Provisions are recognised when the Company has a present obligation (legal or constructive) as a result of apast event, it is probable that an outflow of resources embodying economic benefits will be required to settlethe obligation and a reliable estimate can be made of the amount of the obligation. The expense relating to aprovision is presented in the statement of profit and loss.
Reimbursements expected in respect of expenditure required to settle a provision is recognized only when it isvirtually certain that the reimbursement will be received.
The Company does not recognize a contingent liability but discloses its existence in the financial statementsContingent liability is disclosed in the case of:
• A present obligation arising from past events, when it is not probable that an outflow of resources will berequired to settle the obligation
• A present obligation arising from past events, when no reliable estimate is possible
• A possible obligation arising from past events, unless the probability of outflow of resources is remote.
• Contingent assets are not recognised. A contingent asset is disclosed, as required by Ind AS 37, where aninflow of economic benefits is probable.
“Financial impact of events / information relating to prior years identified in the current year which are notmaterial are accounted for in the current year and are not corrected retrospectively through restatementof comparative amounts. Events or information are considered to be material if they could, individually orcollectively, influence the economic decisions of the users of the financial statements and on the basis ofgoverning laws, rules, regulations or recommendations issued by competent authorities.”
4.25 Earnings per Share
The basic earnings per share is computed by dividing the net profit after tax by the weighted average numberof equity shares outstanding during the year.
Diluted earnings per share is computed by dividing adjusted net profit after tax by the aggregate of weightedaverage number of equity shares and dilutive potential equity shares outstanding during the year. The numberof equity shares and potentially dilutive equity shares are adjusted for share splits /reverse share splits andbonus shares, as appropriate.
Significant accounting judgements, estimates and assumptions.
• The preparation of Standalone financial statements in conformity with Ind AS requires the management to makejudgments, estimates and assumptions that affect the reported amounts of revenues, expenses, assets andliabilities and the disclosure of contingent liabilities, at the end of the reporting period.
• Management believes that the estimates used in the preparation of financial statement are prudent and reasonable.Future result could differ from these estimates. Any revision to accounting estimate is recognized prospectively incurrent and future period.
In the process of applying the company's accounting policies, management has made the following judgements, whichhave a significant risk of causing a material adjustment to the carrying amounts of assets and liabilities within the nextFinancial Year.
• Classification and measurement of financial assets depends on the results of the SPPI and the businessmodel test. The Company determines the business model at a level that reflects how Companies of financialassets are managed together to achieve a particular business objective. This assessment includes judgementreflecting all relevant evidence including how the performance of the assets is evaluated and their performancemeasured, the risks that affect the performance of the assets and how these are managed and how themanagers of the assets are compensated. The Company monitors financial assets measured at amortised costor fair value through other comprehensive income that are derecognised prior to their maturity to understandthe reason for their disposal and whether the reasons are consistent with the objective of the business forwhich the asset was held. Monitoring is part of the Company's continuous assessment of whether the businessmodel for which the remaining financial assets are held continues to be appropriate and if it is not appropriatewhether there has been a change in business model and so a prospective change to the classification of thoseassets.
Estimates and Assumptions
• The key assumptions concerning the future and other key sources of estimation uncertainty at the reportingdate, that have a significant risk of causing a material adjustment to the carrying amounts of assets and liabilitieswithin the next Financial Year, are described below. The Company based its assumptions and estimates onparameters available when the financial statements were prepared. Existing circumstances and assumptionsabout future developments, however, may change due to market changes or circumstances arising that arebeyond the control of the company. Such changes are reflected in the assumptions when they occur
The fair value of financial instruments is the price that would be received to sell an asset or paid to transfera liability in an orderly transaction in the principal (or most advantageous) market at the measurement dateunder current market conditions (i.e., an exit price) regardless of whether that price is directly observable orestimated using another valuation technique. When the fair values of financial assets and financial liabilitiesrecorded in the balance sheet cannot be derived from active markets, they are determined using a varietyof valuation techniques that include the use of valuation models. The inputs to these models are taken fromobservable markets where possible, but where this is not feasible, estimation is required in establishing fairvalues. Judgements and estimates include considerations of liquidity and model inputs related to items suchas credit risk (both own and counterparty), correlation and volatility.
The company's EIR methodology recognises interest income / expense using a rate of return that representsthe best estimate of a constant rate of return over the expected behavioral life of loans given / taken andrecognises the effect of potentially different interest rates at various stages and other characteristics of theproduct life cycle (including prepayments and penalty interest and charges).
This estimation, by nature, requires an element of judgement regarding the expected behaviour and life-cycleof the instruments, as well expected changes to India's base rate and other fee income/expense that areintegral parts of the instrument.
The measurement of impairment losses across all categories of financial assets requires judgement, inparticular, the estimation of the amount and timing of future cash flows and collateral values when determiningimpairment losses and the assessment of a significant increase in credit risk. These estimates are driven by anumber of factors, changes in which can result in different levels of allowances.
The company's ECL calculations are outputs of complex models with a number of underlying assumptionsregarding the choice of variable inputs and their interdependencies. Elements of the ECL models that areconsidered accounting judgements and estimates include:
- The Company's grading model, which assigns PDs to the individual grades
- The Company's criteria for assessing if there has been a significant increase in credit risk and so allowancesfor financial assets should be measured on a LTECL basis and the qualitative assessment
- The segmentation of financial assets when their ECL is assessed on a collective basis - Development ofECL models, including the various formulas and the choice of inputs
- Determination of associations between macroeconomic scenarios and, economic inputs, such asunemployment levels and collateral values, and the effect on PDs, EADs and LGDs.
- Selection of forward-looking macroeconomic scenarios and their probability weightings, to derive theeconomic inputs into the ECL models
It has been the Company's policy to regularly review its models in the context of actual loss experience andadjust when necessary.
The Company operates in a regulatory and legal environment that, by nature, has a heightened element oflitigation risk inherent to its operations. As a result, it is involved in various litigation, arbitration and regulatoryinvestigations and proceedings in the ordinary course of the Company's business.
Given the subjectivity and uncertainty of determining the probability and amount of losses, the Company takesinto account a number of factors including legal advice, the stage of the matter and historical evidence fromsimilar incidents. Significant judgement is required to conclude on these estimates.
The Company's contracts with customers include promises to transfer services to a customer. The Companyassesses the services promised in a contract and identifies performance obligation involves judgement todetermine the deliverables and the ability of the customer to benefit independently from such deliverables.
The Company exercises judgement in determining whether the performance obligation is satisfied at a point intime or over a period of time. The Company considers indicators such as how customer benefits as servicesare rendered or who controls the asset as it is being created or existence of enforceable right to payment forperformance to date and alternate use of such product or services, transfer of significant risks and rewards tothe customer, etc.
Ind AS-116 requires lessees to determine the lease term as the non-cancellable period of a lease adjustedwith any option to extend or terminate the lease, if the use of such option is reasonably certain. The Companymakes an assessment on the expected lease term on a lease-by-lease basis and thereby assesses whetherit is reasonably certain that any options to extend or terminate the contract will be exercised. The lease termin future periods is reassessed to ensure that the lease term reflects the current economic circumstances.Company also used judgement in determining the low value assets as given under the Ind AS-116.
Significant estimates are involved in determining the provision for income taxes, including amount expected tobe paid/recovered for uncertain tax positions and in respect of expected future profitability to assess deferredtax asset.
The references below show where the Company's impairment assessment and measurement approach is set out in thesenotes. It should be read in conjunction with the Summary of significant accounting policies.
- The Company's definition and assessment of default and cure.
- How the Company defines, calculates and monitors the probability of default, exposure at default and loss given default.
- When the Company considers there has been a significant increase in credit risk of an exposure.
- The Company's policy of segmenting financial assets where ECL is assessed on a collective basis.
- The details of the ECL calculations for Stage 1, Stage 2 and Stage 3 assets.
The Company considers a financial instrument as defaulted and considered it as Stage 3 (credit-impaired) for ECL calculationsin all cases, when the borrower becomes 90 days past due on its contractual payments.
The estimation of Probability of Default (PD) shall be carried out in accordance with the following principles:
a. Through-the-Cycle PD (TTC-PD): TTC-PD shall be calculated using an incremental Non-Performing Asset (NPA) approach.In cases where there is limited default history for a specific portfolio, a credit rating-based default study shall be utilized toderive the TTC-PD.
b. Point-in-Time PD (PiT-PD): Through-the-Cycle Probability of Default (TTC-PD) shall be converted into Point-in-TimeProbability of Default (PiT-PD) using a forward-looking model. This model shall incorporate portfolio-specific macroeconomicvariables to ensure that the estimate reflects current and anticipated economic conditions relevant to the portfolio.
c. Stage-II Loans - Lifetime PD: For loans classified under Stage-II, Lifetime Probability of Default shall be estimated usingsurvival analysis techniques over the remaining contractual tenure of the loans.
d. Stage-III Loans: Loans classified under Stage-III shall be assigned a Probability of Default of 100%.
The exposure at default (EAD) represents the gross carrying amount of the financial instruments subject to the impairmentcalculation, addressing both the borrower's ability to increase its exposure while approaching default and potential earlyrepayments too.
The Company segments its lending products into smaller, homogeneous portfolios to facilitate accurate estimation of creditrisk parameters. For all portfolios except Government Loans Backed by Government Guarantee, the Loss Given Default(LGD) is estimated based on historical recovery experience, taking into account actual recoveries observed over time. In thecase of Government Loans Backed by Government Guarantee, a bucket-level LGD approach is adopted. These buckets aredefined using state-level fiscal deficit data, which serves as a proxy for the fiscal strength of each state and the correspondingcredit risk associated with the guarantees provided.
