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You can view the entire text of Notes to accounts of the company for the latest year

BSE: 521064ISIN: INE064C01022INDUSTRY: Textiles - Spinning - Cotton Blended

BSE   ` 39.55   Open: 39.85   Today's Range 39.50
40.15
-0.23 ( -0.58 %) Prev Close: 39.78 52 Week Range 31.18
52.85
Year End :2023-03 

a) Non Convertible debentures

*The non-convertible debentures are secured against pledge of receipt of bank deposit of Rs. 275.0 million. (refer note 5 and note 42-I(B))

#The non-convertible debentures were secured by way of first ranking pari-passu charge by way of mortgage (shared between the Debentures Trustee and Existing Lenders) on the mortgaged properties, first ranking pari-passu charge by way of hypothecation (shared between the Debentures Trustee and Existing Lenders) on the movable fixed assets and second ranking pari-passu charge by way of hypothecation (as shared between the Debentures Trustee and the Existing Lenders) on the hypothecated assets (excluding the moveable fixed assets) of the Company as defined in trust deed.

As per debenture trustee deed, the Debenture holder had the right to either reset the interest rate type from fixed to floating and to increase the effective rate of interest on the NCD w.e.f. November 3, 2022 or in the event, the same is not acceptable to the Company, the put option would be deemed to be exercised by the Debenture Holder and the Company had to repay the entire outstanding along with all dues payable to Debenture Holder on November 3, 2022.

During the current year, the Debenture holder of the Company has requested to increase the effective rate of interest on the NCD w.e.f. November 3, 2022. However the Company on the basis of approval of the Financial Management Committee has exercised the put option and accordingly the Company has repaid the entire outstanding amount of NCDs on November 2, 2022. (refer note 42-II (B)

b) Term loans

Term loans from banks are secured by way of equitable mortgage created or to be created on all the present and future immovable properties including land, buildings, structures, all plant and equipment attached thereon of the Company related to the specific capital project completed/in progress and hypothecation of all the movable properties including movable machinery, spares, tools and accessories, etc., present and future, subject to prior charges created and / or to be created in favour of the Company's bankers on stocks of raw materials, semi finished and finished goods, consumable stores and other movable assets excluding vehicles specifically hypothecated against vehicle loans, as may be required for working capital requirements in the ordinary course of business. The mortgages and charges referred to above are pari-passu among the lenders. (refer note 42-I(A) and 42-II (A)). The amount disclosed as above is net of Current maturities of long-term debts - secured of Rs. 179.4 million (Previous year Rs. 163.6 million).

The interest rates range from 6.25% to 9.80% per annum (Previous year 6.65% to 8.80% per annum) before Interest subsidy under Technology Upgradation Fund Scheme from State Government of Madhya Pradesh.

c) Vehicles loans

Vehicle loans were secured by hypothecation of vehicles acquired against such loans (refer note 42(C) for repayment terms).The amount disclosed as above is net of Current maturities of long-term debts - secured of Rs. Nil (Previous year Rs. 5.0 million).

The interest rates range from Nil (Previous year 7.40% to 8.80% per annum).

For the current maturities of long-term borrowings, refer note 18 short term borrowings.

Cash credit/export packing credit/working capital loans from banks

Cash credit/export packing credit/working capital loans from banks are secured by hypothecation of raw materials, semi finished and finished goods, consumable stores, other movable assets excluding vehicles specifically hypothecated against vehicle loans and book debts, present and future, of the Company.

The interest rates for cash credit/export packing credit/working capital loans from banks range from 4.95% to 8.50% (Previous year 4.75% to 7.30% per annum) before subvention.

The Company has been sanctioned working capital limits from banks during the year on the basis of security of current assets of the Company. The revised quarterly returns/statements filed by the Company for each quarter with such banks are in agreement with the books of accounts of the Company.

A. Contingent Liabilities under service tax of Rs. 67.0 million (Previous year Rs. 66.7 million) represents:

i) Demand and penalty of Rs. 66.7 million (Previous year Rs. 66.7 million) for service tax under reverse charge basis on commission paid to non-executive Directors for the financial year 2014-15 to 2016-17. During the previous year, the Company had filed an appeal before CESTAT Ludhiana.

ii) Demand and penalty of Rs. 0.3 million (Previous year Rs Nil) for service tax under reverse charge basis on notice pay recovery for the financial year 2017-2018. During the current year, the Company has filed an appeal against the same.

