Notes to Accounts of Ugro Capital Ltd.

Mar 31, 2022

The Company had availed total External Commercial Borrowing (ECBs) of USD 4.125 million for financing prospective borrowers as per the ECB guidelines issued by the Reserve Bank of India ("RBI”) from time to time.The borrowing has a maturity of three years. In terms of the RBI guidelines, the borrowing has been swapped into rupees and fully hedged for the entire maturity by way of cross currency swaps .The charges for raising of the aforesaid ECB have been amortised over the tenure of the ECB.

Security and other terms of the loans are as follows :

(a) Rate of interest of the bank overdraft ranges from 730% per annum to 9.70% per annum and the same is secured against fixed deposits.

(b) The above borrowings other than Bank overdraft and unsecured borrowings are secured by specific charge on receivables under financing activities. The Company has maintained the required security cover with respect to its secured borrowings.

(c) Out of the the above, borrowings amounting to '' 30,714 lakh as at March 31, 2022 are guaranteed by directors.

(d) Term Loans were used fully for the purpose for which the same were obtained.

(e) There were no default in the repayment of borrowings.

(f) Periodic statements of securities filed with the lending institutions are as per the books of accounts.

c. Rights, preferences and restrictions attached to equity shares :

The Company has only one class of equity shares having a face value of Rs 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 the remaining assets of the Company after distribution of all preferential amounts, in proportion to their holding. .

f. Objectives for managing capital :

The Company maintains an actively managed capital base to cover risks inherent in the business and is meeting the capital adequacy requirements as prescribed by the Reserve Bank of India (RBI). The adequacy of the Company''s capital is monitored using, among other measures, the regulations issued by the RBI.

Nature and purpose of reserves :(i) Securities Premium Account

Securities premium account is used to record the premium on issue of shares. The reserve is utilised in accordance with the provisions of the Companies Act, 2013.

(ii) Employee stock options scheme outstanding

The shares options outstanding account is used to recognise the grant date fair value of options issued to employees under the stock option schemes of the Company.

(iii) Statutory reserves u/s 45-Ic of the RBI Act, 1934

Statutory reserve fund is required to be created by a Non-Banking Financial Company as per Section 45- IC of the Reserve Bank of India Act, 1934. The Company is not allowed to use the reserve fund except with the authorisation of the Reserve Bank of India.

(iv) capital Reserve

Capital reserve comprises of the amount received on share warrants & which are forfeited by the Company for nonpayment of call money.

(v) Retained earnings - other than Remeasurement of Post Employment Benefit Obligations

Retained earnings represents surplus of accumulated earnings of the Company and which are available for distribution to shareholders.

(vi) Retained earnings - Remeasurement of Post Employment Benefit Obligations

The Company recognises the change on account of remeasurement of the net defined benefit liabilities (assets) as a part of the retained earnings.

(vii) cash Flow Hedges Reserve

It represents the cumulative gains/(losses) arising on revaluation of the derivative instruments designated as cash flow hedges through the other comprehensive income (OCI).

36. Earnings per shareBasic and diluted earnings per share [EPS] computed in accordance with Indian Accounting Standard (indAS) 33 ‘Earnings per share'' :

Basic EPS calculated by dividing the net profit for the year attributable to equity holders by the weighted average number of equity shares outstanding during the year.

Diluted EPS amounts are calculated by dividing the profit attributable to equity holders (after adjusting profit impact of dilutive potential equity shares, if any) by the aggregate of weighted average number of equity shares outstanding during the year and the weighted average number of equity shares that would be issued on conversion of all the dilutive potential equity shares into equity shares.

The dilutive effect on the earnings per share is caused by the potential shares that would be issued upon the exercise of the ESOP options. As a result of the dilution, the denominator increased by 5,73,817 shares (Previous year : nil). During the year ended March 31, 2021 the potential equity shares were anti-dilutive in nature, hence the impact of the same was ignored for the purpose of computation of the diluted earnings per share.

37. Contingent liabilities and capital commitments:a. Contingent liabilities

All tax related liabilities till July 05, 2018 are covered by a deed of indemnity entered by existing promoters with erstwhile promoters. Further, there are no other contingent liability other than those covered under deed of indemnity.

b. Capital commitments		(Rupees in lakh)
Particulars	As at March 31, 2022	As at March 31, 2021
Commitments not provided for :
- Commitments related to loans sanction but undrawn	882.60	1,381.88
- Commitments related to loans sanction but partially undrawn	872.99	-
- Amount of contracts remaining to be executed on capital account	185.00	4700
Total	1,940.59	1,428.88

*Other commitments represent financial guarantees given for Co-lending arrangement entered by the Company during the year.

38. Segment Reporting

There is no separate reportable segment as per the Ind AS 108 "Operating Segments” specified under Section 133 of the Act. The Company operates in a single segment only. There are no operations outside India and hence, there are no reportable geographical segments.

39. corporate Social Responsibility

The average profit before tax of the Company for the last three financial years was '' 1,956.03 lakh, basis which the Company was required to spend Rs.39.12 lakh towards Corporate Social Responsibility (CSR) during the current financial year.

e) The additional disclosure with regard to CSR activities are summarized below:

(i) The amount of shortfall at the end of the year out of the amount required to be spent by the Company during the year - Nil

(ii) The total of previous years'' shortfall amounts - Nil

(iii) The reason for above shortfalls - Not applicable.

f) Nature of CSR activities

The Company is required to contribute to corporate social responsibility activities as per CSR Rules under the Companies Act, 2013. During the year the Company has spent '' 39.12 lakh which was the required amount to be spent under CSR activity. The amount is spent towards healthcare and education of the under-priviledged through an NGO.

