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You can view the entire text of Notes to accounts of the company for the latest year

BSE: 540530ISIN: INE031A01017INDUSTRY: Finance - Term Lending Institutions

BSE   ` 224.50   Open: 229.90   Today's Range 223.35
231.95
-4.15 ( -1.85 %) Prev Close: 228.65 52 Week Range 49.05
242.70
Year End :2023-03 

NOTE: 10(a)(3) Impairment assessment

The references below show where the Company's impairment assessment and measurement approach is set out in these notes. 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.

NOTE: 10(a)(4)(i) Definition of default

The Company considers a financial instrument as defaulted and considered it as Stage 3 (credit-impaired) for ECL calculations in all cases, when the borrower becomes 90 days past due on its contractual payments.

NOTE: 10(a)(4)(ii) Probability of default

The 12 month probability of default is calculated using incremental NPA approach.

NOTE: 10(a)(4)(iii) Exposure at default

The exposure at default (EAD) represents the gross carrying amount of the financial instruments subject to the impairment calculation, addressing both the client's ability to increase its exposure while approaching default and potential early repayments too.

To calculate the EAD for a Stage 1 loan, the Company assesses the possible default events within 12 months for the calculation of the 12mECL. For Stage 2 and Stage 3 financial assets, the exposure at default is considered for events over the lifetime of the instruments.

NOTE: 10(a)(4)(iv) Loss given default

The Company segments its lending products into smaller homogeneous portfolios (Government - Housing,Government -Urban Infrastructure,Non Government and Retail), based on key characteristics that are relevant to the estimation of future cash flows. The data applied is collected loss data and involves a wider set of transaction characteristics (e.g., product type) as well as borrower characteristics.

NOTE: 10(a)(4)(v) Significant increase in credit risk

The Company continuously monitors all assets subject to ECLs. In order to determine whether an instrument or a portfolio of instruments is subject to 12mECL or life time ECL, the Company assesses whether there has been a significant increase in credit risk since initial recognition. The Company considers an exposure to have significantly increased in credit risk when contractual 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 for assessing whether there has been a significant increase in credit risk since initial recognition.

NOTE: 10(a)(4)(vi) Grouping financial assets measured on a collective basis

As explained in Note 4.17, the Company calculates ECLs on collective or individual basis .

The Company calculates ECLs on collective basis on following asset classes:

- Government - Housing

- Government - Urban Infrastructure

- Non Government

- Retail

The Company calculates ECLs on individual basis on all Stage 3 assets of Non Government portfolio.

Note 24 (b) Rights attached to Equity Shares :

The shareholders of the Company are entitled to receive dividend as and when declared by the company and enjoy proportionate voting rights in case any resolution is put to vote. Further, the shareholders have all such rights, as may be available to the shareholders of a listed company, under the Companies Act, 2013 and rules made thereunder, SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 and Memorandum of Association and Articles of Association of the Company.

NOTE 34: Capital

Capital Management

For the purpose of the Company's capital management, capital includes issued equity capital, share premium and all other equity reserves attributable to the equity holders of the Company. The primary objectives of the Company's capital management are safety and security of share capital and maximize the shareholder wealth.

The Company maintains an actively managed capital base to cover risks inherent in the business and is meeting the capital adequacy requirements of the regulator Viz., RBI/NHB. The adequacy of the Company's capital is monitored using, among other measures, the regulations issued by RBI/NHB.

Company has complied in full with all its externally imposed capital requirements over the reported period.

Capital to Risk-weighted Assets Ratio

The Company is complying with the Capital Adequacy requirements as prescribed by the National Housing Bank. Being an NBFC - Housing Finance Company (NBFC-HFC), HUDCO is required to maintain a 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 Risk Weighted Assets.

NOTE 36: Fair Value Measurement

36.1. Valuation principles

Fair value is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction in the principal (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 of valuation techniques.

36.2. Valuation governance

The Company's fair value methodology and the governance over its models include a number of controls and other procedures to ensure enough safeguards and maintain its quality and adequacy. All new product initiatives (including their valuation methodologies) are as per the approved policy of the Company. The ongoing measurement on fair value estimates is reviewed by the appropriate functional department of the Risk management and related finance functions.

36.3. Assets and liabilities by fair value hierarchy

The following table shows an analysis of financial instruments recorded at fair value by the level of the fair value hierarchy:

36.4. Valuation techniques Mutual fund

Mutual funds are valued at the net asset value (NAV) declared by the mutual fund in respect of each particular 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 are available. Such instruments are classified as Level 2. Other equity instruments are fair valued based on the average of the discounted cash flow method and Net assets value (as provided by independent valuer). It is classified 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 contract using present value calculations by estimating future cash flows and discounting them with the appropriate yield curves incorporating 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 investment property 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 in Level 2 (refer 14A).

36.5. Valuation adjustments and other inputs and considerations Credit Valuation Adjustments (CVA)

The Company calculates CVA on a counterparty basis over the entire life of the exposure.

The Company applies CVA to all relevant (not fully collateralised) over-the-counter positions with the exception of positions settled through central clearing houses. Based on regular assessment of the extent of the adjustments, the Company concluded that these adjustments were not significant to the levelling classification of the relevant instruments in 2022-23 and 2021-22.

36.7. Transfer between level 1 and level 2

There have been no transfers between Level 1 and Level 2 for the year ended 31st March, 2022 and 31st March,2023.

36.8. Movements in Level 3 financial instruments measured at fair value

The following tables show a reconciliation of the opening and closing amounts of Level 3 financial assets and liabilities which are recorded at fair value. The Company requires significant unobservable inputs to calculate their fair value.

36.9. Key assumptions and range of inputs

(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 and the 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 financial instruments 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 flow as on 31st March, 2023 is taken.

The range of values indicates the highest and lowest level input used in the valuation technique and, as such, only reflects the characteristics of the instruments as opposed to the level of uncertainty to their valuation.

All changes in the fair market value would be reflected in the Statement of profit and loss based on the classification FVTPL.

The table summarises the valuation techniques together with the significant unobservable inputs used to calculate the fair value of the Company's Level 3 assets and liabilities.

36.10. Quantitative analysis of significant unobservable inputs Interest rate volatility

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 rate volatility varies from time to time and therefore, it is not viable to make reliable and meaningful general statements about volatility levels.

Discount Rates

Discount rates are used for calculating the present value of future cash flows. In discounted cash flow models, discount rates are used as the direct reflection of the expected rate of return of the investments made by the company in the due course of the business. Hence, these rates reflect the net present value of an asset. They generally reflect the premium an investor expects to achieve over the benchmark interest rate to compensate for the higher risk driven by the uncertainty of the cash flows caused by the credit quality of the asset. They can be implied from market prices and are 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 plays an important role to ascertain the recovery rates. Higher loss severity levels / lower recovery rates indicate lower expected cash flows upon the default of the instruments. Recovery rates for complex, less liquid instruments are usually unobservable 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 to as Sales, Turnover, or Income) forms the beginning of a company's Income Statement and often considered the “Top Line” of a business. Growth in revenue from operation directly impacts the profitability of the company, as operation expenses are deducted from a company's revenue to arrive at its profit.

36.11. Sensitivity of fair value measurements to changes in unobservable market data

Sensitivity of fair value measurements to changes in unobservable market data cannot be ascertained due to potential off-sets from economic or accounting hedge relationships in place.

36.12. Fair value of financial instruments not measured at fair value

Set out a comparison, by class, of the carrying amounts and fair values of the Company's financial instruments that are not carried at fair value in the financial statements. This table does not include the fair values of non-financial assets and nonfinancial liabilities.

36.12.1. Valuation Methodology of financial instruments not measured at fair value

Below are the methodologies and assumptions used to determine fair values for the above financial instruments which are not recorded and measured at fair value in the Company's financial statements. These fair values were calculated for disclosure purposes only. The below methodologies and assumptions relate only to the instruments in the above tables and, as such, may differ from the techniques and assumptions explained in Note 36.4.

Short-term financial assets and liabilities

For financial assets and financial liabilities, that have a short-term maturity (less than twelve months), the carrying amounts, which are net of impairment, are a reasonable approximation of their fair value. Such instruments include: cash and cash equivalents, Trade receivables, bank balances other than cash and cash equivalents and trade payables without a specific maturity.

Loans and advances to customers

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.

