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  • Capital Expenditure23. Clause (1) of Regulation 9 of the 2009 Tariff Regulations
  • Law:24. Clause (11) of Regulation 3 of the 2009 Tariff Regulations
  • clause (3) of Regulation 18 of the 2009 Tariff Regulations,
  • SECTION 64 ELECTRICITY ACT
  • INCOME TAX ACT 1961
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citation codes
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  • Capital Expenditure23. Clause (1) of Regulation 9 of the 2009 Tariff Regulations
  • Law:24. Clause (11) of Regulation 3 of the 2009 Tariff Regulations
  • clause (3) of Regulation 18 of the 2009 Tariff Regulations,
  • SECTION 64 ELECTRICITY ACT
  • INCOME TAX ACT 1961
Smart Summary

Concise Analytical Summary of the Opinion — Petition No. 98.TT/2012

Factual and Procedural Background

Power Grid Corporation of India Limited (PGCIL) filed the petition seeking approval of transmission tariff for specified transmission assets forming part of the "Transmission System associated with Pallatana Gas Based Power Project and Bongaigaon Thermal Power Station in NER" for the 2009-14 tariff block under the Central Electricity Regulatory Commission (Terms and Conditions of Tariff) Regulations, 2009 (the "2009 Tariff Regulations").

The investment approval for the transmission project was accorded by Powergrid's Board on 26.2.2010 at an estimated cost of Rs. 214,400 lakh (including IDC Rs. 17,835 lakh) on 3rd quarter, 2009 price level. The project scope comprises multiple transmission lines and substations; the instant petition sought tariff from anticipated dates of commercial operation (DOCO) to 31.3.2014 for five named assets (Asset-1 through Asset-5). PGCIL filed affidavits (notably dated 19.12.2013 and 6.6.2014) and appeared at hearing on 22.4.2014. Assam Power Distribution Company Limited (APDCL) filed a reply (affidavit dated 17.1.2013); the petitioner did not file a rejoinder. Notices under Section 64 of the Electricity Act produced no public comments.

The Commission heard representatives, examined the records and material filed, and proceeded to dispose of the petition by the order summarized herein. This order disposes of Petition No. 98.TT/2012.

Legal Issues Presented

  1. Whether transmission tariff should be allowed for the assets claimed in the petition (identifying which assets or parts thereof are commissioned and eligible for tariff for the 2009-14 block).
  2. How capital cost, cost over-run and additional capitalisation are to be treated for tariff determination under Regulation 7 and Regulation 9 of the 2009 Tariff Regulations (including cut-off date implications).
  3. Whether cost over-run for particular assets is permissible and, if so, whether the petitioner has justified such cost over-run.
  4. How initial spares claimed by the petitioner should be treated under Regulation 8 of the 2009 Tariff Regulations (admissible ceilings and any necessary restriction).
  5. Appropriate debt-equity ratio to be applied (normative 70:30 treatment and treatment of additional capitalisation) under Regulation 12.
  6. Appropriate computation of Return on Equity (grossing up for tax) and whether the claimed additional 0.5% return for timely completion is admissible under Regulation 15.
  7. Methodology for computing Interest on Loan (weighted average on actual loan portfolio and normative repayment equal to depreciation) under Regulation 16.
  8. Application of norms for Depreciation and O&M expenses under Regulations 17 and 19 respectively.
  9. Computation and admissibility of Interest on Working Capital under Regulation 18 (components: receivables, maintenance spares, O&M) and applicable rate (SBI base + 350 bps).
  10. Whether filing fee, publication expenses and licence fee are reimbursable from beneficiaries and whether the petitioner may bill/recover service tax separately.
  11. How transmission charges are to be shared among beneficiaries (reference to Sharing Regulations, 2010).

Arguments of the Parties

Petitioner's (PGCIL) Submissions

  • Claimed transmission tariff for five assets (Assets 1–5) for the 2009-14 block based on 2009 Tariff Regulations, with supporting management/auditor certificates and tariff forms (revised where required).
  • Explained causes for cost over-run for Assets-1, -3 and -5 (tower design changes; additional forest/crop compensations; inclusion of circuit breakers and other items not in FR cost) and sought allowance of such over-runs.
  • Explained an interim commissioning arrangement (Phase‑I and Phase‑II) for Asset-1 due to land acquisition delay at Hailakandi substation, relying on minutes of 10th TCC & RPC of NER to justify interim evacuation arrangement.
  • Requested grant of tariff for Asset-2, Asset-3, Asset-5 and the commissioned part of Asset-1; also requested tariff for Asset-4 (petitioner later sought tariff for Asset-4 pending commissioning, anticipated commission date advised in affidavit).
  • Claimed initial spares and projected additional capitalisation within the cut-off date; submitted capital cost certificates for DOCO.
  • Claimed additional return on equity of 0.5% for completion within timelines specified in the 2009 Tariff Regulations.
  • Requested reimbursement of filing fee and publication expenses; sought recovery of licence fee from beneficiaries; sought permission to bill/recover service tax separately if applicable in future.

Respondent's (APDCL) Submissions

  • Filed objections by affidavit dated 17.1.2013; in particular, sought justification for petitioner's claim of additional 0.5% return on equity.
  • Observed that methodology for recovery of interest on loan is specified in Regulation 16 and implicitly that the Commission should follow the regulation; argued filing fee and publication expenses should be allowed as per 2009 Tariff Regulations.
  • Submitted that licence fee should be allowed in accordance with the 2009 Tariff Regulations.
  • Contended that the petitioner's prayer to bill/recover service tax separately was premature.

Table of Precedents Cited

Precedent Rule or Principle Cited For Application by the Court
Order dated 18.2.2014 in Petition No. 216.TT/2012 Approach of restricting admitted capital cost to apportioned approved cost where Revised Cost Estimate (RCE) is not furnished. The Commission applied the same methodology in this petition by restricting capital cost of assets (in cases where completion cost exceeded apportioned approved cost and no RCE was furnished) to the apportioned approved cost for tariff determination.
Hon'ble Appellate Tribunal for Electricity judgment dated 28.11.2013 in Appeal No. 165 of 2012 Upholding the methodology of restricting capital cost to apportioned approved cost in circumstances where RCE is not furnished (as applied in the Commission's earlier order). The Commission noted that the same methodology had been upheld by the Appellate Tribunal and applied that approach to Asset-1, Asset-3 and Asset-5 in the instant petition.

Court's Reasoning and Analysis

The Commission proceeded by applying the relevant provisions of the 2009 Tariff Regulations to the facts and filings:

  1. Asset commissioning and scope: The Commission first identified which assets (or parts thereof) were commissioned as on the dates alleged by the petitioner. It accepted that part of Asset-1, and Assets-2, -3 and -5 had been commissioned (with DOCOs reflected in the record); part of Asset-1 remained uncommissioned due to land acquisition at Hailakandi substation and an interim LILO arrangement for evacuation had been agreed in the 10th TCC & RPC meeting. Asset-4 was not commissioned as at the date of the order.
  2. Granting tariff only for commissioned assets: Because Asset-4 and part of Asset-1 were not commissioned in the 2009-14 block, the Commission declined to grant tariff for those uncommissioned portions in this order and directed the petitioner to file a fresh petition for these assets on commissioning under the 2014 Tariff Regulations. Transmission tariff was allowed only for Asset-2, Asset-3, Asset-5 and that part of Asset-1 which had been commissioned.
  3. Capital cost principles and prudence check (Regulation 7): The Commission recited Regulation 7 and noted that capital cost admitted after prudence check forms the basis of tariff. The petitioner furnished management/auditor certificates for capital cost as on DOCO; the Commission examined and accepted capital cost submissions subject to applicable restrictions (initial spares ceilings, cost over-run treatment, and absence of RCE).
  4. Time over-run and cost over-run: The Commission observed there was no time over-run for Assets 1–3 and 5 (they were commissioned within the scheduled milestones). It examined the petitioner's explanations for cost over-run for Asset-1, Asset-3 and Asset-5 (tower design changes, increased compensation for forest/crop/houses, inclusion of CBs and other items not captured in FR cost). Finding these reasons persuasive and outside the petitioner's control, the Commission allowed the cost over-run. However, because the petitioner had not furnished any Revised Cost Estimate (RCE), the Commission restricted the capital cost for tariff purposes to the apportioned approved cost where the completion cost exceeded the apportioned approved cost (following its approach in Petition No. 216.TT/2012, upheld by APTEL).
  5. Initial spares (Regulation 8): The Commission applied the ceiling norms in Regulation 8: 2.5% for sub-station and 0.75% for transmission line. Claimed initial spares exceeding norms for Asset-1 and Asset-3 were restricted to the admissible ceiling; initial spares for Asset-2 and Asset-5 were within ceilings and allowed. Admissible initial spares were considered for capital cost up to 31.3.2014 and would be reviewed at truing up with actual expenditure.
  6. Projected additional capitalisation and cut-off date (Regulation 9 and definition of cut-off): The Commission noted the cut-off date is 31.3.2015 for the assets and that additional capitalisation within original scope up to cut-off may be admitted subject to prudence. Projected additional capex claimed was considered only to the extent it did not push admitted capital beyond the apportioned approved cost (where RCE absent) and otherwise was not considered for tariff determination for the 2009-14 period; the projected additions will be reviewed at truing up on submission of actuals.
  7. Debt–equity and normative treatment (Regulation 12): The Commission applied the normative 70:30 debt–equity ratio for projects commissioned on or after 1.4.2009. For additional capitalisation (where considered), the same normative split was applied for computation of normative loan and equity for tariff calculation.
  8. Return on equity (Regulation 15): The Commission computed RoE in rupee terms on the equity base determined under Regulation 12 and grossed up for tax. It used the base RoE 15.5% and grossed it up with the MAT rate applicable for 2008-09 to arrive at 17.481% p.a. on average equity. The petitioner's claim for an additional 0.5% RoE (timely completion incentive) was disallowed because not all project assets were commissioned within the timeline specified in the 2009 Tariff Regulations.
  9. Interest on loan (Regulation 16): The Commission applied Regulation 16 methodology: gross normative loan (normative 70% of capital) and repayment deemed equal to depreciation. Interest on loan was computed by applying the weighted average rate of interest calculated on the basis of the actual loan portfolio at the beginning of each year to the notional average loan; a proposed bond (proposed bond 12-13 at 9.30%) in Form‑13 was not accepted because Regulation 16(5) requires the weighted average rate on the actual loan portfolio. Detailed weighted-average interest computations were annexed and applied to each asset.
  10. Depreciation (Regulation 17): Depreciation was calculated on straight-line method at rates in Appendix-III to the 2009 Tariff Regulations, with salvage value 10% and chargeable from commercial operation. For assets commissioned in 2012, depreciation was computed pro rata for 2012-13 and on annual basis for 2013-14 in accordance with the Regulations.
  11. O&M norms (Regulation 19): The Commission applied the O&M normative rates specified in Regulation 19 for bays and lines (year-wise values for 2009-10 through 2013-14 were applied) to derive allowable O&M for each asset in 2012-13 (pro rata) and 2013-14.
  12. Interest on Working Capital (Regulation 18): The components (receivables = two months of fixed cost; maintenance spares = 15% of O&M; O&M for one month) were computed in accordance with Regulation 18. The rate applied was SBI Base Rate + 350 bps = 13.50% as on 1.4.2012. The Commission adjusted receivables and other components based on two months' transmission charges being allowed in the tariff computed by the order.
  13. Filing fee, publication expenses and licence fee: The Commission accepted that the petitioner is entitled to reimbursement of filing fees and publication expenses directly from beneficiaries on pro-rata basis in accordance with Regulation 42A(1)(a) of the 2009 Tariff Regulations, and licence fee reimbursement is allowed in accordance with Regulation 42A(1)(b). However, the petitioner's prayer to bill and recover service tax on transmission charges in future was held premature and was rejected.
  14. Sharing of charges: The order records that the tariff determined shall be shared by the respondents in accordance with the Central Electricity Regulatory Commission (Sharing of Inter State Transmission Charges and Losses) Regulations, 2010.