The sensitivity analysis has been determined based on reasonably possible changes of the respective assumptions occurring at the end of the reporting period, while holding all other assumptions constant.

The sensitivity analysis presented above may not be representative of the actual change in the projected benefit obligation as it is unlikely that the change in assumptions would occur in isolation of one another as some of the assumptions may be correlated.

Furthermore, in presenting the above sensitivity analysis, the present value of the projected benefit obligation has been calculated using the projected unit credit method at the end of the reporting period, which is the same method as applied in calculating the projected benefit obligation as recognised in the Balance Sheet.

The Company has one stock option scheme ''CSL Employee Stock Option Scheme 2017''. The said scheme was approved by the board of directors on August 13, 2018 and by the shareholders in the EGM dated September 18, 2018.

During the year the Company has issued 270,769 (previous year 3,530,759) options representing equal numbers of equity shares of Rs. 10 each.

The nomination and remuneration committee shall have the authority to determine the exercise price having regard to the valuation report of an independent valuer if any. The said committee shall in its absolute discretion, have the authority to grant the options at such discount / premium as it may deem fit.

Fair value methodology :

The binomial model of valuation is more advanced and involves the use of computational techniques.In this model, the share price is projected from the date of grant to the date of exercise using upward and downward probabilities. The probabilities are estimated from the share price volatility assumption.

Keeping in view the multiple rules and events during vesting period, the Company switched to binomial method for valuation of it''s Share Options as the model is robust model and allows for more complicated rules and events during the vesting period. The fair value of options have been estimated on the date of the grant using Black-Scholes Model (For Grants XVI and XVII) and Binomial model(For Grants XVIII onwards) :

The Company as a lessee, recognises the right-of-use asset and lease liability at the lease commencement date. The right-of-use asset is measured by applying cost model i.e. right-of-use asset at cost less accumulated depreciation /impairment losses. The Company has entered into leasing arrangements for premises. Majority of the leases are cancellable by the Company. ROU asset has been included after the line "Property, Plant & Equipment” and lease liabilities has been included under "Other Financial Liabilities” in the Balance Sheet..

The entity has adequate liquidity for payment of lease liabilities. The Company regularly monitors and pays lease rentals on a timely manner as per the terms of the respective leave and license agreement.

The Company has the right to extend lease term as per mutually agreed terms laid down in the respective leave and license agreement. The Company takes into account effect of extended lease term while recording the lease assets and lease liabilities accordingly.

48. Financial risk managementThe Company has exposure to the following risks from financial instruments:

a. Credit Risk

b. Liquidity Risk

c. Market Risk

d. Operational Risk

The Company is exposed to a variety of risks such as credit risk, liquidity risk, market risk, operational risk, etc. The Company has therefore invested in talent, processes and emerging technologies for building advanced risk and underwriting capabilities. The Board of Directors has constituted a Risk Management Committee to address these risks. The Risk Management Committee''s mandate includes periodic review of the risk management policy, risk management planning, implementation and monitoring of the risk management plan and mitigation of key risks. The risk owners are accountable to the Risk Committee for identification, assessment, aggregation, reporting and monitoring of risks.The board of directors are responsible for providing overall risk oversight, approving risk appetite, risk management policies and frameworks and providing adequate oversight for the decisions.

(A) credit Risk

Risk Management team is engaged in defining a framework, overseeing enterprise wide risks and building a portfolio within the risk appetite of the company. The effective management of credit risk requires the establishment of appropriate credit risk policies and processes. The company has comprehensive and well-defined credit policies across various businesses, products and segments, which encompass credit approval process for all businesses along with guidelines for mitigating the risks associated with them. Credit underwriting is driven by a deep understanding of the selected segments, which forms proprietary risk models and approaches. The company believes in positive sector/sub-sector selection to source its business. Same is done primarily through Analytics and survey. Further the company has also developed sophisticated sector/sub-sector scorecards both statistical and expert. The proposals are appraised based on understanding of these sector/sub-sectors. Fine balance of sector knowledge, data analytics, touch and feel and digital process is used for underwriting the proposals. Given the dynamic nature of the market, the credit policies are regularly reviewed and amended.

Management of credit Risk Write off policy :

Financial assets are written off either partially or in their entirety only when the Company has stopped pursuing the recovery. Any subsequent recoveries are credited to impairment on financial instrument in Statement of profit and loss. The write off decisions will be taken by management which would be based on suitable justification notes presented by the responsible business / collections team.

credit quality analysis :

The Company''s policies for computation of expected credit loss are set out below:

(I) EcL on Loans and advancesEcL is computed for loans and investments portfolio of the company :Loan portfolio :

UGRO Capital Ltd is primarily engaged into SME lending and has segmented its lending portfolio based on the homogenous nature of group of borrowers.

As a result, Portfolio Segmentation considered for ECL computation for seventeen segments.

Definition of default :

A default shall be considered to have occurred when any of the following criteria are met:

a) An asset is more than 90 DPD.

b) If one facility of borrower is NPA, all the facilities of that borrower are to be treated as NPA.

Significant increase in credit risk (SICR) criteria :

(a) External credit rating going below investment grade rating.

(b) significant changes in the expected performance and behavior of the borrower, including changes in the payment status of borrowers.

(c) Other Qualitative parameters :

- existing or forecast adverse changes in business, financial or economic conditions that are expected to cause a significant change in the borrower''s ability to meet its debt obligations.

- an actual or expected significant adverse change in the regulatory, economic, or technological environment of the sector that results in a significant change in the sector''s ability to meet its debt obligations.

(d) Any other qualitative parameter.

Definition of low credit risk :

A case which has scores above cut-off norms as set by the Company from time to time and current status is Stage 1 is termed as low credit risk.