Debt Securities

Fair value of traded bonds is market price of the bonds as on the balance sheet date or close to balance sheet date. In case of Commercial Paper which is Current Liability i.e., short term maturity (less than or equal to twelve months), the face 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 as fair values, since these are reasonable approximation of their fair value.

37. RISK MANAGEMENT

37.1. Introduction and risk management structure

The Company, being a Housing Finance Company, is exposed to various types of risks like credit risk, operational risk, liquidity risk, market risk and foreign currency risk. Company is fully committed to manage these risks in an effective and proactive manner, for which HUDCO has in place a Risk Management Policy and Operating Manual in line with its objectives covering both the internal and external environment. With a view to minimize the impact of various risks to which Company is exposed to, Company has in place a Board level Committee namely ‘Risk Management Committee of the Board'(RMCB) which reviews various suggestions/ recommendations/reports and action taken by three sub-committees namely:

• Assets & Liabilities Management Committee (ALCO);

• Credit Risk Management Committee (CRMC); and

• Operational Risk Management Committee (ORMC)

HUDCO has effective Assets and Liabilities Management system. ALCO reviews the risks relating to Assets and Liabilities and ensures management of mismatches through liquidity gap analysis, interest rate sensitivity analysis as per NHB guidelines. It is ensured that the ALM risks, if any, are managed within the permissible limits.

The Credit Risk Management Committee (CRMC) oversees and ensures that the institution's credit policies are complied with and the procedures are being consistently applied.

The Operational Risk Management Committee (ORMC) oversees and ensures the implementation of operational risk framework to explicitly manage each and every source of operational risk including Technology risk, Employee risk, Customer risk, Capital Asset risk and External risk.

37.2. Credit risk

For management of credit risks in an effective manner, Company has established a strong appraisal mechanism containing comprehensive appraisal techniques/ guidelines in order to ensure timely repayments of principal & interest amount

37.2.1. Derivative financial instruments

Credit risk arising from derivative financial instruments is, at any time, limited to those with positive fair values, as recorded on the balance sheet.

With gross-settled derivatives, the Company is also exposed to a settlement risk, being the risk that the company honours its obligation, but the counterparty fails to deliver the counter value.

37.2.2. Exposure to credit risk

The carrying amount of financial assets represents the maximum credit exposure. The maximum exposure to credit risk was ' 79,236.97 crore and ' 76,989.92 crore as of 31st March,2023 and 31st March, 2022 respectively, being the total of the carrying amount of balances with loans.

37.2.3. Analysis of risk concentration

HUDCO takes into consideration NHB/RBI norms for risk categorisation and the norms adopted for extending loan under HUDCO Niwas. Higher LTV is permissible for lower loan amounts while LTV reduces with the higher loan amounts. (Refer Note:10A)

To manage the liquidity risk, Company has in place an effective Asset Liability Management System. The liquidity risk is being monitored with the help of liquidity gap analysis. Further, the funds are mobilized at competitive rates through various strategies viz. bonds, public deposits, term loans etc.

The Company maintains a pool of liquid assets which represents the primary source of liquidity in stress scenarios. Its composition is subject to limits designed to reduce concentration risks which are monitored on an on-going basis.

37.4. Market risk

In order to mitigate the risks arising from fluctuations in interest rates and foreign currency exchange rates, Company periodically reviews and determines its lending rates based on its cost of funds and the market scenario. Further, the interest rate risk is being monitored with the help of interest rate sensitivity analysis under the Asset Liability Management System

The interest rate risk is being monitored with the help of interest rate sensitivity analysis under the Asset Liability Management System.

The following table demonstrates the sensitivity to a reasonably possible change in interest rates (all other variables being constant) of the Company's statement of profit and loss and equity.

The sensitivity of the statement of profit and loss is the effect of the assumed changes in interest rates on the profit or loss for a year, based on the floating rate non-trading financial assets and financial liabilities held at 31st March, 2023 and 31st March, 2022.

37.4.3. Currency risk

In order to mitigate the risks associated with Foreign Currency Fluctuations, Company has a Foreign Currency Risk Management policy.

The table below indicates the currencies to which the Company had significant exposure at the end of the reported periods. The analysis calculates the effect of a reasonably possible movement of the currency rate against the INR (all other variables being constant) on the statement of profit and loss (due to the fair value of currency sensitive monetary assets and liabilities). A negative amount in the table reflects a potential net reduction in the statement of profit and loss or equity, while a positive amount reflects a net potential increase. An equivalent decrease in each of the currencies below against the INR would have resulted in an equivalent but opposite impact.

37.4.4. Equity price risk

Equity price risk is the risk that the fair value of equities decreases as a result of changes in the level of equity indices and individual stocks. At 10 per cent increase in the value of the Company's equities at 31st March, 2023 would have increased equity by 18.58 crore. An equivalent decrease would have resulted in an equivalent but opposite impact and would cause a potential impairment, which would reduce profit before tax by approximately 18.58 crore.

In order to mitigate the operational risk(s) associated with the operations of the organization both internal as well as external including technology risk, employee risk, capital asset risk, external risk, compliance risks viz. external fraud, legal risk, etc, Company has established a strong reporting and monitoring mechanism.

Operational Risk Management framework covers managing each and every source of Operational Risk as a distinct risk to the institution's safety and soundness. The requisite information on the Operational risk is obtained through quarterly reports of ‘Operational Risk Factors and Key Risk Indicators (KRIs)' from Regional Offices/ departments which are further reviewed and analysed for mitigation of operational risk.

39. Ind AS-116 Leases-

a. Company as a Lessee

Company has lease contracts for the office building which are cancellable by the both the lessor and lessee. Company has some contracts which are cancellable by the either lessor and lessee and at present there is no estimation by the company to continue or discontinue the same, further amount of that leases is not material for the company and therefore company is not creating ROU on that asset based on the materiality as per the guidance given under the Indian accounting standard. Further company used hindsight in determining the lease term where the contract contained options to extend or terminate the lease and therefore its leases are covered under the short-term leases as per the guidance under the Ind AS-116.

Amounts recognised in Statement of Profit and Loss relating to short term leases is 1.56 crore during the year 2022-23 and in the previous year 2021-22 is 1.55 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 Investment Property. Lease Rental recognized as income during the year 2022-23 is ?54.18 Crore and in the Previous year 2021-22 is ' 49.04 crore.

1) The financial results for the Financial Year ended 31st March, 2023 have been drawn up on the basis of Ind-AS that are 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 NHB/RBI or other regulators are adopted/ implemented as and when they are issued/ applicable. The results have been prepared based on the 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 vide notification GSR (E) dated 24th March, 2021.

2) Contingent Liabilities & other commitments not provided for and counter guarantees issued by the Company:

(a) Contingent Liabilities:

(?in Crore)

Particulars

2022-23

2021-22

i.

Demand (including penalty) on account of payment of guarantee fee on SLR debentures guaranteed by Government of India

31.61

31.61

ii.

Disputed Income tax demands against which Company has gone in appeal. The Company has paid a cumulative amount up to 31st March, 2023 of 101.70 crore (previous year 179.80 crore) under protest. (This does not include un-quantified demands pertaining to interest/ penalties which may be levied after the finalization of appeals)

320.69

297.73

iii.

TDS demands as per TRACES Portal

0.05

0.12

iv.

Disputed service tax demands against which Company has gone in appeal. The Company has paid a cumulative amount upto 31st March, 2023 of 1.92 crore (previous year 114 crore) under protest. (This does not include un-quantified demands pertaining to interest/penalties which may be levied after the finalisation of appeals).

6.87

7.07

v.

Levy of Fine by Stock Exchanges (NSE & BSE) due to Non-Compliance with Corporate Governance requirements: NSE: 17,99,260/-, BSE: ?49,12,340/- for the period 30th September. 2019 to 31st December 2022

1.34

1.37

(b)

Capital commitments not provided for

(?in Crore)

Particular

2022-23

2021-22

i.

Estimated amount of commitments remaining to be executed on capital account

167.82

167.82

(c)

Finance Lease Commitments:

The finance lease commitments are in respect of properties at Plot No. A2, Sector 62, NOIDA-201309 and at Paryavas Bhawan, Bhopal

(in '

Particulars

31st March, 2023

31st March, 2022

Minimum lease payments

Present value of MLP

Minimum lease payments

Present value of MLP

Within one year

23,532

21,693*

23,532

2,206

After one year but not more than five years

-

-

23,532

2,033

Total minimum lease payments

23,532

21,693

47,064

4,239

Less amounts representing finance charges

-

-

-

-

Present value of minimum lease payments

23,532

21,693

47,064

4,239

*Present Value for the MLP @8.50% as on 31.03.2023 has been considered.

