5.8 Provisions, contingent liabilities and contingent assets
a) A provision is recognized if, as a result of a past event, the Company has a present legal or constructive obligation that can be estimated reliably, and it is probable that an outflow of economic benefits will be required to settle the obligation. Provisions are not recognised for future operating losses.
If the effect of the time value of money is material, provisions are determined by discounting the expected future cash flows at current pre-tax rate that reflects current market assessments of the time value of money and the risks specific to the liability. When discounting is used, the increase in the passage of time is recognized as finance costs.
The amount recognized as a provision is the best estimate of the consideration required to settle the present obligation as at the balance sheet date, taking into account the risks and uncertainties surrounding the obligation.
When some or all of the economic benefits required to settle a provision are expected to be recovered from a third party, the receivable is recognized as an asset, if it is virtually certain that reimbursement will be received and the amount of the receivable can be measured reliably. The expense relating to provision is presented in the Statement of Profit and Loss net of any reimbursement.
b) A contingent liability is not recognised in the financial statements, however, is disclosed, unless the possibility of an outflow of resources embodying economic benefits is remote.
If it becomes probable that an outflow of future economic benefits will be required for an item dealt with as a contingent liability, a provision is recognized in the financial statements of the period (except in the extremely rare circumstances where no reliable estimate can be made).
c) A contingent asset is not recognised in the financial statements, however, is disclosed, where an inflow of economic benefits is probable.
When the realisation of income is virtually certain, then the related asset is no longer a contingent asset, and is recognised as an asset.
d) Provisions, contingent liabilities and contingent assets are reviewed at each balance sheet date.
5.9 Earnings per Share
a) Basic earnings per share are computed by dividing the net profit/(loss) after tax by the weighted average number of equity shares outstanding during the year (excluding other comprehensive income)
b) Diluted earnings per share are computed by dividing the net profit/(loss) after tax by the weighted average number of equity shares considered for deriving basic earnings per share and also the weighted average number of equity shares which could be issued on the conversion of all dilutive potential equity shares, (excluding other comprehensive income)
5.10 Exceptional Items
The term exceptional items is neither defined in Ind AS nor in Schedule III. However, Ind AS 1 has reference to such items in paras 85,86,97 & 98. Accordingly when the items of income or expenses are material, the Company discloses its nature and amount separately. Following circumstances (as per para 98) gives circumstances that would give rise to the separate disclosure of items of income and expenses and includes:
1) Written down of inventories to net reliasable value or of PPE to recoverable amount, as well as reversals of such write-downs
2) restructuring of the activities of an entity and reversals of any provisions for the costs of restructuring;
3) disposals of items of PPE
4) disposals of investments
5) discontinued operations
6) litigations settlements; and
7) other reversals of provisions
In case the company has more than one such item of income/expense of the above nature which is exceptional, then such items are disclosed on the face of the Statement of Profit and Loss. Details of the all individual items are disclosed in the notes. However, the Company does not have any exceptional items to report during the current reporting period.
5.11 Contingencies and events occurring after the Balance Sheet date
Events occurring after the date of the Balance Sheet, which provide further evidence of conditions that existed
at the Balance Sheet date or that arose subsequently, are considered upto the date of approval of accounts by the Board of Directors, where material.
5.12 Dividends on Ordinary Shares
The Company recognises a liability to make cash distributions to equity holders of the parent when the distribution is authorised and the distribution is no longer at the discretion of the Company.
As per the corporate laws in India, a distribution is authorised when it is approved by the shareholders. A corresponding amount is recognised directly in equity.
5.13 Rounding of amounts
All amounts disclosed in the financial statements and notes have been rounded off to the nearest thousands as perthe requirements
5.14 Recent Pronouncements
The Ministry of Corporate Affairs has vide notification dated 31 March 2023 notified Companies (Indian Accounting Standards) Amendment Rules, 2023 (the'Rules') which amends certain accounting standards. The Rules predominantly amend Ind AS 12, Income taxes, and Ind AS 1, Presentation of financial statements. The other amendments to Ind AS notified by these rules are primarily in the nature of clarifications. These amendments are not expected to have a material impact on the Company in the current or future reporting periods and on foreseeable future transactions. Specifically, no changes would be necessary as a consequence
of amendments made to Ind AS 12 as the Company's accounting policy already complies with the now mandatory treatment.
