24. Provisions, Contingent Liabilities and ContingentAssets
Provisions involving substantial degree of estimation inmeasurement are recognized when there is a presentobligation as a result of past events and it is probablethat there will be an outflow of resources and reliableestimate can be made of the amount of obligation.Contingent Liabilities are not recognized but aredisclosed in the notes. Contingent Assets are neitherrecognized nor disclosed in the Standalone financialstatements.
25. Expenses of Management-Basis of Apportionment
Expenses of management includes exchange gain/loss,excluding GST Expenses. Expenses which are solely andexclusively attributable to a specific Segment i.e. Line ofBusiness (LOB) and which are specifically identifiable tothat particular segment, are allocated to that segmentand the remaining value of expenses of management areapportioned to the revenue accounts on the basis of netpremium.
26. Segregation of Policy Holders and Share Holdersfunds:
Investment Assets includes policyholders as well asshareholders. Investment assets are bifurcated at the endof each quarter between shareholders and policyholdersat 'fund' level on notional basis in accordance with IRDAIguidelines.
27. Income from Investments -Basis of apportionment
Investment Income (net of expenses) is apportionedbetween shareholders' fund and policyholders' fund inproportion to the balance of these funds at the beginningof the year.
Investment income (net of expenses) belonging toPolicyholders is further apportioned to Fire, Marine andMiscellaneous segments in proportion to respectivetechnical reserves balance at the beginning of the year.
Policy holders fund for this purpose consist of estimatedliability for outstanding claims including IBNR and IBNER,unexpired risk reserve (URR), Premium deficiency (ifany). catastrophe reserve (if any) and Other Liabilitiesnet of Other Assets (relating to policy holders) as perthe guidelines of IRDAI. The residual consists of theshareholder fund.
1. Reinsurance Acceptance Transactions:
Reinsurance acceptance transactions pertaining to theyear have been booked for advices received up to April12, 2025.
2. Premium Deficiency Reserve:
Unexpired premium reserve at revenue segment level isfound to be sufficient to cover the expected claim costand claims related expenses as certified by the appointedactuary. Hence no premium deficiency reserve is requiredto be provided during the year.
3. Reserves against cancellation of policies during free-look period:
The reserve against cancellation of policies during free-look period under retail health policies for the periodended 31st March 2025, as certified by the actuary, is?150 Lakhs (PY ?150 Lakhs).
4. IBNR and IBNER:
Provision towards Claims Incurred but Not Reported(IBNR) and those Incurred but Not Enough Reported(IBNER) as on March 31, 2025 has been determined byAppointed Actuary, which is in accordance with acceptedactuarial practice and IRDAI regulations in this regard.
5. taxation:
a) Income Tax: Provision for Tax ?1878 Lakhs (PY.?33115 Lakhs) shown in Profit and Loss Accountincludes ?3439 Lakhs (PY. ?1959 Lakhs) relating toforeign taxes and reversal of earlier year tax ?25470lakhs (PY. Nil).
b) From FY 2022-23 the company has been recognizingand utilizing the available MAT Credit of previousyears to the extent required to be set off against taxcomputed as per the normal provisions of the Actwhich was not accounted for on account of prudenceand absence of convincing evidence of utilizing it.Accordingly, MAT credit of ?9284 Lakhs (previousyear ?18415 Lakhs) has been recognized andutilized during the year and cumulative utilizationamounted to ?52501 lakhs.
c) The Income Tax Assessments of the Company havebeen completed up to assessment year 2022-23.Major disputed demands are in respect of profit onsale of investment, IBNR, expenses paid to Auto tie-up dealers. Based on the decisions of the appellateauthority, the interpretations of the relevantprovisions, the management of the Company is ofthe opinion that the demands are likely to be eitherdeleted or substantially reduced and accordingly noprovision has been made for the same. However,an amount of ?579811 lakhs has been disclosed ascontingent liabilities.
i) A sum of ?2763 Lakhs (PY ?1500 Lakhs)has been debited to the Profit and LossAccount on account of reduction in deferredassets during the year.
