30^th September, 2019, a Demand Notice dated 8^th December, 2022 and an Invocation Notice dated 9^th January, 2023 has been received by the Company from Rolta Private Limited. However, charge for the security interest created in favour of Rolta Private Limited in terms of the aforesaid Deed of Corporate Guarantee read with its Addendum, and Notice of Invocation is pending registration with the Registrar of Companies and transfer of such shares held as security in favor of Rolta Private Limited has also not been effectuated, although, physical share certificates of said shares are in possession of Rolta Private Limited.

d. Rights, Preferences and Restrictions attached to Shares

The Company has one class of equity shares, having a par value of ? 10 each. Each shareholder is eligible for dividend and one vote per share held. In the event of liquidation, the equity shareholders are eligible to receive the remaining assets of the Company, in proportion to their shareholding, after distribution of all preferential amounts.

e. There are no shares issued as bonus or bought back or issued for consideration other than cash during the period of five years immediately preceding the reporting date.

f. Shareholders holding more than 5% of the shares

There are no shareholders holding more than 5% of Shares of the Company as at the end of current as well as previous year.

16.1 Terms of Secured Borrowings from BanksI. Details of Security

Outstanding Loans are secured against pari-passu charge over land & building situated at “Rolta Tower-1”, Plot No 39, MIDC-Marol, Andheri (East), Mumbai 400093; leasehold rights of the land and building “Rolta Tower 2” located on Plot 35, Marol Industrial Area, Andheri (East), Mumbai 400093; Unit No. 201 to 204, 2^nd floor and 501 to 504, 5^th floor, MIDC multi storied building, SEEPZ SEZ, Marol Industrial Area, Andheri (East), Mumbai 400093; Land & Building of Rolta Tower - A, situated at Plot no 15C, Rolta Technology Park, MIDC-Marol, Andheri (E); 6 flats (no. 1801 and 1802 (18th Floor), 1901, and 1902 (19th Floor), 2001 and 2002 (20th Floor), in building known as "Lake Primose" in Lake Homes, Wing-A, Building No.1, Phase-IV, off Adi Shankarcharya Marg, Vill - Chandivali, Powai, Mumbai-400076, Rolta Tower "B", Plot No. C-12, Rolta Technology Park, MIDC, Andheri (East), Rolta Tower "C", Plot No. C-11, Rolta Technology Park, MIDC, Andheri (E); hypothecation charge on the current assets and movable items of Property, Plant and Equipment (PPE) of the Company, movable PPE/ Intellectual Property Rights held by Rolta Defence Technology Systems Pvt. Ltd. (RDTSPL), subsidiary of the Company, hypothecation and charge over cash flows and Corporate Guarantee of RDTSPL. Exclusive charge over DSRA of the Company with the respective banks and pledge of 26,750 Common shares of USD 1000 each in Rolta International Inc. held by the Company, valued at 125% of the loan amount and guaranteed by Rolta International Inc.

II. Break Up of Secured Borrowings (including interest):

Banks have classified the account of the Company as non-performing assets (“NPA”) in the year 2019 w.e.f. dates stated below due to continuing default on loan servicing (principal as well as interest). The Company has continued to account for the interest (including default interest) upto 19^th January, 2023, i.e. the day when the application filed with Hon’ble NCLT by Union Bank of India was admitted and CIRP process initiated, based on the rate of interest applicable as on the date on which account was declared NPA.

* The Company has filed counter claims of ? 35,255.57 Crores before Debt Recovery Tribunal - II at New Delhi against all the consortium bankers and thereafter the Company

has gone into the Corporate Insolvency Resolution Process.

# outstanding balance (including interest) as at the end of the year in which account of the Company was declared NPA by banks.

III. Rate of Interest

Rate of interest was based on the bank’s base rate plus applicable margin. Effective rate of interest ranges from 10% to 16% p.a., based on the base rate applicable as on the date on which account was declared NPA. Default interest rate is 2% p.a.

