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Sandur Manganese & Iron Ores 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.) 10488.20 Cr. P/BV 4.01 Book Value (Rs.) 53.75
52 Week High/Low (Rs.) 238/112 FV/ML 10/1 P/E(X) 22.31
Bookclosure 22/09/2025 EPS (Rs.) 9.67 Div Yield (%) 0.58
Year End :2025-03 

1.13 Provisions and contingent liabilities and
contingent assets

Provisions are recognised when the Company has a
present obligation (legal or constructive) as a result of
a past event, it is probable that the Company will be
required to settle the obligation, and a reliable estimate
can be made of the amount of the obligation.

The amount recognised as a provision is the best
estimate of the consideration required to settle
the present obligation at the end of the reporting
period, taking into account the risks and uncertainties
surrounding the obligation. When a provision is
measured using the cash flows estimated to settle the
present obligation, its carrying amount is the present
value of those cash flows (when the effect of the time
value of money is material).

When some or all of the economic benefits required
to settle a provision are expected to be recovered
from a third party, a receivable is recognised as an
asset if it is virtually certain that reimbursement will be
received and the amount of the receivable can be
measured reliably.

The financial obligation towards mine closure plans
under relevant Acts and Rules are technically
estimated, based on total available ore reserves of
all the mining leases. The amount so determined is
provided in the books of account on the basis of
run of mine ore production of the mines of all the
mining leases.

A contingent liability is a possible obligation that arises
from past events whose existence will be confirmed
by the occurrence or non-occurrence of one or more
uncertain future events beyond the control of the
Company or a present obligation that is not recognised
because it is not probable that an outflow of resources
will be required to settle the obligation. A contingent
liability also arises in extremely rare cases where there is
a liability that cannot be recognised because it cannot
be measured reliably. The Company does not recognize
a contingent liability but discloses its existence in the
Standalone Balance Sheet.

Contingent assets are neither recognised nor disclosed
in the Standalone Financial Statements unless when an
inflow of economic benefits is probable.

1.14. Earnings per share

The basic earnings/ (loss) per share is computed by
dividing the net profit/ (loss) attributable to equity
shareholders for the year by the weighted average
number of equity shares outstanding during the year.
The number of shares used in computing diluted
earnings per share comprises the weighted average
shares considered for deriving basic earnings per share,
and also the weighted average number of equity
shares that could have been issued on the conversion
of all dilutive potential equity shares.

1.15. Segment reporting

Operating segments are reported in a manner
consistent with internal reporting provided to the Chief
Operating Decision Maker (CODM). The Company has
identified business segments as its primary segments.

The Company's primary segments consist of Mining,
Ferroalloys, Coke and energy.

Unallocable represents other income and expenses
which relate to the Company as a whole and are not
allocated to segments.

1.16. Cash flow statement

Cash flows are reported using the indirect method,
whereby profit/ (loss) before extraordinary items
and tax is adjusted for the effects of transactions of
noncash nature and any deferrals or accruals of past
or future cash receipts or payments. The cash flows
from operating, investing and financing activities of
the Company are segregated based on the available
information.

A financial instrument is any contract that gives rise to
a financial asset of one entity and a financial liability or
equity instrument of another entity.

Financial assets and liabilities or equity instruments are
recognised when the Company becomes a party to
the contractual provisions of the financial instrument.
Financial assets and liabilities are initially measured
at fair value. Transaction costs that are directly
attributable to the acquisition or issue of financial assets
and financial liabilities (other than financial assets and
financial liabilities at fair value through profit or loss) are
added to or deducted from the fair value measured on
initial recognition of financial asset or financial liability.
However, trade receivables that do not contain a
significant financing component are measured at
transaction price (net of variable consideration).

The Company derecognises a financial asset only
when the contractual rights to the cash flows from the
asset expire, or when it transfers the financial asset and
substantially all the risks and rewards of ownership of
the asset to another entity. The Company derecognises
financial liabilities when, and only when, the Company's
obligations are discharged, cancelled or have expired.

Cash and cash equivalents:

The Company considers all highly liquid financial
instruments, which are readily convertible into known
amounts of cash that are subject to an insignificant risk
of change in value and having original maturities of
three months or less from the date of purchase, to be
cash equivalents. Cash and cash equivalents consist
of balances with banks which are unrestricted for
withdrawal and usage.

