1) The title deeds of all the immovable properties (other than properties where the Company is the lessee and the lease agreements are duly executed in favour of the lessee), as disclosed in Note 3 on Property, plant and equipment and Note 5 on Other Intangible Assets to the financial statements, are held in the name of the Company.
2) Land for Oragadam plant in Chennai is obtained on 99 years of lease basis from State Industrial Promotion corporation of Tamilnadu Limited (SIPCOT), a Government of Tamilnadu enterprises. The total cost of Lease hold land is amortised over a period of 99 years. Accordingly a sum of Rs. 12.06 Lacs (Previous year Rs. 12.06 Lacs) is amortised during the period.
3) There is no change in the carrying value of Assets on the account of Revaluation of Assets.
4) Capital expenditure incurred on R & D Centre:
* During the previous year 2022-23, the Company had acquired 26% stake in Clean Max Astria Pvt Ltd for a total consideration of Rs. 396.01 Lakhs. Further, the Company has also entered in a Power Purchase Agreement (‘PPA') with Clean Max to procure 100% of the output of solar energy produced for next 25 years as per the rates negotiated in the PPA. Further, in the event of termination of the contracts or completion of the PPA term, the Company will receive fair market value of its investment on the date of termination/ completion of the project. As the Company has significant influence, the investment has been accounted as investment in associate as per Ind AS 28 - Investments in associates and joint ventures.
** During the year 2023-24, pursuant to the NCLT, Ahmedabad order dated 12.10.2023 under Insolvency and Bankruptcy Code, 2016, the company has infused Rs.138.15 Crores into AACL through a mix of equity of Rs.5.00 Crores and inter corporate loan of Rs.133.15 Crores for the acquisition of AACL. By subscribing 50 Lacs equity shares of Face Value of Rs.10/- each in AACL, it became wholly owned subsidiary company of SSWL, w.e.f. 09.01.2024.
1) The Company has entered into an agreement for purchase of land admeasuring 304 kanals approx at village Bir Farozari, Distt. Panchkula, at cost of Rs. 133.00 Lacs for setting up an auto component unit. The Land has not yet been registered in the name of Company . Pending the same , the advance of Rs. 35.00 Lacs paid by the Company has been shown as advances recoverable and being under legal suit, a provision for the same has been made.
2) There are no outstanding loans/advances in nature of loan to Promoters, Key Management Personnel, Director, and Related Party (other than mentioned in Note-14) of the Company.
b) Rights, Preferences and restrictions attached to shares
The Company has issued only one class of shares i.e. equity shares of face value Rs.1/- each. All equity shares rank pari passu and carry equal rights with respect to voting and dividend. The dividend proposed by the board of directors is subject to the approval of the shareholders in the ensuing Annual General Meeting, except in the case of interim dividend.
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 number of equity shares held by the shareholders. Further, the company has not issued any preference shares until now.
1. During the financial year 2023-24, the Company has allotted 416125 equity shares of Face Value of Rs. 1/- each under “Steel Strips Wheels Ltd-Employee Stock Option Scheme 2021 (ESOS 2021)”. Consequently, paid up equity share capital of the Company has been increased from Rs.15,65,13,200/- to Rs.15,69,29,325/-. Therefore, the % of shareholding of certain promoters has slightly reduced as on 31.03.2024. In addition to this, the % change in the shareholding of Smt. Sunena Garg, Promoter of the Company is on account of disposal of equity shares in the open market as well as aforesaid increase in the paid up equity share capital of the company.
2. **Steel Strips Ltd(SSL),promoter group company, had amalgamated into SAB Industries Ltd. as per NCLT order dt. 06.10.2021. Thus, SSL does not exist as on date. However, as at March 31,2023, the name of SSL has been shown above because as per Company's member register SSL is holding 3000 shares of FV Rs.1/- each (before sub division 600 shares of FV Rs. 5/- each) whereas SSL has sold these shares long back and the purchaser did not lodge the same in his own name. Further, during the FY 2023-24, these shares standing in the name of SSL have been transferred to Investor Education and Protection Fund(IEPF) since dividend on these shares was unpaid/unclaimed for 7 consecutive years. As a result, its name and shares have not been shown in the table above as on 31.03.2024.