The Company continuously monitors all assets subject to ECLs. In order to determine whether an instrument or a portfolioof instruments is subject to 12mECL or lifetime ECL, the Company assesses whether there has been a significant increasein credit risk since initial recognition. The Company considers an exposure to have significantly increased in credit risk whencontractual payments are more than 30 days past due.
When estimating ECLs on a collective basis for a group of similar assets, the Company applies the same principles forassessing whether there has been a significant increase in credit risk since initial recognition.
The Company calculates ECLs on collective basis for all Stage I and II Loans and on an individual basis for Stage III Loans
For the purpose of the Company's capital management, capital includes issued equity capital, share premium and all otherequity reserves attributable to the equity holders of the Company. The primary objectives of the Company's capital managementare safety and security of share capital and maximize the shareholders' wealth.
The Company maintains an actively managed capital base to cover risks inherent in the business and is meeting the capitaladequacy requirements of the regulator viz., RBI. The adequacy of the Company's capital is monitored using, among othermeasures, the regulations issued by RBI.
Company has complied in full with all its externally imposed capital requirements over the reporting period.
RBI vide letter dated August 23, 2024 granted Certificate of Registration (CoR) as NBFC-IFC to HUDCO. Accordingly,Company being a NBFC-IFC now, is complying with the Capital Adequacy requirements as prescribed by the Master Directions- Reserve Bank of India (Non-Banking Financial Company- Scale Based Regulations) Directions, 2023 dated October 19,2023 and updated from time to time.
Being an NBFC-IFC, HUDCO is required to maintain Capital Adequacy Ratio or Capital to Risk Weighted Assets Ratio(CRAR) of 15% (with a minimum Tier I Capital of 10%), computed by dividing company's Tier-I and Tier-II capital by RiskWeighted Assets.
Dividend Distribution Policy
BoD monitors the dividend pay-out to the shareholders of the Company. Dividend distribution policy of the Company focuseson various factors including but not limited to the present & future capital requirements, profits earned during the FinancialYear, Capital to Risk-weighted Assets Ratio (CRAR), cost of raising funds from alternate sources, cash flow position andapplicable taxes if any and net worth of the Company, subject to the applicable circulars/ guidelines issued by RBI, DIPAMetc. as applicable from time to time.
As per the extant guidelines issued by DIPAM, Government of India, Company is required to pay a minimum annual dividendof 30% of PAT or 5% of the net-worth, whichever is higher.
Though the Company endeavors to declare the dividend as per these guidelines, the Company may propose lower dividendafter analysis of various financial parameters, cash flow position and funds required for future growth.
Other Policies
The Company has also adopted various policies for the management of the Company which inter-alia include ComprehensiveRisk Management Policy, Whistle Blower Policy, Code of Conduct for Regulating, Monitoring & Reporting of Trading byDesignated Persons & their Immediate Relatives and for Fair Disclosure, Policy for prevention of Fraud, The Code of BusinessConduct and Ethics for Board Members and Senior Management, Fair Practices Code, Internal Guidelines on Corporate
Governance, Policy on 'fit & proper' criteria of Directors etc.
Fair Value is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction in theprincipal (or most advantageous) market at the measurement date under current market conditions (i.e., an exit price),regardless of whether that price is directly observable or estimated using a valuation technique.
In order to show how fair values have been derived, Financial Instruments are classified based on a hierarchy ofvaluation techniques.
The Company's Fair Value methodology and the governance over its models include a number of controls and otherprocedures to ensure enough safeguards and maintain its quality and adequacy. All new product initiatives (includingtheir valuation methodologies) are as per the approved policy of the Company. The ongoing measurement on fair valueestimates is reviewed by the appropriate functional department of the Risk management and related finance functions.
The following table shows an analysis of financial instruments recorded at fair value by the level of the fair valuehierarchy:
Mutual Funds are valued at the Net Asset Value (NAV) declared by the respective Mutual Fund in respect of eachparticular Scheme and is classified as Level 2
Equity Instruments
Equity Instruments, which are not actively traded on public stock exchanges but the active prices on a regular basis areavailable, such instruments are classified as Level 2. Other equity instruments are fair valued based on the averageof the Discounted Cash Flow (DCF) method and Net Assets Value (NAV) (as provided by independent valuer). It isclassified as Level 3.
Interest Rate Swaps, Currency Swaps and Forward Rate Contracts
The most frequently applied Valuation techniques include Forward Pricing and Swap Models and Forward Contractusing Present Value calculations by estimating future cash flows and discounting them with the appropriate yield curvesincorporating funding costs relevant for the position. These contracts are classified under Level 2.
Investment Property
The Company obtains independent valuations for its investment properties annually. The fair values of investmentproperty are determined by an independent registered valuer and the valuation technique adopted are Income approach,Market Approach and Composite Approach. All resulting fair value estimates for investment property are included inLevel 2 (refer 14A).
There have been no transfers between Level 1 and Level 2 for the year ended 31st March, 2024 and 31st March,2025.
The following tables show a reconciliation of the opening and closing amounts of Level 3 financial assets and liabilitieswhich are recorded at fair value. The Company requires significant unobservable inputs to calculate their fair value.
(a) Net Asset Value (NAV) Method:
The Net Asset Value Method represents the value with reference to historical cost of assets owned by the company andthe attached liabilities on the valuation date.
(b) Discounted Projected Cash Flow:
Discounted Projected Cash Flow valuation technique is used to calculate Impact on fair value of level 3 financialinstruments measured at fair value using the following unobservable input such as Discount Rate, Recovery rates,Interest Rate and Revenue from operations to ascertain the change.
(c) To arrive at fair value of unquoted investments average of Net Asset Value (NAV) and Discounted Projected Cash flowas on 31st March, 2025 is taken.
The range of values indicates the highest and lowest level input used in the valuation technique and, as such, onlyreflects the characteristics of the instruments as opposed to the level of uncertainty to their valuation.
Interest Rate volatility measures the expected future variability of a market price. It is generally quoted as a percentage;a higher number represents a more volatile instrument, for which larger swings in price (or interest rate) are expected.Volatility is a key input used to estimate the future prices for the underlying instrument (equity share). Interest ratevolatility varies from time to time and therefore, it is not viable to make reliable and meaningful general statements aboutvolatility levels.
Discount rates are used for calculating the present value of future cash flows. In discounted cash flow models, discountrates are used as the direct reflection of the expected rate of return of the investments made by the company in thedue course of the business. Hence, these rates reflect the net present value of an asset. They generally reflect thepremium an investor expects to achieve over the benchmark interest rate to compensate for the higher risk driven bythe uncertainty of the cash flows caused by the credit quality of the asset. They can be implied from market prices andare usually unobservable for illiquid or complex instruments.
Recovery Rates
Recovery rates reflect the estimated loss that the company will suffer given expected defaults (Non-performing Assets).The recovery rate is given as a percentage and reflects the opposite of loss severity (i.e., 100% recovery reflects 0%loss severity). In line with the operation of the Company, probability of non-performing assets to loss assets playsan important role to ascertain the recovery rates. Higher loss severity levels / lower recovery rates indicate lowerexpected cash flows upon the default of the instruments. Recovery rates for complex, less liquid instruments are usuallyunobservable and are estimated based on historical data.
Revenue from operations
Revenue is the value of all sales of goods and services recognized by a company in a period. Revenue (also referred toas Sales, Turnover, or Income) forms the beginning of a company's Income Statement and often considered the “TopLine” of a business. Growth in revenue from operation directly impacts the profitability of the company, as operationexpenses are deducted from a company's revenue to arrive at its profit.
Sensitivity of fair value measurements to changes in unobservable market data cannot be ascertained due to potentialoff-sets from economic or accounting hedge relationships in place.
The following table indicates the carrying amounts and fair values of the Company's financial instruments, by class, thatare not carried at fair value in the financial statements. This table does not include the fair values of non-financial assetsand non-financial liabilities.
Trade Receivable, Other Receivables and Trade Payables and Other Payables are carried at Carrying amount whichequals fair values, these are not carried at fair value in the financial statements.
Below are the methodologies and assumptions used to determine fair values for the above financial instruments whichare not recorded and measured at fair value in the Company's financial statements. These fair values were calculatedfor disclosure purposes only. The below methodologies and assumptions relate only to the instruments in the abovetables and, as such, may differ from the techniques and assumptions explained in Note 36.4.
For financial assets and financial liabilities, that have a short-term maturity (less than twelve months), the carryingamounts, which are net of impairment, are a reasonable approximation of their fair value. Such instruments include:Trade receivables and trade payables without a specific maturity.
The carrying amount of fixed interest rate bearing loans and floating interest rate bearing loans are taken as fair values.Financial asset at amortised cost
The fair values of financial assets at amortised cost are the carrying amount of the financial asset.
Fair value of traded bonds is market price of the bonds as on the balance sheet date or close to balance sheet date. Incase of Commercial Paper which is Current Liability i.e., short term maturity (less than or equal to twelve months), theface value of outstanding commercial paper is considered as fair value.
Borrowing other than debt securities
The carrying amount of fixed interest rate bearing borrowings and floating interest rate bearing borrowings are taken asfair values, since these are reasonable approximation of their fair value.
The Company being an Infrastructure Finance Company is exposed to various types of risks like credit risk, operationalrisk, liquidity risk, market risk, foreign currency risk etc. The Company is fully committed to manage these risks in aneffective and proactive manner, for which HUDCO has in place a Comprehensive Risk Management Policy and RiskRegister cum Early Warning Signals aligned with its objectives covering both the internal and external environment.