B. Contingent liabilities under Income Tax Act, 1961 of Rs. 34.4 million (Previous year Rs.23.0 million) include:

(i) Rs. 6.1 million (Previous year Rs. 6.1 million) being penalties under Section 271(1)(c) of Income Tax Act, 1961 levied for

assessment years 2004-2005 and 2006-2007.

(ii) Other disputed demands of Rs. 28.30 million pertaining to assessment year 2015-2016, 2016-2017 and 2019-2020 (Previous year Rs. 16.9 million pertaining to assessment year 2013 -14, 2015-16, 2016-17,2018-19 and 2019-2020).

* These matters are subject to legal proceedings in the ordinary course of business. In the opinion of the management, legal proceedings when

ultimately concluded will not have a material effect on the results of operations or financial position of the Company. Based on the favourable orders in

similar matters and based on the opinion of legal counsel of the Company, the Company has a good chance of winning the cases.

C. There are numerous interpretative issues relating to the Supreme Court (SC) judgement on PF dated 28th February, 2019. As a matter of caution, the Company has applied the judgement on a prospective basis from the date of the SC order. The Company will update its provision for the period prior to the Supreme Court judgement, on receiving further clarity on the subject.

NOTE 35 - EMPLOYEE BENEFITS

a) Defined contribution plans

The Company makes contribution towards employees' provident fund scheme. Under the scheme, the Company is required to contribute a specified percentage of salary, as specified in the rules of the scheme. The Company has recognised Rs. 264.8 million during the year (Previous year Rs. 286.7 million) as expense towards contribution to this plan. An amount of Rs. 9.1 million (Previous year Rs. 2.6 million) has been included under Property, plant and equipment / Capital work in progress. Further amount of Rs. 0.3 million (Previous year Rs. 0.6 million) and Rs. 0.1 million (Previous year Rs. 0.3 million) has been reimbursed under Deen Dayal Upadhay Gramin Kaushal Yojna and Scheme for Capacity Building in Textile Sector (Samarth Scheme) respectively.

b) Defined benefit plans

Gratuity scheme

The Company has a defined gratuity plan (funded) and the Gratuity plan is governed by The Payment of Gratuity Act 1972 (“Act"). Under the Act, employees who have completed five years of service are entitled for gratuity benefit of 15 days salary for each completed year of service or part thereof in excess of six months. The amount of benefit depends on respective employee's salary, the years of employment and retirement age of the employee and the gratuity benefit is payable on termination/retirement of the employee. There is no maximum limit for the payment of gratuity benefit. The present value of obligation is determined based on an actuarial valuation as at the reporting date using the Projected Unit Credit Method.

The fund has the form of an irrevocable trust and it is governed by Board of Trustees. The Board of trustees is responsible for the administration of the plan assets and for the definition of investment strategy. The scheme is funded with qualifying insurance policies. The Company is contributing to trusts towards the payment of premium of such gratuity schemes

(VII) Actuarial risks

Through its defined benefit plans, the Company is exposed to a number of risks, the most significant of which are detailed below:

Interest rate risk

The defined benefit obligation calculated uses a discount rate based on government bonds. If bond yields fall, the defined benefit obligation will tend to increase.

Salary Inflation risk

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

Demographic risk

This is the risk of variability of results due to unsystematic nature of decrements that include mortality, withdrawal, disability and retirement. The effect of these decrements on the defined benefit obligation is not straight forward and depends upon the combination of salary increase, discount rate and vesting criteria. It is important not to overstate withdrawals because in the financial analysis the retirement benefit of a short career employee typically costs less per year as compared to a long service employee.

NOTE 40 - SEGMENT INFORMATION

I Segment accounting policies:

a. Product and Services from which reportable segment derive their revenues (Primary Business Segments)

Upto the previous year, the Company had identified two business segments namely Textiles (Yarn, Towel, Bedsheets) and Paper and Chemical. During the current year, the Board of Directors has reviewed the Textiles Segment and considering the nature and class of product included therein, has decided to present Yarn, Towel and Bedsheets as three separate business segments instead of one Textiles business segment on the basis that such segmentation would be more useful to users of the Company's financial statements in terms of the requirements of Ind AS 108.