3. Munak Financiers Pvt. Ltd have originally sold 400 equity shares(after sub-division 2022: 4000 equity shares) long back, but not yet lodged by the purchasers in public category with the Company. These shares are still standing in its name in physical form in company's member register.
Nature and purpose of Reserves(i) Securities premium
Securities premium is used to record the premium on issue of shares. The reserve can be utilised only for limited purposes in accordance with the provisions of the Companies Act, 2013.
(ii) Retained earnings
Retained earnings are the profits that the Company has earned/incurred till date, less any transfers to general reserve, dividends or other distributions paid to shareholders. Retained earnings include re-measurement loss / (gain) on defined benefit plans, net of taxes that will not be reclassified to Statement of Profit and Loss.
(iii) Share Options Outstanding reserve
The share options-based payment reserve is used to recognise the grant date fair value of options issued to employees under Employee stock option plan.
(iv) General Reserve
Under the erstwhile Companies Act 1956, general reserve was created through an annual transfer of net income at a specified percentage in accordance with applicable regulations. The purpose of these transfers was to ensure that if a dividend distribution in a given year is more than 10% of the paid-up capital of the Company for that year, then the total dividend distribution is less than the total distributable results for that year. Consequent to introduction of Companies Act 2013, the requirement to mandatorily transfer a specified percentage of the net profit to general reserve has been withdrawn. However, the amount previously transferred to the general reserve can be utilised only in accordance with the specific requirements of Companies Act, 2013.
(v) Capital revaluation reserve
Cumulative gains and losses arising on revaluation of Fixed assets measured at market value are recognised in capital revaluation reserve. The reserve balance represents such changes recognised net of amounts reclassified to retained earnings on disposal of such assets.
(vi) Equity instruments through other comprehensive income
The Company has elected to recognise changes in the fair value of certain investments in equity securities in other comprehensive income. These changes are accumulated within the Equity instrument through other comprehensive income reserve within retained earnings.
Notes:
I) 1st pari passu charge by way of hypothecation of entire current asset constituted of raw materials, stock in process, finished goods, consumable stores, book debts, bills whether documentary or clean outstanding monies, receivables both present and future of the company. During the year the company has filed quarterly returns or statements with the banks in lieu of the sanctioned working capital facilities, which are in agreement with the books of accounts.
2nd pari-passu charge is on entire Fixed Assets of the company other than exclusively charged.
II) The Company do not have any charges or satisfaction of charges which is yet to be registered with ROC beyond the statutory period.
III) The Company has not made any default in the repayment of loans to banks and other financial institutions including interest thereon.
IV) The term loans have been used for the purpose for which they were obtained and funds raised for a short term basis have not been used for long term purposes.
Foreign Currency Loan
Buyer credit/RA Financing/Suppliers Credit loans are secured by way of lien on Non-Funds based Working Capital Limits and counter indemnity of the company.
1) The transactions with related parties are made on terms equivalent to those that prevail in arm's length transactions. Outstanding balances at the year-end are unsecured and interest free except the interest bearing loan given to subsidiary company. The settlement for these balances occurs through payment. The Company has not recorded any impairment of receivables relating to amounts owed by related parties for the year ended 31st March 2024 and 31st March 2023. This assessment is undertaken each financial year through examining the financial position of the related party and the market in which the related party operates.
2) Inter corporate Loan of Rs.133.15 crores given to wholly owned subsidiary “AACL” (Refer Note 6**). Interest recoverable amounting to Rs.2.41 crores (Rs.2.17 crores net of TDS) on the said loan.
3) There are no outstanding loans/advances in nature of loan to Promoters, Key Management Personnel, Director, and Related Party (other than mentioned in Point 2 above) of the Company.