Financial assets at amortised cost:

Financial assets are subsequently measured at
amortised cost if these financial assets are held within
a business whose objective is to hold these assets to
collect contractual cash flows and the contractual
terms of the financial assets give rise on specified dates
to cash flows that are solely payments of principal and
interest on the principal amount outstanding.

Financial assets at fair value through other
comprehensive income:

Financial assets are measured at fair value through
other comprehensive income if these financial assets
are held within a business whose objective is achieved
by both collecting contractual cash flows on specified
dates that are solely payments of principal and interest
on the principal amount outstanding and selling
financial assets.

Financial assets at fair value through profit or loss:

Financial assets are measured at fair value through
profit or loss unless they are measured at amortised
cost or at fair value through other comprehensive
income on initial recognition. The transaction costs
directly attributable to the acquisition of financial
assets and liabilities at fair value through profit or loss
are immediately recognised in Standalone Statement
of Profit and Loss.

Impairment of financial assets:

The Company applies Expected Credit Loss (ECL)
model, for evaluating impairment of financial assets
other than those measured at Fair Value Through Profit
& Loss (FVTPL).

For Trade receivables, the Company follows 'simplified
approach' which requires expected lifetime losses to be
recognised from initial recognition of the receivables.

Financial liabilities:

Financial liabilities are measured at amortised cost
using the effective interest method.

Equity instruments:

An equity instrument is a contract that evidences
residual interest in the assets of the Company after
deducting all of its liabilities. Equity instruments issued
by the Company are recognised at the proceeds
received net of direct issue cost.

1.18 Borrowing costs

Borrowing costs directly attributable to the acquisition,
construction or production of qualifying assets, which
are assets that necessarily take a substantial period
of time to get ready for their intended use or sale, are
added to the cost of those assets, until such time as the
assets are substantially ready for their intended use or
sale.

All other borrowing costs are recognised in the
Standalone Statement of Profit and Loss in the year in
which they are incurred.

The Company determines the amount of borrowing
costs eligible for capitalisation as the actual borrowing
costs incurred on that borrowing during the year less
any interest income earned on temporary investment
of specific borrowings pending their expenditure on
qualifying assets, to the extent that an entity borrows
funds specifically for the purpose of obtaining a
qualifying asset. In case if the Company borrows
generally and uses the funds for obtaining a qualifying
asset, borrowing costs eligible for capitalisation are
determined by applying a capitalisation rate to the
expenditures on that asset.

Borrowing Cost includes exchange differences arising
from foreign currency borrowings to the extent they are
regarded as an adjustment to the finance cost.

Ministry of Corporate Affairs ("MCA”) notifies new standards or amendments to the existing standards under
Companies (Indian Accounting Standards) Rules as issued from time to time. For the year ended March 31, 2025,
MCA has notified Ind AS - 117 Insurance Contracts and amendments to Ind AS 116 - Leases, relating to sale and
leaseback transactions (applicable to the Company w.e.f. April 1, 2024). The Company has reviewed the new
pronouncements and based on its evaluation has determined that it does not have any significant impact in its
financial statements.

Notes:

i. The Board of Directors of the Company and Sandur Pellets Private Limited ("SPPL”) a wholly owned subsidiary of
the Company have approved the voluntary liquidation of SPPL in their respective meetings held on 24 March
2025 and 26 March 2025. Subsequent to the approval of the respective Board of Directors, the shareholders
of SPPL in the Extraordinary General Meeting (EGM) held on 27 March 2025 have accorded their approval for
voluntary liquidation and subsequently liquidator was appointed as per the provisions of the Insolvency and
Bankruptcy Code, 2016 read with regulations of the IBBI (Voluntary Liquidation Process) Regulations, 2017.

ii. During the year ended 31 March 2025, the Company had entered into a Share Purchase Agreement (SPA)
and acquired 237,65,19,836 equity shares (face value of ^ 10 per share) of Arjas Steel Private Limited (ASPL),
resulting in a holding of 98.94% in ASPL. Consequently, ASPL, has become a subsidiary of the Company w.e.f.
11 November 2024.

(iii) Nature and purpose of reserves

(a) Capital redemption reserve:

A capital redemption reserve is created upon
redemption of capital.

(b) Securities premium:

Amounts received on issue of shares in excess of the
par value has been classified as securities premium.

(c) General reserve:

The general reserve is used from time to time to
transfer profits from retained earnings for appropriation
purposes. There is no policy of regular transfer. Items

included under general reserve shall not be reclassified
back into the Standalone Statement of Profit and Loss.