Accordingly, due to change in composition of reportable segments, as stated above, the corresponding items of segment information for previous year have been restated and presented in these standalone Ind AS financial statements. The Company has identified the following business segments which comprises of:

- Yarn

- Towel

- Bedsheets

- Paper and Chemicals

b. Geographical segments (secondary business segments)

The geographical segments considered and reviewed by Chief Operating Decision Maker for disclosure are based on markets, broadly as under:

India

USA

Rest of the world

c. Segment accounting policies

Segment accounting policies: In addition to the significant accounting policies applicable to the business segment as set out in note 2, the accounting policies in relation to segment accounting are as under:

i. Segment assets and liabilities:

Segment assets include all operating assets used by a segment and consist principally of cash, debtors, inventories, right of use assets and property, plant and equipment including capital work in progress, net of allowances and provisions, which are reported as direct offset in the balance sheet. Segment liabilities include all operating liabilities and consist principally of creditors and accrued liabilities.

ii Segment revenue and expenses:

Joint revenue and expenses of segments are allocated amongst them on reasonable basis. All other segment revenue and expenses are directly attributable to the segments.

iii Inter segment sales:

Inter segment sales are accounted for at cost plus appropriate margin (transfer price) and are eliminated in consolidation.

iv Segment results :

Segment results represent the profit before tax earned by each segment without allocation of central administration costs, other non operating income as well as finance costs. Operating profit amounts are evaluated regularly by the Chief Operating Decision Maker in deciding how to allocate resources and in assessing performance.

NOTE 41 - LEASES

The Company has Lease contracts for Land, office premises, guest houses and factory premises (including plant and equipment). Leases of office premises, guest houses and factory premises (including plant and equipment) generally have lease terms ranging from 11 months to 20 years and leases of lands generally have lease terms between 30-99 years. The Company's obligations under its leases are secured by the lessor's title to the leased assets. Generally, the Company is restricted from assigning and subleasing the leased assets. There are several lease contracts that include extension and termination options.

The Company also has certain leases of office premises and guest houses with lease terms of 12 months or less. The Company applies

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For maturity analysis of lease liability, refer note 45 Financial risk management framework and policies under maturities of financial liabilities.

The Company had total cash outflows for leases of Rs. 65.1 million (previous year: Rs. 56.6 million). There are no future cash outflows relating to leases that have not yet commenced.

There are no leases having variable lease payments. The Company has not entered into any residual value contracts during the year. There are no sale and leaseback transactions during the year.

Extension and termination options are included in a number of leases. These are used to maximise operational flexibility in terms of managing the assets used in the Company's operations. The majority of extension and termination options held are exercisable only by the Company and not by the respective lessor.

Payments associated with short-term leases are recognised on a straight-line basis as an expense in the Statement of Profit and Loss. Short-term leases are leases with a lease term of 12 months or less. The Company did not have any leases impacted by Covid-19 related rent concession amendment.

NOTE 43 - EMPLOYEES‘ STOCK OPTION PLANS

The Board of Directors and the Shareholders of the Company have approved a Scheme called as “Trident Limited Employee Stock Options Scheme - 2020 (“ ESOS Scheme”) and “Trident Limited Employee Stock Purchase Scheme - 2020“ (“ ESPS Scheme”) in their meeting held on July 9, 2020 and May 16, 2020 respectively. Pursuant to the ESOS Scheme, the Company has constituted Trident Limited Employees Welfare Trust ('Trust') to acquire, hold and allocate/transfer equity shares of the Company to eligible employees (as defined in the ESOS and ESPS scheme) from time to time on the terms and conditions specified under the ESOS Scheme and ESPS Scheme.

The said trust had purchased, during the financial year 2020-21, Company's equity shares aggregated to 100,000,000 equity shares from the secondary open market at cost of Rs. 7.50 per share for which the Company had given loan to trust amounting to Rs. 751.0 million. The financial statements of the Trust have been included in the standalone Ind AS financial statements of the Company in accordance with the requirements of Ind AS and cost of such treasury shares has been presented as a deduction in other equity. Such number of equity shares (which are lying with trust) have been reduced while computing basic and diluted earnings per share.

