Note 3.1 Disclosures

i. Refer to Note 48 for information on Property, Plant & Equipment hypothecated as security by the Company.

ii. Refer Note 40 for disclosure of contractual commitments for the acquisition of Property, Plant and Equipment.

iii. All Immovable properties are held in the name of the Company. However, mutation of immovable property situated at Village - Mohra, District Bijnor, Uttar Pradesh having carrying amount of H4,57,830 in the name of Company in the records of local authority is still pending and in progress.

iv. There are no proceedings against the Company that have been initiated or pending against them for holding any benami property under the Benami Transactions (Prohibition) Act, 1988 (45 of 1988) and the rules made thereunder.

Note 11.2 : Other Disclosures:

a) There are no outstanding receivables due from directors or other officers of the Company and firms and companies in which any director is a partner or a director or a member.

b) Refer Note 50 for information about credit risk and market risk on receivables.

c) Refer Note 48 for information on trade receivable hypothecated as security by the Company.

Balances includes term deposit accounts with original maturity period of more than three months and not more than twelve months, pledged as security with banks for issuance of Bank Guarantee and Letter of Credit.

c. Terms and rights attached to Equity Shares

The Company has a single class of equity shares having face value of H10 per share. Accordingly, all equity shares rank equally with regard to dividends and share in the Company's residual assets. The voting rights of an equity shareholder are in proportion to its share of the paid-up equity capital of the Company. Voting rights cannot be exercised in respect of share on which any call or other sums presently payable have not been paid.

The Company declares and pays dividend in Indian rupees. The holders of the equity shares are entitled to receive dividends as declared from time to time. In the event of liquidation of the Company, the holders of equity shares will be entitled to receive any of the 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.

d. Dividend

The Board of Directors of the company proposed final dividend of H2.50 per equity share for the financial year 2023-24. in its meeting dated April 24, 2024. The Company paid final dividend of H3.50 per share for the financial year 2022-23, during the year.

g. Aggregate number and class of shares bought back:

The Company has not bought back shares in the last five years immediately preceding the balance sheet date.

h. No equity shares were allotted as fully paid up by way of bonus shares during the last five years as at the date of balance sheet. However 66387590 Equity shares have been allotted on May 23, 2022 in terms of Scheme of Arrangement without payment received in cash.

(i) Capital Reserve

Capital reserve was created on transfer of demerged undertakings to the Company under the Scheme of Demerger and repesent the excess of book value of assets transferred over the book value of liability assumed and amount of share capital issued.

(ii) Storage fund/reserve for molasses

The storage fund for molasses has been created to meet the cost of construction and maintenance of molasses storage tank as required under Uttar Pradesh Sheera Niyantran (Sansodhan) Adesh, 1974.

(iii) Retained Earnings

Retained earnings represents the undistributed profit / amount of accumulated earnings of the Company.

(iv) Other Comprehensive Income

Other comprehensive income (OCI) represents the balance in equity relating to re-measurement gain/(loss) of defined benefit obligation which will not be reclassified to the statement of profit and loss.

Pursuant to introduction of Section 115BAA of the Income Tax Act, 1961, the Domestic Companies now have an option to pay Corporate income tax at reduce rate plus applicable surcharge and cess (New Tax Rate) by foregoing certain exemptions/deductions. During the year, the Company has assessed the financial year in which it will be able to opt for new Tax rate regime and accordingly has measured its deferred tax assets and liabilities using the income tax rates applicable in the year of reversal. This has resulted in reversal of deferred tax liabilities of Rs. 4.37 crore (P.Y. Rs. 14.52 crore) during the year.

*The Company is in process of rectifying these returns and is confident that demand will be substantially reduced.

# The amount shown above represents the best possible estimates arrived on the basis of available information. The uncertainties and timing of the cash flows are dependent on the outcome of the different legal process which have been invoked by the company or the claimants as the case may be, therefore it cannot be estimated accurately. The Company does not expect any reimbursement in respect of above contingent liabilities.