ii) Deferred Tax Asset in respect of foreignbranches does not have any timing differenceother than fixed asset.
iii) The Company continues to recognise thedeferred tax asset in respect of temporarydifference mentioned in the above table,as in the opinion of the management thereare sufficient evidence to establish thereasonable certainty of realisation of thedeferred tax assets from the future taxableprofits.
e) Taxation Laws (Amendment) Act, 2019 -
The Taxation Laws (Amendment) Act, 2019 wasenacted on 11th December 2019 which amendedthe Income Tax Act, 1961 and the Finance Act(No.2) Act, 2019. It provides domestic companieswith an option to opt for lower tax rate, provided theydo not claim certain deductions. The Company hasnot exercised the option to opt for lower tax rate andhas presently considered the rate existing prior tothe amendment. The management is in the processof evaluating the option to opt for lower tax rate onceit utilises the entire carried forward losses and MATcredit available under the Income Tax Act.
f) Goods and Service Tax (GST):
The company has received an adjudication orderfrom the Goods and Services Tax Departmenttowards non-payment of GST amounting to ?84945lakhs on supply of group medicliam insuranceservices to industrial units located in SpecialEconomic Zones. The matter is an industry wideissue and as per opinion received by the companyhas merits in defending the notice. The Companyhas filed a writ petition before the Hon'ble BombayHigh Court challenging the Order vide writ petitionno 1281 of 2025, date of hearing for admission isyet to be notified. Considering that the denial of the
zero-rating benefit for the period prior to 01.10.2023appears to be without proper legal basis, thecompany has classified this exposure as “Remote”and disclosed it as a contingent liability.
The company has also received an adjudicationorder from the Goods and Services Tax Departmenttowards non-payment of GST amounting to ?7045lakhs on sale of salvage/wreck generated during thesettlement of Motor vehicle claims. The matter is anindustry wide issue and as per opinion received, theCompany has merits in defending the notice. TheCompany has filed a writ petition before the Hon'bleBombay High Court challenging the Order videwrit petition no 15219 of 2025, date of hearing foradmission is yet to be notified. The company hasalso taken into account the clarification issued bythe department through circular no. 215/9/2024-GSTdated 26.06.2024, which states that the salvagevalue deducted from claim settlements should notbe treated as consideration for any taxable supply.Consequently, the company classified this exposureas “Remote” and disclosed it as a contingent liability.
6. Statutory Reserves relating to Foreign Branches:
In accordance with Oman Insurance Company Law,the Head Office had created a contingency reserve of 5million Omani Riyal in FY 2012-13 for claims related tothe Muscat agency. However, this contingency reserveis now maintained within the financial records of MuscatOperations. Consequently, during the current year anamount of ?7031 lakhs has been transferred from thiscontingency reserve to the General Reserve along withthe related foreign currency fluctuation amounting to?3794 lakhs in the Head Office books.
7. Title deeds of immovable properties:
I. Title deed of the following immovable properties arepending to be registered in the name of the Company:
a. Thirty-Two properties having book value (GrossBlock) ?1490 Lakhs (P.Y. Sixty-Seven Propertieshaving book value ?2062 Lakhs) for whichregistration formalities are yet to be completed / titledeeds are in process. Out of which,
i. title deeds of Seven properties havingvalue as per books of ?66 Lakhs (P.Y. ?66Lakhs) are in the name of General InsuranceCorporation of India and the Company is inthe process to get it transferred in its name.
ii. three properties having book value of ?336Lakhs (P.Y. ?336 Lakhs) were received fromTariff Advisory Committee (TAC) and theregistration formalities are still pending.
b. Office property having book value ?217 Lakhs (PY?217 Lakhs) and Office freehold property havingbook value ?752 lakhs (P.Y. ?752 lakhs) for whichagreement registration formalities are pending.
c. One open plot having book value ?24 Lakhs (P.Y.?24 Lakhs) jointly owned by four PSU Companiesand title deed is in the name of GIC, is under litigationand Special Civil Application is pending before theHon'ble Gujarat High Court.