Holding and Implications

Core Ruling: Petition No. 98.TT/2012 is disposed of.

Primary holdings and direct consequences for the parties:

  • The petition was allowed in part: transmission tariff is allowed in this order for Assets-2, Asset-3, Asset-5 and the commissioned part of Asset-1 only. Asset-4 and the remaining part of Asset-1 (not commissioned) were not granted tariff in this order; the petitioner is directed to file a fresh petition for those on commissioning under the 2014 Tariff Regulations.
  • Capital cost: Where the total estimated completion cost exceeded the apportioned approved cost and no Revised Cost Estimate (RCE) was furnished, the admitted capital cost for tariff determination has been restricted to the apportioned approved cost (approach previously adopted in Petition No. 216.TT/2012 and upheld by APTEL in Appeal No.165 of 2012).
  • Cost over-runs for Asset-1, Asset-3 and Asset-5 were allowed after examining and accepting the petitioner's justifications (tower design changes, additional compensation, inclusion of CBs and auxiliaries); those over-runs were treated consistent with prudence review and subject to the capital cost restriction above where applicable.
  • Initial spares claimed in excess of Regulation 8 ceilings were restricted to the admissible percentages (0.75% for transmission line and 2.5% for sub-station); admissible initial spares have been included in capital cost up to 31.3.2014 and will be reviewed at truing up.
  • Debt–equity has been applied normatively at 70:30; additional capitalisation where admitted has been split on that normative basis for tariff computations.
  • Return on Equity allowed at pre‑tax grossed up rate of 17.481% (computed on average equity). The petitioner's claim for an extra 0.5% return (additional return for timely completion) was disallowed as not all project assets were completed within the timeline under the 2009 Regulations.
  • Interest on loan, depreciation, O&M and interest on working capital were calculated in accordance with Regulations 16, 17, 19 and 18 respectively, with detailed figures and weighted average interest calculations reflected in the order and annexures.
  • Filing fee and publication expenses: petitioner entitled to reimbursement from beneficiaries on a pro‑rata basis under Regulation 42A(1)(a). Licence fee: reimbursable under Regulation 42A(1)(b). Service tax: petitioner's prayer to bill/recover service tax separately was rejected as premature.
  • Transmission charges determined by this order are to be shared by respondents in accordance with the CERC (Sharing of Inter State Transmission Charges and Losses) Regulations, 2010.

No broader novel principle of law was stated beyond application of the cited 2009 Tariff Regulations and the Commission's established approach (including the approach affirmed by the Appellate Tribunal) to restrict admitted capital cost in the absence of an RCE. The order is primarily an application of the tariff regulations to the facts of the petition.


This summary has been prepared exclusively from the text of the provided opinion. No information has been added or inferred beyond what appears in that opinion.

    Power Grid Corporation Of India Limited v. Assam State Electricity Board

    The petition has been filed by Power Grid Corporation of India Limited (PGCIL) seeking approval of the transmission tariff from anticipated Notional DOCO to 31.3.2014 for Assets: (i) 132kV Silchar-Hailakandi (AEGCL) line along-with associated bays (Anticipated DOCO 1.4.2012) (ii) 200MVA, 400/132kV, ICT—II at Silchar along-with associated bays (Anticipated DOCO 1.4.2012) (iii) 400kV D/C Pallatana-Surajmaninagar line (Charged at 132kV) alongwith associated bays (Anticipated DOCO 1.7.2012) (iv) 400kV Silchar-Purbakanchanbari line (Charged at 132kV) along-with associated bays (Anticipated DOCO 1.7.2012) (v) 80 MVAR, 420kV Bus Reactor at Bongaigaon along-with associated bay (Anticipated DOCO 1.7.2012) under transmission system associated with Pallatana Gas Based Power Project and Bongaigaon Thermal Power Station in NER for tariff block 2009-14 based on the Central Electricity Regulatory Commission (Terms and Conditions of Tariff) Regulations, 2009 (hereinafter referred to as “the 2009 Tariff Regulations”).

    2. The Investment approval to the transmission project was accorded by Board of Directors of Powergrid vide letter dated 26.2.2010 bearing no. C/CP/Pallatana-Bongaigaon at an estimated cost of Rs. 214400 lakh, including IDC of Rs. 17835 lakh based on 3 quarter, 2009 price level. The scope of work covered under the project is as follows:—

    Transmission Lines:—

    a. Bongaigaon TPS-Bongaigoan 400kV D/C Line 3 km b. Silchar-Badarpur (POWERGRID) Switching station interconnecting 132 kV D/C line 21 km c. Pallatana-Surajmaninagar (TSECL) 400 kV D/C line (charged at 132 kV) 35 km d. Silchar-Purba Kanchan Bari (TSECL) 400 kV D/C line (Charged at 132 kV) 122 km e. Silchar-Melriat (New) 400 kV D/C line (Charged at 132 kV) 160 km f. Silchar-Imphal (New) 400 kV D/C line (Charged at 132 kV) 140 km g. Melriat (New)-Melriat (Mizoram) Interconnecting 132 kV D/C line 30 km h. Silchar-Srikona (AEGCL) 132 kV D/C line 3 km i. Silchar-Hailakandi (AEGCL) 132 kV D/C line 25 km j. LILO of Loktak-Imphal (POWERGRID) 132 kV S/C line at Imphal (New) 6 km k. LILO of Kathalguri-Misa 400 kV S/C line at Mariani (New) (Charged at 220 kV) 2 km 1. Mariani (new)-Mokokchung (POWERGRID) 220 kV D/C line 56 km m. Mokokchung (POWERGRID)-Mokokchung (Nagaland) 132 kV D/C line with Zebra conductor 1 km n. Pasighat-Roing 132 kV S/C line (on D/C tower) 70 km o. Roing-Tezu 132 kV S/C line (on D/C tower) 60 km p. Tezu-Namsai 132 kV S/C line (on D/C tower) 90 km