The Board of Directors has overall responsibility for the establishment and oversight of the Company's risk managementframework. With a view to minimize the impact of various risks to which the company is exposed to , HUDCO hasin place a Board level Committee i.e. 'Risk Management Committee' (RMC) which reviews various suggestions/recommendations/reports and action taken by the sub-committees namely :
• Credit & Operational Risk Management Sub-Committee (CORMSC); and
• Assets & Liabilities Management Committee (ALCO)
The Credit & Operational Risk Management Sub-Committee (CORMSC) oversees and ensures that the institution'scredit policies are complied with and the laid down procedures are being consistently applied. The CORMSC alsooversees and ensures the implementation of operational risk framework to explicitly manage each and every source ofoperational risk including Technology risk, Employee risk, Customer risk, Capital Assets risk and External risk.
Assets and Liabilities Management Committee (ALCO) reviews the liquidity and market risks and ensures managementof mismatches through liquidity gap analysis, interest rate sensitivity analysis as per RBI guidelines. It is ensured thatthe ALM risks, if any, are managed within the permissible limits.
For managing credit risk in the business at different levels including at appraisal, disbursement and post- disbursement,the Company has in place a strong and effective credit appraisal mechanism containing comprehensive appraisaltechniques/ guidelines, and Comprehensive Risk Management Policy and Risk Register cum Early Warning Signals toidentify and mitigate stress in the credit portfolio.
Credit risk arising from derivative financial instruments is, at any time, limited to those with positive fair values, as recorded onthe balance sheet.
With gross-settled derivatives, the Company is also exposed to a settlement risk, being the risk that the company honours itsobligation, but the counterparty fails to deliver the counter value.
The carrying amount of financial assets represents the maximum credit exposure. The maximum exposure to credit risk was? 1,24,340.71 Crore and ? 91,365.05 Crore as of 31st March,2025 and 31st March, 2024 respectively, being the total of thecarrying amount of balances with loans.
Equity Price Risk is the risk that the fair value of equities decreases as a result of changes in the level of equity indicesand individual stocks. At increase in the value of the Company's Equities at 31st March, 2025 would have increasedEquity by ? 28.17Crore. An equivalent decrease would have resulted in an equivalent but opposite impact and wouldcause a potential impairment, which would reduce profit before tax by approximately by ? 28.17Crore.
Operational Risk Management Framework covers managing each and every source of Operational Risk as a distinct riskto the Company's safety and soundness. In order to mitigate the Operational Risk(s) of the organization, both internalas well as external, including Technology Risk, Cyber Security Risk, Employee Risk, Capital Asset Risk, ComplianceRisks, Fraud Risk ,Legal Risk, etc. the Company has established a strong reporting and monitoring mechanism.
To manage the operational risks effectively, the Company has implemented a Comprehensive Risk Management Policyand Risk Register cum Early Warning Signals, through which all operational risks are measured and categorised ashigh, moderate or low and necessary steps are taken to manage these risks.
1. Hedge effectiveness is determined at the inception of the hedge relationship, and through periodic prospective
effectiveness assessments to ensure that an economic relationship exists between the hedged item and hedginginstrument.
The Company has used hypothetical derivative method for effectiveness assessment. Under this method, the hedgedrisk is modelled as a derivative called the hypothetical derivative which has the same terms as the hedged item. Thehypothetical derivative approach compares the change in fair value of the hedging instrument with the change in the fairvalue of the hypothetical derivative. Prospective hedge effectiveness testing has been performed using the sensitivityanalysis approach. Under this approach, the impact of a uniform /- 5% shock on the forward curve has been performedto assess the effectiveness of the hedge.
The currency swap and option contracts are denominated in the same currency as the highly probable future foreigncurrency principal and interest payments, therefore the hedge ratio is 1:1.
NOTE 40: Ind AS-116 Leases
a. Company as a Lessee
The Company has Lease Contracts for the Office Building, which are cancellable by the both the lessor and lessee.The Company has some Contracts, which are cancellable by the either lessor and lessee and at present, there is noestimation by the Company to continue or discontinue the same. Further amount of that leases are not material for theCompany and therefore Company is not creating ROU on that asset based on the materiality as per the guidance givenunder the Indian Accounting Standard. Besides Company used hindsight in determining the Lease Term, where theContract contained options to extend or terminate the lease and therefore its leases are covered under the Short-TermLeases as per the guidance under the Ind AS-116.
Amounts recognised in Statement of Profit and Loss relating to Short Term Leases is ? 1.81 Crore during the year 2024¬25 and in the previous year 2023-24 is ?1.73 Crore.
b. Company as a Lessor
The Company has given its Assets on the leases, details of the same are given under the “Note No-14A InvestmentProperty”.
Lease Rental recognized as Income during the year 2024-25 is ? 56.29 Crore and in the Previous year 2023-24 is ?54.76 Crore.
1) The financial statements for the Financial Year ended 31st March, 2025 have been drawn up on the basis of Ind-AS thatare applicable to the Company based on MCA Notification G. S. R. 111 (E) and G. S. R. 365 (E) dated 16th February,2015 and 30th March, 2016 respectively as amended from time to time. Any guidance/ clarifications issued by RBI orother regulators are adopted/ implemented as and when they are issued/ applicable. The results have been preparedbased on the Division III of Schedule III for Non-Banking Financial Companies as per Notification G.S.R. 1022 (E)issued by the Ministry of Corporate Affairs on 11th October, 2018 and as amended from time to time.
i. HUDCO had initiated execution of Andrews Ganj Project (AGP) on behalf of the then Ministry of Urban Development,(MoUD) in the year 1989-90.
ii. As per minutes of the meeting held on 7th September, 1995, it has been agreed to pay interest @ 17% p.a. (simple) onthe expenditure incurred on AGP along with 1.5% of project cost as administrative charges.
iii. As per Perpetual Lease Deed dated 4th July, 1997, the Company is liable to make available “Net Resources” from thedevelopment and disposal of properties of the AGP to then MoUD and accordingly the Company was crediting intereston Net Resources generated on the project upto 3rd November, 2004. Subsequently, a separate “No Lien AGP Account”has been opened under the name of “HUDCO AGP Account”, in which the surplus lying to the credit of the then MoUDwas credited and interest accrued/ earned on “No Lien AGP Account” was also credited to that account.
iv. HUDCO contends that as per minutes of the meeting held on 7th September, 1995 and in terms of Perpetual LeaseDeed dated 4th July, 1997, the status of the Company is “Agent of MoUD”. The contention of HUDCO is that it is workingas an agent and as such total ownership rights and responsibilities of AGP are of MoHUA-GOI (erstwhile MoUD) andthere is no financial liability of HUDCO in respect of AGP. This has been upheld by learned Shri GE Vahanvati, the thenSolicitor General of India, vide his opinion dated 12th April, 2005. This opinion was re-confirmed by learned Shri GEVahanvati as Attorney General of India vide his opinion dated 19th August, 2009. The opinion was also duly endorsedby the then Law Secretary and Law Minister of Government of India.
v. Keeping this position in view and in accordance with HUDCO's Board decision in 459th meeting dated 24th August,2009, HUDCO has been making payments / settling claims on Ministry's behalf and accounting them in “No Lien AGPAccount” being separately maintained by HUDCO. As on 31st March, 2025, this account has a deficit in the form ofdebit balance of ? 626.51 Crore, recoverable from MoHUA (erstwhile MoUD). This represents amount paid by HUDCOon behalf of the Ministry for the capital and revenue expenditures on AGP project over and above the recoveries andthe accumulated interest amounting to ? 350.28 Crore charged @ 10.75% p.a. (simple), on excess of expenditureover recoveries. The MoHUA (erstwhile MoUD) in a meeting held on 27th April, 2015 have also asserted that HUDCOshall continue to implement and manage the AGP in terms of Perpetual Lease Deed and all the pending issues shallbe looked into for resolution by the Ministry. The MoHUA (erstwhile MoUD) in the said meeting has also decided thatHUDCO as a Lessee will bear all the liabilities including the liabilities generated out of compliance of various courtorders in cases related to the project. The company vide its letter dated 30th September, 2015, conveyed its reservation
to accept the decision for bearing the liabilities of Andrews Ganj project as HUDCO is acting as an agent of MoHUA,Government of India, for AGP, in terms of perpetual lease deed conditions and other agreed terms.
vi. The Ministry has been informed specifically of the above facts and figures on various occasions through correspondenceas also in the meetings. A communication was received from Dy. L&DO vide letter dated 22nd March, 2016 whereinDy. L&DO had conveyed that HUDCO may continue to implement Andrews Ganj project and manage “No Lien AGPAccount” in line with the terms and conditions as stipulated in the Perpetual Lease Deed dated 4th July, 1997. TheMinistry again informed in specific vide Dy L&DO letter dated 31st May, 2018 that HUDCO as a lessee is permitted toincur/book maintenance and legal expenditure in respect to Andrews Ganj Project from “No Lien AGP Account”. Likeearlier years, in-line with the minutes of meeting dated 7th September, 1995, the perpetual lease deed dated 4th July,1997, income of ? 29.46 Crore on account of interest accrued on AGP Project has been credited to Statement of Profitand Loss for the period year ended 31st March, 2025.
vii. As decided by HUDCO Board in its 596th meeting held on 14th June, 2018, Ministry of Housing and Urban Affairshas been requested vide letter dated 9th July, 2018 to consider taking over the Andrews Ganj project with assetsand liabilities and pay the amount incurred / to be incurred by HUDCO, towards implementing the project. It has alsobeen conveyed that “till the project is taken over by Ministry”, HUDCO shall be continuing implementing the projectas per existing arrangements and continue booking maintenance and legal expenses, interest @ 10.75% p.a. andadministrative charges @1.5% in “No Lien AGP Account”.
viii. The company, in its aforesaid capacity as an agent of MoHUA (erstwhile MoUD), relating to AGP, is in possession of realestate properties (9 guest houses blocks and hotel site) which command much higher realizable market value sufficientto recover aforesaid amount of ? 626.51 Crore, as on 31st March, 2025.
ix. MoHUA was requested vide letter dated 13th January, 2021 to make arrangement towards reimbursement of the amountrecoverable endorsement for settling the same from the project proceeds as and when the same are realized, which isalso in line with the Lease agreement and well settled and agreed.
