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Company Information

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DCM SHRIRAM INDUSTRIES LTD.

22 November 2024 | 02:14

Industry >> Sugar

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ISIN No INE843D01027 BSE Code / NSE Code 523369 / DCMSRIND Book Value (Rs.) 93.73 Face Value 2.00
Bookclosure 07/08/2024 52Week High 243 EPS 13.27 P/E 13.57
Market Cap. 1565.86 Cr. 52Week Low 141 P/BV / Div Yield (%) 1.92 / 1.11 Market Lot 1.00
Security Type Other

NOTES TO ACCOUNTS

You can view the entire text of Notes to accounts of the company for the latest year
Year End :2024-03 

d) Terms, rights, preferences and restrictions attached to equity shares

The Company has one class of equity shares having a par value of Rs. 2 per share. Each shareholder is eligible for one vote per share held. In the event of liquidation of the Company, the holders of equity shares will be entitled to receive remaining assets of the Company, after distribution of all preferential amounts. The distribution will be in proportion to the equity shares held by the shareholders. The Company declares and pays dividends in Indian Rupees. The dividend, if proposed by the Board of Directors, is subject to the approval of the shareholders in the Annual General Meeting, except in case of interim dividend.

* A Composite Scheme of Amalgamation for the merger of Versa Trading Private Limited, Bantam Enterprises Private Limited, Hi-Vac Wares Private Limited and HR Travels Private Limited into and with the Lily Commercial Private Limited with effect from 1 April 2023 (which is the appointed date under the scheme) has been approved by the NCLT.

g) Issue of shares for other than cash:

There were no buy back of shares, issue of shares by way of bonus shares or issue of shares pursuant to contract without payment being received in cash during the previous 5 years.

A. SECURED I. From Banks

a) Rs.271.21 lakhs (March 31,2023: Rs.1,356.04 lakhs) carrying interest of 5% p.a., repayable in 3 monthly instalments, is secured by first pari-passu charge on all the immovable and movable properties of the Company excluding assets on exclusive charges.

b) Nil (March 31,2023: Rs.267.19 lakhs), Nil lakhs (March 31,2023: Rs.180.18 lakhs) and Rs.1,039.98 lakhs (March 31,2023: Rs.2,076.41 lakhs) carrying interest linked to lender’s 1 year MCLR, repayable in 4 quarterly instalments, were/are secured by first pari-passu charge on all the immovable and movable properties of the Company excluding assets on exclusive charges.

c) Rs.2,916.89 lakhs (March 31,2023: Rs.4,338.97 Lakhs) carrying interest linked to lender’s 1 year MCLR and spread thereon, repayable in 10 quarterly instalments, is secured by first pari-passu charge on all the immovable and movable properties of the Company excluding assets on exclusive charges.

d) Rs.1,736.47 lakhs (March 31,2023: Rs.2,941.50 lakhs) carrying interest of 8% p.a., repayable in 18 monthly instalments, is secured by first pari-passu charge by way of mortgage/hypothecation on all the fixed assets of the Company, excluding assets on exclusive charges.

e) Nil (March 31,2023: Rs.333.26 lakhs) and Rs.156.25 (March 31,2023: Rs.781.25 lakhs) carrying interest rate of 8.95% p.a., repayable in 1 quarterly instalment, were/are secured by residual pari-passu charge on fixed assets of sugar factory at Daurala Sugar Works, a unit of the Company.

f) Rs.145.12 lakhs (March 31,2023: Rs.762.90 lakhs) carrying interest linked to lender’s 1 year MCLR and spread thereon with 50% interest subvention on part of the loan, repayable in 1 quarterly instalment, is secured by first pari-passu charge on fixed assets of Daurala Sugar Works - Sugar & Alcohol division, a unit of the Company.

g) Rs.900.00 lakhs (March 31,2023: Nil) carrying interest linked to lender’s 1 year MCLR and spread thereon, repayable in 20 quarterly instalments, is secured by first pari-passu charge on fixed assets of Daurala Sugar Works - Sugar & Alcohol division, a unit of the Company.

h) Rs.59.02 Lakhs (March 31,2023: Rs.71.87 lakhs) is secured by hypothecation of specific asset carrying interest of 8.50%, repayable in 45 monthly instalments.

