All transactions entered into by us with entities who qualify as ‘related parties’ under Indian laws and accounting standards have been duly disclosed by us. Further these have been carried out on arm’s length terms in accordance with applicable laws. Further, these are also disclosed by us, are publicly available to all regulators and our stakeholders, and have been duly verified and audited by independent third parties who are competent and have the required expertise in this respect. As stated above, Adani Portfolio companies follow a stated policy of having global big 6 or regional leaders as Statutory Auditors. 19/ (Allegation #44) We have identified a series of transactions from 2013-2015 whereby assets were transferred from a subsidiary of listed Adani Enterprises to a private Singaporean entity controlled by Vinod Adani, without disclosure of the related party nature of these deals. What is the explanation for these transactions and the lack of disclosure? 20/ (Allegation #45) The private Singaporean entity controlled by Vinod Adani almost immediately wrote down the value of the transferred assets. Were those still held on the books of Adani Enterprises, it likely would have resulted in an impairment and significant decline in reported net income. What is the explanation for why these assets were transferred to a private undisclosed related party before being written down? Common Response - The transactions relate to transfer of the cost to the specific project entity which was incorporated for rail businesses (Carmichael Rail Network Trust incorporated on 17th September 2014). These transactions have been carried out in compliance with applicable law and on arm’s length terms. The amounts transferred included: (i) Exploration and Evaluation Assets (i.e. Capital works in progress (‘C I ’)); and (ii) Amounts already expensed to profit and loss account and an arms length management fee charged by Adani Mining Pty Ltd (a step-down subsidiary of Adani Enterprises) These transactions were fully disclosed in the financial statements Adani Mining Pty Ltd. (AMPL), as below. Source: Page 14 of the Financial Statement of AMPL for FY15 showing the part-transfer of Exploration and Evaluation Assets. Source: Page 13 of the Financial Statement of AMPL for FY15 showing the reversal of cost which was expensed in P&L account in earlier years and other income on account of management fee 33
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