The above does not include any contingent liability in respect of Andrews Ganj Project (AGP), arising on account of various court cases/arbitration/allottees' claims against cancellation of allotment etc., as in this case, HUDCO is only working as an agent being project executed on behalf of Govt. of India. As such, liability (if any) whenever ascertained/ finalized shall be passed on to MoHUA, Govt. of India and met out of AGP (No Lien AGP Account), being maintained separately, in line with the directions of the then MoUD

3) Andrews Ganj Project

(a) (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) on the expenditure incurred on AGP along with 1.5% of project cost as administrative charges.

(iii) As per Perpetual Lease Deed dated 04th July, 1997, the Company is liable to make available “Net Resources” from the development and disposal of properties of the AGP to then MoUD and accordingly the Company was crediting interest on Net Resources generated on the project upto 03rd 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 MoUD was 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 07th September, 1995 and in terms of Perpetual Lease Deed dated 04th July, 1997, the status of the Company is “Agent of MoUD”. The contention of HUDCO is that it is working as an agent and as such total ownership rights and responsibilities of AGP are of MoHUA-GOI (erstwhile MoUD) and there is no financial liability of HUDCO in respect of AGP This has been upheld by learned Shri GE Vahanvati, the then Solicitor General of India, vide his opinion dated 12th April, 2005. This opinion was re-confirmed by learned Shri GE Vahanvati as Attorney General of India vide his opinion dated 19th August, 2009. The opinion was also duly endorsed by 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 AGP Account” being separately maintained by HUDCO. As on 31st March, 2023, this account has a deficit in the form of debit balance of ?558.97 crore, recoverable from MoHUA (erstwhile MoUD). This represents amount paid by HUDCO on behalf of the Ministry for the capital and revenue expenditures on AGP project over and above the recoveries and the accumulated interest amounting to ' 291.81 crore charged @ 10.75% p.a. (simple), on excess of expenditure over recoveries. The MoHUA (erstwhile MoUD) in a meeting held on 27th April, 2015 have also asserted that HUDCO shall continue to implement and manage the AGP in terms of Perpetual Lease Deed and all the pending issues shall be looked into for resolution by the Ministry. The MoHUA (erstwhile MoUD) in the said meeting has also decided that HUDCO as a Lessee will bear all the liabilities including the liabilities generated out of compliance of various court orders 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 correspondence as also in the meetings. A communication was received from Dy. L&DO vide letter dated 22nd March, 2016 wherein Dy. L&DO had conveyed that HUDCO may continue to implement Andrews Ganj project and manage “No Lien AGP Account” in line with the terms and conditions as stipulated in the Perpetual Lease Deed dated 04th July, 1997. The Ministry again informed in specific vide Dy L&DO letter dated 31st May, 2018 that HUDCO as a lessee is permitted to incur/book maintenance and legal expenditure in respect to Andrews Ganj Project from “No Lien AGP Account”. Like earlier years, in-line with the minutes of meeting dated 07th September, 1995, the perpetual lease deed dated 04th July, 1997, income of ' 28.51 crore on account of interest accrued on AGP Project has been credited to Statement of Profit and Loss for the period year ended 31st March, 2023.

(vii) As decided by HUDCO Board in its 596th meeting held on 14th June, 2018, Ministry of Housing and Urban affairs has been requested vide letter dated 09th July, 2018 to consider taking over the Andrews Ganj project with assets and liabilities and pay the amount incurred / to be incurred by HUDCO, towards implementing the project. It has also been conveyed that “till the project is taken over by Ministry”, HUDCO shall be continuing implementing the project as per existing arrangements and continue booking maintenance and legal expenses, interest @ 10.75% p.a. and administrative charges @1.5% in “No Lien AGP Account”. The decision on the same from the Ministry is awaited.

(viii) The company, in its aforesaid capacity as an agent of MoHUA (erstwhile MoUD), relating to AGP, is in possession of real estate properties (9 guest houses blocks and hotel site) which command much higher realizable market value sufficient to recover aforesaid amount of ' 558.97 crore, as on 31st March, 2023.

(ix) MoHUA was requested vide letter dated 13th January, 2021 to make arrangements towards reimbursement of the

amount recoverable endorsement for settling the same from the project proceeds as and when the same are realized, which is also in line with the Lease agreement and well settled and agreed.

In reply to the same, Ministry vide letter dated 10th March, 2021 has requested for certain additional information including the breakup details of principal amount and interest amount as contained in the “No Lien AGP Account” to process HUDCO's request.

Ministry vide letter dated 28 th June, 2021 has stated that the “HUDCO's proposal is under examination in consultation with IFD, MoHUA. Till the proposal of HUDCO vide their letter dated 13th January, 2021 is approved, the existing arrangement may be continued as conveyed vide this office letter dated 22nd March, 2016 and 31st May, 2018”.

(b) (i) The Company had allotted a hotel site including car parking space to M/s Tomorrowland Technologies Exports Ltd. i.e.,

TTEL (formerly known as M/s. M S Shoes East Limited). Due to default in payment of installments by TTEL, the Company cancelled the allotment of hotel site including car parking space and forfeited the amount paid by TTEL in terms of the allotment letter.

(ii) TTEL started litigation regarding hotel site and filed suit for declaration in lower courts that cancellation of allotment letter by HUDCO, be declared as null & void. The Sr. Civil Judge passed final order dated 03rd July, 2010 against HUDCO. HUDCO filed first appeal against the Order of Sr. Civil Judge Before Additional District Judge (ADJ) Delhi. The ADJ vide Order dated 18th July, 2014 dismissed the first appeal of HUDCO and passed the judgment in favour of TTEL. HUDCO filed Regular Second Appeal (RSA) with Hon'ble High Court of Delhi which passed the final judgment on 03rd July, 2016 in favour of HUDCO. TTEL challenged the High Court Order by filing SLP NO: 34338/2016 in the Hon'ble Supreme Court. The matter is currently in pendency before Hon'ble Supreme Court.

(iii) 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 installment by TTEL and amount of first installment paid by TTEL was forfeited as per terms of allotment letter. TTEL filed a civil suit for permanent injunction and possession against HUDCO & Union of India. The Hon'ble High Court, vide Order dated 10th August, 2016, directed that HUDCO &Union of India should consider the proposal given by TTEL for refund of entire amount deposited by way of 1st installment by it with HUDCO along with interest at such rate which may 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 on 23rd August, 2016 resolved to approve the proposal to refund first installment forfeited by HUDCO excluding earnest money & the interest for delayed payment paid thereof by TTEL for guest house blocks after adjusting the commercial losses caused to HUDCO and other expenses incurred by HUDCO since 1997-98 from the date of completion of project subject to necessary approval/NOC of MoUD, Govt. of India.

The Hon'ble High Court passed a decree dated 13th January, 2017 for payment of 1st installment of ?35.75 crore to TTEL along-with interest @ 6% p.a., w.e.f. 30th January, 1995 till date of payment and directed HUDCO to refund the interest paid by TTEL (?0.99 crore) on the delayed period of payment of 1stinstallment (from 30th 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 30th June, 2017.

TTEL filed Review Petition in the month of May, 2017, before Hon'ble High Court of Delhi for review of the Decree dated 13th January, 2017, praying inter-alia for refund of EMD, grant of interest @ 16.48% p.a. on quarterly rests. 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 against the Decree dated 13th January, 2017 and Hon'ble High Court Order dated 12th December, 2017. The Company filed application for recalling the Hon'ble High Court Order dated 13th January, 2017, in view of 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 in Supreme Court challenging the High Court Order dated 28th August, 2018 and 13th January, 2017. Vide Order dated 18th September, 2018, the Hon'ble Supreme Court has dismissed the SLP as withdrawn, with liberty to HUDCO to 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 by TTEL on 23rd December, 2017. Thereafter, TTEL has filed Revised Execution Petition, making Govt. of India also a party and claiming rate of interest @ 11% p.a. as per the decree dated 13th January, 2017.The matter was listed on 3rd May, 2018, wherein the Hon'ble High Court first directed for attachment of HUDCO Property i.e. HUDCO Bhawan, 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 directed that 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 to perform the terms of the Order dated 13th January, 2017 was conditional on UOI's support

and in the event, any liability 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 Execution Petition, pending in Delhi High Court. The matter was listed on 29th October, 2018. After hearing the submission of HUDCO's Counsel, the Hon'ble Court dismissed the objections. HUDCO filed two appeals in Delhi High Court as under:

(a.) Regular first Appeal (RFA 79/2018) against the final order/ decree dated 13th January, 2017 and order dated 28th August, 2018 (Dismissal of Recall application by High Court). Notices have been issued.

