Statement of deviation(s) or variation(s) under Reg. 32

PAVNA INDUSTRIES LIMITED CIN-L34109UP1994PLC016359 Registered Office: Vimlanchal, Hari Nagar, Aligarh, Uttar Pradesh – 202001 Corporate Address: Sushayat Khurd Aligarh-Agra Road, Near Mangalayatan Mandir, Sasni, Hathras, Aligarh, Uttar Pradesh, India, 204216 Email: cs@pavnagroup.com; Website: www.pavna.in Tel No.: +91-8006409332 August 13, 2026 To, To, The BSE Limited The National Stock Exchange of India Dept of Corporate Services Limited Phirozee Jeejeebhoy Towers, The Listing Department Dalal Street, Fort, Exchange Plaza, C-1, Block G, Bandra Kurla Mumbai - 400001 (Maharashtra) Complex, Bandra (East), Mumbai- 400051(Maharashtra) Scrip Code :543915 Symbol :PAVNAIND ISIN-INE07S101038 Sub: Statement of deviation or variation in utilization of issue proceeds for the quarter ended 30th June, 2026. Dear Sir/Mam, Pursuant to Regulation 32 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, we hereby confirm that there is no deviation or variation in the use of proceeds of preferential issue of Equity Shares & Fully Convertible Warrants. A statement of deviation or variation, in the prescribed format, duly reviewed by Audit Committee is attached herewith. You are requested to take the above information on record. Yours faithfully For Pavna Industries Limited Swapnil Jain Managing Director DIN:01542555 Encl: As above PAVNA INDUSTRIES LIMITED CIN-L34109UP1994PLC016359 Registered Office: Vimlanchal, Hari Nagar, Aligarh, Uttar Pradesh – 202001 Corporate Address: Sushayat Khurd Aligarh-Agra Road, Near Mangalayatan Mandir, Sasni, Hathras, Aligarh, Uttar Pradesh, India, 204216 Email: cs@pavnagroup.com; Website: www.pavna.in Tel No.: +91-8006409332 Statement of deviation or variation in utilization of issue proceeds: Name of listed entity PAVNA INDUSTRIES LIMITED Mode of Fund Raising Preferential Issue Date of Raising Funds 29th January, 2025 Amount Raised (Rs. In Crores) 210.70 (Refer Note 1) Report filed for Quarter ended June 30, 2026 Monitoring Agency Yes Monitoring Agency Name, if applicable CARE Ratings Limited Is there a Deviation / Variation in use of funds raised No If yes, whether the same is pursuant to change in terms of a contract or objects, Not Applicable which was approved by the shareholders If Yes, Date of shareholder Approval Not Applicable Explanation for the Deviation / Variation Not Applicable Comments of the Audit Committee after review None Comments of the auditors, if any None Note 1-PIL has issued 17,72,200 preferential equity shares at Rs.505 per share (including premium of Rs.495 per share) and 24,00,000 fully convertible warrants at issue price of Rs.505 per warrant aggregating Rs.210.70 crore. Entire proceeds pertaining to preferential equity shares amounting to Rs.89.50 crore and 25% proceeds pertaining to fully convertible warrants amounting Rs. 30.30 crores aggregating to Rs.119.80 crore have been received. The balance 75% was payable at the time of exercise of warrants within a period of 18 months from the date of allotment, i.e., on or before July 28, 2026. Since, the Company has not received the balance 75% consideration from the warrant holders within the stipulated timeline, accordingly, the outstanding warrants have lapsed upon expiry of the exercise period, i.e., on July 28, 2026.Consequently, with effect from July 29, 2026, the upfront subscription amount received at the time of allotment, being 25% of the issue price, amounting to ₹30,30,00,000/- (₹30.30 Crore) stands forfeited, in line with Regulation 169(3) of Chapter V of the SEBI ICDR Regulations. Objects for which funds have been raised and where there has been a deviation, in the following table: (Rs. In Cr) Amount of Deviation/Variation Modified Funds for Allocation Utilised the quarter Modified Original if any (Note according to Remarks if Original Object Object, if any Allocation (Note 3) 5) applicable object any Issue related expenses Not Applicable 0.28 0.28 Nil Not Applicable (Note 2) Working capital requirements Not Applicable 81.50 81.50 Nil Not Applicable - General Corporate Purposes Not Applicable 80.25 50.00 Nil Not Applicable - Strategic acquisitions Not Applicable 160.00 78.92 Nil Not Applicable - 322.03 210.70 - (Note 4) PAVNA INDUSTRIES LIMITED CIN-L34109UP1994PLC016359 Registered Office: Vimlanchal, Hari Nagar, Aligarh, Uttar Pradesh – 202001 Corporate Address: Sushayat Khurd Aligarh-Agra Road, Near Mangalayatan Mandir, Sasni, Hathras, Aligarh, Uttar Pradesh, India, 204216 Email: cs@pavnagroup.com; Website: www.pavna.in Tel No.: +91-8006409332 Note 2: Issue expense had already been incurred. However the same is yet to reimburse from Monitoring Account. Note 3: Modification in allocated amount is due to undersubscription of preferential issue of Equity Shares & Fully Convertible Warrants. Note 4: The Company has not received funds during the quarter ended June 30, 2026. Note 5: There has been no utilisation of funds during the quarter ended June 30, 2026. Note 6: Comments of the Monitoring Agency: As of August 4, 2026, the Company's share price of ₹18.41 per share was significantly lower than the warrant conversion price of ₹50.50 per share. Upon the expiry of the prescribed period for payment of the balance 75% warrant consideration, the warrants lapsed and the upfront subscription amount of ₹30.30 crore was forfeited on July 28, 2026. As a result, after considering the preferential equity issue of ₹89.50 crore, the effective fund raise stands reduced to ₹119.80 crore. The reduction in the overall issue size has consequently increased the proportion of issue proceeds allocated towards General Corporate Purpose, causing it to exceed the 25% limit stipulated under applicable SEBI regulations, thereby resulting in a regulatory breach. Note 7: Comments of the Board of Directors: The Preferential Issue size was ₹210.70 crore, of which ₹50.00 crore was allocated towards General Corporate Purposes (GCP), well within the permissible limit of 25% under applicable SEBI regulations. Against this allocation, the Company has utilised only ₹38.30 crore.The observation appears to arise from comparing the GCP utilisation of ₹38.30 crore with the ₹119.80 crore received as of the relevant date. However, at the time of utilisation, the Company was entitled to receive the balance warrant consideration within the stipulated 18-month period, and therefore the approved issue size, and not the amount received as on a particular date, should be the basis for assessing permissible GCP utilisation. Any subsequent forfeiture of warrants, resulting in a lower amount ultimately received, does not retrospectively alter the approved allocation or the utilisation of funds already made in accordance with the objects of the issue. Accordingly, since the GCP utilisation of ₹38.30 crore is within the approved allocation of ₹50.00 crore, the Board is of the view that the utilisation is fully compliant with applicable regulatory requirements and does not constitute any breach or non-compliance. For Pavna Industries Limited Swapnil Jain Managing Director DIN:01542555