BEFORE THE MADHYA PRADESH ELECTRICITY REGULATORY COMMISSION BHOPAL

True Up for FY 2015-16 BEFORE THE MADHYA PRADESH ELECTRICITY REGULATORY COMMISSION BHOPAL CASE NO: Filing of the Petition for True Up of FY 2015-16 under the MPERC (Terms and Conditions for determination of tariff for supply and wheeling of electricity and methods and principles for fixation of charges) Regulations, 2012 along with other guidelines and directions issued by the MPERC from time to time AND under Part VII (Section 61 to Section 64) of the Electricity Act, 2003 read with the relevant Guidelines. Filed by:- MADHYA PRADESH AUDYOGIK KENDRA VIKAS NIGAM (INDORE) LTD 3/54, Press Complex, Free Press House, Indore (Madhya Pradesh) Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 1

True Up for FY 2015-16 BEFORE THE MADHYA PRADESH ELECTRICITY REGULATORY COMMISSION BHOPAL Filing No: Case No: IN THE MATTER OF Filing of the Petition for True Up of FY 2015-16 under the MPERC (Terms and Conditions for determination of tariff for supply and wheeling of electricity and methods and principles for fixation of charges) Regulations, 2012 along with other guidelines and directions issued by the MPERC from time to time AND under Part VII (Section 61 to Section 64) of the Electricity Act, 2003 read with the relevant Guidelines AND IN THE MATTER OF Madhya Pradesh Audhogik Vikas Nigam (Indore) Ltd. 3/54, Press Complex, Free Press House, Indore (M.P.) PETITIONER THE PETITIONER ABOVE NAMED RESPECTFULLY SUBMITS Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 2

True Up for FY 2015-16 TABLE OF CONTENTS 1. Executive Summary... 6 1.1. Preamble... 6 1.2. True Up of FY 2015-16... 7 2. Introduction... 15 2.1. Preamble... 15 2.2. Introduction... 15 2.3. Submission to the Hon ble Commission... 16 3. True Up for FY 2015-16... 17 3.1. Preamble... 17 3.2. Principles for True Up for FY 2015-16... 17 3.3. Category wise Sales... 17 3.4. Distribution Losses... 18 3.5. Energy Requirement and Energy Balance... 18 3.6. Power Purchase Cost... 19 3.7. Transmission Charges... 20 3.8. Capitalisation... 21 3.9. Funding of Capital Expenditure... 21 3.10. Changes in the value of Gross Fixed Assets and consequent changes in the Opening Consumer Contribution, Debt and Equity for FY 2015-16... 22 3.11. Aggregate Revenue Requirements for FY 2015-16... 24 3.12. Operation & Maintenance Expenses... 24 3.13. Depreciation... 26 3.14. Interest & Financial Charges... 27 3.15. Interest on Working Capital... 28 3.16. Lease Rent... 29 3.17. Return on equity... 31 3.18. Other Income... 31 3.19. Aggregate Revenue Requirement for FY 2015-16... 32 3.20. Revenue for FY 2015-16... 32 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 3

True Up for FY 2015-16 3.21. Revenue Gap / (Surplus) for FY 2015-16... 33 4. Prayer... 34 Annexure 1: Tariff Filing Formats... 35 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 4

True Up for FY 2015-16 LIST OF TABLES Table 1 : Category-wise Sales... 8 Table 2 : Distribution Losses... 8 Table 3 : Energy Requirement and Energy Balance... 9 Table 4 : Net Power Purchase Cost for FY 2015-16... 9 Table 5 : Transmission Charges for FY 2015-16... 10 Table 6 : Capitalization for FY 2015-16... 10 Table 7 : O&M Expenses for FY 2015-16... 10 Table 8 : Net Depreciation for FY 2015-16... 11 Table 9 : Interest & Financial Charges for FY 2015-16... 11 Table 10 : Interest on Working Capital for FY 2015-16... 12 Table 11 : Lease Rent for FY 2015-16... 13 Table 12 : Return on Equity for FY 2015-16... 13 Table 13 : Other Income for FY 2015-16... 13 Table 14 : Aggregate Revenue Requirement for FY 2015-16... 14 Table 15 : Revenue Gap/ (Surplus) for FY 2015-16... 14 Table 16 : Category-wise Sales... 18 Table 17 : Distribution Losses... 18 Table 18 : Energy Requirement and Energy Balance... 19 Table 19 : Net Power Purchase Cost for FY 2015-16... 20 Table 20 : Transmission Charges for FY 2015-16... 20 Table 21 : Capitalization for FY 2015-16... 21 Table 22 : Funding of Capitalisation... 21 Table 23 : Calculation of Opening Consumer Contribution for FY 2015-16... 23 Table 24 : Calculation of Opening equity & net debt for FY 2015-16... 23 Table 25 : Employee Cost for FY 2015-16... 24 Table 26 : Repair & Maintenance Cost for FY 2015-16... 25 Table 27 : Administration & General Expenses for FY 2015-16... 25 Table 28 : MPERC Expenses for FY 2015-16... 25 Table 29 : O&M Expenses for FY 2015-16... 26 Table 30 : Depreciation for FY 2015-16... 27 Table 31 : Net Depreciation for FY 2015-16... 27 Table 32 : Interest & Financial Charges for FY 2015-16... 28 Table 33 : Interest on Consumer Security Deposit for FY 2015-16... 28 Table 34 : Interest on Working Capital for FY 2015-16... 29 Table 35 : Lease Rent for FY 2015-16... 30 Table 36 : Return on Equity for FY 2015-16... 31 Table 37 : Other Income for FY 2015-16... 32 Table 38 : Aggregate Revenue Requirement for FY 2015-16... 32 Table 39 : Revenue Gap/ (Surplus) for FY 2015-16... 33 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 5

True Up for FY 2015-16 1. Executive Summary 1.1. Preamble 1.1.1. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd., (hereinafter referred as the Petitioner, MPAKVN, the Company or the Licensee ), is a Company incorporated under the Companies Act, 1956(Now Companies Act, 2013) having its registered office at 3/54, Press Complex, Free Press House, Indore. The Petitioner is a deemed distribution licensee under the fifth Proviso to Section 14 of the Electricity Act, 2003. The area of supply of the Petitioner is SEZ Indore (Pithampur) within the State of Madhya Pradesh ( MP ). 1.1.2. The Government of Madhya Pradesh ( GoMP or State Government ), has passed the Special Economic Zone Policy in August 2003. The Indore Special Economic Zone (Special Provisions), Act 2003 was also enacted in the year 2003. This Act has been passed by the Madhya Pradesh Vidhan Sabha on dated 28 th March 2003 (Madhya Pradesh Act No 23 of 2003), The Indore Special Economic Zone (Special Provisions), Act 2003 an Act to provide for the development, operation, maintenance and administration of Indore Special Economic Zone. 1.1.3. It is submitted that licensee MPAKVN (I) Ltd. is the wholly owned undertaking of Government of Madhya Pradesh and working for the Industrial Promotion & Development in the State. MPAKVN (I) Ltd has three subsidiary Companies viz. SEZ Indore Ltd (Specially formed for the operation, development, maintenance and administration of SEZ for which MPAKVN (I) Ltd is a Deemed Distribution Licensee), Crystal IT Park Indore Ltd. and Pithampur Auto Cluster Ltd. 1.1.4. In the backdrop of the above facts and circumstances, the present application is being submitted by the Petitioner (MPAKVN Indore Ltd.) under Section 61 and Section 62 (1) (d) of the Electricity Act 2003 for True up for ARR of FY 2015-16 under the MPERC (Terms and Conditions for determination of tariff for supply and wheeling of electricity and methods and principles for fixation of charges) Regulations, 2012 hereinafter referred as Tariff Regulations, 2012. 1.1.5. The present application is being submitted by the Petitioner under Section 61 and Section 62 (1) (d) of the Electricity Act 2003 for True up for ARR of FY 2015-16 under the tariff principles laid down in the MYT Regulations, 2012 for approval by the Hon ble Commission. 1.1.6. It is submitted that the MPAKVN has prepared separate Accounts for the power business of the SEZ for FY 2015-16 on the basis of rational allocation of Revenue, Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 6

True Up for FY 2015-16 Expenses, and Assets & Liabilities between power & other business and shall continue preparing separate Accounts for subsequent years as directed by the Hon ble Commission. 1.1.7. While filing the present True up and ARR under the prevailing Regulations, MPAKVN has endeavoured to comply with the various applicable legal and regulatory directions and stipulations including the directions of the Hon ble Commission in the Business Rules of the Commission, the Guidelines, previous ARR of Discoms and Tariff Orders and the Regulations. 1.1.8. Based on the information available, the Petitioner has made sincere efforts to comply with the Regulations of the Hon ble Commission and discharge its obligations to the best of its capabilities. However, if any further material information becomes available in the near future, the applicant craves leave of the Hon ble Commission to file such additional information and consequently amend/ revise the application. 1.1.9. Shri B.L. Goyal, Joint Director (Planning) of MPAKVN has been authorized to execute and file all the documents on behalf of the petitioner in this regard. Accordingly, the current filing is signed and verified by, and backed by the affidavit of Shri B.L. Goyal. 1.2. True Up of FY 2015-16 1.2.1. The actual ARR for FY 2015-16 is based on audited accounts of FY 2015-16 and the principles adopted by the Hon ble Commission in its previous Orders on various ARR elements. The actual expenses have been compared against those approved for FY 2015-16 in the Tariff Order dated 23 rd March, 2015. 1.2.2. The actual Energy Sales and those approved by the Hon ble Commission in its Order approving the ARR for FY 2015-16 are compared for True up purposes. It is submitted that actual HT sales have been higher than that approved in the ARR Order and the Petitioner requests the Hon ble Commission to approve the same. The following table shows the energy sales for FY 2015-16. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 7

True Up for FY 2015-16 Table 1 : Category-wise Sales MU Consumer Category 2015-16 Approved Actual LT Consumer Categories Non Domestic 0.04 0.31 Public Water Works and Street Light 0.41 0.34 Industrial 0.11 0.12 Total LT Sale 0.56 0.77 HT Consumer Categories Industrial 220.12 285.37 Non Industrial - - Total HT Sale 220.12 285.37 Total LT+HT Sale 220.68 286.14 1.2.3. In FY 2015-16, the actual distribution losses were 2.22% as against the approved level of 3.30%. The table below highlights the comparison of actual distribution losses against that approved by the Hon ble Commission vide its Tariff Order. Table 2 : Distribution Losses FY 2015-16 FY 2015-16 Particulars (Approved) (Actual) Distribution Losses 3.30% 2.22% 1.2.4. It is submitted that MPAKVN has been able to control the actual distribution losses to levels well below those approved by the Hon ble Commission for the FY 2015-16. However, as the overall retail sales to consumers have increased during the FY 2015-16, the overall requirement for power purchase has increased beyond the approved levels. The energy balance based on the actual sales during the year and the distribution losses for FY 2015-16 is given below. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 8

True Up for FY 2015-16 Table 3 : Energy Requirement and Energy Balance Sr. No. Particlars unit 2015-16 Approved Actual 1 Total Units sold to LT category MU 0.56 0.77 2 Total Units sold to HT category MU 220.12 285.37 3 Total Units Sold (1+2) MU 220.68 286.14 4 Distribution Losses % 3.30% 2.22% 5 Distribution Losses MU 7.53 6.49 6 Units Input at AKVN Distribution Boundary (3 + 5) MU 228.21 292.63 7 Transmission Losses % 3.00% 3.00% 8 Transmission Losses MU 7.06 9.05 9 Input at G-T interface (6 + 8) MU 235.27 301.68 10 PGCIL Losses % 0.00% 0.00% 11 PGCIL Losses MU - - 12 Total Units Purchased (9 + 11) MU 235.27 301.68 1.2.5. For FY 2015-16 the petitioner had proposed the procurement of 32 MW power from MPPMCL @ Rs. 3.48 per unit. Further, MPAKVN has executed a long term power purchase agreement with MPPMCL for a quantum of 40 MW with effect from 1 April, 2015 on 29 th March, 2016. The comparison of the approved and the actual cost of power purchase for FY 2015-16 is given in the table below. Table 4 : Net Power Purchase Cost for FY 2015-16 Approved Actual Sr. No. Particular Units (MU) Cost (Rs. Crores) Units (MU) Cost (Rs. Crores) 1 MPPMCL 218.80 69.14 317.08 109.02 2 Solar Power Purchase 2.35 1.80 - - 3 Non-solar Power Purchase 14.12 6.97 - - 4 Unschedule Interchange - - - - 5 Unschedule Interchange (Credit) - - 15.39 3.31 6 Net Power Purchase ( sum(1 to 4) - 5) 235.27 77.91 301.68 105.71 1.2.6. In the tariff petition for FY 2015-16, MPAKVN had proposed to source the entire requirement of 32 MW from MPPMCL to meet the energy requirement of SEZ. Accordingly, the Hon ble Commission had considered the intra-state transmission charges in accordance with its transmission tariff order for FY 2013-14 to FY 2015-16 dated April 2, 2013 at Rs. 0.1235 Crore per MW per annum for FY 2015-16. The Commission had also considered SLDC charges for FY 2015-16 as admitted in the Commission s Order for FY 2014-15 subject to true up. The comparison of the approved and the actual transmission cost is as given in the table below. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 9

