11. Provisions, Contingent Liabilities and
Assets

Provisions are recognised when the Company
has a present legal or constructive obligation
as a result of past events, it is probable that an
outflow of resources will be required to settle
the obligation and the amount can be reliably
estimated. Provisions are not recognised for
future operating losses.

Provisions are measured at the present value of
management's best estimate of the expenditure
required to settle the present obligation at the
end of the reporting period. The discount rate
used to determine the present value is a pre-tax
rate that reflects current market assessments
of the time value of money and the risks specific
to the liability. The increase in the provision
due to the passage of time is recognised as
interest expense.

Where it is not probable that an outflow of
economic benefits will be required, or the
amount cannot be estimated reliably, the
obligation is disclosed as a contingent liability,
unless the probability of outflow of economic
benefits is remote. Possible obligations,
whose existence will only be confirmed by the
occurrence or non-occurrence of one or more
future uncertain events not wholly within the
control of the company, are also disclosed as
contingent liabilities unless the probability of
outflow of economic benefits is remote.
Contingent Assets are not recognized in the
financial statements. However, when the
realization of income is virtually certain, then
the related asset is not a contingent asset and
its recognition is appropriate.

Mines Restoration Provision

An obligation for restoration, rehabilitation and
environmental costs arises when environmental
disturbance is caused by the development or
ongoing extraction from mines. Costs arising
from restoration at closure of the mines and
other site preparation work are provided for
based on their discounted net present value,
with a corresponding amount being capitalised
at the start of each project. The amount
provided for is recognised, as soon as the
obligation to incur such costs arises. These
costs are charged to the Statement of Profit
and Loss over the life of the operation through
the depreciation of the asset and the unwinding
of the discount on the provision. The costs
are reviewed periodically and are adjusted to
reflect known developments which may have
an impact on the cost or life of operations.

The cost of the related asset is adjusted for
changes in the provision due to factors such as

updated cost estimates, new disturbance and
revisions to discount rates. The adjusted cost
of the asset is depreciated prospectively over
the lives of the assets to which they relate. The
unwinding of the discount is shown as a finance
cost in the Statement of Profit and Loss.

12. Revenue Recognition

The Company derives revenues primarily from
sale of Cement and allied products.

Ind AS 115 "Revenue from Contracts with
Customers" provides a control-based revenue
recognition model and provides a five step
application approach to be followed for
revenue recognition.

• Identify the contract(s) with a customer;

• Identify the performance obligations;

• Determine the transaction price;

• Allocate the transaction price to the
performance obligations;

• Recognise revenue when or as an entity
satisfies performance obligation.

The disclosure of significant accounting
judgements, estimates and assumptions
relating to revenue from contracts with
customers are provided in Note 27.

Revenue from contracts with customers is
recognised when control of the goods or
services are transferred to the customer at
an amount that reflects the consideration to
which the Company expects to be entitled in
exchange for those goods or services. The
Company has generally concluded that it is
the principal in its revenue arrangements,
except for the agency services, because it
typically controls the goods or services before
transferring them to the customer.

Revenue excludes amounts collected on behalf
of third parties.

Sale of goods

For sale of goods, revenue is recognised
when control of the goods has transferred at
a point in time i.e. when the goods have been
delivered to the specific location (delivery).
Following delivery, the customer has full
discretion over the responsibility, manner of
distribution, price to sell the goods and bears
the risks of obsolescence and loss in relation
to the goods. A receivable is recognised by the
Company when the goods are delivered to the
customer or their agent as this represents the
point in time at which the right to consideration
becomes unconditional, as only the passage
of time is required before payment is due. The
Company considers the effects of variable
consideration, the existence of significant

financing components, non cash consideration
and consideration payable to the customer(if
any).

Revenue towards satisfaction of a performance
obligation is measured at the amount of
transaction price (net of variable consideration)
allocated to that performance obligation.

The transaction price of goods sold is net of
variable consideration on account of various
discounts and schemes offered by the
Company as part of contract.

Variable consideration

This includes incentives, volume rebates,
discounts etc. It is estimated at contract
inception considering the terms of various
schemes with customers and constrained until
it is highly probable that a significant revenue
reversal in the amount of cumulative revenue
recognised will not occur when the associated
uncertainty with the variable consideration is
subsequently resolved. It is reassessed at end
of each reporting period.

Significant financing component

The Company receives short-term advances
from its customers. Using the practical
expedient in Ind AS 115, the Company does not
adjust the promised amount of consideration
for the effects of a significant financing
component if it expects, at contract inception,
that the period between the transfer of the
promised good or service to the customer
and when the customer pays for that good or
service will be one year or less.

Contract balances
Trade receivables

A receivable represents the Company's
right to an amount of consideration that is
unconditional (i.e., only the passage of time is
required before payment of the consideration
is due). Refer to accounting policies of
financial assets Financial instruments - initial
recognition and subsequent measurement.

Contract liabilities

A contract liability is the obligation to transfer
goods or services to a customer for which
the Company has received consideration (or
an amount of consideration is due) from the
customer. If a customer pays consideration
before the Company transfers goods or
services to the customer, a contract liability is
recognised when the payment is made or the
payment is due (whichever is earlier). Contract
liabilities are recognised as revenue when the
Company performs under the contract.

Cost to obtain a contract

The Company pays sales commission to its
selling agents for each contract that they obtain
for the Company. The Company has elected to
apply the optional practical expedient for costs
to obtain a contract which allows the Company
to immediately expense sales commissions
(included in advertisement and sales promotion
expense under other expenses) because
the amortization period of the asset that the
Company otherwise would have used is one
year or less.

Costs to fulfil a contract i.e. freight, insurance
and other selling expenses are recognized as an
expense in the period in which related revenue
is recognised

Critical judgements

The Company's contracts with customers
include promises to transfer goods to the
customers. Judgement is required to determine
the transaction price for the contract. The
transaction price could be either a fixed
amount of customer consideration or variable
consideration with elements such as schemes,
incentives, cash discounts, etc. The estimated
amount of variable consideration is adjusted in
the transaction price only to the extent that it is
highly probable that a significant reversal in the
amount of cumulative revenue recognised will
not occur and is reassessed at the end of each
reporting period.