(b.) Execution First Appeal (EFA No 19/2018) against the order dated 29th October, 2018, wherein objections of HUDCO in execution petition were dismissed. The matter was listed on 27th November, 2018. After hearing the matter, the Hon'ble Court stayed the execution proceeding pending in Delhi High Court till the next date. The matter was listed again on the application of the M/s TTEL for vacation of stay on 08th July, 2020 before Division Bench, 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 (RFA 79/2018). 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 High Court stayed the execution proceedings. However, the same has been withdrawn by TTEL on 14th January, 2019.

TTEL has filed Special Leave Petition (SLP No 10752/53 of 2018) in Supreme Court against Decree dated 13th January, 2017 and Hon'ble High Court Order dated 12thDecember,2017. The SLP filed by TTEL is currently pending in Hon'ble Supreme Court. Further, in the SLP No 10752/53 of 2018, the Union of India has filed an affidavit denying its liability on this account. The said affidavit, was placed before the Board of Directors of HUDCO and as per the decision, the company has also filed a reply/affidavit to the affidavit of Union of India denying its liabilities on account of the same bases on perpetual Lease Deed 04th July, 1997 and Record Note of discussion dated 07th September, 1995. The matter is currently pending before Hon'ble Supreme Court of India.

Hence, in view of the facts and circumstances stated above, the Company does not expect any liability on this account and any expenditure related thereof. In case of any liability by virtue of any court order or otherwise, the same shall be in the account of “No Lien AGP Account” of MoUD, based on the facts and documents and the legal opinions obtained by HUDCO.

(c) The arbitrator has 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 has also allowed the counter claim of HUDCO amounting to approximately ' 0.85 crore along with interest @ 18% p.a. on account of maintenance charges w.e.f. 1st January, 2001 up-to 31st July, 2005. HUDCO has challenged the award before the Hon'ble High Court of Delhi and, as per the directions of the court, has deposited a sum of ?7.99 crore in the court out of “No Lien AGP Account”.

APIL has invoked arbitration for refund of ground rent paid by it from November, 1995 to October, 1999 and the arbitrator has pronounced the award on 21st July, 2006 holding therein that APIL is not liable to pay the ground rent up to October, 1999 i.e. till the shopping arcade was constructed and became operational in October, 1999. The amount of ?3.93 crore deposited earlier by APIL has been directed to be adjusted towards the future ground rent payment dues w.e.f. November,1999 along-with Interest @ 7% p.a. for delayed payment. HUDCO has filed petition challenging the award before the Hon'ble High Court of Delhi. The Hon'ble High Court on 10th May, 2012 has set aside the arbitration award dated 21st July, 2006. APIL filed an appeal against the above-mentioned order before Division Bench of Hon'ble High Court, Delhi. Division Bench vide its order dated 24th January, 2013, allowed APIL appeal and upheld the Arbitrators award. HUDCO filed SLP on 10th May, 2013 before Hon'ble Supreme Court against this order which is currently pending. On the last day of hearing, i.e., 5th January,2023, APIL's counsel has informed the court that vide Order dated 16th November 2022, APIL has been declared insolvent by NCLT and therefore, now the APIL is under Moratorium. Hence as per the law, all the proceedings pending against APIL are automatically stayed by virtue of law. Further, HUDCO has filed its total claims due against APIL before the Resolution Professional appointed for the above purpose.

4) HUDCO had allotted 6435 sq. mtr. of built-up space in 1993 at HUDCO Vishala, Bhikaji Cama Place, New Delhi to EPFO on Long Term Sub-lease basis. The sub-lease in favour of EPFO is yet to be executed and ?0.35 crore is recoverable from EPFO.

5) (a) The Company has a procedure for seeking confirmation of outstanding balances at each quarter end from all the

borrowers except cases under litigation. In case of receipt of balance confirmation from the agency for any Quarter of the year, the same is treated as confirmed during the year. Confirmation of balances covering approximately 99.16% received up to 11th May 2023 (Previous Year: 92.63% received upto 11th May 2022) in value of the total project loan outstanding (excluding Litigation cases) have been received from the borrowers.

(b) The Company has impairment provision on loans (as per ECL approach) of ?2,431.06 crore as on 3181 March 2023 and ?2,504.23 crore as on 31st March, 2022 as per Ind-AS requirement.

(c) As per RBI notification no. RBI/2019-20/170 Circular DOR (NBFC). CC.PD.No.109/ 22.10.106/2019-20 dated 13th March, 2020 on implementation of Indian Accounting Standards, Housing Finance Companies are required to create an Impairment Reserve for any shortfall in impairment allowances under Ind-AS 109 and IRACP norms (including provision on standard assets). The impairment allowance under Ind-AS 109 made by the company is lower than the total provision required under IRACP as at 31st March, 2023 and accordingly, impairment reserve of ?67.88 crore has been created

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

In the event of excess payment, the same is adjusted towards principal.

However, in respect of default cases, repayments are first adjusted towards liquidation of the oldest default by following above order and after appropriation of default, the balance, if any, is adjusted as per the normal practice as above.

7) During the FY 2022-23, the company has implemented restructuring plan in case of M/s VS Lignite Power Private Limited in March 2023 from the date of order of NCLT, Hyderabad, dated 16th March 2021, with principal outstanding of ?78.75 crore. As per the restructuring plan, 10.14 crore of the principal outstanding will be paid by M/s VS Lignite Power Private Limited to HUDCO, out of the same 1.66 crore as upfront and remaining 17.48 crore is to be repaid as Term loan repayable over 5 years. The balance principal amount of ?48.61 crores to be written off with the reversal of the corresponding ECL allowance thereof. As per NHB norms, the same will kept as NPA under watch period for next one year. The Principal Outstanding as on 31.03.2023 is 10.61 crore

8) HUDCO had earned dividend income of 106 Crore (Previous Year: 108 Crore) during the Financial Year 2022-2023.

9) The Company had made Long Term Investments at a total cost of 19.86 crore which represents Investment in Equity Shares, Infrastructure Debt Fund, Debts Instruments and Investments in Associates. As per the applicable Ind AS, Investments as on 31st March, 2023 are being shown at fair value through profit or loss of 161.68 crore.

10) HUDCO had invested as equity of 12.85 Crores in Cochin International Airport Ltd (CIAL). CIAL came out with rights issue in March 2023. HUDCO Board in its 652nd Board meeting held on 24th March, 2023 approved for applying in rights entitlement for 31,42,207 shares and for additional 7,85,552 shares in the event of non-subscription of rights issue by other existing shareholders, with issue price of 10/- per share (Including premium of ?40/- per share) for a total value of 19.64 crore. CIAL Board approved allotment of rights issue in 5th May 2023, accordingly HUDCO was allotted 36,09,547/- shares (Rights entitlement of 31,42,207 shares and additional 4,67,340 shares) amounting to 18.05 crore. HUDCO has got refund of 1.59 crores in 10th May 2023 towards the balance amount.

11) Loans granted by the company directly to individuals and bulk loans 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 the Developing Authority / Developer;

(iii) Hypothecation of Distribution Assets of the borrower Company.

(iv) Negative Lien on the assets of the borrower Company. Assets of the Company include the book debts and future receivable.

(v) Government Guarantee, first charge on the assets of the housing finance company or First Pari-Passu charge on the outstanding loans or Exclusive Charge/ First Pari-Passu charge on the present and future receivables/ Book Debts, Escrow mechanism, postdated cheques or ECS or RTGS, First Pari-Passu charge on immovable property/ Undertakings, Demand promissory note and irrevocable Power of Attorney in favour of HUDCO to recover the money from individual borrowers.

In addition to (i) and (ii) above, the assignment of Life Insurance Policies, pledge of National Saving Certificates, Fixed Deposits, etc. are also obtained.