    Sub-stations:—

    a. 2×200 MVA, 400/132 kV New Sub-station at Silchar

    b. 2×50 MVA, 132/33 kV New Sub-station at Melriat (upgradable to 400 kV)

    c. 2×50 MVA, 132/33 kV Imphal (New) Sub-station

    d. 220 kV New Switching Station at Mariani

    e. 2×50 MVA, 220/33 kV New Sub-station at Mokokchung

    f. 2×50 MVA, 132/33 kV New Sub-station at Roing

    g. 2×15 MVA, 132/33 kV New Sub-station at Tezu

    h. 2×15 MVA, 132/33 kV New Sub-station at Namsai

    3. The petitioner has claimed transmission tariff for the following transmission assets:—

    Description Anticipated DOCO (as per the petition) Actual DOCO (as per affidavit dated 19.12.2013) 132 kV Silchar-Hailakandi Transmission Line up to LILO point of 132 kV S/C Panchgram-Dullavcherra AEGCL Line along with associated bays(hereinafter referred to as “Asset-1”) 1.4.2012 1.7.2012 200 MVA, 400/132KV ICT-II at Silchar along with associated bays (hereinafter referred to as “Asset-2”) 1.7.2012 400KV D/C Pallatana-Surajmaninagar line (charged at 132 KV) along with associated bays (hereinafter referred to as “Asset-3”) 1.7.2012 400KV Silchar-Purbakanchanbari Line (charged at 132KV) along with associated bays (hereinafter referred to as “Asset-4”) 1.7.2012 Yet to be commissioned 80 MVAR, 420 KV Bus Reactor at Bongaingaon along with associated bays (hereinafter referred to as “Asset-5”) 1.11.2012

    4. The petitioner has claimed transmission tariff for some of the other assets covered under project “Transmission System associated with Pallatana Gas Power Project and Bongaigaon Thermal Power Station” in another petition. The details of those assets are as follows:—

    S. No. Asset Reference 1 400kV D/C Bongaigaon TPS-Bongaigaon Line along with associated bays 2 132 kV D/C Silchar-Badarpur line along with associated bays 3 132 kV D/C Silchar-Sirkona line along with associated bays Order dated 22.2.2014 in Petition No. 184.TT/2011 4 200 MVA, 400/132kV ICT at Silchar S/S along with associated bays 5 50 MVAR switchable line reactors for 400 kV D/C Silchar-Palatana at Silchar S/S along with associated bays and 63 MVAR Bus Reactor at Silchar S/S along with associated bays

    5. The transmission charges claimed by the petitioner based on the actual date of commercial operation are as under:—

    (Rs. in lakh)

    Particulars Asset 1 Asset 2 2012-13 (Pro-rata) 2013-14 2012-13 (Pro-rata) 2013-14 Depreciation 69.57 105.82 81.00 113.40 Interest on Loan 83.52 118.60 97.87 128.12 Return on equity 69.00 104.97 80.45 112.63 Interest on Working Capital 7.81 11.38 9.82 13.58 O & M Expenses 48.83 68.82 69.66 98.19 Total 278.73 409.59 338.80 465.92

    (Rs. in lakh)

    Particulars Asset 3 Asset 5 2012-13 (Pro-rata) 2013-14 2012-13 (Pro-rata) 2013-14 Depreciation 343.01 504.27 19.10 51.64 Interest on Loan 414.72 571.43 22.97 58.94 Return on equity 340.66 500.64 18.97 51.29 Interest on Working Capital 28.99 41.51 2.83 7.34 O & M Expenses 67.11 94.59 25.80 65.46 Total 1194.49 1712.44 89.67 234.67

    6. The details submitted by the petitioner in support of its claim for interest on working capital are given hereunder:—

    (Rs. in lakh)

    Asset 1 Asset 2 Particulars 2012-13 (Pro-rata) 2013-14 2012-13 (Pro-rata) 2013-14 Maintenance Spares 9.77 10.32 13.93 14.73 O & M Expenses 5.43 5.74 7.74 8.18 Receivables 61.94 68.27 75.29 77.65 Total 77.14 84.33 96.96 100.56 Rate of Interest 13.50% 13.50% 13.50% 13.50% Interest 7.81 11.38 9.82 13.58

    (Rs. in lakh)

    Asset 3 Asset 5 Particulars 2012-13 (Pro-rata) 2013-14 2012-13 (Pro-rata) 2013-14 Maintenance Spares 13.42 14.19 9.29 9.82 O & M Expenses 7.46 7.88 5.16 5.46 Receivables 265.44 285.41 35.87 39.11 Total 286.32 307.48 50.32 54.39 Rate of Interest 13.50% 13.50% 13.50% 13.50% Interest 28.99 41.51 2.83 7.34

    7. No comments or suggestions have been received from the general public in response to the notices published by the petitioner under Section 64 of the Electricity Act. Assam Power Distribution Company Limited (APDCL), Respondent No. 1 has filed its reply vide affidavit dated 17.1.2013 The petitioner has not filed any rejoinder to the reply filed by APDCL. The objections raised by APDCL in its reply are addressed in the relevant paragraphs of this order.

    8. Having heard the representatives of the parties and perused the material on records, we proceed to dispose of the petition.

    9. The petitioner has submitted in the petition that the land for Hailakandi Sub-Station of AEGCL is under acquisition. Accordingly, it has been decided in the 10 RPC that in the absence of Hailakandi Sub-station, an interim arrangement to facilitate the evacuation of power from Pallatana via Silchar Sub-station, LILO of existing 132 kV S/C Panchgram-Dullavcherra line of AEGCL would be made by connecting it to 132 kV D/C Silchar-Hailakandi line so as to form Silchar-Panchgram & Silchar-Dullavcherra links. In view of this arrangement, the assets would be commissioned in two phases:—

    Phase-I: 2 nos 132 kV Bays at Silchar end & 132 kV D/C line up to LILO point of 132 kV Dullavcherra-Panchgram (15 km) and

    Phase-II: 2 nos 132 kV bays at Hailakandi end & 132 kV D/C line from LILO point of Hailakandi (10 km), not covered in the instant petition.

    10. The petitioner, in response to a query, has reiterated, vide affidavit dated 6.6.2014 that this interim arrangement has been discussed and agreed in 10th TCC & RPC meeting of NER and submitted a copy of the minutes of the said meeting. The representative of the petitioner submitted during the hearing on 22.4.2014 that remaining part of Asset-1 and Asset-4 would be commissioned during the 2014-19 period and requested to allow tariff for Asset-2, 3 and 5 and that part of Asset-1 which has been commissioned.

    11. We have considered the submissions made by the petitioner vide affidavits dated 19.12.2013 and 6.6.2014 and during the hearing on 22.4.2014 It is observed that out of the five assets covered in the instant petition, part of Asset-1, Asset-2, Asset-3 and Asset-5 have been commissioned. Part of Asset-1 has not been commissioned due to land acquisition problem at Hailakandi Substation of AEGCL and accordingly an interim arrangement has been worked out and agreed upon by the constituents of NER. As regards Asset-4, the petitioner has submitted in its affidavit dated 28.5.2014 that due to reasons beyond its control, it is anticipated to be commissioned on 1.6.2014 and requested to grant tariff for it also in the instant petition. Asset-4 and part of Asset-1 have not been commissioned and will be commissioned during the 2014-19 tariff period and as such we are not inclined to grant tariff for these assets in the instant order. The petitioner is directed to file a fresh petition for Asset-4 and the remaining part of Asset-1 on their commissioning as per the Central Electricity Regulatory Commission (Terms and Conditions of Tariff) Regulations, 2014 (hereinafter referred to as “the 2014 Tariff Regulations”). Transmission tariff for Assets-2, 3, 5 and part of Asset-1 only is allowed in the instant petition.

    12. The petitioner has submitted the auditor's certificate dated 22.9.2011 for “132 kV D/C Silchar-Hailakandi Transmission Line and its associated bays at Silchar S/S and Hailakandi S/S”. However, tariff forms have been submitted only for Phase I. Accordingly, petitioner was directed to submit the capital cost expenditure and revised tariff forms for Phase-I, i.e “2 nos 132 kV Bays at Silchar end & 132 kV D/C line up to LILO point of 132 kV Dullavcherra-Panchgram” along with the status of commissioning of the other assets covered in the instant petition. In response, the petitioner vide affidavit dated 19.12.2013 has submitted that inadvertently the capital expenditure certificate for “132 kV Silchar-Hailakandi line along with associated bays at Silchar and Hailakandi S/S” was submitted instead of “132 kV Silchar-Hailakandi Transmission Line up to LILO point of 132 kV S/C Panchgram-Dullavcherra AEGCL Line along with associated bays at Silchar S/S” and after correcting the capital expenditure, submitted the revised management certificate along with revised tariff forms.

    13. Details of apportioned approved cost, capital cost as on the actual date of commercial operation and estimated additional capitalization projected to be incurred for the assets covered in this petition are as follows:—

    (Rs. in lakh)

    Asset Apportioned approved cost Projected exp. as on DOCO* Projected additional capitalization Capital cost up to 31.3.2014 Projected additional capitalization Total estimated completion cost DOCO to 31.3.13 2013-14 2014-15 Asset-1 1758.12 1519.15 470.40 24.13 2013.68 0.00 2013.68 Asset-2 2429.64 1995.45 100.00 104.55 2200.00 0.00 2200.00 Asset-3 8128.60 8306.04 710.00 1060.56 10076.59 110.84 10187.44 Asset-4 Not covered in the instant petition Asset-5 740.90 828.38 80.00 139.23 1047.61 10.00 1057.61

    * inclusive of initial spares pertaining to & transmission line and sub-station.