II One leasehold property having book value of ?3 Lakhs(P.Y. ?3 Lakhs) where lease term expired and renewalprocess is pending with the concerned GovernmentAuthorities.
III Following are the properties for which legal proceedingsare/will be initiated by the Company for acquiring PhysicalPossession:
a) Out of total 23 properties owned by the Company,08 properties are occupied by corporate tenantsand 15 are occupied by Individual Tenants.Legal proceedings are in process against all 08corporate tenants. Out of 15 Individual Tenants;legal proceedings are in process against 11. Forremaining 4 Individual tenant's eviction proceedingare contemplated.
b) One Lease hold property consisting of 123 tenementsand 6 Godowns having book value of ?3 Lakhs (P.Y.?3 Lakhs) is in the possession of the Company butoccupied by inherent tenants. Now, the property isunder the purview of MHADA Authority.
IV As per legal opinion obtained from the Advocatesdated 23.10.2021, 20.02.2023 & 21.02.2023
regarding procedure to be followed to regularizethe title deeds in Company's name, on perusal, theAdvocates opined that the documents available inthe records of the files are sufficient and havingevidentiary value to prove our ownership (ie.Gazette Notification issued by Government ofIndia, Agreement registered/unregistered, sharecertificate, Municipal tax, property tax bill etc).Hence, as per Advocates' opinion, in another 37 Nosof units having value of ?169 lakhs are to be treatedas having clear titles.
8. Investments:
a) As certified by the Custodian, securities are held bythe Company as on March 31, 2025. Variations andother differences, which include shortages, havebeen provided for.
b) Provision for standard assets @ 0.40% amountingto ?5665 Lakhs (P.Y. ?6023 Lakhs) has been madeas per Insurance Regulatory and DevelopmentAuthority of India (IRDAI) guidelines.
d) Short-term Investments (Schedule - 8) in debenturesand other guaranteed securities include those, whichare fully repayable in the next year. As regards thosedebentures and other guaranteed securities, whichhave fallen due and remain unpaid as on March31, 2025, these have been shown under long-terminvestments, as their realisability is unascertainable.Necessary provision, wherever required, has beenmade.
e) Pursuant to the IRDAI regulations the companyhad recognised impairment loss of ?10966 Lakhsin the profit and loss account during the year 2023¬24 on its equity investment in one of the subsidiarynamely Prestige Assurance PLC, Nigeria, due tothe impairment loss being considered as other thantemporary due to steep fall of Nigerian currency,Naira. As on Balance Sheet date the currency Nairahas improved as compared to Previous Year andaccordingly impairment loss of ?2109 lakhs hasbeen reversed during the year.
f) Fixed deposits forming part of Investment Assets,amounting to ?2,61,331 lakhs and ?365 lakhsdue within 12 months and more than 12 monthsrespectively, have been included under Cash andBank Balance in Schedule 11, as per consistentpractice followed.
9. Reinsurance, Coinsurance, Inter Office, GST Balancesand old credit /debit balances:
a) The net balances due to/due from in respect of re¬insurance activities of the company ?541637 lakhscomprising of ?5,89,529 Lakhs (Dr.) and ?47,892lakhs (Cr.) contain various entries outstanding formore than 10 years where process of matchingopen items, confirmation and reconciliation is inprogress. The above include balances relating toTerrorism Pool ?3,45,823 lakhs and Nuclear Pool
of ?23,308 lakhs due from General InsuranceCorporation of India (GIC Re) and ?34,979 Lakhsdue from Agricultural Insurance Company of IndiaLtd. for which confirmation of balances is receivedbut these are subject to reconciliation in respect ofold entries appearing in the books. These accountsare still under the process of compilation/age-wiseanalysis/ reconciliation and segregating into debitand credit balances. Also, there are migrationdifferences which need to be reconciled. Pending allsuch activities the impact on the financial statementsis unascertainable. The process of matching andreconciliation by the task force formed by thecompany is at different stages and any resultantaccounting adjustments shall be carried out onoutcome of such process.