(A) Trident Employees Stock Options Scheme, 2020

The Company had granted 66,00,000 stock options under the ESOS Scheme on November 12, 2022. Each option granted and vested under the Scheme shall entitle to the holder to acquire 1 equity share of Re. 1 each.

Based on various judicial prouncements and opinion obtained by the Company from experts, the Company has taken allowance of share based payment expense while computing income tax provision for the current year.

During the current year, nomination and remuneration committee (“NRC") has approved the winding-up of Trident Limited Employee Stock Purchase Scheme - 2020 and approved the excess monies or shares remaining with the Trust after meeting all the obligations, if any, to be utilised for repayment of loan to Trident Limited. Accordingly, during the current year, Trust has sold 18,293,707 shares and proceeds from transfer of shares has been utilised for the repayment of loan to the Company.

Based on approval of NRC, for remaining 62,328,640 Equity Shares, the Company is seeking approval of shareholders of the Company for implementation of Trident Limited General Employee Benefits Scheme - 2023 by transferring remaining shares from Trident Limited Employee Stock Purchase Scheme - 2020 to Trident Limited General Employee Benefits Scheme - 2023. The Company has also obtained expert opinion on compliance in this regard.

NOTE 45 - FINANCIAL INSTRUMENTS

Capital management

For the purpose of Company's capital management, capital includes Issued equity capital and alt reserves attributable to equity holders of the Company.

The Company's capital management objectives are:

- to ensure the Company's ability to continue as a going concern

- to provide an adequate return to shareholders by pricing products and services commensurately with the level of risk."

The Company manages capital risk in order to maximize shareholders' profit by maintaining sound/optimal capital structure through monitoring of financial ratios, such as net debt-to-equity ratio on a monthly basis and implements capital structure improvement plan when necessary. There is no change in the overall capital risk management strategy of the Company compared to last year.

The management assessed that fair value of trade receivables, cash and cash equivalents, other bank balances, other current financial assets (except derivative financial assets), short term borrowings, trade payables and other current financial liabilities (except derivative financial liabilities) approximate their carrying amounts largely due to short-term maturities of these instruments.

The fair value of the financial assets and 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.

Fair value hierarchy

The following table provides an analysis of financial instruments that are measured subsequent to initial recognition at fair value, grouped into Level 1 to Level 3, as described below

Level 1: 'Quoted prices in an active market: This level of hierarchy includes financial instruments that are measured by reference to quoted prices (unadjusted) in active markets for identical assets or liabilities.

Level 2: 'Valuation techniques for which the lowest level input that is significant to the fair value measurement is directly or indirectly observable. This level of hierarchy include Company's over-the-counter (OTC) derivative contracts and mutual funds.

Level 3: Valuation techniques for which the lowest level input that is significant to the fair value measurement is unobservable.

Financial Risk Management Framework

The Company's principal financial liabilities, other than derivatives, comprise loans and borrowings, lease liabilities, trade and other payables. The main purpose of these financial liabilities is to finance the Company's operations. The Company's principal financial assets include trade and other receivables, receivables from government authorities, security deposits and cash and cash equivalents that derive directly from its operations. The Company also holds investments and enters in to derivative transactions.

The Company's corporate treasury function provides services to the business, co-ordinates access to domestic and international financial markets, monitors and manages the financial risks relating to the operations of the Company through internal risk reports which analyse exposures by degree and magnitude of risks. These risks include market risk (including currency risk, interest rate risk and other price risk), credit risk and liquidity risk.

The Company seeks to minimise the effects of these risks by using derivative financial instruments to hedge risk exposures. The Company does not enter into or trade financial instruments, including derivative financial instruments, for speculative purposes.

The Chief financial officer reports quarterly to the Board of Directors of the Company for monitoring risks and reviewing policies implemented to mitigate risk exposures.

Credit risk

Credit risk arises when a counterparty defaults on its contractual obligations to pay resulting in financial loss to the Company. The Company has adopted a policy of only dealing with creditworthy counterparties and obtaining sufficient collateral, where appropriate, as a means of mitigating the risk of financial loss from defaults. The Company has also taken export credit insurance for mitigation of export credit risk for certain parties.