    Capital Cost

    14. Regulation 7 of the 2009 Tariff Regulations so far as relevant provides as follows:—

    “(1) Capital cost for a project shall include:—

    (a) The expenditure incurred or projected to be incurred, including interest during construction and financing charges, any gain or loss on account of foreign exchange risk variation during construction on the loan — (i) being equal to 70% of the funds deployed, in the event of the actual equity in excess of 30% of the funds deployed, by treating the excess equity as normative loan, or (ii) being equal to the actual amount of loan in the event of the actual equity less than 30% of the fund deployed, - up to the date of commercial operation of the project, as admitted by the Commission, after prudence check.

    (b) capitalised initial spares subject to the ceiling rates specified in regulation 8; and

    (c) additional capital expenditure determined under regulation 9:

    Provided that the assets forming part of the project, but not in use shall be taken out of the capital cost.

    (2) The capital cost admitted by the Commission after prudence check shall form the basis for determination of tariff:

    Provided that in case of the thermal generating station and the transmission system, prudence check of capital cost may be carried out based on the benchmark norms to be specified by the Commission from time to time:

    Provided further that in cases where benchmark norms have not been specified, prudence check may include scrutiny of the reasonableness of the capital expenditure, financing plan, interest during construction, use of efficient technology, cost over-run and time over-run, and such other matters as may be considered appropriate by the Commission for determination of tariff.”

    15. The petitioner has claimed following capital cost as on the date of commercial operation vide affidavit dated 19.12.2013:—

    (Rs. in lakh)

    Particulars Management Certificate dated Capital cost as on DOCO Asset-1 30.10.2013 1519.15 Asset-2 7.3.2013 1995.45 Asset-3 7.3.2013 8306.04 Asset-5 7.3.2013 828.38

    Time Over-run

    16. As per the investment approval dated 26.2.2010, the assets were scheduled to be commissioned within 34 months progressively from the date of investment approval i.e by 1.1.2013 Asset-1 to Asset-3 were put under commercial operation on 1.7.2012 and Asset-5 was put under commercial operation on 1.11.2012 Accordingly, there is no time over-run in case of Assets 1 to 3 and Asset-5. The petitioner has submitted reasons for time over-run in case of Asset-4 vide affidavit dated 28.5.2014 and the same shall be considered at the time of determining transmission tariff for Asset-4.

    Cost Over-run

    17. There is cost over-run in case of Asset-1, Asset-3 and Asset-5. The petitioner was asked to furnish the reasons for cost over-run. In response, the petitioner vide affidavit dated 19.12.2013 has submitted that cost over-run in case of Asset-1 was due to higher awarded cost and adoption of design for WZ-6 requirement. Further, 220 kV D/C WZ-2 towers have been used in the line as design for 132 kV D/C WZ-6 towers are not available. In case of Asset-3, the petitioner has submitted that there were rubber plantation and other valuable trees and houses and huts across the line corridor and accordingly increased forest and crop compensation was paid as per the assessment of the local revenue authorities and this led to increase in cost of preliminary works leading to cost over-run. As regards Asset-5, the petitioner has submitted that the Circuit Breakers (CBs) (@ Rs. 29.37 lakh) part of the 1 half breaker scheme with BTPS-Bongaigaon Transmission Line was not considered in the FR cost. However, the asset was commissioned ahead of BTPS-Bongaigaon Transmission Line and accordingly, CBs have been considered in the DOCO cost of the reactor instead of BTPS line. Similarly, other items which are part of 1 half breaker scheme not considered in FR cost of the reactor have been included in the cost at the time of commercial operation.

    18. We have considered the submissions made by the petitioner regarding the cost over-run. It is observed that cost over-run is due to change in tower design and addition of CBs as part of 1 half breaker scheme and other auxiliaries system as per the site requirement at the time of the execution of work which were not considered at the time of estimation of FR cost. We are satisfied with the reasons submitted by the petitioner for the cost over-run and find that the cost over-run is not within the control of the petitioner and accordingly the cost over-run in case of Asset-1, Asset-3 and Asset-5 is allowed.

    19. The total estimated completion cost of Asset-2 up to 31.3.2014 fall within the apportioned approved cost. However, the completion cost in case of Asset-1, 3 and 5 exceeds the apportioned approved cost. The petitioner has not furnished any RCE for the instant transmission assets. Accordingly, the capital cost of the instant assets has been restricted to the apportioned approved cost for the purpose of tariff determination. Similar approach was adopted by us in order dated 18.2.2014 in Petition No. 216.TT/2012. This approach has been upheld by the Hon'ble Appellate Tribunal for Electricity in its judgment dated 28.11.2013 in Appeal No. 165 of 2012. The same methodology has been adopted in the instant petition in case of Asset-1, Asset-3 and Asset-5.

    Initial Spares

    20. As per the norms specified in Regulation 8 (iv) (a) of 2009 Tariff Regulations, initial spares to be allowed for sub-station is 2.5% of total substation cost and for transmission line is 0.75% of the total transmission line cost. Details of the initial spares claimed by the petitioner for the transmission line and sub-station are as follows:—

    (Rs. in lakh)

    Particulars Initial Spares claimed Transmission Line Sub-station Asset-1 13.74 4.53 Asset-2 0.00 50.00 Asset-3 74.25 7.19 Asset-5 0.00 23.17

    21. Initial spares claimed by the petitioner for Asset-2 and Asset-5 falls within the ceiling limit specified under Regulation 8 of 2009 Tariff Regulations. However, the initial spares claimed by the petitioner for Asset-1 and Asset-3 exceed the norms specified in the said Regulation. Initial spares are allowed as per the norms specified and it has been restricted to 0.75% and 2.5% of the original project cost of transmission line and sub-station respectively. The detail of admissible and non-admissible initial spares is as follows:—

    (Rs. in lakh)

    Particulars Initial Spares Transmission Line Sub-station Admissible Non-Admissible Admissible Non-Admissible Asset-1 12.08 1.66 3.69 0.84 Asset-2 0.00 0.00 50.00 0.00 Asset-3 60.16 14.09 2.67 4.52 Asset-5 0.00 0.00 18.52 4.65

    22. The cut-off date for all the assets is 31.3.2015, which falls in the next tariff block i.e 2014-19. However, for determination of admissible initial spares capital cost only up to 31.3.2014 (subject to cost over-run) has been considered. The same methodology was adopted by us in Petition No. 65.TT/2012. Accordingly, initial spares so allowed/restricted shall be reviewed at the time of truing up on the submission of the actual expenditure and then in the next tariff period, considering additional capital expenditure for the year 2014-15.

    Projected Additional Capital Expenditure

    23. Clause (1) of Regulation 9 of the 2009 Tariff Regulations provides as follows:—

    “Additional Capitalisation: (1) The capital expenditure incurred or projected to be incurred, on the following counts within the original scope of work, after the date of commercial operation and up to the cut-off date may be admitted by the Commission, subject to prudence check:

    (i) Undischarged liabilities;

    (ii) Works deferred for execution;

    (iii) Procurement of initial capital Spares within the original scope of work, subject to the provisions of Regulation 8;

    (iv) Liabilities to meet award of arbitration or for compliance of the order or decree of a court; and

    (v) Change in Law:”

    24. Clause (11) of Regulation 3 of the 2009 Tariff Regulations defines “cut-off” date as under:—

    “cut-off date” means 31 March of the year closing after 2 years of the year of commercial operation of the project, and in case the project is declared under commercial operation in the last quarter of the year, the cut-off date shall be 31 March of the year closing after 3 years of the year of commercial operation”.

    Therefore, cut-off date for the above mentioned assets is 31.3.2015

    25. The details of the projected additional capital expenditure claimed by the petitioner and considered for tariff determination is as follows:—

    Asset-1:

    (Rs. in lakh)

    Particular 2012-13 2013-14 2012-13 2013-14 Claimed Considered Transmission Line 438.50 6.14 225.09 0.00 Sub-Station Equipments 31.85 16.92 16.35 0.00 PLCC 0.05 1.08 0.03 0.00 Total 470.4 24.14 241.47 0.00

    The total estimated completion cost up to 31.3.2014 i.e Rs. 2013.68 lakh exceeds the apportioned approved cost of Rs. 1758.12 lakh by Rs. 255.56 lakh. Accordingly, to restrict the completion cost up to apportioned approved cost, the projected additional cost for the year 2012-13 has been restricted to Rs. 241.47 lakh and projected additional capital expenditure has not been considered.

    Asset-2:

    The petitioner has claimed projected additional capital expenditure of Rs. 100.00 lakh and Rs. 104.55 lakh pertaining to sub-station for 2012-13 and 2013-14 respectively. The same has been considered for the purpose of tariff determination.

    Asset-3 and asset-5:

    The petitioner has claimed the following projected additional capital expenditure for Asset-3 and Asset-5:—

    (Rs. in lakh)

    Particular 2012-13 2013-14 2012-13 2013-14 Asset-3 Asset-5 Building and Civil works 0.00 4.69 0.00 0.00 Transmission Line 680.00 923.23 0.00 0.00 Sub-Station Equipments 30.00 90.16 80.00 139.23 PLCC 0.00 42.48 0.00 0.00 Total 710.00 1060.56 80.00 139.23

    The total estimated completion cost up to 31.3.2014 exceeds the apportioned approved cost in case of Asset-3 and Asset-5 as stated in Para 19 above. Accordingly, to restrict the completion cost to apportioned approved cost the projected additional capital expenditure for the year 2012-13 and 2013-14 has not been considered for the purpose of tariff determination

    26. The additional capital expenditure claimed by the petitioner falls within the cut-off date and it is mainly on account of balance and retention payments. Hence, subject to cost over-run, the same has been considered for all the assets covered in the instant petition for the purpose of tariff determination under Regulations 9 (1) 2009 Tariff Regulations. The entire projected additional capital expenditure will be reviewed at the time of truing up on submission of the actual additional capital expenditure.