Forward looking factors :

Forward looking factors are considered while determining the significant increase in credit risk.

Staging criteria :

Following staging criteria is used for loans :

(i) Stage 1: 0-30 DPD;

(ii) Stage 2: 31-89 DPD and

(iii) Stage 3: >= 90 DPD

Any deviation to the above classification shall be approved by the audit committee of the board (ACB).

Probability of Default (PD%)

PDs are determined depending on the risk profile of the pool of loans based on the internal rating models, credit bureau models, corporate ratings, specific market estimates as applicable to the respective portfolio segments.

Loss given default (LGD%)

Loss given default (LGD) represents recovery from defaulted assets.

LGD computation is based on the Foundational-Internal Rating Based (F-IRB) approach or basis cashflows from post default workout and collections, as applicable to the respective portfolio segments.

LGD is determined based on F-IRB approach for Stage 1 and Stage 2 loans. For Stage 3, loans the Company estimates the cash flows expected over a time period.

Exposure at Default (EAD)

Exposure at default represents the outstanding balance at the reporting date plus expected drawdowns on committed facilities. UGRO Capital Ltd has considered the following for EAD computation :

a. On books principal exposure

b. Accumulated interest exposure

c. Excluding FLDG amount, if any

The Company actively participates in co-lending with other NBFC partners. In many of these deals there is a FLDG in the form of FD (or equivalent) or corporate guarantee. In such scenarios, while arriving at EAD, FLDG amount is subtracted. In case of default in such arrangements, if the trigger event occurs for both unsecured and secured loans on the 89th day, the POS plus accumulated interest would be adjusted from the FLDG. The interest accumulation to stop in the accounting books for such assets in case there is no principal outstanding.

(II) ECL on fixed deposits, investments, trade and other receivables

With respect to the Fixed Deposits and Investments held by the Company, ECL provisioning has been computed taking guidance from the RBI''s IRB approach.

The Company has followed Simplified Approach of ECL provisioning on its Trade and other receivables.

Applicable provisions for NBFcs covered under Ind AS:

RBI vide circular no. RBI/2019-20/170 DOR (NBFC).CC.PD.No.109/22.10.106/2019-20 dated 13 March, 2020 provides that NBFCs which are required to comply with Indian Accounting Standards (Ind AS) shall, as hitherto, continue to be guided by the guidelines duly approved by their board and as per the ICAI guidelines for recognition of the impairments. The Company follows the aforesaid circular.

Portfolio default and loss estimates :

To arrive at an early estimation of loss, an internally developed methodology has been adopted.

i) For term loans, the method combines macroeconomic outlook of the sector demand, entities'' cash in hand and losses incurred during/immediately after the lockdown period, to arrive at a projection of delinquency and loss.

ii) For SCF portfolio, the assessment is based on evaluation of anchors basis personal interviews conducted by the Company officers, focussing on the key business aspects such as capacity utilization, production impact, fixed costs v/s cash flow.

iii) For onward lending , the estimates are based on a client level assessment.

iv) For direct assignment, the estimates are based on partner assessment and high-level multipliers.

Further, the management will continue to review the situation and do this analysis at regular intervals during FY 2023 as the Company will have more data points and keep updating the analysis and make appropriate adjustments, as warranted and reflect the same in the financials also considering further regulatory guidance as may be forthcoming.

Impact of covid - 19 on expected credit loss :

The impact of COVID-19, including changes in customer behaviour and pandemic fears, as well as restrictions on business and individual activities, led to significant volatility in global and Indian financial markets and a significant decrease in global and local economic activities. The disruptions following the outbreak, impacted loan originations, MSME lending and the efficiency in collection efforts resulting in increase in the delinquency rates and consequent increase in provisions therefor.

India has now emerged from the COVID-19 pandemic and we have witnessed significant revival in the MSME sector in terms of demand resulting in increased disbursements and improved collection efficiency. The extent to which any new wave of COVID-19 will impact the Company''s results is estimated to be minimal with the increasing vaccination coverage in the country which will help in mitigating the risks associated with the pandemic and its impact thereof.

In view of the above, the Management estimates that in future there would be minimal impact of the pandemic on the Company.

Management Overlay :

The Company has maintained management overlay of '' 273.79 lakh towards its restructured loans and advances as at March 31, 2022.

b. Liquidity risk

Liquidity risk arises from the Company''s inability to meet its cash flow commitments on time. Prudent liquidity risk management implies maintaining sufficient stock of cash and marketable securities and maintaining availability of standby funding through an adequate line up of committed credit facilities. Our Treasury team actively manages asset and liability positions in accordance with the overall guidelines laid down by the regulator in the Asset Liability management framework. Company continues to maintain positive ALM.

The Company''s ALCO monitors asset liability mismatches to ensure that there are no imbalances or excessive concentrations on either side of the Balance Sheet. The Company continuously monitors liquidity in the market; and as a part of its ALCO strategy.

(vi) Institutional set-up for liquidity risk management :

The Company monitors its inflows and outflows in various buckets and ensures that there are no major mismatches in the assets and liabilities in various buckets. The ALM is tabled and evaluated in the ALCO on a monthly basis. The Company ensures that there is adequate liquidity cushion available in the form of investments in G-Secs/T-Bills/Mutual Funds etc. and unavailed Bank lines. The Company issues various instruments including Term Loans, Lines of Credit, Non-Convertible Debentures, External Commercial Borrowings and other market instruments.

c. Market Risk

Market risk is the risk that the fair value of the future cash flows of financial instruments will fluctuate due to changes in market variables such as interest rates. The Company does not have any direct exposure to foreign currency (refer foreign currency risk note below).