Costs to obtain a contract are generally
expensed as incurred. The assessment of this
criteria requires the application of judgement, in
particular when considering if costs generate or
enhance resources to be used to satisfy future
performance obligations and whether costs are
expected to be recovered.

Other revenue streams
Interest Income

For all financial asset measured at amortised
cost interest income is recorded using the
effective interest rate (EIR). EIR is the rate
that exactly discounts the estimated future
cash payments or receipts over the expected
life of the financial instrument or a shorter
period, where appropriate, to the gross
carrying amount of the financial asset or to
the amortised cost of a financial liability. When
calculating the effective interest rate, the
Company estimates the expected cash flows
by considering all the contractual terms of the
financial instrument (for example, prepayment,
extension, call and similar options) but does not
consider the expected credit losses. Interest
income is included in Other income in the
statement of profit and loss.

13. Government Grants and Subsidies

Grants from the government are recognised
at their fair value where there is a reasonable
assurance that the grant will be received
and the Company will comply with all
attached conditions.

Government grants that compensate the
Company for expenses incurred are recognised
in profit or loss as income on a systematic
basis in the periods in which the expense
is recognised.

Government grants relating to the purchase of
property, plant and equipment are included in
non-current liabilities as deferred income and
are credited to profit or loss on a straight-line
basis over the expected lives of the related
assets and presented within other income.

When loans or similar assistance are provided
by governments or related institutions, with
an interest rate below the current applicable
market rate, the effect of this favourable interest
is regarded as a government grant. The loan or
assistance is initially recognised and measured at
fair value and the government grant is measured
as the difference between the initial carrying
value of the loan and the proceeds received.

The loan is subsequently measured as per the
accounting policy applicable to financial liabilities.

14. Employee benefits

(i) Short term employee benefits

Short-term employee benefits are expensed
as the related service is provided. A liability
is recognised for the amount expected to be
paid if the Company has a present legal or
constructive obligation to pay this amount as a
result of past service provided by the employee
and the obligation can be estimated reliably.

Accumulated compensated absences which
are expected to be settled wholly within twelve
months after the end of the period in which
the employees render the related service are
treated as short-term benefits. The Company
measures the expected cost of such absences
as the additional amount that it expects to pay
as a result of the unused entitlement that has
accumulated at the reporting date.

(ii) Defined contribution plans

Obligations for contributions to defined
contribution plans are expensed as the related
service is provided. The company has following
defined contribution plans:

a) Provident fund

The Company makes specified monthly
contributions towards Provident Fund and

Employees State Insurance Corporation
('ESIC'). The contribution is recognized as
an expense in the Statement of Profit and
Loss during the period in which employee
renders the related service.

b) Superannuation scheme

Certain employees of the Company
are eligible for participation in defined
contribution plans such as superannuation.
Contributions towards these funds are
recognized as an expense periodically
based on the contribution by the Company,
since Company has no further obligation
beyond its periodic contribution.

(iii) Defined benefit plans

The company's net obligation in respect of
defined benefit plans is calculated separately
for each plan by estimating the amount of
future benefit that employees have earned in
the current and prior periods, discounting that
amount and deducting the fair value of any
plan assets.

The calculation of defined benefit obligations
is performed annually by a qualified actuary
using the projected unit credit method. When
the calculation results in a potential asset for
the company, the recognised asset is limited
to the present value of economic benefits
available in the form of any future refunds from
the plan or reductions in future contributions
to the plan. To calculate the present value of
economic benefits, consideration is given to
any applicable minimum funding requirements.

Remeasurement of the net defined benefit
liability, which comprise actuarial gains and
losses, the return on plan assets (excluding
interest) and the effect of the asset ceiling
(if any, excluding interest), are recognised
immediately in Other Comprehensive Income.
Net interest expense (income) on the net
defined liability (assets) is computed by
applying the discount rate, used to measure the
net defined liability (asset), to the net defined
liability (asset) at the start of the financial year
after taking into account any changes as a
result of contribution and benefit payments
during the year. Net interest expense and other
expenses related to defined benefit plans are
recognised in profit or loss.

When the benefits of a plan are changed or
when a plan is curtailed, the resulting change in
benefit that relates to past service or the gain or
loss on curtailment is recognised immediately
in profit or loss. The company recognises gains
and losses on the settlement of a defined
benefit plan when the settlement occurs.

The company has following defined
benefit plans:

Gratuity

The company provides for its gratuity liability
based on actuarial valuation of the gratuity
liability as at the Balance Sheet date, based on
Projected Unit Credit Method, carried out by
an independent actuary and contributes to the
Gratuity Trust fund formed by the Company.

The contributions made are recognized as
plan assets. The defined benefit obligation
as reduced by fair value of plan assets
is recognized in the Balance Sheet. Re¬
measurements are recognized in the Other
Comprehensive Income, net of tax in the year in
which they arise.

(iv) Other long-term employee benefits

The Company's net obligation in respect of
long-term employee benefits is the amount
of future benefit that employees have earned
in return for their service in the current and
prior periods. That benefit is discounted to
determine its present value. Re-measurements
are recognised in profit or loss in the period in
which they arise.

15. Foreign currency transactions

Transactions in foreign currencies are
translated into the Company's functional
currency at the exchange rates at the dates of
the transactions.

Monetary assets and liabilities denominated
in foreign currencies are translated into the
functional currency at the exchange rate at
the reporting date. Non-monetary assets
and liabilities that are measured at fair value
in a foreign currency are translated into the
functional currency at the exchange rate when
the fair value was determined. Non-monetary
items that are measured based on historical
cost in a foreign currency are translated at the
exchange rate at the date of the transaction.
Foreign currency differences are generally
recognised in profit or loss.

16. Borrowing Cost

Borrowing costs directly attributable to the
acquisition, construction or production of
an asset that necessarily takes a substantial
period of time to get ready for its intended use
or sale are capitalised as part of the cost of the
asset. All other borrowing costs are expensed
in the period in which they occur. Borrowing
costs consist of interest and other costs that an
entity incurs in connection with the borrowing
of funds. Borrowing cost also includes
exchange differences to the extent regarded as
an adjustment to the borrowing costs.

17. Taxes

Tax expense comprises current and
deferred tax. It is recognised in profit or loss
except to the extent that it relates to items
recognized directly in equity or in Other
Comprehensive Income.