Notes forming part of the Financial Statements
6. Segement Information Primary Segment
The Company's primary business segments are reflected based on the principal business carried out i.e. Investments & Financing. All other activities of the Company revlove around the main business.
The risk and returns of the business of the Company is not associated with geographical segmentation,hence there is no secondary segment reporting based on geographical segment.
As such, there are no separate reportable segments as perthe Indian Accounting Standard 108
7. Significant Accounting Judgements, Estimates and Assumptions
The preparation of the Company's financial statements in conformity with the Ind AS requires the management to make judgments, estimates and assumptions that affect the reported amounts of revenues, expenses, assets and liabilities and the accompanying disclosure and the disclosure of contingent liabilities, at the end of the reporting period. Estimates and underlying assumptions are reviewed on an ongoing basis. Revisions to accounting estimates are recognised in the period in which the estimates are revised and future periods are affected.
Although these estimates are based on the management's best knowledge of current events and actions, uncertainty about these assumptions and estimates could result in the outcomes requiring a material adjustment to the carrying amounts of assets or liabilities in future periods. In particular, information about significant areas of estimation, uncertainty and critical judgments in applying
accounting policies that have the most significant effect on the amounts recognized in the financial statements isincluded in the following notes:
7.1 Business Model Assessment
Classification and measurement of financial assets depends on the results of the SPPI and the business model test.
The Company determines the business model at a level that reflects how groups of financial assets are managed together to achieve a particular business objective. This assessment includes judgement reflecting all relevant evidence including how the performance of the assets is evaluated and their performance is measured, the risks that affect the performance of the assets and how these are managed and how the managers of the assets are compensated. The Company monitors financial assets measured at amortised cost or fair value through other comprehensive income that are derecognised prior to their maturity to understand the reason for their disposal and whether the reasons are consistent with the objective of the business for which the asset was held. Monitoring is part of the Company's continuous assessment of whether the business model for which the remaining financial assets are held continues to be appropriate and if it is not appropriate whether there has been a change in business model and so a prospective change to the classification of those assets.
7.2 Fair Value Measurement
When the fair values of financial assets and financial liabilities recorded in the balance sheet cannot be measured based on quoted prices in active markets, their fair value is measured using different valuation techniques. The inputs to these models are taken from observable markets where possible, but where this is not feasible a degree of judgment is required in establishing fair values. Judgments include considerations of inputs such as liquidity risk, credit risk and volatility. Changes in assumptions about these factors could affect the reported fair value of financial instruments.
7.3 Impairment of financial asset
The measurement of impairment losses across all categories of financial assets requires judgement, in particular, the estimation of the amount and timing of future cash flows when determining impairment losses and the assessment of a significant increase in credit risk. These estimates are driven by a number of factors, changes in which can result in different levels of allowances.
It has been the Company's policy to regularly review its models in the context of actual loss experience and adjust when necessary. The impairment loss on loans and advances is disclosed in more detail in Note 5.2 (iii)(f) Overview of ECL principles.
7.4 Contingent liabilities and Provisions otherthan Impairment on Loan Portfolio
The Company operates in a regulatory and legal environment that, by nature, has a heightened element of litigation risk inherent to its operations. As a result, it is involved in various litigation, arbitration in the ordinary course of the Company's business.
When the Company can reliably measure the outflow of economic benefits in relation to a specific case and considers such outflows to be probable, the Company records a provision against the case.
Where the probability of outflow is considered to be remote, or probable, but a reliable estimate cannotbe made, a contingent liability is disclosed. Given the subjectivity and uncertainty of determining the probability and amount of losses, the Company takes into account a number of factors including legal advice, the stage of the matter and historical evidence from similar incidents. Significant judgement is required to conclude on these estimates.
7.5 Effective Interest Rate (EIR)
The Company's EIR methodology, recognises interest income / expense using a rate of return that represents the best estimate of a constant rate of return over the expected behavioural life of \ loans given/taken and recognises the effect of potentially different interest rates at various stages and other characteristics of the product life cycle (including prepayments and penalty interest and charges).