In reply to the same, Ministry vide letter dated 10th March, 2021 had requested for certain additional information includingthe breakup details of principal amount and interest amount as contained in the “No Lien AGP Account” to processHUDCO's request.
Ministry vide letter dated 28th June, 2021 had stated that the “HUDCO's proposal is under examination in consultationwith IFD, MoHUA. Till the proposal of HUDCO vide their letter dated 13th January, 2021 is approved, the existingarrangement may be continued as conveyed vide this office letter dated 22nd March, 2016 and 31st May, 2018”.
In the review meeting held by JS (L&E), MoHUA on 19th March 2025 it was desired to lower the applicable Rate ofInterest charged by HUDCO on outstanding balance of 'No lien AGP account'. Pursuant thereto, HUDCO vide letterdated 28th March 2025 to Ministry has suggested 8.75% rate of interest with prospective effect from 1st April 2025; theconfirmation on the same by the Ministry is awaited.
HUDCO vide letter dated 13th March 2025 informed the Ministry about the Judgement and order dated 13th February2025 of the Hon'ble Supreme Court, which has been noted by the Ministry vide its letter dated 24th April 2025.
Hence, in view of the facts and circumstances stated above, the Company does not expect any liability on this accountand any expenditure related thereof. In case of any liability by virtue of any court order or otherwise, the same shall bein the account of 'No lien AGP Account', based on the facts and documents and the legal opinions obtained by HUDCO.
(B) Litigation Status
i. Tomorrowland Technologies Exports Ltd.
The Company had allotted a hotel site including car parking space to M/s Tomorrowland Technologies ExportsLtd. i.e., TTEL (formerly known as M/s. M S Shoes East Limited). Due to default in payment of instalments byTTEL, the Company cancelled the allotment of hotel site including car parking space and forfeited the amount paidby TTEL in terms of the allotment letter.
TTEL started litigation regarding hotel site and filed suit for declaration in lower courts that cancellation of allotmentletter by HUDCO, be declared as null & void. The Sr. Civil Judge passed final order dated 3rd July, 2010 againstHUDCO. HUDCO filed first appeal against the Order dated 3.07.2010 of Sr. Civil Judge before the AdditionalDistrict Judge (ADJ) Delhi. The ADJ vide Order dated 18th July, 2014 dismissed the first appeal of HUDCO andpassed the judgment in favour of TTEL. HUDCO filed Regular Second Appeal (RSA) before the Hon'ble HighCourt of Delhi which vide its judgement dated 3rd June, 2016 allowed the second appeal of HUDCO and upheldthe cancellation of allotment by HUDCO w.r.t. Hotel Site & car Parking slots. TTEL challenged the High CourtOrder dated 3.06.2016 by filing SLP (C) No.: 34338 / 2016 before the Hon'ble Supreme Court of India. TheHon'ble Supreme Court vide its judgment and order dated 13.02.2025 has decided the said SLP and has directed
for refund of the forfeited amount of Rs.28,11,31,939/- to TTEL within three months from the date of the order,failing which, TTEL shall be entitled to interest @ 6% per annum till the date of payment.
The allotment of 9 blocks of guest houses, restaurants, kitchens, and shops, which were allotted to TTEL,was cancelled due to default in payment of instalment by TTEL and amount of first instalment paid by TTELwas forfeited as per terms of allotment letter. TTEL filed civil suit challenging the cancellation of allotment, forpermanent injunction and possession, against HUDCO & Union of India. The Hon'ble High Court, vide Orderdated 10th August, 2016, directed that HUDCO & Union of India should consider the proposal given by TTEL forrefund of entire amount deposited by way of 1st instalment by it with HUDCO along with interest at such rate whichmay be deemed appropriate by Court.
In view of Hon'ble High Court of Delhi order dated 10th August, 2016, the Board in its 568th meeting held on23rd August, 2016 resolved to approve the proposal to refund first instalment forfeited by HUDCO excludingearnest money & the interest for delayed payment paid thereof by TTEL for guest house blocks after adjusting thecommercial losses caused to HUDCO and other expenses incurred by HUDCO since 1997-98 from the date ofcompletion of project and subject to necessary approval / NOC of MoUD, Govt. of India.
The Hon'ble High Court passed a decree dated 13th January, 2017 for refund of the first instalment excluding theearnest money to TTEL along-with interest @ 6% p.a., w.e.f. 30th January, 1995 till date of payment and directedHUDCO to refund the interest paid by TTEL (?0.99 Crore) on the delayed period of payment of 1st instalment (from30th November, 1994 till 30th January, 1995). If the entire amount is not paid on or before 31st December, 2017,the rate of interest would then stand enhanced to 11% p.a. However, the decree was made in-executable till 30thJune, 2017. Both HUDCO and TTEL challenged the said decree dated 13.01.2017.
TTEL filed Review Petition in the month of May, 2017, before Hon'ble High Court of Delhi for review of the Decreedated 13th January, 2017, praying inter-alia for refund of EMD, grant of interest @ 16.48% p.a. on quarterlyrests. Subsequently, Review Petition filed by TTEL was disposed off by the High Court on 12th December, 2017.Thereafter, TTEL has filed Special Leave Petition (SLP No 10752/53 of 2018) in Hon'ble Supreme Court againstthe Decree dated 13th January, 2017 and Hon'ble High Court Order dated 12th December, 2017. The same havebeen disposed off by the Hon'ble Supreme Court of India vide its Order dated 10.12.2024 and referred them toDelhi High Court where they are listed as Regular First Appeal No. 1/2025 & 2/2025 of TTEL. The said two RFAsof TTEL are listed with the RFA No. 79/2018 of HUDCO and are currently pending.
The Company also filed application for recalling the Hon'ble High Court Order dated 13th January, 2017, in viewof the Review Petition filed by TTEL and directions of Govt. of India. The matter was listed on 28th August, 2018,after hearing all parties, Hon'ble High Court dismissed the “Recall Application” of HUDCO. HUDCO filed SLP inSupreme Court challenging the High Court Order dated 28th August, 2018 and 13th January, 2017. Vide Orderdated 18th September,2018, the Hon'ble Supreme Court dismissed the SLP as withdrawn, with liberty to HUDCOto file all legal objections regarding the executability of the decree in the executing Court.
Further, TTEL also filed first Execution Petition in Delhi High Court and later on, the same was also withdrawn byTTEL on 23rd December, 2017. Thereafter, TTEL has filed Revised Execution Petition, making Govt. of India alsoa party and claiming rate of interest @ 11% p.a. as per the decree dated 13th January, 2017.The matter was listedon 3rd May, 2018, wherein the Hon'ble High Court first directed for attachment of HUDCO Property i.e. HUDCOBhawan, IHC, Lodhi Road, New Delhi. However, after hearing the submission of HUDCO, vide the same order,Hon'ble High Court kept the attachment order of HUDCO Property in abeyance till the next date and also directedthat HUDCO will not sell the property at Andrews Ganj, Delhi.
Further, the learned Justice V.N. Khare, former Chief Justice of India, has opined that, “HUDCO's consent toperform the terms of the Order dated 13th January, 2017 was conditional on UOI's support and in the event anyliability is indeed ascribed to HUDCO, the same should then be recoverable from the UOI”.
In view of the Supreme Court's Order dated 18th September, 2018, HUDCO filed objection in the ExecutionPetition, pending in Delhi High Court. The matter was listed on 29th October, 2018. After hearing the submissionof HUDCO's Counsel, the Hon'ble Court dismissed the objections. HUDCO filed two appeals in Delhi High Courtas under:
1. Regular first Appeal (RFA 79/2018) against the final order/ decree 13th January, 2017 and order dated 28thAugust, 2018 (Dismissal of Recall application by High Court). The said Regular First Appeal of HUDCO iscurrently pending.
2. Execution First Appeal (EFA No 19/2018) against the order dated 29th October, 2018, wherein objections ofHUDCO in execution petition were dismissed. The matter was listed on 27th November, 2018. After hearing thematter, the Hon ble Court stayed the execution proceeding pending in Delhi High Court till the next date. Thematter was listed again on the application of the M/s TTEL for vacation of stay on 8th July, 2020 before DivisionBench, Delhi High Court, after hearing the matter, the Hon'ble Court directed that Execution First Appeal (EFA)19/2018) shall be adjourned sine die and will be listed after the final disposal of the Regular First appeal (RFA79/2018). The parties are at liberty to move the application for revival of EFA after final disposal of RFA 79/2018.Till the further order, the stay on the Execution proceedings shall be continued. Both the cases are pending.
TTEL filed SLP in Supreme Court, against the High Court Order dated 27th November, 2018, wherein HighCourt stayed the execution proceedings. However, the same has been withdrawn by TTEL on 14th January,2019.
(ii) M/s. Ansal Properties and Industries Ltd. (APIL)
The arbitrator had passed an award in favour of M/s. Ansal Properties and Industries Ltd. (APIL) amounting to?8.84 Crore along with interest @ 18% p.a. on 28th July, 2005 in respect of the property leased to APIL at AGP.The Arbitrator had also allowed the counter claim of HUDCO amounting to approximately ?0.85 Crore along withinterest @ 18% p.a. on account of maintenance charges w.e.f. 1st January, 2001 up-to 31st July, 2005. HUDCOchallenged the award before the Hon'ble High Court of Delhi and, as per the directions of the court, deposited asum of ?7.99 Crore in the court out of “No Lien AGP Account”.