The Company primarily deploys funds in bank deposits and liquid debt securities as a part of its liquidity management approach. The Company regularly reviews its average borrowing / lending cost including proportion of fixed and floating rate borrowings / loans so as to manage the impact of changes in interest rates.

Exposure to price risk :

The Company''s exposure to price risk arises from investments held by the Company and is classified in the Balance Sheet through fair value through profit and loss account.

Interest rate risk :

Interest rate risk is the risk where changes in market interest rates might adversely affect the Company''s financial conditions. The interest rate risk can be viewed from the two perspectives as mentioned below:

a. Earnings perspective - change in net interest income (NII) or net interest margin (NIM) due to change in interest rates.

b. Economic value perspective - change in market value of the company due to change in the company''s assets, liabilities and off-Balance Sheet positions due to variation in interest rates.

The board has established limits on the interest rate gaps for stipulated periods. The management monitors these gaps on a regular basis to ensure that the positions are maintained within the established limits.

Foreign Currency Risk

Currency risk is the risk that the value of a financial instrument will fluctuate due to changes in foreign exchange rates. Foreign currency risk for the company arises mainly on account of the foreign currency borrowings. The company manages this foreign currency risk by entering into cross currency interest rate swaps and forward contract. When a derivative is entered into for the purpose of being as hedge, the company negotiates the terms of those derivatives to match with the terms of the hedge exposure. The company''s policy is to fully hedge its foreign currency borrowings at the time of drawdown and remain so till repayment.

The company holds the derivative financial instruments such as cross currency interest rate swaps to mitigate the risk of changes in exchange rate in foreign currency and floating interest rate. The counterparty for these contracts is generally a bank. These derivative financial instruments are valued based on the quoted prices for similar assets and liabilities in active markets or inputs that are directly or indirectly observable in the market place.

d. Operational Risk

Operational risk is the risk of loss arising from systems failure, human error, fraud or external events. When controls fail to operate effectively, operational risks can cause damage to reputation, have legal or regulatory implications, or may lead to financial loss. The Company cannot expect to eliminate all operational risks, but it endeavors to manage these risks through a control framework and by monitoring and responding to potential risks. Controls include maker-checker controls, effective segregation of duties, access, authorisation and reconciliation procedures, staff education and assessment processes, such as the use of internal audit.

The Company''s capital management objective is primarily to safeguard the business continuity. The Company''s capital raising policy is aligned to the macro-economic situations and incidental risk factors. The Company''s cashflows are regularly monitored in sync with the annual operating plans and the long-term and other strategic investment plans. The operational funding requirements are met through debt and operating cash flows generated. The company believes that this approach would create shareholder value in the long run. Also, the company has adopted a conservative approach for ALM management with primacy to adequate liquidity. At present, a large portion of the company''s resource base is equity. Therefore, the company enjoys a low gearing.

Unrecognised deductible temporary differences, unused tax losses and unused tax credits :

There are no deductible temporary differences, unused tax losses and unused tax credits for which no deferred tax assets have been recognised.

51. Fair value of financial instruments :

Fair value is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction in the principal (or most advantageous) market at the measurement date under current market conditions, regardless of whether that price is directly observable or estimated using a valuation technique.

Ind AS 107, ''Financial Instruments - Disclosure'' requires classification of the valuation method of financial instruments measured at fair value in the Balance Sheet using a three-level fair-value-hierarchy (which reflects the significance of inputs used in the measurements). The hierarchy gives the highest priority to un-adjusted quoted prices in active markets for identical assets or liabilities (Level 1 measurements) and lowest priority to unobservable inputs (Level 3 measurements). The three levels of the fair-value-hierarchy under Ind AS 107 are described below:

Level 1: Level 1 hierarchy includes financial instruments measured using quoted prices.

Level 2: The fair value of financial instruments that are not traded in an active market is determined using valuation techniques which maximise the use of observable market data and place limited reliance on the entity specific estimates. If all significant inputs required to fair value an instrument are observable, the instrument is included in level 2.

Level 3: If one or more of the significant inputs is not based on observable market data, the instrument is included in level 3.

Valuation methodologies of financial instruments not measured at fair value :Short-term financial assets and liabilities :

For financial assets and financial liabilities that have a short-term nature, the carrying amounts, which are net of impairment, are a reasonable approximation of their fair value. Such instruments include: cash and bank balances, trade receivables, other receivables, balances other than cash and cash equivalents ,payables, debt securities, other financial assets and other financial liabilities .

Loans and advances to customers :

The fair values of loans and receivables are calculated using a portfolio-based approach, grouping loans as far as possible into homogenous groups based on similar characteristics. The fair value is then extrapolated to the portfolio using discounted cash flow models that incorporate interest rate estimates considering all significant characteristics of the loans. Impairment loss allowance and adjustments related to effective interest rate are not part of above disclosure.

Borrowings :

The fair values of these instruments are estimated by determining the price of the instrument taking into consideration the origination date, maturity date, coupon rate, actual or approximation of frequency of interest payments and incorporating the actual or estimated / proxy yields of identical or similar instruments through the discounting factor. For instruments, having contractual residual maturity less than one year, the carrying value has been considered as fair value.

2. Exchange traded interest rate (IR) derivatives

The Company has not entered into any exchange traded derivative.

3. Disclosures on risk exposure and derivativesQualitative Disclosures

II. The Company undertakes the derivative transactions to prudently hedge the risk in context of a particular borrowing or diversify sources of borrowing and to maintain fixed and floating borrowing mix. The Company does not indulge into any derivative trading transaction. The Company reviews the proposed transaction and outlines any consideration associated with the transaction, including identification of the benefits and potential risks (worst case scenario) ; an independent analysis of potential savings from the proposed transaction. The Company evaluates all the risks inherent in the transaction viz. , counter party risk , market risk, operational risk, basis risk, etc.

