Construction & Engineering

Company response: The Company respectfully advises the Staff that it considered the guidance in ASC 326-20, including the illustrative Example 5 in paragraphs 55-37 through 55-40, in developing its accounting policy for measuring expected credit losses on accounts receivable and determining the related disclosures. In evaluating the need for additional disclosures regarding past-due accounts receivable, the Company specifically considered whether quantitative aging disclosures or further qualitative discussion would be necessary to enable users to understand the credit risk profile of the portfolio, consistent with ASC 326-20-50-2 and 50-3. This assessment included consideration of the proportion of past-due… response letter →

Company response: 1 to our Form 20-F for the fiscal year ended April 30, 2025. Upon identifying the need to amend our original Form 20-F to include the previously omitted items, management, including our principal executive officer and principal financial officer (the “Certifying Officers”), re-evaluated the effectiveness of our disclosure controls and procedures (“DCP”) as of April 30, 2025. This re-evaluation was conducted specifically to determine whether the omission of these items from the original filing indicated a material weakness or a significant deficiency in our DCP that would alter the original conclusion of effectiveness. The re-evaluation considered the following factors: 1. Nature of the… response letter →

Company response: The Company respectfully advises the Staff that with respect to the defects liability period, the clients of the Company's operating subsidiary may retain up to 5% to 10% of each payment to be made to the operating subsidiary, as retention monies. The defects liability period does not represent a separate performance obligation and therefore does not impact the timing of revenue recognition. The defects liability period is merely a warranty in nature, and it is not an additional service provided to the customer. It does not increase the scope of work done in a construction project, and does not constitute a distinct service. Revenue is recognized when the construction work services were… response letter →

Company response: The Company respectfully advises the Staff that the accounts receivable balance from the customer in question included amounts that were past due as of March 31, 2025. The Company has subsequently collected a significant portion of this balance. Specifically, the aging of the gross accounts receivable of $8,888,000 from this customer as of March 31, 2025, was as follows: Not yet past due: $ 1,340,000 Past due over 180 days but within 1 year: $ 3,841,000 Past due over 1 year but within 2 years: $ 3,707,000 Total Gross Accounts Receivable: $ 8,888,000 As of March 31, 2025, the Company had recorded an allowance for credit loss of $148,000 against this receivable, resulting in a net accounts… response letter →