APIL invoked arbitration for refund of ground rent paid by it from November, 1995 to October, 1999 and thearbitrator pronounced the award on 21st July, 2006 holding therein that APIL is not liable to pay the ground rentup to October, 1999 i.e. till the shopping arcade was constructed and became operational in October, 1999. Theamount of ?3.93 Crore deposited earlier by APIL has been directed to be adjusted towards the future ground rentpayment dues w.e.f. November,1999 along-with Interest @ 7% p.a. for delayed payment. HUDCO filed petitionchallenging the award before the Hon'ble High Court of Delhi. The Hon'ble High Court on 10th May, 2012 setaside the arbitration award dated 21st July, 2006. APIL filed an appeal against the above-mentioned order beforeDivision Bench of Hon'ble High Court, Delhi. Division Bench vide its order dated 24th January, 2013, allowed APILappeal and upheld the Arbitrators award. HUDCO filed SLP on 10th May, 2013 before Hon'ble Supreme Courtagainst this order which is currently pending.
On the last day of hearing, i.e., 5th January,2023, APIL's counsel informed the court that vide Order dated 16thNovember 2022, APIL was declared insolvent by NCLT and therefore, now the APIL is under Moratorium. Henceas per the law, all the proceedings pending against APIL are automatically stayed by virtue of law. Further, HUDCOfiled its total claims due against APIL before the Resolution Professional appointed for the above purpose. Theclaim of HUDCO was not considered as the matter was related to specific property only.
Recently, application of the IL&FS under Section 7 of the IBC, 2016 was admitted by the NCLT, New Delhi againstAnsal Properties & Infrastructure Ltd. (APIL) on 25.02.2025 and Sh. Navneet Kumar Gupta appointed as the IRP.As moratorium is also imposed, all the proceedings pending against APIL are now under moratorium. IRP issueda public notice on 28.02.2025 for filing of claim by the claimants of APIL on or before 11.03.2025. Accordingly,HUDCO has filed claim of Rs. 401.54 Crore (till 25th Feb 2025) on APIL in the stipulated timeline. The matter ispending.
4) HUDCO had allotted 6435 sq. mtr. of built-up space in 1993 at HUDCO Vishala, Bhikaji Cama Place, New Delhito EPFO on Long Term Sub-lease basis. The sub-lease in favour of EPFO is yet to be executed and ?0.35 Croreis recoverable from EPFO.
6) The receipts from the agencies in the loan accounts is appropriated as per loan agreement in the following order:
a. Other dues/ expenses recoverable
b. Penal interest
c. Normal interest
d. Principal
The appropriation stated above is apportioned vertically amongst the above components of the loan overdue, in order
stated above at borrower level. In the event of excess payment, the same is adjusted towards principal.,
HUDCO has Board approved Technical Write off Policy.
7) In terms of the settlement under Insolvency and Bankruptcy Code (IBC) proceedings/ One time settlement (OTS)/
Restructuring, the company has written off loans amounting to Rs. 35.17 Crores (Previous Year Rs.46.58 Crores). The
details of write-offs are as below:
a) During the Current Year (a) During the FY 2024-25, the company has implemented settlement plan in case ofCoastal Energen Private Limited with principal outstanding Rs. 243.92 Crore, as per NCLT order. As per the orderthe account was settled by payment of Rs. 208.75 Crore, and balance principal amount of Rs. 35.17 Crores havebeen written off.
b) During the Previous Year (a) During the FY 2023-24, the company has implemented restructuring plan in case ofPipavav Defense and Offshore Engineering Co. Ltd with principal outstanding Rs. 84.03 Crore, as per NCLT order.As per the order part of the outstanding loan was converted into a debt of Rs. 34.40 Crore, with an upfront paymentof Rs. 3.05 Crore and balance principal amount of Rs. 46.58 Crores have been written off.
8) HUDCO had earned dividend income of ? 7.38 Crore (Previous Year: ? 5.89 Crore) during the Financial Year 2024¬2025.
9) The company has elected to continue with the carrying value of all its property, plant and equipment and intangibleassets and use that carrying value as the deemed cost of the property, plant and equipment and intangible assets as on01st April 2017.
10) The Company had made Long Term Investments at a total cost of ? 1090.14 Crore (Previous Year: ? 67.91 Crore) whichrepresents Debt instruments, Government securities, Trade Investment in Equity Shares, Investments in Associates. Asper the applicable Ind AS, Investments as on 31st March, 2025 are being shown at fair value through profit or loss of ?1319.62 Crore (Previous Year: ? 272.75 Crore).
11) Loans granted by the company directly to individuals under HUDCO Niwas Scheme are secured fully/partly by:
(i) Equitable Mortgage of the property and /or
(ii) Undertaking to create security through execution of Tripartite Agreement between the Company, borrower, and theDeveloping Authority / Developer;
In addition to (i) and (ii) above, the assignment of Life Insurance Policies, pledge of National Saving Certificates, FixedDeposits, etc. are also obtained.
12) The Company has adopted Ind AS-19 'Employee Benefits'. Defined employee benefit schemes which are as follows:General description of various defined employee's benefits schemes is as under:-
(a) Expenditure on company contributions to Provident Fund, Group Saving Linked Insurance Scheme, EPFO'sEmployees' Pension Scheme and HUDCO's Employees' Pension Scheme is accounted for on accrual basis in accordancewith the terms of the relevant schemes and charged to Statement of Profit & Loss. The Company's obligation towardsgratuity, provident fund and post-retirement medical benefits to employees are actuarially determined and provided foras per Ind AS 19 on Employee Benefits. Liability for gratuity as per actuarial valuation is paid to a fund administeredthrough a separate trust.
(b) The Company's obligation towards sick leave, earned leave, gift on long service & retirement are determined onactuarial basis and provided for as per Ind AS 19 on Employee Benefits
(1) Provident Fund
(a) The Company has a separate trust to manage Provident Fund Scheme and provides interest guarantee as perEmployees' Provident Fund Scheme, 1952. The Company pays fixed contribution of Provident Fund at a predeterminedrate to the trust, which invests the funds in permitted securities. The trust is required to pay a minimum notified rate ofinterest on contribution to the members of the trust and the provident fund scheme additionally requires the company toguarantee the payment of interest at rates notified by the Central Government from time to time under the Employees'Provident Fund Scheme, 1952 and recognizes such deficiency as an expense in the year it is determined.
(b) In view of the interest rate guarantee by the Company, the plan although being a defined contribution plan is beingtreated as defined benefit plan for the purpose of disclosure as per Ind AS 19, since as per Section 17 of the EmployeesProvident Funds (EPF) Act, 1952, the company has to guarantee the interest rate as announced by the EPFO from timeto time. Accordingly, the actuarial valuer has done valuation to the extent of interest rate guarantee and details of thesame have been disclosed as given below.
(c) The fair value of the plan assets of the Provident Fund and the accumulated members' corpus is ?456.29 Crore and?460.36 Crore respectively (Previous year ?450.34 Crore and ?436.36 Crore respectively). The fair value of the assetsof the provident fund as at 31st March, 2025 is lower than the obligation under the defined contribution plan. Provision of?4.06 Crore (Previous year (-) ?13.98 Crore) is outstanding based on actuarial valuation.
The total employee benefit expense for the valuation period is ? 9.59 Crore. The amount for Other ComprehensiveIncome is ? 19.03 Crore.
The actuarial assumptions include discount rate of 6.65% (Previous year 7.10%) and an average expected future periodof 7.27 years (Previous year 6.02 years). The Company recognized ? 11.34 Crore (Previous year ?11.42 Crore) forProvident Fund contributions in the Statement of Profit and Loss. The contributions payable to this plan by the Companyare at rates specified in the rules of the schemes.
EL is accrued @ 30 days per year , with 75% encashable at the option of the employee . The EL balance is accumulatedmaximum up to 300 days at any point of time .At the time of retirement or superannuation , an employee is entitled toencash the entire accumulated balance not exceeding 300 days . In case , there is a shortfall , employee is entitled toencash the HPL balance standing to his/her credit subject to total encashment not exceeding 300 days .
For period ended 31.03.2025, the Company has recognized ? 10.13 Crores (previous period: ? 8.92 Crores) in theStatement of Profit & Loss account towards earned leave as per actuarial valuation.
(3) Half Pay Leave benefit (HPL)
HPL is accrued @ 20 days for each completed year of service . There is no provision for encashment while in service .However , encashment is permissible at the time of retirement or superannuation , only to the extent there is a shortfallin his/her EL Balance subject to total encashment not exceeding 300 days .
For period ended 31.03.2025, the Company has recognized ? 0.71 Crores (previous period: ? 2.02 Crores) in theStatement of Profit & Loss account towards Half pay leave as per actuarial valuation
(4) Gratuity
(a) The Company has a defined benefit gratuity plan. Every employee is entitled to gratuity as per the provisions of thepayment of Gratuity Act, 1972. The scheme is managed by a separate trust . The company/trust has also taken up agroup insurance plan from LIC to cover the future service gratuity in the unfortunate of death while in service and thepremium paid by the Trust is funded by the Company.
(b) The Company expects to contribute ?1.33 Crore (Previous year ? 0.46 Crore) to the Gratuity Fund in the nextFinancial Year. The weighted average duration of the defined benefit obligation as at 31st March, 2025 is 4.62 years(Previous year 5.91 years).