12) The Company has adopted Ind AS-19 ‘Employee Benefits'. Defined employee benefit schemes are as follows:

(a) The Company has a separate trust to manage provident fund scheme and provides interest guarantee as per Employees' Provident Fund Scheme, 1952. The Company pays fixed contribution of provident fund at a predetermined rate to the trust, which invests the funds in permitted securities. The trust is required to pay a minimum notified rate of interest on contribution to the members of the trust and the provident fund scheme additionally requires the company to guarantee the payment of interest at rates notified by the EPFO from time to time under the Employees' Provident Fund Scheme,

1952 and recognizes such deficiency as an expense in the year it is determined.

In view of the interest rate guarantee by the Company, the plan although being a defined contribution plan is being treated as defined benefit plan for the purpose of disclosure as per Ind AS 19, since as per Section 17 of the Employees Provident Funds (EPF) Act, 1952, the company has to guarantee the interest rate as announced by the EPFO from time to time. Accordingly, the actuarial valuer has done valuation to the extent of interest rate guarantee and details of the same have been disclosed as given below.

o The fair value of the plan assets of the Provident Fund and the accumulated members' corpus is ?415.90 crore and ?411.57 crore respectively (Previous year ?338.93 crore and ?377.44 crore respectively). The fair value of the assets of the provident fund as at 31st March, 2023 is higher than the obligation under the defined contribution plan. Provision of (?4.33) crore (Previous year ?38.51 crore) is outstanding based on actuarial valuation. o The total employee benefit expense for the valuation period is ?4.85 crore. The amount for Other Comprehensive Income is (?36.45) crore.

The actuarial assumptions include discount rate of 7.27% (Previous year 6.81%) and an average expected future period of 6.38 years (Previous year 6.85 years). The Company recognized '11.09 crore (Previous year ?10.62 crore) for Provident Fund contributions in the Statement of Profit and Loss. The contributions payable to this plan by the Company are at rates specified in the rules of the schemes.

(b) The Company has a defined benefit gratuity plan. Every employee is entitled to gratuity as per the provisions of the payment of Gratuity Act, 1972. The scheme is managed by a separate trust through LIC Policy and the premium paid by the Trust is funded by the Company.

The estimates of future salary increase on account of inflation, promotions and other relevant factors have been considered in actuarial valuation.

$ It represents the amount to be recognized in the Statement of Profit & loss as per actuarial valuation. However, since the scheme is managed by a separate trust through LIC Policy and the premium paid by the Trust is funded by the Company, so the premium paid is debited to the Statement of Profit & Loss.

# The scheme of Gratuity is managed by a separate trust through LIC Policy and the premium paid by the Trust is funded by the Company. Further, the schemes of Leave Encashment and Post-Retirement medical benefits are unfunded.

Note:-

a) The Company expects to contribute ' 1.62 crore (Previous year ' 1.24 crore) to the Gratuity Fund in the next financial year. The weighted average duration of the defined benefit obligation as at 31st March, 2023 is 6.20 years (Previous year 6.85 years).

b) The Company expects to contribute ' 8.30 crore (Previous year ' 7.34 crore) to the Medical Benefit Fund in the next financial year. The weighted average duration of the defined benefit obligation as at 31st March, 2023 is 21.21 years (Previous year 21.43 years).

14) a. The Govt. of India through its Notification dated 9th August, 2019 had made Reserve Bank of India (RBI) as the regulator for HFCs and the supervision part continued to remain with NHB.

RBI has issued notification dated 22nd October, 2020, on regulatory framework for HFCs, by which the definition of HFC has undergone a change. HFCs which are unable to fulfill the criteria shall be treated as NBFC - Investment and Credit Companies (NBFC-ICC).

Since, HUDCO does not fulfil the criteria of HFC as per the new definition, RBI was requested vide letter dated 16th December, 2020 for special dispensation to HUDCO for granting exemption and treat HUDCO as HFC.

RBI in its reply letter dated 10th February, 2021 has informed its inability to accede to HUDCO's request for exemption and accordingly suggested to submit a Board approved plan to fulfill the principal business criteria for HFC or to convert into a NBFC-ICC.

RBI was requested vide letter dated 8th March, 2021 to grant six months' time for transition to NBFC and to retain the status of HFC and to continue operations with the special dispensations/ relaxations given earlier with regard to credit concentration 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 till 31st December, 2021 to submit Board approved plan for conversion to NBFC. RBI has further advised that the exemptions from concentration/exposure norms granted previously by NHB/RBI would continue to apply at present subject to the conditions 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 the HUDCO's Board in its meeting held on 28th December, 2021. Thereafter, HUDCO required approval from Ministry of

Housing 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 to RBI and to retain the status of HFC and RBI vide letter dated 31st December, 2021 granted time till 31st March, 2022 for conversion from HFC to NBFC-IFC.

HUDCO had submitted application to RBI on 29th March, 2022 to convert from HFC to NBFC- IFC. In reference thereof, RBI vide letter dated December 22, 2022 expressed its inability to accede to HUDCO's request for conversion of certificate of registration (CoR) to an NBFC-IFC owing to non-fulfilment of certain condition of RBI Master Directions for NBFCs. After detailed deliberation and ensuring compliance with the RBI Master Directions for NBFCs, HUDCO has resubmitted the application with necessary documents with RBI for conversion of certificate as NBFC-IFC on February 22, 2023. In view of the above, the management reckons to receive the said approval from RBI in FY 2023-24. Till such time HUDCO continues to retain the status of HFC.

b. RBI vide circular number DOR.CRE.REC.No.60/03.10.001/2021-22 dated October 22, 2021 has introduced Scale-Based Regulations (SBR) for NBFCs and these guidelines have been made effective from October 01,2022.

As per this framework Government owned NBFCs are still in the transition period and therefore RBI decided not to subject them to the Upper Layer regulatory framework. Guidelines as applicable for the NBFC-Middle Layer (ML) shall be applicable to the Company. Disclosures applicable to the Company have been made in the notes to Accounts under regulatory disclosures.

15)

- RBI has issued Master Directions for NBFC-HFC vide their Notification dated 17th February, 2021. RBI's credit concentration norms state that a Housing Finance Company's lending exposure to any single borrower or investment in the shares of another company should not exceed 15% of its owned funds and lending exposure to any single group of borrowers or investment in the shares of single group of companies should not exceed 25% of its owned funds. As per the said circular, Investment of a Housing Finance Company (HFC) in the shares of another HFC shall not exceed 15% of the Equity Capital of the investee company.

The Company is complying with National Housing Bank's credit concentration norms except in one case of investment in another HFC viz., Indbank Housing Ltd. (IBHL), a subsidiary of Indian Bank in which HUDCO has invested 25% capital of investee.

HUDCO had invested ?2.50 crore, out of total paid up capital of ?10 crore, in the equity shares of IBHL in the year 1990-1991 and 1991-1992, resulting in investment to the extent of 25% of the equity. The investment was made before regulatory guidelines were issued. No further investment was done nor any disinvestment has been made.

HUDCO has been making efforts for past several years to exit/bring down its stake within the prescribed norms however since Ind-Bank Houing Finance is having accumulated losses and is non-operational for several years it has not been successful. However, recently Ind-Bank with a view to revive its operations and adequately capitalize it has decided to increase equity base and invited investment bids from strategic investors and Indian Bank would also subscribe by way of preferential allotment so as to maintain its 51% stake. The proposal has been submitted to RBI and in case it is approved, HUDCO's stake would come down below 25% which will be well within norms. Further, HUDCO has written down the investment in its books and being reflected at Rs. 1.

- NHB/ RBI, from time to time, has given certain relaxations from credit concentration norms considering the role envisaged for HUDCO. However, vide its letter No. NHB(ND)/ DRS/ SUP/ 3911/ 2018 dated 2nd April, 2018, NHB capped the credit concentration (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% for infrastructure/ 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 NOF in respect of State of Telangana and 100% of NOF for all other States. HUDCO is required to take suitable steps to bring down the group exposure in respect of State of Telangana also to 100% within a maximum period of 3 years The conditions relating to compliance by the concerned State with the FRBM limits shall continue to be ensured by HUDCO.

The Board of Directors of HUDCO in its 594th meeting held on 19th April, 2018 considered above and directed that “NHB be again requested to expeditiously review its decision communicated vide its letter dated 2nd April, 2018 and permit HUDCO to continue on the already approved pattern of credit concentration norms communicated by NHB vide its letters from time to time”.