As against Net Reinsurance balance of ?5,41,637Lakhs(Net) (Dr.) as on March 31,2025, the Companyhas maintained a provision of ?93536 Lakhs up toMarch 31,2025, towards doubtful debts as a prudentmeasure. During the period ended March 31, 2025,the Company has written off (net debit) non-movingreinsurance balances of ?5,383 Lakhs.
b) In respect of Coinsurance business, the balanceswith various Co-insurers represent a net receivableof ?49,304 lakhs (receivable of ?85,335 lakhs andpayable of ?36,031 lakhs), which included balancesrelating to PMFBY amounting to ?1,559 lakhs(Net). The process of obtaining confirmations andreconciliation of balances is at different stagesand entries remaining to be reconciled based onthe confirmation are also being attended to. Age-wise breakup of the outstanding entries has beencompiled based on available information.
Based on the Board approved policy depending onthe age of outstanding, the company has maintainedprovision of ?22,395 lakhs during the year (Previous
year ?34,075 lakhs) against the net coinsurancebalance of ?49,304 lakhs and written off an amountof ?2520 lakhs as on March 31, 2025.
c) The reconciliation of various accounts relatingto inter-office accounts of domestic and foreignoperations amounting to ?12,357 Lakhs (Net Debit)[PY ?1,045 Lakhs (Net Debit)], Control Accounts,certain banking transactions, loans and advancesincluding those given to employees and otheraccounts including indirect tax related balancesis under progress, the impact of the above, ifany, on the Standalone Financial statements isunascertainable.
d) As per the consistent practice followed by theCompany, interest accrued on employee loansis recognized to the extent recovered from theemployee instead accrued to the account of theemployee. The impact, if any, arising out of theabove may not be material though the same hasnot been identified.
e) Old balances other than policy holder dues mainlyrelating to various control accounts amounting to?1,637 lakhs (Net credit) (PY ?13,779 lakhs Netdebit) outstanding for more than three years hasbeen credited to Profit & Loss Account during theyear. Necessary accounting adjustments in thebooks of operating offices would be carried out indue course. As per the board approved policy, theCompany has written-off balances under variouscontrol accounts outstanding more than 10 yearsaggregating to ?2890 lakhs and has maintained aprovision amounting to ?4251 lakhs against debitbalances more than 3 years and less than 10 years,during and as at March 31,2025 respectively.
f) In view of various accounts being reconciledand balances under confirmation, the effect ofsuch pending reconciliation on compliance of taxlaws has been ensured to the extent of availableinformation and necessary adjustments /paymentsof any liability arising out of such reconciliation is tobe done in due course.
15. Corporate Social Responsibilities (CSR):
As per Section 135 of the Companies Act 2013 (the Act), the Company was required to spend an amount of ?803 lakhs (PY?1832 lakhs) for the financial year 2024-25.
The charge for the year to profit and loss account on account of CSR amounting to ?803 Lakhs (PY ?1832 lakhs) consistsof following:
a) An amount of ?617 Lakhs (P Y ?293 Lakhs) spent directly & through implementing agencies.
b) The balance unspent amount for the current year ended March 31, 2025 of ?186 Lakhs (P.Y. ?1539 Lakhs) which hasbeen provided for in the books. The balance unspent CSR amount of current year is lying in separate Unspent CSRBank Account.
16. Books maintained on Calendar year:
The accounts incorporate Audited accounts of branches in Fiji and Thailand which are prepared on calendar year basisas per the requirement of local laws. There are no material changes during the period January 1, 2025 to March 31, 2025requiring adjustments to figures reported in the audited accounts as received. Fixed deposits aggregating to ?18838 lakhs
17. Accounts of Run-off offices:
Hong Kong and Manila Offices of the company are since in Run-off status as the company has stopped any new business inthese locations. The accounts of Manila office have been prepared on liquidation basis and the accounts of Hong Kong officeare prepared based on going concern basis. In the case of Kuwait office there is material uncertainty about its going concernstatus. In the opinion of the management this does not have any material impact on the standalone financial statements.