II. Credit risk is controlled by restricting the counter parties that the Company deals with, to those who either have banking relationship with the Company or are internationally reowned or can provide sufficient information. Market/ price risk arising from the fluctuation of interest rates and foreign exchange rates or from other factors shall be closely monitored and controlled. Normally transaction entered for hedging, will run over the life of the underlying instrument, irrespective of profit or loss. Liquidity risk is controlled by restricting counter parties to those who have adequate facility, sufficient information and sizable trading capacity and capability to enter into transactions in any market around the world.

56 Note on Social Security Code

The Code on Social Security 2020 (''the Code'') relating to employee benefits, during the employment and post-employment, has received Presidential assent on September 28, 2020. The Code has been published in the Gazette of India. Further, the Ministry of Labour and Employment has released draft rules for the Code on November 13, 2020. However, the effective date from which the changes are applicable is yet to be notified and rules for quantifying the financial impact are also not yet issued. The Company will assess the impact of the Code and will give appropriate impact in the financial statements in the period in which, the Code becomes effective and the related rules to determine the financial impact are published.

57 Events after the reporting period

There have been no events after the reporting date that require disclosure in these financial statements.

58 Total Fixed Deposits stand at '' 762.29 lakh as at March 31, 2022 (Previous year '' 630.10 lakh) on account of securitisation transactions.

60 The company has not purchased any credit impaired financial assets during the financial year 2021-22. However, the company has transferred certain credit impaired assets to the Asset Reconstruction Company in terms of guidelines issued by RBI circular number DOR.STR.REC.51/21.04.048/2021-22 dated September 24, 2021. Further, the company has not sold any credit impaired financial asset to institutions other than to securitization/reconstruction Company (SC/RC) [refer note no. 71(c)].

61 The Company does not hold any immovable property as at 31st March 2022 and 31st March 2021. All the lease agreements are duly executed in the favour of the Company for properties where the Company is the lessee.

62 The Company does not have any transactions with the Companies struck off under section 248 of Companies Act, 2013 or section 560 of Companies Act, 1956 during the year ended 31 March 2022 and 31 March 2021.

63 No proceedings have been initiated or pending against the Company for holding any benami property under the Benami Transactions (Prohibition) Act, 1988 and rules made thereunder, as at 31 March 2022 and 31 March 2021.

64 The Company is not a declared wilful defaulter by any bank or financial institution or other lender, in accordance with the guidelines on wilful defaulters issued by the Reserve Bank of India, during the year ended 31 March 2022 and 31 March 2021.

66 There have been no transactions which have not been recorded in the books of accounts, that have been surrendered or disclosed as income during the year ended 31 March 2022 and 31 March 2021, in tax assessments under the Income Tax Act, 1961. There have been no previously unrecorded income and related assets which were to be properly recorded in the books of account during the year ended 31 March 2022 and 31 March 2021.

67 The Company has not traded or invested in crypto currency or virtual currency during the year ended 31 March 2022 and 31 March 2021.

68 Disclosure under rule 11(e) of the Companies (Audit and Auditors) Rules, 2014:

(a) - The Company has not advanced or loaned or invested funds (either borrowed funds or share premium or any other sources or kind of funds) to any other person(s) or entity(ies), including foreign entities (Intermediaries) with the understanding (whether recorded in writing or otherwise) that the Intermediary shall

- 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

- Provide any guarantee, security or the like to or on behalf of Ultimate Beneficiaries:

(b) - 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

- 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

- Provide any guarantee, security or the like to or on behalf of Ultimate Beneficiaries:

69 Gold Loans

The Company does not provide any loans on collateral of gold and gold jewellery.

73 Previous year figures have been reclassified / regrouped wherever necessary to conform to / with the current year classification / disclosure.

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Mar 31, 2015

Note 1 Segment Reporting

The Company treats Share Trading Activity, Commodity Trading Activity, Inter-Corporate Deposits and Loan Given and taken to company (under the same Management) as single segment. Therefore, no Segment Reporting is required.

Note 2

In the opinion of the Board of Directors, Current Assets, Loans and Advances have the value at which these are stated in the Balance Sheet to be realized in the ordinary course of business and the provision for all known liabilities is adequate and not in excess of or less than the amount reasonably necessary.

Note 3 - Deferred Tax Asset/Liability

There are no Deferred Tax Asset or Liability in current and previous year.

Note 4 - Related Party Disclosures

Name of the Party Relationship

Ramakant R. Chokhani Key Management Personnel

Manish Chandrahas Parikh Key Management Personnel (CFO)

Transaction during the year

For the year ended For the year ended Particulars 31 March, 2015 31 March, 2014

Managerial Remuneration to Manish Chandrahas Parikh for the month of March, 2015 26,000 -

Note 5

Previous year''s figures have been regrouped or rearranged or reclassified wherever necessary.

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Mar 31, 2014

Note 1 Segment Reporting

The Company treats Share Trading Activity, Commodity Trading Activity, Inter-Corporate Deposits and Loan Given and taken to company (under the same Management) as single segment. Therefore no Segment Reporting is required.

Note 2

In the opinion of the Board of Directors, Current Assets, Loans and Advances have the value at which these are stated in the Balance Sheet, if realized in the ordinary course of business and the provision for all known liabilities is adequate and not in excess of or less than the amount reasonably necessary.

Note 3 - Deferred Tax Asset/Liability

There are no Deferred Tax Asset or Liability in current and previous year.

Note 4

Previous year''s figures have been regrouped or rearranged or reclassified wherever necessary.