(d) Amalgamation adjustment deficit account:

It represents excess of the carrying value of the net
assets (including reserves) in case of common control
business combination. This amount will be adjusted
in determining the surplus available for dividend
distribution.

(e) Retained earnings:

Retained earnings comprise of the Company's
undistributed earnings after taxes, other comprehensive
income and if any transfer from general reserve.

Notes:

(i) Terms of repayment

Non-convertible debentures of ? 44,100 lakh is
repayable in:

(a) 2 quarterly instalments of ^ 450 lakh each on 30
June 2025 and 30 September 2025.

(b) 2 quarterly instalments of ^ 900 lakh each on 31
December 2025 and 31 March 2026.

(c) 6 quarterly instalments of ^ 1,350 lakh from 30 June
2026 to 30 September 2027.

(d) 3 quarterly instalments of ^ 1,687 lakh each from 31
December 2027 to 30 June 2028.

(e) 6 quarterly instalments of ^ 2,025 lakh each from 30
September 2028 to 31 December 2029.

(f) 1 quarterly instalment of ^ 2,139 lakh on 31 March
2030.

(g) 5 quarterly instalments of ^ 2,250 lakh each from 30
June 2030 to 30 June 2031.

(h) 1 quarterly instalment of ^ 2,700 lakh on 30
September 2031.

Term loan from Axis bank of ? 5,709 lakh is
repayable in:

(a) 23 monthly instalments of ^238 lakh each from 30
April 2025 to 28 February 2027.

(b) 1 instalment of ^ 235 lakh on 31 March 2027.

Term loan from ICICI bank of ? 4,167 lakh is
repayable in:

35 monthly instalments from of ^119 lakh each from 30
April 2025 to 29 February 2028.

Term loan from Aditya Birla Finance Limited of ?
34,300 lakh is repayable in:

(a) 2 quarterly instalments of ^ 350 lakh each from 1
April 2025 to 1 October 2025.

(b) 2 quarterly instalments of ^ 700 lakh each on 1
January 2026 and 1 April 2026.

(c) 6 quarterly instalments of ^ 1,050 lakh each from 1
July 2026 to 1 October 2027.

(d) 3 quarterly instalments of ^ 1,312 lakh each from 1
January 2028 to 1 July 2028.

(e) 6 quarterly instalments of ^ 1,575 lakh each from 1
October 2028 to 1 January 2030.

(f) 1 quarterly instalment of ^ 1,664 lakh on 1 April

2030.

(g) 5 quarterly instalments of ^ 1,750 lakh each from 1
July 2030 to 1 July 2031.

(h) 1 quarterly instalment of ^ 2,100 lakh on 1 October

2031.

Term loan from Bajaj Finance Limited of ? 14,700
lakh is repayable in:

(a) 2 quarterly instalments of ^ 150 lakh each from 1
April 2025 to 1 October 2025.

(b) 2 quarterly instalments of ^ 300 lakh each on 1
January 2026 and 1 April 2026.

(c) 6 quarterly instalments of ^ 450 lakh each from 1
July 2026 to 1 October 2027.

(d) 3 quarterly instalments of ^ 562 lakh each from 1
January 2028 to 1 July 2028.

(e) 6 quarterly instalments of ^ 675 lakh each from 1
October 2028 to 1 January 2030.

(f) 1 quarterly instalment of ^ 714 lakh on 1 April 2030.

(g) 5 quarterly instalments of ^ 750 lakh each from 1
July 2030 to 1 July 2031.

(h) 1 quarterly instalment of ^ 900 lakh on 1 October
2031.

* Includes current and non-current borrowings (gross
i.e. without adjusting unamortised processing fees).

(ii) During the year ended 31 March 2025, the
Company has issued and allotted 45,000 secured,
Non-Convertible Debentures of ^ 1,00,000/- each
aggregating to ^ 45,000 lakh on private placement

basis bearing 11% interest per annum which have
been listed on BSE Limited on 28 October 2024. The
Company has utilised the entire proceeds towards
the objects of the issue.

(iii) Weighted average interest rate on term loan as on
31 March 2025 is in the range of 8.79% to 11.50%.

(iv) Weighted average interest rate on non-convertible
debentures as on 31 March 2025 is 11%.

(v) Interest rates applicable for working capital
facilities ranges from 8.07% to 9.30%.