True Up for FY 2015-16 Table 5 : Transmission Charges for FY 2015-16 Rs. Crore Particulars Approved Actual Intra-State Transmission Charges 3.95 4.07 Inter-State Transmission Charges - - SLDC Charges 0.01 0.12 Total Transmission Charges 3.96 4.19 1.2.7. The actual capitalization of MPAKVN during the FY 2015-16 is Rs. 1.96 Crores which is higher than that approved by the Hon ble Commission. The Hon ble Commission had approved capitalization of Rs. 0.93 Crores in the Tariff Order dated 29 th March, 2015. The following table shows the capitalisation for FY 2015-16. Table 6 : Capitalization for FY 2015-16 Rs. Crore Sr. No. Schemes FY 2015-16 (Actual) 1 Furniture and Fixture 0.16 2 Computers - 3 Buildings 1.71 4 Plant and Macinery 0.08 Total 1.96 1.2.8. The Hon ble Commission in its Tariff Order for FY 2015-16 had approved the O&M expenses on a consolidated basis rather than element wise as provided in the MYT Regulations, 2012 considering the agreement executed by MPAKVN for O&M of the SEZ area. The actual O&M expenses incurred are higher than those approved by the Hon ble Commission. The element wise details and justification for the same has been provided in the subsequent chapters of the Petition. The summary of actual O&M expenses as against approved by the Hon ble Commission are given in the table below. Table 7 : O&M Expenses for FY 2015-16 Rs. Crore Particulars Approved Actual Employee Expenses 3.66 Repair & Maintenance Expenses 4.74 4.99 Administrative & General Expenses 0.70 MPERC Fees 0.02 Operation & Maintenance Expenses 4.99 9.12 1.2.9. In FY 2015-16, the amount of depreciation has reduced substantially due to reduction in opening GFA. The rate of depreciation as specified in the MYT Regulations, 2012 have been considered for the computation of depreciation. The actual and approved depreciation for FY 2015-16 is as shown below: Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 10

True Up for FY 2015-16 Table 8 : Net Depreciation for FY 2015-16 Rs. Crore Particulars Approved Actual Depreciation 0.58 0.32 Less: Consumer contribution amortized 0.26 0.03 Net Depreciation 0.32 0.29 1.2.10. MPAKVN does not have actual loans and hence in line with Hon ble Commission s methodology, the weighted average rate of interest of three state Discoms of 9.36% as approved by the Hon ble Commission in its Tariff Order dated 17 th April, 2015 is considered. The opening and closing loan balance details are provided in the subsequent chapters. The repayment of loan is considered equal to the depreciation in line with the regulations. The Interest & Financial charges for FY 2015-16 computed by MPAKVN against approved by the Hon ble Commission is as shown below. Table 9 : Interest & Financial Charges for FY 2015-16 Rs. Crore Particulars Approved Actual Debt Associated with GFA as on the beginning of the year (Net of consumer 3.67 0.20 contribution) Addition to net debt 0.47 1.20 Repayment during the year 0.32 0.29 Total debt associated with GFA at the end of the year 3.82 1.11 Weighted average interest rate of State Discoms 10.20% 9.36% Interest on project loans(normative) 0.38 0.06 1.2.11. The interest on working capital has been calculated on the basis of normative parameters as provided in the MYT Regulations, 2012. The rate of interest considered is the State Bank Advance Rate (SBAR) as on 1 st April 2015 as provided in MYT Regulations, 2012. The interest on working capital for FY 2015-16 incurred by MPAKVN as against that approved by the Hon ble Commission is as shown below: Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 11

True Up for FY 2015-16 Table 10 : Interest on Working Capital for FY 2015-16 Rs. Crore Particulars Approved Actual For Wheeling Activity Inventory for 2 months based on ARR considered at 1% of GFA for previous year 0.02 0.01 1/12th of O&M Expenses 0.42 0.76 2 months of Receivables from Wheeling charges - - Total Working Capital 0.44 0.77 Rate of Interest 13.50% 14.75% Interest on Working Capital 0.06 0.11 For Retail Activity Inventory for 2 months based on ARR for previous year 0.00 0.00 O&M expenses for one month - - 2 months of Receivables of average biling 14.80 16.22 1/12th of Power Purchase expenses 6.49 9.16 Minus: Consumer Security Deposit 11.24 13.43 Total Working Capital -2.93-6.37 Rate of Interest 13.50% 14.75% Interest on Working Capital -0.40-0.94 Total Interest on Working Capital - - 1.2.12. MPAKVN is the SEZ developer who is responsible for providing various services to the business units who setup their factories in the SEZ premises. As a deemed licensee, MPAKVN also supplies power to the occupants of the SEZ. For this purpose, MPAKVN (SEZ Developer) has provided land to power business of MPAKVN for setting up its infrastructure necessary for providing power to the industrial units. Against this land which has been allocated to the power business, MPAKVN is charging lease rent for the area leased out to the power business which is a separate business unit within the company and is a distribution licensee recognised by the Hon ble Commission. It is humbly submitted that lease rent is legitimate expense and should be permitted to be recovered as an expense through the ARR. The lease rent applicable for the land allocated for establishing various assets is shown below in the table: Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 12

True Up for FY 2015-16 Table 11 : Lease Rent for FY 2015-16 Rs. Crore Particulars Area in Sq. Mt. Amount LT Lines 25,000 0.11 11 KV Lines 135,000 0.72 33 KV Lines 207,000 1.15 Substation Phase I 18,580 0.08 Substation Phase II 37,161 0.13 Total 2.19 1.2.13. As per the MYT Regulations, 2012, a return @ 16% on the equity base is considered as reasonable and allowed by the Hon ble Commission. Accordingly, MPAKVN has computed the Return on Equity considering a rate of return at 16%. The return on equity for FY 2015-16 is as shown below: Table 12 : Return on Equity for FY 2015-16 Rs. Crore Particulars Approved Actual Equity associated with GFA as on the beginning of the year 2.54 0.94 30% of addition to net GFA considered as funded through equity 0.20 0.51 Total equity associated with GFA at the end of the year 2.74 1.46 Average equity associated with GFA at the end of the year 2.64 1.20 Return on equity @ 16% 0.42 0.19 1.2.14. The actual other Income of MPAKVN for FY 2015-16 is Rs. 0.13 Crore. Element wise detail of the same is as given in table below: Table 13 : Other Income for FY 2015-16 Rs. Crore Particulars Actual Miscellaneous Income 0.0009 Interest Received on Deposit with MPSEB 0.0483 Shutdown Charges 0.0015 Surcharge Received on Power Bill 0.0693 Power Application Processing Fees 0.0112 Total Other Income 0.1312 1.2.15. Based on above, the Aggregate Revenue Requirement of MPAKVN for FY 2015-16 as against the values approved by the Hon ble Commission is summarised in the table below. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 13

True Up for FY 2015-16 Table 14 : Aggregate Revenue Requirement for FY 2015-16 Rs. Crores FY 2015-16 Sr. No. Particulars Approved Actual 1 Purchase of Power 77.91 105.71 2 Intra-State Transmission (MP Transco) Charges 3.95 4.07 3 SLDC Charges 0.01 0.12 4 Employee Expenses 3.66 5 R&M Expenses 4.99 4.74 6 A&G Expenses 0.70 7 MPERC and MPPMCL Fees & Other 0.01 0.02 8 Depreciation 0.32 0.29 9 Interest & Finance Charges 1.39 1.09 10 Interest on Working Capital - - 11 Lease Rent - 2.19 12 Income Tax 0.14-13 Sub Total (1 to 11) 88.73 122.60 14 Return on Equity 0.42 0.19 15 Total Expenditure (12 + 13) 89.15 122.79 16 Less: Other Income 0.32 0.13 17 Aggregate Revenue Requirement (14-15) 88.83 122.66 1.2.16. This Aggregate Revenue Requirement is compared against the actual Income of Rs. 97.21 Crores under the head Revenue from Sale of Power. Accordingly, total Revenue Gap of MPAVN for FY 2015-16 is estimated at Rs. 25.44 Crores as depicted in the table below: Table 15 : Revenue Gap/ (Surplus) for FY 2015-16 Rs. Crore Sr. No. Particulars FY 2015-16 1 Aggregate Revenue Requirement 122.66 2 Revenue from Sale of Power 97.21 3 Revenue Gap/ (Surplus) (1-2) 25.44 1.2.17. The Hon ble Commission is requested to approve above mentioned revenue gap and allow MPAKVN to recover this gap through the approved retail tariff for FY 2017-18. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 14

True Up for FY 2015-16 2. Introduction 2.1. Preamble 2.1.1. This section presents the background and reasons for filing this Petition. 2.2. Introduction 2.2.1. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd., (hereinafter referred as the MPAKVN or Petitioner or the Company or the Licensee ), is a Company incorporated under the Companies Act, 1956 (which has now been superseded by the Companies Act, 2013) having its registered office at 3/54, Press Complex, Free Press House, Indore. The Petitioner is a deemed distribution licensee under the fifth Proviso to Section 14 of the Electricity Act, 2003. The area of supply of the Petitioner is SEZ Indore (Pithampur) within the State of Madhya Pradesh ( MP ). 2.2.2. The Government of Madhya Pradesh ( GoMP or State Government ), has passed the Special Economic Zone Policy in August 2003. The Indore Special Economic Zone (Special Provisions), Act 2003 was also enacted in the year 2003. This Act has been passed by the Madhya Pradesh Vidhan Sabha on dated 28 th March, 2003 (Madhya Pradesh Act No 23 of 2003) and was enacted to provide for the development, operation, maintenance and administration of Indore Special Economic Zone. 2.2.3. The Madhya Pradesh Electricity Regulatory Commission (hereinafter referred to as MPERC or the Hon ble Commission ), an independent statutory body constituted by Government of Madhya Pradesh vide Gazette Notification dated 20 th August, 1998 under Electricity Regulatory Commission s Act, 1998. Subsequently after the M.P. Vidyut Sudhar Adhiniyam, 2000 came into effect from 03 rd July, 2001, the State Regulatory Commission was deemed to have been constituted under State Act. The Electricity Act 2003 (No. 36 of 2003) enacted by parliament has come into force w.e.f. 10 th June, 2003 and the Commission is now deemed to have been constituted and functioning under the provisions of Electricity Act 2003. 2.2.4. The Hon ble Commission has issued the MPERC (Terms and Conditions for determination of tariff for supply and wheeling of electricity and methods and principles for fixation of charges) Regulations, 2012 (hereinafter referred as MYT Regulations, 2012 ) which were effective from 1 st April, 2013 and up to 31 st March, 2016. 2.2.5. The present application is being submitted by the Petitioner under Section 61 and Section 62 (1) (d) of the Electricity Act 2003 for True up for ARR of FY 2015-16 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 15

True Up for FY 2015-16 under tariff principles laid down in the MYT Regulations, 2012 for approval by the Hon ble Commission. 2.3. Submission to the Hon ble Commission 2.3.1. As per clause 8.4 of MYT Regulations, 2015, last date for submission of petition was 31 st October, 2016 which was extended by the Hon ble Commission till 15 th December, 2016 vide letter no. MPERC/RE/2016/1819 dated 18 th November, 2016 upon receipt of request letter from MPAKVN. 2.3.2. MPAKVN hereby submits the Petition under Section 62 of the Electricity Act, 2003 for True-up of FY 2015-16 as per MYT Regulations, 2012. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 16

True Up for FY 2015-16 3. True Up for FY 2015-16 3.1. Preamble 3.1.1. This section outlines the actual performance of MPAKVN for FY 2015-16. The True Up for FY 2015-16 has been prepared in line with the provisions of the MYT Regulations, 2012. The expenses for FY 2015-16 presented for True-Up are based on the audited accounts for the power business of MPAKVN in compliance with the directive issued by the Hon ble Commission and other principles specified in the MYT Regulations, 2012. The ARR so arrived for the purpose of true up has been compared with the ARR for FY 2015-16 approved by the Hon ble Commission vide Tariff Order dated 23 rd March, 2015. 3.2. Principles for True Up for FY 2015-16 3.2.1. As per MYT Tariff Regulations, 2012, the Hon ble Commission shall undertake the True Up of the licensee for FY 2015-16 based on the comparison of the actual performance of the past year with the approved estimates for such year. 3.2.2. In line with the provisions of MYT Regulations, 2012, MPAKVN has filed this Petition for True Up for the FY 2015-16. Information provided in the True Up for FY 2015-16 is based on the audited actual performance and considering the principles adopted by the Hon ble Commission in its previous Orders. The actual performance has been compared with the ARR approved as per the Order dated 23 rd March, 2015. 3.2.3. Accordingly, the details of the elements of the revised Aggregate Revenue Requirement, the actual revenue earned during the year and the consequent revenue gap for FY 2015-16 is discussed in the subsequent paragraphs of this chapter. 3.3. Category wise Sales 3.3.1. The following table shows the category-wise sales approved by the Hon ble Commission and actually recorded for FY 2015-16. 3.3.2. As can be seen from the table, the sales in the HT category are significantly higher than that approved by the Hon ble Commission in its Order approving the ARR for FY 2015-16. Accordingly, MPAKVN requests the Hon ble Commission to approve the actual sales for FY 2015-16. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 17