Note:- 43. Post Retirement Benefits Plans (Ind AS 19)Defined Benefit Plan
The Company provides for gratuity for employees as per the Payment of Gratuity Act, 1972. Employees who are in continuous service for a period of 5 years are eligible for gratuity. The amount of gratuity payable on retirement/termination is the employees last drawn basic salary per month computed proportionately for 15 days salary multiplied for the number of years of service. For the funded plan the Company makes contributions to recognised funds in India. The Company does not fully fund the liability and maintains a target level of funding to be maintained over a period of time based on estimations of expected gratuity payments.
A) PRIMARY SEGMENT (BUSINESS SEGMENT)
A business segment is a distinguishable component of an enterprise that is engaged in providing an individual product or service or a group of related products or services and that is subject to risks and returns that are different from those of other business segments. The Company's Operation predominantly comprise of only one segment i.e Automotive Wheels. In view of the same, separate segmental information is not required to be given as per the requirements of IND AS 108 “Operating Segments”
B) SECONDARY SEGMENT (GEOGRAPHICAL SEGMENT)
The analysis of geographical segment is based on the geographical location of the customers. The Company operates primarily in India and has presence in international markets as well. Its business is accordingly aligned geographically, catering to two markets. The Company has considered domestic and exports markets as geographical segments and accordingly disclosed these as separate segments.
F) Nature of CSR activities undertaken by the Company:
The CSR initiatives of the Company aim towards inclusive development of the communities largely around the vicinity of its plants and corporate office and at the same time ensure environmental protection through a range of structured interventions in the areas of Promotion of education, providing special life skills to mentally challenged children, sanitation and cleanliness, healthcare facilities including preventive health care, rural development, ensuring environment sustainability and Green area development, agriculture development, promotion of nationally recognized sports and Olympic sports.
G) There is no unspent amount at the end of the year to be deposited in specified fund of Schedule VII under Section 135(5) of the Companies Act, 2013.
H) Since there were no ongoing projects of the company in the FY 2023-24, no amount is required to be transferred to a special account in compliance of Section 135(6) of Companies Act, 2013.
Notes:
* During the financial year 2022-23, an amount of Rs.101.83 lakhs was spent in excess towards the Company's CSR obligation for the FY 2022-23 which was available for set-off with the Company's CSR obligation for the FY 2023-24. Thus, the net CSR obligation of the Company for the FY 2023-24 was Rs. 316.09 lakhs.
** During the financial year 2021-22, an amount of Rs.6.19 lakhs was spent in excess towards the Company's CSR obligation which was available for set-off with the Company CSR obligation for the FY 2022-23. Thus, the net CSR obligation of the Company for the FY 2022-23 was Rs. 250.60 lakhs.
Note: 46. Securities and Terms of repayments for Secured Long term borrowings
I) Nature of Securities
a) Rupee Term Loans/ Foreign currency term loan/ NBFC
Term Loans from banks, financial institutions and others are secured / to be secured by equitable mortgage created/ to be created by deposit of title deeds of the Company's immovable properties for Dappar (In Punjab),Oragadam (In Chennai) & Seraikella (In Jharkhand) in addition to the deed of hypothecation charging Company's moveable properties, both present and future and second charge created / to be created on raw materials, semi-finished goods, consumable stores, finished goods and book debts etc on paripassu basis. However in regard to term loan taken from Banks/Financial Institutions for Mehsana (Gujarat) project, the said loan will be secured (first charge) through equitable mortgage by deposit of title deeds of the Company's immovable properties situated at Mehsana (in Gujarat) and Second pari passu charge on all other immovable properties, movable properties and current assets situated at Dappar (In Punjab), Oragadam (In Chennai) unit, & Seraikella (In Jharkhand).
Loan of Rs.100 crores taken from HDFC Bank for acquisition of AMW Autocomponent to be secured on exclusive charge on AACL assets along with corporate guarantee issued by AACL.