Current tax

Current tax comprises the expected tax
payable or receivable on the taxable income or
loss for the year and any adjustment to the tax
payable or receivable in respect of previous
years. It is measured using tax rates enacted or
substantively enacted at the reporting date.

Current income tax relating to items recognised
outside profit or loss is recognised outside
profit or loss (either in other comprehensive
income or in equity). Current tax items are
recognised in correlation to the underlying
transaction either in OCI or directly in equity.
Management periodically evaluates positions
taken in the tax returns with respect to
situations in which applicable tax regulations
are subject to interpretation and establishes
provisions where appropriate.

Current tax assets and liabilities are offset only
if, the Company:

a) Has a legally enforceable right to set off
the recognised amounts; and

b) Intends either to settle on a net basis,
or to realise the asset and settle the
liability simultaneously.

Deferred tax

Deferred tax is recognised in respect of
temporary differences between the carrying
amounts of assets and liabilities for financial
reporting purposes and the amounts used
for taxation purposes. Deferred tax is not
recognised for temporary differences on the
initial recognition of assets or liabilities in a
transaction that is not a business combination
and that affects neither accounting nor taxable
profit nor loss and does not give rise to equal
taxable and deductible temporary differences.

Deferred tax assets are recognised for unused
tax losses, unused tax credits and deductible
temporary differences to the extent that it
is probable that future taxable profits will be
available against which they can be used.
Deferred tax assets are reviewed at each
reporting date and are reduced to the extent
that it is no longer probable that the related
tax benefit will be realised; such reductions are
reversed when the probability of future taxable
profits improves.

Unrecognized deferred tax assets are
reassessed at each reporting date and

recognised to the extent that it has become
probable that future taxable profits will be
available against which they can be used.
Deferred tax is measured at the tax rates
that are expected to be applied to temporary
differences when they reverse, using tax
rates enacted or substantively enacted at the
reporting date.

The measurement of deferred tax reflects the
tax consequences that would follow from the
manner in which the company expects, at the
reporting date, to recover or settle the carrying
amount of its assets and liabilities.

The carrying amount of deferred tax asset is
reviewed on each reporting date.

Deferred tax assets and liabilities are offset
only if:

a) The entity has a legally enforceable right to
set off current tax assets against current
tax liabilities; and

b) The deferred tax assets and the deferred
tax liabilities relate to income taxes levied
by the same taxation authority on the same
taxable entity.

Minimum alternate tax (MAT) paid in a year is
charged to the statement of profit and loss as
current tax for the year. The deferred tax asset
is recognised for MAT credit available only to
the extent that it is probable that the concerned
company will pay normal income tax during
the specified period, i.e., the period for which
MAT credit is allowed to be carried forward. In
the year in which the company recognizes MAT
credit as an asset, it is created by way of credit
to the statement of profit and loss and shown
as part of deferred tax asset. The company
reviews the "MAT credit entitlement" asset at
each reporting date and writes down the asset
to the extent that it is no longer probable that it
will pay normal tax during the specified period.

Goods and service taxes (GST) paid on
acquisition of assets or on incurring
expenses

Expenses and assets are recognised net
of the amount of goods and service taxes
paid, except:

• when the tax incurred on a purchase of
assets or services is not recoverable from
the taxation authority, in which case, the
tax paid is recognised as part of the cost
of acquisition of the asset or as part of the
expense item, as applicable.

• when receivables and payables are stated
with the amount of tax included.

The net amount of tax recoverable from, or
payable to, the taxation authority is included as

part of other current assets or liabilities in the
balance sheet.

18. Leases

The Company assesses at contract inception
whether a contract is, or contains, a lease. That
is, if the contract conveys the right to control
the use of an identified asset for a period of
time in exchange for consideration.

Company as a lessee

The Company applies a single recognition and
measurement approach for all leases, except
for short-term leases and leases of low-
value assets. The Company recognises lease
liabilities to make lease payments and right-
of-use assets representing the right to use the
underlying assets.

i) Right-of-use assets

The Company recognises right-of-use
assets at the commencement date of the
lease (i.e., the date the underlying asset is
available for use). Right-of-use assets are
measured at cost, less any accumulated
depreciation and impairment losses, and
adjusted for any remeasurement of lease
liabilities. The cost of right-of-use asset
includes the amount of lease liabilities
recognised, initial direct costs incurred,
and lease payments made at or before
the commencement date less any lease
incentives received. Right-of-use assets
are amortised over their actual lease
period as per lease deed.

Leasehold Land and Building is amortised
over the primary lease period.

Mining Land is depleted according to the
'unit of production' method by reference to
the ratio of extraction of limestone in the
year to the related reserves of limestone.

Limestone reserves are estimated by
the management based on the internal
best estimates or independent expert's
valuation as considered appropriate. These
estimates are reviewed atleast annually.

The right-of-use assets are also subject
to impairment. Refer to the accounting
policies in Note 19 section-impairment of
non- financial assets.

ii) Lease Liabilities

At the commencement date of the lease,
the Company recognises lease liabilities
measured at the present value of lease
payments to be made over the lease
term. The lease payments include fixed
payments (including in substance fixed
payments) less any lease incentives
receivable, variable lease payments that
depend on an index or a rate, and amounts
expected to be paid under residual value
guarantees. The lease payments also
include the exercise price of a purchase
option reasonably certain to be exercised
by the Company and payments of penalties
for terminating the lease, if the lease term
reflects the Company exercising the option
to terminate. Variable lease payments
that do not depend on an index or a rate
are recognised as expenses (unless they
are incurred to produce inventories) in the
period in which the event or condition that
triggers the payment occurs.

In calculating the present value of
lease payments, the Company uses its
incremental borrowing rate at the lease
commencement date because the interest
rate implicit in the lease is not readily
determinable. After the commencement
date, the amount of lease liabilities
is increased to reflect the accretion
of interest and reduced for the lease
payments made. In addition, the carrying
amount of lease liabilities is remeasured
if there is a modification, a change in the
lease term, a change in the lease payments
(e.g., changes to future payments resulting
from a change in an index or rate used
to determine such lease payments) or a
change in the assessment of an option to
purchase the underlying asset.

iii) Short-term leases and leases of low-
value assets

The Company applies the short-term lease
recognition exemption to its short-term
leases of wharehouses, machinery and
equipment (i.e., those leases that have a
lease term of 12 months or less from the
commencement date and do not contain
a purchase option). It also applies the
lease of low-value assets recognition
exemption to leases of office equipment
that are considered to be low value. Lease
payments on short-term leases and leases
of low-value assets are recognised as
expense on a straight-line basis over the
lease term.