    27. Details of the capital expenditure from the date of commercial operation to 31.3.2014 considered for the purpose of tariff determination is as follows:—

    (Rs. in lakh)

    Particulars Asset-1 Asset-2 Asset-3 Asset-5 Apportioned approved cost 1758.12 2429.64 8128.60 740.90 Capital cost claimed as on DOCO (i) 1519.15 1995.45 8306.04 828.38 Less: Excess Initial Spares claimed (ii) 2.50 0.00 18.61 4.65 Less: Cost over-run as on DOCO (iii) 0.00 0.00 158.83 82.83 Capital cost considered as on DOCO (i)-(ii)-(iii) 1516.65 1995.45 8128.60 740.90 Projected Add Cap 2012-13 241.47 100.00 0.00 0.00 2013-14 0.00 104.55 0.00 0.00 Capital cost as on 31.3.2014 1758.12 2200.00 8128.60 740.90

    Debt-Equity Ratio

    28. Regulation 12 of the 2009 Tariff Regulations provides as under:—

    “12. Debt-Equity Ratio (1) For a project declared under commercial operation on or after 1.4.2009, if the equity actually deployed is more than 30% of the capital cost, equity in excess of 30% shall be treated as normative loan:

    Provided that where equity actually deployed is less than 30% of the capital cost, the actual equity shall be considered for determination of tariff:

    Provided further that the equity invested in foreign currency shall be designated in Indian rupees on the date of each investment.

    Explanation- The premium, if any, raised by the generating company or the transmission licensee, as the case may be, while issuing share capital and investment of internal resources created out of its free reserve, for the funding of the project, shall be reckoned as paid up capital for the purpose of computing return on equity, provided such premium amount and internal resources are actually utilised for meeting the capital expenditure of the generating station or the transmission system.

    (2) In case of the generating station and the transmission system declared under commercial operation prior to 1.4.2009, debt-equity ratio allowed by the Commission for determination of tariff for the period ending 31.3.2009 shall be considered.

    (3) Any expenditure incurred or projected to be incurred on or after 1.4.2009 as may be admitted by the Commission as additional capital expenditure for determination of tariff, and renovation and modernisation expenditure for life extension shall be serviced in the manner specified in clause (1) of this regulation.”

    29. Debt-equity ratio as on the actual date of commercial operation considered for the purpose of tariff calculation is as follows:—

    (Rs. in lakh)

    Particulars Apportion approved cost Capital cost as on date of commercial operation Asset 1 Amount % Amount % Debt 1230.68 70.00 1061.66 70.00 Equity 527.44 30.00 455.00 30.00 Total 1758.12 100.00 1516.65 100.00 Asset 2 Amount % Amount % Debt 1700.75 70.00 1396.82 70.00 Equity 728.89 30.00 598.64 30.00 Total 2429.64 100.00 1995.45 100.00 Asset 3 Amount % Amount % Debt 5690.02 70.00 5690.02 70.00 Equity 2438.58 30.00 2438.58 30.00 Total 8128.60 100.00 8128.60 100.00 Asset 5 Amount % Amount % Debt 518.63 70.00 518.63 70.00 Equity 222.27 30.00 222.27 30.00 Total 740.90 100.00 740.90 100.00

    30. Debt-equity ratio for projected additional capital expenditure is given below:—

    (Rs. in lakh)

    Asset-1 Asset-2 Particulars Normative Normative 2012-13 2012-13 Amount % Amount % Debt 169.03 70.00 70.00 70.00 Equity 72.44 30.00 30.00 30.00 Total 241.47 100.00 100.00 100.00 2013-14 2013-14 Debt Not considered due to cost over-run 73.19 70.00 Equity 31.37 30.00 Total 104.55 100.00
    Asset-3 Asset-5 Normative Normative 2012-13 2011-12 Particulars Amount % Amount % Debt Not considered due to cost over-run Not considered due to cost over-run Equity Total 2013-14 2012-13 Debt Not considered due to cost over-run Not considered due to cost over-run Equity Total

    31. Detail of debt-equity ratio of assets as on 31.3.2014 is as follows:—

    (Rs. in lakh)

    Particulars Apportion approved cost Capital Cost as on 31.3.2014 Asset 1 Amount % Amount % Debt 1230.68 70.00 1230.68 70.00 Equity 527.44 30.00 527.44 30.00 Total 1758.12 100.00 1758.12 100.00 Asset 2 Amount % Amount % Debt 1700.75 70.00 1540.00 70.00 Equity 728.89 30.00 660.00 30.00 Total 2429.64 100.00 2200.00 100.00 Asset 3 Amount % Amount % Debt 5690.02 70.00 5690.02 70.00 Equity 2438.58 30.00 2438.58 30.00 Total 8128.60 100.00 8128.60 100.00 Asset 5 Amount % Amount % Debt 518.63 70.00 518.63 70.00 Equity 222.27 30.00 222.27 30.00 Total 740.90 100.00 740.90 100.00

    Return on Equity

    32. Regulation 15 of the 2009 Tariff Regulations provides as under:—

    “15. (1) Return on equity shall be computed in rupee terms, on the equity base determined in accordance with regulation 12.

    (2) Return on equity shall be computed on pre-tax basis at the base rate of 15.5% for thermal generating stations, transmission system and run of the river generating station, and 16.5% for the storage type generating stations including pumped storage hydro generating stations and run of river generating station with pondage and shall be grossed up as per clause (3) of this regulation:

    Provided that in case of projects commissioned on or after 1st April, 2009, an additional return of 0.5% shall be allowed if such projects are completed within the timeline specified in Appendix-II:

    Provided further that the additional return of 0.5% shall not be admissible if the project is not completed within the timeline specified above for reasons whatsoever.

    (3) The rate of return on equity shall be computed by grossing up the base rate with the Minimum Alternate/Corporate Income Tax Rate for the year 2008-09, as per the Income Tax Act, 1961, as applicable to the concerned generating company or the transmission licensee, as the case may be:

    (4) Rate of return on equity shall be rounded off to three decimal points and be computed as per the formula given below:

    Rate of pre-tax return on equity = Base rate/(1-t)

    Where it is the applicable tax rate in accordance with clause (3) of this regulation.

    (5) The generating company or the transmission licensee as the case may be, shall recover the shortfall or refund the excess Annual Fixed charge on account of Return on Equity due to change in applicable Minimum Alternate/Corporate Income Tax Rate as per the Income Tax Act, 1961 (as amended from time to time) of the respective financial year directly without making any application before the Commission;

    Provided further that Annual Fixed charge with respect to the tax rate applicable to the generating company or the transmission licensee, as the case may be, in line with the provisions of the relevant Finance Acts of the respective financial year during the tariff period shall be trued up in accordance with Regulation 6 of these regulations”.

    33. The petitioner's prayer to recover the shortfall or refund the excess Annual Fixed Charges, on account on return on equity due to change in applicable Minimum Alternate Tax/Corporate Income Tax rate as per the Income Tax Act, 1961 of the respective financial year directly without making any application before the Commission shall be dealt under Regulation 15(3) as state above. Return on Equity has been computed @ 17.481% p.a on average equity.

    34. Based on the above, the return on equity has been considered as given hereunder:—

    (Rs. in lakh)

    Particular Asset-1 Asset-2 2012-13 (pro-rata) 2013-14 2012-13 (pro-rata) 2013-14 Opening Equity 455.00 527.44 598.64 628.64 Addition due to Additional Capitalisation 72.44 0.00 30.00 31.37 Closing Equity 527.44 527.44 628.64 660.00 Average Equity 491.22 527.44 613.64 644.32 Return on Equity (Base Rate) 15.50% 15.50% 15.50% 15.50% Tax rate for the year 2008-09 (MAT) 11.33% 11.33% 11.33% 11.33% Rate of Return on Equity (Pre Tax) 17.481% 17.481% 17.481% 17.481% Return on Equity (Pre Tax) 64.40 92.20 80.45 112.63

    (Rs. in lakh)

    Particular Asset-3 Asset-5 2012-13 (pro-rata) 2013-14 2012-13 (pro-rata) 2013-14 Opening Equity 2438.58 2438.58 222.27 222.27 Addition due to Additional Capitalization 0.00 0.00 0.00 0.00 Closing Equity 2438.58 2438.58 222.27 222.27 Average Equity 2438.58 2438.58 222.27 222.27 Return on Equity (Base Rate) 15.50% 15.50% 15.50% 15.50% Tax rate for the year 2008-09 (MAT) 11.33% 11.33% 11.33% 11.33% Rate of Return on Equity (Pre Tax) 17.481% 17.481% 17.481% 17.481% Return on Equity (Pre Tax) 319.72 426.29 16.19 38.86

    Additional Return on Equity

    35. The petitioner has claimed in the petition additional return on equity of 0.5% as the instant transmission assets were anticipated to be commissioned within the timeline specified in the 2009 Tariff Regulations. APDCL has submitted that the Commission should seek petitioner's justification for claiming the additional return on equity of 0.5%. As stated earlier, Asset-4 has not been commissioned yet. As all the assets covered in the instant transmission project are not commissioned within the timeline specified in the 2009 Tariff Regulations, the petitioner's claim of additional return on equity of 0.5% is not admissible and accordingly it is disallowed.

