Khushbu Singhal)
Company Secretary & Compliance Officer
Membership No- A25992
Encl: as above
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SONIA RANI & ASSOCIATES
COMPANY SECRETARIES
Peer Review No.: 3514/2023
Office Address: C – 39, Ground Floor, Gali No. 2, Ganga Vihar, Near Gokal Puri, Delhi – 110094
Mobile: 09971543044, Email Id: soniaranics@gmail.com
SECRETARIAL COMPLIANCE REPORT OF SPACE INCUBATRICS TECHNOLOGIES
LIMITED
FOR THE FINANCIAL YEAR ENDED 31ST MARCH, 2025
We have conducted the review of the compliance of the applicable statutory provisions and the
adherence to good corporate practices by Space Incubatrics Technologies Limited (hereinafter
referred as 'the listed entity'), having its Registered Office at Pawan Puri, Muradnagar,
Ghaziabad-201206 (U.P.). Secretarial Review was conducted in a manner that provided us a
reasonable basis for evaluating the corporate conducts/statutory compliances and expressing our
opinion thereon.
Based on our verification of the listed entity's books, papers, minutes books, forms and returns filed
and other records maintained by the listed entity and also the information provided by the listed
entity, its officers, agents and authorized representatives during the conduct of Secretarial Review,
we hereby report that in our opinion, the listed entity has, during the review period covering the
financial year ended on 31st March, 2025, complied with the statutory provisions listed hereunder
and also that the listed entity has proper Board processes and compliance mechanism in place to the
extent, in the manner and subject to the reporting made hereinafter:
We, Sonia Rani & Associated have examined:
(a) all the documents and records made available to us and explanation provided by Space
Incubatrics Technologies 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;
(c) Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers)
Regulations, 2011;
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SONIA RANI & ASSOCIATES
COMPANY SECRETARIES
Peer Review No.: 3514/2023
Office Address: C – 39, Ground Floor, Gali No. 2, Ganga Vihar, Near Gokal Puri, Delhi – 110094
Mobile: 09971543044, Email Id: soniaranics@gmail.com
(d) Securities and Exchange Board of India (Buyback of Securities) Regulations, 2018; (Not
Applicable during the Year)
(e) Securities and Exchange Board of India (Share Based Employee Benefits and Sweat Equity)
Regulations, 2021; (Not Applicable during the Year)
(f) Securities and Exchange Board of India (Issue and Listing of Debt Securities) Regulations,
2008; ;(Not Applicable during the Year)
(g) Securities and Exchange Board of India (Issue and Listing of Non-Convertible Securities)
Regulations, 2021; ;(Not Applicable during the Year)
(h) Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015
and circulars/ guidelines issued thereunder.
(i) The Securities and Exchange Board of India (Registrars to an Issue and Share Transfer
Agents) Regulations, 1993, regarding the Companies Act and dealing with client;
(j) The Securities and Exchange Board of India (Delisting of Equity Shares) Regulations, 2009;
Not Applicable for the period
(k) The Securities and Exchange Board of India (Depositories and Participants) Regulations,
2018;
I further report that –
• The Company has complied with the requirements of Structural Digital Data Base in terms of
Securities & Exchange Board of India (Prohibition of Insider Trading) Regulation, 2015 including
various Circulars issued by SEBI thereunder and Circular(s) issued by BSE Limited dated March 16,
2023.
• There was no event of appointment/ re-appointment/ resignation of Statutory Auditors of the Listed
Entity during the review period and the Listed Entity has not modified the terms of appointment of
its existing Auditor. In this regard, I report that the Listed Entity has complied with Circular No.
CIR/CFD/CMD1/114/2019 dated October 18, 2019.
Further to the matter and as advised in the BSE Notice No. 20230329-21 dated 29th March 2023 as
well as BSE Notice No. 20230410-41 dated 10th April 2023, following are the additional
information which is the parts of ongoing Annual Secretarial Audit Report –
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), as
notified by the Central Government under section
118(10) of the Companies Act, 2013 and mandatorily
applicable.
YES
NOT ANY
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SONIA RANI & ASSOCIATES
COMPANY SECRETARIES
Peer Review No.: 3514/2023
Office Address: C – 39, Ground Floor, Gali No. 2, Ganga Vihar, Near Gokal Puri, Delhi – 110094
Mobile: 09971543044, Email Id: soniaranics@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
NOT ANY
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, but not
updated
YES, but not
updated
YES, but not
updated
NOT ANY
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
NOT ANY
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
YES
NOT ANY
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
Regulations, 2015.
YES
NOT ANY
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
NOT ANY
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SONIA RANI & ASSOCIATES
COMPANY SECRETARIES
Peer Review No.: 3514/2023
Office Address: C – 39, Ground Floor, Gali No. 2, Ganga Vihar, Near Gokal Puri, Delhi – 110094
Mobile: 09971543044, Email Id: soniaranics@gmail.com
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
YES
NOT ANY
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
NOT ANY
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
NOT ANY
11.
12
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 except as provided under
separate paragraph herein (**).
