Notes to Accounts of Usha Martin Ltd.

Mar 31, 2025

m. Provisions, contingent liabilities

Provisions represent liabilities for which the amount
or timing is uncertain. Provisions are recognized
when the Company has a present obligation (legal
or constructive), as a result of past events and it is
probable that an outflow of resources, that can be
reliably estimated, will be required to settle such
an obligation.

If the effect of the time value of money is material,
provisions are determined by discounting the
expected future cash flows to net present value using
an appropriate pre-tax discount rate that reflects
current market assessments of the time value of
money and, where appropriate, the risks specific to
the liability. Unwinding of the discount is recognized
in the Statement of Profit and Loss as a finance cost.
Provisions are reviewed at each reporting date and are
adjusted to reflect the current best estimate.

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

n. Employee benefit schemes

(i) Short-term employee benefits

Employee benefits payable wholly within twelve
months of receiving employee services are classified as
short-term employee benefits. These benefits include
salaries and wages, performance incentives and
compensated absences which are expected to occur
in next twelve months. The undiscounted amount of
short-term employee benefits to be paid in exchange
for employee services is recognised as an expense as
the related service is rendered by employees.

Compensated absences:

Compensated absences accruing to employees and
which can be carried to future periods but where
there are restrictions on availment or encashment or
where the availment or encashment is not expected to
occur wholly in the next twelve months, the liability on
account of the benefit is determined actuarially using
the projected unit credit method.”

(ii) Post-employment benefits
Defined contribution plan

Retirement benefits in form of superannuation is a
defined contribution scheme. The Company has no
obligation, other than the contribution payable to
the superannuation fund. The Company recognizes
contribution payable to the superannuation scheme
as an expenditure, when an employee renders the
related service. If the contribution payable to the
scheme for service received before the balance sheet
date exceeds the contribution already paid, the deficit
payable to the scheme is recognised as a liability
after deducting the contribution already paid. If the
contribution already paid exceeds the contribution due
for services received before the balance sheet date,
then excess is recognised as an asset to the extent
that the pre-payment will lead to a reduction in future
payment or a cash refund.

Defined benefit plans - Gratuity, Provident fund and
long-term service award

Gratuity

The Company has a defined benefit plan (the "Gratuity
Plan”). The Gratuity Plan provides for a lumpsum
payment to vested employees at retirement, death
while in employment or on termination of employment
of an amount equivalent to 15 to 30 days salary
payable for each completed year of service depending
upon the tenure of service subject to maximum limit
of 20 months'' salary. Vesting occurs upon completion
of five continuous years of service. Presently, the
Company''s gratuity plan is funded.

The present value of the defined benefit obligation
is determined by discounting the estimated future
cash outflows by reference to market yields at the
end of the reporting period on Government bonds
that have terms approximating to the terms of the
related obligation The net interest cost is calculated
by applying the discount rate to the net balance of the
defined benefit obligation and the fair value of plan
assets, if any. This cost is included in employee benefit
expense in the Statement of Profit and Loss.

The liability or asset recognised in the Balance Sheet
in respect of gratuity plan is the present value of the
defined benefit obligation at the end of the reporting
period less the fair value of plan assets, if any. The
defined benefit obligation is calculated annually by
actuaries using the projected unit credit method and
spread over the period during which the benefit is
expected to be derived from employees'' services.

Remeasurements, comprising of actuarial gains and
losses from changes in actuarial assumptions, the
effect of the asset ceiling, excluding amounts included
in net interest on the net defined benefit liability
and the return on plan assets (excluding amounts
included in net interest on the net defined benefit
liability), are recognised immediately in the Balance
Sheet with a corresponding debit or credit to retained
earnings through Other Comprehensive Income (OCI)
in the period in which they occur. Remeasurements
are not reclassified to Statement of Profit and Loss
in subsequent periods. Changes in the present value
of the defined benefit obligation resulting from
plan amendments or curtailments are recognised
immediately in the Statement of Profit and Loss as
past service cost.

Net interest is calculated by applying the discount
rate to the net defined benefit liability or asset. The

Company recognises the following changes in the
net defined benefit obligation as an expense in the
Statement of Profit and Loss:

• Service costs comprising current service costs, past
service costs, gains and losses on curtailments and
non-routine settlements; and

• Net interest expense or income
Provident fund

Eligible employees and the Company make monthly
contributions to the provident fund plan equal to
a specified percentage of the covered employee''s
salary. The Company contributes a portion to the
''Usha Martin Employees Provident Fund Trust''. The
trust invests in specific designated instruments as
prescribed by the Government. The remaining portion
is contributed to the Government administered
pension fund. The rate at which the annual interest
is payable to the beneficiaries by the trust is being
administered by the Government. The Company
has an obligation to make good the shortfall, if any,
between the return from the investments of the Trust
and the notified interest rate.

Share-based payment arrangements

Equity-settled share-based payments to eligible
employees under the Scheme called as "Usha Martin
Employee Stock Options Plan - 2024 ("ESOP Plan”) a
remeasured at the fair value of the equity instruments
at the grant date. Details regarding the determination
of the fair value of equity-settled share-based
transactions are set out in note 28(b). The fair value
determined at the grant date of the equity-settled
share based payments is expensed on a straight-line
basis over the vesting period, based on the Company''s
estimate of equity instruments that will eventually vest,
with a corresponding increase in equity. At the end of
each reporting year, the Company revisits its estimate
of the number of equity instruments expected to vest.
The impact of the revision of the original estimates,if
any, is recognised in Statement of profit and loss
such that the cumulative expense reflects the revised
estimate, with a corresponding adjustment to the
equity settled employee benefits reserve.

The Company has created an Usha Martin Limited
Employee Welfare Trust (''UMLEWT'') for providing
share-based payment to its employees. The Company
uses UMLEWT as a vehicle for distributing shares
to employees under the employee remuneration
schemes. UMLEWT buys shares of the Company from
the secondary market, for giving shares to employees.
Share options exercised during the reporting period
are satisfied with treasury shares. The Company treats

UMLEWT as its extension and shares held by UMLEWT
are treated as treasury shares..

o. Financial instrument

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

Financial assets

Initial recognition and measurement

The classification of financial assets at initial
recognition depends on the financial asset''s
contractual cash flow characteristics and the
Company''s business model for managing them. With
the exception of trade receivables that do not contain
a significant financing component or for which the
Company has applied the practical expedient, the
Company initially measures a financial asset at its
fair value plus, in the case of a financial asset not at
fair value through profit or loss, transaction costs.
Trade receivables that do not contain a significant
financing component or for which the Company has
applied the practical expedient are measured at the
transaction price determined under Ind AS 115:
Revenue from contracts with customers. Revenue
towards satisfaction of a performance obligation is
measured at the amount of transaction price (net of
variable consideration) allocated to that performance
obligation. The transaction price of goods sold and
services rendered is net of variable consideration on
account of various discounts and schemes offered
by the Company as part of the contract. Refer to
the accounting policies in section (d) Revenue from
contracts with customers.

In order for a financial asset to be classified and
measured at amortised cost or fair value through
OCI, it needs to give rise to cash flows that are "solely
payments of principal and interest (SPPI)” on the
principal amount outstanding. This assessment is
referred to as the SPPI test and is performed at an
instrument level. Financial assets with cash flows
that are not SPPI are classified and measured at
fair value through profit or loss, irrespective of the
business model.

The Company''s business model for managing
financial assets refers to how it manages its financial
assets in order to generate cash flows. The business
model determines whether cash flows will result
from collecting contractual cash flows, selling the
financial assets, or both. Financial assets classified and
measured at amortised cost are held within a business
model with the objective to hold financial assets in
order to collect contractual cash flows while financial

assets classified and measured at fair value through
OCI are held within a business model with the objective
of both holding to collect contractual cash flows
and selling.

Purchases or sales of financial assets that require
delivery of assets within a timeframe established by
regulation or convention in the market place (regular
way trades) are recognised on the trade date, i.e., the
date that the Company commits to purchase or sell
the asset.

Subsequent measurement

For purposes of subsequent measurement, financial
assets are classified in four categories :

(i) Financial assets at amortised cost (debt
instruments)

A ''financial asset'' is measured at the amortised
cost if both the following conditions are met:

a) The asset is held within a business model
whose objective is to hold assets for
collecting contractual cash flows, and

b) Contractual terms of the asset give rise on
specified dates to cash flows that are solely
payments of principal and interest (SPPI) on
the principal amount outstanding.

After initial measurement, such financial assets
are subsequently measured at amortised cost
using the effective interest rate (EIR) method.
Amortised cost is calculated by taking into
account any discount or premium on acquisition
and fees or costs that are an integral part of the
EIR. The EIR amortisation is included in finance
income in the Statement of Profit and Loss. The
losses arising from impairment are recognised in
the Statement of Profit and Loss. This category
generally applies to trade and other receivables.

(ii) Financial assets at fair value through Other
Comprehensive Income (FVOCI) with recycling of
cumulative gains and losses (debt instruments)

A ''financial asset'' is classified as at the FVOCI if
both of the following criteria are met:

a) The objective of the business model is
achieved both by collecting contractual cash
flows and selling the financial assets, and

b) The asset''s contractual cash flows
represent SPPI.

Debt instruments included within the
FVOCI category are measured initially as
well as at each reporting date at fair value.

For debt instruments, at fair value through
OCI, interest income, foreign exchange
revaluation and impairment losses or
reversals are recognised in the Statement of
Profit and Loss and computed in the same
manner as for financial assets measured
at amortised cost. The remaining fair value
changes are recognised in OCI. Upon
derecognition, the cumulative fair value
changes recognised in OCI is reclassified
from the equity to profit or loss.

(iii) Financial assets at fair value through profit or
loss (FVTPL)

A financial asset which is not classified in any of
the above categories are measured at FVTPL.
Financial assets are reclassified subsequent to
their recognition, if the Company changes its
business model for managing those financial
assets. Changes in business model are made and
applied prospectively from the reclassification
date which is the first day of immediately next
reporting period following the changes in
business model in accordance with principles laid
down under Ind AS 109: Financial Instruments.
Financial assets at fair value through profit or
loss are carried in the Balance Sheet at fair value
with net changes in fair value recognised in the
Statement of Profit and Loss.

Dividends on listed equity investments are
recognised in the Statement of Profit and Loss
when the right of payment has been established.”

(iv) Financial assets designated at fair value through
OCI with no recycling of cumulative gains and
losses upon derecognition (equity instruments)

Upon initial recognition, the Company can elect
to classify irrevocably its equity investments
as equity instruments designated at fair value
through OCI when they meet the definition of
equity under Ind AS 32: Financial Instruments:
Presentation and are not held for trading. The
classification is determined on an instrument-by¬
instrument basis.

Gains and losses on these financial assets are
never recycled to Statement of Profit and Loss.
Dividends are recognised as other income
in the Statement of Profit and Loss when
the right of payment has been established,
except when the Company benefits from such
proceeds as a recovery of part of the cost of
the financial asset, in which case, such gains are
recorded in OCI. Equity instruments designated

at fair value through OCI are not subject to
impairment assessment.

Derecognition

A financial asset (or, where applicable, a part of
a financial asset or part of a Company of similar
financial assets) is primarily derecognised when
the contractual rights to receive cash flows from
the financial asset have expired or it transfers
the financial asset and the transfer qualifies
for derecognition under Ind AS 109. Financial
Instruments”

Impairment of financial assets

The Company recognises an allowance for
expected credit losses (ECLs) for all financial
instruments and receivables not held at fair value
through profit or loss in accordance with Ind AS
109: Financial Instruments. ECLs are based on
the difference between the contractual cash
flows due in accordance with the contract and
all the cash flows that the Company expects to
receive, discounted at an approximation of the
original effective interest rate. The expected
cash flows will include cash flows from the sale of
collateral held or other credit enhancements that
are integral to the contractual terms.

ECLs are recognised in two stages. For credit
exposures for which there has not been a
significant increase in credit risk since initial
recognition, ECLs are provided for credit losses
that result from default events that are possible
within the next 12-months from the reporting
date (a 12-month ECL). For those credit
exposures for which there has been a significant
increase in credit risk since initial recognition,
a loss allowance is required for credit losses
expected over the remaining life of the exposure,
irrespective of the timing of the default (a lifetime
ECL).

For trade receivables and contract assets,
the Company applies a simplified approach in
calculating ECLs. Therefore, the Company does
not track changes in credit risk, but instead
recognises a loss allowance based on lifetime
ECLs at each reporting date. The Company has
established a provision matrix that is based on
its historical credit loss experience, adjusted for
forward-looking factors specific to the debtors
and the economic environment.

For debt instruments at fair value through
OCI, the Company applies the low credit risk
simplification. At every reporting date, the

Company evaluates whether the debt instrument
is considered to have low credit risk using all
reasonable and supportable information that is
available without undue cost or effort. In making
that evaluation, the Company reassesses the
internal credit rating of the debt instrument. In
addition, the Company considers that there has
been a significant increase in credit risk when
contractual payments are more than 30 days
past due.

The Company''s debt instruments at fair value
through OCI comprise solely of quoted bonds
that are graded in the top investment category
(very good and good) by the good credit rating
agency and, therefore, are considered to be
low credit risk investments. It is the Company''s
policy to measure ECLs on such instruments on a
12-month basis. However, when there has been a
significant increase in credit risk since origination,
the allowance will be based on the lifetime ECL.
The Company uses the ratings from the good
credit rating agency both to determine whether
the debt instrument has significantly increased in
credit risk and to estimate ECLs.

The Company considers a financial asset in
default when contractual payments are 90 days
past due. However, in certain cases, the Company
may also consider a financial asset to be in default
when internal or external information indicates
that the Company is unlikely to receive the
outstanding contractual amounts in full before
taking into account any credit enhancements
held by the Company. A financial asset is written
off when there is no reasonable expectation of
recovering the contractual cash flows.

Financial liabilities

Initial recognition and measurement

Financial liabilities are classified, at initial
recognition, as financial liabilities at fair value
through profit or loss, borrowings (net of directly
attributable cost), payables, or as derivatives
designated as hedging instruments in an effective
hedge, as appropriate. Fees of recurring nature
are directly recognised in the Statement of Profit
and Loss as finance cost.

All financial liabilities are recognised initially at
fair value and, in the case of financial liabilities
at amortised cost, net of directly attributable
transaction costs.

The Company''s financial liabilities include trade
and other payables, borrowings including bank

overdrafts, financial guarantee contracts and
derivative financial instruments.

Subsequent measurement

The measurement of financial liabilities depends
on their classification, as described below:

Financial Liabilities at fair value through Profit
and Loss (FVTPL)

Financial liabilities at fair value through profit or
loss include financial liabilities held for trading
and financial liabilities designated upon initial
recognition as at fair value through profit or
loss. Financial liabilities are classified as held for
trading if they are incurred for the purpose of
repurchasing in the near term.

This category also includes derivative financial
instruments entered into by the Company that
are not designated as hedging instruments in
hedge relationships as defined by Ind AS 109:
Financial instruments.

Gains or losses on liabilities held for trading are
recognised in the Statement of Profit and Loss.

Financial liabilities designated upon initial
recognition at fair value through profit and
loss are designated as such at the initial date
of recognition, and only if the criteria in Ind AS
109: Financial instruments are satisfied. For
liabilities designated as FVTPL, fair value gains/
losses attributable to changes in own credit risk
are recognized in OCI. These gains/losses are
not subsequently transferred to the Statement
of Profit and Loss. However, the Company may
transfer the cumulative gain or loss within equity.
All other changes in fair value of such liability are
recognised in the Statement of Profit and Loss.
The Company has designated forward exchange
contracts as at fair value through profit and loss.
For trade and other payables maturing within one
year from the balance sheet date, the carrying
amounts approximate fair value due to the short
maturity of these instruments.

Financial liabilities at amortised cost (loans and
borrowings)

After initial recognition, interest-bearing loans
and borrowings are subsequently measured at
amortised cost using the effective interest rate
(EIR) method. Gains and losses are recognised in
Statement of Profit and Loss when the liabilities
are derecognised as well as through the EIR
amortisation process.

Amortised cost is calculated by taking into
account any discount or premium on acquisition
and fees or costs that are an integral part of the
EIR. The EIR amortisation is included as finance
costs in the Statement of Profit and Loss.

Financial guarantee contracts

Financial guarantee contracts issued by the
Company are those contracts that require a
payment to be made to reimburse the holder
for a loss it incurs because the specified debtor
fails to make a payment when due in accordance
with the terms of a debt instrument. Financial
guarantee contracts are recognised initially as
a liability at fair value, adjusted for transaction
costs that are directly attributable to the issuance
of the guarantee. Subsequently, the liability
is measured at the higher of the amount of
loss allowance determined as per impairment
requirements of Ind AS 109: Financial
instruments and the amount recognised less
cumulative amortisation.

Derecognition

A financial liability is derecognised when the
obligation under the liability is discharged or
cancelled or expires. When an existing financial
liability is replaced by another from the same
lender on substantially different terms, or the
terms of an existing liability are substantially
modified, such an exchange or modification
is treated as the derecognition of the original
liability and the recognition of a new liability. The
difference in the respective carrying amounts is
recognised in the Statement of Profit and Loss.

Offsetting of financial instruments

Financial assets and financial liabilities are offset
and the net amount is reported in the Balance
Sheet if there is a currently enforceable legal right
to offset the recognised amounts and there is an
intention to settle on a net basis, to realise the
assets and settle the liabilities simultaneously.

p. Derivative financial instruments

Initial recognition and subsequent measurement

The Company uses derivative financial instruments,
such as foreign exchange contracts to hedge its
exposure to movements in foreign exchange rates
relating to the underlying transactions. The Company
does not hold derivative financial instruments for
speculation purposes. Such derivative financial
instruments are initially recognised at fair value on
the date on which a derivative contract is entered into

and are subsequently re-measured at fair value and
the resulting profit and loss is taken to the Statement
of Profit and Loss. Derivatives are carried as financial
assets when the fair value is positive and as financial
liabilities when the fair value is negative. Any gains
or losses arising from changes in the fair value of
derivatives are taken directly to Statement of Profit
and Loss.

q. Cash and cash equivalents

Cash and cash equivalent in the Balance Sheet
comprise cash at banks and on hand and short-term
deposits with an original maturity of three months
or less, which are subject to an insignificant risk of
changes in value.

For the purpose of the statement of cash flows, cash
and cash equivalents consist of cash and short-term
deposits, as defined above.

r. Cash dividend distributions to equity holders

The Company recognises a liability to make cash
distributions to equity holders when the distribution
is authorised and the distribution is no longer at the
discretion of the Company. As per the corporate
laws in India, a distribution is authorised when it is
approved by the shareholders.

s. Earnings per share

Basic earnings per share is calculated by dividing the
net profit or loss before OCI for the year attributable
to equity shareholders by the weighted average
number of equity shares outstanding during the year.
For the purpose of calculating diluted earnings per
share, the net profit or loss before OCI for the year
attributable to equity shareholders and the weighted
average number of shares outstanding during the year
are adjusted for the effects of all dilutive potential
equity shares.

t. Operating Segment

Based on the Company''s internal structure and
information reviewed by the Chief Operating Decision
Maker (CODM) to assess the Company''s financial
performance, the Company is engaged solely in the
business of manufacture and sale of Wire and Wire
ropes, steel wires, strands, cords, related accessories,
wire drawing and allied machine, etc. Accordingly, the
Company has a single operating segment, i.e., "Wire &
Wire Ropes”.

u. Use of estimates and critical accounting judgments

The preparation of the financial statements in
conformity with Ind AS requires management to make

judgements, estimates and assumptions that affect
the application of accounting policies and the reported
amounts of assets, liabilities, income, expenses and
disclosures of contingent assets and liabilities at the
date of these financial statements and the reported
amounts of revenues and expenses for the years
presented. Actual results may differ from these
estimates under different assumptions and conditions.

Estimates and underlying assumptions are reviewed
on an ongoing basis. Revisions to accounting estimates
are recognised in the period in which the estimate is
revised and future periods affected.

Uncertainty about these assumptions and estimates
could result in outcomes that require a material
adjustment to the carrying amount of assets or
liabilities affected in next financial years (Refer
note 29).

v. Climate-related matters

The Company considers climate-related matters
in estimates and assumptions, where appropriate.

This assessment includes a wide range of possible
impacts on the Company due to both physical and
transition risks. Even though the Company believes
its business model and products will still be viable
after the transition to a low-carbon economy,
climate-related matters increase the uncertainty in
estimates and assumptions underpinning several
items in the financial statements. Even though climate
related risks might not currently have a significant
impact on measurement, the Company is closely
monitoring relevant changes and developments, such
as new climate-related legislation. The items and
considerations that are most directly impacted by

climate -related matters are:- Useful life of property,
plant and equipment. When reviewing the residual
values and expected useful lives of assets, the
Company considers climate-related matters, such
as climate-related legislation and regulations that
may restrict the use of assets or require significant
capital expenditures.

2B. RECENT ACCOUNTING PRONOUNCEMENTS

New and amended standards

a) The Ministry of Corporate Affairs (MCA)
has notified Companies (Indian Accounting
Standards) Amendment Rules, 2024 to amend
the following Ind AS which are effective for annual
periods beginning on or after 1^st April 2024. The
Company has not early adopted any standard,
interpretation or amendment that has been
issued but is not yet effective.

- Ind AS 116 ‘Leases’ - This amendment specifies
the requirements that a seller-lessee uses in
measuring the lease liability arising in a sale and
leaseback transaction, to ensure the seller-lessee
does not recognise any amount of the gain or loss
that relates to the right of use it retains.

- Ind AS 117 ‘Insurance Contracts’ - It is a

comprehensive new accounting standard which
replaces Ind AS 104 ''Insurance Contracts''.

It applies to all types of insurance contracts,
regardless of the type of entities that issue
them as well as to certain guarantees and
financial instruments with discretionary
participation features.

These amendments had no impact on the
Company''s standalone financial statements.

(b) 1,78,65,450 (31^st March, 2024 : 2,28,65,450) equity shares of face value of Re 1 each are represented by Global
Depository Receipts (GDRs). Each GDR represents five underlying equity shares.

(c) Rights, preference and restrictions attached to equity shares

The Company has only one class of equity shares having par value of Re. 1 per share. Each holder of equity shares is
entitled to one vote per share (except in case of GDRs). The holders of GDRs do not have voting right with respect to
underlying equity shares. Dividend, if proposed, by the Board of Directors is subject to the approval of the shareholders
in the ensuing Annual General Meeting, except in case of interim dividend.

In the event of liquidation of the Company, the holders of equity shares will be entitled to receive residual assets of the
Company, after distribution of all preferential amounts. The distribution will be in proportion to the number of equity
shares held by each shareholder.

Loan covenants

Bank loans contain certain debt covenants relating to net debt to EBITDA, debt service coverage ratio, fixed assets coverage

ratio etc. The Company has complied with all debt covenants stipulated by the terms of bank loan during the year.

EBITDA = Profit before tax Finance cost Depreciation/amortization - Non operating income

Nature of security

(A) Secured by a first pari-passu charge by hypothecation/mortgage over all the property, plant and equipment (present
and future) of the Company.

(B) Secured by a second charge on entire current assets of the Company (present and future), pari-passu with other
term lenders.

(C) Secured by personal guarantee of Managing Director of the Company.

Interest rate and terms of repayment

(a) Rupee term loan from a bank amounting to Rs. 7,119 lakhs (31^st March, 2024: Rs. 9,073 lakhs) is repayable in thirteen
quarterly instalments from 1^st April 2026 to 1^st April 2029. Interest is payable on monthly basis at one-year marginal
cost of fund of the bank plus 0.35% p.a.

(b) As at 31^st March, 2024, rupee term loan from a bank amounting to Rs. 2,772 lakhs is repayable in three quarterly
instalments from 30^th June 2025 to 31^st December 2025. Interest is payable on monthly basis at one-year marginal
cost of fund of the bank plus 0.85% p.a. The same is classified as current maturities during the year as disclosed it in
note 15(i).

(c) As at 31^st March, 2024, rupee term loan from a bank amounting to Rs. 749 lakhs is repayable on 30^th June 2025.
Interest is payable on monthly basis at one-year marginal cost of fund of the bank plus 0.85% p.a. The same is classified
as current maturities during the year as disclosed it in note 15(i).

(d) Outstanding balances of loans and terms of repayment as indicated in (a) to (c) are exclusive of current maturities of
such loans.

Nature of security

(A) Secured by a first charge by hypothecation/mortgage over all the property, plant and equipment (present and future)
of the Company

(B) Secured by a second charge on entire current assets of the Company (present and future), pari-passu with other
term lenders.

(C) Secured by personal guarantee of Managing Director of the Company.

Interest rate and terms of repayment

(a) Rupee term loan from a bank amounting to Rs. 1,654 lakhs (31^st March, 2024: Rs. Nil) is repayable in three quarterly
instalments from 1^st July 2025 to 1^st January 2026. Quarterly instalment due on 1^st April, 2025 amounting to Rs. 300
lakhs was prepaid during the year. Rupee term loan of Rs. 900 lakhs which was due for three quarterly instalments from
1^st July 2024 to 1^st January 2025 was prepaid during the year ended 31^st March 2024. Interest is payable on monthly
basis at one-year marginal cost of fund of the bank plus 0.35% p.a.

(b) Rupee term loan from a bank amounting to Rs. 2,772 lakhs (31^st March, 2024: Rs. Nil) is repayable in three quarterly
instalments from 30^th June 2025 to 31^st December 2025. Rupee term loan amounting to Rs. 2,400 lakhs to be repaid
for four quarterly instalments from 30^th June 2024 to 31^st March 2025 was prepaid during the year ended 31^st March
2024. Interest is payable on monthly basis at one-year marginal cost of fund of the bank plus 0.85% p.a.

28(b). EMPLOYEE SHARE BASED PAYMENT PLANS

The Board of Directors of the Company had approved a Scheme called as "Usha Martin Employee Stock Options Plan - 2024
("ESOP Plan”) in their meeting held on August 12, 2024. Pursuant to the ESOP Plan, the Company has constituted Usha
Martin Employees Welfare Trust (''Trust'') to acquire, hold and allocate/transfer equity shares of the Company to eligible
employees (as defined in the ESOP Plan) from time to time on the terms and conditions specified under the ESOP Plan. The
said trust had purchased, during the financial year 2024-25, Company''s equity shares aggregated to 1,90,500 equity shares
from the secondary open market at cost of Rs. 342.23 per share for which the Company had given loan to trust amounting
to Rs. 652 lakhs. The financial statements of the Trust have been included in the standalone financial statements of the
Company in accordance with the requirements of Ind AS and cost of such treasury shares has been presented as a deduction
in equity share capital of Rs. 2 lakhs (31^st March, 2024: Nil) and in other equity of Rs. 650 lakhs (31^st March, 2024: Nil). Such
number of equity shares (which are lying with trust) have been reduced while computing basic and diluted earnings per share.

29. SIGNIFICANT ACCOUNTING JUDGEMENTS,
ESTIMATES AND ASSUMPTIONS

The preparation of the Ind AS financial statements
requires management to make judgements, estimates
and assumptions that affect the reported amounts and
the disclosures. The Company based its assumptions and
estimates on parameters available when the financial
statements were prepared and these are reviewed at each
Balance Sheet date.

Other disclosures relating to the Company''s exposure to
risks and uncertainties includes:

• Capital management (Refer note 33D)

• Financial risk management objectives and policies (Refei
note 33B)

• Sensitivity analysis disclosures (Refer note 31b)
Estimates and assumptions

The key assumptions concerning the future and other
key sources of estimation uncertainty at the reporting
date, that have a significant risk of causing a material
adjustment to the carrying amounts of assets and
liabilities within the next financial year, are described
below. Existing circumstances and assumptions about
future developments, however, may change due to market
changes or circumstances arising that are beyond the

control of the Company. Such changes are reflected in the
assumptions when they occur.

Useful economic lives of property, plant and equipment
and impairment considerations

Property, plant and equipment are depreciated over their
useful economic lives. Management reviews the useful
economic lives at least once a year and any changes could
affect the depreciation rates prospectively and hence the
carrying values of assets. The Company also reviews its
property, plant and equipment, for possible impairment if
there are events or changes in circumstances that indicate
that carrying values of the assets may not be recoverable.

In assessing the property, plant and equipment for
impairment, factors leading to significant reduction in
profits such as changes in commodity prices, the Company''s
business plans and changes in regulatory environment are
taken into consideration.

Impairment exists when the carrying value of an asset
or cash generating unit exceeds its recoverable amount,
which is the higher of its fair value less costs of disposal
and its value in use. The fair value less costs of disposal
calculation is based on available data from binding sales
transactions, conducted at arm''s length, for similar assets
or observable market prices less incremental costs for
disposing of the asset. The value in use calculation is based
on a DCF model. The carrying value of the assets of a cash

generating unit (CGU) is compared with the recoverable
amount of those assets, that is, the higher of fair value
less costs of disposal and value in use. Recoverable value is
based on the management estimates of commodity prices,
market demand and supply, economic and regulatory
climates, long-term plan, discount rates and other factors.
The recoverable amount is sensitive to the discount rate
used for the DCF model as well as the expected future
cash-inflows and the growth rate used for extrapolation
purposes. Any subsequent changes to cash flow due to
changes in the above mentioned factors could impact the
carrying value of the assets.

The impairment provisions for financial assets are based
on assumptions about risk of default and expected cash
loss rates. The Company uses judgement in making these
assumptions and selecting the inputs to the impairment
calculation, based on Company''s past history, existing
market conditions as well as forward-looking estimates at
the end of each reporting period.

Judgements are required in assessing the recoverability
of overdue trade receivables and determining whether a
provision against those receivables is required. Factors
considered include the credit rating of the counterparty,
the amount and timing of anticipated future payments and
any possible actions that can be taken to mitigate the risk of
non-payment.

Taxes

Deferred tax assets are recognised for deductible
temporary differences and unused tax losses to the extent
that it is probable that taxable profit will be available
against which the losses can be utilised. Significant
management judgement is required to determine the
amount of deferred tax assets that can be recognised,
based upon the likely timing and the level of future taxable
profits and business developments together with future tax
planning strategies.

Defined benefit plans

The cost and the present value of the defined benefit
gratuity plan and long term service award are determined
using actuarial valuations. An actuarial valuation involves
making various assumptions that may differ from
actual developments in the future. These include the
determination of the discount rate, future salary increases
and mortality rates. Due to the complexities involved
in the valuation and its long-term nature, a defined
benefit obligation is highly sensitive to changes in these
assumptions. All assumptions are reviewed at each
reporting date. The parameter most subject to change is
the discount rate. In determining the appropriate discount
rate for plans, the management considers the interest rates
of Government bonds in currencies consistent with the

currencies of the post-employment benefit obligation. The
mortality rate is based on publicly available mortality table.
Those mortality tables tend to change only at interval in
response to demographic changes. Future salary increases
and gratuity increases are based on expected future
inflation rates.

Leases - estimating the incremental borrowing rate

The Company cannot readily determine the interest rate
implicit in the lease, therefore, it uses its incremental
borrowing rate (IBR) to measure lease liabilities. The IBR is
the rate of interest that the Company would have to pay to
borrow over a similar term, and with a similar security, the
funds necessary to obtain an asset of a similar value to the
right-of-use asset in a similar economic environment. The
Company estimates the IBR using observable inputs (such
as market interest rates) when available.

Provisions and contingencies

The assessments undertaken in recognising provisions
and contingencies have been made in accordance with the
applicable Ind AS.

A provision is recognized if, as a result of a past event, the
Company has a present legal or constructive obligation
that can be estimated reliably, and it is probable that an
outflow of economic benefits will be required to settle
the obligation. Where the effect of time value of money
is material, provisions are determined by discounting the
expected future cash flows.

The Company has capital commitments in relation to
various capital projects which are not recognized on the
Balance Sheet. In the normal course of business, contingent
liabilities may arise from litigation and other claims against
the Company. Guarantees are also provided in the normal
course of business. There are certain obligations which
management has concluded, based on all available facts
and circumstances, are not probable of payment or are
very difficult to quantify reliably, and such obligations
are treated as contingent liabilities and disclosed in the
notes but are not reflected as liabilities in the financial
statements. Although there can be no assurance regarding
the final outcome of the legal proceedings in which
the Company is involved, it is not expected that such
contingencies will have a material effect on its financial
position or profitability.

The timing of recognition and quantification of the liability
(including litigations) requires the application of judgement
to existing facts and circumstances, which can be subject to
change. The carrying amounts of provisions and liabilities are
reviewed regularly and revised to take account of changing
facts and circumstances.

Non-current assets held for sale

Assets and liabilities of non-current assets held for sale
are measured at the lower of carrying amount and fair
value less cost to sale. The determination of fair value
less costs to sale include use of management estimates
and assumptions. The fair value has been estimated
using valuation techniques (including income and market
approach) which includes unobservable inputs.

Valuation of inventories

The Company follows suitable provisioning norms for
writing down the value of slow-moving, non-moving and
surplus inventory. This involves various judgements and
assumptions that may differ from actual developments
in the future. Raw materials used in the production are
written down below cost as finished products in which
they will be consumed are expected to be sold below
cost. Inventory which is expected to be sold to third party
is only considered for provision which is computed by
comparing Net realisable value and cost. Net realisable
value represents the estimated selling price for inventories
less all estimated costs of completion and costs necessary
to make the sale.

