As per section 204 read with Rule 9 of companies( appointment and remuneration of managerial personnals) rules 2014,
a)Every listed company and Every public company having a paid-up share capital of fifty crore rupees or more; or
(b) Every public company having a turnover of two hundred fifty crore rupees or more; 1[or]
1[(c) every company having outstanding loans or borrowings from banks or public financial institutions of one hundred crore rupees or more.]
(2) The format of the Secretarial Audit Report shall be in Form No. MR.3.
conclusion: yes in above case secretarial audit report is mandatory for this company.
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The Act mandate that the company, subject to section 204, shall attach MR-3 with every Board report. On the other hand, if we do interpret the section 134, It requires that every company shall prepare financial statements and Board report.
Accordingly, in my view, the company in the given case shall be subject to Secretarial audit.