(5) PRMB
(a) Under PRMB, the company provides medical coverage to retired employees and their eligible dependent spouse.For period ended 31.03.2025, the Company has recognized ? 24.36 Crores (previous period: ? 41.76 Crores) in theStatement of Profit & Loss account towards PRMB as per actuarial valuation
(b) The weighted average duration of the defined benefit obligation as at 31st March, 2025 is 22.7 years (Previous year20.78 years).
(6) Long service Award
The Company recognizes the contribution of its employee for long service rendered by them through long service awardscheme. The scheme provides for payment of ? 5000 , ? 15000 & ? 21000 for completing 10 years , 20 years & 30years old service .Further , at the time of superannuation , after completion of 20 years of continuous service , the em¬ployee is entitled to receive ? 1,000 per year of each completed year of service .
During the period ended 31.03.2025, the Company has provided / recognized liability in the financial statement towardsthe long service award ? 1.37 Crores (previous period: ? 1.39 Crores).
(7) Retirement Gift
At the time of retirement of employees, company provides retirement gift to employee as per policy framed for thispurpose. Presently , nominal amount of ? 7,500 payable on retirement to retired employees.
During the period ended 31.03.2025, the Company has provided / recognized liability in the financial statement towardsthe retirement Gift ? 0.22 Crores (previous period: ? 0.23 Crores).
The summarized position of various defined benefit schemes recognized in the Statement of Profit & Loss, BalanceSheet Other Comprehensive Income (OCI) and other disclosures are as under:
RBI was requested vide letter dated 8th March, 2021 to grant six months' time for transition to NBFC and to retain thestatus of HFC and to continue operations with the special dispensations/ relaxations given earlier with regard to creditconcentration norms/ exposure norms permitted by NHB/ RBI.
In response to HUDCO's request, RBI vide letter dated 26th March, 2021 and 27th September, 2021 granted time till31st December, 2021 to submit Board approved plan for conversion to NBFC. RBI further advised that the exemptionsfrom concentration/exposure norms granted previously by NHB/RBI would continue to apply at present subject to theconditions specified while granting such exemptions.
The proposal for transition of HUDCO from its present status of HFC to NBFC - IFC was approved in principle by theHUDCO Board in its meeting held on 28th December, 2021. Thereafter, HUDCO obtained approval from Ministry ofHousing and Urban Affairs for the conversion before submission of application form to RBI.
RBI was requested vide letter dated 28th December, 2021 to grant three months' time for submission of application toRBI and to retain the status of HFC. RBI vide letter dated 31st December, 2021 granted time till 31st March, 2022 forconversion from HFC to NBFC-IFC.
HUDCO had submitted application to RBI on 29th March, 2022 for conversion of Certificate of Registration (CoR) fromNBFC- Housing Finance Company (HFC) to NBFC-Infrastructure Finance Company (IFC). In reference thereof, RBIvide letter dated 22nd December, 2022 expressed its inability to accede to HUDCO's request for conversion of theCertificate of Registration (CoR) to an NBFC-IFC stating that HUDCO is not meeting the criterion specified for NBFC-IFC at Para 3 (xvi)(a) of the Master Direction-Non-Banking Financial Company Systemically Important Non-DepositTaking Company and Deposit Taking Company (Reserve Bank) Directions, 2016.
After detailed deliberation and ensuring compliance with the RBI Master Directions for NBFCs, HUDCO resubmittedthe application with necessary documents to RBI for conversion of certificate as NBFC-IFC on 22nd February, 2023.RBI vide letter dated 25th October, 2023 expressed its inability to consider HUDCO's request stating that HUDCO is notmeeting the criterion specified for NBFC- IFC at Para 3 (xvi)(a) of the Master Direction-Non-Banking Financial CompanySystemically Important Non-Deposit Taking Company and Deposit Taking Company (Reserve Bank) Directions, 2016i.e. minimum criteria of 75% of its total assets deployed in infrastructure Loans.
Consequent to that, HUDCO's senior management team convened a meeting with RBI officials for consideration of thematter of registration of HUDCO as NBFC-IFC. During the meeting a comprehensive presentation was delivered toaddress RBI's concerns & queries. Additionally, a detailed roadmap outlining the attainment of infrastructure portfolio byMarch 2026 was shared with RBI to expedite the conversion process.
Based on the submissions made by the Company, RBI has decided to process our request for conversion of CoR onmerit. In this regard, the Company has been advised to submit the application for conversion of CoR along with all latestdocuments, a statutory auditor certificate indicating position of infrastructure portfolio as on 31st March, 2024 and revisedroadmap to achieve the Principal Business Criteria (PBC).
As advised by RBI, the Company submitted the application form along with necessary documents including revisedroadmap to RBI on 9th May, 2024 for registration of HUDCO as NBFC-IFC.
RBI had requested for various additional details/documents and clarifications. In response, HUDCO submitted all thedesired details/documents/clarifications as and when required.
RBI issued Certificate of Registration (CoR) dated 23rd August, 2024 as an NBFC-IFC, pursuant to the company'sapplication to RBI for conversion of Certificate of Registration (CoR) from NBFC- Housing Finance Company (HFC) toNBFC-Infrastructure Finance Company (IFC).
HUDCO was functioning as HFC under NHB regulations and in accordance to the relaxations permitted by NHB till 28thAugust, 2024. However, from 29th August, 2024 HUDCO is registered as NBFC-IFC with RBI. Accordingly, HUDCO iscomplying with credit concentration norms in accordance to RBI regulations
NHB, from time to time, has given certain relaxations from credit concentration norms considering the role envisagedfor HUDCO. However, vide its letter No. NHB(ND)/ DRS/ SUP/ 3911/2018 dated 2nd April, 2018, NHB capped the creditconcentration (Exposure) limit for Government/Public agencies as follows:
a. The individual exposure limit of HUDCO to Government/Public Agencies (inclusive of the exposure limit of upto 30% forinfrastructure/ non-housing related activities) shall be capped at 50% of its NOF.
b. The exposure limit of HUDCO for State Government (under group exposure) shall be capped at 150% of its NOFin respect of State of Telangana and 100% of NOF for all other States. HUDCO is required to take suitable steps tobring down the group exposure in respect of State of Telangana also to 100% within a maximum period of 3 years Theconditions relating to compliance by the concerned State with the FRBM limits shall continue to be ensured by HUDCO.
c. The Board of Directors of HUDCO in its 594th meeting held on 19th April, 2018 considered above and directed that “NHBbe again requested to expeditiously review its decision communicated vide its letter dated 2nd April, 2018 and permitHUDCO to continue on the already approved pattern of credit concentration norms communicated by NHB vide itsletters from time to time”.
NHB vide its letter no. NHB(ND)/DRS/SUP/7085/2018 dated 13th July, 2018 conveyed its decision to allow HUDCO tocontinue its disbursals as per the schedule in relation to the existing sanctions made upto 31st May, 2018. However,HUDCO shall be required to take suitable steps to bring down the exposure to Government/Public Agencies and StateGovernments (under group exposure) in the above cases also to 50% and 100% respectively latest by March, 2023.
The exposure limits of upto 50% for Government/Public Agencies (inclusive of the exposure limit of upto 30% forinfrastructure/non-housing related activities) and upto 100% for State Governments (under group exposure) will continueto be applicable in all other cases. The condition relating to compliance by the concerned State with the FRBM limitsshall continue.
HUDCO vide letter dated 6th March, 2019 requested NHB seeking relaxation in the individual/ group exposure norms.Further, HUDCO also sought exemption from exposure norms for funding of PMAY (U) programme through ExtraBudgetary Resources (EBRs).
NHB vide its letter no. NHB(ND)/DRS/SUP/879/2019 dated 8th March, 2019 granted relaxation in credit concentrationnorms (under individual borrower exposure to Government /public agency) to HUDCO to extend loan upto ?20,000Crore to BMTPC under the PMAY-U subject to the condition that demand under Credit Linked Subsidiary Scheme(CLSS) is met on priority while utilizing funds lent to BMTPC.
NHB vide its letter no. NHB(ND)/DRS/SUP/880/2019 dated 8th March, 2019 granted relaxation to HUDCO in respectof credit concentration (exposure) norms upto 140%, 175% and 120% of the NOF in respect of the State of AndhraPradesh, Telangana and Uttar Pradesh respectively (under group exposure) and upto 55% (under individual exposure)each in case of APTIDCO and HMWSSB subject to the following conditions:
(i) HUDCO shall continue to ensure that the extended exposures (beyond 50% and 100% respectively) are guaranteed bythe State Government(s) and HUDCO will cease to extend further exposure to these states if FRBM limits are breached.
(ii) HUDCO shall also be required to bring down its exposure to 50% in respect of individual exposure and 100% inrespect of group exposure latest by 31st March, 2023, in accordance with the roadmap for graded reduction in exposureapproved by Board of Directors.
(iii) The position should be reviewed by the Board of HUDCO on a six-monthly basis to ensure strict adherence to the Boardapproved exposure reduction plan.
(iv) In the event of HUDCO failing to comply with the above exposure reduction plan, HUDCO will be required to assign riskweight of 100% on the excess exposure in addition to any regulatory penalty as may be applied by the NHB.
The exposure limit of up-to 50% for Govt./Public agencies (inclusive of the exposure limit of up-to 30% for infrastructure/Non housing related activities) and up-to 100% for State Govt. (under group exposure) will continue to be applicable inall other cases.
RBI has vide its letter no 1736/3.10.136/2019-20 dated 5th March, 2020 granted relaxation of credit concentration normsfor exposure to Telangana State Housing Corporation Limited (TSHCL) upto 75% of Net Owned Fund of HUDCOsubject to following conditions:
(i) The additional exposure is backed by explicit guarantee from State Government.
(ii) The exposure to TSHCL will be brought down to 50% of NOF by 31st March, 2023 as prescribed by NHB (ND)/DRS/SUP/880/2019 letter dated 8th March, 2019. A detailed action plan to this effect may be forwarded to NHB.