III. Legal Cases

i) Honorable Allahabad High Court in the case of PIL Rashtriya Kisan Mazdoor Sangathan VS State of U.P. passed a final order on March 09, 2017 directing the Cane Commissioner to decide afresh the issue as to whether the Sugar Mills are entitled for waiver of interest on the delayed payment of the price of sugarcane for the seasons 2012-13, 2013-14 and 2014-15 under the provisions of Section 17(3) of the U.P Sugarcane (Regulations of Supply and Purchase) Act, 1953 (in short 'the Act').The matter is yet to be finalised and pending before Supreme Court for adjudication. Based on the legal review of the facts of the case and considering past practice, no liability is likely to crystalise on the Company in this matter.

ii) Cane societies are in dispute with the State Government of Uttar Pradesh with regard to retrospective partial waiver of society commission payable by the sugar mills for the crushing seasons 2012-13, 2014-15 and 2015-16. Company was the beneficiary of such waiver. The matter is yet to be finalised and pending before Supreme Court for adjudication. Based on the legal review of the facts of the case and considering past practice, no liability is likely to crystalise on the Company in this matter.

Note 42: Revenue

The disclosures pertaining to disaggregation of revenue and performance obligation in terms of Ind AS 115 - Revenue from contracts with customers are as follows:

(a) Sugar

The Sugar segment of the Company principally generates revenue from manufacturing and sale of sugar and its by-products. Domestic sales of sugar is made on ex-factory terms/agreed terms to wholesale /institutional buyers/merchant exporters within the country. Domestic sugar sales is majorly done on advance payment terms.

Export sales of sugar to merchant exporters are done on ex-factory /delivered basis in terms of the agreement and revenue is recognised when the goods have been shipped to / delivered to the buyers' specific location (as per agreed terms). The sale price and payment terms is fixed as per contracted terms.

Power is supplied to distribution companies from the Company's facilities in accordance with the sale price, payment terms and other conditions as per the Power Purchase Agreements ("PPA").

Bagasse and pressmud are sold generally on advance payment terms agreed to wholesaler /institutional buyer /to customers on exfactory basis in terms of the agreement and revenue is recognised when the goods have been shipped to/delivered to the buyer.

(b) Bio Fuels & Spirits

The Bio Fuels & Spirits segment of the Company principally generates revenue from sale of industrial alcohol which mainly constitutes ethanol sold under contracts with Public and Private Oil Marketing Companies ("OMCs") and other products to institutional buyers.

For sale of ethanol under contracts with OMCs, sale price is pre-determined based on Expression of Interest ("EOI")/Tender floated from OMCs. The prices are on delivered cost basis at OMC's locations inclusive of all duties/levies/taxes/charges etc. Payment terms for sale of ethanol is within 45 days after delivery of material and submission of original invoices.

Other products like ENA, SDS etc. are sold on bulk basis to institutional buyers on ex-factory basis as per agreed terms. Revenue is recognised when goods have been shipped to the buyers' specific location as per agreed terms. The payment terms are fixed as per Company's credit policy which is up-to 45 days.

(c) Country Liquor

The Country Liquor segment of the Company principally generates revenue from sale of country liquor to CL2 Licence holders within state (i.e. Uttar Pradesh). Sales price of Country liquor includes freight cost and all duties including excise duty. Country liquor are sales majorly on advance payment terms.

a) The Central Government, vide its Notification No. 1(10)/2018-SP-I dated July 19, 2018, notified a Scheme with a view to increase production of ethanol by enhancing the number of working days of existing in a year by installation new Incineration boilers or by adoption any other matter approved by Central Pollution Control Board (CPCB) for Zero Liquid Discharge (ZLD) in a distillery. Every Sugar Mill which fulfil the conditions stipulated in the scheme will be eligible for the interest subvention @ 6% per annum or 50% of the rate of interest charged by bank, whichever is lower, on the loans to be extended by banks, shall be borne by central Government for five years. Till March 31, 2024, the Company has complied with all the conditions as stated in the scheme and submitted the claim for interest subvention. The interest subvention accrued under the Scheme till March 31,2024 is H8.35 crore (P.Y. H5.96 crore) and out of which H1.05 crore (P.Y. H1.04 crore) has been received till March, 2024.

b) The State Government, with a view to improve the liquidity position of private sector sugar mills of the State enabling them to clear the cane price arrears of crushing seasons 2016-17 and 2017-18 and timely settlement of cane price as per State Advised Price (SAP) fixed by the State Government, to the sugarcane farmers, has notified the scheme, namely "Scheme for Extending Financial Assistance to Sugar Undertakings-2018" vide notification No.: 15 /2018/1719/46-3-18-3 (36-A) / 2018 dated October 16, 2018. The Company had availed the term loan in the F.Y 2018-19 under the Scheme, wherein, the government grant has been received in form of Subsidized rate of interest.

Note 45: Segment Reporting

I) Identification of Segments

The Company's operating segments are established on the basis of those components of the Company that are evaluated regularly by the Board of Director's (the 'Chief Operating Decision Maker' as defined in Ind AS 108 - 'Operating Segments').