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Mar 31, 2013

Note 1 Segment Reporting

The Company treats Share Trading Activity, Commodity Trading Activity, Inter-Corporate Deposits and Loan Given and taken to company (under the same Management) as single segment. Therefore no Segment Reporting is required.

Note 2

In the opinion of the Bozard of Directors, Current Assets, Loans and Advances have the value at which these are stated in the Balance Sheet, if realized in the ordinary cours eof business and the provision for all known liabilities is adequate and not in excess of or less than the amount reasonably necessary.

Note 3 - Deferred Tax Asset/Liability

There are no Deferred Tax Asset or Liability in current and previous year.

Note 4

Previous year''s figures have been regrouped or rearranged or reclassified wherever necessary.

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Mar 31, 2012

1 Segment Reporting

The company treats Share Trading Activity and Inter-Corporate Deposits and Loan given and taken to company (under the same Management) as single segment. Therefore no Segment Reporting is required.

2 Contingent Liabilities

(a) Contingent Liabilities on account of contracts remaining to be executed on capital account NIL

(b) Claims not acknowledged by the Company relating to cases contested by the Company :

(Rs in lakhs)

Particulars 2011-12 2010-11

Income Tax Matter (Pending before Appellate Authorities in 111.77 NIL respect of which the Company is in appeal)

3 In the opinion of the Board of Directors, Current Assets, Loans and Advance have the value at which these are stated in the Balance Sheet, if realized in the ordinary course of business and the provisions for all known liabilities is adequate and not in excess of or less than the amount reasonably necessary.

4. Deferred Tax

Deferred tax is recognized on timing differences between taxable income and accounting income that originate in one period and are capable of reversal in one or more subsequent period in accordance with AS 22- Accounting for Taxes on Income issued by The Institute of Chartered Accountants of India.

5. Previous year''s figures have been regrouped or rearranged or reclassified wherever necessary.

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Mar 31, 2011

1. SEGMENT REPORTING:

The company treats Share Trading Activity And Inter-Corporate Deposits as single segment. Therefore no Segment Reporting is required.

2) DEFERRED TAX:

Deferred tax is recognized on timing differences between taxable income and accounting income that originate in one period and are capable of reversal in one or more subsequent period in accordance with AS 22- Accounting for Taxes on Income issued by The Institute of Chartered Accountants of India.

3) CONTINGENT LIABILITIES :

a) Contingent Liabilities on account of contracts remaining to be executed on capital account NIL

b) Claims against the Company not acknowledged as debts NIL.

OTHER NOTES:

a) In the opinion of the Board of Directors, Current Assets, Loans and Advance have the value at which these are stated in the Balance Sheet, if realized in the ordinary course of business and the provisions for all known liabilities is adequate and not in excess of or less than the amount reasonably necessary.

b) During the year, management conducted test for impairment of fixed assets as per guideline given under Accounting Standard 28 "Impairment of Assets" and accordingly management impaired full value of fixed assets of company since the future cash flow from assets impaired and net realizable value as on date of balance sheet is negligible.

c) Previous years figures have been regrouped or rearranged or reclassified wherever necessary.

---

Mar 31, 2010

1. SEGMENT REPORTING:

The Company treats the Share Trading as a Single Business Segment and hence segment wise information is not given.

2. DEFERRED TAX :

Deferred tax is recognized on timing differences between taxable income and accounting income that originate in one period and are capable of reversal in one or more subsequent period in accordance with AS 22- Accounting for Taxes on Income issued by The Institute of Chartered Accountants of India.

3. CONTINGENT LIABILITIES :

a) Contingent Liabilities on account of contracts remaining to be executed on,capital account NIL

b) Claims against the Company not acknowledged as debts NIL.

OTHER NOTES:

a) In the opinion of the Board of Directors, Current Assets, Loans and Advance have the value at which these are stated in the Balance Sheet, if realized in the ordinary course of business and the provisions for all known liabilities is adequate and not in excess of or less than the amount reasonably necessary.

b) In the opinion of the Management the fixed assets of the Company can reasonably fetch the amount at which they are carried in the books. Therefore the assets are not impaired and do not call for recognizing loss in accordance with the AS-28 issued by the Institute of Chartered Accountants of India.

c) Previous years figures have been regrouped or rearranged or reclassified wherever necessary.

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Mar 31, 2009

1. SEGMENT REPORTING:

The Company treats the Share Trading as a Single Business Segment and hence segment wise information is not given.

2. CONTINGENT LIABILITIES :

a) Contingent Liabilities on account of contracts remaining to be executed on capital account NIL

b) Claims against the Company not acknowledged as debts NIL. OTHER NOTES:

a) In the opinion of the Board of Directors, Current Assets, Loans and Advance have the value at which these are stated in the Balance Sheet, if realized in the ordinary course of business and the provisions for all known liabilities is adequate and not in excess of or less than the amount reasonably necessary.

b) In the opinion of the Management the fixed assets of the Company can reasonably fetch the amount at which they are carried in the books. Therefore the assets are not impaired and do not call for recognizing loss in accordance with the AS-28 issued by the Institute of Chartered Accountants of India.

c) Previous years figures have been regrouped or rearranged or reclassified wherever necessary.

---

Mar 31, 2008

1. SEGMENT REPORTING:

The Company treats the Share Trading as a Single Business Segment and hence segment wise information is not given.

2. CONTINGENT LIABILITIES :

a) Contingent Liabilities on account of contracts remaining to be executed on capital account NIL

b) Claims against the Company not acknowledged as debts NIL.