18. Analysis of Unclaimed amounts of Policyholders/Consumers:
As required by IRDAI Master circular no. IRDA/F&I/CIR/Misc/282/11/2020 dated November 17, 2020 read with subsequentmodification to the master circular number IRDA/LIFE/CIR/Misc/41/2/2024 dated 16th February, 2024, age-wise analysis ofunclaimed amount of the policyholders amounting to ?21458 Lakhs (PY ?22942 Lakhs) as at March 31, 2025 representingthe excess premium collected, refund premium, stale cheque accounts and Claims settled but not paid to policyholders/Insured is as under:
Footnote 1: The Company received an order fromCompetition Commission of India (CCI) imposing a penaltyof ?25107 Lakhs in 2015-16. The Company contested theorder in Competition Appeal Tribunal and the Tribunalawarded a penalty of ?20 Lakhs as against ?25107 Lakhsof CCI order. The penalty was paid in January 2017. CCIhas appealed against the order of the Tribunal at the ApexCourt and the case has been admitted in the Apex Courtin March 2017. As per the latest information available,the case has been awaiting a hearing since the 10th ofAugust, 2017.Counter-affidavit/reply has already beenfiled by NIA as on March 31, 2023.
Footnote 2: Bombay Stock Exchange (BSE) and NationalStock Exchange (NSE) each have levied a penalty of?472 lakhs for quarter ended September 30, 2024 anda penalty of ?117 lakhs for quarter ended December 31,2024 for non-compliance with Regulation 17(1) of SEBI(LODR), 2015. The Company had applied for waiver ofthe penalties, as appointment of Directors can only bedone by the Ministry of Finance and the Company has noauthority regarding the appointment of Directors.
Footnote 3: The company has received a penaltyamounting to ?84945 lakhs and ?7045 lakhs for non¬
payment of GST on supply of group medicliam insuranceservices to industrial units located in Special EconomicZones and sale of salvage/wreck generated during thesettlement of Motor vehicle claims, respectively. Both thematters are industry wide and as per opinion received,the company has merits in defending the notice. TheCompany has filed a writ petition before the Hon'bleBombay High Court challenging the Order.
Footnote 4: The Income Tax Department imposedpenalties on the company for AY 2016-17 and AY 2019¬20 following disallowance of payments to auto dealers.However, the company has received a favorable orderon the same matter for AY 2014-15 from the IncomeTax Appellate Tribunal (ITAT). Based on the same, thecompany has filed appeals with the before NationalFaceless Appeal Centre - NFAC (erstwhile CIT(A))against the penalties.
22. Internal Controls:
The Company has a fairly adequate internal control andappropriate validations in the system. The Company is inthe continuous process of further strengthening internalcontrols in other areas of its operations, by bringing more
controls and validation in system. The Internal AuditSystem including that relating to Foreign offices is alsobeing strengthened and is under comprehensive review.
23. Fraud Monitoring Cell:
The Company has a Fraud Monitoring Cell which monitorsexternal frauds reported and a Vigilance Departmentwhich monitors matters related to employees. The saidfraud cell compiles data based on inputs from operatingoffices. As per the assessment made by the Cell, therewere no matters related to external frauds reported duringthe year, which required any disclosure or adjustmentsto the standalone financial statements of the Companyexcept as under:
a) Online Fraud using Broker Portal has been reportedwhere 514 two-wheeler Motor policies issued in thesystem were modified as four wheeler policies andgiven to customers. The Company has cancelled allthe policies ab initio without any refund and informedthe concerned RTOs by registered post under therelevant rules and guidelines of the Company. Thepremium amount has been forfeited and there is norevenue loss to the Company.
b) Dehradun RO reported some cases of irregularpremium deposits to the tune of ?6 lacs under healthinsurance policies. A Special Audit was conducted,and the concerned branch in-charge has beensuspended. Appropriate action is also being initiated.
c) Jaipur RO has recently reported 96 fake policiesissued through Square Insurance web integrationonline channel. FIR has been lodged against theBroker. The R.O. has been advised to initiate aspecial audit.