    Interest on Loan

    36. Regulation 16 of the 2009 Tariff Regulations provides as under:—

    “16. Interest on loan capital (1) The loans arrived at in the manner indicated in regulation 12 shall be considered as gross normative loan for calculation of interest on loan.

    (2) The normative loan outstanding as on 1.4.2009 shall be worked out by deducting the cumulative repayment as admitted by the Commission up to 31.3.2009 from the gross normative loan.

    (3) The repayment for the year of the tariff period 2009-14 shall be deemed to be equal to the depreciation allowed for that year:

    (4) Notwithstanding any moratorium period availed by the generating company or the transmission licensee, as the case may be the repayment of loan shall be considered from the first year of commercial operation of the project and shall be equal to the annual depreciation allowed.

    (5) The rate of interest shall be the weighted average rate of interest calculated on the basis of the actual loan portfolio at the beginning of each year applicable to the project:

    Provided that if there is no actual loan for a particular year but normative loan is still outstanding, the last available weighted average rate of interest shall be considered:

    Provided further that if the generating station or the transmission system, as the case may be, does not have actual loan, then the weighted average rate of interest of the generating company or the transmission licensee as a whole shall be considered.

    (6) The interest on loan shall be calculated on the normative average loan of the year by applying the weighted average rate of interest.

    (7) The generating company or the transmission licensee, as the case may be, shall make every effort to re-finance the loan as long as it results in net savings on interest and in that event the costs associated with such refinancing shall be borne by the beneficiaries and the net savings shall be shared between the beneficiaries and the generating company or the transmission licensee, as the case may be, in the ratio of 2:1.

    (8) The changes to the terms and conditions of the loans shall be reflected from the date of such re-financing.

    (9) In case of dispute, any of the parties may make an application in accordance with the Central Electricity Regulatory Commission (Conduct of Business) Regulations, 1999, as amended from time to time, including statutory re-enactment thereof for settlement of the dispute:

    Provided that the beneficiary or the transmission customers shall not withhold any payment on account of the interest claimed by the generating company or the transmission licensee during the pendency of any dispute arising out of re-financing of loan.”

    37. APDCL has submitted that methodology for recovery of interest on loan is specified in Regulation 16 of the 2009 Tariff Regulations and it is worked out on the basis of the normative loan and normative repayment considering the weighted average rate of interest on loan. APDCL has submitted that the petitioner's prayer has already been taken in the 2009 Tariff Regulations. We would like to clarify that interest on loan is allowed as per the provisions of Regulation 16 of the 2009 Tariff Regulations. The petitioner's entitlement to interest on loan has been calculated on the following basis:—

    (a) Gross amount of loan, repayment of instalments and rate of interest and weighted average rate of interest on actual average loan have been considered as per the petition;

    (b) The repayment for the tariff period 2009-14 shall be deemed to be equal to the depreciation allowed for that period;

    (c) Weighted average rate of interest on actual average loan worked out as per (a) above is applied on the notional average loan during the year to arrive at the interest on loan; and

    (d) Notwithstanding moratorium period availed by the transmission licensee, the repayment of the loan shall be considered from the first year of commercial operation of the project and shall be equal to the annual depreciation allowed.

    38. Accordingly, the interest on loan has been calculated on the basis of prevailing rate as on the date of commercial operation. Any change in rate of interest subsequent to the date of commercial operation will be considered at the time of truing up. Further, the petitioner has considered the proposed bond 12-13 (9.30%) in the Form-13 for calculation of weighted average rate of interest on actual loan. However, as per Regulation 16 (5) of the 2009 Tariff Regulations, the rate of interest shall be the weighted average rate of interest calculated on the basis of the actual loan portfolio. Accordingly, the same has not been considered for the purpose of computation of weighted average rate of interest.

    39. Detailed calculations in support of the weighted average rates of interest have been given in Annexure 1 to 4 to this order.

    40. Based on the above, interest on loan has been calculated as follows:—

    (Rs. in lakh)

    Particulars Asset 1 Asset 2 2012-13 (Pro-rata) 2013-14 2012-13 (Pro-rata) 2013-14 Gross Normative Loan 1061.66 1230.68 1396.82 1466.82 Cumulative Repayment upto previous year 0.00 64.94 0.00 81.00 Net Loan-Opening 1061.66 1165.74 1396.82 1385.82 Addition due to additional capital expenditure 169.03 0.00 70.00 73.19 Repayment during the year 64.94 92.96 81.00 113.40 Net Loan-Closing 1165.74 1072.78 1385.82 1345.60 Average Loan 1113.70 1119.26 1391.32 1365.71 Weighted Average Rate of Interest on Loan 9.3320% 9.2756% 9.3819% 9.3842% Interest 77.95 103.82 97.90 128.16

    (Rs. in lakh)

    Particulars Asset 3 Asset 5 2012-13 (Pro-rata) 2013-14 2012-13 (Pro-rata) 2013-14 Gross Normative Loan 5690.02 5690.02 518.63 518.63 Cumulative Repayment upto previous year 0.00 321.93 0.00 16.30 Net Loan-Opening 5690.02 5368.09 518.63 502.33 Addition due to additional capital expenditure 0.00 0.00 0.00 0.00 Repayment during the year 321.93 429.24 16.30 39.12 Net Loan-Closing 5368.09 4938.85 502.33 463.21 Average Loan 5529.06 5153.47 510.48 482.77 Weighted Average Rate of Interest on Loan 9.4023% 9.4036% 9.2095% 9.2107% Interest 389.89 484.61 19.59 44.47

    Depreciation

    41. Regulation 17 of the 2009 Tariff Regulations provides as follows:—

    “17. Depreciation (1) The value base for the purpose of depreciation shall be the capital cost of the asset admitted by the Commission.

    (2) The salvage value of the asset shall be considered as 10% and depreciation shall be allowed up to maximum of 90% of the capital cost of the asset.

    Provided that in case of hydro generating stations, the salvage value shall be as provided in the agreement signed by the developers with the State Government for creation of the site;

    Provided further that the capital cost of the assets of the hydro generating station for the purpose of computation of depreciable value shall correspond to the percentage of sale of electricity under long-term power purchase agreement at regulated tariff.

    (3) Land other than the land held under lease and the land for reservoir in case of hydro generating station shall not be a depreciable asset and its cost shall be excluded from the capital cost while computing depreciable value of the asset.

    (4) Depreciation shall be calculated annually based on Straight Line Method and at rates specified in Appendix-III to these regulations for the assets of the generating station and transmission system:

    Provided that, the remaining depreciable value as on 31st March of the year closing after a period of 12 years from date of commercial operation shall be spread over the balance useful life of the assets.

    (5) In case of the existing projects, the balance depreciable value as on 1.4.2009 shall be worked out by deducting the cumulative depreciation as admitted by the Commission up to 31.3.2009 from the gross depreciable value of the assets.

    (6) Depreciation shall be chargeable from the first year of commercial operation. In case of commercial operation of the asset for part of the year, depreciation shall be charged on pro rata basis.”

    42. Asset-1, Asset-2 and Asset-3 have been put under commercial operation as on 1.7.2012 and Asset-5 has been put under commercial operation as on 1.11.2012 The assets will complete 12 years beyond 2013-14. Accordingly, depreciation has been calculated annually based on Straight Line Method and at rates specified in Appendix-III to the 2009 Tariff Regulations as per the details given hereunder:—

    (Rs. in lakh)

    Particulars Asset 1 Asset 2 2012-13 (Pro-rata) 2013-14 2012-13 (Pro-rata) 2013-14 Opening Gross Block 1516.65 1758.12 1995.45 2095.45 Addition due to Projected Additional Capitalisation 241.47 0.00 100.00 104.55 Closing Gross Block 1758.12 1758.12 2095.45 2200.00 Average Gross Block 1637.39 1758.12 2045.45 2147.73 Rate of Depreciation 5.2881% 5.2876% 5.2800% 5.2800% Depreciable Value 1473.65 1582.31 1840.91 1932.95 Remaining Depreciable Value 1473.65 1517.37 1840.91 1851.95 Depreciation 64.94 92.96 81.00 113.40 Cumulative Depreciation 64.94 157.90 81.00 194.40

    (Rs. in lakh)

    Particulars Asset 3 Asset 5 2012-13 (Pro-rata) 2013-14 2012-13 (Pro-rata) 2013-14 Opening Gross Block 8128.60 8128.60 740.90 740.90 Addition due to Projected Additional Capitalisation 0.00 0.00 0.00 0.00 Closing Gross Block 8128.60 8128.60 740.90 740.90 Average Gross Block 8128.60 8128.60 740.90 740.90 Rate of Depreciation 5.2806% 5.2806% 5.2800% 5.2800% Depreciable Value 7315.74 7315.74 666.81 666.81 Remaining Depreciable Value 7315.74 6993.81 666.81 650.51 Depreciation 321.93 429.24 16.30 39.12 Cumulative Depreciation 321.93 751.17 16.30 55.42

    Operation & Maintenance Expenses (O & M Expenses)