True Up for FY 2015-16 Table 16 : Category-wise Sales MU Consumer Category 2015-16 Approved Actual LT Consumer Categories Non Domestic 0.04 0.31 Public Water Works and Street Light 0.41 0.34 Industrial 0.11 0.12 Total LT Sale 0.56 0.77 HT Consumer Categories Industrial 220.12 285.37 Non Industrial - - Total HT Sale 220.12 285.37 Total LT+HT Sale 220.68 286.14 3.4. Distribution Losses 3.4.1. In FY 2015-16, the actual distribution losses were 2.22% as against the approved level of 3.30%. The table below highlights the comparison of actual distribution losses against that approved by the Hon ble Commission vide its Tariff Order. Table 17 : Distribution Losses FY 2015-16 FY 2015-16 Particulars (Approved) (Actual) Distribution Losses 3.30% 2.22% 3.5. Energy Requirement and Energy Balance 3.5.1. The energy balance based on the actual sales during the year and the distribution losses for FY 2015-16 is given below: Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 18

True Up for FY 2015-16 Table 18 : Energy Requirement and Energy Balance Sr. No. Particlars unit 2015-16 Approved Actual 1 Total Units sold to LT category MU 0.56 0.77 2 Total Units sold to HT category MU 220.12 285.37 3 Total Units Sold (1+2) MU 220.68 286.14 4 Distribution Losses % 3.30% 2.22% 5 Distribution Losses MU 7.53 6.49 6 Units Input at AKVN Distribution Boundary (3 + 5) MU 228.21 292.63 7 Transmission Losses % 3.00% 3.00% 8 Transmission Losses MU 7.06 9.05 9 Input at G-T interface (6 + 8) MU 235.27 301.68 10 PGCIL Losses % 0.00% 0.00% 11 PGCIL Losses MU - - 12 Total Units Purchased (9 + 11) MU 235.27 301.68 3.5.2. The net energy purchased by MPAKVN during FY 2015-16 for sale to retail consumers is 301.68 MU as compared to 235.27 MU approved by the Hon ble Commission. 3.5.3. It is submitted that MPAKVN has been able to control the actual distribution losses to levels well below those approved by the Hon ble Commission for the FY 2015-16. However, as the overall retail sales to consumers have increased during the FY 2015-16, the overall requirement for power purchase has increased beyond the approved levels. 3.6. Power Purchase Cost 3.6.1. In its Tariff Petition for FY 2015-16, MPAKVN has submitted that it will solely rely on MPPMCL for all future power procurement. For FY 2015-16, the petitioner had proposed the procurement of 32 MW power from MPPMCL @ Rs. 3.48 per unit. Further, MPAKVN has executed a long term power purchase agreement with MPPMCL for a quantum of 40 MW with effect from 1 April, 2015 on 29 th March, 2016. 3.6.2. The comparison of the approved and the actual cost of power purchase for FY 2015-16 is given in the table below: Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 19

True Up for FY 2015-16 Table 19 : Net Power Purchase Cost for FY 2015-16 Approved Actual Sr. No. Particular Units (MU) Cost (Rs. Crores) Units (MU) Cost (Rs. Crores) 1 MPPMCL 218.80 69.14 317.08 109.02 2 Solar Power Purchase 2.35 1.80 - - 3 Non-solar Power Purchase 14.12 6.97 - - 4 Unschedule Interchange - - - - 5 Unschedule Interchange (Credit) - - 15.39 3.31 6 Net Power Purchase ( sum(1 to 4) - 5) 235.27 77.91 301.68 105.71 3.6.3. The entire power has been sourced from MPPMCL and the actual cost of power purchased charged by MPPMCL is based on the terms of the Power Purchase Agreement executed between MPAKVN and MPPMCL. 3.6.4. The variation in the approved and the actual power purchase expenses is on account of the change in cost of power purchase from MPPMCL and change in quantum of power purchased on account of higher actual sales in FY 2015-16 vis-àvis the sales approved by the Commission in its Order. The Hon ble Commission is requested to approve power purchase cost as actual. 3.7. Transmission Charges 3.7.1. In the tariff petition for FY 2015-16, MPAKVN had proposed to source the entire requirement of 32 MW from MPPMCL to meet the energy requirement of SEZ. Accordingly, the Hon ble Commission had considered the intra-state transmission charges in accordance with its transmission tariff order for FY 2013-14 to FY 2015-16 dated 2 nd April, 2013 at Rs. 0.1235 Crore per MW per annum for FY 2015-16. The Commission had also approved SLDC charges for FY 2015-16 as admitted in the Commission s Order for FY 2014-15 subject to true up. 3.7.2. The comparison of the approved and the actual transmission cost is as given in the table below: Table 20 : Transmission Charges for FY 2015-16 Rs. Crore Particulars Approved Actual Intra-State Transmission Charges 3.95 4.07 Inter-State Transmission Charges - - SLDC Charges 0.01 0.12 Total Transmission Charges 3.96 4.19 3.7.3. Actual SLDC charges comprise of power application charges and power scheduling & operation charges which are to be paid based on actual operation requirement. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 20

True Up for FY 2015-16 It is not possible to projection power application charges and power scheduling & operation charges. Hence, SLDC charges are higher in comparison to approved in Tariff Order for FY 2015-16 dated 23 rd March, 2015. 3.7.4. MPAKVN requests the Commission to approve the actual intra-state transmission charges & SLDC charges for FY 2015-16. 3.8. Capitalisation 3.8.1. The actual capitalization of MPAKVN during the FY 2015-16 is Rs. 1.96 Crores which is higher than that approved by the Hon ble Commission. The Hon ble Commission had approved capitalization of Rs. 0.93 Crores in the Tariff Order dated 29 th March, 2015. 3.8.2. The asset head wise capitalization in FY 2015-16 against that approved by the Hon ble Commission is as shown below. Table 21 : Capitalization for FY 2015-16 Rs. Crore Sr. No. Schemes FY 2015-16 (Actual) 1 Furniture and Fixture 0.16 2 Computers - 3 Buildings 1.71 4 Plant and Macinery 0.08 Total 1.96 3.9. Funding of Capital Expenditure 3.9.1. The funding of above mentioned Capital Expenditure is done through various sources which are mainly categorised under four headings namely: (i) Consumer Contribution; (ii) Grants; (iii) Equity; and (iv) Debt. The detailed breakup of funding of capitalisation which took place during FY 2015-16 is mentioned in the table below. Table 22 : Funding of Capitalisation Rs. Crore Particulars FY 2015-16 Approved Actual Total Capitalization 0.93 1.96 Consumer Contribution 0.26 0.24 Grants - - Balance Capitalisation for the Year 0.67 1.72 Debt 0.47 1.20 Equity 0.20 0.51 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 21

True Up for FY 2015-16 3.9.2. It is submitted that the entire funding of the assets (other than those funded through consumer contribution and grants) capitalised during FY 2015-16 is through equity. However, in view of the provisions of the MYT Regulation, 2012, the quantum of equity has been restricted at 30% of the total funding requirement and the remaining quantum is treated as normative debt. This is in line with the provisions of the MYT Regulations, 2012 and also in line with the approach adopted by the Hon ble Commission in the past. 3.9.3. The details pertaining to the interest charges on the normative debt funding and the Return on the Equity has been discussed in para 3.14 and 3.17 respectively of the Petition. 3.10. Changes in the value of Gross Fixed Assets and consequent changes in the Opening Consumer Contribution, Debt and Equity for FY 2015-16 3.10.1. In case of MPAKVN, upto FY 2012-13 all the assets belonging to the SEZ area were transferred by Journal Voucher entry and disclosed in balance sheet of the sister company M/s SEZ (Indore) Limited. However, from FY 2013-14 this process has been stopped and all the assets have been transferred back to the balance sheet of MPAKVN. Actually, these all assets were belonging to MPAKVN only. Accordingly, in FY 2013-14, the assets were transferred from SEZ (Indore) Ltd. to MPAKVN at Written Down Value (WDV) computed as per the provisions of the Income Tax Act in place of book value. Hence, the value of the gross fixed asset was reduced in FY 2013-14 by the amount equivalent to the difference between the book value and the WDV as calculated as per Income Tax Act. 3.10.2. While, the value of the Gross fixed asset which is partly created from consumer contribution was reduced as mentioned previously, the total cumulative value of the consumer contribution in the balance sheet remained same as earlier in annual accounts. On account of this, while the value of the gross fixed assets was reduced from Rs. 12.01 Crore to Rs. 5.36 Crore during FY 2013-14, the consumer contribution increased from Rs. 4.04 Crore to Rs. 4.44 Crore. 3.10.3. In normal course of action, the detail of the consumer contribution received from consumers is recorded in the balance sheet and the same is considered for the purpose of tariff determination. However, considering the foregoing discussion regarding the accounting adjustments undertaken in FY 2013-14 and to ensure that MPAKVN is not unnecessarily burdened, it is proposed to proportionately reduce the consumer contribution being considered for the purpose of tariff determination process. This will ensure that MPAKVN will continue to recover adequate interest costs and return on equity during the life of the asset which has Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 22

True Up for FY 2015-16 been partly funded through its own funds. 3.10.4. The value of the opening consumer contribution for FY 2015-16 computed in line with the above discussion is shown as under: Table 23 : Calculation of Opening Consumer Contribution for FY 2015-16 Particular Amount (Rs. Crore) GFA as on 1st april 2013 12.11 consumer contribution as on 1st April 2013 4.04 Addition to GFA 0.03 Addition to consumer contribution 0.40 Reduction in GFA due to asset transfer 6.77 Proportionate reduction in consumer contribution considered due to asset transfer 2.48 Closing GFA for FY 2013-14 5.36 Closing consumer contribution for FY 2013-14 1.96 Addition during FY 2014-15 0.57 Closing consumer contribution for FY 2014-15 2.53 Opening consumer contribution for FY 2015-16 2.53 3.10.5. It is prayed to the Hon ble Commission to consider opening consumer contribution of Rs. 2.53 for FY 2015-16 for the purpose of determining the cost elements forming part of the ARR for MPAKVN. 3.10.6. Similarly, the opening net debt and equity considered for the computation of the interest on loans and return on equity for FY 2015-16 is calculated as under. Table 24 : Calculation of Opening equity & net debt for FY 2015-16 Particulars FY 2015-16 (Opening) Rs. Crore Total GFA 5.68 Consumer Contribution 2.53 Grants - Balance Capitalisation for the Year 3.15 Gross Debt 2.20 Equity 0.94 Gross Debt 2.20 Acccumulated depreciation - considered as repayment 2.00 Net Debt 0.20 3.10.7. It is prayed to the Hon ble Commission to consider opening balance of debt of Rs. 0.20 Crore and opening balance of equity of Rs. 0.94 Crore for FY 2015-16 for the purpose of determining the cost elements forming part of the ARR for MPAKVN. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 23

True Up for FY 2015-16 3.11. Aggregate Revenue Requirements for FY 2015-16 3.11.1. The ARR of MPAKVN for the FY 2015-16 has been determined in accordance with the provisions of the MYT Regulations, 2012 and also considers the cost elements (both equity and normative debt components) emanating from the Capital Cost of the Capitalised Expenditure considered in FY 2015-16. 3.11.2. The net ARR of MPAKVN has been computed after netting off non-tariff income for the gross ARR mentioned previously. 3.11.3. The subsequent paragraphs outline the details of all the elements of the ARR of MPAKVN. 3.12. Operation & Maintenance Expenses 3.12.1. Operations and Maintenance (O&M) Expenses of MPAKVN consists of the following elements: Employee Expenses Repairs and Maintenance Costs Administrative and General Expenses MPERC Expenses Employee Cost 3.12.2. Employees of various department of MPAKVN like planning, commercial, technical, legal, financial & accounts, administrative etc. are involved in activity of power business. Actual employee expense for FY 2015-16 is Rs. 3.66 Crore which also includes DA and terminal benefits. The summary of the actual employee expenses for FY 2015-16 is given in the table below: Table 25 : Employee Cost for FY 2015-16 Rs. Crore Particulars Actual Employee Cost excluding arrears, DA, terminal benefits and incentives 1.33 Arrears - DA 1.10 Terminal Benefits 1.23 Incentive - Total Employee Cost 3.66 Repair & Maintenance Cost 3.12.3. MPAKVN has entered into an agreement with MPPKVVCL, Indore dated 26 th March Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 24