All secured loans are further secured by personal guarantee of Managing Director of the Company.
Note 47. Employee stock option plan
Share Reserved for Issue under Options outstanding as at the end of the year on unissued share capital
As on 1st April, 2023, the company had 2 (two) ongoing Employee Stock Options Schemes i.e Steel Strips Wheels Limited- Employee Stock Option Scheme, 2016 (ESOS 2016) and Steel Strips Wheels Limited- Employee Stock Option Scheme, 2021 (ESOS 2021).
1. Steel Strips Wheels Limited- Employee Stock Option Scheme, 2016 (ESOS 2016)
The Company has implemented an Employee Stock Option Scheme (ESOS) titled as “Steel Strips Wheels Limited-Employee Stock Option Scheme 2016” (“ESOS 2016” or “the Scheme”) in accordance with the Securities and Exchange Board of India (Share Based Employee Benefits) Regulations, 2014 which was approved by the Board of Directors and subsequently by shareholders of the Company in their 30th Annual General Meeting (AGM) held on 30.09.2016, authorizing the company to create, offer, issue and grant, in one or more tranches, upto 1,00,000 options to the employees of the company. As per the terms of the scheme, all the options granted on any date shall vest not earlier than 1 (one) year and not later than a maximum of 4(four) years from the respective date of grant of options as may be determined by Employee Compensation Committee (ECC). Further, the Exercise Price is Rs. 200/- per share and the Exercise period would commence from the date of vesting and will expire on completion of 5 years from the respective dates of grant of options. Pursuant
to the terms of the said Scheme, the Company had granted 87350 options from time to time to employees of the Company. Each option would entitle the holder thereof to subscribe one equity share of face value (FV) Rs. 10/- each at an exercise price of Rs. 200/- per equity share of the company. As decided by the ECC, the vesting period for the said 87350 options granted was one year from the respective dates of grant. Exercise period would commence from the date of vesting and will expire on completion of 5 years from the respective dates of grant of options.
Since the inception of the scheme, a total of 43750 options have been exercised by the option holders from time to time and consequently, equivalent number of equity shares have been allotted until the close of financial year 2021-22. Further, pursuant to the approval of the shareholders at their 35th Annual General Meeting of the Company held on 30.09.2021, each equity share of FV of Rs.10/- was subdivided into 2( two) equity shares of FV of Rs. 5/- each, with effect from the record date i.e. 22.11.2021. Accordingly, the number of all outstanding stock options (vested but not exercised and unvested stock options) i.e. 43600 options, the number of stock options available for future grant(s) and the exercise price thereof were proportionately adjusted. Thus, after this adjustment, the number of all outstanding stock options (vested but not exercised and unvested stock options) were increased from 43600 options to 87200 options convertible into equal number of equity shares of FV Rs. 5/- each at an exercise price of Rs. 100/- per share.
Later, during the financial year 2022-23, 83700 options each convertible into one equity share of FV Rs. 5/- each were exercised by the option holders and consequently, equivalent number of shares of FV Rs. 5/- each have been allotted on 10.06.2022. Further, pursuant to the approval of the shareholders at their 36th Annual General Meeting of the Company held on 30.09.2022, each equity share of FV of Rs. 5/-was sub-divided into 5(five) equity shares of FV of Rs. 1/- each, with effect from the record date i.e. 11.11.2022. Accordingly, the number of all outstanding stock options (vested but not exercised and unvested stock options) i.e. 3500 options, the number of stock options available for future grant(s) and the exercise price thereof was proportionately adjusted. Thus, after this adjustment, the number of all outstanding stock options (vested but not exercised and unvested stock options) were increased from 3500 options to 17500 options convertible into equal number of equity shares of FV Rs. 1/- each at an exercise price of Rs. 20/- per share.
Furthermore, during the financial year 2023-24, all the outstanding 17500 vested stock options granted under ESOS 2016 were forfeited by the ECC in its meeting held on 16.03.2024. These outstanding vested stock options were forfeited as the employees to whom these options were granted have left the company.
