Hitachi Energy India Ltd

The Company has not acquired shares or voting rights in unlisted Company therefore it is not applicable during the quarter ended March 31, 2026.

The Company has responded to the notice in the month of October, 2025, with all necessary supporting documents to justify that the expenses claimed by the Company were in order and are allowable under the provisions of the Act. The re-assessment proceedings are yet to be disposed off. Further, there is no update during the quarter ended March 31, 2026.

After the completion of scrutiny assessment for FY 2020-21, the Company had received a show cause notice under section 148A (procedure before issuance of notice u/s 148) for re-assessment under section 147 on March 29, 2025. The Company had responded to the said notice in April 2025 with full explanation highlighting that there is no escapement of income during the assessment proceedings. However, the Assessing Officer did not take the same into account and initiated the reassessment proceedings by passing the order u/s 148A(3) on June 30, 2025. In the said order, the Assessing Officer has proposed an adjustment to taxable income to the tune of Rs. 28,06,45,970 with corresponding tax impact of Rs. 9,39,41,860 including interest. As per the Income-tax law provisions, the proceedings u/s 148 of the Act should be carried out though automated allocation and under faceless assessment manner. Hence, the Company believes that the notice and the order issued by the Jurisdictional Assessing Officer u/s 148 of the Act are bad in law and are liable to be quashed. Notwithstanding the same, the Company had filed a revised return u/s 148 on August 25, 2025 (replica of the original return) as required under the provisions of the Act. Further, the Company is in the process of responding to the notice with all necessary supporting documents to justify that the expenses claimed by the Company were in order and are allowable under the provisions of the Act. The Company is confident of getting the favorable outcome in this matter and hence, no additional provision would be required.

The Company has received the order from GST authorities in respect of GST audit conducted for Uttar pradesh in relation to FY 2021-22 for alleged: - short payment of Tax on outward supply for the difference of value declared in TDS return and GST return - ITC availed on cancelled dealer invoices - Input tax availed and utilized on blocked Input tax credit Total Tax Demands: GST: Rs. 9,02,10,392.00, Penalty: Rs. 90,21,037.00 plus Interest as per UP SGST Act, 2017 (not quantified) Based on assessment of facts and prevailing law, the Company is of the view that the Tax Demand and Penalty levied is arbitrary, unjustified and unsustainable in law. The Company will file necessary appeal with the Appellate Authority in this regard within the permissible timeline.

The Company has received the order from GST authorities in respect of GST audit conducted for Karnataka in relation to FY 2021-22 for alleged: - Non-payment of GST on E-way bill transactions - Wrong payment of GST on supplies to Solar project - Non-Payment of GST on Non-GST supplies (Import of Services) Total Tax Demands: GST: Rs. 75,49,347.00, Interest: Rs. 58,11,549.00 Penalty: Rs. 7,66,295.00 Based on assessment of facts and prevailing law, the Company is of the view that the Tax Demand and Penalty levied is arbitrary, unjustified and unsustainable in law. The Company will file necessary appeal with the Appellate Authority in this regard within the permissible timeline.

The Company has received the order from GST authorities in respect of GST audit conducted for Tamil Nadu in relation to FY 2021-22 for alleged: - Excess ITC reversal reported in Form GSTR-09 - ITC claimed from cancelled dealers, return defaulters & tax non payers - Interest on ITC reversed under Rule 37 Total Tax Demands: GST: Rs. 69,046.00, Interest: Rs. 1,61,903.00, Penalty: Rs. 20,000.00 Based on assessment of facts and prevailing law, the Company is of the view that the Tax Demand and Penalty levied is arbitrary, unjustified and unsustainable in law. The Company will file necessary appeal with the Appellate Authority in this regard within the permissible timeline.

As the amount has been debited from the Electronic Credit Ledger, no further litigation is being pursued and the matter stands closed.

A Demand Order has been issued by the State of Punjab for the reversal of Input Tax Credit (ITC) available in the Electronic Credit Ledger as on December 18, 2025. Since we have surrendered our registration, the department has directed us to reverse the excess credit balance accumulated in the Electronic Credit Ledger. The GST demand amounts to INR 1,68,685.00. The Company is currently evaluating the matter and will determine the appropriate course of action.