    43. Regulation 19(g) of the 2009 Tariff Regulations prescribes the norms for O & M Expenses for the transmission system based on the type of sub-station and the transmission line. The norms for the transmission assets covered in the instant petition are as follows:—

    Element 2009-10 2010-11 2011-12 2012-13 2013-14 400 kV bay (Rs. 1akh/bay) 52.40 55.40 58.57 61.92 65.46 132 kV & below bay (Rs. 1akh/bay) 26.20 27.70 29.28 30.96 32.73 D/C single conductor TL (Rs. 1akh/km) 0.269 0.284 0.301 0.318 0.336 S/C single conductor TL (Rs. 1akh/km) 0.179 0.189 0.200 0.212 0.224 D/C twin conductor TL (Rs. 1akh/km) 0.627 0.663 0.701 0.741 0.783

    44. The allowable O & M Expenses for the assets covered in this petition as per the 2009 Tariff Regulations, are given overleaf:—

    (Rs. 1akh/bay)

    Asset-1

    Elements 2012-13 (pro-rata) 2013-14 15 km 132 kV S/C, single conductor T/L 2.39 3.36 2 no., 132 kV bays 46.44 65.46 Total O & M 48.83 68.82

    Asset-2

    Elements 2012-13 (pro-rata) 2013-14 1 no, 400 kV bay 46.44 65.46 1 no, 132 kV bay 23.22 32.73 Total O & M 69.66 98.18

    Asset-3

    Elements 2012-13 (pro-rata) 2013-14 37.2 km 400kV D/C, twin conductor T/L 20.67 29.13 2 no., 132 kV 46.44 65.46 Total O & M 67.11 94.59

    Asset-5

    Elements 2012-13 (pro-rata) 2013-14 1 no, 400 kV bay 25.80 65.46 Total O & M 25.80 65.46

    45. The petitioner has submitted that O & M Expenses for 2009-14 tariff block had been arrived on the basis of normalized actual O & M Expenses of the petitioner during the year 2003-04 to 2007-08. The wage hike of 50% on account of pay revision of the employees of public sector undertaking was also considered while calculating the O & M Expenses for tariff period 2009-14. The petitioner has submitted that it would approach the Commission for suitable revision in the norms for O & M Expenses due to wage revision, if any. The petitioner further submitted that in O & M norms for tariff block 2009-14 the cost associated with license fees had not been captured and the license fee may be allowed to be recovered separately from the beneficiaries.

    46. The Commission has given effect to impact of pay revision in the 2009 Tariff Regulations by factoring 50% on account of pay revision of the employees of PSUs after extensive stakeholders' consultation. We do not see any reason why the admissible amount is inadequate to meet the requirement of the employee cost. However, in case the petitioner approaches with any such application, the same shall be dealt with in accordance with law.

    Interest on Working Capital

    47. The petitioner is entitled to claim interest on working capital as per the 2009 Tariff Regulations. The components of the working capital and the petitioner's entitlement to interest thereon are discussed hereunder:—

    (i) Receivables

    As per Regulation 18(1) (c) (i) of the 2009 Tariff Regulations, receivables as a component of working capital will be equivalent to two months of fixed cost. The petitioner has claimed the receivables on the basis of 2 months of annual transmission charges. In the tariff being allowed, receivables have been worked out on the basis of 2 months transmission charges.

    (ii) Maintenance Spares

    Regulation 18 (1) (c) (ii) of the 2009 Tariff Regulations provides for maintenance spares @ 15% per annum of the O & M Expenses as part of the working capital from 1.4.2009 The value of maintenance spares has accordingly been worked out.

    (iii) O & M Expenses

    Regulation 18(1) (c) (iii) of the 2009 Tariff Regulations provides for O & M Expenses for one month to be included in the working capital. The petitioner has claimed O & M Expenses for one month of the respective year. This has been considered in the working capital.

    (iv) Rate of Interest on Working Capital

    In accordance with clause (3) of Regulation 18 of the 2009 Tariff Regulations, the rate of interest on working capital shall be on normative basis and shall be equal to State Bank of India Base Rate of 10% plus 350 bps as on 1.4.2012 (13.50%). The interest on working capital for the assets covered in the petition has been worked out accordingly.

    48. Necessary computations in support of Interest on Working Capital are given hereunder:—

    (Rs. in lakh)

    Particulars Asset 1 Asset 2 2012-13 (Pro-rata) 2013-14 2012-13 (Pro-rata) 2013-14 Maintenance Spares 9.77 10.32 13.93 14.73 O & M Expenses 5.43 5.74 7.74 8.18 Receivables 58.58 61.38 75.30 77.66 Total 73.77 77.43 96.97 100.57 Rate of Interest 13.50% 13.50% 13.50% 13.50% Interest 7.47 10.45 9.82 13.58

    (Rs. in lakh)

    Particulars Asset 3 Asset 5 2012-13 (Pro-rata) 2013-14 2012-13 (Pro-rata) 2013-14 Maintenance Spares 13.42 14.19 9.29 9.82 O & M Expenses 7.46 7.88 5.16 5.46 Receivables 250.24 245.13 32.20 32.39 Total 271.12 267.20 46.65 47.66 Rate of Interest 13.50% 13.50% 13.50% 13.50% Interest 27.45 36.07 2.62 6.43

    Transmission Charges

    49. The transmission charges allowed for the assets are summarized below:—

    (Rs. in lakh)

    Particulars Asset 1 Asset 2 2012-13 (Pro-rata) 2013-14 2012-13 (Pro-rata) 2013-14 Depreciation 64.94 92.96 81.00 113.40 Interest on Loan 77.95 103.82 97.90 128.16 Return on Equity 64.40 92.20 80.45 112.63 Interest on Working Capital 7.47 10.45 9.82 13.58 O & M Expenses 48.83 68.82 69.66 98.18 Total 263.59 368.25 338.83 465.95

    (Rs. in lakh)

    Particulars Asset 3 Asset 5 2012-13 (Pro-rata) 2013-14 2012-13 (Pro-rata) 2013-14 Depreciation 321.93 429.24 16.30 39.12 Interest on Loan 389.89 484.61 19.59 44.47 Return on Equity 319.72 426.29 16.19 38.86 Interest on Working Capital 27.45 36.07 2.62 6.43 O & M Expenses 67.11 94.59 25.80 65.46 Total 1126.10 1470.80 80.50 194.34

    Filing Fee and Publication Expenses

    50. The petitioner has sought reimbursement of fee paid by it for filing the petition and publication expenses. APDCL has submitted that filing fee and publication expenses should be allowed as per the provisions of 2009 Tariff Regulations. The petitioner shall be entitled for reimbursement of the filing fees and publication expenses in connection with the present petition, directly from the beneficiaries on pro-rata basis in accordance with Regulation 42A (1) (a) of the 2009 Tariff Regulations.

    Licence fee

    51. The petitioner has submitted that in O & M norms for tariff block 2009-14 the cost associated with license fees had not been captured and the license fee may be allowed to be recovered separately from the respondents. APDCL has submitted that licence fee should be allowed as per the 2009 Tariff Regulations. The petitioner shall be entitled for reimbursement of licence fee in accordance with Regulation 42 A (1) (b) of the 2009 Tariff Regulations

    Service tax

    52. The petitioner has made a prayer to be allowed to bill and recover the service tax on transmission charges separately from the respondents, if it is subjected to such service tax in future. APDCL has submitted that the petitioner's prayer is premature and it should not be entertained. We consider petitioner's prayer pre-mature and accordingly this prayer is rejected.

    Sharing of Transmission Charges

    53. Tariff for assets given above shall be shared by the respondents in accordance with the Central Electricity Regulatory Commission (Sharing of Inter State Transmission Charges and Losses) Regulations, 2010.

    54. This order disposes of Petition No. 98.TT/2012.

    Annexure 1

    Calculation of Weighted Average Rate of Interest on Actual Loans for Asset-1

    (Rs. in lakh)

