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Whirlpool of India Ltd. Notes to Accounts
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You can view the entire text of Notes to accounts of the company for the latest year
Market Cap. (Rs.) 9105.59 Cr. P/BV 2.14 Book Value (Rs.) 336.05
52 Week High/Low (Rs.) 1437/706 FV/ML 10/1 P/E(X) 31.00
Bookclosure 28/08/2026 EPS (Rs.) 23.15 Div Yield (%) 0.70
Year End :2026-03 

31 EARNINGS PER SHARE (EPS)

Basic EPS amounts are calculated by dividing the profit for the year attributable to equity holders of the
Company 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 of the Company by
the weighted average number of equity shares outstanding during the year plus the weighted average number
of equity shares that would be issued on conversion of all the dilutive potential equity shares into equity
shares. There are no convertible preference shares or debentures being issued by the Company.

32 SIGNIFICANT ACCOUNTING JUDGEMENTS, ESTIMATES AND ASSUMPTIONS

The preparation of the standalone financial statements requires management to make judgements, estimates
and assumptions that affect the reported amounts of revenues, expenses, assets and liabilities, and the
accompanying disclosures, and the disclosure of contingent liabilities. Uncertainty about these assumptions
and estimates could result in outcomes that require a material adjustment to the carrying amount of assets
or liabilities affected in future years.

Judgements

In the process of applying the Company's accounting policies, management has made the following judgements,
which have the most significant effect on the amounts recognised in the standalone financial statements.

Determining the lease term of contracts with renewal and termination options-Company as a lessee

The Company determines the lease term as the non-cancellable term of the lease, together with any periods
covered by an option to extend the lease if it is reasonably certain to be exercised, or any periods covered by
an option to terminate the lease, if it is reasonably certain not to be exercised.

The Company has several lease contracts that include extension and termination options. The Company applies
judgement in evaluating whether it is reasonably certain whether or not to exercise the option to renew or
terminate the lease. That is, it considers all relevant factors that create an economic incentive for it to exercise

either the renewal or termination. After the commencement date, the Company reassesses the lease term if
there is a significant event or change in circumstances that is within its control and affects its ability to exercise
or not to exercise the option to renew or to terminate.

Revenue from contracts with customers

The Company applied the following judgements that significantly affect the determination of the amount and
timing of revenue of contract with customers:

Determining method to estimate variable consideration and assessing the constraint:

Certain contracts for the sale of products include a right to return and volume rebates that give rise to variable
consideration. In estimating the variable consideration, Company is required to use either the expected value
method or the most likely amount method based on which method better predicts the amount of consideration
to which it will be entitled.

The Company determined that the expected value method is the most appropriate method in estimating the
variable consideration for the sale of products with rights to return and volume rebates, given the large number
of customer contracts that have similar characteristics. In estimating the variable consideration for the sale of
product with volume rebates, the Company determined that using a combination of the most likely amount
method and expected value method is appropriate. The selected method that better predicts the amount of
variable consideration was primarily driven by the number of volume thresholds contained in the contract.
The most likely amount method is used for those contracts with a single volume threshold, while the expected
value method is used for contracts with more than one volume threshold.

Before including any amount of variable consideration in the transaction price, the Company considers whether
the amount of variable consideration is constrained. The Company determined that the estimates of variable
consideration are not constrained based on its historical experience, business forecast and the current
economic condition. In addition, the uncertainty on the variable consideration will be resolved within a short
time frame.

Estimates and assumptions

The key assumptions concerning the future and other key sources of estimation uncertainty at the reporting
date, that have a significant risk of causing a material adjustment to the carrying amounts of assets and
liabilities within the next financial year, are described below. The Company based its assumptions and estimates
on parameters available when the financial statements were prepared. Existing circumstances and assumptions
about future developments, however, may change due to market changes or circumstances arising that are
beyond the control of the Company. Such changes are reflected in the assumptions when they occur.

Share-based payments

The Company measures the cost of equity-settled transactions with employees by erstwhile ultimate holding
company using a Black Scholes Options Pricing model to determine the fair value of the liability incurred.
Estimating fair value for share-based payment transactions requires determination of the most appropriate
valuation model, which is dependent on the terms and conditions of the grant. This estimate also requires
determination of the most appropriate inputs to the valuation model including the expected life of the share
option, volatility and dividend yield and making assumptions about them. The assumptions and models used
for estimating fair value for share-based payment transactions are disclosed in note 34.

