24. Provisions, Contingent Liabilities and Contingent Assets
Provisions involving substantial degree of estimation in measurement are recognized when there is a present obligation as a result of past events and it is probable that there will be an outflow of resources and reliable estimate can be made of the amount of obligation. Contingent Liabilities are not recognized but are disclosed in the notes. Contingent Assets are neither recognized nor disclosed in the Standalone financial statements.
25. Expenses of Management-Basis of Apportionment
Expenses of management includes exchange gain/loss, excluding GST Expenses. Expenses which are solely and exclusively attributable to a specific Segment i.e. Line of Business (LOB) and which are specifically identifiable to that particular segment, are allocated to that segment and the remaining value of expenses of management are apportioned to the revenue accounts on the basis of net premium.
26. Segregation of Policy Holders and Share Holders funds:
Investment Assets includes policyholders as well as shareholders. Investment assets are bifurcated at the end of each quarter between shareholders and policyholders at 'fund' level on notional basis in accordance with IRDAI guidelines.
27. Income from Investments -Basis of apportionment
Investment Income (net of expenses) is apportioned between shareholders' fund and policyholders' fund in proportion to the balance of these funds at the beginning of the year.
Investment income (net of expenses) belonging to Policyholders is further apportioned to Fire, Marine and Miscellaneous segments in proportion to respective technical reserves balance at the beginning of the year.
Policy holders fund for this purpose consist of estimated liability for outstanding claims including IBNR and IBNER, unexpired risk reserve (URR), Premium deficiency (if any). catastrophe reserve (if any) and Other Liabilities net of Other Assets (relating to policy holders) as per the guidelines of IRDAI. The residual consists of the shareholder fund.
1. Reinsurance Acceptance Transactions:
Reinsurance acceptance transactions pertaining to the year have been booked for advices received up to April 12, 2025.
2. Premium Deficiency Reserve:
Unexpired premium reserve at revenue segment level is found to be sufficient to cover the expected claim cost and claims related expenses as certified by the appointed actuary. Hence no premium deficiency reserve is required to be provided during the year.
3. Reserves against cancellation of policies during free- look period:
The reserve against cancellation of policies during free- look period under retail health policies for the period ended 31st March 2025, as certified by the actuary, is ?150 Lakhs (PY ?150 Lakhs).
4. IBNR and IBNER:
Provision towards Claims Incurred but Not Reported (IBNR) and those Incurred but Not Enough Reported (IBNER) as on March 31, 2025 has been determined by Appointed Actuary, which is in accordance with accepted actuarial practice and IRDAI regulations in this regard.
5. taxation:
a) Income Tax: Provision for Tax ?1878 Lakhs (PY. ?33115 Lakhs) shown in Profit and Loss Account includes ?3439 Lakhs (PY. ?1959 Lakhs) relating to foreign taxes and reversal of earlier year tax ?25470 lakhs (PY. Nil).
b) From FY 2022-23 the company has been recognizing and utilizing the available MAT Credit of previous years to the extent required to be set off against tax computed as per the normal provisions of the Act which was not accounted for on account of prudence and absence of convincing evidence of utilizing it. Accordingly, MAT credit of ?9284 Lakhs (previous year ?18415 Lakhs) has been recognized and utilized during the year and cumulative utilization amounted to ?52501 lakhs.
c) The Income Tax Assessments of the Company have been completed up to assessment year 2022-23. Major disputed demands are in respect of profit on sale of investment, IBNR, expenses paid to Auto tie- up dealers. Based on the decisions of the appellate authority, the interpretations of the relevant provisions, the management of the Company is of the opinion that the demands are likely to be either deleted or substantially reduced and accordingly no provision has been made for the same. However, an amount of ?579811 lakhs has been disclosed as contingent liabilities.
i) A sum of ?2763 Lakhs (PY ?1500 Lakhs) has been debited to the Profit and Loss Account on account of reduction in deferred assets during the year.
ii) Deferred Tax Asset in respect of foreign branches does not have any timing difference other than fixed asset.
iii) The Company continues to recognise the deferred tax asset in respect of temporary difference mentioned in the above table, as in the opinion of the management there are sufficient evidence to establish the reasonable certainty of realisation of the deferred tax assets from the future taxable profits.
e) Taxation Laws (Amendment) Act, 2019 -
The Taxation Laws (Amendment) Act, 2019 was enacted on 11th December 2019 which amended the Income Tax Act, 1961 and the Finance Act (No.2) Act, 2019. It provides domestic companies with an option to opt for lower tax rate, provided they do not claim certain deductions. The Company has not exercised the option to opt for lower tax rate and has presently considered the rate existing prior to the amendment. The management is in the process of evaluating the option to opt for lower tax rate once it utilises the entire carried forward losses and MAT credit available under the Income Tax Act.