In addition to above, the ECC in its meeting held on 16.03.2024 have also approved the closure of the “Steel Strips Wheels Limited-Employees Stock Option Scheme, 2016” (ESOS 2016) w.e.f. 16.03.2024.
2. Steel Strips Wheels Limited- Employee Stock Option Scheme, 2021 (ESOS 2021)
The Company also has an another Employee Stock Option Scheme (ESOS) titled as “Steel Strips Wheels Limited - Employee Stock Option Scheme, 2021” (“ESOS 2021” or “the scheme”) in accordance with the Securities and Exchange Board of India (Share Based Employee Benefits and Sweat Equity) Regulations, 2021 which was approved by the Board of Directors and subsequently by shareholders of the Company in their Annual General Meeting (AGM) held on 30.09.2021, authorizing the company to create, offer, issue and grant, in one or more tranches, up to 10,00,000 options (adjusted figure post 1st sub-division as approved in the AGM held on 30.09.2021) to the employees of the company. As per the terms of the Scheme, all the options granted on any date shall vest not earlier than 1 (one) year and not later than a maximum of 4 (four) years from the respective date of grant of options as may be determined by Employee Compensation Committee (ECC) and each option would entitle the holder thereof to subscribe one equity share of face value (FV) Rs. 5/- each at an exercise price as may be determined by the ECC/ Board of Directors of the Company. Further, the exercise period would commence from the date of vesting and will expire on completion of 5 years from the date of grant of options.
Further, pursuant to the approval of the shareholders at their 36th Annual General Meeting of the Company held on 30.09.2022, each equity share of FV of Rs. 5/- was sub-divided into 5(five) equity shares of FV of Re. 1/- each, with effect from the record date i.e., 11.11.2022. Till the said record date, the company had not granted any stock options under ESOS 2021. Accordingly, the number of stock options available for future grant(s) have increased from 10,00,000 to 50,00,000 options convertible into equal number of equity shares of FV Rs. 1/- each at an exercise price as may be determined by the ECC/ Board of Directors of the Company.
Furthermore, on 17.11.2022, 5,00,000 options (Tranche 1) were granted to the employees of the Company. Each option would entitle the holder thereof to subscribe one equity share of FV Re. 1/- each at an exercise price of Rs. 20/- per share of the company. As per the terms of the Scheme, all the options granted on any date shall vest not earlier than 1(one) year and not later than a maximum of 4(four) years from the respective date of grant of options as may be determined by ECC. As decided by the ECC, the vesting period for the said 5,00,000 options granted is one year from the date of grant. Exercise period would commence from the date of vesting and will expire on completion of 5 years from the respective date of grant of options.
During the financial year 2023-24, 416125 options, each convertible into one equity share of FV Rs. 1/- each, were exercised by the option holders and consequently, equivalent number of equity shares of FV Rs. 1/- each were allotted by the Allotment Committee of the Board of
Directors in its meeting held on 12.12.2023 under the ESOS 2021. Additionally, the ECC in its meeting held on 16.03.2024 have forfeited 4750 options out of total outstanding stock options granted under Tranche 1 of ESOS 2021, as the employees to whom these options were granted have left the company.
Furthermore, the ECC in its meeting held on 16.03.2024 have granted 2,00,000 (Tranche 2) stock options to eligible employees of the Company in accordance with ESOS 2021. Each option shall entitle the holder to acquire one (1) equity share of face value Re. 1/- each of the Company at an exercise price of Rs. 20/- per equity share. The Options granted shall vest after completion of one(1) year from the date of grant i.e. on 16.03.2025 and exercise period would commence from date of vesting and will expire on completion of 5 years from the date of grant.