The chief operational decision maker monitors the operating results of its Business Segments separately for the purpose of making decisions about resource allocation and performance assessment. Segment performance is evaluated based on profit or loss and is measured consistently with profit or loss in the financial statements. Operating Segments have been identified by the management and reported taking into account, the nature of products and services, the differing risks and returns, the organization structure, and the internal financial reporting systems.

II) Operating Segments

The Company is organized into three main business segments, namely:

- Sugar which consists of manufacture and sale of Sugar and its byproducts along with co-genration and sale of power,

- Bio Fuels & Spirits which consists of manufacture and sale of SDS, ENA, Ethanol, sanitizer etc.

- Country Liquor.

No operating segments have been aggregated in arriving at the aforesaid reportable segments of the Company.

III) Geographical segments

Since the Company's activities/ operations are primarily within the country and considering the nature of products/ services it deals in, the risks and returns are same and as such there is only one geographical segment.

IV) Segment Accounting Policies:

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

a) Segment revenue and results:

Revenue and expenses directly attributable to segments are reported under each reportable segment. Other expenses and incomes which are not directly attributable to any business segment are shown as unallocable expenses (net of unallocated income).

b) Segment assets and liabilities:

Assets and liabilities that are directly attributable or allocable to segments are disclosed under each reportable segment. Unallocated assets include deferred tax, investments, interest bearing deposits loans to subsidiary and income tax refund. Unallocated liabilities include interest bearing liabilities, tax provisions and deferred tax. Capital expenditure pertains to additions made to fixed assets during the year and includes capital work in progress.

c) Inter segment sales/transfer:

Transactions between segments are primarily for materials which are transferred at cost /market determined prices. These transactions are eliminated in consolidation.

C. Terms and Conditions of Settlement

The transactions with the related parties are made on term equivalent to those that prevail in arm's length transactions. The assessment is under taken each financial year through examining the financial position of the related party and in the market in which the related party operates. Outstanding balances at the year end are un-secured and settlement occurs in cash.

Note 47: Employees benefits

The required disclosures of employees benefits as per Indian Accounting Standard (Ind AS) -19 are given hereunder :-

(i) Defined contribution plan :

The Company's defined contribution plans are Employees' Pension Scheme, Employees' Provident Fund (under the provisions of Employees' Provident Funds and Miscellaneous Provisions Act, 1952) and Employees State Insurance. The Company has no further obligations beyond making the contributions.

(ii) Defined benefit plan :

In respect of defined benefit scheme of gratuity (Based on actuarial valuation) :

The gratuity plan is governed by the payment of Gratuity Act,1972. Under the said Act an employee who has completed five years of services is entitled to specific benefit. The Gratuity Plan provides a lump-sum payment to vested employees at retirement, death, incapacitation or termination of employment, of an amount based on the respective employee's salary and the tenure of employment with the Company.

In respect of defined scheme of Compensated absences

The accumulated Compensated absences, expected to be carried forward beyond the period of twelve months from the reporting date as per Company's policy, are measured on Acturial valuation using projected unit credit method for the unused entitlement and respective employee's salary

The Company is exposed to various risks in providing the above defined benefit which are as follows:

Interest Rate risk : The plan exposes the Company to the risk of fall in interest rates. A fall in interest rates will result in an increase in the ultimate cost of providing the above benefit and will thus result in an increase in the value of the liability (as shown in financial statements).

Salary escalation risk : The present value of the defined benefit plan is calculated with the assumption of salary increase 0.50% per annum of plan participants in future. Deviation in the rate of increase of salary in future for plan participants from the rate of increase in salary used to determine the present value of obligation will have a bearing on the plan's liability.

Actual mortality & disability :Deaths & disability cases proving lower or higher than assumed in the valuation can impact the liabilities. The following tables summaries the components of net benefit expense recognized in the statement of Profit and Loss

Sensitivity analysis presented above may not be representative of the actual change in the defined 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.

The sensitivity analysis above has been determined based on a method that extrapolates the impact on defined benefit obligation as a result of reasonable changes in key assumptions occurring as at the balance sheet date.

All sensitives are calculated using the same actuarial method as for the disclosed present value of the defined benefits obligation at year end.

Note 48: Borrowings- Nature of Security and Terms of Repayment a) Nature of Security in respect of Long Term Borrowings:

(i) Rupee term loan from PNB (funded by State Government UP.) is secured by first parri passu charge on block of fixed assets and current Assets of the Company and further secured by personal guarantee of Managing Director of the Company .