30. COMMITMENTS AND CONTINGENCIES

A Leases

Company as a lessee

(i) The Company as a lessee has entered into various
lease contracts, which includes lease of land, office
space, employee residential accommodation, guest
house etc. Generally, the Company is restricted from
assigning and subleasing the leased assets. There are
lease contracts that include extension and termination
options. These options are negotiated by management
to provide flexibility in aligning with the Company''s
business needs. Management exercises significant
judgement in determining whether these extension
and termination options are reasonably certain to
be exercised.

The Company has certain leases of office space,
employee residential accommodation, guest house etc
with lease terms of 12 months or less. The Company
applies the ''short-term lease'' and ''lease of low-value
assets'' recognition exemptions for these leases.

Set out below are the net carrying amounts of right-
of-use assets recognised in Balance Sheet and the
movement during the year:

## Includes demand aggregating to Rs. 3,829 lakhs (31^st March, 2024: Rs. 3,829 lakhs) received by the Company towards entry tax in Punjab.
Subsequent to the decision of the Hon’ble Supreme Court of India, vide order dated 11^th November, 2016, upholding the rights of State
Governments to impose entry tax, the Company has filed petitions before the Hon’ble High Court of the aforesaid State on grounds that entry tax
imposed by the State legislation is discriminatory in nature. Pending decisions by the Hon’ble High Court of Punjab, the Company’s obligation, if any,
towards entry tax is not ascertainable. Based on legal opinion obtained, management believes that there will be no resultant adverse impact on the
Company.

@ The Company had given an undertaking to deposit Rs. 1,922 lakhs (31^st March, 2024:Rs. 1,922 lakhs) in six instalments in terms of the order of the
Hon’ble High Court of Jharkhand. Against the same, the Company has deposited an amount of Rs. 1,922 lakhs upto 31^st March, 2020. During the
year ended 31^st March 2025, the Hon’ble High Court of Jharkhand issued an order setting aside the demand of Rs. 2,847 lakhs.

(iv) Others

a) The Company has provided a Letter of Comfort to a bank that has provided credit facilities to its joint venture, Pengg
Usha Martin Wires Private Limited. Such facilities have been utilised to the extent of Rs. 2,510 lakhs as at 31^st March,
2025 (31^st March, 2024: Rs. 1,486 lakhs) by the joint venture company. Vide the letter of comfort, the Company has
provided an undertaking not to dispose off its investment in that joint venture company and to ensure that no losses
are suffered by the lender concerned. The Company has assessed that it is only possible, but not probable, that outflow
of economic resources will be required [Refer note 32(iii)].

b) The Company has provided a Letter of Comfort to a bank that has provided credit facilities to its subsidiary, UM Cables
Limited. Such facilities have been utilised to the extent of Rs. 2,185 lakhs as at 31^st March, 2025 (31^st March, 2024:

Rs. 2,961 lakhs) by the subsidiary company. Vide the letter of comfort, the Company has provided an undertaking

not to dispose off its investment in that subsidiary company and to ensure that no losses are suffered by the lender
concerned. The Company has assessed that it is only possible, but not probable, that outflow of economic resources
will be required [Refer note 32(iii)].

c) The Company has provided a Letter of Comfort to a bank that has provided credit facilities to its subsidiary, Usha
Martin Singapore Pte. Limited. Such facilities have been utilised to the extent of Rs. 3,295 lakhs as at 31^st March, 2025
(31^st March, 2024: Rs. 4,019 lakhs) by the subsidiary company. Vide the letter of comfort, the Company has provided
an undertaking not to dispose off its investment in that subsidiary company and to ensure that no losses are suffered
by the lender concerned. The Company has assessed that it is only possible, but not probable, that outflow of economic
resources will be required [Refer note 32(iii)].

The sensitivity analysis above have been determined based on a method that extrapolates the impact on defined
benefit obligation as a result of reasonable changes in key assumptions occurring at the end of the reporting period.

The sensitivity analysis are based on a change in a significant assumption, keeping all other assumptions constant. The
sensitivity analysis may not be representative of an actual change in the defined benefit obligation as it is unlikely that
changes in assumptions would occur in isolation from one another.

In presenting the above sensitivity analysis, the present value of defined benefit obligation has been calculated using the
project unit credit method at the end of reporting period, which is the same as that applied in calculating the defined
benefit obligation liability recognized in the balance sheet.

K Risk analysis

Company is exposed to a number of risks in the defined benefit plans. Most significant risks pertaining to defined
benefit plans and management''s estimation of the impact of these risks are as follows:

(i) Interest risk

A decrease in the interest rate on plan assets will increase the plan liability.

(ii) Longevity risk/Life expectancy

The present value of the defined benefit plan liability
is calculated by reference to the best estimate of
the mortality of plan participants both during and at
the end of the employment. An increase in the life
expectancy of the plan participants will increase the
plan liability.

(iii) Salary growth risk

The present value of the defined benefit plan liability
is calculated by reference to the future salaries of
plan participants. An increase in the salary of the plan
participants will increase the plan liability.

(iv) Investment risk

The Gratuity plan is funded with Life Insurance
Corporation of India (LIC). The Company does not
have any liberty to manage the fund provided to
LIC. The present value of the defined benefit plan
liability is calculated using a discount rate determined
by reference to Government of India bonds. If the
return on plan asset is below this rate, it will create a
plan deficit.

III Provident Fund

Provident Fund contributions in respect of employees
are made to Trusts administered by the Company
and such Trusts invest funds following a pattern of
investments prescribed by the Government. Both
the employer and the employees contribute to this
Fund and such contributions together with interest
accumulated thereon are payable to employees at
the time of their separation from the Company or
retirement, whichever is earlier. The benefit vests
immediately on rendering of services by the employee.
The interest rate payable to the members of the Trusts
is not lower than the rate of interest declared annually
by the Government under the Employees'' Provident
Funds and Miscellaneous Provisions Act, 1952 and
shortfall, if any, on account of interest is to be made

good by the Company. In terms of the guidance on
implementing Indian Accounting Standard 19 on
Employee Benefits, a provident fund set up by the
Company is treated as a defined benefit plan in view
of the Company''s obligation to meet interest shortfall,
if any.

The Actuary has carried out actuarial valuation of
plan''s liabilities and interest rate guarantee obligations
as at the balance sheet date using projected unit
credit method and deterministic approach as outlined
in the Guidance Note 29 issued by the Institute of
Actuaries of India. Based on such valuation, there is
no future anticipated shortfall with regard to interest
rate obligation of the Company as at the Balance
Sheet date. Further during the period, the Company''s
contribution of Rs. 541 lakhs (31^st March, 2024: Rs.
494 lakhs) to the Provident Fund Trust, has been
expensed under Contribution to provident and other
funds. Disclosures given hereunder are restricted to
the information available as per the Actuary''s report.

Principal actuarial assumptions

Principal actuarial assumptions used to determine the
present value of the defined benefit obligation are
as follows:

The Company enters into derivative financial instruments with various counterparties, principally financial institutions with
investment grade credit ratings. Foreign exchange forward contracts are valued using valuation techniques, which employs
the use of market observable inputs. The most frequently applied valuation techniques include forward pricing model,
using present value calculations. The model incorporate various inputs including the credit quality of counterparties, foreign
exchange spot and forward rates, yield curves of the respective currencies, currency

---

Mar 31, 2024

4B. ASSETS HELD FOR SALE

During the year, Board of Directors of the Company has approved transfer of rights of leasehold land [Gross block: Rs. 218 lakhs (31^st March, 2023: Rs. 218 lakhs); Net block: Rs. 207 lakhs (31^st March, 2023: Rs. 208 lakhs)] and sale of building [Gross block:

Rs. 917 lakhs (31^st March, 2023: Rs. 917 lakhs); Net block: Rs. 585 lakhs (31^st March, 2023: Rs. 611 lakhs)]. Pursuant to the same, these assets have been reclassified and shown under "Assets held for sale" as the management believes that these are available for immediate sale in its present condition.

(b) 2,28,65,450 (31^st March, 2023 : 2,28,65,450) equity shares of face value of Re 1 each are represented by Global Depository Receipts (GDRs). Each GDR represents five underlying equity shares.

(c) Rights, preference and restrictions attached to equity shares

The Company has only one class of equity shares having par value of Re. 1 per share. Each holder of equity shares is entitled to one vote per share (except in case of GDRs). The holders of GDRs do not have voting right with respect to underlying equity shares. Dividend, if proposed, by the Board of Directors is subject to the approval of the shareholders in the ensuing Annual General Meeting, except in case of interim dividend.

In the event of liquidation of the Company, the holders of equity shares will be entitled to receive residual assets of the Company, after distribution of all preferential amounts. The distribution will be in proportion to the number of equity shares held by each shareholder.

Loan covenants

Bank loans contain certain debt covenants relating to net debt to EBITDA, debt service coverage ratio, fixed assets coverage ratio

etc. The Company has complied with all debt covenants stipulated by the terms of bank loan during the year.

EBITDA = Profit before tax Finance cost Depreciation/amortisation - Non operating income

Nature of security

A Secured by a first pari-passu charge by hypothecation/mortgage over all the property, plant and equipment (present and future) of the Company.

B Secured by a second charge on entire current assets of the Company (present and future), pari-passu with other term lenders.

C Secured by personal guarantee of Managing Director of the Company.

Interest rate and terms of repayment

(a) Rupee term loan from a bank amounting to Rs. 9,073 lakhs (31^st March, 2023: Rs. 4450 lakhs) is repayable in seventeen quarterly instalments from 1^st April 2025 to 1^st April 2029. Interest is payable on monthly basis at one-year marginal cost of fund of the bank plus 0.35% p.a.

(b) Rupee term loan from a bank amounting to Rs. 2,772 lakhs (31^st March, 2023: Rs. 5,144 lakhs) is repayable in three quarterly instalments from 30^th June, 2025 to 31^st December, 2025. Interest is payable on monthly basis at one-year marginal cost of fund of the bank plus 0.85% p.a.

(c) Rupee term loan from a bank amounting to Rs. 749 lakhs (31^st March, 2023: Rs.3,460 lakhs) is repayable on 30^th June, 2025. Interest is payable on monthly basis at one-year marginal cost of fund of the bank plus 0.85% p.a.

(d) Outstanding balances of loans and terms of repayment as indicated in (a) to (c) are exclusive of current maturities of such loans. The current maturities of such loans outstanding as at 31^st March 2024 is prepaid during the year as disclosed in Note 16(i).

Nature of security

A Secured by a first charge by hypothecation/mortgage over all the property, plant and equipment (present and future) of the Company

B Secured by a second charge on entire current assets of the Company (present and future), pari-passu with other term lenders.

C Secured by personal guarantee of Managing Director of the Company.

Interest rate and terms of repayment

(a) Rupee term loan from a bank amounting to Rs. 900 lakhs which was due to be repaid for three quarterly instalments from

1^st July 2024 to 1^st Jan 2025 is prepaid during the year. Interest is payable on monthly basis at one-year marginal cost of fund of the bank plus 0.35% p.a.

(b) Rupee term loan from a bank amounting to Rs. 2,400 lakhs which was due to be repaid for four quarterly instalments from 30^th June 2024 to 31^st March 2025 is prepaid during the year. Balance outstanding as at 31^st March, 2023 amounting to Rs.

1,500 lakhs has been repaid during the year. Interest is payable on monthly basis at one-year marginal cost of fund of the bank plus 0.85% p.a.

(C) Rupee term loan from a bank amounting to Rs. 2,750 lakhs which was due to be repaid for four quarterly instalments from 30^th June 2024 to 31^st March 2025 is prepaid during the year. Balance outstanding as at 31^st March, 2023 amounting to Rs. 2,000 lakhs has been repaid during the year. Interest is payable on monthly basis at one-year marginal cost of fund of the bank plus 0.85% p.a.

## The Company has discounted trade receivables on recourse basis. Accordingly, the monies received on this account are shown as borrowings as underlying trade receivable does not meet de-recognition criteria. These bills are discounted @ 7.60% to 8.25% p.a. and are repayable within 180 days.

Year ended 31^st March, 2024

The Company had submitted FFR report for Quarter ended 30^th June, 2023 and 30^th Sept, 2023 during the financial year. There is no material discrepancy between books of accounts and statement filed with the banks.

Subsequently, on the basis of confirmation obtained from the banks, the Company is not required to file quarterly financial follow up report (FFR) with it for availing cash credit facility and working capital loan.

Trade payables are non interest bearing and normally settled up to 180 days terms.

Acceptances represent arrangements whereby banks make direct payments to suppliers of raw materials. The banks are subsequently repaid by the Company at a later date providing working capital timing benefits. Where these arrangements are for raw materials and have a maturity of upto the credit period contracted with the suppliers, the economic substance of the transaction is considered to be operating in nature and included under "Trade payables".

Acceptances payable to banks are secured by hypothecation of all current assets of the Company. Further such acceptances are also secured by charge on certain movable & immovable properties, subject to first charge in favour of financial institutions and banks created/to be created in respect of any existing/future financial assistance/accommodation which has been/may be obtained by the Company. In respect of acceptances from another bank, personal guarantee of Managing Director has been given.

Refer note 33B(b) for explanations on the Company''s liquidity risk management processes.

(iii) Research and development costs that are not eligible for capitalisation have been expensed during the year amounting to

Rs. 636 lakhs (31^st March, 2023 : Rs 580 lakhs), and are recognised in miscellaneous expenses and employee benefits expense.

(iv) In view of the absence of net profits (calculated in the manner as per the provisions of Section 198 of the Companies Act,

2013) over the last three financial years, provisions of Section 135 of the Companies Act, 2013 relating to spending for Corporate Social Responsibility are not applicable to the Company.

29. SIGNIFICANT ACCOUNTING JUDGEMENTS, ESTIMATES AND ASSUMPTIONS

The preparation of the financial statements requires management to make judgements, estimates and assumptions that affect the reported amounts and the disclosures. The Company based its assumptions and estimates on parameters available when the financial statements were prepared and these are reviewed at each Balance Sheet date.

Other disclosures relating to the Company''s exposure to risks and uncertainties includes:

• Capital management (Refer note 33D)

• Financial risk management objectives and policies (Refer note 33B)

• Sensitivity analysis disclosures (Refer note 31b)

Estimates and assumptions

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

Useful economic lives of property, plant and equipment and impairment considerations

Property, plant and equipment are depreciated over their useful economic lives. Management reviews the useful economic lives at least once a year and any changes could affect the depreciation rates prospectively and hence the carrying values of assets. The Company also reviews its property, plant and equipment, for possible impairment if there are events or changes in circumstances that indicate that carrying values of the assets may not be recoverable. In assessing the property, plant and equipment for impairment, factors leading to significant reduction in profits such as changes in commodity prices, the Company''s business plans and changes in regulatory environment are taken into consideration.

Impairment exists when the carrying value of an asset or cash generating unit exceeds its recoverable amount, which is the higher of its fair value less costs of disposal and its value in use. The fair value less costs of disposal calculation is based on available data from binding sales transactions, conducted at arm''s length, for similar assets or observable market prices less incremental costs for disposing of the asset. The value in use calculation is based on a DCF model. The carrying value of the

assets of a cash generating unit (CGU) is compared with the recoverable amount of those assets, that is, the higher of fair value less costs of disposal and value in use. Recoverable value is based on the management estimates of commodity prices, market demand and supply, economic and regulatory climates, long-term plan, discount rates and other factors. The recoverable amount is sensitive to the discount rate used for the DCF model as well as the expected future cash-inflows and the growth rate used for extrapolation purposes. Any subsequent changes to cash flow due to changes in the above mentioned factors could impact the carrying value of the assets.

The impairment provisions for financial assets are based on assumptions about risk of default and expected cash loss rates. The Company uses judgement in making these assumptions and selecting the inputs to the impairment calculation, based on Company''s past history, existing market conditions as well as forward-looking estimates at the end of each reporting period.

Judgements are required in assessing the recoverability of overdue trade receivables and determining whether a provision against those receivables is required. Factors considered include the credit rating of the counterparty, the amount and timing of anticipated future payments and any possible actions that can be taken to mitigate the risk of non-payment.

Taxes

Deferred tax assets are recognised for deductible temporary differences and unused tax losses to the extent that it is probable that taxable profit will be available against which the losses can be utilised. Significant management judgement is required to determine the amount of deferred tax assets that can be recognised, based upon the likely timing and the level of future taxable profits and business developments together with future tax planning strategies.

Defined benefit plans

The cost and the present value of the defined benefit gratuity plan and long term service award are determined using actuarial valuations. An actuarial valuation involves making various assumptions that may differ from actual developments in the future. These include the determination of the discount rate, future salary increases and mortality rates. Due to the complexities involved in the valuation and its long-term nature, a defined benefit obligation is highly sensitive to changes in these assumptions. All assumptions are reviewed at each reporting date. The parameter most subject to change is the discount rate. In determining the appropriate discount rate for plans, the management considers the interest rates of Government bonds in currencies consistent with the currencies of the post-employment benefit obligation.

The mortality rate is based on publicly available mortality table. Those mortality tables tend to change only at interval in response to demographic changes. Future salary increases and gratuity increases are based on expected future inflation rates.

Leases - estimating the incremental borrowing rate

The Company cannot readily determine the interest rate implicit in the lease, therefore, it uses its incremental borrowing rate (IBR) to measure lease liabilities. The IBR is the rate of interest that the Company would have to pay to borrow over a similar term, and with a similar security, the funds necessary to obtain an asset of a similar value to the right-of-use asset in a similar economic environment. The Company estimates the IBR using observable inputs (such as market interest rates) when available.

Provisions and contingencies

The assessments undertaken in recognising provisions and contingencies have been made in accordance with the applicable Ind AS.

A provision is recognised if, as a result of a past event, the Company has a present legal or constructive obligation that can be estimated reliably, and it is probable that an outflow of economic benefits will be required to settle the obligation. Where the effect of time value of money is material, provisions are determined by discounting the expected future cash flows.

The Company has capital commitments in relation to various capital projects which are not recognised on the Balance Sheet. In the normal course of business, contingent liabilities may arise from litigation and other claims against the Company. Guarantees are also provided in the normal course of business. There are certain obligations which management has concluded, based on all available facts and circumstances, are not probable of payment or are very difficult to quantify reliably, and such obligations are treated as contingent liabilities and disclosed in the notes but are not reflected as liabilities in the financial statements. Although there can be no assurance regarding the final outcome of the legal proceedings in which the Company is involved, it is not expected that such contingencies will have a material effect on its financial position or profitability.

The timing of recognition and quantification of the liability (including litigations) requires the application of judgement to existing facts and circumstances, which can be subject to change. The carrying amounts of provisions and liabilities are reviewed regularly and revised to take account of changing facts and circumstances.

Non-current assets held for sale

Assets and liabilities of non-current assets held for sale are measured at the lower of carrying amount and fair value less cost to sale. The determination of fair value less costs to sale include use of management estimates and assumptions. The fair value has been estimated using valuation techniques (including income and market approach) which includes unobservable inputs.

Valuation of inventories

The Company follows suitable provisioning norms for writing down the value of slow-moving, non-moving and surplus inventory. This involves various judgements and assumptions that may differ from actual developments in the future. Raw materials used in the production are written down below cost as finished products in which they will be consumed are expected to be sold below cost. Inventory which is expected to be sold to third party is only considered for provision which is computed by comparing Net realisable value and cost.

Net realisable value represents the estimated selling price for inventories less all estimated costs of completion and costs necessary to make the sale.

30. COMMITMENTS AND CONTINGENCIESA. Leases

Company as a lessee

(i) The Company as a lessee has entered into various lease contracts, which includes lease of land, office space, employee residential accommodation, guest house etc. Generally, the Company is restricted from assigning and subleasing the leased assets. There are lease contracts that include extension and termination options. These options are negotiated by management to provide flexibility in aligning with the Company''s business needs. Management exercises significant judgement in determining whether these extension and termination options are reasonably certain to be exercised.

The Company has certain leases of office space, employee residential accommodation, guest house etc with lease terms of 12 months or less. The Company applies the ''short-term lease'' and ''lease of low-value assets'' recognition exemptions for these leases.

B.	Capital commitments	As at 31st March, 2024	As at 31st March, 2023
Estimated amount of contracts remaining to be executed [net of advances of Rs. 2,836 lakhs (31st March, 2023: Rs. 3,535 lakhs)] on capital account and not provided for		4,821	5,090
C.	Contingent liabilities	As at 31st March, 2024	As at 31st March, 2024
(i)	Guarantees
Loan amount outstanding against corporate guarantee as at year-end [Refer note 32(iii)]
	The Company has given corporate guarantee amounting to Rs 8,341 lakhs (31st March, 2023: Rs 8,217 lakhs) to banks / third parties to secure financial assistance / accommodation extended to subsidiaries.	1,158	1,729
The Company has assessed that it is only possible, but not probable, that outflow of economic resources will be required.

	(All amounts in Rs. lakhs unless stated otherwise)
		As at 31st March, 2024	As at 31st March, 2024
(ii)	Bank guarantees
The Company has given bank guarantees details of which are as below:
	in favour of various parties against various contracts	448	680
The Company has assessed that it is only possible, but not probable, that outflow of economic resources will be required.
(iii)	Claims against the Company not acknowledged as debt#
	Demand for income tax matters	1,672	1,672
	Demand for sales tax, entry tax##	4,145	737
	Demand for excise duty and service tax	1,556	11,692
	Demand for customs duty	1,129	1,129
	Demand for Goods and Service Tax	1,000	574
	Demand for Land revenue	-	295
	Outstanding labour disputes	53	34
	Demand for fuel surcharge matter and delayed payment surcharge pending with appropriate authority	11,294	10,980
	Demand for mining matter pending with High Court of Jharkhand@	2,862	2,862
	Demand for compensation on account of mining and dump /infrastructure/colony established outside approved mining lease area	1,710	1,710
	Demand for financial assurance amount in Escrow account	226	226
	Disputed claims by parties not acknowledged as debt by the Company	3,126	3,126

^#Future cash outflows in respect of the above matters are determinable only on receipt of judgments/decisions pending at various forums/authorities. Based on discussions with the solicitors/favourable decisions in similar cases/legal opinions taken by the Company, the management believes that the Company has a good chance of success in above mentioned matters and hence no provision against these matters is considered necessary.

## Includes demand aggregating to Rs. 3,829 lakhs (31^st March, 2023: Rs. 697 lakhs) received by the Company towards entry tax in Punjab. Subsequent to the decision of the Hon''ble Supreme Court of India, vide order dated 11^th November, 2016, upholding the rights of State Governments to impose entry tax, the Company has filed petitions before the Hon''ble High Court of the aforesaid State on grounds that entry tax imposed by the State legislation is discriminatory in nature. Pending decisions by the Hon''ble High Court of Punjab, the Company''s obligation, if any, towards entry tax is not ascertainable. Based on legal opinion obtained, management believes that there will be no resultant adverse impact on the Company.

@ The Company had given an undertaking to deposit Rs. 1,922 lakhs in six instalments in terms of the order of the Hon''ble High Court of Jharkhand.

Against the same, the Company has deposited an amount of Rs. 1,922 lakhs upto 31^st March, 2020.

(iv) Others

a) The Company has provided a Letter of Comfort to a bank that has provided credit facilities to its joint venture, Pengg Usha Martin Wires Private Limited. Such facilities have been utilised to the extent of Rs. 1,486 lakhs as at 31^st March, 2024 (31^st March, 2023: Rs 3,150 lakhs) by the joint venture company. Vide the letter of comfort, the Company has provided an undertaking not to dispose off its investment in that joint venture company and to ensure that no losses are suffered by the lender concerned. The Company has assessed that it is only possible, but not probable, that outflow of economic resources will be required [Refer note 32(iii)].

b) The Company has provided a Letter of Comfort to a bank that has provided credit facilities to its subsidiary, UM Cables Limited. Such facilities have been utilised to the extent of Rs. 2,961 lakhs as at 31^st March, 2024(31^st March, 2023: Rs 3,890 lakhs) by the subsidiary company. Vide the letter of comfort, the Company has provided an undertaking not to dispose off its investment in that subsidiary company and to ensure that no losses are suffered by the lender concerned. The Company has assessed that it is only possible, but not probable, that outflow of economic resources will be required [Refer note 32(iii)].

c) The Company has provided a Letter of Comfort to a bank that has provided credit facilities to its subsidiary, Usha Martin Singapore Pte. Limited. Such facilities have been utilised to the extent of Rs. 4,019 lakhs as at 31^st March, 2024 (31^st March, 2023: Rs 4,355 lakhs) by the subsidiary company. Vide the letter of comfort, the Company has provided an undertaking not to dispose off its investment in that subsidiary company and to ensure that no losses are suffered by the lender concerned. The Company has assessed that it is only possible, but not probable, that outflow of economic resources will be required [Refer note 32(iii)].

(b) Post employment defined benefit plans

I Gratuity plan

The Company has a defined benefit gratuity plan. Every employee who has completed five years or more of service is entitled to gratuity on terms not less favourable than the provisions of The Payment of Gratuity Act, 1972. The level of benefits provided depends on the member''s length of service and salary at retirement age. The scheme is funded with an insurance company.

II Long service award

Employees of the Company rendering greater than twenty years of service will receive long service award on all causes of exit as per the Company''s policy. The cost of providing benefits under this plan is determined by actuarial valuation using the projected unit credit method by independent qualified actuaries at the year end.

The following tables summarise the components of net benefit expense recognised in the Statement of Profit and Loss and the funded status and amounts recognised in the Balance Sheet for the above defined benefit plans:

H The estimate of future salary increases considered in actuarial valuation, take account of inflation, seniority, promotion and other relevant factors, such as supply and demand in the employment market. The above information is certified by the actuary.

The expected rate of return on plan assets is determined considering several applicable factors, mainly the composition of plan assets held, assessed risks, historical results of return on plan assets and the Company''s policy for plan assets management.

The sensitivity analysis above have been determined based on a method that extrapolates the impact on defined benefit obligation as a result of reasonable changes in key assumptions occurring at the end of the reporting period. The sensitivity analysis are based on a change in a significant assumption, keeping all other assumptions constant. The sensitivity analysis may not be representative of an actual change in the defined benefit obligation as it is unlikely that changes in assumptions would occur in isolation from one another.

In presenting the above sensitivity analysis, the present value of defined benefit obligation has been calculated using the project unit credit method at the end of reporting period, which is the same as that applied in calculating the defined benefit obligation liability recognised in the balance sheet.

K Risk analysis

Company is exposed to a number of risks in the defined benefit plans. Most significant risks pertaining to defined benefit plans and management''s estimation of the impact of these risks are as follows:

(i) Interest risk

A decrease in the interest rate on plan assets will increase the plan liability.

(ii) Longevity risk / Life expectancy

The present value of the defined benefit plan liability is calculated by reference to the best estimate of the mortality of plan participants both during and at the end of the employment. An increase in the life expectancy of the plan participants will increase the plan liability.

(iii) Salary growth risk

The present value of the defined benefit plan liability is calculated by reference to the future salaries of plan participants.

An increase in the salary of the plan participants will increase the plan liability.

(iv) Investment risk

The Gratuity plan is funded with Life Insurance Corporation of India (LIC). The Company does not have any liberty to manage the fund provided to LIC. The present value of the defined benefit plan liability is calculated using a discount rate determined by reference to Government of India bonds. If the return on plan asset is below this rate, it will create a plan deficit.

III Provident Fund

Provident Fund contributions in respect of employees are made to Trusts administered by the Company and such Trusts invest funds following a pattern of investments prescribed by the Government. Both the employer and the employees contribute to this Fund and such contributions together with interest accumulated thereon are payable to employees at the time of their separation from the Company or retirement, whichever is earlier. The benefit vests immediately on rendering of services by the employee. The interest rate payable to the members of the Trusts is not lower than the rate of interest declared annually by the Government under the Employees'' Provident Funds and Miscellaneous Provisions Act, 1952 and shortfall, if any, on account of interest is to be made good by the Company. In terms of the guidance on implementing Indian Accounting Standard 19 on Employee Benefits, a provident fund set up by the Company is treated as a defined benefit plan in view of the Company''s obligation to meet interest shortfall, if any.

The Actuary has carried out actuarial valuation of plan''s liabilities and interest rate guarantee obligations as at the balance sheet date using projected unit credit method and deterministic approach as outlined in the Guidance Note 29 issued by the Institute of Actuaries of India. Based on such valuation, there is no future anticipated shortfall with regard to interest rate obligation of the Company as at the Balance Sheet date. Further during the period, the Company''s contribution Rs 494 lakhs (31^st March, 2023: Rs 428 lakhs) to the Provident Fund Trust, has been expensed under "Contribution to provident and other funds". Disclosures given hereunder are restricted to the information available as per the Actuary''s report.

Terms and conditions of transactions with related parties

The sales to and purchases from related parties are made on terms equivalent to those that prevail in arm''s length transactions with third parties. Outstanding balances at the year-end are unsecured and settlement occurs through normal banking channels. For the year ended 31^st March, 2024 and 31^st March, 2023, the Company has not recorded any impairment of receivables relating to amounts owed by related parties. This assessment is undertaken each financial year through examining the financial position of the related party and the market in which the related party operates.

The Company routinely enters into transactions with these related parties in the ordinary course of business at market rates and terms.

The Company enters into derivative financial instruments with various counterparties, principally financial institutions with investment grade credit ratings. Foreign exchange forward contracts are valued using valuation techniques, which employs the use of market observable inputs. The most frequently applied valuation techniques include forward pricing model, using present value calculations. The model incorporate various inputs including the credit quality of counterparties, foreign exchange spot and forward rates, yield curves of the respective currencies, currency basis spreads between the respective currencies, interest rate curves and forward rate curves of the underlying commodity. As at 31^st March, 2024, the mark-to-market value of other derivative assets / liabilities positions is net of a credit valuation adjustment attributable to derivative counterparty default risk.

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

The following explains the judgements and estimates made in determining the fair values of the financial instruments that are recognised and measured at fair value through profit and loss. To provide an indication about the reliability of the inputs used in determining fair value, the Company has classified its financial investments into the three levels prescribed under the accounting standard.

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

Level 1 hierarchy includes financial instruments measured using quoted prices in active markets for identical assets or liabilities.

Level 2 hierarchy includes the fair value of financial instruments that are not traded in an active market (for example, over-the counter derivatives) and the fair value is determined using valuation techniques which maximise the use of observable market data and rely as little as possible on entity-specific estimates. If all significant inputs required to fair value an instrument are observable, the instrument is included in level 2.

If one or more of the significant inputs is not based on observable market data, the instrument is included in level 3.

There are no transfers between levels 1 and 2 during the year. The Company''s policy is to recognise transfers into and transfers out of fair value hierarchy levels as at the end of the reporting period.

33 B. FINANCIAL RISK MANAGEMENT OBJECTIVES AND POLICIES Risk management framework

The Company''s board of directors has overall responsibility for the establishment and oversight of the Company''s risk management framework. The board of directors has established the Risk Management Committee (RMC) which is responsible for developing and monitoring the Company''s risk management policies.

The Company''s risk management policies are established to identify and analyse the risks faced by the Company, to set appropriate risk limits and control and monitor risks and adherence to limits. Risk management policies and systems are reviewed regularly to reflect changes in market conditions and the Company''s activities.

The Company''s activities expose it to market risk, liquidity risk and credit risk which are measured, monitored and managed to abide by the principles of risk management.

(a) Credit risk

Credit risk refers to the risk of financial loss that may arise from counterparty failure on its contractual obligations resulting in financial loss to the Company. Credit risk encompasses both the direct risk of default and the risk of deterioration of creditworthiness as well as concentration risks.

The Company controls its own exposure to credit risk. All external customers undergo a creditworthiness check. The Company performs an on-going assessment and monitoring of the financial position and the risk of default. Based on the aforesaid checks, monitoring and historical data, the Company does not perceive any significant credit risk on trade receivables. Outstanding customer receivables are regularly monitored and any shipments to major customers are generally covered by letters of credit or other forms of credit insurance obtained from reputable banks and other financial institutions.

In addition, as part of its cash management and credit risk function, the Company regularly evaluates the creditworthiness of financial and banking institutions where it deposits cash and performs trade finance operations. The Company primarily has banking relationships with the public sector, private and large international banks with good credit rating.

Trade Receivable aggregating Rs. 3,012 lakhs (31^st March, 2023: Rs. 7,077 lakhs) from three customers, each contributes to more than 10% of outstanding trade receivables as at 31^st March, 2024.

The maximum exposure to the credit risk at the reporting date is the carrying value of all financial assets amounting to Rs. 61,437 lakhs (31^st March, 2023 : Rs 53,185 lakhs) as disclosed in note 33A(a).

An impairment analysis is performed at each reporting date using a provision matrix to measure expected credit losses.

The provision rates are based on days past due for groupings of various customer segments with similar loss patterns (i.e., by geographical region, product type, customer type and rating, and coverage by letters of credit or other forms of credit insurance). The calculation reflects the probability-weighted outcome, the time value of money and reasonable and supportable information that is available at the reporting date about past events, current conditions and forecasts of future economic conditions. The Company does not hold collateral as security. The letters of credit and other forms of credit insurance are considered integral part of trade receivables and considered in the calculation of impairment. The Company evaluates the concentration of risk with respect to trade receivables and contract assets as low, as its customers are located in several jurisdictions and industries and operate in largely independent markets. Movement in the allowance for credit impaired trade receivables is given in Note 9 (i).