NHB vide its letter no. NHB(ND)/DRS/SUP/7085/2018 dated 13th July, 2018 has conveyed its decision to allow HUDCO to continue 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 State Governments (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% for

infrastructure/non-housing related activities) and upto 100% for State Governments (under group exposure) will continue to be applicable in all other cases. The condition relating to compliance by the concerned State with the FRBM limits shall 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 Extra Budgetary Resources (EBRs).

NHB vide its letter no. NHB(ND)/DRS/SUP/879/2019 dated 8th March, 2019 granted relaxation in credit concentration norms (under individual borrower exposure to Government /public agency) to HUDCO to extend loan upto ?20,000 crore 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 respect of credit concentration (exposure) norms upto 140%, 175% and 120% of the NOF in respect of the State of Andhra Pradesh, 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 by the 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% in respect of group exposure latest by 31st March, 2023, in accordance with the roadmap for graded reduction in exposure approved 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 Board approved exposure reduction plan.

(iv) In the event of HUDCO failing to comply with the above exposure reduction plan, HUDCO will be required to assign risk weight 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 in all other cases.

RBI has vide its letter no 1736/3.10.136/2019-20 dated 5th March, 2020 granted relaxation of credit concentration norms for exposure to Telangana State Housing Corporation Limited (TSHCL) upto 75% of Net Owned Fund of HUDCO subject 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 26 March, 2021 has permitted that the exemptions from concentration/exposure norms granted previously by NHB/RBI would continue to apply at present subject to the conditions specified while granting such exemptions. However, a review shall be undertaken at the time of conversion to NBFC.

HUDCO was given the time limit to bring down exposure upto 50% in respect of individual exposure and upto 100% for State Governments (under group exposure) by March 2023. In compliance with the same, HUDCO has brought down the exposure to 50% in respect of individual exposure and upto 100% for State Governments (under group exposure) as on March 31,2023 in respect of all states.

- HUDCO is in the process of transition from its present status of HFC to NBFC-IFC. In view of the above, HUDCO has requested RBI to allow HUDCO to continue operations with the special dispensations/relaxations given with regard to credit concentration/exposure norms by NHB/RBI. Furthermore, HUDCO has requested RBI that it may be granted exemption from the applicability of concentration of credit/investment norms in respect of its exposure towards Central/ State Government entities consequent upon registration as NBFC-IFC in line with other Government NBFCs.

17) The Company in terms of SEBI (Listing Obligations and Disclosure Requirements) (Fifth Amendments) Regulations 2021 dated 07/09/2021, is presently transferring principal and/or interest, or both (if any) which remains unclaimed for 7 years from the date of payment to Investor Education and Protection Fund (IEPF) constituted in terms of Section 125 of the Companies Act, 2013. The bondholders, whose unclaimed principal and/or interest has been transferred to IEPF, may claim the same by making an online application in the prescribed Form No. IEPF-5 available on the website (www.iepf.gov.in) and sending a physical copy of the same, duly signed by all the bondholders to the Company, along with requisite documents enumerated in Form No. IEPF-5. No claims shall lie against the Company in respect of the amounts, so transferred to the IEPF Authority. Dividend on equity shares and Principal & interest on Debentures/Bonds/PDS aggregating to ' 14.90 Crore (Previous Year ' 11.52 Crore) were due and unclaimed as on 31st March, 2023. During the year 2022-23, an amount of ' 1.88 Crore (previous year ' 0.03 Crore) has been transferred to IEPF after completion of statutory period of seven years.

19) The Company is engaged in the business of providing loans/finance for Housing/ Infrastructure projects and all other activities of the Company revolve around the main business within India. Accordingly, the company does not have separate 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, there is no

Impairment of Assets during the Financial Year 2022-23.

(ii) Vide gazette notification no. 26/2019 dated 20th March, 2019, Company was notified for the purposes of Section 194A(3)(iii)(f) of the Income Tax Act, 1961 for non-deduction of Tax at source.

21) The Company has discontinued acceptance/renewal of Public Deposits under its Public Deposit Scheme from 01st July, 2019. However, redemption of deposits already taken shall be made on due dates.

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 over life of resource raised. The aforesaid expenses are charged to Statement of Profit and Loss under the Head “Fees & Commission Expense”

23) HUDCO had invested an amount of ?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 proposed to close/wind up the scheme prematurely due to inability to comply with SEBI guidelines, high cost involved and low returns of around 4% since inception vis a vis market condition. In this regard, the company has decided to cast its vote in favour of the resolution proposed to be passed for premature closure/winding up the scheme of IIFCL Mutual Fund.

25) During the year ended 31st March 2023, the Company has raised funds through issue of listed non-convertible debt securities of different tenors 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 there has been no deviation / variation in the use of proceeds of non-convertible debt securities from the objects stated in the 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 and interest, 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 lease by mutual consent on mutually agreeable terms. The aggregate lease rentals payable is charged as office rent under Note No. 32- Other Expenses of the Statement of Profit & Loss. Further, there is no financial lease as Company's leasing 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 1961 equivalent to 5% of the taxable income (after allowing deduction u/s 36(1)(viii)), totaling to ' 105 crore has been created.

29) (a) The company has declared an interim dividend of ?150.14 crore @ ?0.75 per share of ?10/- each, to its shareholders, during the year 2022-23 after approval of Board of Directors in its meeting held on 14th March 2023. The same has been paid on 29th March 2023 to the Ministry of Housing & Urban affairs and Ministry of Rural Development, GOI and to the Retail Public.

(b) The Board of Directors at its meeting held on 26th May, 2023 has recommended a Final Dividend of 3.10 per share of ?10/-each, which is subject to approval of shareholders at the ensuing Annual General Meeting.

33) Exit from Associate Companies:

(a) Signa Infrastructure India Ltd. (SIIL)

The company has decided to exit from the Associate Company (Signa Infrastructure India Ltd.-SIIL) with Marg Construction Ltd. In pursuance of the Board's approval, the valuer was appointed by the Associate Company i.e., SIIL and indicated the value of the shares (?10 each) at ?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 HUDCO Board in its meeting held on 19th December, 2019 decided that steps be taken for termination of joint venture agreement with M/s. Marg construction Ltd. (Promoter of Signa Infrastructure India Ltd) withdrawal of HUDCO Nominee Director and further action for dissolution (wind up) of Associate Company on grounds of non-compliance of various statutory compliances. In pursuance of Board Decision, HUDCO Nominee Director had submitted his resignation to the Company. In subsequent discussion held with Parent Co.-Marg Limited, HUDCO has requested for submission of concrete proposal for exit of HUDCO.

(b) Pragati Social Infrastructure & Development Ltd.

The company has decided to exit from the Associate Company (Pragati Social Infrastructure & Development Ltd.-PSIDL) with Pragati 47. PSIDL is not providing any financial information for the purpose of valuation of shares because of Court injunction. Further, HUDCO has also filled petition to National Company Law Tribunal (NCLT) for oppression and mismanagement of operations against the company, which is pending adjudication.

(c) Shristi Urban Infrastructure Development Ltd.

The company had decided to exit from the Associate Company (Shristi Urban Infrastructure Development Ltd.-SUIDL) with Shristi Infrastructure Development 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 for Insolvency Proceedings resulting in non-availability of authentic data for valuation of Associate Company.

34) Valuation of Investment

The Company had invested ' 2.50 crore in the shares of the Indbank Housing Ltd. (IBHL) more than 30 years back. Considering the fact that IBHL has highly negative Net Worth and meagre volume of trading in the share of the company, even though market price of the share as on 31st March, 2023 is ' 25.22 per share (previous year ' 27.40 per share), HUDCO continues to reflect the investment of ?2.50 crore in IBHL at diminished value of '1 only as on 31st March, 2023.

(d) Transactions with Key Management Personnel:

i) Shri M. Nagaraj, DCP, has not taken any advance during the year. Hence, there is no outstanding towards advances as on 31st March, 2023.

ii) Shri D. Guhan, DF, has not taken any advance during the year. Hence, there is no outstanding towards advances as on 31st March, 2023.

iii) Shri Harish Sharma, Company Secretary has taken the following advances in the ordinary course of business.