Defined benefit plans (gratuity benefits)

The cost of the defined benefit gratuity plan and the present value of the gratuity obligation are determined
using actuarial valuations. An actuarial valuation involves making various assumptions that may differ from

actual developments in the future. These include the determination of the discount rate, future salary increases
and mortality rates. Due to the complexities involved in the valuation and its long-term nature, a defined
benefit obligation is highly sensitive to changes in these assumptions. All assumptions are reviewed at each
reporting date.

The parameter most subject to change is the discount rate. In determining the appropriate discount rate for
plans operated in India, the management considers the interest rates of government bonds where remaining
maturity of such bond correspond to expected term of defined benefit obligation.

The mortality rate is based on publicly available mortality tables. Those mortality tables tend to change only
at interval in response to demographic changes. Future salary increases and gratuity increases are based on
expected future inflation rates. Further details about gratuity obligations are given in note 33.

Fair value measurement of financial instruments

When the fair values of financial assets and financial liabilities recorded in the balance sheet cannot be
measured based on quoted prices in active markets, their fair value is measured using valuation techniques
including the DCF model. The inputs to these models are taken from observable markets where possible, but
where this is not feasible, a degree of judgement is required in establishing fair values. Judgements include
considerations of inputs such as liquidity risk, credit risk and volatility. Changes in assumptions about these
factors could affect the reported fair value of financial instruments. See note 41 and 42 for further disclosures.

Revenue recognition-Estimating variable consideration for returns and volume rebates

The Company estimates variable considerations to be included in the transaction price for the sale of products
with rights of return and volume rebates.

The Company developed a statistical model for forecasting sales returns. The model used the historical return
data of each product to come up with expected return percentages. These percentages are applied to determine
the expected value of the variable consideration. Any significant changes in experience as compared to historical
return pattern will impact the expected return percentages estimated by the Company.

The Company expected volume rebates are analysed on a per customer basis for contracts that are subject to
a single volume threshold. Determining whether a customer will be likely entitled to rebate will depend on the
customer's historical rebates entitlement and accumulated purchases to date.

The Company applied a statistical model for estimating expected volume rebates for contracts with more
than one volume threshold. The model uses the historical purchasing patterns and rebates entitlement of
customers to determine the expected rebate percentages and the expected value of the variable consideration.
Any significant changes in experience as compared to historical purchasing patterns and rebate entitlements
of customers will impact the expected rebate percentages estimated by the Company.

The Company updates its assessment of expected returns and volume rebates quarterly and the refund
liabilities are adjusted accordingly. Estimates of expected returns and volume rebates are sensitive to changes
in circumstances and the Company's past experience regarding returns and rebate entitlements may not be
representative of customers' actual returns and rebate entitlements in the future.

Product warranties accruals

The provisions for product warranties, on account of goods sold, recorded in the balance sheet on the basis
of actuarial valuations. An actuarial valuation involves making various assumptions that may differ from actual
developments in the future. These include the determination of the discount rate and failure rates. Due to the
complexities involved in the valuation and its long-term nature, a provision for product warranty is highly
sensitive to changes in these assumptions. All assumptions are reviewed at each reporting date.

The parameter most subject to change is the discount rate. In determining the appropriate discount rate, the
management considers the interest rates of government bonds in currencies consistent with the currencies
of the product warranty provision.

The failure rate is based on actual number of calls received by the Company from customers on account of
complaints.

Further details about provisions for product warranties are given in note 16.

Taxes

Uncertainties exist with respect to the interpretation of complex tax regulations, changes in tax laws, and the
amount and timing of future taxable income. Given the nature of business differences arising between the
actual results and the assumptions made, or future changes to such assumptions, could necessitate future
adjustments to tax income and expense already recorded. The Company establishes provisions, based on
reasonable estimates. The amount of such provisions is based on various factors, such as experience of
previous tax audits and different interpretations of tax regulations by the taxable entity and the responsible
tax authority. Such differences of interpretation may arise on a wide variety of issues depending on the
conditions prevailing in the jurisdiction of the Company.