16.2 Terms of Inter Corporate Deposit (“ICD”) from Rolta Private Limited (Related Party)I. Applicability of security and terms of repayment

The Company had taken a call money ICD from Rolta Private Limited (“RPL”), a related party, having outstanding balance as at 31^st March 2024 ?634.73 crores

(Previous year ? 634.73 crores) and executed the Deed of Corporate Guarantee dated 29th March, 2019, Addendum dated 30th September, 2019 for the same. As per said deed, only if the Company defaults on repayment of ICD, when demanded, RPL gets rights on the equity shares of the Company’s three subsidiaries, namely, Rolta Global BV, Rolta BI and Big Data Analytics Pvt. Ltd. and Rolta Defence Technology Systems Pvt. Ltd.

RPL sent a Demand Notice dated 8th December, 2022, which was not honoured by the Company, hence the Security clause got enabled and the ICD has been classified as Secured Borrowing w.e.f. 9^th January, 2023, i.e. when RPL had sent an Invocation Notice. However, charge for the security interest created on investment of the Company in equity shares of the above mentioned three subsidiaries in favour of RPL is pending registration with the Registrar of Companies.

II. Further, PRL entered into Assignment Agreement dated 15^th January, 2024 with Peanence Commercial Private Limited (“PCPL”) for assignment of aforesaid ICD for a one-time consideration of Rs. 50 Crores on as is where is basis, however, the same has not been approved/acknowledged by Resolution Professional (“RP”) and therefore the RPL filed an application to the Hon’ble NCLT, which was rejected and subsequently the same was appealed by RPL and PCPL in the Hon’ble National Company Law Appellate Tribunal (“NCLAT”) and the same was dismissed. Consequently, PCPL has filed an appeal with the Hon’ble Supreme Court of India and the same is not yet concluded. In view of this, necessary effect in respect of the aforesaid Assignment Agreement has not been considered in the books of account, i.e. the ICD has been continued to be reported as payable to RPL.

III. Rate of Interest

The said ICD was carrying a rate of 15% p.a., however, during the financial year 2021-22, RPL agreed to waive off the interest effective from 1^st April, 2019.

16.3 Terms of Inter Corporate Deposit (“ICD”) from Rolta Overseas Private Limited (Related Party)

The Company had taken a call money ICD (interest-free) from Rolta Overseas Private Limited, a related party, having outstanding balance as at 31^st March 2024 ?2.44 crores (Previous year ?2.44 crores). The said ICD is unsecured and is repayable on demand.

b. During the year, the Company has reassessed its deferred tax assets recognized on unused tax losses and unabsorbed depreciation. Given the lack of convincing evidence supporting the likelihood of sufficient future taxable profits to utilize these assets, the previously recognized deferred tax asset of ? 994.28 crores has been reversed.

*The said guarantee was invoked by the lender in earlier years, however, the Company has not accepted the same and has disputed.

Notes:

a) Related party relationship is as identified by the Company on the basis of information available.

b) No amount has been written off or written back or provided for during the year in respect of debts due from or to related parties, except what is stated above.

c) The Company has entered into transactions with certain parties as listed above during the year under consideration. Full disclosures have been made and the Board considers such transactions to be in the normal course of business and at rates agreed upon between the parties.

d) Some of the Key Management Personnel (KMP) also covered under the Company’s Gratuity Plan and are also entitled for leave benefits along with the other employees of the Company. However, provision for gratuity and leave entitlement for such KMP is not disclosed separately since the same is computed for Company as a whole.

e) Disclosure pursuant to Regulation 34(3) of the SEBI (Listing Obligation and Disclosure Requirements) Regulations, 2015:

32. Ratio Analysis

Considering the insignificant level of business operations, accounts of the Company classified as NPA and admission of the Company in CIRP Process, ratios analysis as required to be disclosed in accordance with the Schedule III of the Act, is not meaningful and comparable. Accordingly, no disclosure of ratio analysis is being given.