19. Impairment of non-financial assets

At each reporting date, the Company reviews
the carrying amounts of its non-financial assets
(other than inventories and deferred tax assets)
to determine whether there is any indication on
impairment. If any such indication exists, then
the asset's recoverable amount is estimated.

For impairment testing, assets are grouped
together into the smallest group of assets that
generates cash inflows from continuing use
that are largely independent of the cash inflows
of other assets or Cash Generating Units
('CGUs').

The recoverable amount of an asset or CGU is
the greater of its value in use and its fair value
less costs to sell. Value in use is based on the
estimated future cash flows, discounted to their
present value using a pre-tax discount rate that
reflects current market assessments of the
time value of money and the risks specific to
the asset or CGU.

An impairment loss is recognised if the
carrying amount of an asset or CGU exceeds its
recoverable amount.

Impairment loss in respect of assets other than
goodwill is reversed only to the extent that
the assets carrying amount does not exceed
the carrying amount that would have been
determined, net of depreciation or amortisation,
if no impairment loss had been recognised.

20. Segment Reporting

Operating segments are reported in a manner
consistent with the internal reporting provided
to the chief operating decision maker.

The board of directors of the Company has
been identified as being the chief operating
decision maker by the Management of
the company. Refer note 38 for segment
information presented.

21. Cash and cash equivalents

Cash and cash equivalents comprise cash at
Bank and on hand and short term deposits with
original maturities of three months or less that
are readily convertible to known amounts of
cash and which are subject to an insignificant
risk of change in value.

22. Exceptional item

Items of income or expense of non-routine
are presented separately when their nature
and amount of such significance and is
relevant to an understanding of the entity's
financial performance.

23. Earnings Per Share (EPS)

Basic earnings per share are computed by
dividing the profit for the year by the weighted
average number of equity shares outstanding
during the period. Diluted earnings per shares
is computed by dividing the profit for the year
by the weighted average number of equity
shares considered for deriving basic earnings
per shares and also the weighted average

number of equity shares that could have been
issued upon conversion of all dilutive potential
equity shares.

The weighted average number of equity shares
outstanding during the period is adjusted for
events such as bonus issue, bonus elements in
a rights issue, share split and reverse share split
(consolidation of shares) that have changed the
number of equity shares outstanding without a
corresponding change in resources.

24. Effective Interest Method

The effective interest method is a method of
calculating the amortised cost of a financial
asset or financial liability and of allocating
interest income / interest expenses over the
relevant period. The effective interest rate
is the rate that exactly discounts estimated
future cash receipts / payments (including
all fees and points paid or received that form
an integral part of the effective interest rate,
transaction costs and other premiums or
discounts) through the expected life of the
debt instrument, or, where appropriate, a
shorter period, to the net carrying amount on
initial recognition.

25. Dividend

The Company recognises a liability to pay
dividend to equity holders of the Company
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.

26. Business Combination under common
control

A business combination involving entities
or businesses under common control is a
business combination in which all of the
combining entities or businesses are ultimately
controlled by the same party or parties both
before and after the business combination and
the control is not transitory.

The transactions between entities under
common control are specifically covered by
Ind AS 103. Such transactions are accounted
for using the pooling of-interest method. The
assets and liabilities of the acquired entity
are recognised at their carrying amounts
of the Company's financial statements.

The components of equity of the acquired
companies are added to the same components

within the Company's equity. The financial
statements in respect of prior periods have
been restated as if the business combination
had occurred from the beginning of the
preceding period in the financial statements.

27. Events after the reporting period

If the Company receives information after
the reporting period, but prior to the date of
approved for issue, about conditions that
existed at the end of the reporting period, it
will assess whether the information affects
the amounts that it recognises in its separate
financial statements. The Company will
adjust the amounts recognised in its financial
statements to reflect any adjusting events after
the reporting period and update the disclosures
that relate to those conditions in light of the
new information. For non-adjusting events
after the reporting period, the Company will not
change the amounts recognised in its separate
financial statements but will disclose the nature
of the non-adjusting event and an estimate of
its financial effect, or a statement that such an
estimate cannot be made, if applicable.

28. Non-current assets held for sale

The Company classifies non-current assets
as held for sale if their carrying amounts will
be recovered principally through a sale rather
than through continuing use. This condition
is regarded as met only when the asset is
available for immediate sale in its present
condition subject only to terms that are usual
and customary for sales of such asset and
its sale is highly probable. Also, such assets
are classified as held for sale only if the
management expects to complete the sale
within one year from the date of classification.
Non-current assets classified as held for sale
are measured at the lower of their carrying
amount and the fair value less cost to sell.
Non-current assets are not depreciated
or amortised.

29. Incentives under the State Industrial
Policy

The Company's manufacturing units in various
States are eligible for incentives under the
respective State Industrial Policy. The Company
accrues these incentives as refund claims
in respect of GST paid, on the basis that all
attaching conditions were fulfilled by the
Company and there is reasonable assurance
that the incentive claims will be disbursed by
the State Governments.

Refer note 17a(2) & 22 for information on trade receivable pledged as security by the Company.

No trade receivable are due from directors or other officers of the Company or any of them either severally or jointly
with any other persons or amounts due from firms or private companies respectively in which any director is a partner
or a director or a member.

There are no unbilled receivables, hence the same is not disclosed in the ageing schedule.

Trade receivables are non-interest bearing and are generally on terms of maximum 90 days.

*Where due date of payment is not available date of transaction has been considered.

a. Terms and rights attached to equity shares

There are only 1 class of equity shares having a par value of H 10 each. Each holder of equity shares is entitled
to one vote per share. 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. There is no restriction on distribution of
dividend. The Company declares and pays dividends in Indian rupees. The dividend proposed by the Board of
Directors is subject to the approval of the shareholders in the ensuing Annual General Meeting.