(vi) Security provided for non-convertible debentures,
term loans, and working capital facilities. First pari
passu charge on

- All the current and movable fixed assets of the

Company, both present and future.

- All the fixed assets (excluding any mining land)
of the Company, both present and future.

- The pledged shares of ASPL held by the
Company.

- Escrow accounts of the Company.

(vii) The Company has complied with the covenants
as per the terms of the loan agreement.

(viii) The quarterly returns/ statements filed by the
Company with the banks or financial institutions, in
lieu of the sanctioned working capital facilities, are
in agreement with the books of account.

(ix) The Company has not defaulted on repayment of
principal and payment of interest on any of the
above borrowings during the year.

Notes:

i. The above amounts have been arrived at based on the notice of demand or the assessment orders, as the case
may be, and the Company is contesting these claims with the respective authorities. Outflows (if any arising out of
these claims would depend on the outcome of the decisions of the appellate authorities.

ii. The Company has reviewed all its pending litigations and proceedings and has adequately provided for
where provisions are required and disclosed as contingent liabilities where applicable, in its Standalone Financial
Statements. The Company does not expect the outcome of these proceedings to have adverse effect on its
financial position. The Company does not expect any reimbursements in respect of the above contingent liabilities.

(b) Defined Benefit Plan
(i) Gratuity (Funded)

The Company operates a gratuity plan covering qualifying employees. The benefit payable is as per The Payment
of Gratuity Act, 1972. The Company makes annual contributions to an insurance managed fund to fund its gratuity
liability. The activity of the Company is administered by SMIORE Gratuity Fund Trust. The scheme provides for lump
sum payment to vested employees on retirement, death while in employment or on termination of employment as
per the Company's Gratuity Scheme.

The plan liabilities are calculated using a discount rate set with references to government bond yields. If plan assets
underperform compared to the government bonds discount rate, this will create or increase a deficit. The defined
benefit plans hold a significant proportion of debt type assets, which are expected to outperform government
bonds in the long-term.

Notes:

i. The mortality rates considered are as per the published rates in the Indian Assured Lives Mortality (2012-14) Ult table.

ii. The weighted average duration to the payment of these cash flows is 15.31 years.

Note No. 35 - Segment information

The Chief Operating Decision maker of the Company examines the performance of the Company from a product
perspective and has identified three reportable segments (a) Mining, (b) Ferroalloys and (c) Coke and Energy.
Unallocable represents the income, expenses, assets and liabilities which are related to the Company as a whole
and cannot be allocated to a particular segment.

Prices between operating segments are on an arm's length basis in a manner similar to transactions with third
parties.

The accounting policies adopted for segment reporting are in line with the accounting policy of the Company with
following additional policies for segment reporting.

(a) Revenue and expenses have been identified to a segment on the basis of relationship to operating activities
of the segment. Revenue and expenses which relate to enterprise as a whole and are not allocable to a
segment on reasonable basis have been disclosed as "Unallocable”.

(b) Segment assets and Segment liabilities represent assets and liabilities in respective segments. Investments, tax
related assets and other assets and liabilities that cannot be allocated to a segment on reasonable basis have
been disclosed as "Unallocable”.

ii. Disclosure as per Regulation 34(3) and 53(f) read with Part A of Schedule V of the SEBI (Listing
Obligations and Disclosure Requirements) Regulations, 2015:

Disclosure of transactions with the entity belonging to the promoter/ promoter group holding 10% or more
shareholding in the Company:

There are no transactions during the financial year with promoter and no amounts receivable/ payable in respect
of the related parties have been written off/ back during the year.

iii. Terms and conditions of transactions with related parties

The sales to and purchases from related parties are made on terms equivalent to those that prevail in arm's length
transactions. Amount owed to and by related parties are unsecured and interest free and settlement occurs
in cash. There have been no guarantees received or provided for any related party receivables or payables.
For the year ended 31 March, 2025, the Company has not recorded any impairment of receivables relating to
amounts owed by related parties (31 March, 2024: ^ Nil). This assessment is undertaken each financial year through
examining the financial position of the related party and the market in which the related party operates.

Note No. 37 - Financial instruments

The material accounting policies, including the criteria for recognition, the basis of measurement and the basis on
which income and expenses are recognised, in respect of each class of financial asset, financial liability and equity
instrument are disclosed in material accounting policies to the Standalone Financial Statements.