33. Earnings Per Share - (EPS)

EPS is calculated by dividing the profit / (loss) attributable to the equity shareholders by the weighted average number of equity shares outstanding during the year. Numbers used for calculating basic and diluted earnings per equity share are as stated below.

a.) The Company's pending litigations comprise of claims against the Company and proceedings pending with Tax and other Authorities (including the cases, where the tax authorities have filed the appeal against the matters decided in favour of the Company). The Company has reviewed all its pending litigations and proceedings and has made adequate provisions wherever required and disclosed the contingent liabilities, wherever applicable, in its financial statements the Company does not reasonably expect the outcome of these proceedings to have a material impact on its financial statements.

a) The said corporate guarantees given on behalf of the foreign subsidiary had been invoked and claim to the extent of ? 6,268.80 has been admitted in CIR process of the Company.

b) The Company had filed an application under Vivad Se Vishwas for the assessment year 2019-20 towards disputed interest on TDS amounting to ? 2.09 crores prior to commencement of CIR process and is pending for issuance of Form 3.

35. Leases:

The Company does not have any Long Term operating leases.

37. Financial Instrument

The fair value of the financial assets and liabilities are included at the amount at which the instrument that would be received to sell an asset or paid to transfer liability in an orderly transaction between market participants at the measurement date.

The management assessed that cash and cash equivalents, trade receivables, trade payables and other current liabilities approximate their carrying amounts largely due to the short-term maturities of these instruments. The fair value of the financial assets and financial liabilities is included at the amount at which the instrument could be exchanged in a current transaction between willing parties, other than in a forced or liquidation sale.

All the financial assets and financial liabilities of the Company are carried at amortised cost and their amortised cost represents the fair value of those assets /liabilities. Refer note no. 38 and 39 to the consolidated financial statements with regards to the admission of the Company to the CIRP process and submission of the claims by the various operations/ financial creditors and Government dues. Accordingly, the assets/liabilities of the Company are subject to the said CIRP process.

Capital Management and Financial Risk Management Framework:

The Company’s financial risk management is an integral part of how to plan and execute its business strategies. The Company’s activity expose it to market risk, liquidity risk and credit risk. The Company’s financial risk management policy is set by the Chairman and Managing Director and governed by overall direction of Board of Directors of the Company.

Market risk is the risk of loss of future earnings, fair values or future cash flows that may result from a change in the price of a financial instrument. The value of a financial instrument may change as a result of changes in the interest rates, foreign currency exchange rates, equity prices and other market changes that affect market risk sensitive instruments. Market risk is attributable to all market risk sensitive financial instruments including investments and deposits, foreign currency receivables, payables and loans and borrowings.

Foreign currency exchange rate risk:

The fluctuation in foreign currency exchange rates may have a potential impact on the standalone statement of profit and loss and equity. This arises from transactions entered into in foreign currency and assets/liabilities which are denominated in a currency other than the functional currency of the Company.

A majority of the Company’s foreign currency transactions are denominated in US Dollars. Other foreign currency transactions entered into by the Company are in Sterling Pound (GBP), Euro, Saudi Riyal, Canadian Dollar, Australian Dollar and UAE Dirhams. However, the size of these transactions are relatively small in comparison to the US dollar transactions. Thus, the foreign currency sensitivity analysis has only been performed in relation to the US Dollar (USD).

The Company evaluates the impact of foreign exchange rate fluctuations by assessing its exposure to exchange rate risks. Further, in accordance with its risk management policy, Company does not hedge its risks by using any derivative financial instruments.

Foreign Currency sensitivity:

A 5% appreciation / depreciation of the USD with respect to INR would result in decrease / increase in the Company’s net loss before tax for the year ended 31^st March, 2024 by approximately ? 0.31 Crores / ? 0.31 Crores respectively (previous year - ? 0.35 Crores / ? 0.35 Crores respectively).

