Jain Resource Recycling Ltd

1. Position of Chairperson and Managing Director is held by the same person.Further, Mr. Kamlesh Jain, being a Promoter of the Company, is categorised as Chairperson related to Promoter in the XBRL filing. 2. Mr. Mayank Pareek is the Joint Managing Director. hence, categorized as MD

The applicability of Risk Management Committee became applicable from December 31, 2025 based on the Market Capitalisation categorised by the NSE. And the Company constituted the committee on 09-02-2026.

During the quarter ended December 31, 2025, Jain Resource Recycling Limited held 94.55% of the share capital of Jain CY Circular Solutions Private Limited (CIN: U38300TN2025PTC186805), an unlisted private limited company. Subsequent to the quarter, the said unlisted company completed a private placement of 49,94,500 equity shares of face value Rs. 10/- each at par, aggregating to Rs. 4,99,45,000/-, pursuant to a Special Resolution dated 24/12/2025 and Board Resolution dated 14/01/2026. As a result of this fresh allotment to C&Y Group Investments Inc., USA, Jain Resource Recycling Limited and Mr. Atul Pareek, the holding of Jain Resource Recycling Limited in Jain CY Circular Solutions Private Limited stood reduced from 94.55% to 52.00%. The reduction of 42.55% is solely on account of dilution arising from the said fresh issue and does not involve any outright sale or transfer of shares by the Jain Resource Recycling Limited.

It has been alleged by the department that Jain Metal Rolling Mills has availed CENVAT credit based on invoices during the month of June 2012 from Moral Alloys Private Limited although goods have not been actually received. Further to the personal hearing of the assessee, the Asst. Commissioner of GST & Central Excise has issued an order dated June 6, 2018 levying penalty of Rs. 37,96,211, being the excise duty on these invoice for which CENVAT credit has been availed by the assessee. The assessee has made an appeal against the same before Commissioner (Appeals) Central Excise during September 2018 and the matter is pending before Commissioner (Appeals). The assessee has made a pre-deposit of 7.50% of the demand for the purpose of filing the appeal.

Notice received from Additional Commissioner of Customs dated August 6, 2024 informing that the Lead Scrap Radio imported by Jain Resource Recycling Private Limited from M/s. Vector Freight Forwarders is to be categorised as ammunition and required license to import. In view of this, the goods valued at Rs. 28.64 lakhs was confiscated and a penalty of Rs. 290,000 has been imposed

Notice received from Additional Commissioner of Customs dated October 10, 2024 informing that Lead Scrap Rails imported by Jain Resource Recycling Private Limited are liable to be confiscated as the importer has not produced mandatory Pre-Shipment Inspection Certificate. In view of this, the goods valued at Rs. 62.42 lakhs has been confiscated with an option to the importer to redeem the good after payment of a fine of Rs. 10,000. Also, a penalty of Rs. 25000 has been levied

1. Department has sent a communication dated October 1, 2024 intimating discrepancies in the GST Return filed by the Company on the following: a) Excess input credit claimed when compared between GSTR 3B and GSTR 2A - Rs. 8,28,083 b) Interest for late payment of tax under GSTR 3B - Rs. 2,147 c) Interest on late payment of RCM - Rs. 16,163 d) late fee for delay in filing GSTR 3B and GSTR 1 - Rs. 3,350 2. Notice received from the GST department dated October 4, 2024 intimating discrepancies in the GST return in respect of difference in ITC availed in respect of Import of goods show in GSTR 3B and GSTR 2A to the tune of Rs. 1,93,23,399 Consequently, combined order dated 27-02-25 for the 2 cases was passed amounting to Rs.2,32,48,558/- as the demand (inclusive of interest).

9. CBIC 13 27-06-2025 Audit for the period April 2020 to March 2023 was conducted by the GST department. The department has issued the audit report with the following observations: a) short payment of GST when compared between GSTR 1 and GSTR 3B - Rs. 61,501 b) non-payment of interest for delayed payment - Rs. 104,537 c) non-reversal of ITC in GSTR 3B - Rs. 86,96,656 d) non-payment of GST under RCM - Rs. 4,708 e) non-reversal of ITC as supplier not filed GSTR 3B - Rs. 2506 A new order was issued on 28 February 2025 with below remarks, 1)Dropped liability of c point mentioned above to 34,21,080 2)Ordered for recovery of 68,715(as mentioned in points a,d,e above) 3)Ordered for recovery of 53,263 as interest and 3,48,978 as penalty

Show Cause Notice bearing no. 49/2026 (DC) issued by the department with respect to the GST Audit carried for the financial years 2021-22 to 2023-24. The amount of demand is Rs.1,78,93,661. Further, the matter is pending.