True Up for FY 2015-16 2013 to carry out all R&M Expenses of its Electrical Network situated in the Special Economic Zone Phase I and Phase II in Pithampur area of the Dhar District and also to provide consultancy services in various techno-commercial matters relating to the distribution and supply of electricity in the Special Economic Zone area for an initial period of 3 years from the effective date. Based on this agreement, the R&M expenditure for FY 2015-16 is as under: Table 26 : Repair & Maintenance Cost for FY 2015-16 Rs. Crore Particulars Actual R&M Expenses 4.74 3.12.4. It is submitted that the Hon ble Commission had not considered this expenditure while approving the O&M expenses for FY 2015-16. 3.12.5. In view of the same, the Hon ble Commission is requested to consider these as genuine R&M expenses and approve the same. Administration & General Expenses 3.12.6. The actual A&G expense for FY 2015-16 is Rs. 0.70 Crores which is lower than normative A&G expenses approved by the Hon ble Commission in MYT Regulations, 2012. Actual A&G expense of MPAKVN are given in the table below: Table 27 : Administration & General Expenses for FY 2015-16 Rs. Crore Particulars Actual A&G Expenses 0.70 MPERC Expenses 3.12.7. The actual MPERC expense for FY 2015-16 is Rs. 0.02 Crores. Actual MPERC expenses of MPAKVN are given in the table below: Table 28 : MPERC Expenses for FY 2015-16 Rs. Crore Particulars Actual MPERC Expenses 0.02 Consolidated O&M Expenses 3.12.8. The Hon ble Commission in its Tariff Order for FY 2015-16 had approved the O&M expenses on a consolidated basis rather than element wise as provided in the MYT Regulations, 2012 considering the agreement executed by MPAKVN for O&M of the Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 25

True Up for FY 2015-16 SEZ area. 3.12.9. The Hon ble Commission in its Tariff Order for FY 2015-16 dated 23 rd March, 2015, approved only additional O&M sought by MPAKVN which was actually outsourcing of R&M activities to MPPKVVCL amounting to Rs. 4.99 Crore ignoring other expenses like employee cost, A&G cost and MPERC expenses sought by MPAKVN. MPAKVN requires to incur employees cost as well as A&G expenses over and above expenses on R&M activity which is outsourced for running their power business. In view of the same, the Hon ble Commission is requested to approve actual O&M expenses incurred by MPAKVN. 3.12.10. The summary of actual O&M expenses as against approved by the Hon ble Commission are given in the table below: Table 29 : O&M Expenses for FY 2015-16 Rs. Crore Particulars Approved Actual Employee Expenses 3.66 Repair & Maintenance Expenses 4.74 4.99 Administrative & General Expenses 0.70 MPERC Fees 0.02 Operation & Maintenance Expenses 4.99 9.12 3.12.11. The Hon ble Commission is requested to approve actual O&M expenses incurred by MPAKVN for FY 2015-16. 3.13. Depreciation 3.13.1. In FY 2015-16, the amount of depreciation has reduced substantially due to reduction in opening GFA. The rate of depreciation as specified in the MYT Regulations, 2012 have been considered for the computation of depreciation. The actual and approved depreciation for FY 2015-16 is as shown below: Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 26

True Up for FY 2015-16 Table 30 : Depreciation for FY 2015-16 Rs. Crore Particulars Approved Actual Opening Gross Fixed Asset 13.01 5.68 Addition during the year 0.93 1.96 Deduction 0.00 0.00 Closing Gross Fixed Asset 13.94 7.64 Depreciation 0.58 0.32 Depreciation Rate 4.30% 4.84% 3.13.2. MPAKVN has reduced the amortization of the assets capitalized from the consumer contribution & grant. Accordingly, net depreciation on GFA for FY 2015-16 after reducing amortization on consumer contribution is shown in the table below: Table 31 : Net Depreciation for FY 2015-16 Rs. Crore Particulars Approved Actual Depreciation 0.58 0.32 Less: Consumer contribution amortized 0.26 0.03 Net Depreciation 0.32 0.29 3.13.3. The Hon ble Commission is requested to approve depreciation expenses incurred by MPAKVN for FY 2015-16 3.14. Interest & Financial Charges 3.14.1. For assessing interest charges on loans in FY 2015-16, the opening balance of Loans has been considered as discussed in para 3.10 of the Petition. The loan addition in FY 2015-16 is considered at Rs. 1.20 Crores based on the actual capitalisation during the year as discussed in paragraph 3.8 above. 3.14.2. In line with the approach adopted by the Hon ble Commission in its Tariff Order dated 23 rd March, 2015 and as prescribed by MYT Regulations, 2012 repayment during the year has been considered equal to depreciation charged for the financial year. 3.14.3. MPAKVN does not have actual loans and hence in line with Hon ble Commission s methodology, the weighted average rate of interest of three state Discoms of 9.36% as approved by the Hon ble Commission in its Tariff Order dated 17 th April, 2015 is considered. 3.14.4. The Interest & Financial charges for FY 2015-16 computed by MPAKVN against approved by the Hon ble Commission is as shown below: Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 27

True Up for FY 2015-16 Table 32 : Interest & Financial Charges for FY 2015-16 Rs. Crore Particulars Approved Actual Debt Associated with GFA as on the beginning of the year (Net of consumer 3.67 0.20 contribution) Addition to net debt 0.47 1.20 Repayment during the year 0.32 0.29 Total debt associated with GFA at the end of the year 3.82 1.11 Weighted average interest rate of State Discoms 10.20% 9.36% Interest on project loans(normative) 0.38 0.06 3.14.5. The interest paid on consumer security deposit in line with the provisions of the MYT Regulations, 2012 is given in table below: Table 33 : Interest on Consumer Security Deposit for FY 2015-16 Rs. Crore Particulars Approved Actual Consumer Security Deposit 11.40 12.77 Interest amount claimed 1.00 1.03 3.14.6. Based on the above, the Hon ble Commission is requested to approve total interest & finance charges of Rs. 1.09 Crore for FY 2015-16. 3.15. Interest on Working Capital 3.15.1. The interest on working capital has been calculated on the basis of normative parameters as provided in the MYT Regulations, 2012. 3.15.2. The rate of interest considered is the State Bank Advance Rate (SBAR) as on 1 st April 2015 as provided in MYT Regulations, 2012. The interest on working capital for FY 2015-16 incurred by MPAKVN as against that approved by the Hon ble Commission is as shown below: Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 28

True Up for FY 2015-16 Table 34 : Interest on Working Capital for FY 2015-16 Rs. Crore Particulars Approved Actual For Wheeling Activity Inventory for 2 months based on ARR considered at 1% of GFA for previous year 0.02 0.01 1/12th of O&M Expenses 0.42 0.76 2 months of Receivables from Wheeling charges - - Total Working Capital 0.44 0.77 Rate of Interest 13.50% 14.75% Interest on Working Capital 0.06 0.11 For Retail Activity Inventory for 2 months based on ARR for previous year 0.00 0.00 O&M expenses for one month - - 2 months of Receivables of average biling 14.80 16.22 1/12th of Power Purchase expenses 6.49 9.16 Minus: Consumer Security Deposit 11.24 13.43 Total Working Capital -2.93-6.37 Rate of Interest 13.50% 14.75% Interest on Working Capital -0.40-0.94 Total Interest on Working Capital - - 3.16. Lease Rent 3.16.1. MPAKVN is the SEZ developer who is responsible for providing various services to the business units who setup their factories in the SEZ premises. As a deemed licensee, MPAKVN also supplies power to the occupants of the SEZ. For this purpose, MPAKVN (SEZ Developer) has provided land to power business of MPAKVN for setting up its infrastructure necessary for providing power to the industrial units. Against this land which has been allocated to the power business, MPAKVN is charging lease rent for the area allocated to the power business which is a separate business unit within the company and is a distribution licensee recognised by the Hon ble Commission. The lease rent applicable for the land allocated for establishing various assets is shown below in the table: Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 29

True Up for FY 2015-16 Table 35 : Lease Rent for FY 2015-16 Rs. Crore Particulars Area in Sq. Mt. Amount LT Lines 25,000 0.11 11 KV Lines 135,000 0.72 33 KV Lines 207,000 1.15 Substation Phase I 18,580 0.08 Substation Phase II 37,161 0.13 Total 2.19 3.16.2. It is humbly submitted that lease rent is legitimate expense and should be permitted to be recovered as an expense through the ARR. The lease rent is being charged by MPAKVN as it is an opportunity cost lost for MPAKVN SEZ business as they could have leased out this land to some other industry and received lease rent against it. 3.16.3. Further, as a distribution licensee, in normal course of action MPAKVN would have purchased this land for establishment of its power distribution infrastructure. The cost incurred for purchase of land gets capitalized and the Hon ble Commission allows depreciation, interest on loan and return on equity chargeable on account of this cost as part of ARR. Accordingly, this expenditure, in the form of either lease rent or depreciation, interest on loan and return on equity chargeable on the capital cost incurred by MPAKVN, is inevitable. 3.16.4. MPAKVN has sought lease rent in its review petition 86 of 2012 and the Hon ble Commission in its Order dated 21 st December, 2012 has disallowed lease rent sighting reason of non-payment. The relevant part of the same is reproduced here below for reference. ii. Land Premium and Lease rent charges:. The Commission considered the matter and observed that in the instant case since no actual payments are being made to the SEZ on account of land premium or lease rent such notional expense cannot be charged to the consumers. The claim made by the petitioner in this regard is not sustainable. 3.16.5. MPAKVN has now made all past payments towards lease rent and hence the Hon ble Commission is requested to approve lease rent. 3.16.6. There have been instances in other states wherein the Commission has allowed this expenditure pertaining to lease rental as a pass through in the tariff over and above the other expenses. 3.16.7. A precedence in this matter can be seen in case of approval of the Truing-up of FY Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 30

True Up for FY 2015-16 2013-14 and FY 2014-15, Provisional Truing-up of FY 2015-16, and Projection of ARR for the 3rd Control Period FY 2016-17 to FY 2019-20 for the transmission licensee MEGPTCL in Maharashtra by the Hon ble MERC in Case no. 50 of 2016. In the said case, the land for Akola-II Sub-station was initially to be purchased and handed over by MSETCL to MEGPTCL, however, later on based on management decision, the land was later leased out to MEGPTCL. Accordingly, while the total capital cost of land in the overall capital cost was reduced, the corresponding increase in the lease rental for the same was factored as additional Operation and Maintenance (O&M) expenses in the ARR for the Control Period. Considering the facts of the case, the Hon ble Commission had approved the least rent for Akola II Sub-station over and above the normative O&M expenses of MEGPTCL prescribed in the MYT Regulations. 3.16.8. In view of the above, the Hon ble Commission is humbly requested to allow lease rent charged to MPAKVN to the power business as a legitimate expenditure as part of the ARR. 3.17. Return on equity 3.17.1. As per the MYT Regulations, 2012, a return @ 16% on the equity base is considered as reasonable and allowed by the Hon ble Commission. Accordingly, MPAKVN has computed the Return on Equity considering a rate of return at 16%. 3.17.2. The Opening Equity for FY 2015-16 is considered as discussed in para 3.9 of the Petition. Accordingly, the return on equity for FY 2015-16 is as shown below: Table 36 : Return on Equity for FY 2015-16 Rs. Crore Particulars Approved Actual Equity associated with GFA as on the beginning of the year 2.54 0.94 30% of addition to net GFA considered as funded through equity 0.20 0.51 Total equity associated with GFA at the end of the year 2.74 1.46 Average equity associated with GFA at the end of the year 2.64 1.20 Return on equity @ 16% 0.42 0.19 3.18. Other Income 3.18.1. The actual other Income of MPAKVN for FY 2015-16 is Rs. 0.13 Crore. Element wise detail of the same is as given in table below: Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 31

True Up for FY 2015-16 Table 37 : Other Income for FY 2015-16 Rs. Crore Particulars Actual Miscellaneous Income 0.0009 Interest Received on Deposit with MPSEB 0.0483 Shutdown Charges 0.0015 Surcharge Received on Power Bill 0.0693 Power Application Processing Fees 0.0112 Total Other Income 0.1312 3.19. Aggregate Revenue Requirement for FY 2015-16 3.19.1. Based on above, the Aggregate Revenue Requirement of MPAKVN for FY 2015-16 as against the values approved by the Hon ble Commission is summarised in the table below. Table 38 : Aggregate Revenue Requirement for FY 2015-16 Rs. Crores FY 2015-16 Sr. No. Particulars Approved Actual 1 Purchase of Power 77.91 105.71 2 Intra-State Transmission (MP Transco) Charges 3.95 4.07 3 SLDC Charges 0.01 0.12 4 Employee Expenses 3.66 5 R&M Expenses 4.99 4.74 6 A&G Expenses 0.70 7 MPERC and MPPMCL Fees & Other 0.01 0.02 8 Depreciation 0.32 0.29 9 Interest & Finance Charges 1.39 1.09 10 Interest on Working Capital - - 11 Lease Rent - 2.19 12 Income Tax 0.14-13 Sub Total (1 to 11) 88.73 122.60 14 Return on Equity 0.42 0.19 15 Total Expenditure (12 + 13) 89.15 122.79 16 Less: Other Income 0.32 0.13 17 Aggregate Revenue Requirement (14-15) 88.83 122.66 3.20. Revenue for FY 2015-16 3.20.1. During the FY 2015-16, MPAKVN s actual revenue from sale of power was Rs. 97.21 Crores. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 32

