What changed in this filing

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Item 4. Controls and Procedures

2025-01-14 compared with 2018-02-28 · 56 added, 43 removed, 3 unchanged (97% of the section changed)

Controls and Procedures.

Management’s

Report on Disclosure Controls and Procedures

Chief Executive Officer and our Chief Financial Officer conducted an evaluation of the effectiveness of the design and operation

of our disclosure controls and procedures, as defined in Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act of 1934

Exchange Act ”), as amended, as of September 30, 2017 to ensure that information required to be disclosed

by us in the reports filed or submitted by us under the Exchange Act is recorded, processed, summarized and reported, within the

time periods specified in the rules and forms adopted by the Securities and Exchange Commission (the “

SEC ”),

including to ensure that information required to be disclosed by us in the reports filed or submitted by us under the Exchange

Act is accumulated and communicated to our management, including our Chief Executive Officer (our Principal Executive Officer)

and our Chief Financial Officer (our Principal Financial and Accounting Officer), or persons performing similar functions, as

appropriate to allow timely decisions regarding required disclosure.

Based on that evaluation, our Chief Executive Officer and

Chief Financial Officer have concluded that as of June 30, 2017, our disclosure controls and procedures were not effective at

the reasonable assurance level due to the material weaknesses identified in the “

Risk Factors ”

section of our

Registration Statement on Form S-1 (File No.

Chief Executive Officer and Chief Financial Officer do not expect that our disclosure controls or internal controls will prevent

all error and all fraud.

Although our disclosure controls and procedures were designed to provide reasonable assurance of achieving

their objectives and our principal executive officer has determined that our disclosure controls and procedures are effective

at doing so, a control system, no matter how well conceived and operated, can provide only reasonable, not absolute assurance

that the objectives of the system are met.

Further, the design of a control system must reflect the fact that there are resource

constraints, and the benefits of controls must be considered relative to their costs.

Because of the inherent limitations in all

control systems, no evaluation of controls can provide absolute assurance that all control issues and instances of fraud, if any,

within the Company have been detected.

These inherent limitations include the realities that judgments in decision-making can

be faulty, and that breakdowns can occur because of simple error or mistake.

Additionally, controls can be circumvented if there

exists in an individual a desire to do so.

There can be no assurance that any design will succeed in achieving its stated goals

under all potential future conditions.

in Internal Controls Over Financial Reporting

were no changes in our internal controls over financial reporting that occurred during the period covered by this report that

has materially affected, or is reasonably likely to materially affect, our internal control over financial reporting.

connection with the restatement of the Company’s financial statements included in this Amendment, our Chief Executive Officer and

Chief Financial Officer re-evaluated the effectiveness of the design and operation of our disclosure controls and procedures and internal

control over financial reporting, as defined in Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act of 1934, as amended (the

“ Exchange Act ”), as of September 30, 2023.

ensure that information required to be disclosed by us in the reports filed or submitted by us under the Exchange Act is recorded, processed,

summarized and reported, within the time periods specified in the rules and forms of the SEC, including to ensure that information required

to be disclosed by us in the reports filed or submitted by us under the Exchange Act is accumulated and communicated to our management,

including our Chief Executive Officer and Chief Financial Officer, as appropriate to allow timely decisions regarding required disclosure.

on that re-evaluation, our Chief Executive Officer and Chief Financial Officer have concluded that as of September 30, 2023, our disclosure

controls and procedures and internal control over financial reporting were not effective, due to material weaknesses in SSi’s internal

control in that:

failed to design controls and procedures to provide reasonable assurance that U.S.

GAAP was being properly applied to the matters

resulting the restatement of our financial statements, including accounting for merger transaction, recognition of revenue in case

of deferred payment sales, recognition of right of use of certain assets and lease liabilities and functional and other classifications,

resulting in the accounting errors described in Note 1.

Restatement of Previously Issued Condensed Consolidated Financial

Statements , of this Amendment.

do not have written documentation of our internal control policies and procedures.

Written documentation of key internal controls

over financial reporting is a requirement of Section 404 of the Sarbanes-Oxley Act.

Management evaluated the impact of our failure

to have written documentation of our internal controls and procedures on our assessment of our disclosure controls and procedures

and has concluded that the control deficiency that resulted represented a material weakness.

do not have sufficient segregation of duties within accounting functions, which is a basic internal control.

Due to our size and

nature, segregation of all conflicting duties may not always be possible and may not be economically feasible.

However, to the extent

possible, the initiation of transactions, the custody of assets and the recording of transactions should be performed by separate

Management evaluated the impact of our failure to have segregation of duties on our assessment of our disclosure controls

and procedures and procedures and has concluded that the control deficiency that resulted represented a material weakness.

Company has been addressing and remediating these material weaknesses with the support and assistance of the accounting and financial

staff employed by our Indian operating subsidiary.

We are enhancing the review process for significant transactions to ensure proper

accounting treatment under applicable guidelines and are engaging external experts where necessary to assist in the application of accounting

principles to complex transactions.

In addition, we are implementing a new ERP system which is designed to integrate all business functions

within the accounting and financial department to further address the abovementioned weaknesses.

Chief Executive Officer and Chief Financial Officer do not expect that our disclosure controls or internal controls will prevent all

errors and all fraud.

Although our disclosure controls and procedures were designed to provide reasonable assurance of achieving their

objectives a control system, no matter how well conceived and operated, can provide only reasonable, not absolute assurance that the

objectives of the system are met.

Further, the design of any control system is subject to resource constraints and the benefits of controls

must be considered relative to their costs.

Because of the inherent limitations in all control systems, no evaluation of controls can

provide absolute assurance that all control issues and instances of fraud, if any, within the Company have been detected.

These inherent

limitations include the fact that judgments in decision-making can be faulty, and that breakdowns can occur because of simple errors

Additionally, controls can be circumvented if there exists in an individual a desire to do so.

There can be no assurance

that any design will succeed in achieving its stated goals under all potential future conditions.

Changes in Internal Controls Over Financial Reporting

for the remediation efforts described above, there were no changes in our internal controls over financial reporting that occurred during

the last fiscal quarter covered by this report that has materially affected, or is reasonably likely to materially affect, our internal

control over financial reporting.

II – OTHER INFORMATION

Legal Proceedings.

Risk Factors.

the section of our prospectus entitled “

Risk Factors ”

in our Registration Statement on Form S-1 (File No.

declared effective by the Securities and Exchange Commission on July 31, 2017.

Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-Q/A

Item 4. Controls and Procedures