Leases

As the Company's lease agreements normally do not provide an implicit interest rate, we apply the Company's
incremental borrowing rate based on the information available at commencement date in determining the
present value of future lease payments. Relevant information used in determining the Company's incremental
borrowing rate includes the duration of the lease, location of the lease, and the Company's credit risk relative
to risk-free market rates.

33 GRATUITY AND OTHER POST-EMPLOYMENT BENEFIT PLANS

Gratuity (being administered by a Trust) is computed as 15 days salary, for every completed year of service or
part thereof in excess of 6 months and is payable on retirement/termination/resignation. The benefit vests
on the employee completing 5 years of service. The Gratuity plan for the Company is a defined benefit scheme
where annual contributions as demanded by the insurer are deposited, to a Gratuity Trust Fund established
to provide gratuity benefits. The Trust has taken an Insurance policy, whereby these contributions are
transferred to the insurer. The Company makes provision of such gratuity asset/ liability in the books of
account on the basis of actuarial valuation carried out by an independent actuary.

The Company also provide certain additional retirement benefits to the employees of the Faridabad
Refrigeration Operations where INR 35,000 and Puducherry Washer Operations where INR 30,000 is paid to
employee on retirement. This retirement benefit is an unfunded defined benefit scheme. The Company makes
provision of such liability on the basis of actuarial valuation carried out by an independent actuary.

The following tables summarise the components of net benefit expense recognised in the statement of profit
or loss and the net funded status and amounts recognised in the balance sheet for the respective plans:

The average duration of the defined benefit plan obligation at the end of the reporting period is 12.51 years
(31 March 2025: 12.62 years).

34 SHARE-BASED PAYMENTS

The Company does not provide any share-based compensation to its employees. However, the erstwhile
ultimate holding company, Whirlpool Corporation, USA has provided various share-based payment schemes
to employees.

A. Description of share-based payment arrangements

I. Restricted Stock Units (RSU) & Performance Stock Units (PSU)

a. Performance based- These are the units of stock granted to employee at nil exercise price. It
converts one for one shares of Whirlpool Corporation at the end of the vesting period of three
years.

b. Time based- These are the units of stock granted to employee at nil exercise price. It converts
one for one shares of Whirlpool Corporation at the end of the vesting period in the following
manner: -

i) One third of the option vests after one year, another one third vests after two years and
final one third will vests after three years.

ii) Vesting for one half option after two years and rest after four years.

iii) Vesting for one half option after one year and rest after three years.

II. Employee Stock Options

A stock option gives an employee, the right to purchase shares of Whirlpool Corporation at a fixed
price for a specific period of time. The grant price (or strike price) is fixed based on the closing price
of Whirlpool Corporation common stock on the date of grant. Stock options vest in three equal
annual instalments and expire in ten years from the date they are granted.

a. (i) Transfer Pricing Adjustments: For AY 2004-05 to 2005-06, the pending Transfer Pricing (TP)
litigation of INR 1,708 lacs (31 March 2025: INR 1,708 lacs) on account of TP adjustment made
in the TP assessment for alleged short fall in profit on account of differences in the arm's
length price and prices charged/received by the Company from associated enterprises alongwith
the disallowance of other expenses of INR 928 lacs (31 March 2025: INR 928 lacs) are pending
for adjudication / re-computation before the ITAT. The year wise facts and updates are as
follows:-

AY 2004-05 - The company in the earlier years received a revised final assessment order from
the TPO / AO giving effect to the ITAT order directing re-computation of TP adjustments on the
appeal of the Revenue against the CIT-A order deleting the TP adjustments of INR 7,968 lacs as
per the original TP / assessment order. The TPO while giving effect to the ITAT order sustained
an addition of INR 633 lacs (March 2025: INR 633 lacs) attributing the same to the alleged
general functions performed by WOIL on behalf of its AE's. The DRP, on the objection of the
company, directed the TPO/ AO to pass a speaking order but the TPO/ AO continued with the
TP adjustment of INR 633 lacs (31 March 2025: INR 633 lacs) against which, the company is in
appeal for second time before the ITAT.