Interest Rate Risk:

The Company is exposed to Interest rate risk because the Company has borrowed funds at both fixed & floating interest rates. Interest rate risk has been measured by using the cash flow sensitivity for changes in variable interest rates. The sensitivity analysis has been determined based on the exposure to financial instruments at the end of the reporting period. Any movement in reference rates could have an impact on the Company’s cash flows as well as costs.

The Company borrowed through a number of financial instruments such as External Commercial Borrowings (ECBs), Rupee term loans and working capital demand loans. The Holding Company was subject to variable interest rates on some of these interest-bearing liabilities.

However, as stated in note no. 16.1 (II) above, the account of the Holding Company was declared as NPA by banks and also admission of the Company into CIRP process, therefore, exposure of interest rate risk has not been disclosed.

Liquidity Risk:

Being under the CIRP, the Holding company does not have any sources of funds. Amount available in the current accounts, is being utilised by the RP to meet the cash flow needs of day-to-day operations/CIRP process in accordance with the IBC code and also to keep the company as Going concern.

Maturities of Financial liabilities:

Since the company is presently under CIRP, it is not required to meet any loan repayment or interest obligation / other operational creditors wherein the claims submission process is being going on and those claims are subject to CIRP process. Hence, no maturities profile of the financial liabilities has been given.

Credit Risk:

Credit risk is the risk of financial loss arising from counter party failure to repay or service debt according to the contractual terms or obligations. Credit risk encompasses both the direct risk of default and the risk of deterioration of creditworthiness as well as concentration risks.

Financial instruments that are subject to concentrations of credit risk principally consist of trade receivables and loans.

(A) Trade Receivables:

The Company continuously monitors defaults of customers and other counterparties and incorporates this information into its credit risk controls. The Company’s policy is to deal only with creditworthy counter parties. The Company management considers that all the financial assets that are not impaired for each of the reporting dates under

review are of good credit quality, including those that are past due.

Refer note no. 7 for provision for doubtful debts.

(B) Other Financial Assets:

The credit risk for liquid funds and other short-term financial assets is considered negligible, since the counterparties are reputable banks with high quality external credit ratings.

38. The Hon’ble National Company Law Tribunal (“NCLT”), Mumbai Bench, vide its order dated 19^th January, 2023 had admitted the Company for initiation of Corporate Insolvency Resolution Process (CIRP) under the Insolvency and Bankruptcy Code, 2016 (IBC) ("the Code") and appointed Ms. Mamta Binani having Registration no. IBBI/IPA-002/IP-N00086/2017-18/10227 as the Interim Resolution Professional in an application filed by Union Bank of India against the Company. Thereafter at the 1^st Meeting of the Committee of Creditors (“COC”) of the Company held on 17^th February, 2023 the Interim Resolution Professional Ms. Mamta Binani was appointed as the Resolution Professional (“RP”). Also, the power of directors of the Company is vested with the RP w.e.f. 19^th January, 2023. As per the CIRP timelines, the 270 days of the CIRP period was expiring on 16^th October, 2023. However, with the several approvals of the CoC and the Hon'ble National Company Law Tribunal, Mumbai Bench 330 days of CIRP ended on 18^th August, 2024.

In the 25th CoC meeting held on 21^st May, 2024, subsequently adjourned and reconvened, concluding on 27^th May, 2024, the CoC approved the resolution plan submitted by successful resolution applicant by a unanimous vote and the same is under adjudication for the approval before the Hon’ble NCLT, read with note no. 16.2 (II), with regards to pending application with the Hon’ble Supreme Court of India, in respect of voting rights in CoC pursuant to the Assignment Agreement entered by RPL, i.e. one of the secured creditors.

39. As per the IBC, the RP has received, collated, verified the claims submitted by the creditors as on the Insolvency Commencement date i.e. 19^th January, 2023. The latest list of Creditors Version 8 dated 20^th November, 2024 is available at http://www.rolta.com/cirp-process/. As per the latest List of Creditors the RP received claims from financial and operational creditors, including employees and government dues, aggregating to ? 22,546.23 crores (including ? 7,099.10 crores from secured financial creditors) and after verification admitted a sum of ? 14,074.13 crores (including ? 7,086.55 crores from secured financial creditors).