This case was selected for scrutiny assessment for FY2021-22, pursuant to which the Assessing Officer (“AO”) referred the matter to the Transfer Pricing Officer (“TPO”) for carrying out the transfer pricing assessment. The transfer pricing assessment was concluded and the TPO proposed a transfer pricing adjustment aggregating to INR 113.2 crores on account of alleged low margins in the manufacturing segment, system integration segment and deemed interest on delayed receivables. The transfer pricing order was issued on January 23, 2025. Subsequently, the AO passed a draft assessment order under section 144C(1) of the Income‑tax Act, 1961 on March 4, 2025, incorporating the proposed transfer pricing adjustments. In addition, the AO disallowed Group Management Fees amounting to INR 69.95 crores, without duly considering the submissions made by the Company. Aggrieved by the draft assessment order, the Company filed objections before the Dispute Resolution Panel (“DRP”) on April 2, 2025. The DRP issued its directions on December 26, 2025, largely confirming the adjustments proposed by the TPO. However, with respect to the Group Management Fees, while the DRP confirmed the disallowance made by the AO, it directed that the said fees should not be considered while computing the margins for the manufacturing segment and system integration segment. Pursuant to the directions of the DRP, the AO passed the final assessment order on January 21, 2026, wherein the Group Management Fees amounting to INR 699.5 million and interest on delayed receivables amounting to INR 16.4 million were disallowed. On account of these disallowances, the segmental margins improved and were within the range determined by the TPO. Consequently, the transfer pricing adjustment aggregating to INR 1,114.8 million was deleted, resulting in a reduced tax demand of INR 260.9 million as against the earlier demand of INR 435.8 million. The Company is of the view that no addition is warranted in respect of the disallowance of Group Management Fees and notional interest on delayed receivables. Accordingly, the Company has preferred an appeal before the Income‑tax Appellate Tribunal (“ITAT”) on March 25, 2026 against the aforesaid additions.

The Company received an order from GST authorities in respect of GST audit conducted for Karnataka in relation to FY 2019-20. There is tax demand of INR 46.29 Crore (GST – INR 24.41 Crore plus interest & penalty – INR 21.87 Crore). The Company filed an Appeal on December 2, 2024 before Joint Commissioner of Commercial Taxes, Bengaluru. Hearing for appeal filed on December 2, 2024 before Joint Commissioner of Commercial Taxes, Bengaluru is concluded. The Company awaits the order. The Appeal filed on on December 2, 2024, before Joint Commissioner of Commercial Taxes, Bengaluru, has been rejected on March 11, 2025. Accordingly, awaiting the formation of Goods and Service Tax Tribunal for filing appeals against the Joint Commissioner of Commercial Taxes (Appeals) order.

Post de-merger, non-novated transactions were carried out with ABB India Limited ('ABB') in FY 2019-20 & FY 2020-21 and offshore sales by transfer of documents of title to the goods were transacted. The goods moved from a country (other than India) and where destined for Nepal / Bangladesh / Sri Lanka. While raising invoice on ABB we had charged GST. However, since these transactions were carried out entirely outside India, no GST should have been charged. Accordingly, The Company had issued credit Note to ABB and lodged refund claim of INR 14.41 Crores with GST authorities. The Company filed an Appeal on June 3, 2022 before Joint Commissioner of Commercial Taxes, Bengaluru and same was rejected on December 26, 2023 and September 24, 2024. Awaiting the formation of Goods and Service Tax Tribunal for filing appeals against the Joint Commissioner of Commercial Taxes (Appeals) order.

In respect of Q2 FY 2022-23, refund claim of INR 19.39 Crores has been rejected by Deputy Commissioner of Commercial Taxes, Vadodara. The Company is eligible for refund in respect of export turnover of both goods and services. However, turnover relating to services was not considered by tax authorities. Further, Input Tax Credit (ITC) amount was considered as NIL in refund computation. Accordingly, the Company filed an Appeal on January 24, 2024 before Additional Commissioner (Appeals), Vadodara and the same has been rejected on October 25, 2024. Awaiting the formation of Goods and Service Tax Tribunal for filing appeal against the order.

In respect of Q3 & Q4 of FY 2021-22, Input Tax Credit (ITC) refund of INR 10.51 crores was received. Subsequently, pursuant to internal review by Goods and Service Tax authorities, they filed an appeal before Additional Commissioner of GST seeking to deny the refund. The Company filed cross objection on April 17, 2024 before Additional Commissioner (Appeals), Vadodara and the same has been rejected on October 25, 2024. Awaiting the formation of Goods and Service Tax Tribunal for filing appeal against the order.