(iii) Other conditions as prescribed by NHB vide their above-mentioned letter dated 8th March, 2019 are adhered to.
RBI vide their letter dated 26th March, 2021 has permitted that the exemptions from concentration/exposurenorms granted previously by NHB/RBI would continue to apply at present subject to the conditions specified whilegranting such exemptions. However, a review shall be undertaken at the time of conversion to NBFC.
As discussed above HUDCO was given the time limit to bring down exposure upto 50% in respect of individual exposureand upto 100% for State Governments (under group exposure) by March 2023. In compliance with the same HUDCOhas brought down the exposure to 50% in respect of individual exposure and upto 100% for State Governments (undergroup exposure) as on March 31, 2023 in respect of all states.
RBI has issued Master Direction on Scale Based Regulation, 2023 which also states Credit Concentration Normsapplicable to NBFC-Middle Layer (HUDCO being a govt. owned NBFC falls under middle layers). RBI's creditconcentration norms state that a NBFC-IFC shall not have exposure (credit/investment taken together) exceeding 30%of its Tier 1 capital to a single party and 50% of its Tier 1 capital to a single group of parties.
RBI has issued Circular No. RBI/DOR.CRE.REC.70/21.01.003/2023-24/112 dated January 15, 2024 on Credit/investment Concentration Norms- Credit Risk Transfer. As per the Circular, the following shall be offset/kept outside thepurview of the computation of exposure:
a. Cash Margin/caution money/security deposit held as collateral on behalf of the borrower against the advances forwhich right to setoff is available;
b. Central Government guaranteed claims which attract 0 % risk weight for capital computation;
c. State Government guaranteed claims which attract 20 % risk weight for capital computation.
Currently, HUDCO is computing exposure and complying with credit concentration norms as per RBI Circular No. RBI/DOR.CRE.REC.70/21.01.003/2023-24/112 dated January 15, 2024 on Credit/investment Concentration Norms- CreditRisk Transfer above relaxations /circulars.
19) The Company is engaged in the business of providing loans/finance for Housing/ Infrastructure projects and all otheractivities of the Company revolve around the main business within India. Accordingly, the company does not haveseparate reportable segments in terms of Indian Accounting Standard (Ind AS-108) on “Operating Segments”.
20) (i) The company has tested Impairment on assets in detail as per Ind-As 36 and as a result of assessment/testing, thereis no Impairment of Assets during the Financial Year 2024-25.
(ii) Vide gazette notification no. 26/2019 dated 20th March, 2019, the Company was notified for the purposes of Section194A(3)(iii)(f) of the Income Tax Act, 1961 for non-deduction of Tax at source.
21) HUDCO had discontinued accepting / renewing Public Deposit under the Public Deposit Scheme w.e.f. 1st July, 2019,no fresh deposits were accepted/renewed by HUDCO thereafter. Deposits of Rs.0.04 Crore were matured/paid to 4depositors in the Financial Year 2024-25. Accordingly, the outstanding amount under HUDCO Public Deposit Schemewas NIL as on 31st March, 2025 except Unclaimed amount under HUDCO Public Deposit Scheme.
22) The company, while raising resources, is incurring expenses of recurring nature such as debenture trusteeship fees,listing fees to stock exchanges, custodian charges to depositories, R&T Charges etc., which are not amortized overlife of resource raised. The aforesaid expenses are charged to Statement of Profit and Loss under the Head “Fees andCommission Expense.”
23) HUDCO had invested an amount of Rs.50 Crore in “IIFCL Mutual Fund Infrastructure Debt Fund Series-1” in FY 2013¬14, which constitute 16.67% of total holding of the fund. IIFCL Mutual Fund has prematurely closed/winded up theaforesaid scheme due to its inability to comply with SEBI guidelines due to high compliance cost given the small sizeof fund. The return on investment is of around 4% since inception, which is very low when compared to market return.The redemption amount of Rs.75.72 Crore was remitted in the month of Sept.2023 based on realised investments.Further “IIFCL Mutual Fund Infrastructure Debt Fund Series-1” in meeting dated 15.03.2023 had decided with requisitemajority, that future realisation from illiquid Investments, if any shall be distributed after discharge of all the liabilities andexpenses, to the respective Unit holder(s), in proportion to their interest in the assets of the scheme. Accordingly, anamount of Rs.10.93 Crore was received by HUDCO in March 2024, and Rs.0.63 Crores was received in the month ofNovember, 2024 on account of realisation by IIFCL Mutual Fund with an aggregate realization amounting to Rs.87.28Crore.
25) During the year ended 31st March 2025, the Company has raised funds through issue of listed non-convertible debtsecurity on private placement basis. The issue proceeds of non-convertible debt securities issued during the period,have been fully utilized for the purpose(s)/ objects stated in the offer documents/ Information memorandum and therehas been no deviation / variation in the use of proceeds of non-convertible debt securities from the objects stated inthe offer documents/ Information memorandum. Further, there has been no default in repayment of debt securities,borrowings and other liabilities and the Company has met all its debt servicing obligations, both towards principal andinterest, during the period in a timely manner.
26) The Company makes full provision on doubtful debtors/ receivables which are outstanding for more than three years.
27) The Company has taken various office premises on cancellable operating lease basis with an option to renew the leaseby mutual consent on mutually agreeable terms. The aggregate lease rentals payable is charged as “Office Rent underNote No. 32- Other Expenses” of the Statement of Profit & Loss. Further, there is no financial lease as Company'sleasing arrangement does not transfer substantially all risks & rewards incidental to the ownership of an asset.
28) During the year under review, a provision for bad and doubtful debts under section 36(1)(viia), of Income Tax Act 1961equivalent to 5% of the taxable income (after allowing deduction u/s 36(1)(viii)), totaling to ? 135.00 Crore has beencreated.
29) (a) The company has declared an interim dividend-I of ?410.39 Crore @ ?2.05 per Share of ?10/- each, to itsshareholders, during the Financial Year 2024-25 after approval of Board of Directors in its meeting held on 22nd January2025. The same has been paid to shareholders within prescribed timelines.
(b) The company has declared an interim dividend-II of ?210.20 Crore @ ?1.05 per Share of ?10/- each, to itsshareholders, during the FY 2024-25 after approval of Board of Directors in its meeting held on 10th March 2025. Thesame has been paid to shareholders within prescribed timelines.
(c) The Board of Directors at its meeting held on 7th May, 2025 has recommended a Final Dividend of ?1.05 per Shareper share of ?10/- each, which is subject to approval of shareholders at the ensuing Annual General Meeting.
The company has decided to exit Signa Infrastructure India Ltd. With Marg Construction Ltd. In pursuance of the Board'sapproval, the valuer was appointed by the Associate Company i.e., SIIL and indicated the value of the shares (Rs.10each) at Rs.76.22 per share. HUDCO has made an offer to the Associate Partner to purchase HUDCO shares in SIIL.The company has not responded to HUDCO offer. The board of HUDCO was updated of the latest status and HUDCOBoard in its meeting held on 19th December, 2019 decided that steps be taken for termination of joint venture agreementwith M/s. Marg construction Ltd. (Promoter of Signa Infrastructure India Ltd) & withdrawal of HUDCO Nominee Director,in pursuance of Board Decision, HUDCO Nominee Director had submitted his resignation to the Company. In subsequentdiscussion held with Parent Co.-Marg Limited, HUDCO has requested for submission of concrete proposal for exit ofHUDCO. Reply is awaited from Parent Co.-Marg Limited.
(b) Pragati Social Infrastructure & Development Ltd.
HUDCO has decided to exit from Pragati Social Infrastructure & Development Ltd.-PSIDL. PSIDL is not providing anyfinancial information for the purpose of valuation of shares because of court injunction. HUDCO has filed a Petition u/s 397& 398 of the Companies Act 1956 before National Company Law Tribunal (NCLT) for oppression and mismanagementof operations, against Pragati Social Infrastructure & Development Limited (PSIDL) and others which is pending for finalhearing.
(c) Shristi Urban Infrastructure Development Ltd.
The company had decided to exit from Shristi Urban Infrastructure Development Ltd.-SUIDL with Shristi infrastructureDevelopment Corporation Ltd. In this regard, the underlying assets i.e., SARGA Udaipur Hotels and Resorts Pvt.Ltd. (Being subsidiary of Shristi Urban Infrastructure Development Ltd.-SUIDL) has voluntarily approached NCLT forInsolvency Proceedings which is underway, resulting in non-availability of authentic data for valuation of AssociateCompany.
The company had decided to exit from Ind Bank Housing Limited. The Company had invested Rs.2.50 Crore in theshares of the Ind bank Housing Ltd. (IBHL) more than 30 years back. Considering the fact that IBHL has highly negativeNet Worth and meagre volume of trading in the share of the company, even though market price of the share as on31st March, 2025 is 39.57 per share (previous year Rs.46.61 per share), HUDCO continues to reflect the investmentof Rs.2.50 Crore in IBHL at diminished value of Rs.1 only as on 31st March, 2025. Besides RBI vide letter dated 10thOctober 2023 has informed that CoR granted by NHB to IBHL has been cancelled vide order dated 21st September 2023hence no longer an HFC.
(a) Associates
(1) Shristi Urban Infrastructure Development Ltd.
(2) Pragati Social Infrastructure & Development Ltd.
(3) Signa Infrastructure India Ltd.
(4) Indbank Housing Ltd.