(ii) Rupee term loan from PNB is secured by first pari passu charge on block of fixed assets of the Company and further secured by personal guarantee of Managing Director of the Company.

(iii) Rupee Term loan from PNB are secured by first pari passu charge on entire block of assets of Asmoli Unit of the Company and further secured by personal guarantee of Managing Direcror of the Company

(iv) Rupee term loan from HDFC Bank are secured by first parri passu charge on all the movable fixed assets of the Company, both present and future and further secured by personal guarantee of the Managing Director of the Company.

(v) Rupee term loan from ICICI Bank are secured by first parri passu charge on all the movable fixed assets of the Company, both present and future.

(vi) Rupee term loan from Sugar Development Fund (SDF) are secured by first parri passu charge over the movable and immovable properties of Division - Sugar, situated at unit Asmoli of the Company. The term loan was sanctioned in the name of Dhampur Sugar Mills Limited, the Demerged Company and pending documentation for transfer it in name of the Company. The same is continuing in the name of Demerged Company. The outstanding amount of loan is NIL as of March 31,2024.

c) Nature of Security in respect of Short Term Borrowings:

Working Capital facility from Punjab National Bank are secured :

- by way of first parri passu charge and pledge of stocks of sugar and sugar-in-process both present and future.

- by way of first parri passu charge and hypothecation of molasses, bagasse, general stores, chemicals unit finished goods/raw material, co-generation unit raw material, book debts etc. both present and future of the Company.

- by way of third parri passu charge on the block of fixed assets/immovable properties of the Company.

Working Capital facility from ICICI Bank are secured :

- by way of first pari passu charge on current assets of the company.

- by way of third parri passu charge on the block of fixed assets/immovable properties of the Company.

Working Capital facility from all District Co-operative Banks are secured:

- by way of pledge of stocks of sugar

- by personal guarantee of Managing Director of the Company Working Capital facility from Prathma U P Gramin Bank are secured:

- by way of first pari passu charge on sugar stock of white crystal/raw sugar/ BISS & other processed sugar in bags and sugar in process.

- by way of third parri passu charge on the block of fixed assets/immovable properties of the Company.

- by personal guarantee of Managing Director of the Company

Working Capital facility from HDFC Bank are backed by:

- by way of first pari passu charge on current assets of the company.

- by way of third parri passu charge on the block of fixed assets/immovable properties of the Company.

Note 49: Financial instruments - Accounting, classification and fair value measurement I. Financial instruments by category

The criteria for recognition of financial instruments is explained in accounting policies of Company.

II Method and assumptions used to estimate fair values:

1. Fair value of cash and cash equivalents, bank balances other than cash and cash equivalents, trade and other receivables, other current financial assets, short term borrowings from banks and financial institutions, trade and other payables and other current financial liabilities approximate their carrying amounts due to the short-term nature of these instruments.

2. The fair values of borrowings (non-current) consisting of loans from banks and government authorities are determined by using discounted cash flow method that reflects the Company's borrowing rate at the end of the reporting period. The own nonperformance risks as at year end was assessed to be insignificant.

III Fair Value Hierarchy

The fair value of the financial assets and financial liabilities are 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 table provides the fair value measurement hierarchy of Company's asset and liabilities, grouped into Level 1 to Level 3 as described below :-

Level 1: Quoted prices (unadjusted) in active markets for identical assets or liabilities.

Level 2: Inputs other than quoted prices included within Level 1 that are observable for the asset or liability, either directly or indirectly.

Level 3: Inputs for the assets or liabilities that are not based on observable market data (unobservable inputs).

Management uses its best judgement in estimating the fair value of its financial instruments. However, there are inherent limitations in any estimation technique. Therefore, for substantially all financial instruments, the fair value estimates presented above are not necessarily indicative of the amounts that the Company could have realized or paid in sale transactions as of respective dates. As such, the fair value of financial instruments subsequent to the reporting dates may be different from the amounts reported at each reporting date.