II. From Others

i) Rs.346.15 lakhs (March 31,2023: Rs.445.05 lakhs) carrying interest linked to RBI’s Bank rate minus 2%., repayable in 7 half yearly instalments, is secured by first pari-passu charge on immovable and movable properties of sugar factory at Daurala Sugar Works, a unit of the Company.

ii) Rs.8.49 lakhs (March 31,2023: Rs.24.66 lakhs) is secured by hypothecation of specific asset carrying interest of 6.63%, repayable in 6 monthly instalments.

B. Unsecured

Rs.902.86 lakhs (March 31,2023: Rs.916.56 lakhs), deposits from public, carries interest between 9% p.a to 10% p.a., are currently repayable after 3 years from the date of acceptance of deposits.

C. The quarterly returns/statements filed by the Company with the banks are in agreement with the books of account of the Company.

The amount of Rs. 329.02 lakhs included in contract liabilities at March 31,2023 has been recognised as revenue during the year ended March 31, 2024 (March 31, 2023: Rs. 488.75 lakhs)

Revenue from sale of goods is recognised at the point in time when control of products is transferred to the customer. Amounts disclosed as revenue are net of returns and allowances, trade discounts and rebates.

Invoices are generated at that point in time. Invoices are usually payable within 180 days.

# The Company continues to pay income tax under the old tax regime and has not opted for lower tax rate pursuant to Taxation Law (Amendment) Ordinance, 2019 (Section 115BAA of The Income Tax Act, 1961) considering the accumulated MAT credit and other benefits under The Income Tax Act, 1961. The Company plans to opt for lower tax regime once these benefits are utilised, which is expected by financial year ending March 31, 2025. Accordingly, deferred tax liability on temporary differences which are expected to reverse after the financial year ending March 31, 2025 has been remeasured considering the revised rate.

In accordance with Ind AS 108 'Segment Reporting' as specified in section 133 of the Companies Act, 2013, the Company has identified three business segments viz. 'Sugar', 'Industrial fibres and related products', and 'Chemicals'. The above segments have been identified and reported taking into account the differing risks and returns, and the current internal financial reporting systems. For each of the segments, the Chief Operating Decision Maker (CODM) reviews internal management reports on at least a quarterly basis. The CODM monitors the operating results separately for the purpose of making decisions about resource allocation and performance measurement (Refer Note 2A(p)). Segment revenue, results and capital employed include the respective amounts identifiable to each of the segments. Other unallocable expenditure includes expenses incurred on common services provided to the segments, which are not directly identifiable.

In addition to the material accounting policies applicable to the business segments as set out in note 2A(p) above, the accounting policies in relation to segment accounting are as under:

a) Segment revenue and expenses

Segment revenue and expenses are, generally, directly attributable to the segments. Joint revenue and expenses of segments are allocated amongst them on a reasonable basis.

b) Segment assets and liabilities

Segment assets include all operating assets used by a segment and consist principally of operating trade receivables, inventories and property plant and equipment and intangible assets, net of allowances and provisions, which are reported as direct offsets in the balance sheet. Segment liabilities include all operating liabilities and consist principally of creditors and accrued liabilities and do not include deferred income taxes and borrowings. While most of the assets / liabilities can be directly attributed to individual segments, the carrying amount of certain assets / liabilities pertaining to two or more segments are allocated to the segments on a reasonable basis.

The following summary describes the operations in each of the Company's reportable segments:

Sugar Comprising sugar, power and alcohol

Industrial fibres and related products Comprising rayon, synthetic yarn, cord, fabric, etc.

Chemicals Comprising organics and fine chemicals

* Matters are subject to legal proceedings in the ordinary course of business. The legal proceedings, when ultimately concluded, are not likely to, in the opinion of the management, have a material effect on the results of the operations or financial position of the Company.

B. Commitments

a. Capital commitments: Estimated amount of contracts remaining to be executed on capital account and not provided for (net of advances) amount aggregating to Rs. 250.92 lakhs (March 31,2023: Rs. 99.42 lakhs) relating to Property, plant and equipment.

b. Other commitments: The Company has other commitments, for purchase / sales orders which are issued after considering requirements per operating cycle for purchase / sale of goods and services, employee benefits including union agreement in the normal course of business. The Company does not have any long term commitments / contracts, including derivative contracts, with any material foreseeable losses.

42. A petition challenging the Preferential Issue of equity warrants by the Company filed by a shareholder before the Hon’ble Company Law Board (now National Company Law Tribunal), pending since November 2007, had been dismissed as withdrawn in the hearing held on March 07, 2023.