• House Building loan of 122 crore (interest bearing) from the company which was released in two tranches of '0.11 crore in December, 2016 and '0.11 crore in March, 2018, which was completely repaid during the FY 20222023. The interest accrued as on 31st March, 2023 is '0.01 crore. (Previous year: - '0.02 crore)

• Welfare Advance of '0.02 crore in February, 2021, which was completely repaid during the FY 2022-2023 along with applicable interest. (Previous year: - '0.01 crore).

• Festival Advance (interest free) of '0.01 crore in October, 2020 which was completely repaid during the FY 20222023 (Previous year: '0.01 crore).

Information in respect of Investments in Associate viz., Pragati Social Infrastructure & Development Ltd, Signa Infrastructure India Ltd and Indbank Housing Limited has not been incorporated as HUDCO has decided to exit from the Associate and has provided for full diminution in the value of investment.

37) Corporate Social Responsibility

a) The Company has formulated a CSR Policy in line with the guidelines issued by Department of Public Enterprise (DPE) vide its Office Memorandum No. CSR- 15/0008/2014-Dir (CSR) dated 01st August, 2016 and provisions of CSR in the Companies Act, 2013 with the approval of HUDCO's Board on the recommendations of Committee of Board.

As per Companies Act, 2013, company approved allocation for CSR Budget for the FY 2022-23, equivalent to 2% of the average profit (Profit before Tax) of immediately preceding three financial years amounting to ?44.98 crore.

During the FY 2022-23, HUDCO has approved CSR assistance of ?26.68 crore for 19 proposals in various states. As per HUDCO's approved CSR Policy, 1st instalment of CSR assistance is to be released on completion of documentation and the subsequent instalments are released on receipt of utilization of certificate of the released CSR grant and after achieving physical/financial progress in the proposal. Since most of the proposals were approved in the last quarter of financial year, concerned agencies are yet to complete the documentation formalities and preparatory works for execution of works e.g., finalization of tender etc. and therefore the 1st instalment could not be released in proposals approved during the year and in view of this, the amount has been transferred to the unspent CSR account. This has resulted in delay in incurring CSR expenditure from the CSR budget of FY 2022-23.

b) Companies (CSR Policy) Amendment Rules 2021 dated 22nd January, 2021 issued by Ministry of Corporate Affairs has notified that the Company hereafter follows the amended rules. Accordingly, any amount remaining unspent pursuant to ongoing projects undertaken by a company in pursuance of its CSR policy shall be transferred by the company in the unspent CSR Account with any Bank within a period of 30 days from the end of financial year. CSR amount transferred to the said account shall be spent by the company in pursuance of its obligation towards CSR Policy within a period of three financial year from the date of such transfer. Thereafter, balance of unspent amount, if any, shall be transferred to a fund specified in Schedule VII mentioned under Section 135 of Companies Act 2013, within a period of 30 days from the date of completion of the third financial year.

c) During the year 2022-23, the company has approved CSR assistance of ?26.68 crore for 19 proposals in various states, however as already stated above no expenditure could be incurred in these proposals as most of the proposals were approved in the last quarter of financial year and concerned agencies are yet to complete the documentation formalities. Accordingly, the amount pertaining to these ongoing proposals is transferred to ‘Unspent CSR account' opened in April 2023 and shall be incurred as per Companies CSR Rules 2021 as stated above. Further, ' 3,20,72,843 /- has been spent during current financial year 2022-23 for the ongoing CSR proposals sanctioned prior to 31st March, 2021.

d) As of 31st March 2023, an amount of 18,30,18,204/-, being the unspent CSR amount other than ongoing CSR activities for the FY 2022-23 shall be transferred to Government fund specified in Schedule VII of the Companies Act,2013 within the stipulated time period, i.e., on or before 30th September,2023.

e) In compliance with the Ministry of Corporate Affairs, Government of India notification dated 22nd January,2021, as already mentioned in the Annual Report under Category “CSR activities” for financial year 2021-22, HUDCO has transferred an amount of 16,99,00,000/- being the unspent CSR budget amount for the financial year 2021-22 to ‘Swachh Bharat Kosh', a fund specified in Schedule VII of the Companies Act,2013 on 30th September, 2022.

f) As on 31st March, 2023, the total amount available under Unspent CSR Account opened in April 2021 is ' 13,75,61,434/-(Previous year 31st March, 2022, ' 27,02,24,158/-). During the year, out of the aforesaid amount, ' 2,53,51,342/- and ' 73,86,085/- has been contributed to ‘Swachh Bharat Kosh' and ‘PM CARES Fund' funds specified in Schedule VII of the Companies Act, 2013, respectively due to closure and curtailment of CSR proposals sanctioned prior to 31st March, 2021. Besides this, ' 8,88,90,596/-amounting to the other than earmarked for ongoing projects of earlier years due to closure and curtailment has been transferred to ‘Swachh Bharat Kosh', a fund specified in Schedule VII of the Companies Act,2013 on 30th September, 2022 as already mentioned in the Annual Report under Category “CSR activities” for financial year 2021-22

38) Research & Development (R&D)

The Company had formulated a Research & Development (R&D) policy in line with the guidelines issued by the Department of

Public Enterprises vide Office Memorandum No. 3(9)/ 2010-DPE (MoU) dated 20.09.2011. However, vide Office Memorandum

No. M-05/0012/2014-DPE(MoU) dated 17th July, 2019, DPE informed that the guidelines prescribed vide above Office

Memorandum dated 20.09.2011 have become redundant and stood withdrawn. The Board of Directors of HUDCO in its meeting held on 19.02.2020 noted the above development and has also approved to continue with HUDCO's own R&D policy formulated in 2012. The Board of Directors also approved to discontinue with earmarking 0.5% of PAT until the accumulated non-lapsable R&D funds are fully utilized. During the FY 2022-23, an amount of ?0.13 crore was spent on R&D. Accordingly an amount of ' 9.30 crore as on 31st March 2023 (Previous Year: ' 9.43 crore) was available with HUDCO as non-lapsable R&D funds.

39) The Company has not advanced or lent or invested any funds which are material either individually or in the aggregate (either from borrowed funds or share premium or any other sources or kind of funds) to or in any other person(s) or entity(ies), including foreign entities (“Intermediaries”), with the understanding, whether recorded in writing or otherwise, that the Intermediary shall, whether, directly or indirectly lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the Company (“Ultimate Beneficiaries”) or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries.

The Company has not received any fund which are material either individually or in the aggregate from any person(s) or entity(ies), including foreign entities (“Funding Parties”), with the understanding, whether recorded in writing or otherwise, that the Company shall, whether, directly or indirectly, lend or invest in other persons or entities identified in any manner whatsoever by or on behalf of the Funding Party (“Ultimate Beneficiaries”) or provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries.

iii) Disclosures on Risk Exposure in Derivatives

A. Qualitative Disclosure

The Company has Risk Management Policy duly approved by the Board. The Policy covers the currency risk (including interest rate risk) of the Company. This policy provides the guiding parameters within which the Company can take decisions for managing the Currency Risk that it is exposed to on account of foreign currency loans. The purpose of the policy is to provide a framework to the company for management of its foreign currency risk.

B. Risk Management Structure:

(a) The Company enters into derivatives viz. Principal only Swaps, Currency and Interest Rate Swaps/ Forward rate contract for hedging the interest/ exchange rate risk in foreign currency liabilities. An Asset Liability Management Committee (ALCO) is currently functioning under the chairmanship of Director Finance with Head of Resources, Head of Operations, Head of Loan accounts, Head of General Accounts, Head of Economic Cell, Head of Risk Management as Member Secretary, or any other officer nominated as by ALCO Chairman as its member ALCO monitors effectiveness of existing and new hedging instruments/ strategies being used/ to be used for management of the Currency risk and also for taking stock of the market movements. The decisions of the ALCO are reviewed by the Risk Management Committee (RMC) for managing the risks. The decisions taken by the RMC are subsequently reported to the Board of Directors.

(b) These derivative transactions are done for hedging purpose and not for trading or speculative purpose.