AY 2005-06 - The Company in the earlier years received a favorable order from the ITAT wherein
the ITAT deleted TP adjustments of INR 9,327 lacs (31 March 2025: INR 9,327 lacs) by upholding
the CIT(A) order restricting the TP adjustment to the international transaction only. For balance
adjustments of INR 407 lacs, ITAT had set aside the issue to the AO / TPO for re-computation of
the TP adjustments. During the course of set aside proceedings, the TPO vide his order dt. 27
Jan 2025 has re-computed the arms length margin and enhanced the adjustment to INR 1,075
lacs and the AO has considered the same and passed its draft order dated 24 March 2025. The
DRP on the objection of the company, passed its directions without providing any relief on the
said additions. Accordingly, AO passed final order confirming the same additions as was made
in the draft order against which, the company is in appeal for second time before the ITAT.

(ii) AY 2020-21 to 2023-24 - Transfer Pricing Adjustment on account of AMP and other issues

During the previous year, the Hon'ble Supreme Court of India vide its order dated Nov 20,
2024 [SLP No. 29270/2016], had dismissed the Revenue's SLP against the Delhi High Court's
judgment in respect of the said expenditure and decided in favour of the Company for the A.Y.
2008-09 and deleted the disallowance of INR 20,343 Lacs. Accordingly, the Income tax
department had not made adjustments in the fresh assessments related to A.Y. 2022-23. Basis
the above favourable order, the matter had now attained finality in the case of the Company
and accordingly the pending cases (at various appellate forums) on the similar issue in the
subsequent years will accordingly be dealt with in due course.

Considering the said judgement of the Hon'ble Supreme Court of India, the management
believes that no tax liability will devolve upon the Company in respect of the AMP adjustments
made for the remaining assessment years and contingent liability aggregating to INR 1,03,639
lacs (March 31, 2025 - INR 1,31,184) assessed as remote and not disclosed in financial
statements.

AY 2020-21 - The company in the previous year received assessment order where in the TPO/
AO in its order made Transfer Pricing adjustment on account of AMP expenses (as mentioned
above) and TP adjustment of INR 5,032 lacs (31 March 2025: INR 5,032 lacs) in the Trading
Segments. The company filed an appeal before the ITAT against the said assessment order
which is pending for disposal.

AY 2022-23 - The company in the previous year received draft assessment order wherein the
TPO/ AO made Transfer Pricing adjustment of INR 470.91 lacs (31 March 2025: INR 470.91
lacs). The DRP on the objection of the company, passed its directions without providing any
relief on the said additions. Accordingly, AO passed final order confirming the same additions
as was made in the draft order against which, the company is in appeal before the ITAT which
is pending for disposal.

AY 2023-24 - The company during the year received draft assessment order wherein the TPO/
AO in its order made Transfer Pricing adjustment of INR 2,130.80 lacs (31 March 2025: INR
NIL). The company filed an objection against the draft assessment order before the DRP which
is pending for disposal.

b. Other than transfer pricing adjustments:

In the Income-tax assessments for preceding assessment years, AY 1994-95 to AY 2020-21 the
Assessing Officer (AO) had made disallowances / additions of various expenses and claims of the
company for which the appeal(s) of the company and also the revenue are pending at various forums.

For AY 1994-95 to 2023-24, the pending Non-TP litigation of INR 11,423 lacs (31 March 2025: INR
10,715 lacs) on account of Non-Transfer Pricing (TP) adjustment (majorly on account of R&D expenses,
bad debts, provision for package tour / travel expenses and other disallowances). During the current
year, following is the update.

AY 2005-06 - During the course of set aside proceedings as mentiond above, the AO vide his order
dt. 24 March 2025 sustained the addition of INR 928 lacs (31 March 2025: INR 928 lacs) on acount of
claim of depreciation and disregarded the recitfication orders passed in the earlier years on the
same issue, since the claim of depreciation was still not verified by the AO and no order was being
passed for the current year as directed by the CIT(A) in the first round of proceedings. The DRP on
the objection of the company, passed its directions expressing their inability to decide on this ground
considering jurisdictional issue Accordingly, AO passed final order confirming the same additions

as was made in the draft order against which, the company is in appeal for second time before the
ITAT.

AY 2022-23 - The AO made Non-Transfer Pricing adjustment of INR 1479 lacs (31 March 2025: INR
1479 lacs) during the course of assessment procedings which was upheld by DRP considering that
the said addition were made by CPC and hence not lie within the scope of variation proposed in the
draft order. Accordingly, AO passed final order confirming the same additions as was made in the
draft order against which, the company is in appeal before the ITAT which is pending for disposal.