The maximum exposure to the credit risk at the reporting date is primarily from trade receivables amounting to Rs. 2,720.2 million and Rs. 5,285.3 million as of March 31,2023 and March 31, 2022, respectively. Trade receivables consist of a large number of customers, spread across diverse industries and geographical areas. Credit risk has always been managed by the Company through credit approvals, establishing credit limits and continuously monitoring the credit worthiness of customers to which the Company grants credit terms in the normal course of business and by way of taking credit insurance against export receivables.

(i) Liquidity risk management

The Company's objective is to maintain optimum levels of liquidity to meet its cash and collateral requirements at all times.

The Chief Financial Officer of the Company is responsible for liquidity risk management and the Company has established an appropriate liquidity risk management framework for the management of the Company's short, medium and long-term funding and liquidity management requirements. Liquidity risk is managed by maintaining adequate reserves, banking facilities and reserve borrowing facilities, by continuously monitoring forecast and actual cash flows, and by matching the maturity profiles of financial assets and liabilities. The Chief Financial Officer reports the same to the Board of Directors on quarterly basis."

Market risk is the risk that the fair value or future cash flows of a financial instrument will fluctuate because of changes in market prices. Market risk comprises two types of risk: currency risk and interest rate risk. Financial instruments affected by market risk includes loan and borrowings, lease liabilities and derivative financial instruments. The objective of market risk management is to manage and control market risk exposures within acceptable parameters, while optimising the return. The Company uses derivatives to manage market risks. Derivatives are only used for economic hedging purposes and not as speculative investments. All such transactions are carried out within the guidelines set by the Board of Directors and Risk Management Committee.

There has been no significant changes to the Company's exposure to market risk or the methods in which they are managed or measured.

Currency Risk

Foreign currency risk is the risk that the fair value or future cash flows of an exposure will fluctuate because of changes in foreign exchange rates. The Company undertakes transactions denominated in foreign currencies; consequently, exposures to exchange rate fluctuations arise. The Company's exposure to currency risk relates primarily to the Company's operating activities when transactions are denominated in a different currency from the Company's functional currency.

The Company manages its foreign currency risk by hedging transactions that are expected to occur within a maximum 12 month period for hedges of forecasted sales.

For the year ended March 31, 2023, every 1 percent depreciation/appreciation in the exchange rate against USD, might have affected the Company's incremental margins (profit as a percentage to revenue) approximately by 0.43%. The Company's exposure to foreign currency changes for all other currencies is not material.

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 debt obligations with floating interest rates. The borrowings (excluding non convertible debentures) as at March 31, 2023 is Rs. 13,491.1 million (previous year Rs. 14,770.1 million) which are interest bearing and interest rates are variable.

Interest rate sensitivity

For the year ended March 31, 2023, every 1 percentage increase/decrease in weighted average bank interest rate might have affected the Company's incremental margins (profit as a percentage to revenue) approximately by 0.23% (previous year 0.15%).

Price risk

The Company's investments in other funds are susceptible to market price risk arising from uncertainties about future values of the investment securities. The Company manages the price risk through diversification and by placing limits on individual and total equity instruments. Reports on the portfolio are submitted to the Company's senior management on a regular basis.

At the reporting date, the exposure in other funds is Rs.3.7 million (previous year Rs. 9.8 million). A decrease or increase in NAV of 5% could have an impact of approximately of Rs.0.2 million (previous year Rs. 0.5 million) on the profit or loss.

Derivatives not designated as hedging instruments

The Company uses forward currency contracts and option currency contracts to hedge its foreign currency risks. Derivative contracts not designated by management as hedging instruments are initially recognised at fair value on the date on which a derivative contract is entered into and are subsequently re-measured at fair value on each reporting date. Such contracts are entered into for periods consistent with exposure of the underlying transactions.

Derivatives designated as hedging instruments

The Company enters into hedging instruments in accordance with policies as approved by the Board of Directors with written principles which is consistent with the risk management strategy of the Company.

The critical terms of the foreign currency forward contracts match the terms of the expected highly probable forecast sale transactions. As a result, no hedge ineffectiveness arises requiring recognition through profit or loss.

The cash flow hedges of the forecasted sale transactions during the year ended March 31, 2023 were assessed to be highly effective and unrealised loss of Rs. 13.9 million (Previous year Rs. 119.9 million, with a deferred tax charge of Rs. 3.5 million (Previous year Rs. 30.2 million) relating to the hedging instruments, is included in other comprehensive income.