This estimation, by nature, requires an element of judgement regarding the expected behaviour and life-cycle of the instruments, as well expected changes to India's base rate and other fee income/expense that are integral parts of the instrument.
Nature and purpose of Reserves 1} General Reserve
Under the ersrwhile Companies Act 1956, general reserve was created through an annual transfer of net income at a specified percentage in accordance with applicable regulations. However, the amount previously transferred to the general reserve can be utilised only in accordance with the specific requirements of Companies Act, 2013
2} Statutory Reserve
Statutory reserve (Statutory Reserve pursuant to Section 45-IC of The RBI Act, 1934): defines that every non banking finance institution which is a Company shall create a reserve fund and transfer therein a sum not less than twenty percent of its net profit every year as disclosed in the statement of profit and loss before any dividend is declared.
Since the company has reported net loss hence no amount were transferred to Statutory reserve for the F.Y 2023-2024
3) Retained Earnings
Retained earnings are the profits that the Company has earned till date, less any transfers to/from other comprehensive income income, or other distributions paid to shareholders if any and less any transfers to Statutory reserve out of current year's profit pursuant to Section 45-IC of the RBI Act, 1934
4) Other Comprehensive Income
Items of Other Comprehensive income represents the fair value changes (both realised/unrealised and net of income tax) in equity instruments irrevocably designated at FVTOCI as per the business model assessment of the Company and are not recycled to profit and loss. However the same can be transferred within equity as permitted by the Ind AS.
Note No.: 34 Other Disclosures
1. Contingent liabilities and commitments (to the extent not provided for)
a) Contingent liabilities:
NIL
b) Commitments:
There are no capital commitments contracted by the Company duringthe period under review C) Other Statutory & Legal Matters
There has been no significant and/or material order(s) passed by any Regulators/Courts/Tribunals impacting the status.
Further the Company received a notice from BSE dated August 10, 2017 regarding issue related to suspected shell company and appointment of forensic auditor thereon. BSE requested to submit various documents from time to time in this regard along with the queries and other information from the Company. The Company replied to all the reasonable queries issued by the BSE.
Further BSE appointed M/s. BDO India LLP, Chartered Accountants to carry out the forensic audit of the Company. Without prejudice to the interests of the Company ,the Company has then from time to time provided all the necessary informations/ documents explanations as required by the forensic auditors and by the Exchange. Within the rights which are available to the Company, the company has sought legal advisory through its Counsels, and represented before the Exchange and the Courts from time to time.
Further BDO India LLP issued a forensic audit report on March 11, 2020 to which the Company has filed its response with BSE and requested the exchange to carry out the fresh forensic audit of the company.
M/s C.P Jain & Co, Chartered Accountants to carry out the fresh forensic audit of the company and the aforesaid audit was completed by the auditors vide their report dated July 8,2023.
Further the Exchange (the 'BSE') wide letter dated Dec 12, 2023 decided the outscome of the aforesaid audit and revoked the restictions imposed on the the Promoters and Directors of the Company, earlier i.e., the Promoters and Directors be permited only to buy the Securties and of the Company and that, they shall not sell their existing holding in the Company passed by the Exchange vide its interim order dated February 15,2018, stand revoked and the reprsentations filed by the Company were accordingly disposed of.
2) MSME
There are no Micro, Small and Medium Enterprises, to whom the Company owes dues, which are outstanding for more than 45 days as at 31st March, 2024,March 2023. This information as required to be disclosed under the Micro, Small and Medium Enterprises Development Act, 2006 has been determined to the extent such parties have been identified on the basis of information available with the Company.
B. Fairvalue hierarchy
(1) The fair value of the financial assets and financial liabilities are 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
(2) The Company uses the following fair value hierarchy for determining and disclosing the fair value of financial instrument:
Level 1: Quoted prices (unadjusted) in active markets for identical assets or liabilities. This category consists of investment in quoted equity shares
Level 2: Inputs other than quoted prices included within Level 1 that are observable for the asset or liability, either directly or indirectly.