3. Impact of fair Valuation method on Net Profit under EPS
In March 2005, the Institutes of Chartered Accountants of India had issued a guidance note on “Accounting for Employees Share based payments” applicable to Employee based share plan, the grant date in respect of which falls on or after April 1,2005. The said guidance notes requires the Pro-forma Disclosures of the impact of fair value method of accounting of Employee stock Compensation accounting in the financial statements. Applying the fair value based method defined in the said guidance note the impact on the reported net profit and earning per share would be as follows:
ESOS 2021 Method of valuation-Fair value method
The Company has calculated the employee compensation cost using the fair value method of accounting to account for the options granted under and “ESOS 2021” therefore there will not be any impact on profits and EPS of the company.
4. Weighted Average fair value of options granted under ESOS 2016 during the year : NA (No additional options were granted during the year).
5. Weighted Average fair value of options granted under ESOS 2021 during the year : Rs. 222.23 per stock option (convertible into each equity share of Face Value Re. 1/-).
6. The fair Value of the Options, is estimated on the date of grant using the Black-Scholes Model with the following significant assumptions.
The volatility of the options is based on the historical volatility of the share price applicable to the total expected life of each option.
7. No Shares out of the issued, subscribed and paid up Share Capital were allotted as Bonus Shares in the last five years by capitalization of Securities Premium Reserves.
8. No Shares out of the issued , subscribed and paid up Share Capital were allotted in the last five years pursuant to the various scheme of amalgamation without payment being received in cash.
Note:- 48. Financial risk management objectives and policies
The Company's principal financial liabilities comprise loans and borrowings, trade and other payables. The main purpose of these financial liabilities is to finance the Company's operations and to support its operations. The Company's financial assets include loans, trade and other receivables, and cash & cash equivalents that derive directly from its operations.
The Company is exposed to market risk, credit risk and liquidity risk. The company's senior management oversees the management of these risks. The company's senior management is supported by a Business Risk Management committee that advises on financial risks and the appropriate financial risk governance framework for the Company. This Business Risk Management committee provides assurance to the Company's senior management that the Company's financial risk activities are governed by appropriate policies and procedure and that financial risks are identified, measured and managed in accordance with the Company's policies and risk objectives. The Board of Directors reviews and agrees policies for managing each risk, which are summarised as below:
Market risk a) Price Risk
Fluctuation in commodity price in global market affects directly and indirectly the price of raw material and components used by the Company in its products. The key raw material for the Company's business is HR Steel & Aluminium Ingot. The Company has arrangements with its major customers for passing on the price impact. The Company is also regularly taking initiatives like VA VE ( value addition, value engineering ) to reduce its raw material costs to meet targets set up by its customers for cost downs.
b) Interest rate risk
Interest rate risk is the risk that the fair value or future cash flows of a financial instrument will fluctuate because of changes in market interest rates. The Company's exposure to the risk of changes in market interest rates relates primarily to the Company's long term debt obligations with floating interest rates. The Company is carrying its borrowings primarily at variable rate.
Interest rate sensitivity
For the Purpose of computing interest rate sensitivity on the above borrowings, management has estimated a reasonably possible change in interest rate as 50bps based on current as well as expected economic conditions. This analysis is based on Long Term Risk exposures outstanding at the reporting date and assumes that all other variables, in particular foreign currency exchange rates, remains constant. The period and balances are not necessarily representative of the average amounts outstanding during the periods.
d) Credit risk
The credit risk is the risk of financial loss to the Company if a customer or counterparty to a financial instrument fails to meet its contractual obligations towards the Company and arises principally from the Company's receivables from customers and deposits with banking institutions. The maximum amount of the credit exposure is equal to the carrying amounts of these receivables.