Additional Non-compliances, if any:
No additional non-compliance observed for any SEBI
regulation/circular/guidance note etc.
YES
YES
NOT ANY
*Observations /Remarks by PCS are mandatory if the Compliance status is provided as 'No' or 'NA'.
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SONIA RANI & ASSOCIATES
COMPANY SECRETARIES
Peer Review No.: 3514/2023
Office Address: C – 39, Ground Floor, Gali No. 2, Ganga Vihar, Near Gokal Puri, Delhi – 110094
Mobile: 09971543044, Email Id: soniaranics@gmail.com
Compliances related to resignation of statutory auditors from listed entities and their material
subsidiaries as per SEBI Circular CIR/CFD/CMD1/114/2019 dated 18th October, 2019:
Sr.
No.
Particulars Compliance
Status (Yes/No/
NA)
Observations
/Remarks by
PCS*
1. Compliances with the following conditions while appointing/re-appointing an auditor
i. If the auditor has resigned within 45 days from
the end of a quarter of a financial year, the auditor
before such resignation, has issued the limited
review/ audit report for such quarter; or
ii. If the auditor has resigned after 45 days from the
end of a quarter of a financial year, the auditor
before such resignation, has issued the limited
review/ audit report for such quarter as well as
the next quarter; or
iii. If the auditor has signed the limited review/ audit
report for the first three quarters of a financial
year, the auditor before such resignation, has
issued the limited review/ audit report for the last
quarter of such financial year as well as the audit
report for such financial year.
NA
NA
NA
No such
Instance
No such
Instance
No such
instance
2. Other conditions relating to resignation of statutory auditor
i) Reporting of concerns by Auditor with respect to the
listed entity/its material subsidiary to the Audit
Committee:
a In case of any concern with the management of the
listed entity/material subsidiary such as non-
availability of information / non-cooperation by the
management which has hampered the audit
process, the auditor has approached the Chairman
of the Audit Committee of the listed entity and the
Audit Committee shall receive such concern
directly and immediately without specifically
waiting for the quarterly Audit Committee meetings.
b. In case the auditor proposes to resign, all concerns
with respect to the proposed resignation, along with
relevant documents has been brought to the notice
of the Audit Committee. In cases where the
proposed resignation is due to non-receipt of
information / explanation from the company, the
auditor has informed the Audit Committee the
details of information/ explanation sought and not
provided by the management, as applicable.
c. The Audit Committee / Board of Directors, as the
case may be, deliberated on the matter on receipt of
such information from the auditor relating to the
proposal to resign as mentioned above and
communicate its views to the management and the
auditor.
ii) Disclaimer in case of non-receipt of information:
The auditor has provided an appropriate disclaimer
NA
NA
NA
No such
Instance
No such
Instance
No such
Instance
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SONIA RANI & ASSOCIATES
COMPANY SECRETARIES
Peer Review No.: 3514/2023
Office Address: C – 39, Ground Floor, Gali No. 2, Ganga Vihar, Near Gokal Puri, Delhi – 110094
Mobile: 09971543044, Email Id: soniaranics@gmail.com
in its audit report, which is in accordance with the
Standards of Auditing as specified by ICAI / NFRA,
in case where the listed entity/ its material subsidiary
has not provided information as required by the
auditor.
NA
No such
instance
3. The listed entity / its material subsidiary has obtained
information from the Auditor upon resignation, in the
format as specified in Annexure- A in SEBI Circular CIR/
CFD/CMD1/114/2019 dated 18th October, 2019.
NA
No such
instance
(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/
Circul
ar No.
Deviation
s
Action
Taken
by
Type of
Action
Details
of
Violatio
n
Fine
Amoun
t
Obser-
vations/
Remarks
of the
Practicing
Company
Secretary
Man-
age-
ment
Re-
sponse
Re-
mark
s
Nil
(b) 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/
Circula
r No.
Deviati
ons
Action
Taken
by
Type of
Action
Details of
Violation
Fine
Amou
nt
Obser-
vations/
Remarks of
the
Practicing
Company
Secretary
Man-
age-
ment
Re-
sponse
R
e-
ma
rks
Nil
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SONIA RANI & ASSOCIATES
COMPANY SECRETARIES
Peer Review No.: 3514/2023
Office Address: C – 39, Ground Floor, Gali No. 2, Ganga Vihar, Near Gokal Puri, Delhi – 110094
Mobile: 09971543044, Email Id: soniaranics@gmail.com
(c) 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)
Reg
u-
latio
n/
Circ
ular
No.
Deviations Action
Taken
by
Type of
Action
Details of
Violation
Fine
Amount
Obser-
vations/
Remarks
of the
Practicing
Company
Secretary
Man-
age-
ment
Re-
sponse
Re-
mark
s
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.
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 SONIA RANI& ASSOCIATES
Company Secretaries
SONIA RANI
Company Secretaries
Mem No.: A36984
C.P. No. 20372 Date: 28.05.2025
Peer Review No.:3514/2023 Place: New Delhi
UDIN: A036984G000478359
Sonia RaniDigitally signed by Sonia Rani
Date: 2025.05.30
13:34:58 +05'30'
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