Note 50: Financial Risk Management

The company has in place comprehensive risk management policy in order to identify measure, monitor and mitigate various risks pertaining to its business. Along with the risk management policy, an adequate internal control system, commensurate to the size and complexity of its business, is maintained to align with the philosophy of the company. Together they help in achieving the business goals and objectives consistent with the Company's strategies to prevent inconsistencies and gaps between its policies and practices. The Board of Directors/ committees reviews the adequacy and effectiveness of the risk management policy and internal control system. The Company's financial risk management is an integral part of how to plan and execute its business strategies. The Company has exposure to the following risks arising from financial instruments:

Ý Credit risk

Ý Liquidity risk and

Ý Market risk

I. Credit risk

Credit risk is the risk that counterparty will not meet its obligations under a financial instrument or customer contract, leading to a financial loss. The Company's sugar sales and country liqour sales are mostly on advance. Power and ethanol are sold to state government entities and oil manufacturing companies respectively, thereby the credit default risk is significantly mitigated.

The impairment for trade receivables are based on assumptions about risk of default and expected loss rates. The Company uses judgement in making these assumptions and selecting the inputs to the impairment calculation, based on the Company's past history, existing market conditions as well as forward looking estimates at the end of each balance sheet date.

Financial assets are written off when there is no reasonable expectation of recovery, however the Company continues to attempt to recover the receivables. Where recoveries are made, subsequently these are recognized in the statement of profit and loss. The Company's major exposure of credit risk is from trade receivables, which are unsecured and derived from external customers.

The Company uses a provision matrix to determine impairment loss on portfolio of its trade receivable. The provision matrix is based on its historically observed default data over the expected life of the trade receivable and is adjusted for forward- looking estimates. At every reporting date, the historical observed default rates are updated and changes in forward-looking estimates are analysed. In case of probability of non collection, default rate is 100%. However, there is no material expected credit loss based on the past experience.

II. Liquidity Risk

Liquidity risk is defined as the risk that company will not be able to settle or meet its obligation on time or at a reasonable price. The Company's objective is to at all times maintain optimum levels of liquidity to meet its cash and collateral requirements. The Company's management is responsible for liquidity, funding as well as settlement management. In addition, processes and policies related to such risk are overseen by senior management. Management monitors the company's net liquidity position through rolling, forecast on the basis of expected cash flows.

(i) Maturities of financial liabilities

The following are the remaining contractual maturities of financial liabilities at the reporting date. The amounts are gross and undiscounted, and excluding contractual interest payments and exclude the impact of netting agreements

(III) Market Risk

Market 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 three types of risk: interest rate risk, currency risk and other risks, such as regulatory risk and commodity price risk. Financial instruments affected by market risk include loans and borrowings, trade receivables and trade payables involving foreign currency exposure, and inventories.

The sensitivity analysis in the following sections relate to the position as at March 31, 2023 and March 31, 2022. The sensitivity of the relevant profit or loss item is the effect of the assumed changes in respective market risks. This is based on the financial assets and financial liabilities held at March 31,2024 and March 31,2023.

(a) Foreign 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 used foreign currency forward contracts to hedge its risks associated with foreign currency fluctuations relating to certain firm commitments. The use of foreign currency forward contracts is governed by the Company's strategy approved by the Board of Directors, which provide principles on the use of such forward contracts consistent with the Company's Risk Management. The outstanding forward exchange contracts entered into by the company at the year end are as under:

Sensitivity analysis -

A reasonably possible strengthening (weakening) of the Indian Rupee, by 2%, against all other currencies would have affected the measurement of financial instruments denominated in a foreign currency profit or loss by the amounts shown below. This analysis assumes that all other variables, in particular interest rates, remain constant and ignores any impact of forecast sales and purchase.

Derivative financial instruments

The Company holds derivative financial instruments such as foreign currency forward contracts to mitigate the risk of changes in exchange rates on foreign currency exposures. The counterparty is generally a bank. These derivative financial instruments are valued based on quoted prices for similar assets and liabilities in active markets or inputs that are directly or indirectly observable in the marketplace.

(b) Regulatory risk

Sugar industry is regulated both by Central Government as well as State Government. Central and State Governments policies and regulations affects the Sugar industry and the Company's operations and profitability. Distillery business is also dependent on the Government policy.

(c) Commodity price risk

Sugar industry being cyclical in nature, realizations get adversely affected during downturn. Higher cane price or higher production than the demand ultimately affect profitability. The Company has mitigated this risk by well integrated business model by diversifying into co-generation and distillation, thereby utilizing the by-products.

(d) Interest rate risk

Interest rate risk is the risk that the fair value or future cash flows of a financial instrument will fluctuate because of changes in market interest rates.

As the Company does not have exposure to any floating-interest bearing assets, or any significant long-term fixed interest bearing assets, its interest income and related cash inflows are not affected by changes in market interest rates. Consequently, the Company's interest rate risk arises mainly from borrowings obligations with floating interest rates.