A. Defined contribution plans

Rs. 201.03 lakhs (March 31,2023: Rs. 180.88 lakhs) for provident fund contributions and Rs. 254.02 lakhs (March 31,2023: Rs. 247.35 lakhs) for superannuation and national pension scheme fund contributions have been charged to the Statement of Profit and Loss. The contributions towards these schemes are at the rates specified in the rules of the schemes.

B. Defined benefit plans

a) Liabilities for gratuity, privilege leaves and medical leaves are determined on actuarial basis. Gratuity liability is provided to the extent not covered by the funds available in the gratuity fund.

Gratuity:

Gratuity scheme provides for a lump sum payment to vested employees at retirement, death, while in employment, or on termination of employment. Vesting occurs upon completion of five years of service, except death while in employment.

Expected contributions to post-employment benefit plans for the financial year 2024-25 are Rs. 230.42 lakhs (202324: Rs. 221.81 lakhs).

The cost of the defined benefit plans and other long term benefits are determined using actuarial valuations. Actuarial valuations involve making various assumptions that may differ from actual developments in the future. These includes the determination of the discount rate, future salary increases and mortality rate. Due to the complexities involved, the valuation is highly sensitive to the changes in assumptions. All assumptions are reviewed at each reporting date. The present value of the defined benefit obligation and the related current service cost and planned service cost were measured using the projected unit cost method.

The Company has established an income tax approved irrevocable trust fund to which it regularly contributes to finance the liabilities of the gratuity plan. The fund’s investments are managed by certain insurance companies as per the mandate provided to them by the trustees and the asset allocation is within the permissible limits prescribed in the insurance regulations.

vii) Sensitivity analysis

The significant actuarial assumptions for the determination of defined benefit obligations are discount rate and expected salary increase.

C. Compensated absences:

The obligation of compensated absence in respect of the employees of the Company as at March 31, 2024 works out to Rs. 1,447.55 lakhs (March 31,2023: Rs. 1,269.86 lakhs)

D. Provident fund:

All employees are entitled to Provident Fund benefits as per the law. For certain category of employees the Company administers the benefits through a recognised Provident Fund Trust. The Company has an obligation to fund any shortfall on the yield of the trust's investments over the administered interest rates on an annual basis. For other employees contributions are made to the Regional Provident Fund Commissioners. The Government mandates the annual yield to be provided to the employees on their corpus. This plan is considered as a Defined Benefit Plan. For the first category of employees (covered by the Trust), the Company has an obligation to make good the shortfall, if any, between the yield on the investments of the trust and the yield mandated by the Government and these are considered as Defined Benefit Plans and are accounted for on the basis of an actuarial valuation.

Expected contribution to provident fund benefit plans for the financial year 2024-25 are Rs.669.14 lakhs

The cost of the defined benefit plans and other long term benefits are determined using actuarial valuations. Actuarial valuations involve making various assumptions that may differ from actual developments in the future. These includes the determination of the discount rate, future salary increases and mortality rate. Due to the complexities involved, the valuation is highly sensitive to the changes in assumptions. All assumptions are reviewed at each reporting date. The present value of the defined benefit obligation and the related current service cost and planned service cost were measured using the projected unit cost method.

vi) Sensitivity analysis

The significant actuarial assumption for the determination of defined benefit obligations is the discount rate.

The sensitivity analysis above has been determined based on reasonably possible changes of the respective assumptions occurring at the end of reporting period, while holding all other assumptions constant.

Sensitivities due to mortality and withdrawals are insignificant and hence not considered in sensitivity analysis disclosed.

E. Risk exposure

These defined benefit plans typically expose the Company to actuarial risks as under:

a) Investment Risk

The present value of the defined benefit plan liability is calculated using a discount rate which is determined by reference to market yields at the end of the reporting period on government bonds.

b) Interest rate risk

A decrease in bond interest rate will increase the plan liability. However, this shall be partially off-set by increase in return as per debt investments.

c) Longevity risk

The present value of the defined plan liability is calculated by reference to the best estimate of the mortality of plan participants. An increase in the life expectancy will increase the plan’s liability.

d) Salary risk

Higher than expected increase in salary will increase the defined benefit obligation.

Transactions with the related parties are made on normal commercial terms and conditions and at market rates, to be settled in cash except advance for share capital (refer note 55)

46. Financial instruments - Fair values and risk management

a. Financial instruments - by category and fair values hierarchy

Fair values are categorised into different levels in a fair value hierarchy based on the inputs used in the valuation techniques as follows:

Level 1: quoted prices (unadjusted) in active markets for identical assets or liabilities.