The Company has developed guidelines for the management of credit risk from trade receivables. The Company's primary customers are major Indian automobile manufacturers (OEMs) with good credit ratings. Non-OEM clients are subjected to credit assessments as a precautionary measure, and the adherence of all clients to payment due dates is monitored on an on-going basis, thereby practically eliminating the risk of default. The Company has deposited liquid funds at various banking institutions. Primary banking institutions are major Indian and foreign banks. In long term credit ratings these banking institutions are considered to be investment grade. Also, no impairment loss has been recorded in respect of fixed deposits that are with recognised commercial banks and are not past due
e) Liquidity risk
The liquidity risk encompasses any risk that the Company cannot fully meet its financial obligations. To manage the liquidity risk, cash flow forecasting is performed in the operating divisions of the Company and aggregated by Company finance. The Company's finance monitors rolling forecasts of the Company's liquidity requirements to ensure it has sufficient cash to meet operational needs while maintaining sufficient headroom in its undrawn committed borrowing facilities / overdraft facilities at all times so that the Company does not breach borrowing limits or covenants (where applicable) on any of its borrowing facilities.
Note:- 49 Capital Management a) Risk Management
The Company's objectives when managing capital is to safeguard their ability to continue as a going concern, so that they can continue to provide returns for shareholders and benefits for other stakeholders, and maintain an optimal capital structure to reduce the cost of capital. Consistent with peers in the industry, the Company monitors Net Debt to EBITDA ratio i.e. Net Debt (Total Borrowings net of Cash and Cash Equivalents) divided by EBITDA (Profit before tax plus depreciation and amortization expense plus Finance costs).
The Company's strategy is to ensure that the Net Debt to EBITDA is managed at an optimal level considering the above factors. The Net Debt to EBITDA ratios were as follows:
Notes:
I) Pursuant to section 115BAA of Income Tax Act, 1961, the Company has opted for lower tax rates beginning current financial year. Consequent to this, the Company has calculated tax for the current year and re-measured its deferred tax liability basis rates prescribed in section and credited consequential impact in deferred taxes for the current year amounting to Rs 25.19 Crores. Further the Company has MAT Credit entitlement of Rs 22.58 crores as on 31st March 2023 which have been booked as Tax expense in the current year.
II) Effective tax rate has been calculated on profit before tax.
NOTE 53 ADDITIONAL REGULATORY INFORMATION REQUIRED BY SCHEDULE III OF COMPANIES ACT, 2013
I) The Company does not have any Benami Property where any proceedings have been initiated or are pending against the Company for holding benami property under the Benami Transactions (Prohibition) Act, 1988 (45 of 1988) and Rules made there under.
II) The Company has not been declared wilful defaulter by any bank or financial institution or government or any government authority.
III) The Company do not have any balance with the companies struck off under section 248 of Companies Act, 2013 or section 560 of Companies Act, 1956.
IV) The Company has complied with the number of layers prescribed under the Companies Act, 2013.
V) The Company has not entered into any scheme of arrangement which has an accounting impact on current or previous financial year.
VI) The Company has not advanced or loaned or invested funds to any other person or entity, 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 group (Ultimate Beneficiaries) or
b. provide any guarantee, security or the like to or on behalf of the ultimate beneficiaries.
The Company has not received any fund from any person or entity, 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.
(VII) The Company does not have any such 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 provision of the Income Tax Act, 1961).
(VIII) The Company has not traded or invested in crypto currency or virtual currency during the current or previous year.
(IX) The Company has not revalued its property, plant and equipment (including right-of-use assets) or intangible assets or both during the current or previous year.
(X) The Company does not have any charges or satisfaction which are yet to be registered with the Registrar of Companies beyond the statutory period.
(XI) The borrowings obtained by the Company from banks and financial institutions have been applied for the purposes for which such loans were taken.
NOTE 54-Other
The Company has established a comprehensive system of maintenance of information and documents as required by the transfer pricing legislation under section 92-92F of the Income Tax Act, 1961. Since the law requires existence of such information and umentation to be contemporaneous in nature, the Company is in the process of updating the documentation for the transactions entered into with the associated enterprises during the financial year and expects such records to be in existence latest by due date as required under the law. The management is of the opinion that its transactions with the associated enterprises are at arm's length so that the aforesaid legislation will not have any impact on the financial statements, particularly on the amount of tax expense and that of provision for taxation.
The accompanying notes form an integral part of these financial statements (1-54)
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