Financial instruments by category

This section explains the judgements and estimates made in determining the fair values of the financial instruments
that are (a) recognised and measured at fair value and (b) measured at amortised cost and for which fair values
are disclosed in the Standalone Financial Statements.

Notes:

i. Excludes investments of equity shares in subsidiaries and associates, which are carried at cost and hence are not
required to be disclosed as per Ind AS 107, "Financial Instruments Disclosures”.

ii. The management considers that the carrying amount of financial assets and financial liabilities recognised in
these Standalone Financial Statements at amortised cost approximates their fair values.

Fair value hierarchy of financial instruments

The Company uses the following hierarchy for determining and/or disclosing the fair value of financial instruments
by valuation techniques:

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

Level 2: Inputs are other than quoted prices included within Level 1 that are observable for the asset or liability,
either directly (i.e. as prices) or indirectly (i.e. derived from prices).

Level 3: Inputs are not based on observable market data (unobservable inputs). Fair values are determined in whole
or in part using a valuation model based on assumptions that are neither supported by prices from observable
current market transactions in the same instrument nor are they based on available market data.

Financial risk management

The Board of Directors of the Company have the overall responsibility for the establishment and oversight of the their
risk management framework. The Company has constituted a Risk Management Committee. The Company has
in place a Risk management framework to identify, evaluate business risks and challenges across the Company.
The risk management policies are established to identify and analyse the risks faced by the Company, to set
appropriate risk limits and controls and to monitor risks and adherence to limits. Risk management policies and
systems are reviewed regularly to reflect changes in market conditions and the Company's activities. The Audit
Committee oversees how management monitors compliance with the Company's risk management policies
and procedures, and reviews the adequacy of the risk management framework in relation to the risks faced
by the Company. The Audit Committee is assisted in its oversight role by Internal Audit which regularly reviews
risk management controls and procedures, the results of which are reported to the Audit Committee. These risks
include foreign currency risk, credit risk, liquidity risk and interest rate risk.

Foreign currency risk management

The Company's functional currency remains the Indian Rupee (INR). While the primary currency of business
transactions is INR, the Company engages in foreign currency transactions, thereby exposing itself to exchange
rate fluctuations. Such fluctuations impact the cost of imports, particularly in relation to raw materials procurement.

Throughout the fiscal year, the Company has not only continued its focus on imports but has also expanded its
activities to include exports. Approximately 90% of our export transactions are secured with advance payments,
with the remaining 10% receivable upon shipment delivery. While this approach to exports mitigates a substantial
portion of associated risks, it's essential to acknowledge the residual exposure to foreign exchange fluctuations in
these transactions.

Commodity price risk

The Company's profits are exposed to the market risk due to price fluctuations in purchase of manganese ore
and coal. The prices of manganese ore, coal, and coke purchased by the Company are generally determined by
market forces. These prices may be influenced by factors such as supply and demand, production costs, global
and regional economic conditions. Adverse changes in any of these factors may reduce the Company's profits.

The following table details sensitivity to a 5% movement in the input raw material price of manganese ore, coal and
coke, with all other variables held constant. A positive number below indicates an increase in profit or equity where
the commodity prices decrease by 5% and vice-versa.

Credit risk

Credit risk refers to the risk of a counterparty defaulting on its contractual obligations, resulting in financial loss to
the Company. The Company's exposure to credit risk is primarily influenced by the individual characteristics of
each customer. It faces credit risk in various areas, including investments, cash and cash equivalents, other bank
balances, loans, other financial assets, and financial guarantees, primarily arising from its operating activities, such
as trade receivables.

To mitigate the risk of financial loss from defaults, the Company follows a policy of dealing only with creditworthy
counterparties. Credit risk is managed through established credit norms, setting credit limits, and continuously
monitoring the creditworthiness of customers to whom credit terms are granted in the normal course of business.

The provision for doubtful receivables has been historically negligible. Therefore, the Company does not expect
any material risk on account of non-performance by any of the Company's counterparties. The assessment is
done at regular intervals and allowance for doubtful trade receivables as at 31 March 2025 is considered to be
adequate.