Level 2: inputs other than quoted prices included in Level 1 that are observable for the asset or liability, either directly (i.e. as prices) or indirectly (i.e. derived from prices).

Level 3: inputs for the asset or liability that are not based on observable market data (unobservable inputs).

The following table shows the carrying amounts and fair value of financial assets and financial liabilities, including their levels in the fair value hierarchy.

# The Company’s borrowings have been contracted at both floating and fixed rates of interests. The borrowings at floating rates reset at short intervals. Accordingly, the carrying values of such borrowings (including interest accrued but not due) approximate fair values. The fair values of long-term borrowings with fixed rates of interest is estimated by discounting future cash flows using current rates (applicable to instuments with similar terms, currency, credit risk and remaining maturities to discount the future payout).

* The carrying amounts of trade receivables, trade payables, lease liabilites, cash and cash equivalents, investments, bank balances other than cash and cash equivalents, and other financial assets and liabilities, approximate the fair values, due to their short-term nature. The other non-current financial assets represents security deposits given to various parties, loans and advances to employees and bank deposits (due for maturity after twelve months from the reporting date), lease liabilities and other non-current financial liabilities, the carrying values of which approximate the fair values as on the reporting date.

There have been no transfers between Level 1, Level 2 and Level 3 for the years ended March 31,2024 and March 31,2023.

Valuation

Following financial instruments are remeasured at fair value as under :

(a) The fair values of investments in mutual fund units is based on the net asset value (‘NAV’) as stated by the issuers of these mutual fund units in the published statements as at Balance Sheet date. NAV represents the price at which the issuer will issue further units of mutual fund, and the price at which issuers will redeem such units.

(b) The fair value of all derivative contracts is determined using forward exchange rate at the balance sheet date.

Credit risk is the risk that a customer or counterparty to a financial instrument will fail to perform or pay amounts due, causing financial loss to the Company. It arises from cash and cash equivalents, financial instruments and principally from credit exposure to customers relating to receivables. The Company continuously reviews the credit to be given and the recoverability of amounts due. Majority of the trade receivables are from parties with whom the Company has long standing satisfactory dealings.

# The Company continuously reviews the credit to be given and the recoverability of amounts due. Majority of the trade receivables, both domestic and overseas, are from parties with whom the Company has long standing satisfactory dealings. The Company also makes provision for lifetime expected credit loss, based on its previous experience of provisions/write offs in previous years.

Cash and cash equivalents

Credit risk on cash and cash equivalents is limited as the Company generally transacts with the banks with high credit ratings assigned by domestic and international credit rating agencies.

Other financial assets

Other financial assets do not have any significant credit risk (also refer note 52).

(ii) Liquidity risk

Liquidity risk is the risk that the Company will encounter difficulty in meeting the obligations associated with its financial liabilities that are settled by delivering cash or another financial asset. The Company’s approach to managing liquidity is to ensure, as far as possible, that it will have sufficient liquidity to meet its liabilities when they fall due, under both normal and stressed conditions, without incurring unacceptable losses or risking damage to the Company’s reputation.

The Company believes that its liquidity position, including total cash and cash equivalent and bank balances other than cash and cash equivalent of Rs. 3,062.66 as at March 31,2024 (March 31,2023 Rs. 1,223.46 lakhs), anticipated future considering internally generated funds from operations fully available and revolving undrawn credit facility will enable it to meet its future known obligations in the ordinary course of business. However, if liquidity needs were to arise, the Company believes it has access to financing arrangements, which should enable it to meet its ongoing capital, operating, and other liquidity requirements. The Company will continue to consider various borrowing or leasing options to maximize liquidity and supplement cash requirements, as necessary.

The Company’s liquidity management process as monitored by management, includes the following:

- Day to day funding, managed by monitoring future cash flows to ensure that requirements can be met.

- Maintaining rolling forecasts of the Company’s liquidity position on the basis of expected cash flows.

- Maintaining diversified credit lines.

(iii) Market risk

Market risk is the risk that the future cash flows of a financial instrument will fluctuate because of changes in market prices. Market risk comprises two types of risks: currency risk and interest rate risk. The objective of market risk management is to manage and control market risk exposures within acceptable parameters, while optimising the return. The Board of Directors is responsible for setting up of policies and procedures to manage market risks of the Company.