f) Goods and Service Tax (GST):
The company has received an adjudication order from the Goods and Services Tax Department towards non-payment of GST amounting to ?84945 lakhs on supply of group medicliam insurance services to industrial units located in Special Economic Zones. The matter is an industry wide issue and as per opinion received by the company has merits in defending the notice. The Company has filed a writ petition before the Hon'ble Bombay High Court challenging the Order vide writ petition no 1281 of 2025, date of hearing for admission is yet to be notified. Considering that the denial of the
zero-rating benefit for the period prior to 01.10.2023 appears to be without proper legal basis, the company has classified this exposure as “Remote” and disclosed it as a contingent liability.
The company has also received an adjudication order from the Goods and Services Tax Department towards non-payment of GST amounting to ?7045 lakhs on sale of salvage/wreck generated during the settlement of Motor vehicle claims. The matter is an industry wide issue and as per opinion received, the Company has merits in defending the notice. The Company has filed a writ petition before the Hon'ble Bombay High Court challenging the Order vide writ petition no 15219 of 2025, date of hearing for admission is yet to be notified. The company has also taken into account the clarification issued by the department through circular no. 215/9/2024-GST dated 26.06.2024, which states that the salvage value deducted from claim settlements should not be treated as consideration for any taxable supply. Consequently, the company classified this exposure as “Remote” and disclosed it as a contingent liability.
6. Statutory Reserves relating to Foreign Branches:
In accordance with Oman Insurance Company Law, the Head Office had created a contingency reserve of 5 million Omani Riyal in FY 2012-13 for claims related to the Muscat agency. However, this contingency reserve is now maintained within the financial records of Muscat Operations. Consequently, during the current year an amount of ?7031 lakhs has been transferred from this contingency reserve to the General Reserve along with the related foreign currency fluctuation amounting to ?3794 lakhs in the Head Office books.
7. Title deeds of immovable properties:
I. Title deed of the following immovable properties are pending to be registered in the name of the Company:
a. Thirty-Two properties having book value (Gross Block) ?1490 Lakhs (P.Y. Sixty-Seven Properties having book value ?2062 Lakhs) for which registration formalities are yet to be completed / title deeds are in process. Out of which,
i. title deeds of Seven properties having value as per books of ?66 Lakhs (P.Y. ?66 Lakhs) are in the name of General Insurance Corporation of India and the Company is in the process to get it transferred in its name.
ii. three properties having book value of ?336 Lakhs (P.Y. ?336 Lakhs) were received from Tariff Advisory Committee (TAC) and the registration formalities are still pending.
b. Office property having book value ?217 Lakhs (PY ?217 Lakhs) and Office freehold property having book value ?752 lakhs (P.Y. ?752 lakhs) for which agreement registration formalities are pending.
c. One open plot having book value ?24 Lakhs (P.Y. ?24 Lakhs) jointly owned by four PSU Companies and title deed is in the name of GIC, is under litigation and Special Civil Application is pending before the Hon'ble Gujarat High Court.
II One leasehold property having book value of ?3 Lakhs (P.Y. ?3 Lakhs) where lease term expired and renewal process is pending with the concerned Government Authorities.
III Following are the properties for which legal proceedings are/will be initiated by the Company for acquiring Physical Possession:
a) Out of total 23 properties owned by the Company, 08 properties are occupied by corporate tenants and 15 are occupied by Individual Tenants. Legal proceedings are in process against all 08 corporate tenants. Out of 15 Individual Tenants; legal proceedings are in process against 11. For remaining 4 Individual tenant's eviction proceeding are contemplated.
b) One Lease hold property consisting of 123 tenements and 6 Godowns having book value of ?3 Lakhs (P.Y. ?3 Lakhs) is in the possession of the Company but occupied by inherent tenants. Now, the property is under the purview of MHADA Authority.
IV As per legal opinion obtained from the Advocates dated 23.10.2021, 20.02.2023 & 21.02.2023
regarding procedure to be followed to regularize the title deeds in Company's name, on perusal, the Advocates opined that the documents available in the records of the files are sufficient and having evidentiary value to prove our ownership (ie. Gazette Notification issued by Government of India, Agreement registered/unregistered, share certificate, Municipal tax, property tax bill etc). Hence, as per Advocates' opinion, in another 37 Nos of units having value of ?169 lakhs are to be treated as having clear titles.