The details of year-end trade receivables which were past due but not impaired as at 31^st March, 2024 and 31^st March, 2023 is given in Note 9(i).

Credit risk from balances with banks is managed by the Company''s treasury department in accordance with the Company''s policy. Investments of surplus funds are made only with approved counterparties and within credit limits assigned to each counterparty. Counterparty credit limits are reviewed by the Company''s Board of Directors on an annual basis, and may be updated throughout the year. The limits are set to minimise the concentration of risks and therefore mitigate financial loss through counterparty''s potential failure to make payments.

Concentrations arise when a number of counterparties are engaged in the same geographical region, or have economic features that would cause their ability to meet contractual obligations to be similarly affected by changes in economic, political or other conditions. Concentrations indicate the relative sensitivity of the Company''s performance to developments affecting a particular industry.

In order to avoid excessive concentrations of risk, the Company''s policies and procedures include specific guidelines to focus on the maintenance of a diversified portfolio. Identified concentrations of credit risks are controlled and managed accordingly.

(b) Liquidity risk

Liquidity risk arises from the Company''s inability to meet its cash flow commitments on the due date. The Company has liquidity risk monitoring processes covering short-term, mid-term and long-term funding. The Company''s objective is to maintain a balance between continuity of funding and flexibility through the use of committed credit facilities and loan funds. Management regularly monitors projected and actual cash flow data, analyses the repayment schedules of the existing financial assets and liabilities and performs annual detailed budgeting procedures coupled with rolling cash flow forecasts.

The amount of guarantees given on behalf of subsidiaries included in note 30C(i) represents the maximum amount the Company could be forced to settle for the full guaranteed amount. Based on the expectation at the end of the reporting period, the Company considers that it is more likely that such an amount will not be payable under the arrangement.

(c) Market risk

Market risk is the risk that the fair value of future cash flows of a financial instrument will fluctuate because of changes in market prices. The Company is exposed to different types of market risks. The market risk is the possibility that changes in foreign currency exchange rates, interest rates and commodity prices may affect the value of the Company''s financial assets, liabilities or expected future cash flows.The fair value information presented below is based on the information available with the management as of the reporting date.

(c.1) Foreign currency exchange risk

Foreign currency risk is the risk that the fair value or future cash flows of an exposure will fluctuate because of changes in foreign exchange rates. Exposures can arise on account of the various assets and liabilities which are denominated in currencies other than Indian Rupee.

The following analysis is based on the gross exposure as at the reporting date which could affect the statement of profit and loss. The exposure is mitigated by some of the derivative contracts entered by the Company as disclosed under the section on "Derivative financial instruments".

(c.2) Interest rate risk

Interest rate risk is the risk that the fair value or future cash flows of a financial instrument will fluctuate because of changes in market interest rates. The Company''s exposure to the risk of changes in market interest rates relates primarily to the Company''s long-term debt obligations with floating interest rates.

Interest rate risk is measured by using the cash flow sensitivity for changes in variable interest rates. Any movement in the reference rates could have an impact on the Company''s cash flows as well as costs. The Company is subject to variable interest rates on some of its interest bearing liabilities. The Company''s interest rate exposure is mainly related to debt obligations. The Company manages its interest rate risk by having a balanced portfolio of fixed and variable rate loans and borrowings.

If the interest rates applicable to floating rate instruments is increased/decreased by 1%, the profit before tax for the year ended 31^st March, 2024 (and corresponding impact on equity) would decrease/(increase) by Rs. 144 lakhs (31^st March,

2023: Rs 188 lakhs) on an annualised basis. This assumes that the amount and mix of fixed and floating rate debt remains unchanged during the year from that in place as at year end.

(c.3) Commodity price risk

The Company''s revenue is exposed to the risk of price fluctuations related to the sale of its wire & wire rope products.

Market forces generally determine prices for such products sold by the Company. These prices may be influenced by factors such as supply and demand, production costs (including the costs of raw material inputs) and global and regional economic conditions and growth. Adverse changes in any of these factors may reduce the revenue that the Company earns from the sale of wire & wire rope products. The Company primarily purchases its raw materials in the open market from third parties. The Company is therefore subject to fluctuations in prices of wire rods, zinc, lead, lubricants, core and other raw material inputs. The Company purchased substantially all of coal requirements from third parties in the open market during the year ended 31^st March, 2024 and 31^st March, 2023 respectively.

The Company does not have any commodity forward contract for Commodity hedging.

The following table details the Company''s sensitivity to a 5% movement in the input price of wire rod and zinc. The sensitivity analysis includes only 5% change in commodity prices for quantity sold or consumed during the year, with all other variables held constant. A positive number below indicates an increase in profit or equity where the commodity prices decrease by 5%. For a 5% increase in commodity prices, there would be a comparable impact on profit or equity, and the balances below are negative.

33 C. DERIVATIVE FINANCIAL INSTRUMENTS

The Company uses derivative instruments as part of its management of exposure to fluctuations in foreign currency exchange rates. All derivative activities for risk management purposes are carried out by specialist teams that have the appropriate skills, experience and supervision. The Company does not acquire or issue derivative financial instruments for trading or speculative purposes. The Company does not enter into complex derivative transactions to manage the treasury risks. Treasury derivative transactions are normally in the form of forward contracts and these are subject to the Company guidelines and policies. The fair values of all derivatives are separately recorded in the balance sheet within current and non-current assets and liabilities. The use of derivatives can give rise to credit and market risk. The Company tries to control credit risk as far as possible by only entering into contracts with reputable banks and financial institutions. The use of derivative instruments is subject to limits,

authorities and regular monitoring by appropriate levels of management. The limits, authorities and monitoring systems are periodically reviewed by management and the Board. The market risk on derivatives is mitigated by changes in the valuation of the underlying assets, liabilities or transactions, as derivatives are used only for risk management purposes.

33D.CAPITAL MANAGEMENT

For the purpose of the Company''s capital management, capital includes issued equity capital and other equity. The Company''s primary capital management objectives are to ensure its ability to continue as a going concern and to optimise the cost of capital in order to enhance value to shareholders.

The Company manages its capital structure and makes adjustments to it as and when required. To maintain or adjust the capital structure, the Company may pay dividend or repay debts, raise new debt or issue new shares. The Company monitors capital using a gearing ratio, which is net debt divided by total capital plus net debt. No major changes were made in the objectives, policies or processes for managing capital during the year ended 31^st March, 2024 and 31^st March, 2023 respectively. The Company includes within net debt, interest bearing loans and borrowings, less cash and cash equivalents as follows:

34(i) The Company was allocated two coal blocks namely, Kathautia Coal Block and Lohari Coal Block in the State of Jharkhand for captive use. Pursuant to the Hon''ble Supreme Courts'' order dated 24^th September, 2014 followed by promulgation of the Coal Mines (Special Provisions) Act, 2015, (CMSP Act), the allocation of all coal blocks since 1993, including the aforesaid coal blocks allocated to the Company were cancelled with effect from 24^th September, 2014 in case of Lohari Coal Block and 1^st April, 2015 in the case of Kathautia Coal Block.

Through the process of public auction as envisaged in the CMSP Act, the aforesaid Coal Blocks had been allocated to other successful bidders by the Central Government. Pursuant to conclusion of such auction, the Central Government had also issued vesting orders for Kathautia and Lohari Coal Blocks for transfer and vesting the Company''s rights, title and interest in and over the land and mine infrastructure of the said coal blocks to the respective successful bidders.

As at 31^st March, 2024, the Company was carrying an aggregate amount of Rs. 1,118 lakhs (net of provision/impairment charge of Rs. 3,734 lakhs) as property, plant and equipment / advance against land, which consists of assets in the form of land, movable and immovable properties, advances etc. as follows:

The Company''s application before the Hon''ble, Delhi High Court for recovery of Rs. 227 lakhs (31^st March, 2023: Rs. 227 lakhs) which after partial recovery and discounting stands at Rs 123 lakhs (31^st March, 2023: Rs. 153 lakhs) as at the year end. Based on its assessment which is supported by a legal opinion obtained, the management is confident of recovery of the amount. Further, the Company is also engaged in ongoing negotiations with the party to whom the aforesaid Coal Blocks were subsequently allotted for realisation of compensation/investments in the mines.

After taking into consideration the reasons as stated above, management is of the opinion that the realisable value of aforesaid assets will not be less than their carrying values

34(ii) Pursuant to the Business Transfer Agreement dated September 22, 2018 (Novation agreement on October 24, 2018) and Supplemental Business Transfer Agreement dated April 7, 2019 and July 3, 2019 respectively with Tata Steel Long Products Limited (TSLPL) [formerly known as Tata Sponge Iron Limited], the Company had transferred its Steel and Bright Bar Business (SBB Business) as a going concern on slump sale basis during a prior year in accordance with the terms and conditions set out in those agreements. An amount of Rs. 7,446 lakhs (net of working capital adjustment of Rs. 627 lakhs) is receivable as at March 31, 2024 in respect of certain parcels of land for which perpetual lease and license agreements had been executed by the Company in favour of TSLPL pending registration of such land in the name of TSLPL.

38. (a) The Directorate of Enforcement ("ED") had issued an order dated 9^th August, 2019 under the provisions of Prevention of Money Laundering Act, 2002 (PMLA) to provisionally attach certain parcels of land at Ranchi, State of Jharkhand being used by the Company for its business for a period of 180 days in connection with export and domestic sale of iron ore fines in prior years aggregating Rs. 19,037 lakhs allegedly in contravention of terms of the mining lease granted to the Company for the iron ore mines situated at Ghatkuri, Jharkhand. The Hon''ble High Court of Jharkhand at Ranchi had, vide order dated February 14, 2012, held that the Company has the right to sell the iron ore including fines as per the terms of the mining lease which was in place at that point in time. The Company had paid applicable royalty and had made necessary disclosures in its returns and reports submitted to mining authorities. In response to the provisional attachment order, the Company had submitted its reply before the Adjudicating Authority (AA). Subsequently, AA had issued an order by way of which the provisional attachment was confirmed under Section 8(3) of PMLA. Thereafter,

the Company filed an appeal before the Appellate Tribunal, New Delhi and successfully obtained a status quo order from the Tribunal on the confirmed attachment order which continues till the next date of hearing that is now fixed on 22^nd May, 2024. The ED had filed a complaint before the District and Sessions Judge Cum Special Judge, Ranchi (Trial Court, Ranchi), pursuant to which summoning orders dated 20^th May, 2021 were issued to the Company and one of its Officers. In response to the said complaint and summons received, the Company had filed a quashing petition before the Hon''ble Jharkhand High Court and a subsequent Special Leave Petition (''SLP'') before the Hon''ble Supreme Court against the order of the Hon''ble Jharkhand High Court dismissing the Company''s quashing petition. Vide interim order dated 15^th December, 2021, the Hon''ble Supreme Court had granted protection to the Company from arrest and stayed the summoning orders issued by the Trial Court, Ranchi. The Hon''ble Supreme Court vide order dated 28^th September, 2022 had dismissed the SLP with the directions to the Company to present all its defences "which are required to be considered and dealt with at the time of trial" before the aforesaid Trial Court, Ranchi. The matter at the Trial Court, Ranchi is scheduled to be heard on 20^th May, 2024.

The ongoing operations of the Company have not been affected by the aforesaid proceedings. Supported by a legal opinion obtained, management believes that the Company has a strong case in its favour on merit and law. Accordingly, no adjustment to these financial statements in this regard have been considered necessary by the management.

(B) On 2^nd October, 2020, Central Bureau of Investigation (CBI) had filed a First Information Report (FIR) against the Company, its Managing Director (MD) and certain Other Officers under the Prevention of Corruption Act, 1988 and the Indian Penal Code, 1860 before the Special Judge, CBI, New Delhi (CBI Court, New Delhi) for allegedly trying to influence ongoing CBI investigation pertaining to the proceedings mentioned in note 38(a) above. Vide order dated 15^th September, 2022, the CBI Court, New Delhi had taken cognizance of the offence based on interim charge sheet filed by the CBI against the Company, its MD and certain Other Officers and has directed the CBI to take such steps as may be necessary to complete the investigation. The Company strongly refutes the aforesaid allegations made by the CBI. The Company has received intimation from the Directorate of Enforcement (ED) regarding summons issued on this matter by the Special Judge, (PC Act) CBI, New Delhi, under the provisions of PMLA and the matter is scheduled to be heard on 27^th April, 2024.

The Company has been providing information sought by the CBI and ED in this regard and intends to continue cooperating, as required by applicable laws and relevant court orders. The Company and its MD are taking such legal measures as considered necessary in respect of these ongoing proceedings. Supported by a legal opinion obtained, management believes that the Company has a strong case in its favour on merit and law in these matters. Accordingly, no adjustment to these financial statements in this regard have been considered necessary by the management.

39 Based on the Company''s internal structure and information reviewed by the Chief Operating Decision Maker to assesses the Company''s financial performance, the Company is engaged solely in the business of manufacture and sale of wire, wire ropes and allied products. Accordingly, the Company has only one operating segment, i.e., "Wire & Wire Ropes".

40 The Company uses an accounting software for maintaining its books of account which has a feature of recording audit trail (edit log) facility and the same has operated throughout the year for all relevant transactions recorded in the software, except that audit trail feature is not enabled for certain changes which can be made using privileged / administrative access rights to the application and / or the underlying database. Further no instance of audit trail feature being tampered with was noted in respect of the accounting software.

42. OTHER STATUTORY INFORMATION

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

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

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

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

(v) The Company has not advanced or loaned or invested funds to any other person(s) or entity(ies), including foreign entities

(Intermediaries) with the understanding that the Intermediary shall:

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

(b) provide any guarantee, security or the like to or on behalf of the Ultimate Beneficiaries

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

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

(b) provide any guarantee, security or the like on behalf of the Ultimate Beneficiaries,

(vii) The Company does not have any transaction which is not recorded in the books of accounts that has been surrendered or disclosed as income during the year in the tax assessments under the Income Tax Act, 1961 (such as, search or survey or any other relevant provisions of the Income Tax Act, 1961).

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Mar 31, 2023

Loan covenants

Bank loans contain certain debt covenants relating to net debt to EBITDA, debt service coverage ratio, fixed assets coverage

ratio etc. The Company has complied with all debt covenants stipulated by the terms of bank loan during the year.

EBITDA = Profit before tax Finance cost Depreciation/amortization - Non operating income

Nature of security

A Secured by a first pari-passu charge by hypothecation/mortgage over all the property, plant and equipment (present and future) of the Company other than the assets exclusively charged in favour of such lenders

B Secured by a second charge on entire current assets of the Company (present and future), pari-passu with other term lenders.

C Secured by personal guarantee of Managing Director of the Company.

D Secured by pledge of promoter''s holding to the extent of 26% equity in the Company on pari-passu basis

Interest rate and terms of repayment

(a) Rupee term loan from a bank amounting to Rs. 4,450 lakhs is repayable in ten quarterly instalments from 1^st July, 2024 to 01^st October, 2026. Interest is payable on monthly basis at one-year marginal cost of fund of the bank plus 0.35% p.a.

(b) Rupee term loan from a bank amounting to Rs. 5,144 lakhs (31^st March, 2022: Rs. 6,644 lakhs) is repayable in seven quarterly instalments from 30^th June, 2024 to 31^st December, 2025. Interest is payable on monthly basis at one-year marginal cost of fund of the bank plus 0.85% p.a.

(c) Rupee term loan from a bank amounting to Rs. 3,460 lakhs (31^st March, 2022: Rs. 5,460 lakhs) is repayable in five quarterly instalments from 30^th June, 2024 to 30^th June, 2025. Interest is payable on monthly basis at one-year marginal cost of fund of the bank plus 0.85% p.a.

Nature of security

A Secured by a first charge by hypothecation/mortgage over all the property, plant and equipment (present and future) of the Company ranking pari-passu with those of other lenders other than the assets exclusively charged in favour of other lenders.

B Secured by a second charge on entire current assets of the Company (present and future), pari-passu with other term lenders.

C Secured by personal guarantee of Managing Director of the Company.

D Secured by pledge of promoter''s holding to the extent of 26% equity in the Company on pari-passu basis.

Interest rate and terms of repayment

(a) Rupee term loan from a bank amounting to Rs. 1,500 lakhs outstanding as on 31^st March 2023 has been subsequently repaid.

(b) Rupee term loan from a bank amounting to Rs. 2,000 lakhs outstanding as on 31^st March 2023 has been subsequently repaid.

The Company is in compliance with filing of quarterly financial follow up report with State Bank of India and ICICI Bank Limited for cash credit facility and working capital loan. The following table provides a reconciliation of statement filed with the above-mentioned banks and books of accounts :

Trade payables are normally settled up to 365 day terms.

Acceptances represent arrangements whereby banks make direct payments to suppliers of raw materials. The banks are subsequently repaid by the Company at a later date providing working capital timing benefits. Where these arrangements are for raw materials and have a maturity of upto the credit period contracted with the suppliers, the economic substance of the transaction is considered to be operating in nature and included under "Trade payables".

Acceptances payable to banks carry interest @ 6.90% p.a. and are secured by hypothecation of all current assets of the Company. Further such acceptances are also secured by charge on certain movable & immovable properties, subject to first charge in favour of financial institutions and banks created/to be created in respect of any existing/future financial assistance/ accommodation which has been/may be obtained by the Company. Further, in respect of acceptances from a bank, these are secured against pledge of promoter''s holding to the extent of 26% equity in the Company on pari-passu basis. In respect of acceptances from another bank, personal guarantee of Managing Director has been given.

Refer note 33B(b) for explanations on the Company''s liquidity risk management processes.

29. Significant accounting judgements, estimates and assumptions

The preparation of the financial statements requires management to make judgements, estimates and assumptions that affect the reported amounts and the disclosures. The Company based its assumptions and estimates on parameters available when the financial statements were prepared and these are reviewed at each Balance Sheet date.

Other disclosures relating to the Company''s exposure to risks and uncertainties includes:

- Capital management (refer note 33D)

- Financial risk management objectives and policies (refer note 33B)

- Sensitivity analysis disclosures (refer note 31J) Judgements

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

(i) Determining the lease term of contracts with renewal and termination options - Company as lessee

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

The Company has several lease contracts that include extension and termination options. The Company applies judgement in evaluating whether it is reasonably certain whether or not to exercise the option to renew or terminate the lease. That is, it considers all relevant factors that create an economic incentive for it to exercise either the renewal or termination. After the commencement date, the Company reassesses the lease term if there is a significant event or change in circumstances that is within its control and affects its ability to exercise or not to exercise the option to renew or to terminate (e.g. construction of significant leasehold improvements or significant customisation to the leased asset).

The Company included the renewal period as part of the lease term for leases of plant and machinery with shorter non-cancellable period (i.e. three to five years). The Company typically exercises its option to renew for these leases because there will be a significant negative effect on production if a replacement asset is not readily available. The renewal periods for leases of plant and machinery with longer non-cancellable periods (i.e. 10 to 15 years) are not included as part of the lease term as these are not reasonably certain to be exercised. Furthermore, the periods covered by termination options are included as part of the lease term only when they are reasonably certain not to be exercised.

Property lease classification - Company as lessor

The Company has determined, based on an evaluation of the terms and conditions of the arrangements, such as the lease term not constituting a major part of the economic life of the commercial property and the present value of the minimum lease payments not amounting to substantially all of the fair value of the commercial property, that it retains substantially all the risks and rewards incidental to ownership of these properties and accounts for the contracts as operating leases.

(ii) Revenue from contracts with customers

The Company applied the judgement of determining method to estimate variable consideration and assessing the constraint that significantly affect the determination of the amount and timing of revenue from contracts with customers.

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

Estimates and assumptions

The key assumptions concerning the future and other

key sources of estimation uncertainty at the reporting

date, that have a significant risk of causing a material

adjustment to the carrying amounts of assets and

liabilities within the next financial year, are described

below. The Company based its assumptions and estimates on parameters available when the financial statements were prepared. Existing circumstances and assumptions about future developments, however, may change due to market changes or circumstances arising that are beyond the control of the Company.

Such changes are reflected in the assumptions when they occur

(i) Useful economic lives of property, plant and equipment and impairment considerations

Property, plant and equipment/intangible assets are depreciated/amortised over their estimated useful life, after taking into account estimated economic residual value. Management reviews the estimated economic useful life and residual values of the assets annually in order to determine the amount of depreciation/amortisation to be recorded during any reporting period. The useful life and residual values are based on the Company''s historical experience with similar assets and take into account anticipated technological changes.

The depreciation/amortisation for future periods is revised if there are significant changes from previous estimates.

The Company also reviews its property, plant and equipment, for possible impairment if there are events or changes in circumstances that indicate that carrying values of the assets may not be recoverable. In assessing the property, plant and equipment for impairment, factors leading to significant reduction in profits such as changes in commodity prices, the Company''s business plans and changes in regulatory environment are taken into consideration.

Impairment exists when the carrying value of an asset or cash generating unit exceeds its recoverable amount, which is the higher of its fair value less costs of disposal and its value in use. The fair value less costs of disposal calculation is based on available data from binding sales transactions, conducted at arm''s length, for similar assets or observable market prices less incremental costs for disposing of the asset. The value in use calculation is based on a DCF model. The carrying value of the assets of a cash generating unit (CGU) is compared with the recoverable amount of those assets, that is, the higher of fair value less costs of disposal and value in use. Recoverable value is based on the management estimates of commodity prices, market demand and supply, economic and regulatory climates, long-term plan, discount rates and other factors. The recoverable amount is sensitive to the discount rate used for the DCF model as well as the expected future cash-inflows and the growth rate

used for extrapolation purposes. Any subsequent changes to cash flow due to changes in the above mentioned factors could impact the carrying value of the assets.

The impairment provisions for financial assets are based on assumptions about risk of default and expected cash loss rates. The Company uses judgement in making these assumptions and selecting the inputs to the impairment calculation, based on Company''s past history, existing market conditions as well as forward-looking estimates at the end of each reporting period.

Judgements are required in assessing the recoverability of overdue trade receivables and determining whether a provision against those receivables is required. Factors considered include the credit rating of the counterparty, the amount and timing of anticipated future payments and any possible actions that can be taken to mitigate the risk of non-payment.

(ii) Taxes

Deferred tax assets are recognised for deductible temporary differences and unused tax losses to the extent that it is probable that taxable profit will be available against which the losses can be utilised. Significant management judgement is required to determine the amount of deferred tax assets that can be recognised, based upon the likely timing and the level of future taxable profits and business developments together with future tax planning strategies.

(iii) Defined benefit plans

The cost and the present value of the defined benefit gratuity plan and long term service award are determined using actuarial valuations. An actuarial valuation involves making various assumptions that may differ from actual developments in the future. These include the determination of the discount rate, future salary increases and mortality rates. Due to the complexities involved in the valuation and its long-term nature, a defined benefit obligation is highly sensitive to changes in these assumptions. All assumptions are reviewed at each reporting date. The parameter most subject to change is the discount rate. In determining the appropriate discount rate for plans, the management considers the interest rates of Government bonds in currencies consistent with the currencies of the post-employment benefit obligation. The mortality rate is based on publicly available mortality table. Those mortality tables tend to change only at interval in response to demographic changes.

Future salary increases and gratuity increases are based on expected future inflation rates.

(iv) Revenue recognition - estimating variable consideration for volume rebates

The Company estimates variable considerations to be included in the transaction price for the sale of goods with volume rebates. Determining whether a customer will be likely entitled to rebate will depend on the customer''s historical rebates entitlement and accumulated purchases to date. Estimates of volume rebates are sensitive to changes in circumstances and the Company''s past experience regarding rebate entitlements may not be representative of customers'' actual rebate entitlements in the future.

(v) Leases - estimating the incremental borrowing rate

The Company cannot readily determine the interest rate implicit in the lease, therefore, it uses its incremental borrowing rate (IBR) to measure lease liabilities. The IBR is the rate of interest that the Company would have to pay to borrow over a similar term, and with a similar security, the funds necessary to obtain an asset of a similar value to the right-of-use asset in a similar economic environment. The Company estimates the IBR using observable inputs (such as market interest rates) when available.

(vi) Provisions and contingencies

The assessments undertaken in recognising provisions and contingencies have been made in accordance with the applicable Ind AS.

A provision is recognized if, as a result of a past event, the Company has a present legal or constructive obligation that can be estimated reliably, and it is probable that an outflow of economic benefits will be required to settle the obligation. Where the effect of time value of money is material, provisions are determined by discounting the expected future cash flows.

The Company has capital commitments in relation to various capital projects which are not recognized on the Balance Sheet. In the normal course of business, contingent liabilities may arise from litigation and other claims against the Company. Guarantees are also provided in the normal course of business. There are certain obligations which management has concluded, based on all available facts and circumstances, are not probable of payment or are very difficult to quantify reliably, and such obligations are treated as contingent liabilities and disclosed in the notes but are not reflected

as liabilities in the financial statements. Although there can be no assurance regarding the final outcome of the legal proceedings in which the Company is involved, it is not expected that such contingencies will have a material effect on its financial position or profitability.

The timing of recognition and quantification of the liability (including litigations) requires the application of judgement to existing facts and circumstances, which can be subject to change. The carrying amounts of provisions and liabilities are reviewed regularly and revised to take account of changing facts and circumstances.

(vii) Non-current assets held for sale

Assets and liabilities of non-current assets held for sale are measured at the lower of carrying amount and fair value less cost to sale. The determination of fair value less costs to sale include use of management estimates and assumptions. The fair value has been estimated using valuation techniques (including income and market approach) which includes unobservable inputs.

(viii) Valuation of Inventories

The Company follows suitable provisioning norms for writing down the value of slow-moving, non-moving and surplus inventory. This involves various judgements and assumptions that may differ from actual developments in the future.

30. Commitments and contingencies A. Leases Company as a lessee

(i) The Company as a lessee has entered into various lease contracts, which includes lease of land, office space, employee residential accommodation, guest house etc. Generally, the Company is restricted from assigning and subleasing the leased assets. There are lease contracts that include extension and termination options. These options are negotiated by management to provide flexibility in aligning with the Company''s business needs. Management exercises significant judgement in determining whether these extension and termination options are reasonably certain to be exercised.

The Company has certain leases of office space, employee residential accommodation, guest house etc with lease terms of 12 months or less. The Company applies the ''short-term lease'' and ''lease of low-value assets'' recognition exemptions for these leases.

C.	Contingent liabilities
		As at 31st March, 2023	As at 31st March, 2022
(i)	Guarantees
	Loan amount outstanding against corporate guarantee as at year-end The Company has given corporate guarantee amounting to Rs. 8,217 lakhs (31st March, 2022: Rs. 7,579 lakhs) to banks / third parties to secure financial assistance / accommodation extended to subsidiaries.	1,729	5,497
	The Company has assessed that it is only possible, but not probable, that outflow of economic resources will be required. [refer note 32(iii)].
(ii)	Bank guarantees
	The Company has given bank guarantees details of which are as below: in favour of various parties against various contracts	680	633
	The Company has assessed that it is only possible, but not probable, that outflow of economic resources will be required.

	As at 31st March, 2023	As at 31st March, 2022
(iii) Claims against the Company not acknowledged as debt #
Demand for income tax matters	1,672	1,672
Demand for sales tax, entry tax ##	737	2,827
Demand for excise duty and service tax	11,692	12,627
Demand for customs duty	1,129	1,129
Demand for Goods and Service Tax	574	1,017
Demand for Land revenue	295	295
Outstanding labour disputes	34	28
Demand for fuel surcharge matter and delayed payment surcharge pending with appropriate authority	10,980	10,980
Demand for mining matter pending with High Court of Jharkhand@	2,862	2,862
Demand for compensation on account of mining and dump /infrastructure/colony established outside approved mining lease area	1,710	1,710
Demand for financial assurance amount in Escrow account	226	226
Disputed claims by parties not acknowledged as debt by the Company	3,126	3,006

# Future cash outflows in respect of the above matters are determinable only on receipt of judgments/decisions pending at various forums/authorities. Based on discussions with the solicitors/favourable decisions in similar cases/legal opinions taken by the Company, the management believes that the Company has a good chance of success in above mentioned matters and hence no provision against these matters is considered necessary.

## Includes demand aggregating to Rs. 697 lakhs (31^st March, 2022: Rs. 697 lakhs) received by the Company towards entry tax in Punjab. Subsequent to the decision of the Hon''ble Supreme Court of India, vide order dated 11^th November, 2016, upholding the rights of State Governments to impose entry tax, the Company has filed petitions before the Hon''ble High Courts of the aforesaid States and also Jharkhand on grounds that entry tax imposed by respective State legislations is discriminatory in nature. The Hon''ble West Bengal Taxation Tribunal vide order dated 25.03.2022 had specifically held that “the State Legislature is denuded of its plenary power to deal with Entry tax related matters on and from 16^th September 2016 when Constitution (101^st Amendment) Act 2016 came into effect, and thereby the revalidation of Entry Tax by West Bengal State Govt on Entry of Goods into Local Area cannot be sustained. Pending decisions by the Hon''ble High Court of Jharkhand, the Company''s obligation, if any, towards entry tax is not ascertainable. Based on legal opinion obtained, management believes that there will be no resultant adverse impact on the Company.

@ The Company had given an undertaking to deposit Rs. 1,922 lakhs in six instalments in terms of the order of the Hon''ble High Court of Jharkhand. Against the same, the Company has deposited an amount of Rs. 1,922 lakhs upto 31^st March, 2020.

(iv) Others

a) The Company has provided a Letter of Comfort to a bank that has provided credit facilities to its joint venture, Pengg Usha Martin Wires Private Limited. Such facilities have been utilised to the extent of Rs. 3,150 lakhs as at 31^st March, 2023 (31^st March, 2022: Rs. 3,818 lakhs) by the joint venture company. Vide the letter of comfort, the Company has provided an undertaking not to dispose off its investment in that joint venture company and to ensure that no losses are suffered by the lender concerned. The Company has assessed that it is only possible, but not probable, that outflow of economic resources will be required [refer note 32(iii)].

b) The Company has provided a Letter of Comfort to a bank that has provided credit facilities to its subsidiary, UM Cables Limited. Such facilities have been utilised to the extent of Rs. 3,890 lakhs as at 31^st March, 2023(31^st March, 2022: Rs 3,437 lakhs) by the subsidiary company. Vide the letter of comfort, the Company has provided an undertaking not to dispose

off its investment in that subsidiary company and to ensure that no losses are suffered by the lender concerned. The Company has assessed that it is only possible, but not probable, that outflow of economic resources will be required [refer note 32(iii)].

c) The Company has provided a Letter of Comfort to a bank that has provided credit facilities to its subsidiary, Usha Martin Singapore Pte. Limited. Such facilities have been utilised to the extent of Rs. 4,355 lakhs as at 31^st March, 2023 (31^st March, 2022: Rs. 4,017 lakhs) by the subsidiary company. Vide the letter of comfort, the Company has provided an undertaking not to dispose off its investment in that subsidiary company and to ensure that no losses are suffered by the lender concerned. The Company has assessed that it is only possible, but not probable, that outflow of economic resources will be required [refer note 32(iii)].

(b) Post employment defined benefit plans

I Gratuity plan

The Company has a defined benefit gratuity plan. Every employee who has completed five years or more of service is entitled to gratuity on terms not less favourable than the provisions of The Payment of Gratuity Act, 1972. The level of benefits provided depends on the member''s length of service and salary at retirement age. The scheme is funded with an insurance company.

II Long service award

Employees of the Company rendering greater than twenty years of service will receive long service award on all causes of exit as per the Company''s policy. The cost of providing benefits under this plan is determined by actuarial valuation using the projected unit credit method by independent qualified actuaries at the year end.

The following tables summarise the components of net benefit expense recognised in the Statement of Profit and Loss and the funded status and amounts recognised in the Balance Sheet for the above defined benefit plans:

H. The estimates of future salary increases considered in actuarial valuation, take account of inflation, seniority, promotion and other relevant factors, such as supply and demand in the employment market. The above information is certified by the actuary.

The expected rate of return on plan assets is determined considering several applicable factors, mainly the composition of plan assets held, assessed risks, historical results of return on plan assets and the Company''s policy for plan assets management.

The sensitivity analysis above have been determined based on a method that extrapolates the impact on defined benefit obligation as a result of reasonable changes in key assumptions occurring at the end of the reporting period. The sensitivity analysis are based on a change in a significant assumption, keeping all other assumptions constant. The sensitivity analysis may not be representative of an actual change in the defined benefit obligation as it is unlikely that changes in assumptions would occur in isolation from one another.

In presenting the above sensitivity analysis, the present value of defined benefit obligation has been calculated using the project unit credit method at the end of reporting period, which is the same as that applied in calculating the defined benefit obligation liability recognized in the balance sheet.

K. Risk analysis

Company is exposed to a number of risks in the defined benefit plans. Most significant risks pertaining to defined benefit plans and management''s estimation of the impact of these risks are as follows:

(i) Interest risk

A decrease in the interest rate on plan assets will increase the plan liability.

(ii) Longevity risk / Life expectancy

The present value of the defined benefit plan liability is calculated by reference to the best estimate of the mortality of plan participants both during and at the end of the employment. An increase in the life expectancy of the plan participants will increase the plan liability.