AY 2023-24 - The AO made Non-Transfer Pricing adjustment of INR 708.27 lacs (31 March 2025: INR
NIL) during the course of assessment procedings by referring to the adjustments in the intimation
issued by CPC for the said year. The company filed an objection against the draft assessment order
before the DRP which is pending for disposal.

All of the above-mentioned matters are pending with various judicial/appellate authorities including
Dispute Resolution Panel, CIT(Appeals), Income Tax Appellate Tribunal, High Court. For some of the
matters, judicial / appellate authorities have decided the cases in favor of the Company. However,
these are being contested again by the Revenue.

The Parent Company based on its assessment of ongoing litigations, believes that it has merit in
these cases and it is only possible, but not probable that these cases may be decided against the
Company except as per point no. a(ii) above. Hence, these have been disclosed as contingent liability
and no provision is required to be considered in the standalone financial statements.

39 HEDGING ACTIVITIES AND DERIVATIVES

Derivatives not designated as hedging instruments

The Company uses foreign exchange forward contracts to manage some of its transaction exposures. The
foreign exchange forward contracts are not designated as hedge instrument and are entered into for periods
consistent with foreign currency exposure of the underlying transactions, generally for the following period:

- From one to twelve months in case of vendor payments

40 FAIR VALUES

The management assessed that cash and cash equivalents, trade receivables, loans, other receivables, trade
payables and other current liabilities approximate their carrying amounts largely due to the short-term
maturities of these instruments.

The loss allowance on the financial assets are disclosed in note 5 as at 31 March 2026: INR 44 lacs (31 March
2025: INR 44 lacs) provided in the books on account of uncertainty of recoverability for the amount.

The fair value of the financial assets and liabilities is included at the amount at which the instrument could be
exchanged in a current transaction between willing parties, other than in a forced or liquidation sale.

The Company's principal financial liabilities, other than derivatives, comprise trade and other financial liability.
The main purpose of these financial liabilities is to finance the Company's operations and to provide guarantees
to support its operations. The Company's principal financial assets include loans, trade and other receivables,
and cash and cash equivalents that derive directly from its operations. The Company also enters into derivative
transactions.

The Company is exposed to market risk, credit risk and liquidity risk. The Company's senior management
oversees the management of these risks and also ensure that the Company's financial risk activities are
governed by appropriate policies and procedures and that financial risks are identified, measured and managed
in accordance with the Company's policies and risk objectives. All derivative activities for risk management
purposes are carried out by specialist teams that have the appropriate skills, experience and supervision. It is
the Company's policy that no trading in derivatives for speculative purposes may be undertaken.

The Board of Directors reviews and agrees policies for managing each of these risks, which are summarised
below:

A. 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 price risk, such as commodity risk. Financial instruments affected by market risk include
deposits and derivative financial instruments.

The sensitivity analysis in the following sections relate to the position as at 31 March 2026 and 31 March
2025.

The analysis exclude the impact of movements in market variables on the carrying values of gratuity,
other post-retirement obligations and provisions.

The sensitivity of the relevant profit and loss item is the effect of the assumed changes in the respective
market risks. This is based on the financial assets and financial liabilities held as of 31 March 2026 and 31
March 2025.

a. Interest rate risk

Interest rate risk is the risk that the fair value or future cash flows of a financial instrument will
fluctuate because of changes in market interest rates. The Company's exposure to the risk of changes
in market interest rates relates primarily to the overdraft, letter of credit, cash credit etc. facilities
provided by the respective banks to the Company carrying variable interest rates.

Since, the Company has not availed any long-term credit facilities, therefore there is no need for the
Company to enter into hedge contract to mitigate the possible exposure risk.

b. 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's exposure to the risk of changes in
foreign exchange rates relates primarily to the Company's operating activities (when revenue or
expense is denominated in a foreign currency).

The Company manages its foreign currency risk by hedging transactions expected to occur within a
maximum period of 12 months, including forecasted receivables and payables.

When a derivative is entered into for the purpose of being a hedge, the Company negotiates the
terms of those derivatives to match the terms of the hedged exposure. For hedges of forecast
transactions, the derivatives cover the period of exposure from the point the cash flows of the
transactions are forecasted up to the point of settlement of the resulting receivable or payable that
is denominated in the foreign currency.