(e) Price Risk

The company's exposure to equity securities price risk arises from investments held by the company and classified in the balance sheet at fair value through Statement of profit and loss. Since the company does not have any material equity investments measured at fair value though Statement of profit and loss, there is no material price risk exposure at the end of the financial year.

Note 51: 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 shareholders of the Company. The Company's capital management is intended to maximize the return to shareholders for meeting the long-term and short-term goals of the Company through the optimization of the debt and equity balance.

The Company manages its capital structure and makes adjustments in light of changes in the financial condition 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 (buy back its shares) or issue new shares. The Capital structure of the company consists of net debt (borrowings offset by cash and bank balances) and equity of the Company (Comprising issued capital, reserves and retained earnings).

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. The Company has complied with these covenants and there have been no breaches in the financial covenants of any interest-bearing loans and borrowings.

The Company's policy is to maintain a strong capital base so as to maintain investor, creditor and market confidence and to sustain future development of the business. The primary objective of the Company's Capital Management is to maximize the shareholder's value. Management also monitors the return on capital. The Board of Directors seek to maintain a balance between the higher returns that might be possible with higher levels of borrowing and the advantages and security afforded by a sound capital position.

Note 53: Events occurring after the balance sheet date

The Company evaluates events and transactions that occur subsequent to the balance sheet date but prior to approval of financial statement to determine the necessity for recognition and/or reporting of any of these events and transactions in the financial statements. As of 24^th April, 2024 there were no material subsequent events to be recognized or reported that are not already disclosed.

Note 54: Offsetting financial instruments

There are no financial instruments which are offset, or subject to enforceable master netting arrangements and other similar agreements but not offset, as at each reporting date.

Note 55: Accidental Loss

During the previous year, due to an accident, certain quantity of 'B' Heavy molasses stored in storage tank was drained out and spread over the factory premises. The Company recognises insurance claim recoverable from insurance company equivalent to the amout of estimated loss of H 7.27 Crore, recognised in the finanacial statements.

Note 56: Code on Social Security, 2020

The Code on Social Security, 2020 ('Code') relating to employee benefits during employment and post employment received Indian Parliament approval and Presidential assent in September 2020. The Code has been published in the Gazette of India and subsequently on November 13, 2020 draft rules were published and invited for stakeholders' suggestions. However, the date on which the Code will come into effect has not been notified. The Company will assess the impact of the Code when it comes into effect and will record any related impact in the period the Code becomes effective.

Note 57: Reconciliation of quarterly bank returns

Note for discrepancies :

The Bank returns were prepared and filed before the completion of all financial statement closure activities including Ind AS related adjustments/ reclassifications, as applicable, which led to these differences between the final books of accounts and the bank return which were based on provisional books of accounts. Further difference also arises on account of different valuation methodology adopted for valuing the finished goods stock in the books and for the purpose of reporting in the bank return. In the books, stock of finished goods is recorded at lower of cost or net realisable value but for bank purposes it is taken at net realisable value which is determined as per bank norms.

(ii) Creation of charges in respect of term loans availed from the lenders in respect of mortgage of land and building and hypothecation of fixed assets are duly executed as the respective agreements for mortgage/hypothecation are yet to be executed except land situated at Village - Mohra, District Bijnor, Uttar Pradesh, India.

(iii) The Company has not traded or invested in Crypto currency or Virtual Currency during the period/year.

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

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

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

(v) 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.

(vi) The Company does not have any transaction which is not recorded in the books of accounts that has been surrendered or disclosed as income during the year in the tax assessments under the Income Tax Act, 1961 (such as, search or survey or any other relevant provisions of the Income Tax Act, 1961).

(vii) The company has not granted any loans or advances in the nature of loans to promoters, directors, KMPs, and the related parties(as defined under Companies Act, 2013), either severally or jointly with any other person, that are:

a) repayable on demand; or

b) granted without specifying any terms or period of repayment

(viii) The Company has not declared a wilful defaulter by any banks or any other financial institution at any time during the financial year.

(ix) The Company has complied with the number of layers prescribed under clause (87) of section 2 of the Act read with Companies (Restriction on Number of layers) Rules, 2017 as amended.

Note 59: Other Notes

(i) In the opinion of the Board of Directors, trade receivables, other current financial assets, and other current assets have a value on realization in the ordinary course of the company's business, which is at least equal to the amount at which they are stated in the balance sheet.

(ii) The Board of Directors at its meeting held on 24^th April, 2024 has approved the Financial Statement for the year ended March 31,2024.