(iii) Salary growth risk

The present value of the defined benefit plan liability is calculated by reference to the future salaries of plan participants. An increase in the salary of the plan participants will increase the plan liability.

(iv) Investment risk

The Gratuity plan is funded with Life Insurance Corporation of India (LIC). The Company does not have any liberty to manage the fund provided to LIC. The present value of the defined benefit plan liability is calculated using a discount rate determined by reference to Government of India bonds. If the return on plan asset is below this rate, it will create a plan deficit.

III Provident Fund

Provident Fund contributions in respect of employees are made to Trusts administered by the Company and such Trusts invest funds following a pattern of investments prescribed by the Government. Both the employer and the employees contribute to this Fund and such contributions together with interest accumulated thereon are payable to employees at the time of their separation from the Company or retirement, whichever is earlier. The benefit vests immediately on rendering of services by the employee. The interest rate payable to the members of the Trusts is not lower than the rate of interest declared annually by the Government under the Employees'' Provident Funds and Miscellaneous Provisions Act, 1952 and shortfall, if any, on account of interest is to be made good by the Company. In terms of the guidance on implementing Indian Accounting Standard 19 on Employee Benefits, a provident fund set up by the Company is treated as a defined benefit plan in view of the Company''s obligation to meet interest shortfall, if any.

The Actuary has carried out actuarial valuation of plan''s liabilities and interest rate guarantee obligations as at the balance sheet date using projected unit credit method and deterministic approach as outlined in the Guidance Note 29 issued by the Institute of Actuaries of India. Based on such valuation, there is no future anticipated shortfall with regard to interest rate obligation of the Company as at the Balance Sheet date. Further during the period, the Company''s contribution Rs. 428 lakhs (31^st March, 2022: Rs. 387 lakhs) to the Provident Fund Trust, has been expensed under "Contribution to provident and other funds". Disclosures given hereunder are restricted to the information available as per the Actuary''s report.

Terms and conditions of transactions with related parties

The sales to and purchases from related parties are made on terms equivalent to those that prevail in arm''s length transactions with third parties. Outstanding balances at the year-end are unsecured and settlement occurs through normal banking channels. For the year ended 31^st March, 2023 and 31^st March, 2022, the Company has not recorded any impairment of receivables relating to amounts owed by related parties. This assessment is undertaken each financial year through examining the financial position of the related party and the market in which the related party operates.

The Company routinely enters into transactions with these related parties in the ordinary course of business at market rates and terms.

The Company enters into derivative financial instruments with various counterparties, principally financial institutions with investment grade credit ratings. Foreign exchange forward contracts are valued using valuation techniques, which employs the use of market observable inputs. The most frequently applied valuation techniques include forward pricing model, using present value calculations. The model incorporate various inputs including the credit quality of counterparties, foreign exchange spot and forward rates, yield curves of the respective currencies, currency basis spreads between the respective currencies, interest rate curves and forward rate curves of the underlying commodity. As at 31^st March, 2023, the mark-to-market value of other derivative assets / liabilities positions is net of a credit valuation adjustment attributable to derivative counterparty default risk.

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

The following explains the judgements and estimates made in determining the fair values of the financial instruments that are recognised and measured at fair value through profit and loss. To provide an indication about the reliability of the inputs used in determining fair value, the Company has classified its financial investments into the three levels prescribed under the accounting standard.

Notes:

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

Level 1 hierarchy includes financial instruments measured using quoted prices in active markets for identical assets or liabilities.

Level 2 hierarchy includes the fair value of financial instruments that are not traded in an active market (for example, over-the counter derivatives) and the fair value is determined using valuation techniques which maximise the use of observable market data and rely as little as possible on entity-specific estimates. If all significant inputs required to fair value an instrument are observable, the instrument is included in level 2.

If one or more of the significant inputs is not based on observable market data, the instrument is included in level 3.

There are no transfers between levels 1 and 2 during the year. The Company''s policy is to recognise transfers into and transfers out of fair value hierarchy levels as at the end of the reporting period.

33B. Financial risk management objectives and policiesRisk management framework

The Company''s board of directors has overall responsibility for the establishment and oversight of the Company''s risk management framework. The board of directors has established the Risk Management Committee (RMC) which is responsible for developing and monitoring the Company''s risk management policies.

The Company''s risk management policies are established to identify and analyse the risks faced by the Company, to set appropriate risk limits and control and monitor risks and adherence to limits. Risk management policies and systems are reviewed regularly to reflect changes in market conditions and the Company''s activities.

The Company''s activities expose it to market risk, liquidity risk and credit risk which are measured, monitored and managed to abide by the principles of risk management.

(a) Credit risk

Credit risk refers to the risk of financial loss that may arise from counterparty failure on its contractual obligations resulting in financial loss to the Company. Credit risk encompasses both the direct risk of default and the risk of deterioration of creditworthiness as well as concentration risks.

The Company controls its own exposure to credit risk. All external customers undergo a creditworthiness check. The Company performs an on-going assessment and monitoring of the financial position and the risk of default. Based on the aforesaid checks, monitoring and historical data, the Company does not perceive any significant credit risk on trade receivables. Outstanding customer receivables are regularly monitored and any shipments to major customers are generally covered by letters of credit or other forms of credit insurance obtained from reputable banks and other financial institutions.

In addition, as part of its cash management and credit risk function, the Company regularly evaluates the creditworthiness of financial and banking institutions where it deposits cash and performs trade finance operations. The Company primarily has banking relationships with the public sector, private and large international banks with good credit rating.

Trade Receivable aggregating Rs. 7,077 lakhs (31^st March, 2022: Rs. 8,078 lakhs) from two customers, each contributes to more than 10% of outstanding trade receivables as at 31^st March, 2023.

The maximum exposure to the credit risk at the reporting date is the carrying value of all financial assets amounting to Rs. 53,185 lakhs (31^st March, 2022 : Rs. 64,179 lakhs) as disclosed in note 33A(a).

An impairment analysis is performed at each reporting date using a provision matrix to measure expected credit losses. The provision rates are based on days past due for groupings of various customer segments with similar loss patterns (i.e., by geographical region, product type, customer type and rating, and coverage by letters of credit or other forms of credit insurance). The calculation reflects the probability-weighted outcome, the time value of money and reasonable and supportable information that is available at the reporting date about past events, current conditions and forecasts of future economic conditions. The Company does not hold collateral as security. The letters of credit and other forms of credit insurance are considered integral part of trade receivables and considered in the calculation of impairment. The Company evaluates the concentration of risk with respect to trade receivables and contract assets as low, as its customers are located in several jurisdictions and industries and operate in largely independent markets. Movement in the allowance for credit impaired trade receivables is given in Note 9 (i).

The details of year-end trade receivables which were past due but not impaired as at 31^st March, 2023 and 31^st March, 2022 is given in Note 9(i).

Credit risk from balances with banks is managed by the Company''s treasury department in accordance with the Company''s policy. Investments of surplus funds are made only with approved counterparties and within credit limits assigned to each counterparty. Counterparty credit limits are reviewed by the Company''s Board of Directors on an annual basis, and may be updated throughout the year. The limits are set to minimise the concentration of risks and therefore mitigate financial loss through counterparty''s potential failure to make payments.

Concentrations arise when a number of counterparties are engaged in the same geographical region, or have economic features that would cause their ability to meet contractual obligations to be similarly affected by changes in economic, political or other conditions. Concentrations indicate the relative sensitivity of the Company''s performance to development! affecting a particular industry.

In order to avoid excessive concentrations of risk, the Company''s policies and procedures include specific guidelines to focus on the maintenance of a diversified portfolio. Identified concentrations of credit risks are controlled and managed accordingly.

(b) Liquidity risk

Liquidity risk arises from the Company''s inability to meet its cash flow commitments on the due date. The Company has liquidity risk monitoring processes covering short-term, mid-term and long-term funding. The Company''s objective is to maintain a balance between continuity of funding and flexibility through the use of committed credit facilities and loan funds. Management regularly monitors projected and actual cash flow data, analyses the repayment schedules of the existing financial assets and liabilities and performs annual detailed budgeting procedures coupled with rolling cash flow forecasts.

The amount of guarantees given on behalf of subsidiaries included in note 30C(i) represents the maximum amount the Company could be forced to settle for the full guaranteed amount. Based on the expectation at the end of the reporting period, the Company considers that it is more likely that such an amount will not be payable under the arrangement.

(c) Market risk

Market risk is the risk that the fair value of future cash flows of a financial instrument will fluctuate because of changes in market prices. The Company is exposed to different types of market risks. The market risk is the possibility that changes in foreign currency exchange rates, interest rates and commodity prices may affect the value of the Company''s financial assets, liabilities or expected future cash flows.The fair value information presented below is based on the information available with the management as of the reporting date.

(c.1) Foreign currency exchange risk

Foreign currency risk is the risk that the fair value or future cash flows of an exposure will fluctuate because of changes in foreign exchange rates. Exposures can arise on account of the various assets and liabilities which are denominated in currencies other than Indian Rupee

A reasonably possible strengthening/weakening of the Indian Rupee against such foreign currency (converted to US Dollars) as at 31^st March, 2023 and 31^st March, 2022 would have affected profit and loss by the amounts shown below. This analysis assumes that all other variables remain constant and ignores any impact of forecasted sales and purchases.

(c.2) Interest rate risk

Interest rate risk is the risk that the fair value or future cash flows of a financial instrument will fluctuate because of changes in market interest rates. The Company''s exposure to the risk of changes in market interest rates relates primarily to the Company''s long-term debt obligations with floating interest rates.

Interest rate risk is measured by using the cash flow sensitivity for changes in variable interest rates. Any movement in the reference rates could have an impact on the Company''s cash flows as well as costs. The Company is subject to variable interest rates on some of its interest bearing liabilities. The Company''s interest rate exposure is mainly related to debt obligations. The Company manages its interest rate risk by having a balanced portfolio of fixed and variable rate loans and borrowings.

If the interest rates applicable to floating rate instruments is increased/decreased by 1%, the profit before tax for the year ended 31^st March, 2023 (and corresponding impact on equity) would decrease/(increase) by Rs. 188 lakhs (31^st March, 2022: Rs. 238 lakhs) on an annualised basis. This assumes that the amount and mix of fixed and floating rate debt remains unchanged during the year from that in place as at year end.

(c.3) Commodity price risk

The Company''s revenue is exposed to the risk of price fluctuations related to the sale of its wire & wire rope products. Market forces generally determine prices for such products sold by the Company. These prices may be influenced by factors such as supply and demand, production costs (including the costs of raw material inputs) and global and regional economic conditions and growth. Adverse changes in any of these factors may reduce the revenue that the Company earns from the sale of wire & wire rope products.

The Company primarily purchases its raw materials in the open market from third parties. The Company is therefore subject to fluctuations in prices of wire rods, zinc, lead, lubricants, core and other raw material inputs. The Company purchased substantially all of coal requirements from third parties in the open market during the year ended 31^st March, 2023 and 31^st March, 2022 respectively.

The Company does not have any commodity forward contract for Commodity hedging.

The following table details the Company''s sensitivity to a 5% movement in the input price of wire rod and zinc. The sensitivity analysis includes only 5% change in commodity prices for quantity sold or consumed during the year, with all other variables held constant. A positive number below indicates an increase in profit or equity where the commodity prices decrease by 5%. For a 5% increase in commodity prices, there would be a comparable impact on profit or equity, and the balances below are negative.

33 C. Derivative Financial Instruments

The Company uses derivative instruments as part of its management of exposure to fluctuations in foreign currency exchange rates. All derivative activities for risk management purposes are carried out by specialist teams that have the appropriate skills, experience and supervision. The Company does not acquire or issue derivative financial instruments for trading or speculative purposes. The Company does not enter into complex derivative transactions to manage the treasury risks. Treasury derivative transactions are normally in the form of forward contracts and these are subject to the Company guidelines and policies. The fair values of all derivatives are separately recorded in the balance sheet within current and non-current assets and liabilities. The use of derivatives can give rise to credit and market risk. The Company tries to control credit risk as far as possible by only entering into contracts with reputable banks and financial institutions. The use of derivative instruments is subject to limits, authorities and regular monitoring by appropriate levels of management. The limits, authorities and monitoring systems are periodically reviewed by management and the Board. The market risk on derivatives is mitigated by changes in the valuation of the underlying assets, liabilities or transactions, as derivatives are used only for risk management purposes.

33 D. Capital management

For the purpose of the Company''s capital management, capital includes issued equity capital and other equity. The Company''s primary capital management objectives are to ensure its ability to continue as a going concern and to optimize the cost of capital in order to enhance value to shareholders.

The Company manages its capital structure and makes adjustments to it as and when required. To maintain or adjust the capital structure, the Company may pay dividend or repay debts, raise new debt or issue new shares. The Company monitors capital using a gearing ratio, which is net debt divided by total capital plus net debt. No major changes were made in the objectives, policies or processes for managing capital during the year ended 31^st March, 2023 and 31^st March, 2022 respectively. The Company includes within net debt, interest bearing loans and borrowings, less cash and cash equivalents as follows:

34(i) The Company was allocated two coal blocks namely, Kathautia Coal Block and Lohari Coal Block in the State of Jharkhand for captive use. Pursuant to the Hon''ble Supreme Courts'' order dated 24^th September, 2014 followed by promulgation of the Coal Mines (Special Provisions) Act, 2015, (CMSP Act), the allocation of all coal blocks since 1993, including the aforesaid coal blocks allocated to the Company were cancelled with effect from 24^th September, 2014 in case of Lohari Coal Block and 1^st April, 2015 in the case of Kathautia Coal Block.

Through the process of public auction as envisaged in the CMSP Act, the aforesaid Coal Blocks had been allocated to other successful bidders by the Central Government. Pursuant to conclusion of such auction, the Central Government had also issued vesting orders for Kathautia and Lohari Coal Blocks for transfer and vesting the Company''s rights, title and interest in and over the land and mine infrastructure of the said coal blocks to the respective successful bidders.

As on 31^st March, 2022 the Company was carrying an aggregate amount of Rs. 1,314 lakhs (net of provision/impairment charge of Rs. 3,704 lakhs) as assets held for sale/ advance against land, which consists of assets in the form of land, movable and immovable properties, advances etc. as follows:

The Company''s application before the Hon''ble, Delhi High Court for recovery of Rs. 227 lakhs (31^st March, 2022: Rs. 227 lakhs) which after partial recovery and discounting stands at Rs. 153 lakhs (31^st March, 2022: Rs. 183 lakhs) as at the year end. Based on its assessment which is supported by a legal opinion obtained, the management is confident of recovery of the amount. Further, the Company is also engaged in ongoing negotiations with the party to whom the aforesaid Coal Blocks were subsequently allotted for realization of compensation/investments in the mines.

After taking into consideration the reasons as stated above, management is of the opinion that the realizable value of aforesaid assets will not be less than their carrying values.

34(ii). Discontinued operation

Pursuant to the Business Transfer Agreement dated September 22, 2018 (Novation agreement on October 24, 2018) and Supplemental Business Transfer Agreement dated April 7, 2019 and July 3, 2019 respectively with Tata Steel Long Products Limited (TSLPL) [formerly known as Tata Sponge Iron Limited], the Company had transferred its Steel and Bright Bar Business (SBB Business) as a going concern on slump sale basis during a prior year in accordance with the terms and conditions set out in those agreements. During the year, the Company has received Rs. 1,283 lakhs (for the year ended March 31, 2022: Rs. 5,418 lakhs) on transfer of certain parcels of land in the name of TSLPL. The balance amount receivable as at year ended March 31, 2023 is Rs. 8,073 lakhs in respect of certain parcels of land for which perpetual lease and license agreements had been executed by the Company in favour of TSLPL pending registration of such land in the name of TSLPL.

38. (a) The Directorate of Enforcement ("ED") had issued an order dated August 9, 2019 under the provisions of Prevention of Money Laundering Act, 2002 (PMLA) to provisionally attach certain parcels of land at Ranchi, State of Jharkhand being used by the Company for its business for a period of 180 days in connection with export and domestic sale of iron ore fines in prior years aggregating Rs. 19,037 lakhs allegedly in contravention of terms of the mining lease granted to the Company for the iron ore mines situated at Ghatkuri, Jharkhand. The Hon''ble High Court of Jharkhand at Ranchi had, vide order dated February 14, 2012, held that the Company has the right to sell the iron ore including fines as per the terms of the mining lease which was in place at that point in time. The Company had paid applicable royalty and had made necessary disclosures in its returns and reports submitted to mining authorities. In response to the provisional attachment order, the Company had submitted its reply before the Adjudicating Authority (AA). Subsequently, AA had issued an order by way of which the provisional attachment was confirmed under Section 8(3) of PMLA. Thereafter, the Company filed an appeal before the Appellate Tribunal, New Delhi and successfully obtained a status quo order from the Tribunal on the confirmed attachment order which continues till the next date of hearing that is now fixed on October 12, 2023. The ED had filed a complaint before the District and Sessions Judge Cum Special Judge, Ranchi (Trial Court, Ranchi), pursuant to which summoning orders dated May 20, 2021 were issued to the Company and one of its Officers. In response to the said complaint and summons received, the Company had filed a quashing petition before the Hon''ble Jharkhand High Court and a subsequent Special leave Petition (''SLP'') before the Hon''ble Supreme Court against the order of the Hon''ble Jharkhand High Court dismissing the Company''s quashing petition. Vide interim order dated December 15, 2021, the Hon'' ble Supreme Court had granted protection to the Company from arrest and stayed the summoning orders issued by the Trial Court, Ranchi. The Hon''ble Supreme Court vide order dated September 28, 2022, had dismissed the SLP with the directions to the Company to present all its defences "which are required to be considered and dealt with at the time of trial" before the aforesaid Trial Court, Ranchi. The ongoing operations of the Company have not been affected by the aforesaid proceedings.

Supported by a legal opinion obtained, management believes that the Company has a strong case in its favour on merit and law. Accordingly, no adjustment to these financial results in this regard have been considered necessary by the management.

(b) On October 2, 2020, Central Bureau of Investigation (CBI) had filed a First Information Report (FIR) against the Company, Its Managing Director {MD) and certain Other Officers under the Prevention of Corruption Act, 1988 and the Indian Penal Code, 1860 before the Special Judge, CBI, New Delhi (CBI Court, New Delhi) for allegedly trying to influence ongoing CBI investigation pertaining to the proceedings mentioned in 38(a) above. Vide order dated September 15, 2022, the CBI Court, New Delhi had taken cognizance of the offence based on interim charge sheet filed by the CBI against the Company, its MD and certain Other Officers and had directed the CBI to take such steps as may be necessary to complete the investigation. The Company strongly refutes the aforesaid allegations made by the CBI. Subsequent to the quarter/year end, the Company has received intimation from the Directorate of Enforcement (ED) regarding summons issued on this matter by the Special Judge, (PC Act) CBI, New Delhi, under the provisions of PMLA and the matter is scheduled to be heard on May 10, 2023. The Company has been providing information sought by the CBI and ED in this regard and intends to continue cooperating, as required by applicable laws and relevant court orders.

Supported by a legal opinion obtained, management believes that the Company has a strong case in its favour on merit and law in these matters. The Company will take such legal measures as may be considered necessary in respect of these ongoing proceedings.

39. Based on the Company''s internal structure and information reviewed by the Chief Operating Decision Maker to assesses the Company''s financial performance, the Company is engaged solely in the business of manufacture and sale of wire, wire ropes and allied products. Accordingly, the Company has only one operating segment, i.e., "Wire & Wire Ropes".

40. The National Company Law Tribunal (NCLT), Kolkata has vide order dated March 31, 2022 approved the Scheme of Arrangement filed by the Company in accordance with the provisions of section 230 and other applicable provisions of the Companies Act, 2013. During the year, the Company had filed the said order with the Registrar of Companies, West Bengal. In accordance with the said Scheme of Arrangement, accumulated losses/negative balance of retained earnings aggregating Rs. 80,781 lakhs have been adjusted against outstanding balances in Securities Premium Rs. 71,777 lakhs, Capital Redemption Reserve Rs. 2,285 lakhs, Capital Reserve Rs. 369 lakhs and Other Reserves Rs. 6,350 lakhs. The financial position of the Company as at March 31, 2022 reflect the said adjustments.

41. The Board of Directors of the Company have recommended a final dividend of Rs. 2.50/- per fully paid-up Equity Share of Re 1/- each for the financial year ended 31^st March, 2023 (31^st March, 2022: Rs. 2.00/-). The final dividend is subject to the approval of shareholders at the Annual General Meeting and has not been included as a liability in these financial statements.

43. Other Statutory Information

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

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

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

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

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

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

---

Mar 31, 2022

Loan covenants

Bank loans contain certain debt covenants relating to net debt to EBITDA, debt service coverage ratio, fixed assets coverage ratio etc.

The Company has complied with all debt covenants stipulated in the terms of bank loan during the year.

Nature of security

A. Secured by a first pari-passu charge by hypothecation/mortgage over all the property, plant and equipment (present and future) of the Company other than the assets exclusively charged in favour of such lenders

B. Secured by a second charge on entire current assets of the Company (present and future), pari-passu with other term lenders.

C. Secured by personal guarantee of Managing Director of the Company.

D. Secured by pledge of promoter''s holding to the extent of 26% equity in the Company on pari-passu basis.

Secured term loan - interest rate and terms of repayment

(a) Rupee term loan from a bank amounting to Rs. 1,499 lakhs due in two quarterly instalments on 30^th June, 2022 and 30^th September, 2022 (31^st March, 2021: Rs. 1,499 lakhs) has been prepaid during the year.

(b) Rupee term loan from a bank amounting to Rs. 6,644 lakhs (31^st March, 2021 : Rs. 7,604 lakhs) is repayable in eleven quarterly instalments from 30^th June, 2023 to 31^st December, 2025. Interest is payable on monthly basis at one year marginal cost of fund of the bank plus 0.85% p.a.

(c) Rupee term loan from a bank amounting to Rs. 5,460 lakhs (31^st March, 2021 : Rs. 7,377 lakhs) is repayable in nine quarterly instalments from 30^th June, 2023 to 30^th June, 2025. Interest is payable on monthly basis at one year marginal cost of fund of the bank plus 0.85% p.a.

(d) Rupee term loan from a bank amounting to Rs. 2,149 lakhs (31^st March, 2021 : Rs. 2,149 lakhs) due in nine quarterly instalments from 8^th April, 2022 to 8^th April, 2024 has been prepaid during the year.

(e) Outstanding balances of loans and terms of repayment as indicated in (a) to (d) are exclusive of current maturities of such loans as disclosed in Note 16(i).

Nature of security

A. Secured by a first pari-passu charge by hypothecation/mortgage over all the property, plant and equipment (present and future) of the Company other than the assets exclusively charged in favour of such lenders.

B. Secured by a second charge on entire current assets of the Company (present and future), pari-passu with other term lenders.

C. Secured by personal guarantee of Managing Director of the Company.

D. Secured by pledge of promoter''s holding to the extent of 26% equity in the Company on pari-passu basis.

Secured term loan - interest rate and terms of repayment

(a) Rupee term loan from a bank amounting to Rs. 3,000 lakhs outstanding as on 31^st March, 2021 has been repaid during the year.

(b) Rupee term loan from a bank amounting to Rs. 800 lakhs outstanding as on 31^st March, 2021 has been repaid during the year.

(c) Rupee term loan from a bank amounting to Rs. 1,750 lakhs outstanding as on 31^st March, 2021 has been repaid during the year.

Acceptances represent arrangements whereby banks make direct payments to suppliers of raw materials. The banks are subsequently repaid by the Company at a later date providing working capital timing benefits. Where these arrangements are for raw materials and have a maturity of upto the credit period contracted with suppliers, the economic substance of the transaction is considered to be operating in nature and outstanding Acceptance are reported under "Trade payables".

Acceptances payable to banks carry interest @ 5.50% p.a. and are secured by hypothecation of all current assets of the Company. Further such acceptances are also secured by charge on certain movable & immovable properties, subject to first charge in favour of financial institutions and banks created/to be created in respect of any existing/future financial assistance/accommodation which has been/may be obtained by the Company. Further, in respect of acceptances from a bank, these are secured against pledge of promoter''s holding to the extent of 26% equity in the Company on pari-passu basis. In respect of acceptances from another bank, personal guarantee of Managing Director has been given.

Refer note 33B(b) for explanations on the Company''s liquidity risk management processes.

29. SIGNIFICANT ACCOUNTING JUDGEMENTS, ESTIMATES AND ASSUMPTIONS

The preparation of the financial statements requires management to make judgements, estimates and assumptions that affect the reported amounts and the disclosures. The Company based its assumptions and estimates on parameters available when the financial statements were prepared and these are reviewed at each Balance Sheet date.

Other disclosures relating to the Company''s exposure to risks and uncertainties include:

• Capital management (refer note 33D)

• Financial risk management objectives and policies (refer note 33B)

• Sensitivity analysis disclosures [refer note 31 (J)] Judgements

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

(i) Determining the lease term of contracts with renewal and termination options - Company as lessee

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

The Company has several lease contracts that include extension and termination options. The Company applies judgement in evaluating whether it is reasonably certain whether or not to exercise the option to renew or terminate the lease. That is, it considers all relevant factors that create an economic incentive for it to exercise either the renewal or termination. After the commencement date, the Company reassesses the lease term if there is a significant event or change in circumstances that is within its control and affects its ability to exercise or not to exercise the option to renew or to terminate (e.g., construction of significant leasehold improvements or significant customisation to the leased asset).

The Company included the renewal period as part of the lease term for leases of plant and machinery with shorter non-cancellable period (i.e., three to five years). The Company typically exercises its option to renew for these leases because there will be a significant negative effect on production if a replacement asset is not readily available. The renewal periods for leases of plant and machinery with longer non-cancellable periods (i.e., 10 to 15 years) are not included as part of the lease term as these are not reasonably certain to be exercised. Furthermore, the periods covered by termination options are included as part of the lease term only when they are reasonably certain not to be exercised.

Property lease classification - Company as lessor

The Company has determined, based on an evaluation of the terms and conditions of the arrangements, such as the lease term not constituting a major part of the economic life of the commercial property and the present value of the minimum lease payments not amounting to substantially all of the fair value of the commercial property, that it retains substantially all the risks and rewards incidental to ownership of these properties and accounts for the contracts as operating leases.

(ii) Revenue from contracts with customers

The Company applied the judgement of determining method to estimate variable consideration and assessing the constraint that significantly affect the determination of the amount and timing of revenue from contracts with customers.

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

Estimates and assumptions

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

(i) Useful economic lives of property, plant and equipment and impairment considerations

Property, plant and equipment/intangible assets are depreciated/amortised over their estimated useful life, after taking into account estimated economic residual value. Management reviews the estimated economic useful life and residual values of the assets annually in order to determine the amount of depreciation/amortisation to be recorded during any reporting period. The useful life and residual values are based on the Company''s historical experience with similar assets and take into account anticipated technological changes. The depreciation/amortisation for future periods is revised if there are significant changes from previous estimates.

The Company also reviews its property, plant and equipment, for possible impairment if there are events or changes in circumstances that indicate that carrying values of the assets may not be recoverable. In assessing the property, plant and equipment for impairment, factors leading to significant reduction in profits such as changes in commodity prices, the Company''s business plans and changes in regulatory environment are taken into consideration. Impairment exists when the carrying value of an asset or cash generating unit exceeds its recoverable amount, which is the higher of its fair value less costs of disposal and its value in use. The fair value less costs of disposal calculation is based on available data from binding sales transactions, conducted at arm''s length, for similar assets or observable market prices less incremental costs for disposing of the asset. The value in use calculation is based on a DCF model. The carrying value of the assets of a cash generating unit (CGU) is compared with the recoverable amount of those assets, that is, the higher of fair value less costs of disposal and value in use. Recoverable value is based on the management estimates of commodity prices, market demand and supply, economic and regulatory climates, long-term plan, discount rates and other factors. The recoverable amount is sensitive to the discount rate used for the DCF model as well

as the expected future cash-inflows and the growth rate used for extrapolation purposes. Any subsequent changes to cash flow due to changes in the above mentioned factors could impact the carrying value of the assets.

The impairment provisions for financial assets are based on assumptions about risk of default and expected cash loss rates. The Company uses judgement in making these assumptions and selecting the inputs to the impairment calculation, based on Company''s past history, existing market conditions as well as forward-looking estimates at the end of each reporting period.

Judgements are required in assessing the recoverability of overdue trade receivables and determining whether a provision against those receivables is required. Factors considered include the credit rating of the counterparty, the amount and timing of anticipated future payments and any possible actions that can be taken to mitigate the risk of non-payment.

(ii) Taxes

Deferred tax assets are recognised for deductible temporary differences and unused tax losses to the extent that it is probable that taxable profit will be available against which the losses can be utilised. Significant management judgement is required to determine the amount of deferred tax assets that can be recognised, based upon the likely timing and the level of future taxable profits and business developments together with future tax planning strategies.

(iii) Defined benefit plans

The cost and the present value of the defined benefit gratuity plan and long term service award are determined using actuarial valuations. An actuarial valuation involves making various assumptions that may differ from actual developments in the future. These include the determination of the discount rate, future salary increases and mortality rates. Due to the complexities involved in the valuation and its long-term nature, a defined benefit obligation is highly sensitive to changes in these assumptions. All assumptions are reviewed at each reporting date. The parameter most subject to change is the discount rate. In determining the appropriate discount rate for plans, the management considers the interest rates of

Government bonds in currencies consistent with the currencies of the post-employment benefit obligation. The mortality rate is based on publicly available mortality table. Those mortality tables tend to change only at interval in response to demographic changes. Future salary increases and gratuity increases are based on expected future inflation rates.

(iv) Revenue recognition - estimating variable consideration for volume rebates

The Company estimates variable considerations to be included in the transaction price for the sale of goods with volume rebates. Determining whether a customer will be likely entitled to rebate will depend on the customer''s historical rebates entitlement and accumulated purchases to date. Estimates of volume rebates are sensitive to changes in circumstances and the Company''s past experience regarding rebate entitlements may not be representative of customers'' actual rebate entitlements in the future.

(v) Leases - estimating the incremental borrowing rate

The Company cannot readily determine the interest rate implicit in the lease, therefore, it uses its incremental borrowing rate (IBR) to measure lease liabilities. The IBR is the rate of interest that the Company would have to pay to borrow over a similar term, and with a similar security, the funds necessary to obtain an asset of a similar value to the right-of-use asset in a similar economic environment. The Company estimates the IBR using observable inputs (such as market interest rates) when available.

(vi) Provisions and contingencies

The assessments undertaken in recognising provisions and contingencies have been made in accordance with the applicable Ind AS.

A provision is recognized if, as a result of a past event, the Company has a present legal or constructive obligation that can be estimated reliably, and it is probable that an outflow of economic benefits will be required to settle the obligation. Where the

effect of time value of money is material, provisions are determined by discounting the expected future cash flows.

The Company has capital commitments in relation to various capital projects which are not recognized on the Balance Sheet. In the normal course of business, contingent liabilities may arise from litigation and other claims against the Company. Guarantees are also provided in the normal course of business. There are certain obligations which management has concluded, based on all available facts and circumstances, are not probable of payment or are very difficult to quantify reliably, and such obligations are treated as contingent liabilities and disclosed in the notes but are not reflected as liabilities in the financial statements. Although there can be no assurance regarding the final outcome of the legal proceedings in which the Company is involved, it is not expected that such contingencies will have a material effect on its financial position or profitability.

The timing of recognition and quantification of the liability (including litigations) requires the application of judgement to existing facts and circumstances, which can be subject to change. The carrying amounts of provisions and liabilities are reviewed regularly and revised to take account of changing facts and circumstances.

(vii) Non-current assets held for sale

Assets and liabilities of non-current assets held for sale are measured at the lower of carrying amount and fair value less cost to sale. The determination of fair value less costs to sale include use of management estimates and assumptions. The fair value has been estimated using valuation techniques (including income and market approach) which includes unobservable inputs.

(viii) Valuation of Inventories

The Company follows suitable provisioning norms for writing down the value of slow-moving, nonmoving and surplus inventory. This involves various judgements and assumptions that may differ from actual developments in the future.

30. COMMITMENTS AND CONTINGENCIES A. Leases Company as a lessee

(i) The Company as a lessee has entered into various lease contracts, which includes lease of land, office space, employee residential accommodation, guest house etc. Generally, the Company is restricted from assigning and subleasing the leased assets. There are lease contracts that include extension and termination options. These options are negotiated by management to provide flexibility in aligning with the Company''s business needs. Management exercises significant judgement in determining whether these extension and termination options are reasonably certain to be exercised.

The Company has certain leases of office space, employee residential accommodation, guest house etc with lease terms of 12 months or less. The Company applies the ''short-term lease'' and ''lease of low-value assets'' recognition exemptions for these leases.