Currency risk

Currency risk is the risk that the future cash flows of a financial instrument will fluctuate because of changes in foreign exchange rates. The Company is exposed to the effects of fluctuation in the prevailing foreign currency exchange rates on its financial position and cash flows. Exposure arises primarily due to exchange rate fluctuations between the functional currency and other currencies, from the Company's operating, investing and financing activities.

Sensitivity analysis

A reasonably possible strengthening / weakening of the Indian Rupee against below currencies at March 31, 2024 (previous year ended as on March 31, 2023) would have affected the measurement of financial instruments denominated in functional currency and affected equity and profit or loss by the amounts shown below. This analysis is performed on foreign currency denominated monetary financial assets and financial liabilities outstanding as at the year end. This analysis assumes that all other variables, in particular interest rates, remain constant and ignores any impact of forecast sales and purchases.

Foreign exchange derivative contracts

The Company uses derivative financial instruments exclusively for hedging financial risks that arise from its commercial business or financing activities. The Company’s Corporate Treasury team manages its foreign currency risk by hedging transactions that are expected to occur within a period of 1 to 24 months for hedges of forecasted sales, purchases and capital expenditures. When a derivative is entered into for the purpose of being a hedge, the Company negotiates the terms of those derivatives to match the terms of the hedged exposure. For hedges of forecast transactions, the derivatives cover the period of exposure from the point the cash flows of the transactions are forecasted up to the point of settlement of the resulting receivable or payable that is denominated in the foreign currency. All identified exposures are managed as per the policy duly, approved by the Board of Directors. The fair value is determined using quoted forward exchange rates at the reporting date and present value calculations based on high credit risk quality yield curves in the respective currency.

(iii) Market risk

Interest rate risk

Interest rate risk is the risk that the future cash flows of a financial instrument will fluctuate because of changes in interest rates. The Company’s main interest rate risk arises from long-term borrowings with variable rates, which expose the Company to cash flow interest rate risk.

47. Capital management

For the purposes of the Company’s capital management, capital includes issued equity share capital, securities premium and all other equity reserves attributable to the equity holders of the Company. The primary objective of the management of the Company’s capital structure is to maintain an efficient mix of debt and equity in order to achieve a low cost of capital. This also considers the desirable financial flexibility to pursue business opportunities and adequate access to liquidity to mitigate the effect of unforeseen events on cash flows.

The Company manages its capital structure and makes adjustments to it in light of changes in the economic/ business conditions and requirements.

48. Research and development expenses amounting to Rs. 617.10 lakhs (March 31,2023: Rs. 491.48 lakhs) have been charged to the respective revenue accounts. Capital expenditure relating to research and development amounting to Rs. Nil (March 31, 2023: Rs. 8.25 lakhs) has been included in property, plant and equipment.

52. Consequent to introduction of Goods and Services Tax (GST) with effect from July 1,2017, there has been ambiguity with regard to chargeability of indirect tax, i.e., UP VAT or GST or any other tax, on certain supplies made to a party and, therefore, no tax has been charged on invoices raised for such supplies. The Hon’ble Allahabad High Court in the year 2021-22 has held that no VAT is chargeable on such transactions. However, this issue is sub-judice before the Hon’ble Supreme Court in a similar matter. The buyer has provided an undertaking to indemnify the Company for any tax, along with interest, penalty (if levied) and any other related expenses, as may be finally determined in this regard.

The State VAT Authorities had completed assessments for the periods July 1,2017 to October 31, 2020 and raised demands on the Company. These assessments have been cancelled after the Hon’ble Allahabad High Court order, except for the year ended March 31,2020, which is pending disposal before the VAT Tribunal, and the VAT demand raised amounting to Rs. 6,528.32 lakhs in respect of that year has been stayed by the Tribunal. The Company has deposited amounts aggregating Rs.3,417.52 lakhs under protest in respect of the aforesaid VAT matters for the periods July 1, 2017 to October 31, 2020.

During the previous year, GST demands aggregating Rs. 29,617.47 lakhs were raised in relation to these transactions from July 1,2017 to September 30, 2022 (except for the financial year 2019-20) which have been stayed and are being contested. The Company has deposited amounts aggregating Rs.2,249.50 lakhs as of March 31, 2024 (Rs. 1,891.66 lakhs as at March 31,2023) as duty under protest in respect of GST, shown as ‘Government dues paid and recoverble’ under ‘Other non-current assets’.