8. Investments:
a) As certified by the Custodian, securities are held by the Company as on March 31, 2025. Variations and other differences, which include shortages, have been provided for.
b) Provision for standard assets @ 0.40% amounting to ?5665 Lakhs (P.Y. ?6023 Lakhs) has been made as per Insurance Regulatory and Development Authority of India (IRDAI) guidelines.
d) Short-term Investments (Schedule - 8) in debentures and other guaranteed securities include those, which are fully repayable in the next year. As regards those debentures and other guaranteed securities, which have fallen due and remain unpaid as on March 31, 2025, these have been shown under long-term investments, as their realisability is unascertainable. Necessary provision, wherever required, has been made.
e) Pursuant to the IRDAI regulations the company had recognised impairment loss of ?10966 Lakhs in the profit and loss account during the year 2023¬ 24 on its equity investment in one of the subsidiary namely Prestige Assurance PLC, Nigeria, due to the impairment loss being considered as other than temporary due to steep fall of Nigerian currency, Naira. As on Balance Sheet date the currency Naira has improved as compared to Previous Year and accordingly impairment loss of ?2109 lakhs has been reversed during the year.
f) Fixed deposits forming part of Investment Assets, amounting to ?2,61,331 lakhs and ?365 lakhs due within 12 months and more than 12 months respectively, have been included under Cash and Bank Balance in Schedule 11, as per consistent practice followed.
9. Reinsurance, Coinsurance, Inter Office, GST Balances and old credit /debit balances:
a) The net balances due to/due from in respect of re¬ insurance activities of the company ?541637 lakhs comprising of ?5,89,529 Lakhs (Dr.) and ?47,892 lakhs (Cr.) contain various entries outstanding for more than 10 years where process of matching open items, confirmation and reconciliation is in progress. The above include balances relating to Terrorism Pool ?3,45,823 lakhs and Nuclear Pool
of ?23,308 lakhs due from General Insurance Corporation of India (GIC Re) and ?34,979 Lakhs due from Agricultural Insurance Company of India Ltd. for which confirmation of balances is received but these are subject to reconciliation in respect of old entries appearing in the books. These accounts are still under the process of compilation/age-wise analysis/ reconciliation and segregating into debit and credit balances. Also, there are migration differences which need to be reconciled. Pending all such activities the impact on the financial statements is unascertainable. The process of matching and reconciliation by the task force formed by the company is at different stages and any resultant accounting adjustments shall be carried out on outcome of such process.
As against Net Reinsurance balance of ?5,41,637 Lakhs(Net) (Dr.) as on March 31,2025, the Company has maintained a provision of ?93536 Lakhs up to March 31,2025, towards doubtful debts as a prudent measure. During the period ended March 31, 2025, the Company has written off (net debit) non-moving reinsurance balances of ?5,383 Lakhs.
b) In respect of Coinsurance business, the balances with various Co-insurers represent a net receivable of ?49,304 lakhs (receivable of ?85,335 lakhs and payable of ?36,031 lakhs), which included balances relating to PMFBY amounting to ?1,559 lakhs (Net). The process of obtaining confirmations and reconciliation of balances is at different stages and entries remaining to be reconciled based on the confirmation are also being attended to. Age- wise breakup of the outstanding entries has been compiled based on available information.
Based on the Board approved policy depending on the age of outstanding, the company has maintained provision of ?22,395 lakhs during the year (Previous
year ?34,075 lakhs) against the net coinsurance balance of ?49,304 lakhs and written off an amount of ?2520 lakhs as on March 31, 2025.
c) The reconciliation of various accounts relating to inter-office accounts of domestic and foreign operations amounting to ?12,357 Lakhs (Net Debit) [PY ?1,045 Lakhs (Net Debit)], Control Accounts, certain banking transactions, loans and advances including those given to employees and other accounts including indirect tax related balances is under progress, the impact of the above, if any, on the Standalone Financial statements is unascertainable.
d) As per the consistent practice followed by the Company, interest accrued on employee loans is recognized to the extent recovered from the employee instead accrued to the account of the employee. The impact, if any, arising out of the above may not be material though the same has not been identified.
e) Old balances other than policy holder dues mainly relating to various control accounts amounting to ?1,637 lakhs (Net credit) (PY ?13,779 lakhs Net debit) outstanding for more than three years has been credited to Profit & Loss Account during the year. Necessary accounting adjustments in the books of operating offices would be carried out in due course. As per the board approved policy, the Company has written-off balances under various control accounts outstanding more than 10 years aggregating to ?2890 lakhs and has maintained a provision amounting to ?4251 lakhs against debit balances more than 3 years and less than 10 years, during and as at March 31,2025 respectively.
f) In view of various accounts being reconciled and balances under confirmation, the effect of such pending reconciliation on compliance of tax laws has been ensured to the extent of available information and necessary adjustments /payments of any liability arising out of such reconciliation is to be done in due course.