    Details of Loan 2012-13 2013-14 1 Bond XXXIII Gross loan opening 25.00 25.00 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 25.00 25.00 Additions during the year 0.00 0.00 Repayment during the year 0.00 0.00 Net Loan-Closing 25.00 25.00 Average Loan 25.00 25.00 Rate of Interest 8.64% 8.64% Interest 2.16 2.16 Rep Schedule 12 annual installments from 8.7.2014 2 Bond XXXIV Gross loan opening 21.00 21.00 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 21.00 21.00 Additions during the year 0.00 0.00 Repayment during the year 0.00 0.00 Net Loan-Closing 21.00 21.00 Average Loan 21.00 21.00 Rate of Interest 8.840% 8.840% Interest 1.86 1.86 Rep Schedule 12 Equal Annual Installments from 21.10.2014 3 Bond XXXI Gross loan opening 45.00 45.00 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 45.00 45.00 Additions during the year 0.00 0.00 Repayment during the year 0.00 3.75 Net Loan-Closing 45.00 41.25 Average Loan 45.00 43.13 Rate of Interest 8.90% 8.90% Interest 4.01 3.84 Rep Schedule 12 Equal Annual Installments from 25.2.2014 4 Bond XL Gross loan opening 140.40 140.40 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 140.40 140.40 Additions during the year 0.00 0.00 Repayment during the year 0.00 0.00 Net Loan-Closing 140.40 140.40 Average Loan 140.40 140.40 Rate of Interest 9.300% 9.30% Interest 13.06 13.06 Rep Schedule 12 Equal Annual Installments from 28.6.2016 5 Bond XXXVI Gross loan opening 432.00 432.00 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 432.00 432.00 Additions during the year 0.00 0.00 Repayment during the year 0.00 0.00 Net Loan-Closing 432.00 432.00 Average Loan 432.00 432.00 Rate of Interest 9.350% 9.35% Interest 40.39 40.39 Rep Schedule 15 Equal Annual Installments from 29.8.2016 6 Bond XXXV Gross loan opening 400.00 400.00 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 400.00 400.00 Additions during the year 0.00 0.00 Repayment during the year 0.00 0.00 Net Loan-Closing 400.00 400.00 Average Loan 400.00 400.00 Rate of Interest 9.640% 9.640% Interest 38.56 38.56 Rep Schedule 12 Equal Annual Installments from 31.5.2015 7 Bond XLI (AddCap for 2012-13 Drawl on 31.3.2013) Gross loan opening 0.00 329.28 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 0.00 329.28 Additions during the year 329.28 0.00 Repayment during the year 0.00 0.00 Net Loan-Closing 329.28 329.28 Average Loan 164.64 329.28 Rate of Interest 8.85% 8.85% Interest 14.57 29.14 Rep Schedule 12 annual installments from 19.10.2016 Total Loan Gross loan opening 1063.40 1392.68 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 1063.40 1392.68 Additions during the year 329.28 0.00 Repayment during the year 0.00 3.75 Net Loan-Closing 1392.68 1388.93 Average Loan 1228.04 1390.81 Rate of Interest 9.3320% 9.2756% Interest 114.60 129.01

    Annexure 2

    Calculation of Weighted Average Rate of Interest on Actual Loans for Asset-2

    (Rs. in lakh)

    Details of Loan 2012-13 2013-14 1 Bond XXXIII Gross loan opening 50.00 50.00 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 50.00 50.00 Additions during the year 0.00 0.00 Repayment during the year 0.00 0.00 Net Loan-Closing 50.00 50.00 Average Loan 50.00 50.00 Rate of Interest 8.64% 8.64% Interest 4.32 4.32 Rep Schedule 12 annual installments from 8.7.2014 2 Bond XXXIV Gross loan opening 55.00 55.00 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 55.00 55.00 Additions during the year 0.00 0.00 Repayment during the year 0.00 0.00 Net Loan-Closing 55.00 55.00 Average Loan 55.00 55.00 Rate of Interest 8.840% 8.840% Interest 4.86 4.86 Rep Schedule 12 Equal Annual Installments from 21.10.2014 3 Bond XXXI Gross loan opening 150.00 150.00 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 150.00 150.00 Additions during the year 0.00 0.00 Repayment during the year 0.00 12.50 Net Loan-Closing 150.00 137.50 Average Loan 150.00 143.75 Rate of Interest 8.90% 8.90% Interest 13.35 12.79 Rep Schedule 12 Equal Annual Installments from 25.2.2014 4 Bond XXXVI Gross loan opening 490.00 490.00 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 490.00 490.00 Additions during the year 0.00 0.00 Repayment during the year 0.00 0.00 Net Loan-Closing 490.00 490.00 Average Loan 490.00 490.00 Rate of Interest 9.350% 9.35% Interest 45.82 45.82 Rep Schedule 15 Equal Annual Installments from 29.8.2016 5 Bond XXXV Gross loan opening 600.00 600.00 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 600.00 600.00 Additions during the year 0.00 0.00 Repayment during the year 0.00 0.00 Net Loan-Closing 600.00 600.00 Average Loan 600.00 600.00 Rate of Interest 9.640% 9.640% Interest 57.84 57.84 Rep Schedule 12 Equal Annual Installments from 31.5.2015 Total Loan Gross loan opening 1345.00 1345.00 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 1345.00 1345.00 Additions during the year 0.00 0.00 Repayment during the year 0.00 12.50 Net Loan-Closing 1345.00 1332.50 Average Loan 1345.00 1338.75 Rate of Interest 9.3819% 9.3842% Interest 126.19 125.63

    Annexure 3

    Calculation of Weighted Average Rate of Interest on Actual Loans for Asset-3

    (Rs. in lakh)

    Details of Loan 2012-13 2013-14 1 Bond XXXIII Gross loan opening 150.00 150.00 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 150.00 150.00 Additions during the year 0.00 0.00 Repayment during the year 0.00 0.00 Net Loan-Closing 150.00 150.00 Average Loan 150.00 150.00 Rate of Interest 8.64% 8.64% Interest 12.96 12.96 Rep Schedule 12 annual installments from 8.7.2014 2 Bond XXXIV Gross loan opening 125.00 125.00 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 125.00 125.00 Additions during the year 0.00 0.00 Repayment during the year 0.00 0.00 Net Loan-Closing 125.00 125.00 Average Loan 125.00 125.00 Rate of Interest 8.840% 8.840% Interest 11.05 11.05 Rep Schedule 12 Equal Annual Installments from 21.10.2014 3 Bond XXXI Gross loan opening 300.00 300.00 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 300.00 300.00 Additions during the year 0.00 0.00 Repayment during the year 0.00 25.00 Net Loan-Closing 300.00 275.00 Average Loan 300.00 287.50 Rate of Interest 8.90% 8.90% Interest 26.70 25.59 Rep Schedule 12 Equal Annual Installments from 25.2.2014 4 Bond XXXVI Gross loan opening 2140.00 2140.00 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 2140.00 2140.00 Additions during the year 0.00 0.00 Repayment during the year 0.00 0.00 Net Loan-Closing 2140.00 2140.00 Average Loan 2140.00 2140.00 Rate of Interest 9.350% 9.35% Interest 200.09 200.09 Rep Schedule 15 Equal Annual Installments from 29.8.2016 5 Bond XXXV Gross loan opening 2000.00 2000.00 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 2000.00 2000.00 Additions during the year 0.00 0.00 Repayment during the year 0.00 0.00 Net Loan-Closing 2000.00 2000.00 Average Loan 2000.00 2000.00 Rate of Interest 9.640% 9.640% Interest 192.80 192.80 Rep Schedule 12 Equal Annual Installments from 31.5.2015 6 Bond XXXVII Gross loan opening 185.00 185.00 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 185.00 185.00 Additions during the year 0.00 0.00 Repayment during the year 0.00 0.00 Net Loan-Closing 185.00 185.00 Average Loan 185.00 185.00 Rate of Interest 9.25% 9.25% Interest 17.11 17.11 Rep Schedule 12 annual installments from 26.12.2015 Total Loan Gross loan opening 4900.00 4900.00 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 4900.00 4900.00 Additions during the year 0.00 0.00 Repayment during the year 0.00 25.00 Net Loan-Closing 4900.00 4875.00 Average Loan 4900.00 4887.50 Rate of Interest 9.4023% 9.4036% Interest 460.71 459.60

    Annexure 4

    Calculation of Weighted Average Rate of Interest on Actual Loans for Asset-5

    (Rs. in lakh)

    Details of Loan 2012-13 2013-14 1 Bond XXXIII Gross loan opening 25.00 25.00 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 25.00 25.00 Additions during the year 0.00 0.00 Repayment during the year 0.00 0.00 Net Loan-Closing 25.00 25.00 Average Loan 25.00 25.00 Rate of Interest 8.64% 8.64% Interest 2.16 2.16 Rep Schedule 12 annual installments from 8.7.2014 2 Bond XXXVIII Gross loan opening 165.00 165.00 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 165.00 165.00 Additions during the year 0.00 0.00 Repayment during the year 0.00 0.00 Net Loan-Closing 165.00 165.00 Average Loan 165.00 165.00 Rate of Interest 9.250% 9.250% Interest 15.26 15.26 Rep Schedule Bullet payment as on 9.3.2027 3 Bond XXXI Gross loan opening 50.00 50.00 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 50.00 50.00 Additions during the year 0.00 0.00 Repayment during the year 0.00 4.17 Net Loan-Closing 50.00 45.83 Average Loan 50.00 47.92 Rate of Interest 8.90% 8.90% Interest 4.45 4.26 Rep Schedule 12 Equal Annual Installments from 25.2.2014 4 Bond XXXVI Gross loan opening 100.00 100.00 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 100.00 100.00 Additions during the year 0.00 0.00 Repayment during the year 0.00 0.00 Net Loan-Closing 100.00 100.00 Average Loan 100.00 100.00 Rate of Interest 9.350% 9.35% Interest 9.35 9.35 Rep Schedule 15 Equal Annual Installments from 29.8.2016 5 Bond XXXVII Gross loan opening 222.00 222.00 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 222.00 222.00 Additions during the year 0.00 0.00 Repayment during the year 0.00 0.00 Net Loan-Closing 222.00 222.00 Average Loan 222.00 222.00 Rate of Interest 9.25% 9.25% Interest 20.54 20.54 Rep Schedule 12 annual installments from 26.12.2015 Total Loan Gross loan opening 562.00 562.00 Cumulative Repayment upto DOCO/previous year 0.00 0.00 Net Loan-Opening 562.00 562.00 Additions during the year 0.00 0.00 Repayment during the year 0.00 4.17 Net Loan-Closing 562.00 557.83 Average Loan 562.00 559.92 Rate of Interest 9.2095% 9.2107% Interest 51.76 51.57

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