Pursuant to the appeal filed by the Company before the Deputy Commissioner of State Taxes, Chennai on May 27, 2025, against the assessment order issued by the Assistant Commissioner of GST, Nandanam, Chennai, a personal hearing was conducted on December 31, 2025. Pursuant to the hearing, Order-in-Appeal was passed on February 02, 2026 by the Deputy Commissioner (Appeals), Chennai, partially allowing the Company’s appeal and reducing the total demand from INR 13.45 Crores to INR 3.21 Crores (comprising GST of INR 1.69 Crores, interest of INR 1.35 Crores and penalty of INR 16.98 Lakhs). For the balance portion of the demand that has been disallowed, the Company proposes to file an appeal before the GST Appellate Tribunal, Chennai, once the Tribunal is constituted

The Company has received an order from Assistant Commissioner (State Tax), Nandambakkam Assessment Circle, Chennai, Tamil Nadu (“GST Authority”) based on GST Assessment for the FY 2020-21 with the demand of Penalty of Rs. 74,91,593/- under applicable provisions of the Central Goods and Services Tax Act, 2017, the Integrated Goods & Services Tax Act, 2017, the Tamil Nadu Goods & Services Tax Act, 2017 and rules made thereunder. There is a total demand of INR 13.45 Crores (GST – INR 7.49 Crore plus interest & penalty – INR 5.96 Crores). The Company has received the order from the aforesaid authorities for alleged excess availment of Input Tax Credit (ITC) in GSTR-3B returns. Based on assessment of facts and prevailing law, the Company is of the view that the penalty levied is, arbitrary, unjustified and unsustainable in law. Accordingly, the Company has filed an appeal before Deputy Commissioner of State Taxes, Chennai on May 27, 2025 against the order passed by Assistant Commissioner of GST, Nandanam, Chennai.

The Joint Commissioner, CGST & Central Excise has passed the Rectification of Mistake Order on January 22, 2026, declaring the demand of INR 25.26 Crores as inoperative and unenforceable. Accordingly, the matter stands closed.

Demand raised in respect of departmental appeal for Q3 & Q4 of FY 2020-21, Q1 of 2021-22 wherein Input Tax Credit refund was already received by the Company. Subsequently, pursuant to internal review by Goods and Service Tax (GST) authorities, GST Department filed an appeal before Additional Commissioner of GST seeking to deny the aforesaid refund and demanding INR 25.26 crores (INR 22.96 crores GST and INR 2.30 crores Penalty). The Gujarat High Court has quashed the appellate orders passed by the Additional Commissioner of GST on the main issue i.e., litigation dated May 17, 2023 and the Company will be filing an application for rectification of mistake before Joint Commissioner, CGST & CE, Vadodara-I to recall/rectify the Demand Order. Accordingly, Writ Petition has been filed before Gujarat High Court on December 22, 2025.

An appeal was filed by the Company before the Joint Commissioner, CGST & CE, Vadodara-I on January 08, 2026. Personal hearing was duly attended on January 21, 2026. The matter is currently pending for receipt of the order.

Demand raised in respect of departmental appeal for Q3 & Q4 of FY 2021-22, Q1 & Q2 of 2022-23 wherein Input Tax Credit refund was already received by the Company. Subsequently, pursuant to internal review by Goods and Service Tax (GST) authorities, GST Department filed an appeal before Additional Commissioner of GST seeking to deny the refund and demanding INR 19.66 crores (INR 17.87 crores GST and INR 1.79 crores Penalty). The Company intends to file an appeal before Joint Commissioner, CGST & CE, Vadodara-I by November 07, 2025 against the Commissioner (Appeals), Vadodara

The Company has duly paid the penalty of Rs. 50,000, pursuant to which the vehicle bearing registration number RJ47-GA-3211 has been released. The Company does not intend to pursue any further litigation in this matter.

The Sales Tax Officer detained detained the vehicle bearing registration number RJ47-GA-3211 at Songadh check post due to discrepancies in the e-Way Bill and issued Form GST MOV‑01 and MOV‑02 on March 26, 2026

The Company has duly paid the penalty of Rs. 50,000, pursuant to which the vehicle bearing registration number RJ06-GB-5316 has been released. The Company does not intend to pursue any further litigation in this matter.

The Sales Tax Officer detained detained the vehicle bearing registration number RJ06-GB-5316 at Songadh check post due to discrepancies in the e-Way Bill and issued Form GST MOV‑01 and MOV‑02 on March 26, 2026

The Company has duly paid the penalty of Rs. 50,000, pursuant to which the vehicle bearing registration number RJ06-GB-9386 has been released. The Company does not intend to pursue any further litigation in this matter.