An Order u/s. 143(3) read with section 144B of the Income tax Act has been passed on March 2025 resulting in a demand of Rs. 2,58,49,640/- along with an Interest of Rs.31,01,952/-. A appeal vide Form 35 has been filed by the Company. Appeal has allowed by the department and final demand received for Rs. 6,69,680/-

Section 143(1)(b) - Difference in TDS/TCS Credits - Intimation dated October 28, 2024 received under Section 143(1) demanding tax of Rs. 82,530. The same pertains to difference between the TDS credit claimed by the assessee and the credit allowed by the department in the intimation. The Company has replied to the department on November 16, 2024.

Section 143(1)(a) - EPF Contribution Disallowance - In the intimation under Section 143(1) dated December 30, 2021,demanding tax of Rs.62,050 the department has disallowed the EPF contribution alledging that the said contribution for the month of March 2020 was paid after the due date. The assessee has responded that the payment was made on March 16, 2020 which was the due date as the actual due date of March 15, 2020 was a Sunday.

Pursuant to the search conducted at 5 premises of Jain Metal Rolling Mills and its promoter on December 3, 2014, the Commissioner of GST & Central Excise has passed an order on September 30, 2021 alleging that the assessee has removed Lead Ingots from the Factory during the period March 2014 to November 2014 without payment of applicable Excise duty of Rs. 3,22,50,249 and non-payment of excise duty on Plastic recovered from Battery Scrap Rs. 26194 including interest. The same has been alleged by the department based on the Packing Slips which did not have corresponding Excise Invoices. Further, the department has alleged that applicable service tax has not been paid on the Packing and Forwarding charges. Appeal was filed by the Assessee before Customs, Excise and Service Tax Appellate Tribunal on January 12, 2022 and the matter is pending before CESTAT.

Jain Metal Rolling Mills had purchased TIN ingots from Malaysia Smelting Corporation, Malaysia and had availed preferential duty under Notification 46/2011. However, the Certificate of Origin issued in favour of Malaysia Smelting Corporation was revoked. Hence the department had raised duty demand of Rs. 1,33,53,434 on Jain Metal Rolling Mills. The Company had filed a writ petition before the Madras High Court to quash the show cause notice. However, the same was dismissed by the Madras High Court. Further to this, the Company filed an appeal before Commissioner of Customs (Appeal) which rejected the appeal. Subsequently, the Company has filed an appeal before CESTAT and the matter is pending.

Further to the audit of records of Jain Metal Rolling Mills for the period July 2017 to March 2020, the department has raised a demand that the assessee has claimed excess ITC when compared between GSTR 2A and GSTR 3B, non-payment of tax under RCM, short payment of IGST and wrong availment of ineligible ITC. The amount of demand is Rs. 92,19,535 (including 9,00,448 penalty amount). Jain Metal Rolling Mills has appealed the matter before GST Appellate Authority and the matter is pending

Demand raised by the department alledging delay in filing of returns and applicable interest and excess input tax credit availed by the assessee for the period 2021-22 when compared with GSTR 2A. The amount of demand is Rs. 31,54,892. Further to this, the assessee has filed an appeal before GST Appellate Authority and the matter is pending.

Demand raised by the department alledging delay in filing of returns and applicable interest and difference in stock for the period 2022-23 (physical stock vs system stock). The amount of demand is Rs. 1,10,361. Further to this, the assessee has filed an appeal before GST Appellate Authority and the matter is pending.

Demand raised by the department alledging wrong carried forward of CENVAT credit for the period 2017-18 to the tune of Rs. 7,76,893, interest of Rs. 8,55,902 and penalty of Rs. 77,689. Further to this, the assessee has filed an appeal before GST Appellate Authority and the matter is pending

Demand raised by the department alledging difference of input tax credit in annual return and applicable interest and non reversal of blocked credit for the period 2020-21 . The amount of demand is Rs. 7,72,774. Further to this, the assessee has filed an appeal before GST Appellate Authority and the matter is pending.

Show Cause Notice issued by the Office of the Commissioner of Customs, Chennai dated June 27, 2024 alledging that Copper Scrap Druid as Perisri and other imported by Jain Recycling under Advance Authorisation for deemed exports and hence the importer is not eligible for exemption from IGST as claimed by the importer. In view of this, the importer is liable to pay Rs. 1,55,01,978 towards short payment of IGST along with interest and penalty. Penalty imposed equals the amount of differential liability being paid. Further, order stated that, as the goods have already been cleared, a redemption fine of 50 Lakh is imposed.

No direct financial implication on the company, as the appeal has been filed by Mr. Kamlesh Jain, Promoter and Managing Director in his individual capacity.

SAT admitted the appeal filed by Mr. Kamlesh Jain, Promoter and Managing Director, against SEBI's Order dated December 12, 2025. The Tribunal granted a stay of recovery of the penalty, subject to deposit of 50% of the penalty amount within four weeks. SEBI has been granted six weeks’ time to file its reply. The matter is listed for hearing on April 23, 2026.