15. Corporate Social Responsibilities (CSR):
As per Section 135 of the Companies Act 2013 (the Act), the Company was required to spend an amount of ?803 lakhs (PY ?1832 lakhs) for the financial year 2024-25.
The charge for the year to profit and loss account on account of CSR amounting to ?803 Lakhs (PY ?1832 lakhs) consists of following:
a) An amount of ?617 Lakhs (P Y ?293 Lakhs) spent directly & through implementing agencies.
b) The balance unspent amount for the current year ended March 31, 2025 of ?186 Lakhs (P.Y. ?1539 Lakhs) which has been provided for in the books. The balance unspent CSR amount of current year is lying in separate Unspent CSR Bank Account.
16. Books maintained on Calendar year:
The accounts incorporate Audited accounts of branches in Fiji and Thailand which are prepared on calendar year basis as per the requirement of local laws. There are no material changes during the period January 1, 2025 to March 31, 2025 requiring adjustments to figures reported in the audited accounts as received. Fixed deposits aggregating to ?18838 lakhs
17. Accounts of Run-off offices:
Hong Kong and Manila Offices of the company are since in Run-off status as the company has stopped any new business in these locations. The accounts of Manila office have been prepared on liquidation basis and the accounts of Hong Kong office are prepared based on going concern basis. In the case of Kuwait office there is material uncertainty about its going concern status. In the opinion of the management this does not have any material impact on the standalone financial statements.
18. Analysis of Unclaimed amounts of Policyholders/Consumers:
As required by IRDAI Master circular no. IRDA/F&I/CIR/Misc/282/11/2020 dated November 17, 2020 read with subsequent modification to the master circular number IRDA/LIFE/CIR/Misc/41/2/2024 dated 16th February, 2024, age-wise analysis of unclaimed amount of the policyholders amounting to ?21458 Lakhs (PY ?22942 Lakhs) as at March 31, 2025 representing the excess premium collected, refund premium, stale cheque accounts and Claims settled but not paid to policyholders/ Insured is as under:
Footnote 1: The Company received an order from Competition Commission of India (CCI) imposing a penalty of ?25107 Lakhs in 2015-16. The Company contested the order in Competition Appeal Tribunal and the Tribunal awarded a penalty of ?20 Lakhs as against ?25107 Lakhs of CCI order. The penalty was paid in January 2017. CCI has appealed against the order of the Tribunal at the Apex Court and the case has been admitted in the Apex Court in March 2017. As per the latest information available, the case has been awaiting a hearing since the 10th of August, 2017.Counter-affidavit/reply has already been filed by NIA as on March 31, 2023.
Footnote 2: Bombay Stock Exchange (BSE) and National Stock Exchange (NSE) each have levied a penalty of ?472 lakhs for quarter ended September 30, 2024 and a penalty of ?117 lakhs for quarter ended December 31, 2024 for non-compliance with Regulation 17(1) of SEBI (LODR), 2015. The Company had applied for waiver of the penalties, as appointment of Directors can only be done by the Ministry of Finance and the Company has no authority regarding the appointment of Directors.
Footnote 3: The company has received a penalty amounting to ?84945 lakhs and ?7045 lakhs for non¬
payment of GST on supply of group medicliam insurance services to industrial units located in Special Economic Zones and sale of salvage/wreck generated during the settlement of Motor vehicle claims, respectively. Both the matters are industry wide and as per opinion received, the company has merits in defending the notice. The Company has filed a writ petition before the Hon'ble Bombay High Court challenging the Order.
Footnote 4: The Income Tax Department imposed penalties on the company for AY 2016-17 and AY 2019¬ 20 following disallowance of payments to auto dealers. However, the company has received a favorable order on the same matter for AY 2014-15 from the Income Tax Appellate Tribunal (ITAT). Based on the same, the company has filed appeals with the before National Faceless Appeal Centre - NFAC (erstwhile CIT(A)) against the penalties.
22. Internal Controls:
The Company has a fairly adequate internal control and appropriate validations in the system. The Company is in the continuous process of further strengthening internal controls in other areas of its operations, by bringing more
controls and validation in system. The Internal Audit System including that relating to Foreign offices is also being strengthened and is under comprehensive review.