Debenture Redemption Reserve (DRR)

For the debentures issued and outstanding, the Company has created DRR in accordance with requirement of section
71 of the Companies Act 2013. However, pursuant to a Ministry of Corporate Affairs notification dated 16 August 2019
amending Section 71 of the Companies Act, 2013 and Rule 18 (7) of the Companies (Share Capital and Debentures)
Rules, 2014, the Company is not required to maintain DRR for debentures issued and accordingly has applied the said
change in provision to debentures issued prospectively post 31 March 2020.

General Reserve

The Company appropriates a portion to general reserves out of the profits voluntarily to meet future contingencies.
The said reserve is available for payment of dividend to the shareholders as per the provisions of the Act.

Securities Premium

Securities premium reserve is used to record the premium on issue of shares. The reserve can be utilised only for
limited purposes such as issuance of bonus shares in accordance with the provisions of the Companies Act, 2013.

Retained earnings

Retained earnings represents all accumulated net income netted by all dividends paid to shareholders. Retained
earnings includes re-measurement gain/(loss) on defined benefit plans, net of taxes that will not be reclassified to
Statement of Profit and Loss. Retained earnings is a free reserve available to the Company.

Other Comprehensive Income

Remeasurement of defined benefit plans

Remeasurements of defined benefit plans represents the following as per Ind AS 19, Employee Benefits:

(a) actuarial gains and losses

(b) the return on plan assets, excluding amounts included in net interest on the net defined benefit liability
(asset); and

(c) any change in the effect of the asset ceiling, excluding amounts included in net interest on the net defined benefit
liability (asset)

In order to achieve this overall objective, the company's capital management, amongst other things, aims to ensure
that it meets financial covenants attached to the interest-bearing loans and borrowings that define capital structure
requirements. Breaches in meeting the financial covenants would permit the bank to immediately call loans and
borrowings. There have been no breaches in the financial covenants of any interest-bearing loans and borrowing in
the current period.

No changes were made in the objectives, policies or processes for managing capital during the years ended 31 March
2026 and 31 March 2025.

The Board of Directors have recommended a total dividend of H 20.00 per equity share of face value of H 10.00 per
share (200%) for the financial year (FY) 2025-26, subject to the approval of the shareholders at the ensuing annual
general meeting of the Company.

Capital management

For the purpose of the Company's capital management, capital includes issued equity capital, securities premium and
all other equity reserves attributable to the equity holders of the Company. The primary objective of the Company's
capital management is to maximise the shareholder value.

The Company manages its capital structure and makes adjustments in light of changes in economic conditions and
the requirements of the financial covenants. To maintain or adjust the capital structure, the Company may adjust the
dividend payment to shareholders, return capital to shareholders or issue new shares. The Company monitors capital
using a gearing ratio, which is net debt divided by total capital plus net debt. The Company includes within net debt,
interest bearing loans and borrowings (including lease liabilities), less cash and cash equivalent, fixed deposits and
current Investment & quoted non current investments.

Disaggregated revenue information

a. The Company is primarily in the business of manufacture and sale of cement. The product shelf life being short,
all sales are made at a point in time and revenue recognised upon satisfaction of the performance obligations
which is typically upon dispatch/delivery. The amounts receivable from customers are generally on terms of 0 to
90 days. There is no significant financing component in any transaction with the customers.

b. The Company does not have any remaining performance obligation as contracts entered for sale of goods are
for a shorter duration.

c. The Company does not provide performance warranty for products, therefore there is no liability towards
performance warranty.

d. The management determines that the segment information reported in Note 38 is sufficient to meet the
disclosure objective with respect to disaggregation of revenue under Ind AS 115 Revenue from contract
with customers.

38. Segment Information

Segment information is presented in respect of the Company's key operating segments. The operating segments are
based on the Company's management and internal reporting structure.

Operating Segments

The Company's Board of Directors have been identified as the Chief Operating Decision Maker ('CODM'), since they
are responsible for all major decision w.r.t. the preparation and execution of business plan, preparation of budget,
planning, expansion, alliance, joint venture, merger and acquisition, and expansion of any new facility.

Board of Directors reviews the operating results at company level, accordingly there is only one Reportable Segment
for the Company which is "Cement and allied products".

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

Asset volatility: The plan liabilities are calculated using a discount rate set with reference to bond yields; if plan
assets underperform this yield, this will create a deficit. Most of the plan asset investments is in fixed income
securities with high grades and in government securities. These are subject to interest rate risk and the fund
manages interest rate risk with derivatives to minimise risk to an acceptable level.

Changes in bond yields: A decrease in bond yields will increase plan liabilities, although this will be partially
offset by an increase in the value of the scheme's bond holdings.

Life expectancy: The pension obligations are to provide benefits for the life of the member, so increase in life
expectancy will result in increase in plans liability. This is particularly significant where inflationary increases
result in higher sensitivity to changes in life expectancy.

The Company ensures that the investment positions are managed within an asset-liability matching (ALM)
framework that has been developed to achieve long-term investments that are in line with the obligations under
the employee benefit plans. Within this framework, the company's ALM objective is to match assets to the
pension obligations under the employee benefit plan term fixed interest securities with maturities that match
the benefit payments as they fall due and in the appropriate currency. The Company actively monitors how the
duration and the expected yield of the investments are matching the expected cash outflows arising from the
employee benefit obligations. The Company has not changed the processes used to manage its risks from
previous periods. Investments are well diversified, such that the failure of any single investment would not have a
material impact on the overall level of assets. A large portion of assets at reporting date consists of government
and corporate bonds, although the Company also invests in equities, cash and mutual funds. The Company
believes that equities offer the best returns over the long term with an acceptable level of risk.

Notes for terms and conditions of transactions with related parties

(i) Sales to related parties and concerned balances

(a) Sales are made to related parties on the same terms as applicable to third parties in an arm's length
transaction and in the ordinary course of business. JKCL mutually negotiates and agrees sale price,
discount and payment terms with the related parties by benchmarking the same to transactions with non
related parties, who purchase goods and services of the JKCL in similar quantitites. Such sales generally
include payment terms requiring related party to make payment within 30 days 60 days from the date

of invoice.