2. The statement of loans / advances given to Key Managerial Personnel for the Quarter ended 31st March, 2025 isgiven below:
i) Shri Sanjay Kulshrestha, CMD, joined HUDCO on 16th October, 2023. He has taken Festival advance for Rs.2,00,000/- and Welfare Advance for Rs. 2,00,000/- during the period ending 31st March, 2025. An amount of Rs.83,331/- is outstanding towards Festival Advance and Rs. 1,66,053/- is outstanding towards Welfare Advanceincluding interest of Rs. 4,945/- as on 31.03.2025.
ii) Shri M. Nagaraj, joined as DCP HUDCO on 1st February, 2019. He has not taken any advance during the quarter.There is no outstanding towards advances as on 31.03.2025.
iii) Shri Daljeet Singh Khatri, joined as DF HUDCO on 14th August, 2024 and taken charge of CFO on 25.09.2024.He has not taken any advance during the quarter. There is no outstanding towards advances as on 31.03.2025.
iv) Shri D. Guhan, Ex Director Finance, superannuated on 31.05.2024. There was nothing outstanding towardsadvances.
v) Smt. Reva Sethi, was CFO w.e.f. 28.06.2024 to 25.09.2024. She has not taken any advance during the quarter.She has superannuated on 30.11.2024 and there is no outstanding towards advances as on 31.03.2025.
vi) Shri LVS Sudhakar Babu, was KMP w.e.f. 22.01.2025 to 31.03.2025. He has not taken any advance during thisperiod. An amount of Rs.1,04,760/- is outstanding towards Festival Advance and Rs. 23,375/- is outstandingtowards Welfare Advance including interest of Rs. 12,279/- and HBA Interest outstanding of Rs. 5,14,713/- as on31.03.2025.
vii) Shri Vikas Goyal, Company Secretary joined HUDCO on 16th February, 2024 and took charge from 26th February,2024 as Company Secretary. He has not taken any advance during the quarter. There is no outstanding towardsadvances as on 31.03.2025.
3. Total Liabilities has been computed as sum of all financial and non-financial liabilities (extracted from the limitedreviewed Standalone Financial Statements prepared as per IND-AS for the period ended 31.03.2025) and doesnot include equities and Reserve & Surplus.
4. “Public Funds” are as defined in Master Directions- Non-Banking Financial Company -Systemically ImportantNon-Deposit taking Company and Deposit taking Company (Reserve Bank) Directions, 2016, which states that“Public funds” includes funds raised either directly or indirectly through public deposits, inter-corporate deposits,bank finance and all funds received from outside sources such as funds raised by issue of Commercial Papers,debentures etc. but excludes funds raised by issue of instruments compulsorily convertible into equity shareswithin a period not exceeding 5 years from the date of issue.
5. The information stated in this disclosure is based on limited reviewed Standalone Financial Statements (preparedas per IND-AS) for the period ended 31.03.2025.
42) Disclosure on Liquidity Coverage RatioQualitative Disclosure
HUDCO has implemented an integrated risk management approach through which it reviews and assesses significantrisks on a regular basis to ensure that there is a robust system of risk controls and mitigation in place. HUDCO has awell-structured robust Risk Management Policy and Operating Manual in line with its objectives to address the variousrisks.
In compliance with the SEBI (LODR) Regulations, 2015, HUDCO has in place a Board level Committee under thenomenclature 'Risk Management Committee' (RMC) headed by a member of the Board of Directors, which reviewsvarious decisions/recommendations of the two (2) sub-committees namely:
• Credit & Operational Risk Management Sub-Committee (CORMSC);
• Assets Liabilities Management Sub-Committee (ALCO);
The Risk Management Committee (RMC), which is a committee of the Board, that ensures risks are effectively managedand aligned. The ALCO is responsible for ensuring adherence to the liquidity risk tolerance/limits set out in the boardapproved Risk Management policy. The role of the ALCO with respect to liquidity risk includes, inter alia, decision ondesired maturity profile for assets & liabilities, responsibilities and controls for managing liquidity risk, and overseeingthe liquidity position of the company.
Management regularly reviews the position of cash and cash equivalents by aligning the same with the projectedmaturity of financial assets and financial liabilities, economic environment, liquidity position in the financial market,anticipated pipeline of future borrowing & future liabilities and threshold of minimum liquidity defined in the ALM policywith additional liquidity buffers as management overlay.
Quantitative Disclosure
Liquidity Coverage Ratio (LCR) aims to promote resilience of NBFCs to potential liquidity disruptions by ensuring thatthey have sufficient unencumbered High Quality Liquid Asset (HQLA) to survive any acute liquidity stress scenariolasting for 30 days.
“HQLA” means liquid assets that can be readily sold or immediately converted into cash at little or no loss of valueor used as collateral to obtain funds in a range of stress scenarios. “Unencumbered” means free of legal, regulatory,contractual or other restrictions on the ability of the NBFC to liquidate, sell, transfer or assign the asset. Assets to beincluded in the computation of HQLAs are those that the NBFC is holding on the first day of the stress period. Suchassets shall be valued at an amount not greater than their current market value for the purpose of computing theLCR. Depending upon the nature of assets, they have been assigned different haircuts, which are to be applied whilecalculating the HQLA for the purpose of calculation of LCR.
Liquidity Coverage Ratio (LCR) is represented by the following ratio:
In order to determine Net Cash Outflows, the Company considers total expected cash outflow minus total expected cashinflows for the subsequent 30 calendar days by assigning a predefined stress percentage to the overall cash inflows andcash outflows. Total expected cash outflows (stressed outflows) are calculated by multiplying the outstanding balancesof various categories or types of liabilities and off-balance sheet commitments by 115% (15% being the rate at whichthey are expected to run off further or be drawn down). Total expected cash inflows (stressed inflows) are calculatedby multiplying the outstanding balances of various categories of contractual receivables by 75% (25% being the rate atwhich they are expected to under-flow). However, total cash inflows will be subjected to an aggregate cap of 75% of totalexpected cash outflows. In other words:
Total Net Cash Outflows over the next 30 days = Stressed Outflows - Lower of (Stressed Inflows or 75% of StressedOutflows).
The Company computes the LCR and reports the same to the Asset Liability Management Committee (ALCO) everymonth for review and approval.
The Company was registered as a Housing Finance Company (HFC) until August 23, 2024, and complied with therequirements of the RBI Master Direction - Non-Banking Financial Company - Housing Finance Company (ReserveBank) Directions, 2021, dated February 17, 2021. As per these Directions, all non-deposit taking HFCs with an assetsize of ?10,000 Crore and above, and all deposit-taking HFCs irrespective of asset size, are required to maintain aminimum Liquidity Coverage Ratio (LCR) of 70% from December 1,2023.
Subsequently, the Company was granted a Certificate of Registration (CoR) as a Non-Banking Financial Company -Infrastructure Finance Company (NBFC-IFC) in August 2024. As an NBFC-IFC, the Company is now governed by theRBI Master Direction - Reserve Bank of India (Non-Banking Financial Company - Scale Based Regulation) Directions,2023, dated October 19, 2023. Under paragraph 3.3 of these Directions, all non-deposit taking NBFCs with asset sizeof ?10,000 Crore and above, and all deposit-taking NBFCs, are required to maintain a minimum LCR of 85% fromDecember 1, 2023, and 100% from December 1, 2024.
In accordance with the applicable regulatory framework during each period, the Company has maintained the followingLCR levels:
• 70% from December 1, 2023, to August 28, 2024, as an HFC;
• 85% from August 29, 2024, to November 30, 2024, as an NBFC-IFC; and
• 100% from December 1, 2024, onwards, as an NBFC-IFC.
The Company has invested in High Quality Liquid Assets (HQLAs) in line with the relevant regulatory requirements and,in the opinion of the management, maintains adequate liquidity buffers to meet foreseeable short-term obligations
I. No proceedings have been initiated or pending against the Company for holding any benami property under theBenami Transactions (Prohibitions) Act, 1988 (45 of 1988) and the rules made there under, as at March 31, 2025and March 31, 2024.
II. The Company is not a declared willful defaulter by any bank or financial Institution or other lender, in accordancewith the guidelines on willful defaulters issued by the Reserve Bank of India, during the year ended March 31,2025 and March 31,2024.
III. There was no delay in the registration or satisfaction of any charges with Registrar of Companies during the yearended March 31, 2025 and March 31, 2024.
IV. The company does not have any investment in any subsidiary company. Therefore, there is no requirement tocomply with the number of layers prescribed under clause (87) of section 2 of Companies Act, 2013 read withCompanies (Restriction on number of Layers) Rules, 2017.
V. The Company has not traded or invested in Crypto currency or Virtual Currency during the year ended March 31,2025 and March 31,2024
VI. There is no instance of breach of covenant of loan availed / debt securities issued.
VII. There are no undisclosed incomes that has been surrendered or disclosed as income during the year in the taxassessments under the Income Tax Act, 1961.
VIII. Analytical Ratios
a. Capital to Risk-weighted Assets Ratio: -Refer Note No. 41(40)(a)
b. Liquidity Coverage Ratio: - Refer Note No. 41(42)
49) (a) Figures of the previous year have been regrouped/ rearranged/ re-casted wherever considered necessary to make
them comparable with figures for current year.
(b) Figures in rupees have been rounded off to Crore upto two decimals except where specifically indicated.
For and on behalf of the Board
Sd/- Sd/- Sd/- Sd/-
Vikas Goyal Daljeet Singh Khatri M. Nagaraj Sanjay Kulshrestha
Company Secretary Director Finance & Chief Financial Officer Director Corporate Planning Chairman & Managing Director(FCS 6671) (DIN 06630234) (DIN 05184848) (DIN 06428038)
As per our separate report of even date attachedFor S A R C & AssociatesChartered AccountantsFRN- 006085N
Sd/-
Kamal Aggarwal
Place: Mumbai Partner
Date: 7th May, 2025 M. No.- 090129