True Up for FY 2015-16 3.21. Revenue Gap / (Surplus) for FY 2015-16 3.21.1. The Aggregate Revenue Requirement for FY 2015-16 works out to Rs. 122.66 Crore and the revenue from sale of power recovered during the same period is Rs. 97.21 Crore. Accordingly, the revenue gap for FY 2015-16 works out to Rs 25.44 Crore as given in the Table below: Table 39 : Revenue Gap/ (Surplus) for FY 2015-16 Rs. Crore Sr. No. Particulars FY 2015-16 1 Aggregate Revenue Requirement 122.66 2 Revenue from Sale of Power 97.21 3 Revenue Gap/ (Surplus) (1-2) 25.44 3.21.2. The Hon ble Commission is requested to approve above mentioned revenue gap and allow MPAKVN to recover this gap through the approved retail tariff for FY 2017-18. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 33

True Up for FY 2015-16 4. Prayer MPAKVN Indore Ltd. respectfully prays to the Hon ble Commission as under: 1. To admit this petition seeking True up for FY 2015-16. 2. To approve Aggregate Revenue Requirement (ARR) and Revenue Gap for FY 2015-16 as per the provisions of the MYT Regulations, 2012. 3. To allow recovery of the Revenue Gap of FY 2015-16 through the approved retail tariff for FY 2017-18. 4. To allow recovery of lease rent charges for the use of land for the substation and line and premium for the substation land. 5. To grant any other relief as the Hon ble Commission may consider appropriate. 6. To condone any inadvertent omissions, errors, short comings and permit the Petitioner to add/change/modify/alter this filing and make further submissions as may be required at a future date; and 7. To pass any other Order as the Hon ble Commission may deem fit and appropriate under the circumstances of the case and in the interest of justice. Place: Indore Date: 18 th January, 2017 Signature of the Petitioner Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 34

True Up for FY 2015-16 Annexure 1: Tariff Filing Formats Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. 35

True-up Petition FY 2012-13 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) True-up pertaining to Financial Year: 2015-16 INDEX OF FORMATS FOR FILING OF TRUE-UP INFORMATION FOR DISTRIBUTION AND RETAIL SUPPLY LICENSEES Summary Statements 1 Sheet TUD S1 Profit & Loss Account 2 Sheet TUD S2 Balance Sheet 3 Sheet TUD A1 Aggregate Expenditure during financial year Schedules 4 Sheet Schedule TUD 1 Actual Revenue from sale of power 5 Sheet Schedule TUD 1a Revenue from sale of power - LT 6 Sheet Schedule TUD 1b Revenue from sale of power - HT 7 Sheet Schedule TUD 1c Income from Wheeling Charges 8 Sheet Schedule TUD 2 Other income 9 Sheet Schedule TUD 3 Expenses and Income from Business other than Licensed business 10 Sheet Schedule TUD 4 Power Purchase cost 11 Sheet Schedule TUD 4a Energy Balance 12 Sheet Schedule TUD 5 Inter-State Transmission Charges 13 Sheet Schedule TUD 6A Intra State Transmission Charges and Wheeling charges paid to any other Discom 14 Sheet Schedule TUD 6B SLDC Charges 15 Sheet Schedule TUD 7 R&M Expenses 16 Sheet Schedule TUD 8a Details of Employees 17 Sheet Schedule TUD 8b Employees' Cost & Provisions 18 Sheet Schedule TUD 9 Administration & General Expenses 19 Sheet Schedule TUD 10 Depreciation 20 Sheet Schedule TUD 10a Gross Fixed Assets 21 Sheet Schedule TUD 10b Capital Works in Progress - Summary Statement 22 Sheet Schedule TUD 10c Details of Capitalisation during financial year 23 Sheet Schedule TUD 11 Interest & Finance charges on Project and Working Capital Loans 24 Sheet Schedule TUD 11a Interest on Consumer Security Deposit 25 Sheet Schedule TUD 12 Bad & doubtful debts 26 Sheet Schedule TUD 13 Other items of expenditure 27 Sheet Schedule TUD 14 Share Capital and Reserves & Surplus 28 Sheet Schedule TUD 15 Current Assets and Liabilities Performance formats 29 Sheet TUD F1 Normative Working Capital Requirements 30 Sheet TUD F2 Normative O&M expenses 31 Sheet TUD P1 T&D Losses in LT and HT System 32 Sheet TUD P2 Details of physical characterisitics of the network 33 Sheet TUD P3 Sales, Consumers and Connected Load - LT consumers 34 Sheet TUD P4 Sales, Consumers and Connected Load- HT consumers 35 Sheet RoE Retrun on Equity Instructions for the Utility: 1 Electronic copy in the form of CD/ Floppy Disc shall also be furnished 2 These formats are indicative in nature and the utility may align the line items to its chart of accounts Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 36

True-up Petition FY 2012-13 Sr. No. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Profit & Loss Account Form No: TUD S1 True-up pertaining to Financial Year: 2015-16 All figures in Rs. Crs. Particulars Schedule No. Actual As Per Audited Accounts Actual Claimed in True-Up A Revenue 1 Revenue from sale of power 97.21 97.21 2 Other income 2.67 0.13 3 Income from other business allocated to Licensed business 4 Revenue subsidies and grants - 5 Prior Period Adjustments (Net) - TOTAL REVENUE OR INCOME 99.88 97.35 B Expenditure 1 Purchase of Power from MP Genco and other sources 105.71 105.71 2 Inter-State Transmission charges 3 Intra-State Transmission (MP Transco) Charges 4.07 4.07 4 SLDC Charges 0.12 0.12 5 Repairs and Maintenance 4.74 4.74 6 Employee costs 3.66 3.66 7 Administration and General expenses** 0.72 0.72 8 Lease Rental 2.19 2.19 9 Rebate on Power sale 0.12 10 Less: Expenses Capitalized - - Sub Total 121.32 121.20 C PBDIT (21.45) (23.86) D Depreciation and Related Debits 0.29 0.29 E PBIT (21.74) (24.15) 1 Interest & Finance Charges 1.03 1.09 2 Less: Interest Capitalized - - F Total Interest and Finance Charges 1.03 1.09 G TOTAL EXPENDITURE 122.65 122.59 H Profit/Loss before Tax (22.77) (25.24) I Income Tax J Profit/Loss after Tax (22.77) (25.24) K RoE - 0.19 M Profit/Loss after Tax and RoE (22.77) (25.44) Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 37

True-up Petition FY 2012-13 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Balance Sheet Form No: TUD S2 True-up pertaining to Financial Year: 2015-16 All figures in Rs. Crs. Sr. Ref. Form Actual As Per Particulars No. No. Audited Accounts I. EQUITY AND LIABILITIES 1 Shareholders funds (a) Share capital 40.64 (b) Reserves and surplus (60.46) (c) Money received for Capital Work in Progress 9.77 2 Share application money pending allotment E) Non-current liabilities (a) Capital contributions from consumers 5.22 (b) Consumer's Security Deposits 13.43 (c) (d) 4 Current liabilities (a) Short-term borrowings - (b) Trade payables - (c) Other current liabilities 15.64 (d) Lease Rental Payable 10.23 TOTAL 34.47 II. ASSETS Non-current assets 1 (a) Fixed assets (i) Tangible assets(net GFA) 5.31 (ii) Intangible assets (iii) Capital work-in-progress 19.30 (iv) Intangible assets under development (b) Non-current investments (c) Deferred tax assets (net) (d) Long-term loans and advances (e) Other non-current assets 2 Current assets (a) Current investments (b) Inventories (c) Trade receivables (d) Cash and cash equivalents 0.24 (e) Short-term loans and advances (f) Other current assets 9.62 TOTAL 34.47 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 38

True-up Petition FY 2012-13 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Aggregate Expenditure During Financial Year Form No: TUD A1 True-up pertaining to Financial Year: 2015-16 All figures in Rs. Crs. Sr. As Approved in Particulars Schedule No. No. Tariff Order (A) Actual (B) Variance (B-A) A Power Purchase or Energy Available (MU) 235.24 301.68 66.44 B Sale of Power (MU) 220.68 286.14 65.46 C Loss % 6.19% 5.15% (0.01) D Expenditure 1 Cost of power purchase, including T&D losses 77.91 105.71 27.80 2 Inter-State Transmission charges 3 Intra-state Transmission (MP Transco) charges 3.95 4.07 0.12 4 Wheeling charges paid to other distribution licensee 5 SLDC fees and charges 0.01 0.12 0.11 6 Repairs and Maintenance expenses 4.74 7 Employee costs 5.00 3.66 (4.11) 8 Administration and General expenses 0.72 9 Depreciation 0.32 0.29 (0.03) 10 Interest & Finance Charges on project loans 0.39 0.06 (0.33) 11 Interest and Finance Charges on working capital loans 0.00 0.00-12 Interest paid on Consumer Security Deposit 1.00 1.03 0.03 13 Bad and Doubtful debts 0.00 0.00-14 Income Tax 0.14 0.00 (0.14) 15 Return on Equity 0.42 0.19 (0.23) 16 Lease Rent 0.00 2.19 2.19 17 Total Expenditure 89.15 122.79 25.41 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 39

True-up Petition FY 2012-13 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Summary of Actual Revenue from Sale of Power 2015-16 Schedule No. TUD 1 All Figures in Rs. Crore As per Tariff Order (A) Actuals (B) Variance (B-A) Particulars Revenues Revenues Revenues Sales (MU) Sales (MU) Sales (MU) (Rs. Crs.) (Rs. Crs.) (Rs. Crs.) LOW TENSION 0.56-0.77 0.36 0.21 - LV 1: DOMESTIC - - - - LV 2: NON-DOMESTIC 0.04 0.31 0.15 0.27 LV 3: PUBLIC WATER WORKS AND STREET LIGHTS 0.41 0.34 0.15 (0.07) LV 4: LT INDUSTRY 0.11 0.12 0.06 0.01 HIGH TENSION 220.12 285.37 96.86 65.25 HV1: INDUSTRIAL AND NON-INDUSTRIAL 220.12 285.37 96.86 65.25 HV 2: PUBLIC WATER WORKS - - - - - HV 3: SYNCHRONIZATION AND START UP POWER FOR GENERATORS CONNECTED TO THE GRID - - - - - GRAND TOTAL HT + LT 220.68 88.83 286.14 97.21 65.46 8.38 GRAND TOTAL HT + LT as per R-15 (Including ED, Cess, Meter Rent, Surcharge, Misc Charges etc) 286.14 97.21 GRAND TOTAL HT + LT as per Audited Accounts Subsidy as per audited Accounts 88.83 97.21 8.38 Total Sales of power including subsidy 88.83 97.21 8.38 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 40

True-up Petition FY 2012-13 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Revenues from sale of power - LT True-up pertaining to Financial Year: 2015-16 As approved in Tariff Order Actual Category Revenue from fixed charges (Cr) Revenue from variable charges (Cr) Total actual revenues (Cr) Revenue from fixed charges (Cr) Revenue from variable charges (Cr) Total actual revenues (Cr) Revenue from fixed charges (Cr) Variance (Actual-T.O.) Revenue from variable charges (Cr) Schedule No: TUD 1a Total actual revenues (Cr) L T CONSUMERS LV1: Domestic Total LV1 Domestic LV2: Non - Domestic Sanction Load Basis Not Indicated Not Indicated Not Indicated 0.01 0.14 0.15 N.A. N.A. N.A. Demand Based Not Indicated Not Indicated Not Indicated - - - N.A. N.A. N.A. Sub total Not Indicated Not Indicated Not Indicated 0.01 0.14 0.15 N.A. N.A. N.A. X-ray Plant (1 phase) Not Indicated Not Indicated Not Indicated - - - N.A. N.A. N.A. X-ray Plant (3 phase) Not Indicated Not Indicated Not Indicated - - - N.A. N.A. N.A. Dental X-Ray Not Indicated Not Indicated Not Indicated - - - N.A. N.A. N.A. Sub total Not Indicated Not Indicated Not Indicated - - - N.A. N.A. N.A. Total LV2: Non - Domestic Not Indicated Not Indicated - 0.01 0.14 0.15 N.A N.A N.A LV 3: Public Water Works and Street Lights LV3.1: Public Water Works:--- Public Water Works Not Indicated Not Indicated Not Indicated - 0.05 0.05 N.A. N.A. N.A. Sub-Total Public Water Works Not Indicated Not Indicated Not Indicated - 0.05 0.05 N.A. N.A. N.A. LV3.2: Street Lights :--- Street Light Not Indicated Not Indicated Not Indicated - 0.10 0.10 N.A. N.A. N.A. Sub-Total Street Lights Not Indicated Not Indicated Not Indicated - 0.10 0.10 N.A. N.A. N.A. Total - LV 3: PWW and Street Lights Not Indicated Not Indicated - - 0.15 0.15 N.A N.A N.A LV4 LT Industry Non-Seasonal consumers:--- Upto 25 HP Not Indicated Not Indicated Not Indicated 0.01 0.05 0.06 N.A. N.A. N.A. 25 to 100 HP Not Indicated Not Indicated Not Indicated - - - N.A. N.A. N.A. Above 100 HP Not Indicated Not Indicated Not Indicated - - - N.A. N.A. N.A. Sub-total Not Indicated Not Indicated Not Indicated 0.01 0.05 0.06 N.A. N.A. N.A. Temporary Not Indicated Not Indicated Not Indicated - - - N.A. N.A. N.A. Sub-Total(Non-seasonal) Not Indicated Not Indicated Not Indicated 0.01 0.05 0.06 N.A. N.A. N.A. Total LV 4 LT Industrial Not Indicated Not Indicated - 0.01 0.05 0.06 N.A. N.A. N.A. TOTAL LT Not Indicated Not Indicated 0.02 0.34 0.36 N.A. N.A. N.A. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 41