(b) JKCL enters into sales transactions with related parties where prices are agreed at cost to the JKCL plus
pre-agreed mark-up. Mark-up for this purpose is determined using Transfer Pricing study conducted by tax
professionals engaged by the JKCL. Such sales generally include payment terms requiring related party to
make payment within 30 to 60 days from the date of invoice.

(c) The JKCL enters into sales transactions with related parties where prices are agreed at list price less
appropriate discount. Discount for this purpose is mutually negotiated and agreed between transacting
parties. Such sales generally include payment terms requiring related party to make payment within 30 to 60
days from the date of invoice.

(II) Purchases of goods from related parties and concerned balances

(a) Purchases are made from related parties on the same terms as applicable to third parties in an arm's length
transaction and in the ordinary course of business. JKCL mutually negotiates and agrees purchase price
and payment terms with the related parties by benchmarking the same to sale transactions with non-related
parties entered into by the counter-party and similar purchase transactions entered into by JKCL with the
other non-related parties. Such purchases generally include payment terms requiring the JKCL to make
payment within 30 to 60 days from the date of invoice.

(b) JKCL enters into purchase transactions with related parties where prices are agreed at cost to related
party plus mark-up. Mark-up for this purpose is determined using Transfer Pricing study conducted by tax
professionals engaged by the related party. Such purchases generally include payment terms requiring
JKCL to make payment within 30 to 60 days from the date of invoice.

(c) JKCL enter into Power Supply Agreement either as Group Captive Power/Captive Power Purchase at the
competitive rate fixed after negotiation.While deciding the supplier the Company benchmarked rate of other
suppliers negotiated with the suppliers and settled/finalised rate which is comparative with other suppliers.
Hence the arrangement is beneficial to the Company.

(III) Expenses reimbursement/ paid

(a) Reimbursement is claimed by Group Companies on actual basis with condition to make good their payments
within 30 - 60 days time

(b) Brand Promotion-Contractual agreement is made with mark up of 2% on actual cost. Payment term within a
week's time.

(c) Brand Promotion-Contractual agreement is made with mark up of 5% on actual cost. Payment term within a
week's time.

(d) Brand Promotion-On estimation.

(IV) Rent

In case of DLF Chhatarpur Outhouse, as per 99acres.com 4150 square feet market rent is H 0.05 Crores per
month. However in the above case Rent has been fixed H 0.03 Crores per month including furnishing as per
agreement entered into.

In case of Kamla Tower and Kothi Premises market rent is very higher as per 'Property Wala' assessment like
H 0.06 Crores per month. However as per agreement rent has been fixed at lower rate.

In case of Yadu International Private Ltd., rent is being paid as per agreement, where rent has been fixed less than
the market rate.

(V) Business Support Service

J.K. Cement Ltd is charging commission @ 10% on budgeted turnover for use of their platform for distribution
network for JK Maxx Paints Ltd.

d) Terms and conditions of transactions with related parties

The sales to and purchases from 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 and settlement
occurs in cash. There have been no guarantees provided or received for any related party receivables
or payables.

e) Compensation of key management personnel of the Company

B. Fair value hierarchy

This section explains the judgements and estimates made in determining the fair values of the financial
instruments that are:

(a) recognised and measured at fair value and

(b) measured at amortised cost and for which fair values are disclosed in the financial statements.

To provide an indication about the reliability of the inputs used in determining fair value, the Company has
classified its financial instruments into the three levels prescribed under the accounting standard. An explanation
of each level follows underneath the table.

There are no transfers between level 1, level 2 and level 3 during the year.

Valuation technique used to determine fair value

Specific valuation techniques used to value financial instruments include:

- the use of quoted market prices or dealer quotes for similar instruments

- the fair value of forward foreign exchange contracts is determined using forward exchange rates at the
balance sheet date

- the fair value of the remaining financial instruments is determined using discounted cash flow analysis.

The carrying amounts of trade receivables, trade payables, current borrowings, cash and cash equivalent, other
bank balances, other current financial liabilities/ assets are considered to be the same as their fair values, due to
their short-term nature.

Valuation technique used to determine fair value

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. The
following methods and assumptions were used to estimate the fair values :

(a) The fair value of unquoted non current investments and other non current financial liabilities/assets (majorily
Security deposits) are estimated by discounting future cash flows using rates currently available for debt on
similar terms, credit risk and remaining maturities.

(b) Fair value of current investment in mutual funds are based on market observable inputs i.e. Net Asset Value
at the reporting date.

(c) The fair values of the Company's interest-bearing borrowings were determined by using Discounted
Cash Flow (DCF) method using discount rate that reflects the issuer's borrowing rate as at the end of the
reporting period.

(d) The fair value of lease liabilities is estimated by discounting future cash flows using rates currently available
for debt on similar terms, credit risk and remaining maturities.

II. Financial risk management

The Company has exposure to the following risks arising from financial instruments:

- credit risk;

- liquidity risk; and

- market risk

i. Risk management framework

The Company's board of directors has overall responsibility for the establishment and oversight of the
Company's risk management framework. The board of directors has established the Risk Management
Committee, which is responsible for developing and monitoring the Company's risk management policies.
The committee reports regularly to the board of directors on its activities.

The Company's risk management policies are established to identify and analyse the risks faced by the
Company, to set appropriate risk limits and controls and to monitor risks and adherence to limits. Risk
management policies and systems are reviewed regularly to reflect changes in market conditions and the
Company's activities. The Company, through its training and management standards and procedures, aims
to maintain a disciplined and constructive control environment in which all employees understand their roles
and obligations.

The Company's Audit Committee oversees how management monitors compliance with the Company's
risk management policies and procedures, and reviews the adequacy of the risk management framework
in relation to the risks faced by the Company. The Audit Committee is assisted in its oversight role by
Internal Audit. Internal Audit undertakes both regular and ad hoc reviews of risk management controls and
procedures, the results of which are reported to the Audit Committee.

ii. Credit risk

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, and arises principally from the Company's receivables from
customers including deposits with banks and financial institutions.

Expected credit losses are a probability weighted estimate of credit losses. Credit losses are measured as
the present value of all cash shortfalls (i.e. the difference between the cash flows due to the Company in
accordance with the contract and the cash flows that the Company expects to receive).