Level 3: Inputs for the assets or liabilities that are not based on observable market data (unobservable inputs). Fair values are determined in whole or in part,using a valuation model based on assumptions that are neither supported by prices from observable current market transactions in the same instrument nor are they based on available market data. This level of hierarchy includes Company's investment in equity shares which are unquoted or for which quoted prices are not available at the reporting dates Carrying value of investments in unquoted shares approximates cost at which they are purchased.
There have been no transfer between Level 1 and Level 3 for the years ended 31st March 2024 and 31st March 2023. The following methods and assumptions were used to estimate the fair values Financial instruments measured atfairvalue
(I) Investments carried at fair value are generally based on market price quotations. However in cases where quoted prices are not available than different valuation technique are used by the management for different investments.
Certain investments in equity instruments are not held for trading. Instead, they are held for long term strategic purposes, hence. The Company has chosen to designate these investments in equity instruments at FVOCI since, it provides a more meaningful presentation. Further investments which are held for trading and company considers them as stock in trade are designated through FVTPL Level 1 investments are valued at the quoted closing price on stock exchange. Investments included in Level 3 of the fair value hierarchy have been valued using the cost approach to arrive at their fair value.
Cost of unquoted equity instruments have been considered as an appropriate estimate of fair value because of wide range of possible fair value measurements and cost represents the best estimate of fair value within that range.
Financial instruments not measured at fair value
(ii) Financial assets not measured at fair value include cash and cash equivalents, trade receivables, loans and other financial assets. These are financial assets whose carrying amounts approximate fair value, due to their shortterm nature.
Additionally, financial liabilities such as trade payables and other financial liabilities are not measured at FVTPL whose carrying amounts approximate fair value, because of their short-term nature.
(iii) Management uses its best judgement in estimating the fair value of its financial instruments. However, there are inherent limitations in any estimation technique. Therefore, for substantially all financial instruments, the fair value estimates presented above are not necessarily indicative of the amounts that the Company could have realised or paid in sale transactions as of respective dates. As such, fair value of financial instruments subsequent to the reporting dates may be different from the amounts reported at each reporting date.
Note No.: 35 Risk Management 1) Financial risk management
Risk is an integral part of the Company's business and sound risk management is critical to success. The Company's primary business are reflected based on the principal business carried out i.e. loans and investments (and all other activities of the company revolve around the main business), hence the company is exposed to risks that are particular to its lending and the environment within which it operates and primarily includes credit risk, liquidity risk and market risk.
Since the company is Systematically non-important and non-deposit taking NBFC, and also in terms of Sub -Regulation (5) of Regulation 21 of SEBI (Listing Obligation and Disclosure Requirement), Regulations 2015 as amended, the Company is not required to have Risk Management Committee, but as a prudence the Board of Directors of the Company oversees the overall risk management approach, risk management strategies, procedures and principles.
The senior management provides assurance that the Company's financial risks are identified, measured and managed in accordance with the Company's internal guidelines and risk objectives.
a) Credit Risk
Credit risk is the risk that counter party will not meet its obligations under a financial instrument or customer contract, leading to a financial loss to the Company. The Company's main income generating activty inter-alia is lending to customers and therefore credit risk is a principal risk. Credit risk mainly arises from loans and advances which are in entirety payable on demand.
The credit risk management guideline of the company seeks to have following controls and key metrics that allows credit risks to be identified, assessed, monitored and reported in a timely and efficent manner in compliance with regulatory requirements.
> Standardise the process of identifying new risks and having in place appropriate controls forthese risks
> Maintain an appropriate credit administration and loan review system
> Establish metrics for portfolio monitoring
> Minimize losses due to defaults or untimely payments by borrowers and implementing appropriate risk mitigation techniques.
In order to mitigate the impact of credit risk in the future profitability, the company makes reserves basis the Expected Credit Loss (ECL) Model forthe outstanding loans including interest accrued but not due and interest overdue therein at balance sheet date. Asset classification is as per Reserve Bank of India guidelines and provisions is as per Expected Credit Loss Methodology as per Ind AS, which ever is higher than the minimum required as per prudential norms.