True-up Petition FY 2012-13 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Revenues from sale of power - HT True-up pertaining to Financial Year: 2015-16 As approved in Tariff Order Actual Category Revenue from fixed charges (Cr) Revenue from variable charges (Cr) Total actual Revenue from revenues (Cr) fixed charges (Cr) Revenue from variable charges (Cr) Total actual Revenue from revenues (Cr) fixed charges (Cr) Variance (Actual-T.O.) Revenue from variable charges (Cr) Form No: TUD 1b Total actual revenues (Cr) HT CONSUMERS Industrial 11 KV Not Indicated Not Indicated Not Indicated 0.05 0.12 0.17 N.A. N.A. N.A. Industrial 33 KV Not Indicated Not Indicated Not Indicated 12.10 84.59 96.69 N.A. N.A. N.A. TOTAL HV1: INDUSTRIAL AND NON-INDUSTRIAL Not Indicated Not Indicated Not Indicated 12.15 84.71 96.86 N.A. N.A. N.A. 33 KV Not Indicated Not Indicated Not Indicated - - - N.A. N.A. N.A. 11 KV Not Indicated Not Indicated Not Indicated - - - N.A. N.A. N.A. Total HV 2: PUBLIC WATER WORKS Not Indicated Not Indicated Not Indicated 0.00 0.00 0.00 N.A. N.A. N.A. Synchronization and start up power for generators connected to Not Indicated Not Indicated Not Indicated the grid - - - N.A. N.A. N.A. Total HV 3: SYNCHRONIZATION AND START UP POWER FOR GENERATORS CONNECTED TO THE GRID Not Indicated Not Indicated Not Indicated 0.00 0.00 0.00 N.A. N.A. N.A. TOTAL HT Not Indicated Not Indicated Not Indicated 12.15 84.71 96.86 N.A. N.A. N.A. GRAND TOTAL (LT + HT) Not Indicated Not Indicated 88.83 12.17 85.04 97.21 N.A. N.A. 8.38 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 42

True-up Petition FY 2012-13 Sr. No. 1 2 3 4 5 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Income From Wheeling Charges True-up pertaining to Financial Year 2015-16 Name of Discom or Open Access Consumer Contracted Capacity (MW) As per Tariff Order Monthly Wheeling Charges Not indicated in Tariff Order Total revenue from wheeling charges (Rs. Crs.) Contracted Capacity (MW) Schedule No: TUD 1c All Figures in Rs. Crore Actual Monthly Wheeling Charges Total revenue from wheeling charges (Rs. Crs.) Included in Revenue from sale of power Total Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 43

True-up Petition FY 2012-13 Sr. No. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Other Income Schedule No: TUD 2 True-up pertaining to Financial Year: 2015-16 All Figures in Rs. Crore Particulars Account Code Allowed in Tariff Accrued Total Variance Actually Order Received (B) (A) (C) (D) (D-A) A Income from Investment, Fixed & Call Deposits 1 Interest Income from Investments - 0.00 2 Interest on fixed deposits - 0.00 3 Interest from Banks other than Fixed Deposits - 0.00 4 Interest on (any other items) 0.05 0.05 0.05 Sub-Total - 0.05-0.05 0.05 B Other Non Tariff Income 1 Interest on loans and Advances to staff - 0.00 2 Interest on Loans and Advances to other Licensee - 0.00 3 Interest on Loans and Advances to Lessors - 0.00 4 Interest on Advances to Suppliers / Contractors - 0.00 5 Street Light Charges - - 0.00 6 Gain on Sale of Fixed Assets - 0.00 7 Income/Fee/Collection against staff welfare activities 0.00 0.00 0.00 8 Miscellaneous receipts 0.02 - (0.02) 9 Incentive due to Securitisation of CPSU Dues - 0.00 10 Deferred Income (Consumer Contribution) - 0.00 11 Misc. charges from consumers 0.21 - (0.21) 12 Income from wheeling charges - 0.00 13 Meter rent 0.09 - (0.09) 14 Shutdown Charges - 0.00 0.00 0.00 15 Surcharge Received on Power Bill - 0.07 0.07 0.07 16 Power Application Processing Chages 0 0.01 0.01 0.01 Sub-Total 0.32 0.08-0.08 (0.24) Other Income (A+B) 0.32 0.13-0.13 (0.19) Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 44

True-up Petition FY 2012-13 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Expenses and Income from Business other than Licensed business (to be filled if other business utilises the assets of Licensed business) True-up pertaining to Financial Year: 2015-16 Sr. No. Particulars Account Code Allowed in Tariff Order 1 Expenses of other business 2 Total income from other business Not Indicated in tariff 3 Income allocated to Licensed business* order 4 Total profit / (loss) from other business 5 Total profit / (loss) allocated to Licensed business* * Must be supported with rationale and methodology of how allocation is done Schedule No: TUD 3 All figures in Rs Crs. Actuals Nil Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 45

I True-up Petition FY 2012-13 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Power Purchase cost Schedule No: TUD 4 Schedule No: TUD 4 True-up pertaining to Financial Year: 2015-16 2015-16 2015-16 Variable Actual Variable Charge Total power purchase cost Considered in Tariff Order Fixed Cost (Rs. Crs.) Charges Rate of Variable Charge (Paisa/kWH) Average Per Unit Rate (Rs. in Crs.) Diff. of (Rs. Crs,) (Rs. Crs.) variable Installed % Allocated Sr. Capacity for % Allocated Allocated Approved Approved Approved Approved Actual at Diff. (Over Approved Actual Diff. (Over Approved Energy FPA Income ED/Cess MOPA +Gas Dis / Any Other Total Charge (Over Approved Actual Diff. (Over Approved Actual Diff. (Over Approved Actual Source Capacity in Capacity for No. state in MW Capacity for Capacity for Availability in Availability in Availability in dispatch at Ex-Bus & Above in Tariff & Above in Tariff Charge Charge Tax/FBT Heavy Transportatio Incentive Variable & Above the in Tariff & Above in Tariff & Above in Tariff MW state Discom Discom (MW) Tariff Order at Tariff Order at Tariff Order at Ex-Bus the TO) Order the TO) Order Duty n, Decommn, Charges TO) Order the TO) Order the TO) Order state Ex-Bus Ex-Bus (After (After MoD) Charges Insurance (Rs. in Crs.) Boundary MoD) 1 MPPMCL 32.00 100.00% 32.00 100.00% 32.00 218.80 301.68 82.88 69.14 105.71 36.57 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 69.14 105.71 36.57 3.16 3.50 2 Solar 2.35-2.35 1.80 0.00-1.80 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 1.80 0.00-1.80 7.66 0.00 3 Non-Solar 14.12-14.12 6.97 0.00-6.97 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 6.97 0.00-6.97 4.94 0.00 Total 235.27 301.68 66.41 77.91 105.71 27.80 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 77.91 105.71 27.80 Inter state Transmission Charges Total Power Purchase Cost 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 235.27 301.68 66.41 77.91 105.71 27.80 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 77.91 105.71 27.80 0.00 0.00 PP Cost as per Audited Account Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 46

True-up Petition FY 2012-13 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Energy Balance Schedule No. TUD 4a True-up pertaining to Financial Year: 2015-16 Sr. No. Particulars Form / Schedule No. Approved in the Tariff Order Actual % MU % MU 1 Energy Sales a) LT Sales 0.25% 0.56 0.27% 0.77 b) HT Sales at 11kV 0.08% 0.22 99.75% c) HT Sales at 33kV 220.12 99.65% 285.15 c) EHT Sales 0.00% 0.00% - Total Energy Sales 100.00% 220.68 100.00% 286.14 2 Distribution Losses 3.30% 7.53 2.22% 6.49 3 Energy requirement at T-D boundary at Out going feeder of EHV station 228.21 292.63 Direct Injection not included in Scheduled Energy (Mini/Micro Station) - - Energy Drawal from MPPMCL 228.21 292.63 4 Energy Lost between EHV bus and Out Going feeder 4 INTRA DISCOM Sale/Purch 5 INTRA DISCOM UI 6 Scheduled Energy At Discom Boundary 228.21 292.63 4 MP Transco losses 2.99% 7.03 3.00% 9.05 5 Total Energy Requirement of Licensee at G-T boundary 235.24 301.68 6 Intra-State Transmission Losses 0.00% - 0.00% - 7 Total Power Purchase - Including Transmission Losses 235.24 301.68 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 47

True-up Petition FY 2012-13 Sr.N o. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Inter State Transmission Charges True-up pertaining to Financial Year: Schedule No TUD: 5 2015-16 Lines/Links / Region Approved as per Tariff Order (Rs. Crs.) Actual (Rs. Crs.) A B C D ER WR OTHERS TOTAL NIL NIL Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 48

True-up Petition FY 2012-13 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Intra State Transmission and Wheeling Charges Schedule TUD No: 6A True-up pertaining to Financial Year: 2015-16 Intra State Transmission (MPTRANSCO) Charges Sr.No. Year Approved in the Tariff Order Actual 1 Allocated Capacity (MW) 32.00 40.00 2 Transmission charges (Rs./MW/month) - - 3 Total Transmission Charges (Rs. Crs.) 3.95 4.07 Wheeling Charges Paid to Other Distribution Licensee Sr.No. Year 1 Allocated Capacity (MW) 2 Wheeling charges (Rs./MW/month) 3 Total Wheeling Charges (Rs. Crs.) Approved in the Tariff Order Not Applicable Actual Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 49

True-up Petition FY 2012-13 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) SLDC Charges Schedule TUD No: 6B True-up pertaining to Financial Year: 2015-16 SLDC Charges Sr.No. Year Approved in the Tariff Order Actual 1 Total SLDC Charges (Rs. Crs.) 0.01 0.12 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 50

True-up Petition FY 2012-13 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Repair & Maintenance Expenditure True-up pertaining to Financial Year: 2015-16 Schedule No TUD : 7 All figures in Rs Crs. Amount Amount Variance Sr.No. Particulars Account Code As Approved in Tariff Order (A) (B) (B-A) 1 Plant and Machinery - 33kV substation - 11kV substation - Switchgear and cable connections - Others 2 Building 3 Civil Works E) Hydraulic Works 5 Lines, Cables Net Works etc. - 33kV lines - 11kV lines Not Indicated in Tariff order - LT lines - Others 6 Vehicles 7 Furniture and Fixtures 8 Office Equipments 9 Station Supplies 10 R&M agreement with MPPKVVCL 4.74 A Gross R&M expenses 4.74 B R&M expenses capitalised A-B Net R&M expenses 4.74 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 51

True-up Petition FY 2012-13 Sr. No. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Employee Details Schedule No TUD : 8a True-up pertaining to Financial Year: 2015-16 All figures in Rs Crs. Particulars Number of Employees Start of Year End of Year A Employee Strength by category April-15 March-16 Working Strength Employee Category 1 Class - I 8.00 6.00 2 Class - II 5.00 3.00 3 Class - III 17.00 17.00 4 Class - IV 15.00 15.00 Total 45 41 E) Sanctioned Strength Employee Category 1 Class - I 8.00 8.00 2 Class - II 5.00 5.00 3 Class - III 17.00 17.00 4 Class - IV 15.00 15.00 Total 45 45 B Employee Strength by Responsibility Working Strength Employee Category 1 O&M duties 2 Project execution 3 Metering and Billing 4 Consumer services (call centers, etc.) Total Sanctioned Strength Employee Category 1 O&M duties 2 Project execution 3 Metering and Billing 4 Consumer services (call centers, etc.) Total Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 52