Set out below are the net carrying amounts of right-of-use assets recognised in Balance Sheet and the movement during the year :

Particulars		Land
As at 31st March, 2020		301
Addition during the year		-
Less : amortisation		7
As at 31st March, 2021 (refer note 4)		294
Addition during the year		79
Less : amortisation		6
As at 31st March, 2022 (refer note 4)		367
(ii) Set out below are the carrying amounts of lease liabilities and the movement during the year:
	As at 31st March, 2022	As at 31st March, 2021
Balance as at beginning of the year	35	29
Addition	79	-
Accretion of interest (refer note 25)	24	6
Payments	13	-
Balance as at the end of the year	125	35
Current [refer note 16(iii)]	34	14
Non-current [refer note 13(ii)]	91	21
The maturity analysis of lease liabilities is disclosed in Note 33B (b).
The effective interest rate for lease liabilities is 10.95%, with maturity between 2021-2095.
(iii) Amounts recognised in the Statement of Profit and Loss
	As at 31st March, 2022	As at 31st March, 2021
Amortisation expense of right-of-use assets (recognised in depreciation and amortization expenses)	6	7
Interest expense on lease liabilities (recognised in finance costs)	24	6
Expense relating to short-term leases (included in rent and hire charges)	71	99
Total amount recognised in Statement of Profit and Loss for the year	101	112

B. Commitments
	As at 31st March, 2022	As at 31st March, 2021
(i) Capital commitments
Estimated amount of contracts remaining to be executed on capital account and not provided for (net of advances)	304	360
(ii) Other commitments
Export obligations against the import licenses taken for import of capital goods under the Export Promotion Capital Goods Scheme. During the year, the Company has filed an application to the Directorate General of Foreign Trade (DGFT) for re-fixation of Average Export Obligation (AEO) to exclude certain items that are not required to be considered for ascertaining the Company''s AEO. Supported by a legal opinion obtained, the Company is reasonably certain of a favourable outcome and hence it does not anticipate a liability with respect to its obligations. Management believes that in consideration to refixed AEO, no further export obligations are to be met by the Company.		117,500
C. Contingent liabilities
	As at 31st March, 2022	As at 31st March, 2021
(i) Guarantees
Corporate guarantee given by the Company to banks/third parties to secure the financial assistance/ accommodation extended on behalf of subsidiaries. Balance outstanding as at year end Rs. 5,497 lakhs (31st March, 2021 : Rs. 3,583 lakhs) The Company has assessed that it is only possible, but not probable, that outflow of economic resources will be required [refer note 32(iii)].	7,579	7,311
(ii) Bank guarantees
The Company has given bank guarantees details of which are as below:
in favour of various parties against various contracts	633	441
The Company has assessed that it is only possible, but not probable, that outflow of economic resources will be required.
(iii) Claims against the Company not acknowledged as debt ##*
Demand for income tax matters	1,672	1,672
Demand for sales tax, entry tax 1	2,827	4,229
Demand for excise duty and service tax	12,627	13,255
Demand for customs duty	1,129	1,129
Demand for Goods and Service Tax	1,017	487
Demand for Land revenue	295	222
Outstanding labour disputes	28	28
Demand for fuel surcharge matter and delayed payment surcharge pending with appropriate authority	10,980	10,980
Demand for mining matter pending with High Court of Jharkand @	2,862	2,862
Demand for compensation on account of mining and dump/infrastructure/colony established outside approved mining lease area	1,710	1,710
Demand for financial assurance amount in Escrow account	226	226
Disputed claims by parties not acknowledged as debt by the Company	3,006	3,006

* Future cash outflows in respect of the above matters are determinable only on receipt of judgments/decisions pending at various forums/authorities. Based on discussions with the solicitors/favourable decisions in similar cases/legal opinions taken by the Company, the management believes that the Company has a good chance of success in above mentioned matters and hence no provision against these matters is considered necessary.

@ The Company had given an undertaking to deposit Rs. 1,922 lakhs in six instalments in terms of the order of the Hon''ble High Court of Jharkhand. Against the same, the Company has deposited an amount of Rs. 1,922 lakhs upto 31^st March, 2020.

^## Pending necessary clarification, the Company has complied with order of the Hon''ble Supreme Court of India regarding applicability of Employees'' Provident Funds & Miscellaneous Provisions Act, 1952 to certain fixed elements of remuneration paid/payable to employees with effect from the date of such order, i.e., February 28, 2019 and has deposited such statutory dues with appropriate authorities. Any additional provision in respect of earlier periods will be recognised as and when further clarifications will be available.

(iv) Others

(a) The Company has provided a Letter of Comfort to a bank that has provided credit facilities to its joint venture, Pengg Usha Martin Wires Private Limited. Such facilities have been utilised to the extent of Rs. 3,818 lakhs as at 31^st March, 2022 (31^st March, 2021: Rs.2,934 lakhs) by the joint venture company. Vide the letter of comfort, the Company has provided an undertaking not to dispose off its investment in that joint venture company and to ensure that no losses are suffered by the lender concerned. The Company has assessed that it is only possible, but not probable, that outflow of economic resources will be required [refer note 32(iii)].

(b) The Company has provided a Letter of Comfort to a bank that has provided credit facilities to its subsidiary, UM Cables Limited. Such facilities have been utilised to the extent of Rs. 3,437 lakhs as at 31^st March, 2022 (31^st March, 2021: Rs. Nil) by the subsidiary company. Vide the letter of comfort, the Company has provided an undertaking not to dispose off its investment in that subsidiary company and to ensure that no losses are suffered by the lender concerned. The Company has assessed that it is only possible, but not probable, that outflow of economic resources will be required [refer note 32(iii)].

(c) The Company has provided a Letter of Comfort to a bank that has provided credit facilities to its subsidiary, Usha Martin Singapore Pte. Limited. Such facilities have been utilised to the extent of Rs. 4,017 lakhs as at 31^st March, 2022 (31^st March, 2021: Rs. Nil) by the subsidiary company. Vide the letter of comfort, the Company has provided an undertaking not to dispose off its investment in that subsidiary company and to ensure that no losses are suffered by the lender concerned. The Company has assessed that it is only possible, but not probable, that outflow of economic resources will be required [refer note 32(iii)].

(b) Post employment defined benefit plans

I. Gratuity plan

The Company has a defined benefit gratuity plan. Every employee who has completed five years or more of service is entitled to gratuity on terms not less favourable than the provisions of The Payment of Gratuity Act, 1972.The level of benefits provided depends on the member''s length of service and salary at retirement age. The scheme is funded with an insurance company.

II. Long term service award

Employees of the Company rendering greater than twenty years of service will receive long service award on all causes of exit as per the Company''s policy. The cost of providing benefits under this plan is determined by actuarial valuation using the projected unit credit method by independent qualified actuaries at the year end.

The following tables summarise the components of net benefit expense recognised in the Statement of Profit and Loss and the funded status and amounts recognised in the Balance Sheet for the above defined benefit plans:

The sensitivity analysis above have been determined based on a method that extrapolates the impact on defined benefit obligation as a result of reasonable changes in key assumptions occurring at the end of the reporting period. The sensitivity analysis are based on a change in a significant assumption, keeping all other assumptions constant. The sensitivity analysis may not be representative of an actual change in the defined benefit obligation as it is unlikely that changes in assumptions would occur in isolation from one another.

In presenting the above sensitivity analysis, the present value of defined benefit obligation has been calculated using the project unit credit method at the end of reporting period, which is the same as that applied in calculating the defined benefit obligation liability recognized in the balance sheet.

K. Risk analysis

Company is exposed to a number of risks in the defined benefit plans. Most significant risks pertaining to defined benefit plans and management''s estimation of the impact of these risks are as follows:

(i) Interest risk

A decrease in the interest rate on plan assets will increase the plan liability.

(ii) Longevity risk/Life expectancy

The present value of the defined benefit plan liability is calculated by reference to the best estimate of the mortality of plan participants both during and at the end of the employment. An increase in the life expectancy of the plan participants will increase the plan liability.

(iii) Salary growth risk

The present value of the defined benefit plan liability is calculated by reference to the future salaries of plan participants. An increase in the salary of the plan participants will increase the plan liability.

(iv) Investment risk

The Gratuity plan is funded with Life Insurance Corporation of India (LIC). The Company does not have any liberty to manage the fund provided to LIC. The present value of the defined benefit plan liability is calculated using a discount rate determined by reference to Government of India bonds. If the return on plan asset is below this rate, it will create a plan deficit.

(III) Provident Fund

Provident Fund contributions in respect of employees are made to Trusts administered by the Company and such Trusts invest funds following a pattern of investments prescribed by the Government. Both the employer and the employees contribute to this Fund and such contributions together with interest accumulated thereon are payable to employees at the time of their separation from the Company or retirement, whichever is earlier. The benefit vests immediately on rendering of services by the employee. The interest rate payable to the members of the Trusts is not lower than the rate of interest declared annually by the Government under the Employees'' Provident Funds and Miscellaneous Provisions Act, 1952 and shortfall, if any, on account of interest is to be made good by the Company. In terms of the guidance on implementing Indian Accounting Standard 19 on Employee Benefits, a provident fund set up by the Company is treated as a defined benefit plan in view of the Company''s obligation to meet interest shortfall, if any.

The Actuary has carried out actuarial valuation of plan''s liabilities and interest rate guarantee obligations as at the balance sheet date using projected unit credit method and deterministic approach as outlined in the Guidance Note 29 issued by the Institute of Actuaries of India. Based on such valuation, there is no future anticipated shortfall with regard to interest rate obligation of the Company as at the Balance Sheet date. Further during the period, the Company''s contribution Rs. 387 lakhs (31^st March, 2021: Rs. 333 lakhs) to the Provident Fund Trust, has been expensed under "Contribution to provident and other funds". Disclosures given hereunder are restricted to the information available as per the Actuary''s report.

Terms and conditions of transactions with related parties

The sales to and purchases from related parties are made on terms equivalent to those that prevail in arm''s length transactions with third parties. Outstanding balances at the year-end are unsecured and settlement occurs through normal banking channels. For the year ended 31^st March, 2022 and 31^st March, 2021, the Company has not recorded any impairment of receivables relating to amounts owed by related parties. This assessment is undertaken each financial year through examining the financial position of the related party and the market in which the related party operates.

The Company routinely enters into transactions with these related parties in the ordinary course of business at market rates and terms.

The Company enters into derivative financial instruments with various counterparties, principally financial institutions with investment grade credit ratings. Foreign exchange forward contracts are valued using valuation techniques, which employs the use of market observable inputs. The most frequently applied valuation techniques include forward pricing model, using present value calculations. The model incorporate various inputs including the credit quality of counterparties, foreign exchange spot and forward rates, yield curves of the respective currencies, currency basis spreads between the respective currencies, interest rate curves and forward rate curves of the underlying commodity. As at 31^st March, 2022, the mark-to-market value of other derivative assets/liabilities positions is net of a credit valuation adjustment attributable to derivative counterparty default risk.

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

The following explains the judgements and estimates made in determining the fair values of the financial instruments that are recognised and measured at fair value through profit and loss. To provide an indication about the reliability of the inputs used in determining fair value, the Company has classified its financial investments into the three levels prescribed under the accounting standard.

Notes:

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

Level 1 hierarchy includes financial instruments measured using quoted prices in active markets for identical assets or liabilities.

Level 2 hierarchy includes the fair value of financial instruments that are not traded in an active market (for example, over-the counter derivatives) and the fair value is determined using valuation techniques which maximise the use of observable market data and rely as little as possible on entity-specific estimates. If all significant inputs required to fair value an instrument are observable, the instrument is included in level 2.

If one or more of the significant inputs is not based on observable market data, the instrument is included in level 3.

There are no transfers between levels 1 and 2 during the year. The Company''s policy is to recognise transfers into and transfers out of fair value hierarchy levels as at the end of the reporting period.

33 B. Financial risk management objectives and policies Risk management framework

The Company''s board of directors has overall responsibility for the establishment and oversight of the Company''s risk management framework. The board of directors has established the Risk Management Committee (RMC) which is responsible for developing and monitoring the Company''s risk management policies.

The Company''s risk management policies are established to identify and analyse the risks faced by the Company, to set appropriate risk limits and control and monitor risks and adherence to limits. Risk management policies and systems are reviewed regularly to reflect changes in market conditions and the Company''s activities.

The Company''s activities expose it to market risk, liquidity risk and credit risk which are measured, monitored and managed to abide by the principles of risk management.

(a) Credit risk

Credit risk refers to the risk of financial loss that may arise from counterparty failure on its contractual obligations resulting in financial loss to the Company. Credit risk encompasses both the direct risk of default and the risk of deterioration of creditworthiness as well as concentration risks.

The Company controls its own exposure to credit risk. All external customers undergo a creditworthiness check. The Company performs an on-going assessment and monitoring of the financial position and the risk of default. Based on the aforesaid checks, monitoring and historical data, the Company does not perceive any significant credit risk on trade receivables. Outstanding customer receivables are regularly monitored and any shipments to major customers are generally covered by letters of credit or other forms of credit insurance obtained from reputable banks and other financial institutions.

In addition, as part of its cash management and credit risk function, the Company regularly evaluates the creditworthiness of financial and banking institutions where it deposits cash and performs trade finance operations. The Company primarily has banking relationships with the public sector, private and large international banks with good credit rating.

Trade Receivable aggregating Rs. 8,078 lakhs (31^st March, 2021: Rs. 6,318) from two customers, each contributes to more than 10% of outstanding trade receivables as at 31^st March, 2022.

The maximum exposure to the credit risk at the reporting date is the carrying value of all financial assets amounting to Rs. 64,179 lakhs (31^st March, 2021 : Rs. 59,900 lakhs) as disclosed in note 33A(a).

An impairment analysis is performed at each reporting date using a provision matrix to measure expected credit losses. The provision rates are based on days past due for groupings of various customer segments with similar loss patterns (i.e., by geographical region, product type, customer type and rating, and coverage by letters of credit or other forms of credit insurance). The calculation reflects the probability-weighted outcome, the time value of money and reasonable and supportable information that is available at the reporting date about past events, current conditions and forecasts of future economic conditions. The Company does not hold collateral as security. The letters of credit and other forms of credit insurance are considered integral part of trade receivables and considered in the calculation of impairment. The Company evaluates the concentration of risk with respect to trade receivables and contract assets as low, as its customers are located in several jurisdictions and industries and operate in largely independent markets. Movement in the allowance for credit impaired trade receivables is given in Note 9(i).

The details of year-end trade receivables which were past due but not impaired as at 31^st March, 2022 and 31^st March, 2021 is given in Note 9(i).

Credit risk from balances with banks is managed by the Company''s treasury department in accordance with the Company''s policy. Investments of surplus funds are made only with approved counterparties and within credit limits assigned to each counterparty. Counterparty credit limits are reviewed by the Company''s Board of Directors on an annual basis, and may be updated throughout the year. The limits are set to minimise the concentration of risks and therefore mitigate financial loss through counterparty''s potential failure to make payments.

Concentrations arise when a number of counterparties are engaged in the same geographical region, or have economic features that would cause their ability to meet contractual obligations to be similarly affected by changes in economic, political or other conditions. Concentrations indicate the relative sensitivity of the Company''s performance to developments affecting a particular industry.

In order to avoid excessive concentrations of risk, the Company''s policies and procedures include specific guidelines to focus on the maintenance of a diversified portfolio. Identified concentrations of credit risks are controlled and managed accordingly.

(b) Liquidity risk

Liquidity risk arises from the Company''s inability to meet its cash flow commitments on the due date. The Company has liquidity risk monitoring processes covering short-term, mid-term and long-term funding. The Company''s objective is to maintain a balance between continuity of funding and flexibility through the use of committed credit facilities and loan funds. Management regularly monitors projected and actual cash flow data, analyses the repayment schedules of the existing financial assets and liabilities and performs annual detailed budgeting procedures coupled with rolling cash flow forecasts.

The amount of guarantees given on behalf of subsidiaries included in note 30C(i) represents the maximum amount the Company could be forced to settle for the full guaranteed amount. Based on the expectation at the end of the reporting period, the Company considers that it is more likely that such an amount will not be payable under the arrangement.

(c) Market risk

Market risk is the risk that the fair value of future cash flows of a financial instrument will fluctuate because of changes in market prices. The Company is exposed to different types of market risks. The market risk is the possibility that changes in foreign currency exchange rates, interest rates and commodity prices may affect the value of the Company''s financial assets, liabilities or expected future cash flows. The fair value information presented below is based on the information available with the management as of the reporting date.

(c.1) Foreign currency exchange risk

Foreign currency risk is the risk that the fair value or future cash flows of an exposure will fluctuate because of changes in foreign exchange rates. Exposures can arise on account of the various assets and liabilities which are denominated in currencies other than Indian Rupee.

A reasonably possible strengthening/weakening of the Indian Rupee against such foreign currency (converted to US Dollars) as at 31^st March, 2022 and 31^st March, 2021 would have affected profit and loss by the amounts shown below. This analysis assumes that all other variables remain constant and ignores any impact of forecasted sales and purchases.

(c.2) Interest rate risk

Interest rate risk is the risk that the fair value or future cash flows of a financial instrument will fluctuate because of changes in market interest rates. The Company''s exposure to the risk of changes in market interest rates relates primarily to the Company''s long-term debt obligations with floating interest rates.

Interest rate risk is measured by using the cash flow sensitivity for changes in variable interest rates. Any movement in the reference rates could have an impact on the Company''s cash flows as well as costs. The Company is subject to variable interest rates on some of its interest bearing liabilities. The Company''s interest rate exposure is mainly related to debt obligations. The Company manages its interest rate risk by having a balanced portfolio of fixed and variable rate loans and borrowings.

If the interest rates applicable to floating rate instruments is increased/decreased by 1%, the profit before tax for the year ended 31^st March, 2022 (and corresponding impact on equity) would decrease/(increase) by Rs. 238 lakhs (31^st March, 2021 : Rs. 388 lakhs) on an annualised basis. This assumes that the amount and mix of fixed and floating rate debt remains unchanged during the year from that in place as at year end.

(c.3) Commodity price risk

The Company''s revenue is exposed to the risk of price fluctuations related to the sale of its wire & wire rope products. Market forces generally determine prices for such products sold by the Company. These prices may be influenced by factors such as supply and demand, production costs (including the costs of raw material inputs) and global and regional economic conditions and growth. Adverse changes in any of these factors may reduce the revenue that the Company earns from the sale of wire & wire rope products.

The Company primarily purchases its raw materials in the open market from third parties. The Company is therefore subject to fluctuations in prices of wire rods, zinc, lead, lubricants, core and other raw material inputs. The Company purchased substantially all of coal requirements from third parties in the open market during the year ended 31^st March, 2022 and 31^st March, 2021 respectively.

The Company does not have any commodity forward contract for Commodity hedging.

The following table details the Company''s sensitivity to a 5% movement in the input price of wire rod and zinc. The sensitivity analysis includes only 5% change in commodity prices for quantity sold or consumed during the year, with all other variables held constant. A positive number below indicates an increase in profit or equity where the commodity prices decrease by 5%. For a 5% increase in commodity prices, there would be a comparable impact on profit or equity, and the balances below are negative.

33 C. Derivative Financial Instruments

The Company uses derivative instruments as part of its management of exposure to fluctuations in foreign currency exchange rates. All derivative activities for risk management purposes are carried out by specialist teams that have the appropriate skills, experience and supervision. The Company does not acquire or issue derivative financial instruments for trading or speculative purposes. The Company does not enter into complex derivative transactions to manage the treasury risks. Treasury derivative transactions are normally in the form of forward contracts and these are subject to the Company guidelines and policies. The fair values of all derivatives are separately recorded in the balance sheet within current and non-current assets and liabilities. The use of derivatives can give rise to credit and market risk. The Company tries to control credit risk as far as possible by only entering into contracts with reputable banks and financial institutions. The use of derivative instruments is subject to limits, authorities and regular monitoring by appropriate levels of management. The limits, authorities and monitoring systems are periodically reviewed by management and the Board. The market risk on derivatives is mitigated by changes in the valuation of the underlying assets, liabilities or transactions, as derivatives are used only for risk management purposes.

33 D. Capital management

For the purpose of the Company''s capital management, capital includes issued equity capital and other equity. The Company''s primary capital management objectives are to ensure its ability to continue as a going concern and to optimize the cost of capital in order to enhance value to shareholders.

The Company manages its capital structure and makes adjustments to it as and when required. To maintain or adjust the capital structure, the Company may pay dividend or repay debts, raise new debt or issue new shares. The Company monitors capital using a gearing ratio, which is net debt divided by total capital plus net debt. No major changes were made in the objectives, policies or processes for managing capital during the year ended 31^st March, 2022 and 31^st March, 2021 respectively. The Company includes within net debt, interest bearing loans and borrowings, less cash and cash equivalents as follows:

34(i) The Company was allocated two coal blocks namely, Kathautia Coal Block and Lohari Coal Block in the State of Jharkhand for captive use. Pursuant to the Hon''ble Supreme Courts'' order dated 24^th September, 2014 followed by promulgation of the Coal Mines (Special Provisions) Act, 2015, (CMSP Act), the allocation of all coal blocks since 1993, including the aforesaid coal blocks allocated to the Company were cancelled with effect from 24^th September, 2014 in case of Lohari Coal Block and 1^st April, 2015 in the case of Kathautia Coal Block.

Through the process of public auction as envisaged in the CMSP Act, the aforesaid Coal Blocks of the Company had been allocated to other successful bidders by the Central Government. Pursuant to conclusion of such auction, the Central Government had also issued vesting orders for Kathautia and Lohari Coal Blocks for transfer and vesting the Company''s rights, title and interest in and over the land and mine infrastructure of the said coal blocks to the respective successful bidders.

The Company''s application before the Hon''ble, Delhi High Court for recovery of Rs. 227 lakhs (31^st March, 2021 : Rs. 227 lakhs) which after discounting stands at Rs. 183 lakhs (31^st March, 2021 : Rs. 183 lakhs) as at the year end. Based on its assessment which is supported by a legal opinion obtained, the management is confident of recovery of the amount. Further, the Company is also engaged in ongoing negotiations with the party to whom the aforesaid Coal Blocks were subsequently allotted for realization of compensation/investments in the mines. Land parcels aggregating Rs. 1,131 lakhs are in the process of being transferred in the name of the Company for which necessary proceedings before a Civil Court are ongoing pending completion due to pandemic. Management expects that such proceedings will be completed before end of next year and the Company will be able to transfer such land parcels to new allocatee for recovery of the agreed consideration. Accordingly, this has been disclosed as "Asset held for sale" as at 31^st March, 2022.

After taking into consideration the reasons as stated above, management is of the opinion that the realizable value of aforesaid assets will not be less than their carrying values.

34(ii) Discontinued operations

Pursuant to the Business Transfer Agreement dated September 22, 2018, Novation agreement on October 24, 2018 and Supplemental Business Transfer Agreements dated April 7, 2019 and July 3, 2019 respectively with Tata Steel Long Products Limited (TSLPL) [formerly known as Tata Sponge Iron Limited], the Company had transferred its Steel and Bright Bar Business (SBB Business) as a going concern on slump sale basis during a prior year in accordance with the terms and conditions set out in those agreements. An amount of Rs. 16,000 lakhs (subject to net working capital adjustments) was receivable at the commencement of the year in respect of certain parcels of land for which perpetual lease and license agreements had been executed by the Company in favour of TSLPL pending completion of ongoing formalities for registration of such land in the name of TSLPL. During the year, the Company has received Rs. 5,418 lakhs (net of adjustment of Rs. 1,226 lakhs towards final settlement of net working capital) on transfer of some of those parcels of land in the name of TSLPL. The balance amount receivable as at March 31,2022 is Rs. 9,356 lakhs in respect of aforesaid land parcels.

35B. Details of loans given, investments made and guarantee given covered under section 186 (4) of the Companies Act, 2013 Loans given and investments made are given under the respective heads.

Corporate guarantees given by the Company in respect of loans are stated in note 32(iii). All the said corporate guarantees have been given for business purpose.

38. a) The Directorate of Enforcement, Patna ("ED") had issued an order dated August 9, 2019 under the provisions of Prevention of Money Laundering Act, 2002 (PMLA) to provisionally attach certain parcels of land at Ranchi, State of Jharkhand being used by the Company for its business for a period of 180 days in connection with export and domestic sale of iron ore fines in prior years aggregating Rs. 19,037 lakhs allegedly in contravention of terms of the mining lease granted to the Company for the iron ore mines situated at Ghatkuri, Jharkhand. The Hon''ble High Court of Jharkhand at Ranchi had, vide order dated February 14, 2012, held that the Company has the right to sell the iron ore including fines as per the terms of the mining lease which was in place at that point in time. The Company had paid applicable royalty and had made necessary disclosures in its returns and reports submitted to mining authorities. In response to the provisional attachment order, the Company had submitted its reply before the Adjudicating Authority (AA). Subsequently, AA had issued an order by way of which the provisional attachment was confirmed under Section 8(3) of PMLA. Thereafter, the Company filed an appeal before the Appellate Tribunal, New Delhi and successfully obtained a status quo order from the Tribunal on the confirmed attachment order which continues till the next date of hearing that is now fixed on August 5, 2022. In May 2021, the ED had filed a complaint before the District and Sessions Judge Cum Special Judge (CBI), Ranchi against the Company and one of its Officers. In response to the said complaint and summons received by the Company and its Officer pursuant to order dated May 20, 2021, the Company had filed a quashing petition before the Hon''ble Jharkhand High Court which has been dismissed vide order dated November 3, 2021 in which the Hon''ble Court has stated that the facts of the case are voluminous and "the Court is not required to make a roving enquiry and discuss the evidences for coming to a conclusion that no prima-facie case is made out, at this stage, which is against the mandate of law." Subsequently on a Special Leave Petition filed by the Company against the aforesaid o

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Mar 31, 2018

1. Company overview

Usha Martin Limited (the ‘Company’) is a public limited company domiciled in India and is incorporated under the provisions of the Companies Act applicable in India. Its equity shares are listed on two recognised stock exchanges in India and its GDRs are listed on stock exchange in Luxembourg. The registered office of the Company is located at 2A, Shakespeare Sarani, Kolkata - 700071. The Company is engaged in the manufacturing of speciality steel and value added steel products. The Company caters to both domestic and international markets.

a) 2,34,52,950 (31st March, 2017 : 3,20,83,550) equity shares of face value of Re 1 each are represented by Global Depository Receipts (GDRs). Each GDR represents five underlying equity shares.

(b) Rights, preference and restrictions attached to equity shares

The Company has only one class of equity shares having par value of Re. 1 per share. Each holder of equity shares is entitled to one vote per share (except in case of GDRs).The holders of GDRs do not have voting right with respect to shares. The dividend if proposed by the Board of Directors is subject to the approval of the shareholders in the ensuing Annual General Meeting, except in case of interim dividend.

In the event of liquidation of the Company, the holders of equity shares will be entitled to receive residual assets of the Company, after distribution of all preferential amounts. The distribution will be in proportion to the number of equity shares held by each shareholder.

(d) Details of shares held by shareholders holding more than 5 % of the aggregate equity shares in the Company:

Loan covenants

Bank loans contain certain debt covenants relating to net debt to EBITDA, interest coverage ratio, debt service coverage ratio, fixed assets coverage ratio etc. The Company’s applications to lenders in respect of certain covenants not being met for the relevant year/(s) are under consideration of respective lenders. The management believes that the Company’s borrowings classified as non-current borrowings will continue to be on the same repayment terms and conditions as was agreed at the time of disbursement.

Nature of security

A These are secured by a first pari-passu charge by hypothecation/ mortgage over all the property, plant and equipment (present and future) of the Company other than the assets exclusively charged to other lenders.

B These are secured by a second charge on entire current assets of the Company (present and future), pari-passu with other term lenders.

C Personal guarantee of Mr. Rajeev Jhawar, Managing Director of the Company.

D Pledge of promoter’s holding to the extent of 26% equity in the Company on pari-passu basis.

E These are secured against underlying assets.

Secured term loan - interest rate and terms of repayment

(a) Rupee term loan from a bank amounting to Rs. 15,000 lakhs (31st March, 2017 : Rs. 18,740 lakhs) is repayable in twelve quarterly instalments from 29th June, 2019 to 29th March, 2022. Interest is payable on monthly basis at base rate of the bank plus 2.00% p.a.

(b) Rupee term loan from a bank amounting to Rs. 10,107 lakhs (31st March, 2017 : Rs. 11,992 lakhs) is repayable in fourteen quarterly instalments from 30th June, 2019 to 30th September, 2022. Interest is payable on monthly basis at base rate of the bank plus 2.00% p.a.

(c) Rupee term loan from a bank amounting to Rs. 9,836 lakhs (31^st March, 2017 : Rs. 9,829 lakhs) is repayable in twenty seven quarterly instalments from 30th June, 2019 to 31st December, 2025. Interest is payable on monthly basis at base rate of the bank plus 2.00% p.a.

(d) Rupee term loan from a bank amounting to Rs. 18,748 lakhs (31st March, 2017 : Rs. 20,620 lakhs) is repayable in twelve quarterly instalments from 30th June, 2019 to 31st March, 2022. Interest is payable on monthly basis at one year marginal cost of fund lending rate of the bank plus 2.40% p.a.

(e) Rupee term loan from a bank amounting to Rs. 45,375 lakhs (31st March, 2017 : Rs. 49,350 lakhs) is repayable in nineteen quarterly instalments from 30th June, 2019 to 31st December, 2023. Interest is payable on monthly basis at one year marginal cost of fund lending rate of the bank plus 2.90% p.a.

(f) Rupee term loan from a bank amounting to Rs. 89,307 lakhs (31st March, 2017 : Rs. 89,591 lakhs) is repayable in twenty seven quarterly instalments from 31st March, 2019 to 31st December, 2025. Interest is payable on monthly basis at one year marginal cost of fund lending rate of the bank plus 2.50% p.a.

(g) Rupee term loan from a bank amounting to Rs. 9,000 lakhs (31st March, 2017 : Rs. Nil) is repayable in forty quarterly instalments from 31st December, 2019 to 30th September, 2029. Interest is payable on monthly basis at one year marginal cost of fund lending rate of the bank plus 2.50% p.a.

(h) Rupee term loan from a bank amounting to Rs. 7,452 lakhs (31st March, 2017 : Rs. 6,467 lakhs) is repayable in twenty seven quarterly instalments from 30th June, 2019 to 31st December, 2025. Interest is payable on monthly basis at one year marginal cost of fund lending rate of the bank plus 2.70% p.a.

(i) Rupee term loan from a bank amounting to Rs. 1,915 lakhs (31st March, 2017 : Rs. 1,983 lakhs) is repayable in twenty seven quarterly instalments from 30th June, 2019 to 31st December, 2025. Interest is payable on monthly basis at 11.55% p.a.

(j) Rupee term loan from a bank amounting to Rs. 9,739 lakhs (31st March, 2017 : Rs. 11,119 lakhs) is repayable in eighteen quarterly instalments from 30th April, 2019 to 31st July, 2023. Interest is payable on monthly basis at one year marginal cost of fund lending rate of the bank plus 2.90% p.a. Under the terms of the loan, the bank has a put/call option that can be exercised at the end of the fourth year from the date of first disbusement of the loan which will fall due on 31st July, 2018, with one month’s prior notice. Management has reasonable grounds to believe that the bank is not likely to exercise such option and hence the loan has been considered as non-current borrowing in the financial statements.

(k) Rupee term loan from a bank amounting to Rs.12,078 lakhs (31st March, 2017 : Rs. 13,198 lakhs) is repayable in fifteen quarterly instalments from 30th June, 2019 to 31st December, 2022. Interest is payable on monthly basis at base rate of the bank plus 4.00% p.a.

(l) Rupee term loan from a bank amounting to Rs. 4,988 lakhs (31st March, 2017 : Rs. 4,870 lakhs) is repayable in twenty seven equal quarterly instalments from 30th June, 2019 to 31st December, 2025. Interest is payable on monthly basis at one year marginal cost of fund lending rate of the bank plus 1.85% p.a.

(m) Rupee term loan from a bank amounting to Rs. 12,701 lakhs (31st March, 2017 : Rs. 13,763 lakhs) is repayable in twenty quarterly instalments from 30th June, 2019 to 31st March, 2024. Interest is payable on monthly basis at base rate of the bank plus 1.65% p.a. (n) Rupee term loan from a financial institution amounting to Rs. Nil (31st March, 2017 : Rs. 16,247 lakhs) is repayable in three quarterly instalments from 1st April, 2018 to 1st October, 2018. Interest is payable on monthly basis at long-term minimum lending rate plus 1.85% p.a.

(o) Rupee term loan from a financial institution amounting to Rs. 18,671 lakhs (31st March, 2017 : Rs.3,902 lakhs) is repayable in forty quarterly instalments from 1st January, 2020 to 1st October, 2029. Interest is payable on monthly basis at long-term minimum lending rate plus 2.00% p.a.

(p) Rupee loan from a body corporate amounting to Rs. 662 lakhs (31st March, 2017 : Rs. 1,130 lakhs) is repayable in fifty nine quarterly instalments (comprising of various loans with different quarterly payment schedules) between 1st April, 2018 to 1st April, 2021. Interest is payable on quarterly basis at 11.81% p.a.

(q) Outstanding balances of loans and terms of repayment as indicated in (a) to (p) above are exclusive of current maturities of such loans as disclosed in Note 18(iii).