The below discussion describes the Company's approach for assessing impairment as stated in the significant accounting policies.
The mechanics of ECL
Ind AS requires the company to calculate ECL based on probability-weighted scenarios to measure the expected cash shortfalls, discounted at an approximation to the EIR. A cash shortfall is the difference between the cash flows that are due to the Company in accordance with the contract and the cashflows that the company expects to receive. The mechanics of the ECL calculations are outlined below and the key elements are,asfollows:
Probability of default (PD) - The probability of default is an estimate of the likelihood of default over a given
time horizon. A default may only happen at a certain time over the assessed period, if the facility has not been previously derecognised and is still in the portfolio.
Exposure at default (EAD) - The exposure at default is an estimate of the exposure at a future default date.
The outstanding balance (including the interest accrued but not due and interest overdue) at the reporting date is considered EAD by the Company. Since all the loans given by the company are repayable on demand, in this specific of on-demand repayable loan there are two options
1) The borrower is able to pay immediately (if demanded) or
2) The borrower is not able to pay immediately
Hence the company examines whether the borrower has sufficient liquid assets to repay the loan immediately If the borrower has sufficient liquid assets (cash and cash equivalents) to repay the outstanding loan including interest accrued therein, then ECL is close to zero, because probablity of default is zero. The Company considers a financial instrument defaulted and therefore Stage 3 (credit impaired) for ECL. Calculations in all cases when the borrower becomes 90 days past due on its contractual payments.
As a part of the qualitative assessment of whether a customer is in default, the company also considers a variety of instances that may indicate unlikeness to pay. When such events occur, the Company carefully considers whether the event should result in treating the customer as defaulted and therefore assessed as Stage 3 for ECL calculations or whether Stage 2 is appropriate.
Considering that the PD determined above factors in amount at default, there is no separate requirement to estimate EAD. However, the probability of loss (PD) is not zero, if the company assess that the borrower has no sufficient liquid assets to repay the loan when demaded and accordingly the Company estimates the PD based on historical observed default rates adjusted for forward looking estimates, based upon macro-economic developments occuring in the economy and market it operates in and the relationship between key economic trends like GDP, benchmark rates set by the Reserve Bank of India, inflation and most importantly the competitive advantage and disadvantage the company has in comparison to its peergroup(s). Based upon the above facts, the Company has assessed the following PD Percentage as at 31st March, 2024, while PD percentages for 31st March 2023 and on the date of transition remain same at 5%
Category
Loans: Unsecured and repayable on demand
Stage 1: All Standard loans in the above category upto 30 days past due (DPD) are considered as Stage 1 assets for computation of ECL
Stage 2: Exposure under Stage 2 include under-performing loans having 31 to 90 days past due (DPD) for computation of ECL
Stage 3: Exposure under Stage 2 include non-performing loans with overdue more than 90 days past due (DPD).
Probability of default is consistent as mentioned above and LGD are always near to 100% since the loans are unsecured. Further the company is assessing on the continuous basis the likelihood of increased credit risk and reasonable haircuts in view of the Covid-19 pandemic.
Further refer note no 10 which provides information about exposure to credit risk and ECL on loan
Probability of default is consistent as mentioned above and LGD are always near to 100% since the loans are unsecured. Further the company is assessing on the continuous basis the likelihood of increased credit risk and reasonable hair cuts in view of the Covid-19 pandemic.
Further refer note no 10 which provides information about exposure to credit risk and ECL on loan Trade receivables
Trade receivables are non-interest bearing and do not involve significant financing cost further all the receivables are of shortterm in nature, hence transaction value approximates fair value for trade receivables. The Company follows 'simplified approach'for recognition of impairment loss allowance on trade receivables. The application of simplified approach does not require the Company to track changes in credit risk.
An impairment analysis is performed at each balance sheet date on an individual basis for major clients. In addition, number of minor receivables are grouped into homogenous groups and assessed for impairment collectively. Based on Company's past history and the model under which it works, where it obtains most of the revenues on cut off dates or on settlement date, the Company does not provide for loss allowances during the reporting period.
b) Liquidity Risk
Liquidity risk is the risk that the entity will encounter difficulty in meeting the obligations associated with its financial liabilities that are settled by delivering cash or another financial asset. The entity's approach to managing liquidity is to ensure, as far as possible, that it will have sufficient liquidity to meet its liabilities when they are due, under both normal and stressed conditions, without incurring unacceptable losses or risking damage to entity's reputation.