40. In consonance with the stipulations contained in Section 14 of the Code, a moratorium has been declared vide the Order dated 19^th January, 2023 passed by the Hon'ble NCLT, inter alia, prohibiting the following:

a) The Institution of suits or continuation of pending suits or proceedings including relating to Tax and other statutory matters against the Company including execution of any judgement, decree or other in any court of law, tribunal, arbitration panel or other authority;

b) Transferring, encumbering, alienating or disposing of by the Company any of its assets or any legal right or beneficial interest therein;

c) Any action to foreclose, recover or enforce any security interest created by the Company in respect of its property including any action under the Securitization and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002;

d) The recovery of any property by an owner or lessor where such property is occupied by or in the possession of the Company.

41. As stated in Note No. 38, CIRP process was initiated in respect of the Company w.e.f. 19^th January, 2023. These financial statements have been prepared on a going concern assumption considering the Code requires the RP to, among other things, run the Company as a going concern during CIRP.

The RP, in consultation with the CoC of the Company, in accordance with the provisions of the IBC, is making all endeavours to run the Company as a going concern with the assistance of the available resources within the Company considering the future business outlook and the continuity in the operations of the Company. Further, at the end of 3^rd quarter of the year, the CoC has approved the resolution plan submitted by successful resolution applicant and the same is under adjudication for the approval before the Hon’ble NCLT.

42. As a part of the CIRP, the RP had appointed M/s Kansal Singla & Associates, Chartered Accountants for conducting transaction audit as per section 43, 45, 50 and 66 of the Code and audit has been completed and report filed with the RP. As per Transaction audit report there were certain preferential transactions falling under the purview of section 43 of the code. The report also did not contain any transactions falling under the purview of section 45 (i.e Undervalued Transactions), section 50 (i.e Extortionate Transactions) and section 66 of the code (i.e Fraudulent Transactions). The RP has also filed PUFE application for the transactions which are falling under section 43 of the code and the same were dismissed by the Hon'ble Adjudicating Authority by its different orders. The resolution professional has accordingly challenged those orders before the Hon'ble National Company Law

Appellate Tribunal and the applications are under adjudication before the Hon’ble National Company Law Appellate Tribunal.

43. The NCLT, Mumbai Bench, vide its order dated 13 ^th October, 2023 had admitted Rolta BI & Big Data Analytics Private Limited, the Wholly owned Subsidiary of the Company for initiation of CIRP process under the IBC.

44. The NCLT, Mumbai Bench, vide its order dated 2^nd November, 2023 had admitted Rolta Defence Technology Systems Private Limited, the Wholly owned Subsidiary of the Company for initiation of CIRP process under the IBC.

45. An order of Hon'ble Supreme Court of the State of New York, County of New York, has been passed on 02^nd September, 2020 in favour of certain Bondholders for an amount of US $ 183 million (approx.) plus interest at 9% upto the date of payment against the Company and its International Subsidiaries. Further a turnover order dated 20^th October, 2020 on a motion submitted by the plaintiffs was passed by the said Hon’ble Court in New York in favour of the Plaintiffs, directing the defendants to turn over their cash on hand and their stock / membership interest owned in subsidiaries of the company.

The Bond holders had invoked the Corporate Guarantee of the Company on 24^th May, 2018 and 29^thOctober, 2018 issued for the Senior Notes expiring on 2018 and 2019 respectively.

The Company has filed a suit no. 3396/2020 dated 10^th November, 2020 in Hon’ble Bombay High Court with the main prayer to grant interim injunction and declare that the summary judgement dated 02^nd September, 2020 and turnover order dated 20^th October, 2020 cannot be executed and the suit is pending before the Hon’ble Bombay High Court.

The Hon'ble Supreme Court of New York appointed a receiver vide its order dated 16^th April, 2021 against Rolta International Inc, (RUS), its subsidiaries and Rolta India Ltd vide its order dated 24^th August, 2021.