*released to the statement of profit and loss Rs. Nil (31st March, 2017 : Rs. 110 lakhs)

Represents Government assistance in the form of the duty benefit availed under Export Promotion Capital Goods (EPCG) Scheme on purchase of property, plant and equipment accounted for as Government grant. Income from such grant is estimated on the basis of fulfilment of related export obligations. Hitherto, such income was being estimated based on useful lives of concerned property, plant and equipment. The impact of such change in estimate is not material. Contingencies attached to these grants has been disclosed in note 33B(ii)(a).

* Nature of security - Secured by hypothecation of all current assets of the Company. Further such loans from banks are also secured by charge on certain immovable properties, subject to prior charges in favour of financial institutions and banks created/to be created in respect of any existing/future financial assistance/ accommodation which has been/may be obtained by the Company. Further, these are secured against pledge of promoter’s holding to the extent of 26% equity in the Company on pari-passu basis. The loans are repayable on demand and carry interest @ 10.45% to 14.75% p.a. payable at monthly rests. Import buyer’s credit carries interest @ 1/2/3/6 months LIBOR plus 25 bps p.a. to 100 bps p.a and acceptances carry interest @ 8% to 9% p.a. Such buyer’s credit and acceptances from banks are repayable within 180 days.

# The loan carries interest @ 8.75% p.a and is repayable on demand.

## The Company has discounted trade receivables on recourse basis. Accordingly, the monies received on this account are shown as borrowings as the trade receivable does not meet de-recognition criteria. These bills are discounted @ 8% to 10% p.a. and are repayable within 180 days.

Trade payables are non-interest bearing and are normally settled upto 365 day terms.

Import acceptances carry interest @ applicable LIBOR plus 25 bps p.a. to 100 bps p.a and inland acceptances carry interest @ 8% to 9% p.a. Such acceptances are repayable not later than 180 days. These are secured by hypothecation of all current assets of the Company. Further such acceptances are also secured by charge on certain immovable properties, subject to prior charges in favour of financial institutions and banks created/to be created in respect of any existing/future financial assistance/accommodation which has been/may be obtained by the Company. Further, these are secured against pledge of promoter’s holding to the extent of 26% equity in the Company on pari-passu basis.

Refer note 37B for explanations on the Company’s liquidity risk management processes.

@ Includes payable to key management personnel Rs 20 lakhs (31st March, 2017 : Rs 22 lakhs)

# Financial liabilities at fair value through profit and loss

Derivative instruments at fair value through profit and loss reflect the negative change in fair value of those foreign exchange forward contracts that are not designated in hedge relationships. Refer note 37B for details regarding the nature and extent of risks arising from financial instruments to which the Company is exposed at the end of the reporting year.

## There are no amount due for payment to the Investor Education and Protection Fund under Section 125C of the Companies Act, 2013 as at the year end.

### Interest rate, nature of security and terms of repayment are:

Nature of security

A These are secured by a first pari-passu charge by hypothecation / mortgage over all the property, plant and equipment (present and future) of the Company other than the assets exclusively charged to other lenders.

B These are secured by a second charge on entire current assets of the Company (present and future), pari-passu with other term lenders.

C Personal guarantee of Mr. Rajeev Jhawar, Managing Director of the Company.

D Pledge of promoter’s holding to the extent of 26% equity in the Company on pari-passu basis.

E These are secured against underlying assets.

Secured term loan - interest rate and terms of repayment

(a) Rupee term loan from a bank amounting to Rs. 1,876 lakhs (31st March, 2017 : Rs. 1,875 lakhs) is repayable in four quarterly instalments from 30th June, 2018 to 31st March, 2019. Interest is payable on monthly basis at one year marginal cost of fund lending rate of the bank plus 2.40% p.a.

(b) Rupee term loan from a bank amounting to Rs. 4,125 lakhs (31st March, 2017 : Rs. 2,750 lakhs) is repayable in four quarterly instalments from 30th June, 2018 to 31st March, 2019. Interest is payable on monthly basis at one year marginal cost of fund lending rate of the bank plus 2.90% p.a.

(c) Rupee term loan from a bank amounting to Rs. 225 lakhs (31st March, 2017 : Rs. Nil) is repayable in one instalment on 31st March, 2019. Interest is payable on monthly basis at one year marginal cost of fund lending rate of the bank plus 2.50% p.a.

(d) Rupee term loan from a bank amounting to Rs. 19 lakhs (31st March, 2017 : Rs. Nil) is repayable in one instalment on 31st March, 2019.

Interest is payable on monthly basis at one year marginal cost of fund lending rate of the bank plus 2.85% p.a.

(e) External commercial borrowing from a bank amounting to Rs. Nil (31st March, 2017 : Rs. 32,425 lakhs) was repayable in three quarterly instalment from 28th April 2017 to 31st January 2018. Interest was payable on quarterly basis at three month LIBOR plus 2.85% p.a.The loan has been repaid during the year.

(f) Rupee term loan from a bank amounting to Rs. 71 lakhs (31st March, 2017 : Rs. Nil) is repayable in one instalment on 31st March, 2019. Interest is payable on monthly basis at 11.55% p.a.

(g) Rupee term loan from a bank amounting to Rs. 1,400 lakhs (31st March, 2017 : Rs. 1,400 lakhs) is repayable in four quarterly instalments from 30th April, 2018 to 31st January, 2019. Interest is payable on monthly basis at one year marginal cost of fund lending rate of the bank plus 2.90% p.a.

(h) Rupee term loan from a bank amounting to Rs. 1,125 lakhs (31st March, 2017 : Rs. 846 lakhs) is repayable in four quarterly instalments from 30th June, 2018 to 31st March, 2019. Interest is payable on monthly basis at base rate of the bank plus 1.75% p.a.

(i) Rupee term loan from a bank amounting to Rs. 1,875 lakhs (31st March, 2017 : Rs. Nil) is repayable in four quarterly instalments from 28th June, 2018 to 29th March, 2019. Interest is payable on monthly basis at base rate of the bank plus 2.00% p.a.

(j) Rupee term loan from a bank amounting to Rs. 3,750 lakhs (31st March, 2017 : Rs. Nil) is repayable in four quarterly instalments from 28th June, 2018 to 31st March, 2019. Interest is payable on monthly basis at base rate of the bank plus 2.00% p.a.

(k) Rupee term loan from a bank amounting to Rs. 25 lakhs (31st March, 2017 : Rs. Nil) is repayable in one instalments on 31st March, 2019. Interest is payable on monthly basis at base rate of the bank plus 2.00% p.a.

(l) Rupee term loan from a bank amounting to Rs. 1,000 lakhs (31st March, 2017 : Rs. Nil) is repayable in four quarterly instalments from 30th June, 2018 to 31st March, 2019. Interest is payable on monthly basis at base rate of the bank plus 1.65% p.a.

(m) Rupee term loan from a bank amounting to Rs. 13 lakhs (31st March, 2017 : Rs. Nil) is repayable in one instalment on 31st March, 2019. Interest is payable on monthly basis at one year marginal cost of fund lending rate of the bank plus 1.85% p.a.

(n) Rupee term loan from a financial institution amounting to Rs. Nil (31^st March, 2017 : Rs. 13,750 lakhs) was repayable in three quarterly instalments from 1st April 2017 to 1st October, 2017. Interest was payable on monthly basis at long-term minimum lending rate plus 2.00% p.a. The loan has been repaid during the year.

(o) Rupee term loan from a financial institution amounting to Rs. 16,250 lakhs (31st March, 2017 : Rs. 1,000 lakhs) is repayable in three quarterly instalments from 1st April 2018 to 1st October, 2018. Interest is payable on monthly basis at long-term minimum lending rate plus 1.85% p.a.

(p) Rupee loans from a body corporate amounting to Rs. 468 lakhs (31st March, 2017 : Rs. 414 lakhs) is repayable in sixty quarterly instalments (comprising of various loans with different quarterly payment schedules) between 1st April, 2018 to 31st March, 2019. Interest is payable on quarterly basis at 11.81% p.a.

* Advance from customers represents the amount received towards sale of goods and are non-interest bearing

# Statutory dues primarily includes payable in respect of Goods and Services Tax (GST), excise duty, royalties, tax deducted at source etc. ## represent liabilty towards renewable power obligation Sale of goods includes excise duty collected from customers of Rs. 10,718 lakhs (31st March, 2017: Rs. 35,939 lakhs). Sale of goods net of excise duty is Rs. 3,89,071 lakhs (31st March, 2017: Rs. 3,13,873 lakhs). Revenue from operations for periods up to 30th June, 2017 includes excise duty. From 1st July, 2017 onwards the excise duty and most indirect taxes have been replaced by Goods and Service Tax (GST). The Company collects GST on behalf of the Government. Hence, GST is not included in Revenue from operations. In view of the aforesaid change in indirect taxes, Revenue from operations for the year ended 31st March, 2018 is not comparable with 31st March, 2017.

# Rs. 3,335 lakhs (31st March, 2017 : Rs. 3,310 lakhs) on account of profit on sale of land.

## Rs. Nil (31st March, 2017 : Rs. 519 lakhs) towards sale of its entire stake in Dove Airlines Private Limited.

### Rs. Nil (31st March, 2017 : Rs. 3,221 lakhs) towards recognition of accumulated cenvat credit against service tax paid on various input services at the Iron Ore Mines, pertaining to Steel segment.

2. Significant accounting judgements, estimates and assumptions

The preparation of the financial statements requires management to make judgements, estimates and assumptions that affect the reported amounts and the disclosures. The Company based its assumptions and estimates on parameters available when the financial statements were prepared and these are reviewed at each Balance Sheet date. Uncertainty about these assumptions and estimates could result in outcomes that may require a material adjustment to the reported amounts and disclosures.

(i) Useful economic lives of property, plant and equipment and impairment of non-financial assets

Property, plant and equipment are depreciated over their useful economic lives. Management reviews the useful economic lives at least once a year and any changes could affect the depreciation rates prospectively and hence the asset carrying values. The Company also reviews its property, plant and equipment, for possible impairment if there are events or changes in circumstances that indicate that carrying values of the assets may not be recoverable. In assessing the property, plant and equipment for impairment, factors leading to significant reduction in profits such as changes in commodity prices, the Company’s business plans and changes in regulatory environment are taken into consideration.

Impairment exists when the carrying value of an asset or cash generating unit exceeds its recoverable amount, which is the higher of its fair value less costs of disposal and its value in use. The fair value less costs of disposal calculation is based on available data from binding sales transactions, conducted at arm’s length, for similar assets or observable market prices less incremental costs for disposing of the asset. The value in use calculation is based on a DCF model. The carrying value of the assets of a cash generating unit (CGU) is compared with the recoverable amount of those assets, that is, the higher of fair value less costs of disposal and value in use. Recoverable value is based on the management estimates of commodity prices, market demand and supply, economic and regulatory climates, long-term plan, discount rates and other factors. Any subsequent changes to cash flow due to changes in the above mentioned factors could impact the carrying value of the assets.

(ii) Provisions and contingencies

The assessments undertaken in recognising provisions and contingencies have been made in accordance with the applicable Ind AS. A provision is recognized if, as a result of a past event, the Company has a present legal or constructive obligation that can be estimated reliably and it is probable that an outflow of economic benefits will be required to settle the obligation. Where the effect of time value of money is material, provisions are determined by discounting the expected future cash flows. The Company has capital commitments in relation to various capital projects which are not recognized on the balance sheet. In the normal course of business, contingent liabilities may arise from litigation and other claims against the Company. Guarantees are also provided in the normal course of business. There are certain obligations which management has concluded, based on all available facts and circumstances, are not probable of payment or are very difficult to quantify reliably, and such obligations are treated as contingent liabilities and disclosed in the notes but are not reflected as liabilities in the financial statements. Although there can be no assurance regarding the final outcome of the legal proceedings in which the Company is involved, it is not expected that such contingencies will have a material effect on its financial position or profitability.

(iii) Provisions for site restoration and rehabilitation

In determining the fair value of the provision, assumptions and estimates are made in relation to discount rates, the expected cost to dismantle and remove the plant from the site and the expected timing of those costs. The Company estimates that the costs would be incurred upon the expiration of the lease and calculates the provision using the DCF method.

The iron ore mines is being governed by Mineral Conservation and Development Rules, 1988 (MCDR), which requires final mines closure plan to be submitted before two years from the date of intended closure. The mining lease operation is valid up to the year 2055 and accordingly, final mining closure plan is required to be submitted in the year 2053 or any earlier date when mine is intended to be closed due to any reason in future, which is not visible in next two years.

MCDR requires mining plan to be approved for every 5 years which consists of progressive mine closure plan which is being reviewed for implementation at every occasion of approval in 5 years and devised for next 5 years. As such, in case of iron ore mine there will be no incremental activities required at the stage of final mine closure plan beyond the activities of progressive mine closure plan.

(iv) Defined benefit plans

The cost and the present value of the defined benefit gratuity plan and long term service award are determined using actuarial valuations. An actuarial valuation involves making various assumptions that may differ from actual developments in the future. These include the determination of the discount rate, future salary increases and mortality rates. Due to the complexities involved in the valuation and its long-term nature, a defined benefit obligation is highly sensitive to changes in these assumptions. All assumptions are reviewed at each reporting date. The parameter most subject to change is the discount rate. In determining the appropriate discount rate for plans, the management considers the interest rates of Government bonds in currencies consistent with the currencies of the post-employment benefit obligation. The mortality rate is based on publicly available mortality table. Those mortality tables tend to change only at interval in response to demographic changes. Future salary increases and gratuity increases are based on expected future inflation rates.

(v) Taxes

Deferred tax assets are recognised for unused tax losses to the extent that it is probable that taxable profit will be available against which the losses can be utilised. Significant management judgement is required to determine the amount of deferred tax assets that can be recognised, based upon the likely timing and the level of future taxable profits together with future tax planning strategies.

Deferred tax assets on unabsorbed depreciation / business loss have been recognised to the extent of deferred tax liabilities on taxable temporary differences available. It is expected that any reversals of the deferred tax liability would be offset against the reversal of the deferred tax assets.

(vi) Fair value measurement

When fair value of financial assets and financial liabilities recorded in the balance sheet can not be measured based on quoted prices in active markets, their fair value are measured using valuation techniques which involve various judgements and assumptions that may differ from actual developments in the future.

(vii) Non-current assets held for sale

Assets and liabilities of non-current assets held for sale are measured at the lower of carrying amount and fair value less cost to sale. The determination of fair value less costs to sale include use of management estimates and assumptions. The fair value has been estimated using valuation techniques (including income and market approach) which includes unobservable inputs.

(viii) Valuation of Inventories

The Company follows suitable provisioning norms for writing down the value of slow-moving, non-moving and surplus inventory. This involves various judgements and assumptions that may differ from actual developments in the future. Slow moving inventory has been disclosed under Note 8 - Inventories.

3. Commitments and contingencies A Leases

Operating lease commitments — Company as lessee

The Company has two non-cancellable operating lease agreements both having a tenure of fifteen years, in connection with establishment and operation of plants, by the lessor, for production of gaseous oxygen to cater to the Company’s Steel Plant at Jamshedpur. One of such agreements became operative in 200102 (Lease A) and the other one has become operative in 2007-08 (Lease B). Both these lease agreements had been extended till 2026-27. The Company pays minimum lease rent and fixed, as well as, variable operating and maintenance charges for both the leases. There are no subleases and contingent rent in the lease arrangements.

In respect of lease A, 30% of lease rent, fixed and variable operation and maintenance charges are escalated every year in the same proportion as increase in Wholesale Price Index published by the Reserve Bank of India in its bulletin (base period 1st August, 1999 ).

In respect of lease B, 70% of lease rents and operation and maintenance charges are escalated every year in the same proportion as increase in Wholesale Price Index published by the Reserve Bank of India in its bulletin ( base period 20th April, 2007).

Future minimum rentals payable under all non-cancellable operating leases are as follows:

* Rs. 2,086 lakhs (31st March, 2017 : Rs. 2,197 lakhs) and Rs. 165 lakhs (31st March, 2017 : Rs. 175 lakhs) is booked under consumption of stores and spares / loose tools and Rent and hire charges respectively.

The Company has entered into cancellable operating lease arrangements for another gaseous oxygen plant, accommodation for office spaces and employees residential accommodation etc. Tenure of leases generally vary between 1 and 10 years.There are no subleases and contingent rent in the lease arrangements. Terms of the lease include operating term for renewal, increase in rent in future periods and term of cancellation. Related lease rentals aggregating Rs. 358 lakhs (31st March, 2017 : Rs. 486 lakhs) have been debited to the Statement of Profit and Loss in Rent and hire charges.

** Includes demand aggregating to Rs. 2,968 lakhs (31st March, 2017 : Rs. 2,813 lakhs) received by the Company towards entry tax in West Bengal and Punjab. Subsequent to the decision of the Hon’ble Supreme Court of India, vide order dated 11th November, 2016, upholding the rights of State Governments to impose entry tax, the Company has filed petitions before the Hon’ble High Courts of the aforesaid States and also Jharkhand on grounds that entry tax imposed by respective State legislations is discriminatory in nature. Pending decisions by the Hon’ble High Courts, the Company’s obligation, if any, towards entry tax is not ascertainable. Based on legal opinion obtained, management believes that there will be no adverse impact on the Company.

# In respect of one case, the Company has given an undertaking to deposit Rs. 1,922 lakhs in six instalments within a period of six months from January 2018. Against the same, the Company has deposited Rs. 300 lakhs in respect of first instalment in January 2018.

* Future cash outflows in respect of the above matters are determinable only on receipt of judgments / decisions pending at various forums / authorities. Based on discussions with the solicitors / favourable decisions in similar cases / legal opinions taken by the Company, the management believes that the Company has a good chance of success in above mentioned matters and hence no provision there against is considered necessary.

* Contribution towards Provident Fund for certain employees is made to the regulatory authorities. Such provident fund benefit is classified as defined contribution scheme as the Company does not carry any further obligations, apart from the contribution made on a monthly basis which is recognised as expense in the statement of profit and loss, as indicated above.

(b) Post employment defined benefit plans

I. Gratuity plan

The Company has a defined benefit gratuity plan. Every employee who has completed five years or more of service is entitled to gratuity on terms not less favourable than the provisions of The Payment of Gratuity Act, 1972. The scheme is funded with an insurance company.

II. Long term service award

Employees of the Company rendering greater than twenty years of service will receive long service award on all causes of exit as per the Company’s policy. The cost of providing benefits under this plan is determined by actuarial valuation using the projected unit credit method by independent qualified actuaries at the year end.

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

The above sensitivity analysis may not be representative of the actual benefit obligation as it is unlikely that the change in assumptions would occur in isolation of one another as some of the assumptions may be correlated.

In presenting the above sensitivity analysis, the present value of defined benefit obligation has been calculated using the project unit credit method at the end of reporting period, which is the same as that applied in calculating the defined benefit obligation liability recognized in the balance sheet.

K Risk analysis

Company is exposed to a number of risks in the defined benefit plans. Most significant risks pertaining to defined benefit plans and management’s estimation of the impact of these risks are as follows:

(i) Interest risk

A decrease in the interest rate on plan assets will increase the plan liability.

(ii) Longevity risk / Life expectancy

The present value of the defined benefit plan liability is calculated by reference to the best estimate of the mortality of plan participants both during and at the end of the employment. An increase in the life expectancy of the plan participants will increase the plan liability.

(iii) Salary growth risk

The present value of the defined benefit plan liability is calculated by reference to the future salaries of plan participants. An increase in the salary of the plan participants will increase the plan liability.

(iv) Investment risk

The Gratuity plan is funded with Life Insurance Corporation of India (LIC). The Company does not have any liberty to manage the fund provided to LIC. The present value of the defined benefit plan liability is calculated using a discount rate determined by reference to Government of India bonds. If the return on plan asset is below this rate, it will create a plan deficit.

III Provident Fund

Provident Fund contributions in respect of employees [other than those covered in (a) above] are made to Trusts administered by the Company and such Trusts invest funds following a pattern of investments prescribed by the Government. Both the employer and the employees contribute to this Fund and such contributions together with interest accumulated thereon are payable to employees at the time of their separation from the Company or retirement, whichever is earlier. The benefit vests immediately on rendering of services by the employee. The interest rate payable to the members of the Trusts is not lower than the rate of interest declared annually by the Government under the Employees’ Provident Funds and Miscellaneous Provisions Act, 1952 and shortfall, if any, on account of interest is to be made good by the Company. In terms of the guidance on implementing Indian Accounting Standard 19 on Employee Benefits, a provident fund set up by the Company is treated as a defined benefit plan in view of the Company’s obligation to meet interest shortfall, if any.

The Actuary has carried out actuarial valuation of plan’s liabilities and interest rate guarantee obligations as at the balance sheet date using projected unit credit method and deterministic approach as outlined in the guidance note 29 issued by the Institute of Actuaries of India. Based on such valuation, there is no future anticipated shortfall with regard to interest rate obligation of the Company as at the balance sheet date. Further during the period, the Company’s contribution Rs 554 lakhs (31st March, 2017 : Rs 513 lakhs) to the Provident Fund Trust, has been expensed under “Contribution to Provident and Other Funds”. Disclosures given hereunder are restricted to the information available as per the Actuary’s report.

Principal actuarial assumptions

Principal actuarial assumptions used to determine the present value of the defined benefit obligation are as follows:

* Amount is below the rounding off norm adopted by the Company.

Terms and conditions of transactions with related parties

The sales to and purchases from related parties are made on terms equivalent to those that prevail in arm’s length transactions. For the year ended 31st March, 2018 and 31st March, 2017, the Company has not recorded any impairment of receivables relating to amounts owed by related parties. This assessment is undertaken each financial year through examining the financial position of the related party and the market in which the related party operates.

The Company routinely enters into transactions with these related parties in the ordinary course of business at market rates and terms.

As the future liability for gratuity and leave is provided on an actuarial basis for the Company as a whole, the amount pertaining to key management personnel is not ascertainable and therefore not included above.

4. Segment information

Based on evaluation of the Company’s business performance by the Chief operating decision maker, the Company’s businesses are organised in the following reportable segments :

- The steel segment, which manufactures and sells steel wire rods, rolled products, billets, pig iron and allied products.

- The wire and wire ropes segment which manufactures and sells steel wires, strands, wire ropes, cord, bright bar, related accessories, etc.

- Others include manufacturing and selling of wire drawing and allied machines.

The Company’s financing (including finance costs and finance income) and income taxes are managed on a Company level and are not allocated to operating segments.

Transfer prices between operating segments are on an arm’s length basis.

The following table presents revenue and profit information and certain asset information regarding the Company’s business segment as at and for the year ended 31st March, 2018 and 31st March, 2017.

* Revenue aggregating Rs. 55,364 lakhs from one customer constituted 10% or more of the Company’s total revenue for the year. However, revenue from any single customer did not constitute 10% or more of the total revenue during the previous year.

The following explains the judgements and estimates made in determining the fair values of the financial instruments that are recognised and measured at fair value through profit and loss. To provide an indication about the reliability of the inputs used in determining fair value, the Company has classified its financial investments into the three levels prescribed under the accounting standard.

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

Level 1 hierarchy includes financial instruments measured using quoted prices in active markets for identical assets or liabilities.

Level 2 hierarchy includes the fair value of financial instruments that are not traded in an active market (for example, over-the counter derivatives) and the fair value is determined using valuation techniques which maximise the use of observable market data and rely as little as possible on entity-specific estimates. If all significant inputs required to fair value an instrument are observable, the instrument is included in level 2.

If one or more of the significant inputs is not based on observable market data, the instrument is included in level 3.

There are no transfers between level 1 and 2 during the year. The Company’s policy is to recognise transfers into and transfers out of fair value hierarchy levels as at the end of the reporting period.

5 A. Financial risk management objectives and policies Risk management framework

The Company’s board of directors has overall responsibility for the establishment and oversight of the Company’s risk management framework. The board of directors has established the Risk Management Committee (RMC) which is responsible for developing and monitoring the Company’s risk management policies.

The Company’s risk management policies are established to identify and analyse the risks faced by the Company, to set appropriate risk limits and control and monitor risks and adherence to limits. Risk management policies and systems are reviewed regularly to reflect changes in market conditions and the Company’s activities.

The Company’s activities expose it to market risk, liquidity risk and credit risk which are measured, monitored and managed to abide by the principles of risk management.

(a) Credit risk

Credit risk refers to the risk of financial loss that may arise from counterparty failure on its contractual obligations resulting in financial loss to the Company. Credit risk encompasses both the direct risk of default and the risk of deterioration of creditworthiness as well as concentration risks.

The Company controls its own exposure to credit risk. All external customers undergo a creditworthiness check. The Company performs an on-going assessment and monitoring of the financial position and the risk of default. Based on the aforesaid checks, monitoring and historical data, the Company does not perceive any significant credit risk on trade receivables.

In addition, as part of its cash management and credit risk function, the Company regularly evaluates the creditworthiness of financial and banking institutions where it deposits cash and performs trade finance operations. The Company primarily has banking relationships with the public sector, private and large international banks with good credit rating.

The Company’s exposure to customers is diversified and no single customer contributes to more than 10% of outstanding trade receivables as at 31st March, 2018 and 31st March, 2017 respectively.

The maximum exposure to the credit risk at the reporting date is the carrying value of all financial assets amounting to Rs. 78,614 lakhs (31st March, 2017 : Rs. 73,573 lakhs) as disclosed in note 37A.

(b) Liquidity risk

The Company has liquidity risk monitoring processes covering short-term, mid-term and long-term funding. Liquidity risk is managed through maintaining adequate amount of committed credit facilities and loan funds. The company also has plans to sell some of its identified non core assets to manage its liquidity position. Management regularly monitors projected and actual cash flow data, analyses the repayment schedules of the existing financial assets and liabilities and performs annual detailed budgeting procedures coupled with rolling cash flow forecasts.

The contractual maturities of the Company’s financial liabilities are presented below:-

* Includes non-current borrowings, current borrowings, current maturities of non-current borrowings and committed interest payments at the prevailing interest rate

The amount of guarantees given on behalf of subsidiaries included in note 33 B (iii) represents the maximum amount the Company could be forced to settle for the full guaranteed amount. Based on the expectation at the end of the reporting period, the Company considers that it is more likely than not that such an amount will not be payable under the arrangement.

(c) Market risk

Market risk is the risk that the fair value of future cash flows of a financial instrument will fluctuate because of changes in market prices. The Company is exposed to different types of market risks. The market risk is the possibility that changes foreign currency exchange rates, interest rates and commodity prices may affect the value of the Company’s financial assets, liabilities or expected future cash flows.

The fair value information presented below is based on the information available with the management as of the reporting date.

(c.1) Foreign currency exchange risk

Foreign currency risk is the risk that the fair value or future cash flows of an exposure will fluctuate because of changes in foreign exchange rates. The risk of fluctuations in foreign currency exchange rates on its financial liabilities including borrowing, trade and other payable etc., are mitigated through the use of derivative instruments. The Company does not use derivative financial instruments for trading or speculative purposes.

A reasonably possible strengthening / weakening of the Indian Rupee against such foreign currency (converted to US Dollars) as at 31st March, 2018 and 31st March, 2017 would have affected profit or loss by the amounts shown below. This analysis assumes that all other variables remain constant and ignores any impact of forecasted sales and purchases.

Derivative financial instruments

The Company holds derivative financial instruments such as foreign currency forward to mitigate the risk of changes in exchange rates on foreign currency exposures. The counter party for these contracts is generally a bank or a financial institution.

The table below analyses the derivative financial instruments into relevant maturity groupings based on the remaining maturity period.

(c.2) Interest rate risk

Interest rate risk is measured by using the cash flow sensitivity for changes in variable interest rates. Any movement in the reference rates could have an impact on the Company’s cash flows as well as costs. The Company is subject to variable interest rates on some of its interest bearing liabilities. The Company’s interest rate exposure is mainly related to debt obligations.

The exposure of the Company’s financial assets and financial liabilities as at 31st March, 2018 and 31st March, 2017 to interest rate risk is as follows :

If the interest rates applicable to floating rate instruments is increased / decreased by 1%, the profit before tax for the year ended 31st March, 2018 would decrease/(increase) by Rs 4,903 lakhs (31st March, 2017 : Rs 5,211 lakhs) on an annualised basis. This assumes that the amount and mix of fixed and floating rate debt remains unchanged during the year from that in place as at year end.

(c.3) Commodity price risk

The Company’s revenue is exposed to the risk of price fluctuations related to the sale of its steel and wire & wire rope products. Market forces generally determine prices for such products sold by the Company. These prices may be influenced by factors such as supply and demand, production costs (including the costs of raw material inputs) and global and regional economic conditions and growth. Adverse changes in any of these factors may reduce the revenue that the Company earns from the sale of its steel and wire & wire rope products.

The Company primarily purchases its raw materials (except iron ore extracted from captive mine) in the open market from third parties. The Company is, therefore, subject to fluctuations in prices of coking coal, thermal coal, iron ore, ferro alloys, zinc, scrap and other raw material inputs. The Company purchased substantially all of coal requirements from third parties in the open market during the year ended 31st March, 2018 and 31st March, 2017 respectively.

The Company aims to sell the products at prevailing market prices. Similarly the Company procures key raw materials like iron ore and coal based on prevailing market rates as the selling prices of steel prices and the prices of input raw materials move in the same direction.

The Company does not have any commodity forward contract for Commodity hedging.

The following table details the Company’s sensitivity to a 5% movement in the input price of iron ore and coal. The sensitivity analysis includes only 5% change in commodity prices for quantity sold or consumed during the year, with all other variables held constant. A positive number below indicates an increase in profit or equity where the commodity prices decrease by 5%. For a 5% increase in commodity prices, there would be a comparable impact on profit or equity, and the balances below are negative.

5 B. Derivative Financial Instruments

The Company uses derivative instruments as part of its management of exposure to fluctuations in foreign currency exchange rates. The Company does not acquire or issue derivative financial instruments for trading or speculative purposes. The Company does not enter into complex derivative transactions to manage the treasury risks. Treasury derivative transactions are normally in the form of forward contracts and these are subject to the Company guidelines and policies. The fair values of all derivatives are separately recorded in the balance sheet within current and non-current assets and liabilities. The use of derivatives can give rise to credit and market risk. The Company tries to control credit risk as far as possible by only entering into contracts with reputable banks and financial institutions. The use of derivative instruments is subject to limits, authorities and regular monitoring by appropriate levels of management. The limits, authorities and monitoring systems are periodically reviewed by management and the Board. The market risk on derivatives is mitigated by changes in the valuation of the underlying assets, liabilities or transactions, as derivatives are used only for risk management purposes.

5 C. Capital management

For the purpose of the Company’s capital management, capital includes issued equity capital and other equity. The Company’s primary capital management objectives are to ensure its ability to continue as a going concern and to optimize the cost of capital in order to enhance value to shareholders.

The Company manages its capital structure and makes adjustments to it as and when required. To maintain or adjust the capital structure, the Company may pay dividend or repay debts, raise new debt or issue new shares. The Company monitors capital using a gearing ratio, which is net debt divided by total capital plus net debt. No major changes were made in the objectives, policies or processes for managing capital during the year ended 31st March, 2018 and 31st March, 2017 respectively. The Company includes within net debt, interest bearing loans and borrowings, less cash and cash equivalents.

The following table summarises the capital of the Company -

No changes were made in the objectives, policies or processes for managing capital during the years ended 31st March, 2018 and 31st March, 2017.

6 (a) The Company was allocated two coal blocks namely, Kathautia Coal Block and Lohari Coal Block in the State of Jharkhand for captive use. Pursuant to the Supreme Court order dated 24th September, 2014 followed by promulgation of the Coal Mines (Special Provisions) Act, 2015, (CMSP Act), the allocation of all coal blocks since 1993, including the aforesaid coal blocks allocated to the Company was cancelled with effect from 24th September, 2014 in case of Lohari Coal Block and 1st April, 2015 in the case of Kathautia Coal Block.

Through the process of public auction as envisaged in the CMSP Act, the aforesaid Coal Blocks of the Company had been allocated to other successful bidders by the Central Government. Pursuant to conclusion of such auction, the Central Government had also issued vesting orders for Kathautia and Lohari Coal Blocks for transfer and vesting the Company’s rights, title and interest in and over the land and mine infrastructure of the said coal blocks to the respective successful bidders.

Upon de-allocation of aforesaid coal blocks, the Company has reclassified its related non-current assets in form of land, movable and immovable properties, advances etc. and presented the same in the Balance Sheet as follows:

Under the CMSP Act, the Company is entitled to receive compensation for its investment in the land with interest @12% p.a. from the date of purchase / acquisition till the date of the execution of the vesting order and compensation for mine infrastructure as per the written down value reflected in the audited balance sheet of the Company for the previous financial year. Under the said Act, a successful bidder or allottee may negotiate with prior allottee, being the Company, to own or utilize movable properties of the latter used in coal mining operations on such terms and conditions as may be mutually agreed.

During the previous year, the Hon’ble Jharkhand High Court had, vide order dated January 11, 2017, directed the State Government of Jharkhand to take decision on denotification of land acquisition proceedings in respect of land which was being acquired for the Company’s mining purposes. The land acquisition proceedings have since been denotified by the State Government of Jharkhand. Based on interactions with and intimations received from the State Government of Jharkhand, management believes that the advance of Rs 10,532 lakhs deposited by the Company for such acquisition will be refunded/ received within the next financial year.

Further, the Company is also engaged in ongoing negotiations with the party to whom the aforesaid Coal Blocks were subsequently allotted for realization of compensation / investments in the mines.

