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 ----------------Page (0) Break---------------- 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 ----------------Page (1) Break---------------- 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 ----------------Page (2) Break---------------- “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 ----------------Page (3) Break---------------- 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 ----------------Page (4) Break---------------- “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 ----------------Page (5) Break---------------- / / “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 ----------------Page (6) Break---------------- 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 ----------------Page (7) Break----------------
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