24. a) No funds have been advanced or loaned or invested
(either from borrowed funds or share premiumor any other sources or kind of funds) by theCompany to or in any other person(s) or entity(ies),including foreign entities (“Intermediaries”) withthe understanding, whether recorded in writing orotherwise, that the Intermediary shall lend or investin party identified by or on behalf of the Company(Ultimate Beneficiaries).
b) The Company has not received any fund from anyparty(s) (Funding Party) with the understanding thatthe Company shall whether, directly or indirectly lendor invest in other persons or entities identified by oron behalf of the Company (“Ultimate Beneficiaries”)or provide any guarantee, security or the like onbehalf of the Ultimate Beneficiaries.
25. The Code on Social Security, 2020 (“Code”) relating toemployee benefits during the employment and post¬employment benefits has been published in the Gazetteof India on September 28, 2020. The Ministry of Labourand Employment has released draft rules for the Code
on November 13, 2020. The effective date from whichthese changes are applicable is yet to be notified. TheCompany will assess and record the impact, if any, whenthe rules are notified, and the Code becomes effective.
26. Wage revision for employees of PSU GIC is due w.e.f.Aug-22. Pending finalisation of wage negotiations, thecompany has made provision of wage bill based onmanagement assessment amounting to ?19807 Lakhstowards wage revision during the year ended March 31,2025 and the total provision as on March 31, 2025 is?45095 Lakhs.
27. Based on the advisory from IRDAI, the Company hasset up a Committee for IND-AS implementation andappointed knowledge partner who has completed GAPanalysis and submitted GAP assessment report. Forphase-II (solution and system design), the company hasfinalised the vendor for procurement of sub ledger solutionand is in the process of floating tender for engagement ofimplementation partner.
28. In accordance with Proviso to Rule 3(1) of the Companies(Accounts) Rules, 2014, the accounting software usedby the company for maintaining its books of accounthave a feature of recording audit trail of each and everytransaction, creating an edit log of each change made in thebooks of account along with the date when such changeswere made and ensuring that the audit trail cannot bedisabled and these edit logs have been preserved as perthe statutory requirements. Further, the company is in theprocess of compliance of Section 128 of the CompaniesAct 2013 and rules thereunder as amended, regardingmaintaining of books of accounts and papers maintainedin electronic mode at Foreign branches of the companyto be accessible in India at all times and maintenance ofback up of its books of accounts and papers at serversphysically located India on a daily basis.
29. The company has changed its policy for Expenses ofManagement which shall henceforth not include Provisionfor Bad & Doubtful debts. Consequent to this, expenseallocation is lower by ?74721 lakhs for the year endedMarch 31, 2025.
30. Proposed Dividend for current year: The Board ofDirectors of the Company proposed a final dividend of?29664 lakhs (?1.80 per share) being 36% of the Paid-up share Capital of the Company, subject to the approvalof the members at the Annual General meeting. In termsof Revised Accounting Standard (AS)4, Contingenciesand events occurring after the Balance sheet date asnotified by the Ministry of Corporate affairs through theamendments to the Companies (Accounting Standard)Rules, 2016, the company has not appropriated proposeddividend from the standalone Profit and Loss account forthe year ended March 31,2025.
Jyoti Rawat Vimal Kumar Jain Kasturi Sengupta Girija Subramanian
Company Secretary Chief Financial Officer Executive Director Chairman cum Managing Director
DIN: 11017873 DIN: 09196957
As per our report of even date For Chokshi & Chokshi LLP
For R. Devendra Kumar & associates Chartered Accountants
Chartered Accountants Firm Reg. No. 101872W/W100045
Firm Reg. No. 114207W
anand Golas dharmista Shah
Partner Partner
Membership Number 400322 Membership Number 108845
Mumbai, May 19, 2025