I. OTHER NOTES:

a) In the opinion of the Board of Directors, Current Assets, Loans and Advance have the value at which these are stated in the Balance Sheet, if realised in the ordinary course of business and the provisions for all known liabilities is adequate and not in excess of or less than the amount reasonably necessary.

b) In the opinion of the Management the fixed assets of the Company can reasonably fetch the amount at which they are carried in the books. Therefore the assets are not impaired and do not call for recognizing loss in accordance with the AS-28 issued by the Institute of Chartered Accountants of India.

c) Previous years figures have been regrouped or rearranged or reclassified wherever necessary.

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Mar 31, 2007

1. SEGMENT REPORTING:

The Company treats the Share Trading as a Single Business Segment and hence segment wise information is not given.

2. EARNINGS PER SHARE :

Computation for the basic earning 2006-2007 2005-2006 per share of Rs.10 each. Amount (Rs.) Amount (Rs.)

1 Net profitless) available for Equity Shareholders. 2.27,42,124 62,03,716

2 Number of equity shares for baste earning per share 46,98,500 46,98,500

3 Basic Earning Per Share Rs. 4.84 Rs. 1.32

There are no Diluted Equity Shares and hence no working for diluted earnings per share.

3. DEFERRED TAX :

Deferred tax is recognized on timing differences between taxable income and accounting income that originate in one period and are capable of reversal in one or more subsequent period in accordance with AS 22- Accounting for Taxes on Income issued by The Institute of Chartered Accountants of India.

The deferred tax asset as at 31st March 2007 comprise of the following:

2006-2007 2005-2006 Rs. Rs.

Opening Deferred Tax Assets 6,882/- 21,882/-

Deferred Tax (Assets)/Liability: -

On Depreciation AND Public issue exps difference 18160/- 15,000/-

Prior year Deferred Tax Adjustment 32,000/- -

Closing Deferred Tax Asset/(Liability) 57,042/- 6,882/-

4. CONTINGENT LIABILITIES :

a) Contingent Liabilities on account of contracts remaining to be executed on capital account NIL

b) Claims against the Company not acknowledged as debts NIL.

II. OTHER NOTES:

a) In the opinion of the Board of Directors, Current Assets, Loans and Advance have the value at which these are stated in the Balance Sheet if realised in the ordinary course of business and the provisions for all known liabilities is adequate and not in excess of or less than the amount reasonably necessary.

b) In the opinion of the Management the fixed assets of the Company can reasonably fetch the amount at which they are carried in the books. Therefore the assets are not impaired and do not call for recognizing loss in accordance with the AS-28 issued by the Institute of Chartered Accountants of India.

c) Previous years figures have been regrouped or rearranged or wherever necessary.

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Mar 31, 2006

1. SEGMENT REPORTING:

The Company treats the Share Trading as a Single Business Segment and hence segment wise information is not given.

2. EARNINGS PER SHARE :

Computation for the basic earning per 2005-2006 2004-2005 share of Rs.10 each Amount (Rs.) Amount (Rs.)

1 Net profit/(loss) available for Equity 62,03,716 64,27,045 Shareholders.

2 Number of equity shares for basic earning 46,98,500 46,98,500 per share

3 Basic Earning Per Share Rs.1.32 Rs.1.37

There are no Diluted Equity Shares and hence no working for diluted earnings per share.

4. DEFERRED TAX :

Deferred tax is recognized on timing differences between taxable income and accounting income that originate in one period and are capable of reversal in one or more subsequent period in accordance with AS 22- Accounting for Taxes on Income issued by The Institute of Chartered Accountants of India.

The deferred tax asset as at 31st March 2006 comprise of the following:

2005-2006 2004-2005 Rs. RS.

Opening Deferred Tax Assets 21,882/- 38,882/-

Deferred Tax (Assets) Liability:-

On Depreciation difference 15,000/- 17,000/-

Closing Deferred Tax Asset/(Liability) 6,882/- 21,882/-

5. CONTINGENT LIABILITIES :

a) Contingent Liabilities on account of contracts remaining to be executed on capital account NIL

b) Claims against the Company not acknowledged as debts NIL.

II. OTHER NOTES:

a) In the opinion of the Board of Directors, Current Assets, Loans and Advance have the value at which these are stated in the Balance Sheet, if realised in the ordinary course of business and the provisions for all known liabilities is adequate and not in excess of or less than the amount reasonably necessary.

b) In the opinion of the Management the fixed assets of the Company can reasonably fetch the amount at which they are carried in the books. Therefore the assets are not impaired and do not call for recognizing loss in accordance with the AS-28 issued by the Institute of Chartered Accountants of India.

c) Previous years figures have been regrouped or rearranged or reclassified wherever necessary.

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Mar 31, 2004

1. SEGMENT REPORTING:

The Company treats the Share Trading as a Single Business Segment and hence segment wise information is not given.

2. EARNINGS PER SHARE :

March 31.2004 March 31.2003

A. Profit (After Tax) as per Profit & Loss Account Rs. 1,96,73,203/- Rs. (1,569,951)

B. Reconciliation for No. of calculating the Earnings Shares (Basic) used Per each for Share of Rs. 10/-

3. DEFERRED TAX :

The deferred tax asset as at 31st March 2004 comprise of the following:

2003-2004 2002-2003 Deferred Tax Liability: -

Depreciation difference Rs.6,937/- Rs.8,937/-

Deferred Tax Asset: -

Preliminary & Public Issue Expenses Rs.45,929/- Rs 27,819/-

Net Deferred Tax Asset Rs.38,882/- Rs. 18.882/-

4. CONTINGENT LIABILITIES :

a) Contingent Liabilities on account of contracts remaining to be executed on capital account NIL

b) Claims against the Company not acknowledged as debts NIL.