Trade and other receivables

The Company's exposure to credit risk is influenced mainly by the individual characteristics of each
customer. However, management also considers the factors that may influence the credit risk of its
customer base, including the default risk of the industry and country in which customers operate.

The Risk Management Committee has established a credit policy under which each new customer is
analysed individually for creditworthiness before the Company's standard payment and delivery terms and
conditions are offered. The Company's review includes external ratings, if they are available, and in some
cases bank references. Sale limits are established for each customer and reviewed quarterly. Any sales
exceeding those limits require approval from the Risk Management Committee.

In monitoring customer credit risk, customers are accompanied according to their credit characteristics,
including whether they are an individual or a legal entity, their geographic location, industry and existence
of previous financial difficulties. The Company evaluates the concentration of risk with respect to trade
receivables as low, as its customers are located in several jurisdictions and industries and operate in largely
independent markets.

A default on financial assets is when the counterparty fails to make contractual payments within 60 days
of when they fall due. This definition of default is determined by considering the business environment in
which the entity operates and other macro-economic factors. The Company holds security deposits against
trade receivables of H 157.15 Crores (31 March 2025: H203.31 Crores) and as per the terms and condition of
the agreements, the Company has the right to encash the bank guarantee or adjust the security deposits in
case of defaults.

The Company establishes an allowance for impairment that represents its expected credit losses in respect
of trade and other receivables. The management uses a simplified approach for the purpose of computation
of expected credit loss for trade receivables

During the year based on specific assessment, the Company recognised bad debts and advances of H 0.35
Crores(31 March 2025: H 0.40 Crores). The year end trade receivables do not include any amounts with
such parties.

The maximum exposure to credit risk at the reporting date is the carrying value of trade receivables
disclosed in Note 9.

Financial instruments and cash deposits

Credit risk from balances with banks and financial institutions is managed by the Company's treasury
department in accordance with the Company's policy. Investments of surplus funds are made only with
approved counterparties and within credit limits assigned to each counterparty. The limits are set to
minimise the concentration of risks and therefore mitigate financial loss through counterparty's potential
failure to make payments.

The Company's maximum exposure to credit risk for the components of the balance sheet at 31 March
2026 and 31 March 2025 is the carrying amounts as shown in Note 4,5,8,10,11 & 12. The Company has not
recorded any further loss during the year in these financial instruments and cash deposits as these pertains
to counter parties of good credit ratings/credit worthiness.

A default on financial assets is when the counterparty fails to make contractual payments within 60 days of
when they fall due. This definition of default is determined by considering the business environment in which
the entity operates and other macro-economic factors

The Company establishes an allowance for impairment that represents its expected credit losses in respect
of trade and other receivables. The management uses a simplified approach for the purpose of computation
of expected credit loss for trade receivables

iii. Liquidity risk

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

Prudent liquidity risk management implies maintaining sufficient cash and marketable securities and the
availability of funding through an adequate amount of committed credit facilities to meet obligations when
due and to close out market positions. Due to the dynamic nature of the underlying businesses, Company
treasury maintains flexibility in funding by maintaining availability under committed credit lines.

Management monitors rolling forecasts of the Company's liquidity position (comprising the undrawn
borrowing facilities below) and cash and cash equivalent on the basis of expected cash flows. This is
generally carried out in accordance with practice and limits set by the Company. These limits vary by
location to take into account the liquidity of the market in which the entity operates. In addition, the

iv. Market risk

Market risk comprises of Interest rate risk, commodity risk and currency risk is the risk that the fair value of
future cash flows of a financial instrument will fluctuate because of changes in market prices. Market risk
comprises of interest rate risk and currency risk. Financial instruments affected by market risk primarily
include trade and other receivables, trade and other payables and borrowings.

Excessive risk concentration

Concentrations arise when a number of counterparties are engaged in similar business activities, or have
economic features that would cause their ability to meet contractual obligations to be similarly affected by
changes in economic or other conditions. Concentrations indicate the relative sensitivity of the Company's
performance to developments affecting a particular industry. In order to avoid excessive concentrations of
risk, the Company's policies and procedures include specific guidelines to focus on the maintenance of a
diversified portfolio. Identified concentrations of credit risks are controlled and managed accordingly.

Commodity Price Risk

The Company is exposed to commodity price risk arising out of fluctuation in prices of raw materials (flyash,
gypsum and laterite) and fuel (coal and pet coke). Such price movements, mostly linked to external factors,
can affect the production cost of the Company. To manage this risk, the Company take steps such as
monitoring of prices, optimising fuel mix and pursue longer and fixed price contracts, where considered
necessary. Additionally, processes and policies related to such risks are controlled by central procurement
team and reviewed by the senior management.

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's exposure to the risk of changes in foreign exchange
rates relates primarily to the Company's operating activities (when revenue or expense is denominated in
a foreign currency). The Company manages its foreign currency risk by taking foreign currency forward
contracts, if required

Exposure to currency risk

The summary quantitative data about the Company's exposure to currency risk as reported to the
management of the Company is as follows:

Sensitivity analysis

A reasonably possible strengthening (weakening) of the Indian National Rupee ('INR') against all other
currencies at 31 March would have affected the measurement of financial instruments denominated in a
foreign currency and affected equity and profit by the amounts shown below. This analysis assumes that all
other variables, in particular interest rates, remain constant.

Interest rate risk

The Company's main interest rate risk arises from long-term borrowings with variable rates, which expose
the Company to cash flow interest rate risk. Company policy is to maintain most of its borrowings at fixed
rate using interest rate swaps to achieve this when necessary. During 31 March 2026 and 31 March 2025,
the Company's borrowings at variable rate were mainly denominated in Indian National Rupee ('INR').

The Company's fixed rate borrowings are carried at amortised cost. They are therefore not subject to
interest rate risk as defined in Ind AS 107, since neither the carrying amount nor the future cash flows will
fluctuate because of a change in market interest rates.

Currently the Company's borrowings are within acceptable risk levels, as determined by the management,
hence the Company has not taken any swaps to hedge the interest rate risk.

Exposure to interest rate risk

The interest rate profile of the Company's interest-bearing financial instruments as reported to the
management of the Company is as follows.