Liquidity risk

Liquidity risk is the risk that the Company will encounter difficulty in meeting the obligations associated with its
financial liabilities that are settled by delivering cash or another financial asset. The Company's approach to
managing liquidity is to ensure, as far as possible, that it will have sufficient liquidity to meet its liabilities when they
are due, under both normal and stressed conditions, without incurring unacceptable losses or risking damage to
the Company's reputation. Ultimate responsibility for managing the liquidity risk rests with the management, which
has established an appropriate liquidity risk management framework for managing the Company's short-term,
medium-term and long-term funding. The Company manages liquidity risk by maintaining adequate reserves, by
continuously monitoring forecast and actual short-term and long-term cash flows and by matching the maturity
profiles of financial assets and liabilities. The following are the remaining contractual maturities of financial liabilities
at the reporting date. The amounts are gross and undiscounted.

The sensitivity analysis below have been determined based on the exposure to interest rates for floating rate
liabilities, assuming the amount of the liability outstanding at the year end was outstanding for the whole year.

If interest rates had been 100 basis points higher/lower and all other variables were held constant, the Company's
profit for the year ended 31 March 2025 would decrease/increase by ^ 589 lakh (for the year ended 31 March
2024: decrease/increase by ^ 131 lakh). This is mainly attributable to the Company's exposure to interest rates on
its variable rate borrowings.

Capital management

The Company's objective for capital management is to maximize shareholder's wealth, safeguard business
continuity and support the growth of the Company. The Company determines the capital management
requirement based on annual operating plans and long term and other strategic investment plans. The funding
requirement are met through equity, borrowings and operating cash flows required.

Notes:

(a) Decrease in the investments has resulted in an decline in the ratio.

(b) Impact is on account of new borrowings raised during the year.

(c) Increase in profit has resulted in an improvement in the ratio.

(d) Increase in cost of goods sold has resulted in a deterioration in the ratio.

(e) Increase in the revenue and decrease in trade receivables has resulted in improvement in the ratio.

(f) Decrease in trade payables has resulted in deterioration in the ratio.

(g) Increase in revenue from operations and decrease in working capital has resulted in improvement in the ratio.

(h) Decrease in the investments has resulted in an improvement in the ratio.

Note No. 42 - Event occurring after reporting period

On 28 May 2025, the Board of Directors had proposed a dividend of ^ 1.25/- per equity share of ^10/- each in
respect of the year ended 31 March 2025 subject to the approval of shareholders at the Annual General Meeting.
If approved, the dividend would result in a cash outflow of approximately ^ 2,026 lakh.

The Company evaluated all events or transactions that occurred after 31 March 2025 up to the date of the
standalone financial statements were authorized for issue by the Board of Directors. Based on this evaluation, the
Company is not aware of any events or transactions that would require recognition or disclosure in the Standalone
Financial Statements other than those specifically disclosed.

Note No. 43 - Other Statutory information

(i) Relationship with struck off companies

Disclosure related to relationship of the Company with a company which is Struck off under Section 248 of the
Companies Act, 2013 as at 31 March 2025 (31 March 2024: Nil) are as follows:

(ii) Details of benami property held

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

(iii) Compliance with number of layers of companies

The Company is in compliance with the number of layers prescribed under Clause (87) of Section 2 of the
Companies Act read with the Companies (Restriction on number of Layers) Rules, 2017.

(iv) Investment in crypto currency

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

(v) Charge with registrars of the company

The Company does not have any charge or
satisfaction which is yet to be registered with Registrars
of Companies beyond the statutory period.

(vi) The Company has not advanced or loaned
or invested fund to any other person(s) or entit(ies),
including foreign entites (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 on
behalf of the ultimate beneficiaries.

(vii) The Company has not received any fund from any
person(s) or entit(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.

(viii) There are no transactions in the books of
account that has been surrendered or disclosed as
income during the year in the tax assessments under
the Income-tax Act, 1961, that has not been recorded
in the books of account.

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

Note No. 44 The Company has used accounting
software for maintaining its books of account for the
year ended 31 March 2025, 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 in respect
of software used by the Company for maintaining
its payroll records for the year ended 31 March 2025
wherein the accounting software did not have the
audit trail feature enabled throughout the year. The
Company is in process of implementing the changes
inline with the regulation.

For and on behalf of the Board of Directors

T.R. Raghunandan Bahirji Ajai Ghorpade

Chairman Managing Director

DIN: 03637265 DIN: 08452844

Neha Thomas Uttam Kumar Bhageria

Company Secretary & Chief Financial Officer &

Compliance Officer Chief Risk Officer

ICSI Membership No.: A60853

Place: Bengaluru
Date: 28 May 2025


 
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