True-up Petition FY 2012-13 A Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Employee Cost and Provisions True-up pertaining to Financial Year: 2015-16 Sr. No. Particulars Account Code Amount as Approved in Tariff Order (A) Actullay Paid* Amount Provision Made (B) (C) D=(B+C) Employee's Cost (Other Than Covered In 'B'&'C') 1 Salaries 1.33 1.33 2 Overtime - 3 D.A. 1.10 1.10 4 Other Allowances & Relief - 5 Addl. Pay & C.Off Encashment - 6 Sub-Total: (1 to 5) 2.43 2.43 7 Medical Expenses Reimbursement - E) 8 Travelling Allowance(Conveyance Allowance) - 9 Leave Travel Assistance - 10 Honorarium/Overtime - 11 Incentives/Awards Including That In Partnership Project (Specify Items)Compensatory Payment - 12 Earned Leave Encashment 0.06 0.06 13 Tution Fee Re-Imbursement - 14 D.L.I. Board'S Contribution - 15 E.D.L.I. Administration Charges - 16 E.S.I. Board'S Contribution - 17 E.S.I. Administration Charges - 18 Payment Under Workman'S Compensation And Gratuity - 19 Subsidised Electricity To Employees - 20 Any Other Item - 21 Interim Relief / Wage Revision - 22 Sub-Total (7 to 21) 0.06 0.06 23 Staff Welfare Expenses - B Apprentice And Other Training Expenses - C Payment/Contribution To PF Staff Pension And Gratuity - Schedule No TUD: 8b All figures in Rs Crs. Variance Total 1 Terminal Benefits - a) Provident Fund Contribution 0.23 0.23 b) Provision for PF Fund - c) Pension Payments - d) Gratuity Payment 0.94 0.94 2 Any Other Items - Total C 1.17-1.17 Grand Total [A.6 + A.22 + A.23 + B + C] 3.66-3.66 D Bonus/Exgratia To Employees - Other credits to employee cost - E Grand Total 3.66-3.66 3.66 F Employee expenses capitalised - Net Employee expenses (E)-(F) 3.66-3.66 3.66 (D-A) Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 53

True-up Petition FY 2012-13 Sr. No. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Adminstration & General Expenses True-up pertaining to Financial Year: 2015-16 Amount (Rs. in Crore) As Particulars Account Code Approved in Tariff Order (A) Actullay Paid* (B) Amount (Rs. Crs,) Provision Made (C) Schedule No TUD: 9 All figures in Rs Crs. Total D=(B+C) Variance (D-A) A) Administration Expenses Rent rates and taxes Sub - total of Rent rates and taxes i) Rent ii) Rates & Taxes 0.02 0.02 0.02 0.02 iii) Insurance - iv) Revenue Stamp Expenses Account E) Telephone,Postage,Telegram & Telex Charges 0.00 0.00 vi) Incentive & Award To Employees/Outsiders - vii) Consultancy Charges - viii) Technical Fees - ix) Other Professional Charges 0.07 0.07 x) Conveyance And Travel - xi) MPERC License fee 0.02 0.02 License And Registration Fee Of:-- - xii) Plant And Machinery - xiii) Vehicles 0.07 0.07 xiv) Vehicle Expenses (Other Than Trucks And Delivery Vans) - xv) Vehicles Running Expenses Petrol And Oil - xvi) Hiring Of Vehicles (Other Than Trucks And Delivery Vans) - xvii) Security / Service Charges Paid To Outside Agencies 0.53 0.53 Sub-Total of Admistrative Expenses 0.71 0.71 B) Other Charges - i) Fee And Subscriptions Books And Periodicals - ii) Printing And Stationery 0.00 0.00 iii) Advertisement Expenses (Other Than Purchase Related) Exhibition & Demo. 0.01 0.01 iv) Contributions/Donations To Outside Institute / Association * - v) Electricity Charges To Offices - vi) Water Charges - vii) Entertainment Charges - viii) Miscellaneous Expenses - ix) Merchandising, Servicing and Contract Work - x) LT Meter testing/reading on contract - xi) Common expenses by MPSEB - Sub-Total of other charges 0.01 0.01 - C) Legal Charges - - D) Auditor'S Fee - E) Material Related Expenses - i) Freight On Capital Equipments ii) Purchase Related Advertisement Expenses iii) Vehicle Running Expenses Truck / Delivery Van iv) Temporary v) Other Freight - vi) Transit Insurance vii) Octroi viii) Incidental Stores Expenses ix) Fabrication Charges Sub Total of Material related expenses - - F) Direction And Supervision Charges - G) Other credits to A&G Expenses - H) Total Charges 0.72 0.72 0.72 I) A&G expenses capitalised - J) Net A&G expenses - 0.72 0.72 0.72 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 54

True-up Petition FY 2012-13 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Depreciation Schedule No. TUD 10 True-up pertaining to Financial Year: 2015-16 All figures in Rs. Crs. Considered in Tariff Order Actual Sr.No. Particulars Account Code* Useful life (years) Depreciation rate % Opening balance of Depreciation Add. Closing Useful life Withdrawals balance of (years) Depreciation Depreciation rate % Opening balance of Depreciation Closing Add. Adjustment Withdrawals balance of Depreciation Variance 1 Land,Land rights and lease hold 0.00% - 2 Building and Civil Works 3.34% 0.08 Others 1 Others 2 Others 3 Sub-Total E) 3 Hydraulic Works 4 Other Civil Works 5 Plant & Machinery Power Transformers and kiosks Distribution transformers and kiosks Other substation apparatus Switchgears, Control gear & Protection 5.28 0.24 Batteries Others Not Sub-Total 0.24 Indicatd in Not Indicatd in Not Not Indicatd in Tariff order Total - Tariff Tariff order Available 6 Line Cable Networks etc. order Overhead lines upto 11kV Undergound cables upto 11kV LT lines, service connections, etc. Others Sub-Total Total Communication equipment 7 8 Meters, including metering equipment 9 Vehicles 10 Furniture & fixtures 6.33% 0.01 11 Computers 5.22% 0.00 12 Assets of Partnership projects etc. (included in above heads) 13 Assets taken over & pending final valuation 14 Any other items 15 Total (1 to 13) 0.32 0.58 Less: Consumer contribution 16 0.26 0.03 amortized 17 Net depreciation (15-16) 0.32 0.29 (0.03) Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 55

True-up Petition FY 2012-13 Sr.N o. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Gross Fixed Assets True-up pertaining to Financial Year: 2015-16 Considered in the Tariff Order Change During the Year (Additions/ Deductions) Start of Year At End Of Year Start of Year Actual Change During the Year (Additions/ Deductions) At End Of Year 1 Land & Land rights 0.00 0.00 0.00 2 Building and Civil Works Others 1 Others 2 Others 3 Sub-Total 1.23 1.71 2.94 3 Hydraulic Works 0.00 0.00 0.00 4 Other Civil Works 0.00 0.00 0.00 5 Plant & Machinery Power Transformers and kiosks Distribution transformers and kiosks Other substation apparatus Switchgears, Control gear & Protection Batteries 4.40 0.08 4.48 Others Details Not Available Total 4.40 0.08 4.48 6 Line Cable Networks etc. Overhead lines upto 11kV Undergound cables upto 11kV LT lines, service connections, etc. Others Particulars Account Code* in the Tariff Order Schedule No TUD. 10a All figures in Rs. Crs. 1.23 1.71 2.94 Sub-Total 0.00 0.00 0.00 7 Communication equipment - - - 8 Meters, including metering equipment - - - 9 Vehicles 0.00 10 Furniture & fixtures 0.04 0.16 0.21 11 Office Equipments 0.00 12 Assets of Partnership projects etc. (included in above heads) - - - 13 Assets taken over & pending final valuation - - - 14 Any other items (Capex on Assets not belonging to Company) 0.00 15 Total (1 to 14) 5.67 1.96 7.63 0.00 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 56

True-up Petition FY 2012-13 Sr. No. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Capital Works in Progress - Summary Statement Schedule No TUD: 10b True-up pertaining to Financial Year: 2015-16 All figures in Rs. Crs. Particulars Considered in Tariff Order Actual A Opening Balance of CWIP 19.30 B Fresh Investment during the year 1.96 Total Capitalisation during the year (C+D) 21.26 C Out of opening CWIP - - D Out of fresh investment - 1.96 Closing Balance of CWIP (A + B - C - D) - 19.30 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 57

True-up Petition FY 2012-13 Sr. No. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Details of Capitalisation during financial year Schedule No TUD: 10c True-up pertaining to Financial Year: 2015-16 All figures in Rs. Crs. Particulars Ref. Schedule No. As Approved in Tariff Order Actual as per audited accounts 1 Capitalisation of base investment - 2 Capitalisation of expenses:-- Interest & Finance charges Capitalised - - Employee expenses - R&M Expenses - A&G Expenses - Others, if any - 3 Capitalisation of depreciation, if any - Grand Total (1+2+3) - - Variance Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 58

True-up Petition FY 2012-13 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Interest and Finance Charges on Project and Working Capital Loans Schedule No TUD: 11 True-up pertaining to Financial Year: 2015-16 Sr. No. Particulars Nature of loan (Project specific or Working Capital) Mention the name of funding agency 1 Amount of loan oustanding as at the beginning of the financial year 2 Amount of principal overdue as at beginning of the FY 3 Amount of Interest overdue as at beginning of the FY 4 Scheduled repayment of principal during the Financial Year 5 Actual repayment of principal during the Financial Year 6 Drawals during the Financial Year 7 Due next within one year 8 Oustanding loan as at the end of Financial Year** Project Specific 9 Oustanding Principal Overdue as at the end of Financial Year** 10 Interest Expenses accrued during the year 11 Scheduled payment of interest during the Financial Year 12 Actual payment of interest during the Financial Year 13 Oustanding Interest Overdue as at the end of Financial Year** 14 Actual Interest Rates(%)*** S.No Particular Nature of loan (Project specific or Working Capital) STATE GOVT WCL /ED Cess/Sardar Sarovar dues Converted in to Perpetual Loan 1 STATE GOVT Working Capital Loan 2 PFC 1 Amount of loan oustanding as at the beginning of the financial year 2 Scheduled repayment of principal during the Financial Year 3 Actual repayment of principal during the Financial Year 4 Drawals during the Financial Year 5 Due next within one year 6 Oustanding loan as at the end of Financial Year 7 Interest Expenses accrued during the year Scheduled payment of interest during the Financial Year (Including 8 Penal Interest) 9 Actual payment of interest during the Financial Year 10 Actual Interest Rates(%)** Working Capital Sr. No. A Particulars Total interest payments against current dues in financial year (not including any payments against previous year defaults of principal or interest or any penal charges on such defaults) Allowed as per Tariff Order Actual Project Specific Loans Working Capital Loans Project Specific Loans Working Capital Loans B Interest capitalised to project works I Net Interest charges (A - B) II Finance charges actually incurred in financial year iii Penal Interest iv Interest on Overdraft and CC Limits Total (I+II+III+IV) - 0.00 - - Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 59

True-up Petition FY 2012-13 Sr. No. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Interest on Consumer Security Deposit Schedule No TUD: 11a True-up pertaining to Financial Year: 2015-16 All figures in Rs. Crs. Considered in Particulars Actual Variance Tariff Order 1 Opening Balance of CSD 12.77 2 Additional CSD received during the year Not Indicated in 0.66 3 Refunded to consumers during the year tariff order - Closing balance of CSD at the end of the year (1+2-3) 13.43 4 Effective Interest Rate on CSD in % 8.50 Interest paid on CSD (Rs. Crore) 1.00 1.03 0.03 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 60

True-up Petition FY 2012-13 Sr. No. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Bad & Doubtful Debts Schedule No TUD: 12 True-up pertaining to Financial Year: 2015-16 All figures in Rs. Crs. Allowed in Tariff Particulars Actual Variance Order 1 Revenue from sale of power as billed 88.83 97.21 8.38-0.00 2 Normative provision for bad debts @ 1% of sales revenue - - 0.00 Provision for Bad Debts as per Tariff Order - 0.00 3 Provision for Bad Debts as per Balance Sheet 0.00 0.00 Not Applicable - 4 Bad debts actually written off in financial year - 0.00 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 61

True-up Petition FY 2012-13 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Other Items of expendiure Schedule No TUD: 13 True-up pertaining to Financial Year: 2015-16 All figures in Rs. Crs. Sr. Allowed in Tariff Particulars (Provide details of expenditure) Account Code No. Order Actually Paid Provision Made 1 Net prior period credit charges - 2 Miscelleneous losses Write offs/sundry Expenses Not Indicated in - Tariff order 3.00 Extraordinary Items - Less: Chargeable to capital works, if any - Net Total other expenses 0.00 - Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 62

True-up Petition FY 2012-13 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Share Capital and Reserves & Surplus True-up pertaining to Financial Year: 2015-16 Sr. No. Description of capital Account Code Balance at the beginning of the year Actual as per Audited Accounts Withdrawals during the Appropriation year (Purpose to be during the year indicated in the remark column) Schedule No TUD: 14 All figures in Rs. Crs. Balance at the end of the year Remarks 1 2 3 4 5 A SHARE CAPITAL Equity Capital 20.48 20.16 0.00 40.64 Share Application Money pending allotment 0.00 Sub-total of Reserves 20.48 20.16 0.00 40.64 B RESERVES General Reserve 0.00 0.00 0.00 0.00 E) Capital Reserve 0.00 0.00 0.00 0.00 Other reserves (37.69) (22.75) 0.00 (60.44) Sub-total of Reserves (37.69) (22.75) 0.00 (60.44) C SURPLUS Surplus - Government Grants, Consumer Contributions and Other Deferred Income 7.12 2.65 0.00 9.77 Sub-total of Surplus 7.12 2.65 0.00 9.77 D Net Worth (A+B+C) (10.09) 0.06 0.00 (10.03) None Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 63