42. Details of dues to micro and small enterprises as defined under the MSMED,
2006

Information as required to be furnished as per section 22 of the Micro, Small and Medium Enterprises Development
Act, 2006 (MSMED Act) for the year ended 31 March 2026 and 31 March 2025 are given below. This information
has been determined to the extent such parties have been identified on the basis of information available with
the Company.

45. (a) The backup of the books of accounts and other books and papers maintained in electronic mode has been

maintained on servers physically located in India on daily basis.

(b) The Company uses SAP accounting software for maintaining its books of account which has a feature of
recording audit trail facility and the same has operated throughout the year for all relevant transactions
recorded in the software except for direct changes to database using certain access rights where audit trail
feature is in the process of being enabled. Wherever audit trail is enabled, there has not been any instance
where audit trail feature has been tampered with, in respect of the accounting software. Additionally, the
audit trail of prior years has been preserved by the Company as per the statutory requirements for record
retention to the extent it was enabled and recorded in the respective year.

46. Exceptional Item

The Ministry of Labour & Employment (MoLE), Government of India, has announced the implementation of four
Labour Codes viz. the Code on Wages, 2019, the Industrial Relations Code, 2020, the Code on Social Security,
2020 and the Occupational Safety, Health and Working Conditions Code, 2020, effective November 21, 2025. On
the basis of information available, the Company has assessed and accrued the incremental impact for these
changes at ? 46.00 Crores and disclosed as an 'Exceptional Item - Statutory impact of new Labour Codes' in the
standalone financial statement of the Company for the year ended March 31, 2026. The Company continues to
monitor the finalisation of State Rules and clarifications from the Government on other aspects of the Labour
Code and would provide appropriate accounting effect on the basis of such developments as needed.

47. Business combination

Merger of Toshali Cements Private Ltd. with J.K. Cement Ltd.

i. The Company acquired 100% control in Toshali Cements Private Ltd. (TCPL) engaged in the business of
manufacturing and selling cement on 21 February 2024 ('acquisition date') and had become wholly owned
subsidiary. The Company had filed a Scheme of Amalgamation of TCPL with the Company, with National
Company Law Tribunal (NCLT) on 20 December 2024. The said Scheme of Amalgamation, has been approved
by the NCLT on 13 October 2025, with the Appointment date of the Scheme as 01 January 2024. All substantial
conditions prescribed in the Scheme has been fulfilled and accordingly, the Company filed certified copy of
NCLT order with the Registrar of Companies on 15 October 2025 ('Effective date') making the Scheme effective.
Pursuant to the Scheme becoming effective, accounting treatment pursuant to the Scheme has been given
effect from the Appointed date in compliance with NCLT order read with General Circular No. 09/2019, dated 21
August 2019, issued by Ministry of Corporate Affairs, Government of India instead of acquisition date as required
by Ind AS 103 'Business Combinations'. Accordingly, the standalone financial statements of the previous year has
been restated from the Appointed date as per the approved Scheme.

ii. The comparative previous year figures of Balance Sheet, Statement of Profit and Loss (including Other
Comprehensive Income) and Statement of Cash Flows have been restated from the beginning of the previous
year i.e. 01 April 2024 to give effect of the said scheme in accordance with the "Pooling of interest method" of
accounting laid down in Appendix C of Ind AS 103 - Business Combinations, read with Ind AS 10 - Events after
the Reporting Period. The audited financial statements, of erstwhile TCPL for the year ended 31 March 2025 were
audited by the independent auditor of erstwhile TCPL.

Note: Accounting treatment of the arrangements:

Business combination is accounted for using the 'pooling of interests' method as per Appendix C of Ind AS

103 - Business Combinations as notified under Section 230 to 232 of the Companies Act, 2013 and same is

in line with the approved scheme, which involves the following:

(a) The financial information in the financial statements in respect of prior periods is restated as if
the business combination had occured from the beginning of the preceding period in the financial
statements, irrespective of the actual date of the combination. Accordingly, business combinations is
accounted with effect from 1^st April 2024.

(b) The assets, liabilities and reserves are recognised at carrying values as appearing in consolidated
financial statements of the Company.

(c) The value of investment in the Transferor (TCPL) in the books of the Company shall be cancelled.

(d) No adjustments are made to reflect fair values, or recognise any new assets or liabilities.

(e) Inter-company balances as at 31 March 2024 have been eliminated.

(f) The difference between the net assets of the Transferor (TCPL) transferred to Company, after making
adjustment specified in (c) and (d) shall be adjusted in 'Other Equity' of the Company.

48. Additional regulatory information required by Schedule III

(i) Details of benami property held

No proceedings have been initiated on or are pending against the company for holding benami property
under the Benami Transactions (Prohibition) Act, 1988 (45 of 1988) and Rules made thereunder.

(ii) Borrowing secured against current assets

The Company has borrowings from banks and financial institutions on the basis of security of current
assets. The quarterly returns or statements of current assets filed by the Company with banks and financial
institutions are in agreement with the books of accounts.

(iii) Wilful defaulter

The Company has not been declared wilful defaulter by any bank or financial institution or government or
any government authority.

(iv) Relationship with struck off companies

The Company has made transactions along with closing balance with the following companies struck off
under Companies Act, 2013 or Companies Act, 1956.

(vii) Utilisation of borrowings availed from banks and financial institution

The borrowings obtained by the company from banks and financial institutions have been applied for the
purposes for which such loans were taken."

(viii) Undisclosed income

There is no income surrendered or disclosed as income during the current or previous year in the tax
assessments under the Income Tax Act, 1961, that has not been recorded in the books of account.

(ix) Details of crypto currency or virtual currency

The Company has not traded or invested in crypto currency or virtual currency during the current or
previous year.

(x) Valuation of Property, plant and equipment, intangible asset

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.

(xi) Registration of charges or satisfaction with Registrar of Companies

There are no charges or satisfaction which are yet to be registered with the Registrar of Companies beyond
the statutory period.

49 . Absolute amounts less than H 50,000 are appearing in the Standalone Financial Statements as "0.00" and more
then 50,000 to 1,00,000 are appearing in the Standalone Financial Statements as "0.01" due to presentation
in Crores.

(v) Compliance with number of layers of companies

The Company has complied with the number of layers prescribed under the Companies Act, 2013.

(vi) Utilisation of borrowed funds and share premium

The Company has not advanced or lend 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

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