After taking into consideration the present developments as set out above and the recourses available to the Company for recovery of investments from the concerned authorities / parties on the basis of advice of legal counsel, management is of the opinion that the realizable value of aforesaid assets will not be less than their carrying values.

6 (b) The Company has earmarked for disposal certain assets of its Bright Bar plant at Chennai. The written down value of such assets amounting to Rs.1,295 lakhs (31st March, 2017: Rs 1,386 lakhs) has been disclosed as “Assets held for sale”.

6 (c) The Company had closed down the construction steel division at Agra for subsequent sale of its land, building and plant and equipment. The written down value of such assets amounting to Rs.1,035 lakhs (31st March, 2017: Rs 1,035 lakhs) has been disclosed as “Assets held for sale”.

6 (d) The Company has received advance amounting to Rs 390 lakhs against sale of land (31st March, 2017 : Rs 1,239 lakhs) Consequently, the written down value of such assets amounting to Rs 114 lakhs (31st March, 2017 : Rs 750 lakhs) has been disclosed as “Assets held for sale”.

6 (e) Assets held for sale includes 122 plots of Freehold Land amounting to Rs. 282 lakhs (31st March, 2017 : Rs. 282 lakhs) located at Coal Mine sites in respect of which conveyance deeds are yet to be executed in favour of the Company.

7. Disclosures pursuant to the Regulation 34(3) read with para A of Schedule V to SEBI Listing Regulations, 2015

I. Loans and advances in the nature of loans to subsidiaries

II. As per the Company’s policy, loan to employees are not considered in (I) above.

8. Group information

The Company has following subsidiaries and jointly controlled entities for which the Company prepares Consolidated Financial Statements as per Ind AS 110: Consolidated Financial Statements.

@ Represents step-down subsidiary

* Represents step-down jointly controlled entity

# During the financial year 2012-13, Usha Martin International Limited (UMIL), a subsidiary of the Company had issued and allotted 5,13,860 “C” ordinary shares of nominal value GBP 0.61 per share with voting rights to a party with resultant reduction in Company’s control from 100% to 92% in UMIL. In accordance with the terms of the above agreement, UMIL has exercised the option to purchase the shares from the aforesaid shareholder at the price of GBP 0.658 per share for an aggregate purchase price of GBP 3,38,119.88, on July 3, 2017. As a result, effective July 3, 2017, UMIL became a wholly owned subsidiary of the Company.

9. During the year, the Company has continued to incur losses although its performance in terms of profitability and cash flows has improved in the later part of the year primarily due to recent improvements in the domestic steel sector. At the year end, the Company’s current liabilities exceeds its current assets by Rs. 176,620 Lakhs (31st March, 2017 : Rs. 161,141 lakhs). However, based on the Company’s expected improvement in performance, continuation / roll over of working capital facilities from banks, expected receipt of compensation in respect of de-allocated coal block and sale of business / non-core assets being evaluated, management believes that the Company will be in a position to meet its obligations towards the banks and financial institutions and continue its present scale of operations for the next twelve months.

10. The Board of Directors of the Company continues to evaluate the possibility of sale of its “Wire and Wire Rope” business.

11. Previous year’s figures have been regrouped / rearranged wherever necessary, to conform to current year’s presentation.

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Mar 31, 2016

(a) Represents a free reserve not held for any specific purpose.

1. Equity Warrant application money pending allotment

During the previous year the Company had issued 34,285,600 Equity Warrants, each convertible into one Equity Share of Re. 1/- each at the option of holders within a period of eighteen months from the date of allotment, at a price ("Consideration”) of Rs. 35/- (which includes premium of Rs. 34/- per share), on preferential allotment basis to promoter/promoters'' group and their relatives and associates in keeping with related SEBI Regulations. As per the terms of the issue, 25% of the Consideration is payable by the applicants before allotment of Equity Warrants and the balance 75% of consideration will be payable before the conversion of such Warrants into Equity Shares. Further, if the conversion option is not exercised within the stipulated time, the amount paid at the time of application (being 25% of the Consideration) shall be forfeited.

Also refer Note 4C below

2. Money received against Equity Warrants

The Company had allotted on 1st April, 2015, 34,285,600 convertible Equity Warrants referred to in Note 4B above on a preferential basis to promoter / promoters'' group and their relatives and associates in lots under different Series namely I, J and K, convertible at the option of the warrant holders within 30th September, 2016, 31st March, 2016 and 30th September, 2016 respectively as per the terms and conditions mentioned in Note 4B above.

The holders of the Series J of the said Equity Warrants did not exercise the option for conversion of entire 7,50,000 Equity Warrants issued under the aforementioned Series within 31st March, 2016 (the latest date for conversion for the said Series) and accordingly the entire Equity Warrants issued under Series J have been cancelled and the amount of Rs.66 received earlier against issue of those warrants have been forfeited by crediting Capital Reserve (Refer Note 4A). The position is summarized below:

Nature of Security and terms of repayment for secured borrowings : Nature of Security

All Term Loans from Financial Institution and Banks are secured by way of Joint Equitable Mortgage by deposit of title deeds of certain immovable properties and hypothecation over movable assets of the Company both present and future subject to prior charges of the Company''s Bankers on specified movable assets for Working Capital requirements.

Secured Loans - Terms of Repayment

(a) Rupee term loan from a Financial Institution amounting to Rs.13,750 (31st March, 2015 : Rs.16,000) is repayable in three quarterly installments from 1st April, 2017 to 1st October, 2017. Interest is payable on monthly basis at Long-term minimum lending rate plus 1.85% p.a.

(b) Rupee term loan from a Financial Institution amounting to Rs.17,250 (31st March, 2015 : Rs. 18,000) is repayable in seven quarterly installments from 1st April, 2017 to 1st October, 2018. Interest is payable on monthly basis at Long-term minimum lending rate plus 1.85% p.a.

(c) Rupee term loan from a Bank amounting to Rs. 1,600 (31st March, 2015 : Rs. 3,200) is repayable in three quarterly installments from 29th April, 2017 to 29th October, 2017. Interest is payable on monthly basis at Base rate of the Bank plus 1.75% p.a.

(d) Rupee term loan from a Bank amounting to Rs. 22,500 (31st March, 2015 : Rs. 23,750) is repayable in twenty quarterly installments from 30th June, 2017 to 31st March, 2022. Interest is payable on monthly basis at Base rate of the Bank plus 2.50% p.a.

(e) Rupee term loan from a Bank amounting to Rs. 18,750 (31st March, 2015 : Rs. 23,750) is repayable in sixteen quarterly installments from 29th June, 2018 to 29th March, 2022. Interest is payable on monthly basis at Base rate of the Bank plus 2.50% p.a.

(f) Rupee term loan from a Bank amounting to Rs. 52,250 (31st March, 2015 : Rs. 55,000) is repayable in twenty seven quarterly installments from 30th June, 2017 to 31st December, 2023. Interest is payable on monthly basis at Base rate of the Bank plus 3.00% p.a.

(g) Rupee term loan from a Bank amounting to Rs. 14,063 (31st March, 2015 : Rs. 14,812) is repayable in twenty three quarterly installments from 30th June, 2017 to 31st December, 2022. Interest is payable on monthly basis at Base rate of the Bank plus 1.75% p.a.

(h) Rupee term loan from a Bank amounting to Rs. 12,000 (31st March, 2015 : Rs. 14,625) is repayable in eighteen quarterly installments from 30th June,

2018 to 30th September, 2022. Interest is payable on monthly basis at Base rate of the Bank plus 2.50% p.a.

(i) Rupee term loan from a Bank amounting to Rs. 12,600 (31st March, 2015 : Rs. 14,000) is repayable in twenty six quarterly installments from 30th April, 2017 to 31st July, 2023. Interest is payable on monthly basis at Base rate of the Bank plus 1.50% p.a.

(j) Rupee term loan from a Bank amounting to Rs. 54,500 (31st March, 2015 : Rs. Nil) is repayable in twenty eitht quarterly installments from 31st March, 2019 to 31st December, 2025. Interest is payable on monthly basis at Base rate of the Bank plus 2.10% p.a.

(k) Rupee term loan from a Bank amounting to Rs. 6,500 (31st March, 2015 : Rs. Nil) is repayable in twenty eitht quarterly installments from 31st March, 2019 to 31st December, 2025. Interest is payable on monthly basis at Base rate of the Bank plus 1.95% p.a.

(l) Rupee term loan from a Bank amounting to Rs. 14,000 (31st March, 2015 : Rs. Nil) is repayable in twenty four quarterly installments from 30th June, 2018 to 31st March, 2024. Interest is payable on monthly basis at Base rate of the Bank plus 1.65% p.a.

(m) Rupee term loan from a Bank amounting to Rs. 8,800 (31st March, 2015 : Rs. Nil) is repayable in twenty eitht quarterly installments from 31st March, 2019 to 31st December, 2025. Interest is payable on monthly basis at Base rate of the Bank plus 2.00% p.a.

(n) Foreign Currency term loan from a Bank amounting to Rs. 33,128 (31st March, 2015 : Rs.62,500) is repayable in four equal quarterly installments from 29th April, 2017 to 31st January, 2018. Interest is payable on quarterly basis at three months USD LIBOR plus 2.85% p.a.

(o) Outstanding balances of loans as indicated in (a) to (n) above are exclusive of current maturities of such loans as disclosed in Note 11.

Unsecured Loan - Terms of Repayment

(a) Rupee term loans from a Body Corporate amounting to Rs.1,229 (31st March, 2015 Rs. 890) is repayable in sixteen installments from 1st April, 2017 to 1st January, 2021. Interest is payable on quarterly basis at 11.81% p.a. and is exclusive of current maturities of such loan as disclosed in Note 11.

Provision for Restoration of Mines Sites is held for the purpose of meeting site restoration obligation pursuant to Rule 23 under Mineral Conservation and Development (Amendment Rules, 2003) read with Section 18 of the Mines and Minerals (Development and Regulation) Act, 1957.

@ Nature of Security - Working Capital Loans from Banks are secured by hypothecation of all current assets of the Company. Further such loans from Banks are also secured by charge on certain immovable properties, subject to prior charges in favour of Financial Institutions and Banks created/to be created in respect of any existing/future financial assistance/accommodation which has been/may be obtained by the Company.

3(a). The Company had been allocated two Coal Blocks namely, Kathautia Coal Block and Lohari Coal Block in the State of Jharkhand for captive use. Pursuant to the Supreme Court order dated 24th September, 2014 followed by promulgation of the Coal Mines (Special Provisions) Act, 2015, (CMSP Act) the allocation of all Coal Blocks since 1993, including the aforesaid Coal Blocks allocated to the Company stands cancelled with effect from 24th September, 2014 in case of Lohari Coal Block, which was yet to commence mining operations and with effect from 1st April, 2015 in the case of Kathautia Coal Block, which had been carrying out mining operations.

Therefore, through the process of public auction as envisaged in the CMSP Act the aforesaid Coal Blocks of the Company had been allocated to other successful bidders by the Central Government. Pursuant to conclusion of such auction, the Central Government had also issued vesting orders for Kathautia and Lohari Coal Blocks transferring and vesting all the rights, title and interest of the Company in and over the Land and Mine Infrastructure of the said Coal Blocks to the respective successful bidders.

Upon de-allocation of aforesaid coal blocks, the Company has reclassified its related non-current assets in form of land, movable and immovable properties, advances etc. and presented the same in the Balance Sheet as follows:

Under the CMSP Act, the Company is entitled to receive compensation for its investment in the land with interest @12% p.a. from the date of purchase / acquisition till the date of the execution of the vesting order and compensation for mine infrastructure as per the written down value reflected in the audited balance sheet of the Company for the previous financial year. Under the said Act, a successful bidder or allottee may negotiate with prior allottee, being Company, to own or utilize movable properties of the latter used in coal mining operations on such terms and conditions as may be mutually agreed.

The Nominated Authority, Ministry of Coal, Government of India has sanctioned interim claims for the Company''s Kathautia and Lohari Coal Blocks against which the Company has filed various representations but so far without any outcome. In the situation based on legal advice, the Company is contemplating to file two separate writ petitions before the Hon''ble Delhi High Court for both the Coal blocks to realise the claimed compensation.

Further, in respect of advance payment made by the Company to the State Government of Jharkhand for acquisition of land for its coal mining project, the Company has also initiated process of recovery from the said State Government and the Company is also in negotiation with successful bidders of Coal Blocks for realization of compensation / investments in mines, which is ongoing.

After taking into consideration the present developments as set out above and the recourses available to the Company for recovery of investments from the concerned authorities / parties on the basis of advice of Legal Counsel, Management is of the opinion that the realizable value of aforesaid assets will not be less than their carrying values.

4 (b). The Company had closed down the Construction Steel Division at Agra for subsequent disposal of its Land, Building and Plant and Equipment. The written down value of such assets amounting to Rs.926 (31st March, 2015: Rs 926) has been disclosed under Other Current Assets as "Assets held for disposal”.

5(c). Assets held for disposal includes 147 plots of Freehold Land amounting to Rs. 412 located at Coal Mine sites in respect of which conveyance deeds are yet to be executed in favour of the Company.

II. Provident Fund

Provident Fund contributions in respect of employees [other than those covered in (a) above] are made to Trusts administered by the Company and such Trusts invest funds following a pattern of investments prescribed by the Government. Both the employer and the employees contribute to this Fund and such contributions together with interest accumulated thereon are payable to employees at the time of their separation from the Company or retirement, whichever is earlier. The benefit vests immediately on rendering of services by the employee. The interest rate payable to the members of the Trusts is not lower than the rate of interest declared annually by the Government under the Employees'' Provident Funds and Miscellaneous Provisions Act, 1952 and shortfall, if any, on account of interest is to be made good by the Company. In terms of the Guidance on implementing Accounting Standard (AS) 15 on Employee Benefits issued by the Accounting Standards Board of the Institute of Chartered Accountants of India, a provident fund set up by the Company is treated as a defined benefit plan in view of the Company''s obligation to meet interest shortfall, if any.

The Actuary has carried out actuarial valuation of plan''s liabilities and interest rate guarantee obligations as at the balance sheet date using PUCM and Deterministic Approach as outlined in the Guidance Note 29 issued by the Institute of Actuaries of India. Based on such valuation, there is no future anticipated shortfall with regard to interest rate obligation of the Company as at the balance sheet date. Further during the period, the Company''s contribution of Rs. 484 (31st March, 2015 : Rs.613) to the Provident Fund Trust, has been expensed under "Contribution to Provident and Other Funds”. Disclosures given hereunder are restricted to the information available as per the Actuary''s report.

6. Exceptional items in the Statement of Profit and Loss comprise the following:

(a) Pursuant to the Order dated 24th September, 2014 issued by The Hon''ble Supreme Court of India for cancellation of Kathautia and Lohari Coal Blocks of Steel Division, allotted to the Company in earlier years, as well as imposition of additional levy of Rs. 295/- per metric ton of coal extracted from the date of extraction till 31st March 2015, the Company made a provision of Rs. Nil (Previous Year : Rs. 8,373) on prudent basis and without prejudice to its rights.

(b) Write down of the carrying amount of certain assets and other adjustments of Rs. Nil (Previous Year : Rs. 1,643) pertaining to the Coal Blocks.

7. Segment Information for the year ended 31st March, 2016

A. Primary Segment Reporting (by Business Segments)

Composition of Business Segments

Segments have been identified in accordance with the Accounting Standard on Segment Reporting (AS-17) prescribed under the Act. Details of products included in each of the above Segments are given below :

Steel : Steel Wire Rods, Rolled Products, Billets, Pig Iron and allied products.

Wire and Wire Ropes : Steel Wires, Strands, Wire Ropes, Cord, Bright Bar, related accessories, etc.

Others : Jelly Filled Telecommunication Cables, Wire Drawing and allied machineries, etc.

8. Lease Commitments

(a) Operating Lease Commitments

The Company has two non-cancellable operating lease agreements both having a tenure of fifteen years, in connection with establishment and operation of plants, by the lessor, for production of gaseous oxygen to cater to the Company''s Steel Plant at Jamshedpur. One of such agreements became operative in 2001-02 (Lease A) and the other one has become operative in 2007-08 (Lease B). Both these lease agreements had been extended till 2026-27. The Company pays minimum lease rent and fixed, as well as, variable operating and maintenance charges for both the leases.

In respect of lease A, 30% of lease rent, fixed and variable operation and maintenance charges are escalated every quarter in the same proportion as increase in Wholesale Price Index published by the Reserve Bank of India in its bulletin (base period 1st August, 1999 ).

In respect of lease B, 70% of lease rents and operation and maintenance charges are escalated every quarter in the same proportion as increase in Wholesale Price Index published by the Reserve Bank of India in its bulletin ( base period 20th April, 2007)

* Amount is below the rounding off norm adopted by the Company.

(c) Income and Expenses of GWSCL relate to the period from 1st April, 2014 to 9th February, 2015.

(d) Capital Commitment outstanding of Rs. 3 (31st March, 2015 : Rs. 342) related to Pengg Usha Martin Wire Private Limited

(e) Figures in normal type relates to previous year.

II. In view of voluminous data furnishing of particulars such as name, amount outstanding at the year end and maximum amount outstanding during the year in respect of loans and advances in the nature of loan given to employees for medical, furniture, housing, vehicle etc. with interest rate varying from 0 - 6 per cent and repayment terms varying from 1 - 10 years is not considered practicable. Aggregate amount of such advances and loans outstanding at the year end is Rs. 284 [31st March, 2015 : Rs.195).

9. The previous year figures have been reclassified where considered necessary to conform to this year''s classification.

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Mar 31, 2015

(a) 3,58,33,550 (31st March, 2014 : 4,40,93,175) Equity Shares are represented by Global Depository Receipts (GDRs) out of above paid up Equity Shares.

(b) Rights, preference and restrictions attached to shares issued:

The Company has only one class of equity shares having a par value of Re.1/- per share. Each shareholder is eligible for one vote per share held (except in case of GDRs). The dividend if proposed by the Board of Directors is subject to the approval of the shareholders in the ensuing Annual General Meeting, except in case of interim dividend. In the event of liquidation, the equity shareholders are eligible to receive the remaining assets of the Company after distribution of all preferential amounts, in proportion to their shareholding.

2 B. Equity Warrant application money pending allotment

At the Extraordinary General Meeting held on 16th March, 2015, the consent of the Company was accorded to the issuance of 34,285,600 Equity Warrants, each convertible into one Equity Shares of Re. 1/- each at the option of holders within a period of eighteen months from the date of allotment, at a price ("Consideration") of Rs. 35/- (which includes premium of Rs. 34/- per share), on preferential allotment basis to promoter/promoters' group and their relatives and associates in keeping with related SEBI Regulations. As per the terms of the issue, 25% of the Consideration is payable by the applicants before allotment of Equity Warrants and the balance 75% of consideration will be payable before the conversion of such Warrants into Equity Shares. In case the conversion option is not exercised within the stipulated time, the amount paid at the time of application (being 25% of the Consideration) shall be forfeited.

Nature of Security and terms of repayment for secured borrowings : Nature of Security

All Term Loans from Financial Institution and Banks are secured by way of Joint Equitable Mortgage by deposit of title deeds of certain immovable properties and hypothecation over movable assets of the Company both present and future subject to prior charges of the Company's Bankers on specified movable assets for Working Capital requirements.

Secured Loans - Terms of Repayment

(a) Rupee term loan from a Financial Institution amounting to Rs.16,000 (31st March, 2014 : Rs. 19,000) is repayable in six quarterly installments from 20th June, 2016 to 20th September, 2017. Interest is payable on monthly basis at Long-term minimum lending rate plus 1.85% p.a.

(b) Rupee term loan from a Financial Institution amounting to Rs.18,000 (31st March, 2014 : Rs. 19,000) is repayable in ten quarterly installments from 20th June, 2016 to 20th September, 2018. Interest is payable on monthly basis at Long-term minimum lending rate plus 1.85% p.a.

(c) Rupee term loan from a Bank amounting to Rs. 3,200 (31st March, 2014 : Rs. 4,800) is repayable in seven quarterly installments from 29th April, 2016 to 29th October, 2017. Interest is payable on monthly basis at Base rate of the Bank plus 1.75% p.a.

(d) Rupee term loan from a Bank amounting to Rs. 8,000 (31st March, 2014 : Rs. 14,000) is repayable in two quarterly installments from 30th June, 2016 to 30th September, 2016. Interest is payable on monthly basis at Base rate of the Bank plus 1.55% p.a.

(e) Rupee term loan from a Bank amounting to Rs. 23,750 (31st March, 2014 : Rs. 25,000) is repayable in twenty four quarterly installments from 30th June, 2016 to 31st March, 2022. Interest is payable on monthly basis at Base rate of the Bank plus 2.00% p.a.

(f) Rupee term loan from a Bank amounting to Rs. 23,750 (31st March, 2014 : Rs. 25,000) is repayable in twenty four quarterly installments from 29th June, 2016 to 29th March, 2022. Interest is payable on monthly basis at

Base rate of the Bank plus 2.50% p.a.

(g) Rupee term loan from a Bank amounting to Rs. 5,500 (31st March, 2014 : Rs. 8,000) is repayable in five quarterly installments from 31st May, 2016 to 31st May, 2017. Interest is payable on monthly basis at Base rate of the Bank plus 1.55% p.a.

(h) Rupee term loan from a Bank amounting to Rs. 55,000 (31st March, 2014 : Rs. 35,000) is repayable in thirty-one quarterly installments from 30th June, 2016 to 31st December, 2023. Interest is payable on monthly basis at Base rate of the Bank plus 2.50% p.a.

(i) Rupee term loan from a Bank amounting to Rs.14,812 (31st March, 2014 : Rs. 15,000) is repayable in twenty seven quarterly installments from 30th June, 2016 to 31st December, 2022. Interest is payable on monthly basis at Base rate of the Bank plus 2.00% p.a.

(j) Rupee term loan from a Bank amounting to Rs. 14,625 (31st March, 2014 : Rs. 15,000) is repayable in twenty six quarterly installments from 30th June, 2016 to 30th September, 2022. Interest is payable on monthly basis at Base rate of the Bank plus 2.50% p.a.

(k) Rupee term loan from a Bank amounting to Rs. 14,000 (31st March, 2014 : Rs.Nil) is repayable in thirty quarterly installments from 30th April, 2016 to 31st July, 2023. Interest is payable on monthly basis at Base rate of the Bank plus 1.50% p.a.

(l) Foreign Currency term loan from a Bank amounting to Rs. 62,500 (31st March, 2014 : Rs.74,894) is repayable in eight equal quarterly installments from 29th April, 2016 to 31st January, 2018. Interest is payable on quarterly basis at three months USD LIBOR plus 2.85% p.a.

(m) Outstanding balances of loans as indicated in (a) to (l) above are exclusive of current maturities of such loans as disclosed in Note 11.

Unsecured Loan - terms of repayment

(a) Rupee term loans from a Body Corporate amounting to Rs.890 is repayable in nineteen installments from 1st April, 2016 to 1st January, 2020. Interest is payable on quarterly basis at 11.81% p.a. and is exclusive of current maturities of such loan as disclosed in Note 11

(a) The Company's ownership interest and other particulars relating to the Joint Venture Companies have been set out in Note 49.

(b) During the year the Company has purchased 60 Equity Shares of face value of Rs.10 each of Usha Marin Power and Resources Limited to make it a wholly owned subsidiary.

(c) During the year the Company has purchased 76,500 Equity Shares of face value of Rs.10 each of Gustav Wolf Speciality Cords Limited, an erstwhile Joint Venture Company to make it a wholly owned subsidiary.

3. Contingent Liabilities

As at As at 31st March, 31st March, 2015 2014

(a) Claims against the Company not acknowledged as debt

Disputed Tax and Duty for which the Company has preferred appeal before appropriate authorities.

Demand for Income Tax Matters 1,940 1,940

Demand for Sales Tax & Entry Tax # 6,063 3,232

Demand for Excise Duty and Service Tax # 6,583 6,498

Demand for Customs Duty 83 83

Outstanding Labour Disputes 59 48

Disputed Electricity duty rebate matters which is subjudice 552 551

Disputed Demand for Fuel Surcharge matter 1,637 1,637

The writ petition filed by the Company before the Hon'ble High Court of Jharkhand at Ranchi was dismissed by Learned Single Judge vide order dated 8th May 2015. Based on legal opinion obtained, the Company has a strong case and is in a process of filing Letters Patent Appeal (LPA) before the Appellate Jurisdiction of the Hon'ble High Court of Jharkhand at Ranchi to contest the matter.

Disputed Demand for Mining matter for which the Company has filed writ petition before The Hon'ble High 7,033 1,940

Court of Jharkhand at Ranchi.

# Out of the above, stay orders against demand for Sales Tax amounting to Rs. 237 (31st March, 2014 : Rs. 237) and demand for Excise Duty and Service Tax amounting to Rs. 6,404 (31st March, 2014 : Rs. 4,324) have been obtained by the Company.

4 (a). The Company had been allocated two Coal Blocks namely, Kathautia Coal Block and Lohari Coal Block in the State of Jharkhand for captive use. Pursuant to the Supreme Court order dated 24thSeptember, 2014 followed by promulgation of the Coal Mines (Special Provisions) Act, 2015 ( CMSP Act), the allocation of all Coal Blocks since 1993, including the aforesaid Coal Blocks allocated to the Company stands cancelled with effect from 24th September, 2014 in case of Lohari Coal Block, which was yet to commence mining operations and with effect from 1st April , 2015 in case of Kathautia Coal Block, which has been carrying out mining operations.

Thereafter, through the process of public auction as envisaged in the CMSP Act and in which the Company had also participated, the aforesaid Coal Blocks of the Company have been allocated to other successful bidders by the Central Government. Pursuant to conclusion of such auction, the Central Government has issued vesting orders for Kathautia and Lohari Coal Blocks transferring and vesting all the rights, title and interest of the Company in and over the Land and Mine Infrastructure of the said Coal Blocks to the successful bidders.

Upon de-allocation of aforesaid coal blocks, the Company has reclassified its related non-current assets in form of land, movable and immovable properties, advances etc. and presented the same in the Balance Sheet as follows:

Under the CMSP Act, the Company is entitled to receive compensation for its investment in the land with Interest @12% p.a. from the date of purchase/acquisition till the date of the execution of the vesting order and compensation for mine infrastructure as per the written down value reflected in the audited balance sheet of the Company for the previous financial year. Under the said Act, a successful bidder or allottee may negotiate with prior allottee, being the Company, to own or utilize movable properties of the latter used in coal mining operations on such terms and conditions as may be mutually agreed. Further in respect of advance payments made by the Company to the Jharkhand State Government for acquisition of lands for its coal mining projects, the Company also has an option of recovering it from Government.

The Nominated Authority, Ministry of Coal, Government of India has sanctioned an interim claim for the Company's Kathautia Coal Block against which the Company has filed a representation letter. In the meantime to expedite the process, the Company is also under negotiation with the successful bidder of Kathautia Coal Block for realization of compensation/ investments in the said mine.

Any profit or loss arising on aforesaid disposal/settlement, if any, shall be shown in the accounts, as and when the amount of compensation or refund is finally determined by the Government authorities or the amount of consideration is mutually agreed with the successful bidders as the case may be.

After taking into consideration the present development, progress of negotiation with successful bidder and recourse available to the Company for recovery of the investments from the concerned authorities/ parties on the basis of advice of legal counsel, Management is of the opinion that the realizable value of the aforesaid assets will not be less than their carrying values.

5 (a). The Company had decided to close down the Construction Steel Division at Agra and its subsequent disposal of Land, Building and Plant and Equipment. The written down value of such assets amounting to Rs.926 (31st March, 2014:Nil) has been disclosed under Other Current Assets as "Assets held for disposal".

Accordingly, the unutilized portion of Excise Duty and Service Tax amounting to Rs.746 (31st March, 2014:Nil) has been provided for the books.

@ Contribution towards Provident Fund for certain employees is made to the regulatory authorities. Such Provident Fund benefit is classified as Defined Contribution Scheme as the Company does not carry any further obligations, apart from the contribution made on a monthly basis which is recognised as expense in the Statement of Profit and Loss, as indicated above.

(b) Post Employment Defined Benefit Plans I. Gratuity (Funded)

The Company provides for gratuity, a defined benefit retirement plan covering eligible employees. As per the scheme, the Gratuity Trust Funds managed by the Life Insurance Corporation of India (LIC) and other insurance companies make payment to vested employees at retirement, death, incapacitation or termination of employment, of an amount based on the respective employee's eligible salary for specified number of days (ranging from fifteen days to one month) depending upon the tenure of service subject to a maximum limit of twenty months' salary. Vesting occurs upon completion of five years of service. Liabilities with regard to the Gratuity Plan are determined by actuarial valuation as set out in Note 2.12 (b) above, based upon which, the Company makes contributions to the Gratuity Funds.

II. Provident Fund

Provident Fund contributions in respect of employees [other than those covered in (a) above] are made to Trusts administered by the Company and such Trusts invest funds following a pattern of investments prescribed by the Government. Both the employer and the employees contribute to this Fund and such contribu- tions together with interest accumulated thereon are payable to employees at the time of their separation from the Company or retirement, whichever is earlier. The benefit vests immediately on rendering of services by the employee. The interest rate payable to the members of the Trusts is not lower than the rate of interest declared annually by the Government under the Employees' Provident Funds and Miscellaneous Provisions Act, 1952 and shortfall, if any, on account of interest is to be made good by the Company. In terms of the Guidance on implementing Accounting Standard (AS) 15 on Employee Benefits issued by the Accounting Standards Board of the Institute of Chartered Accountants of India, a provident fund set up by the Company is treated as a defined benefit plan in view of the Company's obligation to meet interest shortfall, if any.

The Actuary has carried out actuarial valuation of plan's liabilities and interest rate guarantee obligations as at the balance sheet date using PUCM and Determin- istic Approach as outlined in the Guidance Note 29 issued by the Institute of Actuaries of India. Based on such valuation, there is no future anticipated shortfall with regard to interest rate obligation of the Company as at the balance sheet date. Further during the period, the Company's contribution of Rs. 613 (31st March, 2014 : Rs.663) to the Provident Fund Trust, has been expensed under "Contribution to Provident and Other Funds". Disclosures given hereunder are restricted to the information available as per the Actuary's report.

6. Exceptional items in the Statement of Profit and Loss comprise the following:

(a) Pursuant to the Order dated 24th September, 2014 issued by The Hon'ble Supreme Court of India for cancellation of Kathautia and Lohari Coal Blocks of Steel Division, allotted to the Company in earlier years, as well as imposition of additional levy of Rs. 295/- per metric ton of coal extracted from the date of extraction till 31st March 2015, the Company has made a provision of Rs. 8,373 (Previous Year ; Rs. Nil) during the year on prudent basis and without prejudice to its rights.

Further, during the year, the Company has paid Rs. 7,057 (Previous Year ; Rs. Nil) to an appropriate authority out of the aforesaid provision made up to 31st March, 2015.

(b) Write down of the carrying amount of certain assets and other adjustments of Rs. 1,643 (Previous Year ; Rs. Nil) pertaining to the Coal Blocks refer to in (a) above.

7. Segment Information for the year ended 31st March, 2015 A. primary Segment Reporting (by Business Segments)

Composition of Business Segments

Segments have been identified in accordance with the Accounting Standard on Segment Reporting (AS-17) prescribed under the Act. Details of products included in each of the above Segments are given below :

Steel : Steel Wire Rods, Rolled Products, Billets, Pig Iron and allied products.

Wire and Wire Ropes : Steel Wires, Strands, Wire Ropes, Cord, Bright Bar, related accessories, etc.

Others : Jelly Filled Telecommunication Cables, Wire Drawing and allied machineries, etc.

8. Lease Commitments

(a) Operating Lease Commitments

The Company has two non-cancellable operating lease agreements both having a tenure of fifteen years, in connection with establishment and operation of plants, by the lessor, for production of gaseous oxygen to cater to the Company's Steel Plant at Jamshedpur. One of such agreements became operative in 2001-02 (Lease A) and the other one has become operative in 2007-08 (Lease B). Both these lease agreements had been extended till 2026-27. The Company pays minimum lease rent and fixed, as well as, variable operating and maintenance charges for both the leases.

In respect of lease A, 30% of lease rent, fixed and variable operation and maintenance charges are escalated every quarter in the same proportion as increase in Wholesale Price Index published by the Reserve Bank of India in its bulletin (base period 1st August, 1999 ).

In respect of lease B, 70% of lease rents and operation and maintenance charges are escalated every quarter in the same proportion as increase in Wholesale Price Index published by the Reserve Bank of India in its bulletin ( base period 20th April, 2007)

(b) The Company has entered into cancellable operating lease arrangements for taking on lease gaseous oxygen plant, accommodation for office spaces, employees residential accommodation etc. Tenure of leases generally vary between 1 and 10 years. Terms of the lease include operating term for renewal, increase in rent in future periods and term of cancellation. Related lease rentals aggregating Rs. 636 (31st March, 2014 Rs. 600) have been debited to the Statement of Profit and Loss.