Valuation Technique

The Company enters into derivative financial instruments with various counterparties, principally banks and financial instiutions with investment grade credit ratings. Foreign exchange forward and option contracts are valued using valuation techniques, which employs the use of market observable inputs. The most frequently applied valuation techniques include forward pricing models, using present value calculations. Where quoted market prices are not available, fair values are based on management's best estimates, which are arrived at by the reference to market prices.

(a) Pursuant to approval granted by Union Cabinet on July 14, 2021 (notified on August 13, 2021), for continuation of Rebate of State and Central taxes and Levies (RoSCTL) with the same rates as notified by Ministry of Textiles vide Notification dated March 08, 2019 on exports of Apparel/Garments and Made-ups, during the previous year, the Company had accrued the export benefits of RoSCTL of Rs. 579.3 million pertaining to the eligible export sales for the period from January 1,2021 to March 31,2021.

Further, the Central Government had also notified Remission of Duties and Taxes on Exported Products (RoDTEP) Scheme Guidelines and Rates for other textile products vide Notification dated August 17, 2021. Accordingly, during the previous year, the Company had accrued the benefits under the aforesaid scheme amounting to Rs. 30.9 million on eligible export sales for the period from January 1,2021 to March 31 2021.

Hence, revenue from operations for the year ended March 31,2022 includes Rs. 610.2 million on standalone basis for the period from January 1,2021 to March 31, 2021.

(b) During the previous year, Company had accrued the benefits under the aforesaid schemes amounting to Rs. 2,844.1 million (net of discount of Rs. 579.3 million). Due to lower realization of e-Scrips (received/receivable under RoSCTL and RoDTEP schemes), the Company had reduced the value of such export benefits by the amount of prevailing discount on e-Scrips amounting to Rs. 392.5 million on outstanding e-Scrips as at March 31,2022.

Due to favourable realization of e-Scrips (received/receivable under RoSCTL and RoDTEP schemes) during the year, revenue from operations for the year ended March 31,2023 includes Rs. 228.6 million, being the amount of additional realisation of e-Scrips outstanding as on March 31, 2022.

NOTE 52

During the current year, the Company has acquired Trident Home Textiles Limited ('THTL') on December 1, 2022 which holds 24.5% equity shares of Trident Global Inc. ('TGI') (earlier associate of the Company). Pursuant to the acquisition of THTL, the Company holds 73.5% equity shares of TGI (directly and indirectly) and accordingly, TGI has become a subsidiary of the Company w.e.f. December 1, 2022. Further, during the current year, the Company has acquired 100% share of Trident Innovations Limited on July 22, 2022 and has subscribed for share capital in wholly owned subsidiary company Trident Home Decor Limited on June 22, 2022.

NOTE 53

On April 05, 2021, a major fire broke out in the Cotton warehouse located in the manufacturing facilities at Budhni, Madhya Pradesh, however the fire had not caused any disturbance in the day to day operations of the said facilities. The fire had resulted in major damage of stocks of cotton lying in the cotton warehouse and its building. During the previous year, the Company had received the insurance claim and accounted for loss on account of fire of H 73.5 million.

NOTE 54

The Code on Social Security, 2020 ('Code') relating to employee benefits during employment and post-employment benefits received Presidential assent in September 2020. The Code has been published in the Gazette of India. However, the date on which the Code will come into effect has not been notified. The Company will assess the impact of the Code when it comes into effect and will record any related impact in the period when the Code becomes effective.

NOTE 55 - Other Statutory Information

(i) The Company does not have any Benami property, where any proceeding has been initiated or pending against the Company for holding any benami property.

(ii) The Company does not have any transactions with companies struck off.

(iii) The Company does not have any charges or satisfaction which is yet to be registered with ROC beyond the statutory period,

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

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

(a) directly or indirectly lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the company (Ultimate Beneficiaries) or

(b) provide any guarantee, security or the like to or on behalf of the Ultimate Beneficiaries

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

(a) directly or indirectly lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the Funding Party (Ultimate Beneficiaries) or

(b) provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries,

(vii) The Company does not have any such transaction which is not recorded in the books of account 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

Notes :

1. The above statement also indicates performance and financial position of each of the Subsidiary and Associate Companies.