Foreign currency sensitivity

The following tables demonstrate the sensitivity to a reasonably possible change in USD and Euro
exchange rates, with all other variables held constant. The impact on the Company's profit before
tax is due to changes in the fair value of monetary assets and liabilities.

n

The Company's exposure to foreign currency changes for all other currencies is not material. ^

o

c. Commodity price risk

The Company is affected by the price volatility of certain commodities. Its operating activities require
the ongoing purchase and manufacture of various electronic parts which consist of copper element
and therefore require a continuous supply of the same. However, due to the non-significant
movement in the prices of the copper, the Company has not entered into any forward contracts for
commodity hedging purpose.

B. Credit risk

The maximum exposure to credit risks is represented by the total carrying amount of these financials
assets in the balance sheet

Credit risk on cash and cash equivalents and other bank balances is limited as the Company generally
invests in deposits with financial institutions with high credit ratings assigned by credit rating agencies.
Investments represent investment in the Subsidiary Company. Other financial assets mainly includes
security deposits, government incentive receivables etc.

Trade receivables are generally unsecured and are derived from revenue earned from customers. The
Company monitors the economic environment in which it operates to manage its credit risk. The Company
manages its credit risk through various measures including establishing credit limits and continuously
monitoring credit worthiness of customers to whom it extends credit in the normal course of business.

a. Trade receivables

Customer credit risk is managed subject to the Company's established policy, procedures and control
relating to customer credit risk management. Credit quality of a customer is assessed based on an
extensive credit rating scorecard and individual credit limits are defined in accordance with this
assessment. Outstanding customer receivables are regularly monitored and balances of customers
are not covered by letters of credit or other forms of credit insurance.

An impairment analysis is performed at each quarter end on an individual basis for major customers.
In addition, a large number of minor receivables are grouped into homogenous groups and assessed
for impairment collectively.

The maximum exposure to credit risk at the reporting date is the carrying value of each class of
financial assets disclosed in note 8. The Company does not hold collateral as security. The Company
evaluates the concentration of risk with respect to trade receivables as low, as its customers are
located in several jurisdictions and industries and operate in largely independent markets.

b. Financial instruments and cash deposits

Credit risk from balances with banks and financial institutions is managed by the Company's treasury
department in accordance with the Company's policy. Investments of surplus funds are made only
with approved banks and within limits assigned to each bank by the erstwhile ultimate holding
company.

The Company's maximum exposure to credit risk for the components of the balance sheet at 31
March 2026, 31 March 2025 is the carrying amounts as illustrated in note 9.

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

The Company manages its capital structure and makes adjustments in light of changes in economic conditions
and the requirements of the financial covenants, if any. To maintain or adjust the capital structure, the Company
reviews the fund management at regular intervals and take necessary actions to maintain the requisite capital
structure.

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

45 OTHER STATUTORY INFORMATION

Additional Regulatory Information/disclosures as required by General Instructions to Division II of Schedule III
to the Companies Act, 2013 are furnished to the extent applicable to the Company.

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

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

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

(iv) The Company has not traded or invested in Crypto currency or Virtual Currency during the financial year.

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

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

b) provide any guarantee, security or the like to or on behalf of the ultimate beneficiaries

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

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

b) provide any guarantee, security or the like to or on behalf of the ultimate beneficiaries

(vii) The Company has not any such 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).

(viii) No borrowings from banks or financial institution has been availed by the Company on the basis of
security of current assets.

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

(x) The Company has complied with the number of layers prescribed under clause (87) of section 2 of the
Act read with Companies (Restriction in number of Layers) Rules, 2017.

46 Pursuant to amendment by Ministry of Corporate Affair (MCA) in the Companies (Accounts) Rules 2014, the
Company has used accounting software for maintaining its books of account which has a feature of recording
audit trail (edit log) facility and the same has operated throughout the year for all relevant transactions recorded
in the software, except that audit trail feature is not enabled for changes made using privileged/ administrative
access rights to the SAP and related interfaces across the accounting software at database level. Further, no
instance of audit trail feature being tampered with was noted in respect of above said software except in
regard to privileged access users where the audit trail feature has not been enabled. Additionally, the audit
trail of prior year has been preserved as per the statutory requirements for record retention to the extent it
was enabled and recorded in the respective year.


 
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