(c) Reference may be drawn to Sub Point No. 4.6 of para 4 of Notes forming part of accounts under Significant Accounting Policies for relevant accounting policy on Transactions in Foreign Currency.

j) Rating assigned by Credit Rating Agencies and migration of rating during the year

i. The credit rating of HUDCO's domestic debt instrument(s) and Banking Sector Loan(s)/Facilities reaffirmed as “AAA-Stable” (Long term) and “A1 ” (Short term) the highest rating on Standalone basis by the three credit rating agencies, viz., India Ratings and Research Private Ltd (IRRPL), CARE Ratings Limited and ICRA Limited.

ii. During the financial Year 2022-23, two International Credit Rating agencies viz., Fitch and Moody's have re-affirmed credit rating of “BBB-with Stable Outlook” and “Baa3 with Stable Outlook” respectively of the company. Each of the above credit ratings is equivalent to India's sovereign rating, and is of Investment grade

r) There are no advances outstanding for which intangible securities such as charge over the rights, licenses, authority etc. has been taken.

s) The Company has not extended any loan/advances against gold as collateral security.

t) There is no change in accounting policies during the financial year.

u) The company has the system in place to process all the accounting transactions through independent IT systems. The company is in the process of implementation of ERP system and some of the modules have been operationalised during the Year 2022-23.

v) Principal Business Criteria of HUDCO in accordance with the guidelines outlined in para 4.1.17 and para 5.3 of the Master Directions for Non-Banking Finance Companies- Housing Finance Companies (Reserve Bank) Directions, 2021, dated February 17, 2021 is as follows.

During the computation of Principal Business Criteria, HUDCO has taken into consideration the loan assets extended under the Beneficiary Led Construction (BLC) and Extra Budgetary Resources (EBR) components. Under both these components, loans are provided for affordable housing purposes. HUDCO has classified both these components under the housing category for its book keeping purposes.

HUDCO has recently resubmitted its application to the Reserve Bank of India (RBI) for registration as NBFC-IFC. In this regard, we have submitted the certified infrastructure lending portfolio, certified by our statutory auditors, to the RBI. It is worth noting that in the certified infrastructure lending portfolio, HUDCO has categorized the loans extended under the Beneficiary Led Construction (BLC) and Extra Budgetary Resources (EBR) for affordable housing purposes only, under the Social and Commercial Infrastructure category, as per the Harmonized Master List of Infrastructure Sub-Sectors issued by the Ministry of Finance (Department of Economic Affairs).

1. Significant counterparty/ Significant instrument/ product is defined as single counterparty/ single instrument/ product or group of connected or affiliated counterparties accounting in aggregate for more than 1% of the total liabilities.

2. “Public Deposits” are as defined in the Master Directions - Non-Banking Financial Companies Acceptance of Public Deposits (Reserve Bank) Directions, 2016.

3. Total Liabilities has been computed as sum of all financial and non-financial liabilities (extracted from the audited Standalone Financial Statements prepared as per IND-AS for the period ended March 31, 2023) and does not include equities and Reserve & Surplus.

4. “Public Funds” are as defined in Master Directions- Non-Banking Financial Company -Systemically Important NonDeposit 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 shares within a period not exceeding 5 years from the date of issue.

5. The information stated in this disclosure is based on audited Standalone Financial Statements (prepared as per IND-AS) for the period ended March 31,2023.

42) Disclosure on Liquidity Coverage Ratio Qualitative Disclosure:

Institutional set-up for the Liquidity Risk Management: HUDCO has implemented an integrated risk management approach through which it reviews and assesses significant risks on a regular basis to ensure that there is a robust system of risk controls and mitigation in place. HUDCO has a well-structured robust Risk Management Policy and Operating Manual in line with its objectives to address the various risks.

In compliance with the SEBI (LODR) Regulations, 2015, HUDCO has in place a Board Level Committee under the nomenclature ‘Risk Management Committee' (RMC) headed by an Independent Government Nominee Director, which reviews various decisions/ recommendations of the three sub-committees namely:

• Assets & Liabilities Management Committee (ALCO);

• Credit Risk Management Committee (CRMC); and

• Operational Risk Management Committee (ORMC)

The Risk Management Committee (RMC), which is a committee of the Board, is responsible for evaluating and monitoring the integrated risk management system of the Company including liquidity risk. The ALCO is responsible for ensuring adherence to the liquidity risk tolerance/limits set out in the board approved Asset Liability Management (ALM) policy. The role of the ALCO with respect to liquidity risk includes, inter alia, decision on desired maturity profile for assets & liabilities, responsibilities and controls for managing liquidity risk, and overseeing the liquidity position of the company. The ALM Policy is reviewed periodically to realign the same pursuant to any regulatory changes in the economic landscape or business needs and tabled

Management regularly reviews the position of cash and cash equivalents by aligning the same with the projected maturity 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 policy with additional liquidity buffers as management overlay

The Liquidity Coverage Ratio (LCR) is a global minimum standard to measure the Company's liquidity position. The Reserve Bank of India (RBI), vide its Master Direction - Non-Banking Financial Company - Housing Finance Company (Reserve Bank) Directions, 2021, dated February 17, 2021, introduced the LCR requirement for all non-deposit-taking HFCs with an asset size of ' 10,000 crore and above and all deposit taking HFCs irrespective of their asset size as per the following timeline:

Hence, the company is required to maintain minimum LCR of 50% w.e.f December 01,2021.

Further, the aforementioned Master Direction states that the guidelines on Liquidity Risk Management Framework prescribed for NBFCs by the RBI vide its Master Direction - Non-Banking Financial Company - Systematically Important Non-Deposit taking Company and Deposit taking Company (Reserve Bank) Directions, 2016, dated September 01,2016 shall apply mutatis mutandis to Housing Finance Companies (HFCs).

As per the said guidelines, the Company shall maintain an adequate level of unencumbered High Quality Liquid Assets (HQLA) that can be converted into cash to meet its liquidity needs for a 30 calendar-day time horizon under a significantly severe liquidity stress scenario. “HQLA” means liquid assets that can be readily sold or immediately converted into cash at little or no loss of value or 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 be included in the computation of HQLAs are those that the NBFC is holding on the first day of the stress period. Such assets shall be valued at an amount not greater than their current market value for the purpose of computing the LCR. Depending upon the nature of assets, they have been assigned different haircuts, which are to be applied while calculating the HQLA for the purpose of calculation of LCR.

In order to determine HQLA, the company considers Fixed Deposits which are maintained with Scheduled Commercial Banks owing to the fact that it bears 0% haircut. As a matter of prudence for the purpose of maintenance of LCR, highest level of HQLA requirement in the forthcoming 7 days is considered on continuous basis by the company.

In order to determine Net Cash Outflows, the Company considers total expected cash outflow minus total expected cash inflows for the subsequent 30 calendar days by assigning a predefined stress percentage to the overall cash inflows and cash outflows. Total expected cash outflows (stressed outflows) are calculated by multiplying the outstanding balances of various categories or types of liabilities and off-balance sheet commitments by 115% (15% being the rate at which they are expected to run off further or be drawn down). Total expected cash inflows (stressed inflows) are calculated by multiplying the outstanding balances of various categories of contractual receivables by 75% (25% being the rate at which they are expected to underflow). However, total cash inflows will be subjected to an aggregate cap of 75% of total expected cash outflows. In other words:

Total Net Cash Outflows over the next 30 days = Stressed Outflows - Lower of (Stressed Inflows or 75% of Stressed Outflows).

One of the components of cash outflow of this disclosure includes Other Contractual Funding Obligations, which, inter alia, includes payment of taxes and dividend paid by the company.

The Company computes the LCR and reports the same to the Asset Liability Management Committee (ALCO) every month for review and approval.

46) Additional information

I. No proceedings have been initiated or pending against the Company for holding any benami property under the Benami Transactions (Prohibitions) Act, 1988 (45 of 1988) and the rules made there under, as at March 31,2023 and March 31, 2022.

II. The Company is not a declared willful defaulter by any bank or financial Institution or other lender, in accordance with the guidelines on willful defaulters issued by the Reserve Bank of India, during the year ended March 31,2023 and March 31,2022.

III. There was no delay in the registration or satisfaction of any charges with Registrar of Companies during the year ended March 31,2023 and March 31,2022.

IV. The company does not have any investment in any subsidiary company. Therefore, there is no requirement to comply with the number of layers prescribed under clause (87) of section 2 of Companies Act, 2013 read with Companies (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 31,2023 and March 31,2022

VI. There are no undisclosed incomes that has been surrendered or disclosed as income during the year in the tax assessments under the Income Tax Act, 1961.

VII. Analytical Ratios

a. Capital to Risk-weighted Assets Ratio: -Refer note no. 34

b. Liquidity Coverage Ratio: -Refer note no.41

47) (a) Figures of the previous period 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 without decimals except where specifically indicated.