True-up Petition FY 2012-13 Sr. No. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Current Assets & Liabilities True-up pertaining to Financial Year: 2015-16 Particulars Account code As Approved in Tariff Order Schedule No TUD: 15 All figures in Rs. Crs. Actual As Per Audited Accounts A I Current Assets, Loans and Advances Current Investment II Inventories III Trade Receivables IV Cash and Cash Equivalents 0.24 V Short Term Loans and Advances VI Other Current Assets Not Indicated in Tariff order 9.62 TOTAL OF 'A' 9.86 E) B Current Liabilities and Provisions I Short Term Borrowings II Trade Paybles III Other Current Liability 15.64 IV Short Term Provisions 10.23 TOTAL OF 'B' (I+II+III) 25.87 C NET CURRENT ASSETS (= A - B) (16.01) Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 64

True-up Petition FY 2012-13 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Normative Working Capital Requirements Form No TUD: F1 True-up pertaining to Financial Year: For Wheeling activity 2015-16 All figures in Rs. Crs. Sr. No. Particulars Ref. Form / Schedule Allowed in Tariff Actual No. Order A) 1/6th of annual requirement of inventory for previous year at 1 % GFA for previous year 0.02 0.01 B) Total of O&M expenses 4.99 9.10 B) i) 1/12th of total 0.42 0.76 C) Receivables - - C) i) Annual Revenue from wheeling charges - C) ii) Receivables equivalent to 2 months average billing of wheeling charges - D) Total Working capital 0.44 0.77 (A), B) i), C) ii)) E) Rate of Interest * 13.50% 14.75% F) Interest on Working capital -wheeling 0.06 0.11 For Retail Sale activity Sl. No. Particulars Ref. Form No. Allowed in Tariff Order Actual A) 1/6th of annual requirement of inventory for previous year 0.00 B) Receivables B) i) Annual Revenue 88.83 97.35 B) ii) Receivables equivalent to 2 months average billing 14.80 16.22 C) Power Purchase expenses 77.91 109.90 C) i) 1/12th of power purchase expenses 6.49 9.16 D Consumer Security Deposit 11.24 13.43 E) Total Working capital (A+B ii) - C i) - D) -2.93-6.36 F) Rate of Interest * 13.50% 14.75% G) Interest on Working capital -Retail -0.40-0.94 Total Interest on Working capital -Wheeling 0.06 0.11 Net Interest on Working capital -Retail -0.34-0.83 Total Interest on Working Capital(Wheeling+Retail) 0.00 0.00 The Interest rate for this purpose shall be the rate as specified in the Commission's Rergulations * under section 62 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 65

True-up Petition FY 2012-13 Sr. No. i ii I II A i ii I II B Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Normative O&M Expenses Form No TUD: F2 True-up pertaining to Financial Year: 2015-16 Form / Particulars Schedule Considered in Actual Variance Ref. Tariff Order Metered consumers (nos.) - opening Metereed consumers (nos.) - closing Average Metered consumers (nos.) - (average of i and ii above) O&M expenses Rs. Lakhs per '000 metered consumers as per Regulation Sub-total O&M expenses (I*II/1000) (Rs. Lakhs) Metered sales (MU) - previous year Metered sales (MU) - year in question (for which true-up is sought) Average sales (MU) - average of i and ii above O&M expenses Rs. Lakhs per MU metered sales as per Regulation Sub-total O&M expenses (I*II) (Rs. Lakhs) Additional pre-paid meters to be installed during the year i ii C i ii I II D i ii I II E F G H Multiplying factor-b(rs. Lakh/Meter) O&M-B(Rs. Lakh) Sub-total O&M expenses (I*II) (Rs. Lakhs) Ckt-kms of HT (33kV and 11kV) lines - as at end of previous year Ckt-kms of HT (33kV and 11kV) lines - as at end of year in question Average ckt-kms of HT lines - (average of i and ii above) O&M expenses Rs. Lakhs per 100 ckt-km of HT lines as per Regulation Sub-total O&M expenses (I*II/100) (Rs. Lakhs) Cumulative transformation capacity of 33/11kV transformers in MVA - end of previous year Cumulative transformation capacity of 33/11kV transformers in MVA - end of year in question Average transformation capacity - (average of i and ii above) O&M expenses Rs. Lakhs per MVA as per Regulation Sub-total O&M expenses (I*II) (Rs. Lakhs) Total of other expenses not covered under norms (MPERC License fees, taxes to Govt. or local authorities, etc.) Terminal Benefits Rates and Taxes Total O&M expenses in Rs. Lakhs (A+B+C+D+E+F+G+H) Total O&M expenses in Rs. Crs. As per norms Total O&M expenses in Rs. Crs. As per the Audited Accounts 4.99 9.10 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 66

True-up Petition FY 2012-13 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Distribution Losses in LT and HT system Form No TUD: P1 True-up pertaining to Financial Year: 2015-16 All Figures in MU Sr. No. Particulars As approved in TO 2012-13 Actual A Losses in EHT System (400 kv, 220 kv, 132 kv & 66 kv) 1 Scheduled Energy at Ex-Bus (As per SEA) 301.68 2 Scheduled Energy at Discom Periphery (As per UI) 292.63 3 Difference of Scheduled energy at Ex-bus and at Discom periphery (1-2) - 9.05 Difference of Scheduled energy at Ex-bus and at Discom periphery 4 [(3/1)*100]% 5 Interdiscom Sale/Purchased 3.00% 6 Scheduled Energy at Discom Periphery after inter discom trading 292.63 7 Actual Energy Drawl at Discom periphery (at Interface point) 292.63 8 UI (2-7) - - Actual Energy input at Discom periphery (i.e. at outgoing feeders of EHV 9 S/S) - 292.63 Energy Lost between interface point and outgoing feeders of EHV s/s 10 [i.e. Bus loss = (7-9)] - 11 Total Loss in the Bus of Transmission system [10/(7)*100]% 0.00% 12 Direct Injection at 33 kv which is not included in scheduled energy - 13 Direct Injection at 11 kv which is not included in scheduled energy - 14 Total Energy Input at Discom Periphery (9+12+13) - 292.63 15 Energy sold at this voltage level 292.63 16 Energy transmitted to the 33 kv level 292.63 17 Energy transmitted to the11 kv level - 18 Energy Lost in EHV feeders feeding EHV Consumers (14-15-16-17) (292.63) 19 Total Loss in EHV feeders feeding EHV Consumers [18/(14)*100]% -100.00% B System Losses At 33 KV 1 Energy injection at 33 kv level from MP Transco EHV s/s 292.63 2 Direct Injection at 33 kv which is not included in scheduled energy 3 Total Energy input at 33kV Voltage level (1+2) 292.63 4 Energy sold at this voltage level 285.15 5 Energy transmitted to the 11 kv voltage level 0.22 6 Energy Lost (3-4-5) 7.26 7 Total Loss in the system [6/(3)*100]% 2.48% C Losses At 11 KV +LT 1 Energy received into the system from 33 kv system 1.14 2 Direct Energy injection at 11 kv level from MP Transco EHV s/s 3 Direct Injection at 11 kv which is not included in scheduled energy 4 Total Energy input at 11kV Voltage level (1+2+3) 1.14 5 Energy sold at 11 kv voltage level 0.22 6 Energy sold at LT voltage level 7 Totall Energy sold at 11kV + LT level (5+6) 0.22 Energy transmitted to the next (lower) voltage level 0.86 8 Energy Lost (4-7) 0.07 9 Total Loss in 11kV + LT system [8/(4)*100]% 6.00% D E LT System Losses 1 Energy received into the system 0.86 2 Energy sold at this voltage level 0.77 3 Energy Lost (1-2) 0.09 4 Total Loss in the system (3/1)*100% 10.00% Distribution system losses 1 Energy In (A16) 292.63 2 Energy Out (A17+B4+C7) 286.14 3 Total Distribution Losses [(1-2)/(1)*100]% 2.22% F Overall Losses 1 Total Energy Lost (A3+A10+A18+B6+C8) 15.54 2 Energy Out (A15+B4+C7) 286.14 3 Total T&D Loss [(1)/(1+2)*100]% 5.15% Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 67

True-up Petition FY 2012-13 Sr. No. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Physical statistics of the network True-up pertaining to Financial Year: 2015-16 Actual Particulars At the start of year Additions during the year Withdrawal / Disconnections from service Form NO. TUD P2 At the end of year 1 Length of lines (ckt-km) - 33kV 24.6 24.6-11kV 12 12 - LT 5 5 Total 41.6 41.6 2 Number of 33/11kV substations 1 1 3 No. of Power Transformers 1 1 Total MVA capacity of power transformers 5 5 3 Number of Distribution Transformers 14 2 16 Total MVA capacity of Distribution Trfs. 2.8 0.4 3.2 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 68

True-up Petition FY 2012-13 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Sales, Consumers & Connected load - LT consumers True-up pertaining to Financial Year: 2015-16 As approved in Tariff Order Actual Category LV1: Domestic L T CONSUMERS Consumers (No) Sales (MU) Connected Load / Contract Demand (kw) Consumers (No) Sales (MU) Connected Load / Contract Demand (kw) Consumers (No) Variance (Actual-T.O.) Sales (MU) Form No: TUD P3 Connected Load / Contract Demand (kw) LV2: Non - Domestic Non Domestic Not Indicated Not Indicated Not Indicated 15 0.31 229 N.A. N.A. N.A. Sub total Not Indicated Not Indicated Not Indicated 15 0.31 229 N.A. N.A. N.A. Total LV2: Non - Domestic Not Indicated 0.04 Not Indicated 15 0.31 229 N.A 0.27 N.A LV 3: Public Water Works and Street Lights LV3.1: Public Water Works:--- Public Water Works Not Indicated Not Indicated Not Indicated 3 0.09 80 N.A. N.A. N.A. Sub-Total Public Water Works Not Indicated Not Indicated Not Indicated 3 0.09 80 N.A. N.A. N.A. LV3.2: Street Lights :--- Street Light Not Indicated Not Indicated Not Indicated 7 0.25 120 N.A. N.A. N.A. Sub-Total Street Lights Not Indicated Not Indicated Not Indicated 7 0.25 120 N.A. N.A. N.A. Total - LV 3: PWW and Street Lights Not Indicated 0.41 Not Indicated 10 0.34 200 N.A (0.07) N.A LV4 LT Industry Non-Seasonal consumers:--- Upto 25 HP Not Indicated Not Indicated Not Indicated 8 0.12 101 N.A. N.A. N.A. 25 to 100 HP Above 100 HP Sub-total Not Indicated Not Indicated Not Indicated 8 0.12 101 N.A. N.A. N.A. Sub-Total(Non-seasonal) Not Indicated Not Indicated Not Indicated 8 0.12 101 N.A. N.A. N.A. Total LV 4 LT Industrial Not Indicated 0.11 Not Indicated 8 0.12 101 N.A. 0.01 N.A. LV 5: Agricultural and Other than Agricultural TOTAL LT Not Indicated 0.56 Not Indicated 33 0.77 530 N.A. 0.21 N.A. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 69

True-up Petition FY 2012-13 Sales, Consumers & Connected load - HT consumers Category True-up pertaining to Financial Year: 2015-16 As approved in Tariff Order Consumers (No) Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Sales (MU) Connected Load / Contract Demand (kw) Consumers (No) Sales (MU) Connected Load / Contract Demand (kw) Consumers (No) Variance (Actual-T.O.) Sales (MU) Form No: TUD P4 Connected Load / Contract Demand (kw) HT CONSUMERS 11 KV 1 0.22 300 33 KV 33 285.14 53,458 HV1: INDUSTRIAL AND NON-INDUSTRIAL Not Indicated 220.12 Not Indicated 34 285.36 53,758 N.A 65.24 N.A HV 2: PUBLIC WATER WORKS HV 3: SYNCHRONIZATION AND START UP POWER FOR GENERATORS CONNECTED TO THE GRID TOTAL HT Not Indicated 220.12 Not Indicated 34 285.36 53758 N.A. 65.24 N.A. GRAND TOTAL (LT + HT) Not Indicated 220.68 Not Indicated 67 286.13 54,288 N.A. 65.45 N.A. Actual Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 70

True-up Petition FY 2012-13 Sr. No. Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Limited (MPAKVN) Summary of Actual Revenue from Sale of Power True-up pertaining to Financial Year: Particulars Approved in the Tariff Order (A) Form TUD: RoE 2015-16 All figures in Rs Crs. Actuals A Gross Fixed Assets at the beginning of year (net of consumer contributions) 5.68 (B) Variance (B-A) A1 Opening balance of equity 0.94 B Actual capitalisation of assets as per Annual Accounts (net of consumer contribution) 1.72 B1 Addition of equity, internal reserves during the year for capitalized assets Not Provided 0.51 C1 Normative additional Equity (30% of B) 0.51 D1 Excess / shortfall of additional equity over normative (B1-C1) - E Equity eligible for Return (A1+(C1/2)) OR (A1+(B1/2)), whichever is lower 1.20 F Return on Equity - (16% on E) 0.42 0.19-0.23 Madhya Pradesh Audyogik Kendra Vikas Nigam (Indore) Ltd. Page - 71