Further, GST Council in its meeting dated October 7, 2023 has ceded the right to tax such supplies to State Governments. However, State Government has not notified any rules in this regard as yet.

Pending necessary amendments / notifications in this regard, the Company has continued the same accounting treatment in respect of the transactions as in previous year(s) and the Company has recognized a provision for contingencies of Rs. 30,580.42 lakhs as at March 31, 2024 (Rs. 26,312.70 lakhs as at March 31, 2023) under Provisions (current). Basis the undertaking from the buyer, the Company has recognized corresponding reimbursement assets amounting to Rs. 30,580.42 lakhs as at March 31, 2024 (Rs. 26,312.70 lakhs as at March 31,2023) under “Other financial assets (current)”.

The amounts aggregating Rs. 5,667.02 lakhs as at March 31,2024 (Rs.5,309.18 lakhs as at March 31,2023) paid under protest have been shown as recoverable under “Other non-current assets” with corresponding amount shown as payable to the buyer under “Other non-current financial liabilities”.

The above does not have any impact on the profits of the Company.

54. The Board of Directors in the meeting held on 14 November, 2023 approved a Composite Scheme of Arrangement (the Scheme) between DCM Shriram Industries Limited and DCM Shriram Fine Chemicals Limited and DCM Shriram International Limited (wholly owned subsidiaries of DCM Shriram Industries Limited) and Lily Commercial Private Limited, for amalgamation of Lily Commercial Private Limited with DCM Shriram Industries Limited, and subsequent demerger of Chemical and Rayon businesses of DCM Shriram Industries Limited into DCM Shriram Fine Chemicals Limited and DCM Shriram International Limited, respectively, with effect from the appointed date of 1 April 2023, subject to regulatory and statutory approvals, as applicable. The Scheme is presently under consideration of Bombay Stock Exchange (BSE) and National Stock Exchange (NSE). Pending the necessary approvals, which are substantive in nature, the effect of the Scheme has not been given in the financial statements.

55. a) During the previous year, the Company subscribed to 10,00,00,000 equity shares of Rs. 2 each in DCM Shriram Fine Chemcials Limited, a wholly owned subsidiary of the Company, including conversion of advance against equity Rs. 1,670.64 lakhs as on March 31,2022. Additional advance of Rs. 411.27 lakhs has been given during the year and, accordingly, an amount of Rs. 742.55 lakhs (March 31,2023: Rs. 331.27 lakhs) has been shown as “Advance against share capital” and included in Note no. 5 “Investment-Non current”.

b) During the previous year, the Company subscribed to 50,000 equity shares of Rs. 2 each in DCM Shriram International Limited, a wholly owned subsidiary of the Company. Additional advance of Rs. 0.34 lakhs had been given during the previous year and, accordingly, an amount of Rs. 0.34 lakhs (March 31, 2023: Rs. 0.34 lakhs) has been shown as “Advance against share capital” and included in Note no. 5 “Investment-Non current”.

iv) The Company has not traded or invested in crypto currency or any virtual currency during the financial year.

v) The Company has not advanced or loaned or invested funds to any other person(s) or entity(ies), including foreign entities (Intermediaries) with the understanding that the Intermediary shall:

a) directly or indirectly lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the Company (ultimate beneficiaries) or

b) provide any guarantee, security or the like to or on behalf of the ultimate beneficiaries.”

vi) The Company has not received any fund from any person(s) or entity(ies), including foreign entities (Funding Party) with the understanding (whether recorded in writing or otherwise) that the Company shall:

a) directly or indirectly lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the funding party (ultimate beneficiaries) or

b) provide any guarantee, security or the like to or on behalf of the ultimate beneficiaries.

vii) The Company does not have any transaction which is not recorded in the books of accounts that has been

surrendered or disclosed as income during the year in the tax assessments under the Income Tax Act, 1961 (such

as, search or survey or any other relevant provisions of the Income Tax Act, 1961).

viii) The Company has not been declared as a wilful defaulter by any banks or any other financial institution at any time during the financial year or after the end of the reporting period but before the date when the financial statements are approved by the Board of Directors.

ix) The Group earlier had five Core Investment Companies (CICs) within the Group, out of which four have merged with the fifth CIC subsequent to receipt of NCLT order retrospectively from the appointed date, i.e., April 01,2023. Accordingly, the Group (as per the provisions of the Core Investment Companies (Reserve Bank) Directions, 2016) has one CIC remaining as part of the Group.