09. The remuneration payable to the Joint Managing Director of the Company aggregating Rs. 41 (Previous Year ; Rs. Nil) for the period from 1st February, 2015 to 31st March, 2015 has been approved by the Shareholders of the Company and being in excess of the limits specified in Schedule V (read with Section 197) to the Companies Act, 2013, the Company has filed an application for approval of the Central Government, which is pending. The Company however, has paid remuneration amounting to Rs. 36 for the said period to the Joint Managing Director as per the terms of the earlier appointment.

10. The previous year figures have been reclassified where considered necessary to conform to this year's classification.

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Mar 31, 2014

1. Contingent Liabilities As 31st March, As at 31st March, 2014 2013

(a) Claims against the Company not acknowledged as debt

Disputed Tax and Duty for which the Company has preferred appeal before appropriate authorities.

Demand for Income Tax Matters 1,940 1,940

Demand for Sales Tax & Entry Tax # 3,232 1,977

Demand for Excise Duty and Service Tax # 6,498 6,493

Demand for Customs Duty 83 83

Outstanding Labour Disputes 48 44

Disputed Electricity duty rebate matters which is sub judice 551 528

Disputed Demand for Fuel Surcharge matter for which the Company has filed writ petition 1,637 - before The Hon''ble High Court of Jharkhand at Ranchi.

Disputed Demand for Mining matter for which the Company has filed writ petition before 1,940 - The Hon''ble High Court of Jharkhand at Ranchi.

# Out of the above, stay orders against demand for Sales Tax amounting to Rs.237 (31st March, 2013 : Rs. 744) and demand for Excise Duty and Service Tax amounting to Rs. 4,324 (31st March, 2013 : Rs. 2,606) have been obtained by the Company.

(b) Guarantees

Corporate Guarantee Given by the Company to secure the financial assistance/accommo- 15,056 12,878 dation extended to other Bodies Corporate_

(c) Bills discounted with Banks including against Letter of Credit 15,433 8,189

(d) In respect of the contingent liabilities mentioned in Note 23(a) above, pending resolution of the respective proceedings, it is not practicable for the Company to estimate the timings of cash outflows, if any. In respect of matters mentioned in Note 23 (b) above, the cash outflows, if any, could generally occur during the validity period of the respective guarantees. The Company does not expect any reimbursements in respect of the above contingent liabilities.

(b) Post Employment Defined Benefit Plans

I. Gratuity (Funded)

The Company provides for gratuity, a defined benefit retirement plan covering eligible employees. As per the scheme, the Gratuity Trust Funds managed by the Life Insurance Corporation of India (LIC) and other insurance companies make payment to vested employees at retirement, death, incapacitation or termination of employment, of an amount based on the respective employee''s eligible salary for specified number of days (ranging from fifteen days to one month) depending upon the tenure of service subject to a maximum limit of twenty months'' salary. Vesting occurs upon completion of five years of service. Liabilities with regard to the Gratuity Plan are determined by actuarial valuation as set out in Note 2.12 (b) above, based upon which, the Company makes contributions to the Gratuity Funds.

The expected return on plan assets is determined after taking into consideration composition of the plan assets held, assessed risks of asset management, historical results of the return on plan assets, the Company''s policy for plan asset management and other relevant factors.

II. Provident Fund

Provident Fund contributions in respect of employees [other than those covered in (a) above] are made to Trusts administered by the Company and such Trusts invest funds following a pattern of investments prescribed by the Government. Both the employer and the employees contribute to this Fund and such contributions together with interest accumulated thereon are payable to employees at the time of their separation from the Company or retirement, whichever is earlier. The benefit vests immediately on rendering of services by the employee. The interest rate pay- able to the members of the Trusts is not lower than the rate of interest declared annually by the Government under the Employees'' Provident Funds and Miscellaneous Provisions Act, 1952 and shortfall, if any, on account of interest is to be made good by the Company. In terms of the Guidance on implementing Accounting Standard (AS) 15 on Employee Benefits issued by the Accounting Standards Board of the Institute of Chartered Accountants of India, a provident fund set up by the Company is treated as a defined benefit plan in view of the Company''s obligation to meet interest shortfall, if any.

The Actuary has carried out actuarial valuation of plan''s liabilities and interest rate guarantee obligations as at the balance sheet date using PUCM and Deterministic Approach as outlined in the Guidance Note 29 issued by the Institute of Actuaries of India. Based on such valuation, there is no future anticipated shortfall with regard to interest rate obligation of the Company as at the balance sheet date. Further during the year, the Company''s contribution of Rs. 663 (31st March, 2013 : Rs.528) to the Provident Fund Trust, has been expensed under "Contribution to Provident and Other Funds". Disclosures given hereunder are restricted to the information available as per the Actuary''s report.

2. Segment Information for the year ended 31st March, 2014

A. Primary Segment Reporting (by Business Segments)

Composition of Business Segments

Segments have been identified in accordance with the Accounting Standard on Segment Reporting (AS-17) prescribed under the Act.

Details of products included in each of the above Segments are given below :

Steel : Steel Wire Rods, Rolled Products, Billets, Pig Iron and allied products.

Wire and Wire Ropes : Steel Wires, Strands, Wire Ropes, Cord, Bright Bar, related accessories, etc.

Others : Jelly Filled Telecommunication Cables, Wire Drawing and allied machineries, etc.

3. Lease Commitments

(a) Operating Lease Commitments

The Company has two non-cancellable operating lease agreements both having a tenure of fifteen years, in connection with establishment and operation of plants, by the lessor, for production of gaseous oxygen to cater to the Company''s Steel Plant at Jamshedpur. One of such agreements became operative in 2001-02 (Lease A) and the other one has become operative in 2007-08 (Lease B). Both these lease agreements had been extended till 2026-27. The Company pays minimum lease rent and fixed, as well as, variable operating and maintenance charges for both the leases.

In respect of Lease A, 30% of lease rent, fixed and variable operation and maintenance charges are escalated every quarter in the same proportion as increase in Wholesale Price Index published by the Reserve Bank of India in its bulletin (base period 1st August, 1999).

In respect of Lease B, 70% of lease rents and operation and maintenance charges are escalated every quarter in the same proportion as increase in Wholesale Price Index published by the Reserve Bank of India in its bulletin (base period 20th April, 2007).

(b) The Company has entered into cancellable operating lease arrangements for taking on lease gaseous oxygen plant, accommodation for office spaces, employees residential accommodation etc. Tenure of leases generally vary between 1 and 10 years. Terms of the leases include operating term for renewal, increase in rent in future periods and term of cancellation. Related lease rentals aggregating Rs. 600 (31st March, 2013 Rs. 554) have been debited to the Statement of Profit and Loss.

4. The previous year figures have been reclassified where considered necessary to conform to this year''s classification.

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Mar 31, 2013

1. General Information

Usha Martin Limited (the ''Company'') is a public limited company domiciled in India, incorporated under the provisions of the Companies Act, 1956 and is listed on two stock exchanges in India and its GDRs are listed on stock exchange in Luxembourg. The Company is engaged in the manufacturing of speciality steel and value added steel products. The Company caters to both domestic and international markets.

2. Segment Information for the year ended 31st March, 2013

A. Primary Segment Reporting (by Business Segments)

Composition of Business Segments

Segments have been identified in accordance with the Accounting Standard on Segment Reporting (AS-17) prescribed under the Act.

Details of products included in each of the above Segments are given below :

Steel : Steel Wire Rods, Rolled Products, Billets, Pig Iron and allied products.

Wire and Wire Ropes : Steel Wires, Strands, Wire Ropes, Cord, Bright Bar, related accessories, etc.

Others : Jelly Filled Telecommunication Cables, Wire Drawing and allied machineries, etc.

Change in Segment Composition :

Based on a review of product portfolio of various segments, related risks and returns, business developments etc., Wire Drawing and allied machinery products, hitherto included in ''Wire and Wire Ropes'' segment, have been identified with ''Others'' segment with effect from this year. Accordingly previous year figures relating to ''Wire and Wire Ropes'' and ''Others'' segments have been regrouped / rearranged to conform to this year''s presentation.

3. Lease Commitments

(a) Operating Lease Commitments

The Company has two non-cancellable operating lease agreements both having a tenure of fifteen years, in connection with establishment and operation of plants, by the lessor, for production of gaseous oxygen to cater to the Company''s Steel Plant at Jamshedpur. One of such agreements became operative in 2001-02 (Lease A) and the other one has become operative in 2007-08 (Lease B). During the year, both these agreements have been extended till 2026-27. The Company pays minimum lease rent and fixed, as well as, variable operating and maintenance charges for both the Leases.

In respect of Lease A, 30% of lease rent, fixed and variable operation and maintenance charges are escalated every quarter in the same proportion as increase in Wholesale Price Index published by the Reserve Bank of India in its bulletin (base period 1st August, 1999 ).

In respect of Lease B, 70% of lease rents and operation and maintenance charges are escalated every quarter in the same proportion as increase in Wholesale Price Index published by the Reserve Bank of India in its bulletin ( base period 20th April, 2007).

(b) The Company has entered into cancellable operating lease arrangements for taking on lease accommodation for office spaces, employees residential accommodation etc. Tenure of leases generally vary between 1 and 3 years. Terms of the lease include operating term for renewal, increase in rent in future periods and term of cancellation. Related lease rentals aggregating Rs. 554 (31st March, 2012 : Rs. 558) have been debited to the Statement of Profit and Loss.

4. During the year, the management has identified fraudulent encashment of four cheques aggregating Rs.9 from one of the bank accounts of the Company, which have since been fully recovered from the concerned bank upon lodgement of claim.

5. The previous year figures have been reclassified where considered necessary to conform to this year''s classification.

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Mar 31, 2012

1. General Information

Usha Martin Limited (the 'Company') is a public limited company domiciled in India, incorporated under the provisions of the Companies Act, 1956 and is listed on two stock exchanges in India and its GDRs on one stock exchange in Luxembourg. The Company is engaged in the manufacturing of specialty steel and value added steel products. The Company caters to both domestic and international markets.

(a) 8,019,495 (31 March, 2011: 4,729,370) Equity Shares are represented by Global Depository Receipts (GDRs) out of above paid up Equity Shares.

(b) Rights, preference and restrictions attached to shares issued:

The Company has only one class of equity shares having a par value of Re.1 per share. Each shareholder is eligible for one vote per share held (except in case of GDRs). The dividend if proposed by the Board of Directors is subject to the approval of the shareholders in the ensuing Annual General Meeting, except in case of interim dividend. In the event of liquidation, the equity shareholders are eligible to receive the remaining assets of the Company after distribution of all preferential amounts, in proportion to their shareholding.

Nature of Security and terms of repayment for secured borrowings : Nature of Security

All Term Loans from Financial Institution and Banks are secured by way of Joint Equitable Mortgage by deposit of title deeds of certain immovable properties and hypothecation over movable assets of the Company both present and future subject to prior charges of the Company's Bankers on specified movable assets for Working Capital requirements.

Terms of Repayment

(a) Rupee term loan from a Financial Institution amounting to Rs.25,000 (31st March, 2011:Rs. 25,000) is repayable in eighteen quarterly installments commencing from 20th June 2013 to 20th September 2017. Interest is payable on monthly basis at One Year Gsec plus 2.85% p.a.

(b) Rupee term loan from a Financial Institution amounting to Rs.20,000 (31st March, 2011:Rs. Nil) is repayable in eighteen quarterly installments commencing from 20th June 2014 to 20th September 2018. Interest is payable on monthly basis at One Year Gsec plus 3.25% p.a.

(c) Rupee term loan from a Bank amounting to Rs.10,000 (31st March, 2011 :Rs. 10,000) is repayable in twenty quarterly installments commencing from 1st April 2013 to 1st January 2018. Interest is payable on monthly basis at Base rate of the Bank plus 2% p.a.

(d) Rupee term loan from a Bank amounting to Rs. 8,000 (31st March, 2011:Rs. 9,600) is repayable in nineteen quarterly installments from 29th April 2013 to 29th October 2017. Interest is payable on monthly basis at Base rate of the Bank plus 1.75% p.a.

(e) Rupee term loan from a Bank amounting to Rs. 20,000 (31st March, 2011:Rs. 24,000) is repayable in eleven quarterly installments from 30th June 2013 to 31st December 2015. Interest is payable on monthly basis at Base rate of the Bank plus 2.15% p.a.

(f) Rupee term loan from a Bank amounting to Rs.20,000 (31st March, 2011:Rs. Nil) is repayable in twelve quarterly installments commencing from 31st December 2013 to 30th September 2016. Interest is payable on monthly basis at Base rate of the Bank plus 1.15% p.a.

(g) Rupee term loans from Banks aggregating to Rs. Nil (31st March, 2011 Rs. 10224) carrying interest at Base rate of the banks plus 2.25% p.a. have been prepaid during the year.

(h) Foreign Currency term loan from a Bank amounting to Rs. 63,588 (31st March, 2011:Rs. 11,138) is repayable in ten equal quarterly installments commencing from 30th October 2015 to 31st January 2018. Interest is payable on quarterly basis at three months USD LIBOR plus 2.85% p.a.

(i) Foreign Currency term loan from a Bank amounting to Rs. 12,717 (31st March, 2011 :Rs.20,048) is repayable in five equal quarterly installments from 16th May 2013 to 16th May 2014. Interest is payable on half yearly basis at six months JPY LIBOR plus 1.40% p.a.

(j) Foreign Currency term loan from a Bank amounting to Rs. 17,804 (31st March , 2011:Rs. 15,592) is repayable in five equal quarterly installments commencing from 16th August 2013 to 16th August 2014. Interest is payable on half yearly basis at six months JPY LIBOR plus 2% p.a.

(k) Foreign Currency term loan from a Bank amounting to Rs. Nil (31st March, 2011:Rs. 2,339) is repayable in two equal installments on 15th August, 2012 and 15th February, 2013 respectively. Interest is payable on half yearly basis at six months USD LIBOR plus 1.50% p.a.

(l) Foreign Currency term loan from a Bank amounting to Rs. Nil (31st March, 2011:Rs. 4,009) is repayable on 5th June, 2012 and 3rd July, 2012 respectively. Interest is payable on monthly basis at six months USD LIBOR plus 1.50% p.a.

(m) Outstanding balances of loans as indicated in (a) to (l) above are exclusive of current maturities of such loans as disclosed in Note 11.

2. Contingent Liabilities

As at 31st As at 31st March, 2012 March, 2011

A Claims against the Company not acknowledged as debt

Disputed Tax and Duty for which the Company has preferred appeal before appropriate authorities.

Demand for Income Tax Matters 1,940 1,940

Demand for Sales Tax 465 84

Demand for Excise Duty and Service Tax 5,812 4,433

Demand for Customs Duty 83 124

Outstanding Labour Disputes 31 34

Disputed Electricity duty rebate matters which is subjudice 504 -

B Guarantees

Corporate Guarantee given by the Company to secure the financial assistance/accommodation 6,779 6,851 extended to other Bodies Corporate

C Bills discounted with Banks including against Letter of Credit 12,682 11,034

@ Contribution towards Provident Fund for certain employees is made to the regulatory authorities, where the Company has no further obligations. Such benefits are classified as Defined Contribution Schemes as the Company does not carry any further obligations, apart from the contribution made on a monthly basis and recognised as expense in the statement of Profit and Loss, indicated above.

(b) Post Employment Defined Benefit Plans

I. Gratuity (Funded)

The Company provides for gratuity, a defined benefit retirement plan covering eligible employees. As per the scheme, the Gratuity Trust Funds managed by the Life Insurance Corporation of India (LIC) and other insurance companies make payment to vested employees at retirement, death, incapacitation or termination of employment, of an amount based on the respective employee's eligible salary for specified number of days (ranging from fifteen days to one month) depending upon the tenure of service subject to a maximum limit of twenty months' salary. Vesting occurs upon completion of five years of service. Liabilities with regard to the Gratuity Plan are determined by actuarial valuation as set out in Note 2.13 (b) above, based upon which, the Company makes contributions to the Gratuity Funds.

II. Provident Fund

Provident Funds contributions in respect of employees [other than those covered in (a) above] are made to Trusts administered by the Company and such Trusts invest funds following a pattern of investments prescribed by the Government. Both the employer and employee contribute to this Fund and such contributions together with interest accumulated thereon are payable to employees at the time of their separation from the Company or retirement, whichever is earlier. The benefit vests immediately on rendering of services by the employee, The interest rate payable to the members of the Trusts is not lower than the rate of interest declared annually by the Government under the Employees' Provident Funds and Miscellaneous Provisions Act, 1952 and shortfall, if any, on account of interest is to be made good by the Company. In terms of the Guidance on implementing Accounting Standard (AS) 15 on Employee Benefits issued by the Accounting Standards Board of the Institute of Chartered Accountants of India, a provident fund set up by the Company is treated as a defined benefit plan in view of the Company's obligation to meet interest shortfall, if any.

Unlike in earlier years, the Actuary has carried out actuarial valuation of plan's liabilities and interest rate guarantee obligations as at the balance sheet date using PUCM and Deterministic Approach as outlined in the Guidance Note 29 issued by the Institute of Actuaries of India. Based on such valuation, there is no future anticipated shortfall with regard to interest rate obligation of the Company as at the balance sheet date. Further during the year, the Company's contribution of Rs.412 (Previous year:Rs.333) to the Provident Fund Trust, has been expensed under "Contribution to Provident and Other Funds". Disclosures given hereunder are restricted to the information available as per the Actuary's report,

3. Lease Commitments

(a) Operating Lease Commitments

The Company has two non-cancellable operating lease agreements both having a tenure of fifteen years, in connection with establishment and operation of plants, by the lessor, for production of gaseous oxygen to cater to the Company's Steel Plant at Jamshedpur. One of such agreements became operative in 2001-02 (Lease A) and the other one has become operative in 2007-08 (Lease B). The Company pays minimum lease rent and fixed, as well as, variable operating and maintenance charges for both the Leases.

In respect of Lease A, 30% of lease rent, fixed and variable operation and maintenance charges will be escalated every quarter in the same proportion as increase in Wholesale Price Index published by the Reserve Bank of India in its bulletin (base period 1st August, 1999 ).

In respect of Lease B, 70% of lease rents and operation and maintenance charges will be escalated every quarter in the same proportion as increase in Wholesale Price Index published by the Reserve Bank of India in its bulletin ( base period 20th April, 2007)

(b) The Company has entered into cancellable operating leases and transactions for leasing of accommodation for office spaces, employees residential accommodation etc. Tenure of leases generally vary between 1 and 3 years. Terms of the lease include operating term for renewal, increase in rent in future periods and term of cancellation. Related lease rentals aggregating Rs.558 (Previous year Rs.393 ) have been debited to the Profit and Loss Account.

a - denotes Subsidiaries

b - denotes Loans outstanding as at 31st March, 2012

c - denotes amount due on account of accrued interest, management service charges and recovery of expenses outstanding as at 31st March, 2012

d - denotes maximum amount outstanding during the year ended 31st March, 2012 e - denotes no repayment schedule or repayment beyond seven years.

II. In view of voluminous data furnishing of particulars such as name, amount outstanding at the year end and maximum amount outstanding during the year in respect of loans and advances in the nature of loan given to employees for medical, furniture, housing, vehicle etc. with interest rate varying from 0 - 6 per cent and repayment terms varying from 1 - 10 years is not considered practicable. Aggregate amount of such advances and loans outstanding at the year end is Rs.124 [31st March 2011 ; Rs.132).

4. Provision for Dividend Tax is net of write back of excess provision Rs.Nil (Pervious Year : Rs.12) made in earlier year,

5. The financial statements for the year ended 31st March, 2011 had been prepared as per the then applicable, pre-revised Schedule-VI to the Companies Act, 1956. Consequent to the notification of Revised Schedule VI under the Companies Act, 1956, the financial statements for the year ended 31st March, 2012 are prepared as per Revised Schedule VI. Accordingly, the previous year figures have also been reclassified to confirm to this year's classification.

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Mar 31, 2011

1. Outstanding Capital Commitments are estimated at Rs. 4,392,989 (Net of advances ) (Previous Year Rs. 1,214,365)

2. a) According to the usual practice, Electricity Charges are being accounted for on the basis of bills received. Any supplementary bill arising out of revision in the rates will be accounted for as and when such bills are received.

b) Provision for Fuel Surcharge upto December, 2003 had been made as per interim order passed by the Honble High Court of Patna .

3. Research and Development Expenditure

For the year ended For the year ended 31st March, 2011 31st March, 2010

Revenue 7,428 5,001

Capital 927 1,022

4. There are Contingent Liabilities in respect of :

a) Bills discounted with Banks Rs.1,103,368 (Previous Year Rs.1,073,915) including against Letter of Credit Rs.589,536 (Previous Year Rs.329,942)

b) Bank Guarantees outstanding Rs.295,103 (Previous Year Rs.341,697)

c) Disputed Income Tax matters amounting to Rs.194,022 (Previous Year Rs.55,178 ) for which the Company has preferred appeal before appropriate authorities.

d) Demand for Sales Tax amounting to Rs.8,431 (Previous Year Rs.7,963) for earlier years not acknowledged as debts and in respect of which the Company has preferred appeals before appropriate authorities.

e) Demand for Excise Duty and Service Tax Rs.443,346 (Previous Year Rs.134,982) not acknowledged as debts and in respect of which the Company has preferred appeal before appropriate authorities.

f) Demand for Customs Duty Rs.12,439 (Previous year Rs.12,439 ) not acknowledged as debts and in respect of which the Company had preferred appeal before appropriate authorities.

g) Corporate Guarantees given by the Company to secure the financial assistance / accommodation extended to other Bodies Corporate amounting to Rs.685,107 (Previous Year Rs.659,318).

h) Claims against the Company not acknowledged as debts Rs.3,390 (Previous Year Rs.75,974).

5. Lease Commitments

a) Operating Lease Commitments

The Company has two non-cancelable operating lease agreements both having a tenure of fifteen years, in connection with establishment and operation of plants, by the lessor, for production of gaseous oxygen to cater to the Companys Steel Plant at Jamshedpur. One of such agreements became operative in 2001-02 (Lease A) and the other one has become operative in 2007-08 (Lease B). The Company pays minimum lease rent and fixed, as well as, variable operating and maintenance charges for both the Leases.

In respect of Lease A, 30% of lease rent, fixed and variable operation and maintenance charges will be escalated every quarter in the same proportion as increase in Wholesale Price Index published by the Reserve Bank of India in its bulletin (base period 1st August, 1999 ).

In respect of Lease B, 70% of lease rents and operation and maintenance charges will be escalated every quarter in the same proportion as increase in Wholesale Price Index published by the Reserve Bank of India in its bulletin (base period 20th April, 2007)

(b) The Company has entered into cancelable operating leases and transactions for leasing of accommodation for office spaces, employees residential accommodation etc. Tenure of leases generally vary between 1 and 3 years. Terms of the lease include operating term for renewal, increase in rent in future periods and term of cancellation. Related lease rentals aggregating Rs.39,312 (Previous year Rs.15,949 ) have been debited to the Profit and Loss Account.

$ As certified by the Management.

a. Including internal consumption 192,229 M.T. (Previous Year 175,423 M.T.)

b. Including internal consumption 16,006 M.T. (Previous Year 27,404 M.T.) ; excluding trial production Nil M.T. (Previous Year 48,049 M.T.)

c. Including internal consumption 503,410 M.T. (Previous Year 378,925 M.T. ) and purchase (net) 6,895 M.T. (Previous Year 27,749 M.T. ); excluding trial production Nil M.T. (Previous Year 77,100 M.T.)

d. Including internal consumption 312,286 M.T. (Previous Year 119,650 M.T. ) excluding trial run production 45,669 M.T. (Previous year Nil M.T.)

e. Including internal consumption 240,123 M.T. (Previous Year 147,303 M.T. ) ; excluding trial production Nil M.T. (Previous Year 39,283 M.T.)

f. Including internal consumption 99 M.T. ( Previous Year 2,371 M.T.)

g. Including internal consumption 3,100 M.T. (Previous Year 3,663 M.T. )

h. including internal consumption 7,447 M.T. (Previous Year 6,155 M.T.)

i. Including internal consumption 2,977 M.T.(Previous Year 1,070 M.T.) ; excluding trial production Nil M.T. (Previous Year 995 M.T.)

j. Including internal consumption 6 Nos. (Previous Year 3 Nos. ).

k. Including internal consumption Nil Sets. (Previous Year 2 Sets ).

l. Including internal consumption 16,277 Pcs. (Previous Year 61,029 Pcs. ).

m. Including internal consumption Nil Pcs. (Previous Year 5 Pcs. ).

n. Including internal consumption 2 Sets (Previous Year Nil set ).

6. Segment Information for the year ended 31st March, 2011

A. Primary Segment Reporting (by Business Segments)

I. Composition of Business Segments

Segments have been identified in accordance with the Accounting Standard on Segment Reporting (AS-17) prescribed under the Act.

Details of products included in each of the above Segments are given below : Steel : Steel Wire Rods, Rolled Products, Billets, Pig Iron and allied products.

Wire and Wire Ropes : Steel Wires, Strands, Wire Ropes, Cord, Bright Bar, related accessories including Wire Drawing and allied machines, etc.

Others : Jelly Filled Telecommunication Cables, etc.

II Inter Segment Transfer Pricing

Inter segment prices are normally negotiated amongst the segments with reference to the costs, market prices and business risks, within an overall optimisation objective for the Company.

Legends to classification :-

a - denotes Subsidiaries

b - denotes Loans outstanding as at 31st March, 2011

c - denotes amount due on account of accrued interest, management service charges and recovery of expenses outstanding as at 31st March, 2011 d - denotes maximum amount outstanding during the year ended 31st March, 2011

e - denotes no repayment schedule or repayment beyond seven years.

II. In view of voluminous data furnishing of particulars such as name, amount outstanding at the year end and maximum amount outstanding during the year in respect of loans and advances in the nature of loan given to employees for medical, furniture, housing, vehicle etc. with interest rate varying from 0 - 6 per cent and repayment terms varying from 1 - 10 years is not considered practicable. Aggregate amount of such advances and loans outstanding at the year end is Rs.13,249 (Previous year Rs.19,098).

7. Employee Benefits

(I) Post Employment Defined Contribution Plans

During the year an amount of Rs. 45,594 (Previous year Rs.38,539) has been recognised as expenditure towards Defined Contribution Plans of the Company.

(II) Post Employment Defined Benefit Plans

Gratuity (Funded)

The Company provides for gratuity, a defined benefit retirement plan covering eligible employees. As per the scheme, the Gratuity Trust Funds managed by the Life Insurance Corporation of India ( LIC ) and other insurance companies make payment to vested employees at retirement, death, incapacitation or termination of employment, of an amount based on the respective employees eligible salary for specified number of days (ranging from fifteen days to one month) depending upon the tenure of service subject to a maximum limit of twenty months salary. Vesting occurs upon completion of five years of service. Liabilities with regard to the Gratuity Plan are determined by actuarial valuation as set out in Note 1 (j) (ii) above, based upon which, the Company makes contributions to the Gratuity Funds.

The estimate of future salary increases takes into account inflation, seniority, promotion and other relevant factors.

The expected return on plan assets is determined after taking into consideration composition of the plan assets held, assessed risks of asset management, historical results of the return on plan assets, the Companys policy for plan asset management and other relevant factors.

(i) Contributions towards provident funds are recognised as expense. Provident fund contributions in respect of employees are made to Trusts administered by the Company and such Trusts invest funds following a pattern of investments prescribed by the Government. The interest rate payable to the members of the Trusts is not lower than the rate of interest declared annually by the Government under the Employees Provident Funds and Miscellaneous Provisions Act, 1952 and shortfall, if any, on account of interest is to be made good by the Company. In terms of the Guidance on implementing Accounting Standard (AS) 15 on Employee Benefits issued by the Accounting Standards Board of the Institute of Chartered Accountants of India, a provident fund set up by the Company is treated as a defined benefit plan in view of the Companys obligation to meet interest shortfall, if any. However, there is no such interest shortfall at the year end which is required to be made good by the Company. The Actuary has expressed his inability to provide an actuarial valuation of the provident fund liability as at the year end in the absence of any guidance from the Actuarial Society of India. Accordingly, complete information required to be considered as per AS 15 in this regard are not available and the same could not be disclosed. During the year, the Company has contributed Rs. 35,720 ( Previous year Rs.25,397) to the Provident Fund.

8. Provision for Dividend Tax is net of write back of excess provision Rs.1,177 ( Previous year Rs. Nil ) made in earlier year.

9. Figures for the previous year have been regrouped/ rearranged wherever necessary to make them comparable with the current years figures.

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Mar 31, 2010

1. Outstanding Capital Commitments are estimated at Rs.1,214,365 (Net of advances) (Previous Year Rs. 2,468,874)

2. There are Contingent Liabilities in respect of :

a) Bills discounted with Banks Rs.1,073,915 (Previous Year Rs.615,535) including against Letter of Credit Rs.329,942 (Previous year Rs. 571,527)

b) Bank Guarantees outstanding Rs. 341,697 (Previous Year Rs.197,287)

c) Disputed income tax matter amounting to Rs.55,178 for which the company has preferred appeal before appropriate authorities.

d) Demand for Sales Tax amounting to Rs. 7,963 (Previous Year Rs.2,374) for earlier years not acknowledged as debts and in respect of which the Company has preferred appeals before appropriate authorities.

e) Demand for Excise Duty and Service Tax Rs.134,982 (Previous Year Rs.40,979) not acknowledged as debts and in respect of which the Company has preferred appeal before appropriate authorities.

f) Demand for interest Rs. Nil (Previous Year Rs.11,434) for non-payment of Excise Duty on electricity raised by Bihar State Electricity Board not admitted and which is subjudice.

g) Demand for Customs Duty Rs. 12,439 (Previous year Rs.12,229) not acknowledged as debts and in respect of which the Company had preferred appeal before appropriate authorities.

h) Demand for Wealth Tax Rs.Nil (Previous Year Rs. 569).

i) Corporate Guarantees given by the Company to secure the financial assistance / accommodation extended to other Bodies Corporate amounting to Rs.659,318 (Previous Year Rs.947,907).

j) Claims against the Company not acknowledged as debts Rs. 75,974 (Previous Year Rs.51,122).

Footnotes :

i) The Investments in overseas subsidiaries have been accounted for at the exchange rate prevailing on the date of remittance/ advice.

ii) During the year, Brunton Shaw Americas Inc, (BSAI) a wholly owned subsidiary of the Company merged with Usha Martin Americas Inc (UMAI) another wholly owned subsidiary of the Company with effect from 1st April, 2009 and accordingly 3,300,000 shares held by the Company in BSAI were allotted to the Company in UMAI pursuant to the scheme of merger.

iii) In case of unquoted long term investments in Subsidiary Companies, diminution, if any, in the year-end carrying amount, worked out solely on the basis of their respective break-up values is considered to be temporary, in nature, having regard to long term strategic value, benefits arising out of continuing business relationships etc.

iv) The Companys ownership interest and other particulars relating to GWSCL, PUMWPL, CCLUMSSL, DAPL and BMPL, the Joint Venture Companies have been set out in Note 28 below.

v) During the year the Company has purchased 100,000 Equity Shares of face value of Rs.10 each of Bharat Minex Private Limited (BMPL), an erstwhile Joint Venture Company to make it a Wholly Owned Subsidiary.

vi) Transfer of 3,044,451 Ordinary Shares in UMICOR Africa (Proprietary) Limited in the name of the Company could not be processed as the said UMICOR have gone into liquidation and placed under final winding up vide Order dated 30th July, 2008 of the High Court of South Africa (Witwatersrand Local Division).

3. Segment Information for the year ended 31st March, 2010

A. Primary Segment Reporting (by Business Segments)

I. Composition of Business Segments

Segments have been identified in accordance with the Accounting Standard on Segment Reporting (AS-17) prescribed under the Act.

Details of products included in each of the above Segments are given below :

Steel : Steel Wire Rods, Rolled Products, Billets,

Pig Iron and allied products.

Wire and Wire Ropes : Steel Wires, Strands, Wire Ropes, Cord, Bright

Bar, related accessories including Wire

Drawing and allied machines, etc.

Others : Jelly Filled Telecommunication Cables, etc.

II Inter Segment Transfer Pricing

Inter segment prices are normally negotiated amongst the segments with reference to the costs, market prices and business risks, within an overall optimisation objective for the Company.

h) Contributions towards provident funds are recognised as expense. Provident fund contributions in respect of employees are made to Trusts administered by the Company and such Trusts invest funds following a pattern of investments prescribed by the Government. The interest rate payable to the members of the Trusts is not lower than the rate of interest declared annually by the Government under the Employees Provident Funds and Miscellaneous Provisions Act, 1952 and shortfall, if any, on account of interest is to be made good by the Company. In terms of the Guidance on implementing Accounting Standard (AS) 15 on Employee Benefits issued by the Accounting Standards Board of the Institute of Chartered Accountants of India, a provident fund set up by the Company is treated as a defined benefit plan in view of the Companys obligation to meet interest shortfall, if any. However, there is no such interest shortfall at the year end. The Actuary has expressed his inability to provide an actuarial valuation of the provident fund liability as at the year end in the absence of any guidance from the Actuarial Society of India. Accordingly, complete information required to be considered as per AS 15 in this regard are not available and the same could not be disclosed. During the year, the Company has contributed Rs. 25,397 (Previous year Rs.21,150) to the Provident Fund.

4. Figures for the previous year have been regrouped/ rearranged wherever necessary.