E. OTHER NOTES:

a) In the opinion of the Board of Directors, Current Assets, Loans and Advance have the value at which these are stated in the Balance Sheet, if realised in the ordinary course of business and the provisions for all known liabilities is adequate and not in excess of or less than the amount reasonably necessary.

b) Previous years figures have been regrouped or rearranged or reclassified wherever necessary.

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Mar 31, 2003

1 SEGMENT REPORTING:

The Company treats the Share Trading as a Single Business Segment and hence segment wise information is not given.

2 EARNINGS PER SHARE :

March 31. 2003 March 31. 2002

A. Profit (After Tax) as per Profit & Loss Rs. (1,569,951) Rs. 13,083,464 Account

There are no Diluted Equity Shares and hence no working for diluted earnings per share.

3. DEFERRED TAX :

The deferred tax asset as at 31st March 2003 comprise of the following:-

2002-2003 2001-2002

Deferred Tax Liability: Depreciation difference Rs. 8,937/- Rs.11,773/- Deferred Tax Asset:

Preliminary & Public Issue Expenses Rs.27,819/- Rs.41,232/-

Net Deferred Tax Asset Rs.18.882/- Rs. 29,459/-

4 CONTINGENT LIABILITIES :

a) Contingent Liabilities on account of contracts remaining to be executed on capital account NIL

b) Claims against the Company not acknowledged as debts NIL.

5. OTHER NOTES:

a) In the opinion of the Board of Directors, Current Assets, Loans and Advance have the value at which these are stated in the Balance Sheet, if realised in the ordinary course of business and the provisions for all known liabilities is adequate and not in excess of or less than the amount reasonably necessary.

b) Previous years figures have been regrouped or rearranged or reclassified wherever necessary.

---

Mar 31, 2002

1. SEGMENT REPORTING:

The Company treats the Share Trading as a Single Business Segment and hence segment wise information is not given.

2. DEFERRED TAX:

During the year, the Company has for the first time accounted for Deferred Tax in accordance with Accounting Standard 22 "Accounting for Taxes on Income" issued by the Institute of Chartered Accountants of India. Consequently, the Company has recognised in these financial statements the deferred tax assets/liabilities accumulated prior to April 1, 2001 and credited the net deferred tax assets of Rs. 39,862/- to Profit & Loss Account as on April 1, 2001 and has charged the Profit & Loss Account with the Deferred Tax Liability relating to the year net of Rs. 10,403/-. However no deferred tax assets/liabilities accumulated prior to April 1, 2001, has been recognised on the assets sold/written off during the year.

Deferred Tax Asset on account of Preliminary & Public Issue Expenses has been recognised, as the Company is of the opinion that there is virtual certainty of realisation of the same in view of the profits of the Company.

3. CONTINGENT LIABILITIES:

a) Contingent Liabilities on accouct of contracts remaining to be executed on capital account NIL

b) Claims against the Company not acknowledged as debts NIL.

4. OTHER NOTES:

a) In the opinion of the Board of Directors; Current Assets, Loans and Advance have the value at which these are stated ia the Balance Sheet, if realised in the ordinary course of business and the provisions for all known liabilities is adequate and not in excess of or less than the amount reasonably necessary.

b) Previous years figures have been regrouped or rearranged or reclassified wherever necessary.

---

Mar 31, 2001

A) In the opinion of the Board of Directors, Current Assets, Loans and Advance have the value at which these are stated in the Balance Sheet, if realised in the ordinary course of business and the provisions for all known liabilities is adequate and not in excess of or less than the amount reasonably necessary.

b) Previous year's figures have been regrouped or rearranged or reclassified wherever necessary.

---

Mar 31, 1999

CONTINGENT LIABILITIES :

a) Contingent Liabilities on account of contracts remaining to be executed On capital account NIL

b) Claims against the Company not acknowledged as debts NIL.

1. Y2K Issue :

The Company has taken appropriate and effective steps to be Y2K compliant. The expenditure to ensure Y2K compliance is not material

2. In the opinion of the Board of Directors, Current Assets, Loans and Advance have the value at which these are stated in the Balance Sheet, if realised in the ordinary course of business and the provisions for all known liabilities is adequate and not in excess of or less than the amount reasonably necessary.

3. Previous years figures have been regrouped or rearranged or reclassified wherever necessary.

---

Mar 31, 1998

A. In the opinion of the Board of Directors, Current Assets, Loans and Advance have the value at which these are stated in the Balance Sheet, if realised in the ordinary course of business and the provisions for all known liabilities is adequate and not in excess of or less than the amount reasonably necessary.

b. A sum of Rs. 20,46,600/- has been disclosed under VDIS 1997 by way of reversal of depreciation claimed of Rs. 15,38,600/- for the accounting year 1994-95 and Rs. 5,08,000/- for the accounting year 1995-96 and VDIS Tax of Rs. 7,16,310/- has been paid thereof.

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Mar 31, 1997

CONTINGENT LIABILITIES :

a) Contingent Liabilities on account of contracts remaining to be executed on capital account NIL

b) Claims against the Company not acknowledged as debts NIL.

OTHER NOTES :

a. In the opinion of the Board of Directors, Current Assets, Loans and Advance have the value at which these are stated in the Balance Sheet, if realised in the ordinary course of business and the provisions for all known liabilities is adequate and not in excess of or less than the amount reasonably necessary.

b. Previous years figures have been regrouped or rearranged or reclassified wherever necessary.

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Sep 30, 1995

1. Previous years figures have been regrouped/rearranged wherever considered necessary.

2. AUDITORS FEES :

Current Previous Year Year Rupees Rupees ------- -------- a) Statutory Audit Fees 10,000 5,000 b) Tax Audit Fees 7,500 - ------- --------- 17,500 5,000 ------- ---------

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Sep 30, 1994

No Information Available.