Prudent liquidity risk management requires sufficient cash and marketable securities and availability of funds through adequate committed credit facilities to meet obligations when due and close out market positions.
The Company has a view of maintaining liquidity with minimal risks while making investments. The Company invests its surplus funds in short term liquid assets. The Company monitors its cash and bank balances periodically in view of its short term obligations associated with its financial liabilities.
Refer note 36 for analysis of maturities of financial assets and financial liabilities.
c) Market Risk
Market risk arises when movements in market factors (interest rates, credit spreads, equity prices etc.) impact the Company's income or market value of its portfolios. The Company, in its course of business, is exposed to market risk due to change in equity prices and interest rates. The objective of market risk management is to maintain an acceptable level of market risk exposure while aiming to maximizing returns.
fl) Equity price
The Company's exposure to equity price risk arises primarily on account of investments in equity instruments (both short term and long term). The Company designates its investments in equity instruments based upon its business model. Investments which are held for trading are fair valued through profit and loss, whereas investments which are held for long term and strategic purpose are fair valued through Other comprehensive income. The Company's equity price risk is managed in accordance with the objective of the Company and as approved by the senior management of the Company.
(ii) Interest Rate Risk
The Company is exposed to Interest rate risk if the fair value or future cash flows of its financial instruments will fluctuate as a result of changes in market interest rates. Fair value interest rate risk is the risk of changes in fair values of fixed interest bearing investments because of fluctuations in the interest rates.
The Company's interest rate risk arises from interest bearing deposits with bank and loan given to customers. Such instrument exposes the Company to fair value interest rate risk. Management believes that the interest rate risk attached to these financial assets is not significant due to the nature of these financial assets.
d) Operational And Business Risk
Operational risk is the risk of loss arising from systems failure, human error, fraud or external events, when controls fails to operate effectively, operational risks can cause damage to reputation, have legal or regulatory implications, or lead to financial loss. The Company cannot expect to eliminate all operational risks, but it endeavours to manage these risks through a control framework and by monitoring and responding to potential risks. Controls include effective segregation of duties, access, authorisation and reconciliation procedures, staff education and assessment processes, such as the use of internal audit.
2) Capital Management
The Company's capital management is intended to create value for shareholders by facilitating the meeting of long term and short term goals of the Company. The Company determines the amount of capital required on the basis of recurring business plan coupled with long term and short term Strategic investments and expansion plans.
The funding needs are met through equity, cash generated from operations, short term borrowings and through use of bank overdrafts if required. For the purpose of the Company's capital management, capital includes issued equity capital, and all other equity reserves attributable to the equity shareholders of the Company. The Company's objective when managing capital is to safeguard its ability to continue as a going concern so that it can continue to provide returns to shareholders and other stake holders
The Company manages its capital structure and makes adjustments in light of changes in the financial condition and the requirement of the financial covenants if any. To maintain or adjust the capital structure, the Company may adjust the dividend payment to shareholders, return capital to shareholders (buy back its shares) or issue new shares.
a) Asset classifiation is as per Reserve Bank of India guidelines and provisions is as per Expected Credit Loss methodology as per Ind AS which is higher than minimum required as per prudential norms.
b) As the ECL provisions is higher than provision required under IRACP (Income Recognition, Assets classification &provisioning, there is no requirement to create Impairment allowance reserve.
Note No 37(1)
Additional Regulatory Information
Amended Schedule III requires additional regulatory information to be provided in the financial statements.