23. Fraud Monitoring Cell:
The Company has a Fraud Monitoring Cell which monitors external frauds reported and a Vigilance Department which monitors matters related to employees. The said fraud cell compiles data based on inputs from operating offices. As per the assessment made by the Cell, there were no matters related to external frauds reported during the year, which required any disclosure or adjustments to the standalone financial statements of the Company except as under:
a) Online Fraud using Broker Portal has been reported where 514 two-wheeler Motor policies issued in the system were modified as four wheeler policies and given to customers. The Company has cancelled all the policies ab initio without any refund and informed the concerned RTOs by registered post under the relevant rules and guidelines of the Company. The premium amount has been forfeited and there is no revenue loss to the Company.
b) Dehradun RO reported some cases of irregular premium deposits to the tune of ?6 lacs under health insurance policies. A Special Audit was conducted, and the concerned branch in-charge has been suspended. Appropriate action is also being initiated.
c) Jaipur RO has recently reported 96 fake policies issued through Square Insurance web integration online channel. FIR has been lodged against the Broker. The R.O. has been advised to initiate a special audit.
24. a) No funds have been advanced or loaned or invested
(either from borrowed funds or share premium or any other sources or kind of funds) by the Company to or in any other person(s) or entity(ies), including foreign entities (“Intermediaries”) with the understanding, whether recorded in writing or otherwise, that the Intermediary shall lend or invest in party identified by or on behalf of the Company (Ultimate Beneficiaries).
b) The Company has not received any fund from any party(s) (Funding Party) with the understanding that the Company shall whether, directly or indirectly lend or invest in other persons or entities identified by or on behalf of the Company (“Ultimate Beneficiaries”) or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries.
25. The Code on Social Security, 2020 (“Code”) relating to employee benefits during the employment and post¬ employment benefits has been published in the Gazette of India on September 28, 2020. The Ministry of Labour and Employment has released draft rules for the Code
on November 13, 2020. The effective date from which these changes are applicable is yet to be notified. The Company will assess and record the impact, if any, when the rules are notified, and the Code becomes effective.
26. Wage revision for employees of PSU GIC is due w.e.f. Aug-22. Pending finalisation of wage negotiations, the company has made provision of wage bill based on management assessment amounting to ?19807 Lakhs towards wage revision during the year ended March 31, 2025 and the total provision as on March 31, 2025 is ?45095 Lakhs.
27. Based on the advisory from IRDAI, the Company has set up a Committee for IND-AS implementation and appointed knowledge partner who has completed GAP analysis and submitted GAP assessment report. For phase-II (solution and system design), the company has finalised the vendor for procurement of sub ledger solution and is in the process of floating tender for engagement of implementation partner.
28. In accordance with Proviso to Rule 3(1) of the Companies (Accounts) Rules, 2014, the accounting software used by the company for maintaining its books of account have a feature of recording audit trail of each and every transaction, creating an edit log of each change made in the books of account along with the date when such changes were made and ensuring that the audit trail cannot be disabled and these edit logs have been preserved as per the statutory requirements. Further, the company is in the process of compliance of Section 128 of the Companies Act 2013 and rules thereunder as amended, regarding maintaining of books of accounts and papers maintained in electronic mode at Foreign branches of the company to be accessible in India at all times and maintenance of back up of its books of accounts and papers at servers physically located India on a daily basis.
29. The company has changed its policy for Expenses of Management which shall henceforth not include Provision for Bad & Doubtful debts. Consequent to this, expense allocation is lower by ?74721 lakhs for the year ended March 31, 2025.
30. Proposed Dividend for current year: The Board of Directors of the Company proposed a final dividend of ?29664 lakhs (?1.80 per share) being 36% of the Paid- up share Capital of the Company, subject to the approval of the members at the Annual General meeting. In terms of Revised Accounting Standard (AS)4, Contingencies and events occurring after the Balance sheet date as notified by the Ministry of Corporate affairs through the amendments to the Companies (Accounting Standard) Rules, 2016, the company has not appropriated proposed dividend from the standalone Profit and Loss account for the year ended March 31,2025.
Jyoti Rawat Vimal Kumar Jain Kasturi Sengupta Girija Subramanian
Company Secretary Chief Financial Officer Executive Director Chairman cum Managing Director
DIN: 11017873 DIN: 09196957
As per our report of even date For Chokshi & Chokshi LLP
For R. Devendra Kumar & associates Chartered Accountants
Chartered Accountants Firm Reg. No. 101872W/W100045
Firm Reg. No. 114207W
anand Golas dharmista Shah
Partner Partner
Membership Number 400322 Membership Number 108845
Mumbai, May 19, 2025
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