The Sales Tax Officer detained detained the vehicle bearing registration number RJ06-GB-9386 at Songadh check post due to discrepancies in the e-Way Bill and issued Form GST MOV‑01 and MOV‑02 on March 26, 2026

The Company has duly paid the penalty of Rs. 50,000, pursuant to which the vehicle bearing registration number MH46-AF-9529, containing the consignment bearing Bill of Entry number 8071210 has been released. The Company does not intend to pursue any further litigation in this matter.

The Sales Tax Officer detained the vehicle bearing registration number MH46-AF-9529, containing the consignment bearing Bill of Entry number 8071210 at the Bhilad check post due to discrepancy in the e‑Way Bill and issued FORM GST MOV‑01 and MOV‑02 on March 25, 2026

The Company has duly paid the penalty of Rs. 50,000, pursuant to which the vehicle bearing registration number MH46-AF-9529, containing the consignment bearing Bill of Entry number 8072373 has been released. The Company does not intend to pursue any further litigation in this matter.

The Sales Tax Officer detained the vehicle bearing registration number MH46-AF-9529, containing the consignment bearing Bill of Entry number 8072373 at the Bhilad check post due to discrepancy in the e‑Way Bill and issued FORM GST MOV‑01 and MOV‑02 on March 25, 2026

The Company will be paying the penalty amount of Rs. 500 on the next hearing date, i.e., April 20, 2026, to close the case.

The Company has received the complaint from the office of the Labour Enforcement Officer for alleged under Minimum Wages Act, for breach of following: Rule-22 - Display of notice in Hindi and English at the work place Rule: Wages not paid within the statutory time limit Rule-25(2) & 26 (1) - Maintenance of Wage Register (Form B). Rule 21 (4) - Maintenance of register for loan/recoveries in Form C. Rule 21 (4) - Maintenance of attendance register (Form D). Accordingly Rs. 500 penalty was imposed for violation of the same

The Company has received the complaint from the office of the Labour Enforcement Officer for alleged under Minimum Wages Act, for breach of following: Rule-22 - Display of notice in Hindi and English at the work place Rule: Wages not paid within the statutory time limit Rule-25(2) & 26 (1) - Maintenance of Wage Register (Form B). Rule 21 (4) - Maintenance of register for loan/recoveries in Form C. Rule 21 (4) - Maintenance of attendance register (Form D). The Company has initially received a show cause notice dated September 22, 2025 pursuant to an inspection conducted on September 18, 2025 by the Labour Enforcement Officer, Rajkot at a premises of a third party wherein our Company was appointed to undertake contract work. During the Inspection certain irregularities in relation to compliance with the Minimum Wages Act, 1948 & Central Rules, 1950 were observed. In our reply dated September, 26, 2025, we informed to the authority that appropriate compliances are made in place and requested to drop the further proceedings on the reference notice. Subsequently, a complaint dated March 12, 2026 was filed before the Hon'ble Labour Court, Jamnagar by the Labour Enforcement Officer (Central) under the Minimum Wages Act, 1948. Accordingly, the Company will be paying the penalty amount of Rs. 500 on the next hearing date, i.e., April 20, 2026.

Financial impact: • Recovery of Drawback & RoDTEP amounting to INR 28,12,516/‑ • Penalty imposed of INR 1,00,000/‑ (Interest applicable as per law) Based on assessment of facts and prevailing law, the Company has filed an appeal before the Appellate Authority on April 06, 2026.

Order‑in‑Original No. 157/PJ/DC/DRC/NCH/2025‑26 dated 06.02.2026 passed by the Deputy Commissioner of Customs, Drawback Recovery Cell, New Custom House, Mumbai, pursuant to Show Cause Notice No. 72/2024‑25 dated 21.03.2025, alleging ineligible availing of Drawback and Remission of Duties and taxes on Exported Products (RoDTEP) benefit under the provisions of the Customs Act, 1962, Customs and Central Excise Duties Drawback Rules, 2017 and Notification No. 76/2021‑Customs (N.T.).

The Company allegedly failed to realise export proceeds within the stipulated period under FEMA and RBI guidelines in respect of certain Shipping Bills, resulting in: • Short realisation of export proceeds for some Shipping Bills • Delay / non‑realisation of export proceeds for certain Shipping Bills. Accordingly, proportionate recovery of Drawback and RoDTEP along with interest was proposed under Rule 18(2) of the Drawback Rules, 2017 and Notification No. 76/2021‑Customs (N.T.).