These are as follows;
1) Title deeds of Immovable Property
Title deeds of immovable properties in the case of office building are held in the name of the company
2) Revaluation of Property, Plant and Equipment and Right -of- Use Assets
The Company has not revalued any of its Property, Plant and Equipment (including Right-of-Use Assets) during the current reporting period and also reporting period and also for previous year's reporting period
3) Fairvaluation of Investment property
The company has not classified any property as Investment property, hence fair valuation of Investment property by a registered valuer as defined under Rule 2 of Companies (Registered Valuers and Valuation) Rules, 2017 does not arise
4) Intangible Assets under development
The Company does not have any intangible assets under development during the current and previous year reporting period
5) Details of Benami Property held: Additional Disclosure
The Company does not hold any Benami Property and hence there were no proceedings initiated or pending against the Company for holding any benami property under the Benami Transactions (Prohibitions) Act, 1988 and the Rules made thereunder, hence no disclosure is required to be given as such.
6) Capital Work in Progress
The Company does not have any capital work in progress during the current and previous year reporting period
7) Loans or advances to specified persons
The Company has granted loans to related parties (as defined under the Companies Act, 2013) either severally or jointly with any other person, that are repayable on demand
Refer note no 34 (6) and Note 10 for further details.
8) Undisclosed Income
The Company does not have any undisclosed Income which was not recorded in the books of accounts and which 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. Also the Company does not have previously unrecorded income and related assets which were required to be properly recorded in the books of accounts duringthe year.
9) Borrowings secured against current assets
The Company does not have any borrowings from banks or financial institutions on the basis of security of current assets hence no disclosure is required as such
10) Wilful Defaulter
The Company has not been declared as wilful defaulter by any bank or financial institution or government or any government authority or any lender as at the date of the balance sheet or on the date of approval of the financial statements.
11) Relationship with Struck off Companies
The Company does not have any transactions with Companies which are struck off under Section 248 of the Companies Act, 2013 or Section 560 of the Companies Act, 1956, hence no disclosure is required as such
12) Registeration of Charges or Satisfaction with Registrar of Companies (ROC)
There are no charges against the companies which are yet to be registered or satisfaction yet to be registered with ROC beyond the statutory period, hence no disclosures are required as such
13) Compliance with number of layers of companies
The Company does not have investment in any downstream companies for which it has to comply with the number of layers prescribed under Clause (87) of Section 2 of the Companies Act, 2013 read with Companies (Restriction on number of layers) Rules, 2017, hence no disclosure is required as such
14) Utilization of Borrowings
The Company does not have any outstanding balances towrads the borrowings from banks and financial institutions at the balance sheet date, hence nofurther disclosure is required as such
15) Utilization of Borrowed Funds and Share Premium
(A) 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 person(s) or entity(ies), including foreign entities (intermediaries) with the understanding (whether recorded in writing or otherwise ) that the intermediary shall;
a) Directly or indirectly lent or invest in other person(s) or entity(ies) 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. Hence no disclosure is required as such.
(B) The Company has not received any fund from any person(s) or entity(ies), including foreign entities (Funding Parties) with the understanding (whether recorded in writing or otherwise) that the company shall;
a) Directly or indirectly lend or invest in other person(s) or entity(ies) identified in any manner whatsoever by or on behalf of the unding Party (Ultimate Beneficiaries) Or
b) Provide any guarantee, security or the like to or on behalf of the Ultimate Beneficiaries. Hence no disclosure is required as such.
16) Details of Crypto Currency Or Virtual Currency
The Company has not traded or invested in Crypto Currency or Virtual Currency during the financial year, hence disclosure requirmentsforthe ame is not applicable
17) Corporate Social Responsibility Activities
The Company is not required to comply with the provisions of Section 135 of the Companies Act, 2013
NOTES:
1. As defined in paragraph 2 (1) (xii) of the Non- Banking Financial Companies Acceptance of Public Deposits (Reserve bank) Directions, 1998.
2. Provisioning Norms shall be applicable as prescribed in Non-Systemically Important Non-Banking Financial (Non-Deposit Accepting or Holding) Companies Prudential Norms (Reserve Bank) Directions, 2007.
3. All Accounting Standards and Guidance Notes issued by ICAI are applicable including for valuation of Investments and other asset as also assets acquired in satisfaction of debts. Flowever, market value in respect of quoted investment and break-up/ fair value/ NAV in respect of unquoted investment should be disclosed irrespective of whether they are classified as long term or current in (4) above.
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