Based on the advice of Legal Advisor for the Company in US, the company turned over its shareholding in Rolta Canada Ltd, Rolta LLC and Rolta America LLC, the subsidiaries of RUS, to the Bondholders on 13th September, 2021 who had obtained the Turnover Order dated 20^th October, 2020 from Hon'ble Supreme Court of the County of New York. As per New York Court Order, the Rolta Directors on RUS have ceased to be on Board of RUS and the Receiver has taken over the Management and financial control of RUS and its subsidiaries from September, 2021. However, ownership of RUS still remains with Rolta India Ltd and Rolta Global BV as turnover order for shares owned by Rolta India Ltd and Rolta Global BV has not been domesticated in local jurisdictions.

On 22^nd March, 2022, Company had perfected the appeal before the higher Appellate court of New York against the (i) Turnover Orders, (ii) the Receivership Orders which is still under consideration of Appellate Court.

The New York court also ordered RIL and its Chairman and Managing Director to provide all emails from May, 2016 onwards including privileged communication also to be handed over to the litigant bondholders. The company appealed this order in appellate court of New York and got the interim stay from the appellate court on 09^th June 2022.

Consideration for transfer of shares of the three US subsidiaries of RUS would be accounted by RUS as and when ordered by Court and thereafter, would be adjusted against the liability of the Bondholders. Meanwhile, these subsidiaries have been considered for consolidation upto September, 2021. Further, the audit of Rolta International Inc., and it’s four subsidiaries could not be undertaken as the books of the accounts or financial statement, are not available as they are under control of Receiver.

During the financial year ended on 31^st March 2023, the Company had booked the expenses incurred towards legal and professional fees in respect of aforesaid matters on behalf its overseas Subsidiary amounting to ? 17.79 Crores.

The Resolution Professional has admitted the claim of the Bond holders to the extent of ? 6,268.80 crores as against the claim of ? 8,788.63 crores against the principal guarantee issued by the Company.

46. During the year ended 31^st March, 2023, the Company had received ? 196.87 from a customer after deduction of applicable TDS (Income Tax and GST) of ? 7.72 Crores and further deducted ? 23.18 Crores towards TDS payable by the Company for earlier period and remitted the same to the tax department directly. The said proceeds were received in the Kotak Mahindra Bank, however, they freeze the account due to the claim received from the Union Bank of India. The Company therefore filed a commercial suit against Kotak Mahindra Bank in the Hon’ble High Court, Mumbai. Subsequently, after the commencement of CIRP, an order for the release of the funds had been passed on 10^th April, 2023 by the Hon’ble High Court.

47. The Company has adjusted in its books the amount receivable from its UK subsidiary i.e. Rolta UK Limited (RUK) arising from devolvement of Standby Letter of Credit (SBLC) and interest thereon against long term export advance received. Further, the company has also adjusted the receivables against the payables and advance of RUK. Similarly, the Company has also adjusted in its books the amount receivable from its subsidiary i.e. Rolta Middle East FZ LLC (RME) arising from devolvement of Standby Letter of Credit (SBLC) and interest thereon against long term export advance received. Further, the company has also adjusted the receivables against the payables and advance of RME.

The Company had made necessary application stating the above facts to Reserve Bank of India seeking their permission for the above adjustments and the approval is awaited.

48. Company’s Current Bank Accounts (except for current account with Axis Bank where inward/ outward foreign remittances were not permitted) were attached by the Income Tax Department (TDS Division) since September, 2019. In absence of operating Current Accounts, the Export remittances from RIL’s overseas subsidiaries were received by the promoter group companies, Rolta Private Ltd (RPL) and Rolta Overseas Private Limited (ROPL) by way of assignments of Invoices raised on RIL’s overseas subsidiaries, based on the legal opinion, and the funds so received were fully utilised for RIL’s expenses through Axis Bank upto June, 2021 and thereafter these companies made the payments directly to the parties as per RIL’s directions. However, after the commencement of CIRP all such realisation & Operations has been made through Company’s own account under the authority of the Resolution Professional.

49. Business Segment:

The Company is engaged in the business of Enterprise Geospatial, Defence, Data Analytics and connected Solutions and reviewed by the Chairman and Managing Director to make decisions about resources to be allocated to the segment and assess its Performance. Currently, the Company has only one Business Segment. Also, refer note no. 38.

50. Employee benefitsA. Defined Contribution Plan

The Company participates in defined contribution plan on behalf of relevant personnel. Expenses recognized in relation to the plan represent the value of contributions payable during the period by the Company at rates specified by the rules of the plan.

Provident fund

In accordance with Indian law, eligible employees of the Company are entitled to receive benefits in respect of provident fund, a defined contribution plan, in which both employees and the Company make monthly contributions at a specified percentage of the covered employees" salary (currently 12% of employees" salary).

The contributions, as specified under the law, are made to the respective Regional

Provident Fund Commissioner and the Central Provident Fund under the State Pension scheme. The total cost charged to Statement of Profit and Loss during the year is ? 0.18 crores (Previous year - ? 0.38 crores)

B. Defined benefit plansGratuity (Unfunded)

The Company has an obligation towards gratuity, a defined benefit retirement plan covering eligible employees. The plan provides for a lump-sum payment to vested employees at retirement, death while in employment or on termination of employment of an amount equivalent to 15 days salary payable for each completed year of service. Vesting occurs upon completion of five years of service. The Company accounts for the liability for gratuity benefits payable in the future based on an actuarial valuation. The Company is exposed to actuarial risk with respect to this plan.

The following table sets out the amounts recognized in the financial statements for the gratuity plans in respect of the Company.

51. Details of Benami Property Held:

The Company do not have any Benami Property, where any proceeding has been initiated or pending against the Company for holding any Benami Property under the Benami Transactions (Prohibition) Act, 1988 (45 of 1988) and rules made there under.

52. Wilful Defaulter

The Company has not been declared as a Wilful Defaulter by any Financial Institution or bank as at the date of Standalone Balance Sheet.

53. Relationship with Struck Off Companies:

The Company has not identified any transactions or balances in any reporting periods with companies whose name is struck off under section 24B of the Companies Act, 2013 or section 560 of Companies Act, 1956.

54. Registration of Charges or Satisfaction with Registrar of Companies (ROC) :

The Company has no pending charges or satisfactions which are yet to be registered with the ROC beyond the statutory period, except for one charge as stated in note no. 16.2.

55. Compliance with Number of Layers of Companies:

The Company has complied with the provision of the number of layers prescribed under clause (87) of section 2 of the Act, read with the Companies (Restriction on number of Layers) Rules, 2017.

56. Compliance with approved Scheme(s) of Arrangements:

There are no Schemes of arrangements has been approved by the Competent Authority in terms of sections 230 to 237 of Companies Act,2013

57. Discrepancy in Utilization of Borrowings:

During the year, the Company has not availed any borrowings from banks and financial institutions.

58. Utilisation of Borrowed funds and share premium:

(i) The Company has not advanced or loaned or invested funds (either borrowed funds or share premium or any other sources or kind of funds) to any other persons(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;

(ii) 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 on behalf of the Ultimate beneficiaries.

59. Undisclosed Income:

The Company has no transaction that 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)

60. Details of Crypto Currency or Virtual Currency

The Company has not traded or invested in Crypto currency or Virtual Currency.

61. Amount mentioned as ? 0.00 crore represents amount less than ? 50,000.

62. The RP has authorised, vide letter dated 15^th November, 2024, Mr. Kamal Krishan Singh, Chairman and Managing Director and Mr. Rangarajan Sundaram, Director Finance & Corporate affairs to sign the financial statements.

63. Previous year’s figures have been regrouped / rearranged wherever necessary to confirm to the classification adopted for the current year.