To the Members of The Karur Vysya Bank Limited
Report on the Audit of the Financial Statements
1. We have audited the accompanying financial statements of The Karur Vysya BankLimited (the Bank') which comprise the Balance Sheet as at 31 March 2021 theStatement of Profit and Loss and the Statement of Cash Flows for the year then ended anda summary of the significant accounting policies and other explanatory information inwhich are included the returns for the year ended on that date audited by the respectivestatutory branch auditors of the Bank's 807 branches and other offices.
2. In our opinion and to the best of our information and according to the explanationsgiven to us and based on the consideration of the reports of the statutory branchauditors as referred to in paragraph 16 below the aforesaid financial statements give theinformation required by the Banking Regulation Act 1949 as well as the Companies Act2013 (Act') and circulars and guidelines issued by the Reserve Bank of India in themanner so required for banking companies and give a true and fair view in conformity withthe accounting principles generally accepted in India including the Accounting Standardsprescribed under section 133 of the Act read with rule 7 of the Companies (Accounts)Rules 2014 (as amended) of the state of affairs of the Bank as at 31 March 2021 and itsprofit and its cash flows for the year ended on that date.
Basis for Opinion
3. We conducted our audit in accordance with the Standards on Auditing specified undersection 143(10) of the Act. Our responsibilities under those standards are furtherdescribed in the Auditor's Responsibilities for the Audit of the Financial Statementssection of our report. We are independent of the
Bank in accordance with the Code of Ethics issued by the Institute of CharteredAccountants of India (ICAI') together with the ethical requirements that arerelevant to our audit of the financial statements under the provisions of the Act and therules thereunder and we have fulfilled our other ethical responsibilities in accordancewith these requirements and the Code of Ethics. We believe that the audit evidence we haveobtained and that obtained by the statutory branch auditors in terms of their reportsreferred to in paragraph 16 of the Other Matter section below is sufficient andappropriate to provide a basis for our opinion.
Emphasis of Matter
4. We draw attention to note 5.14 of schedule 18 of the accompanying financialstatements which describes the uncertainties due to the outbreak of COVID-19. The impactof these uncertainties on the Bank's financial results is significantly dependent onfuture developments. Our opinion is not modified in respect of the above matter.
Key Audit Matters
5. Key audit matters are those matters that in our professional judgment and based onthe consideration of the reports of the statutory branch auditors as referred to paragraph16 below were of most significance in our audit of the financial statements of thecurrent period. These matters were addressed in the context of our audit of the financialstatements as a whole and in forming our opinion thereon and we do not provide aseparate opinion on these matters.
6. We have determined the matters described below to be the key audit matters to becommunicated in our report.
Information Technology (IT) systems and controls impacting financial reporting
|Key audit matter ||How our audit addressed the key audit matter |
|The Information Technology environment of the Bank is complex and involves a large number of both independent and inter-dependent information technology systems used in the operations of the Bank for processing and recording a large volume of transactions in numerous locations on a daily basis. As a result there is a high degree of reliance and dependency on such IT systems for financial reporting process of the Bank. Appropriate automated general and application controls are required to ensure that such IT systems and applications are able to process the data as required completely accurately and consistently which directly impact the completeness and accuracy of financial reporting. ||Our audit procedures included but were not limited to the following: |
|Appropriate and adequate controls contribute to mitigating the risk of potential misstatements caused by frauds or errors as a result of changes to applications and data. Amongst its multiple IT systems Flexcube IDEAL LAPS LOS SWIFT Peoplesoft and Mercury systems are key for its overall financial reporting. Thus our audit approach focusses on IT systems and the related control environment including: ||In assessing the controls around the IT systems relevant for financial reporting we included our specialist in information technology audits as part of our audit team to obtain an understanding of the Information Technology infrastructure and selected Information Technology systems based on their importance and relevance to Bank's financial reporting process for evaluation and testing of Information Technology general controls and Information Technology automated controls. |
| IT related general controls over user access management and change management across applications database and operating systems; ||Access rights were tested over applications operating systems and databases which are relied upon for financial reporting. We also assessed the operating effectiveness of controls over granting removal and periodical review of access rights. We further tested segregation of duties including preventive controls to ensure that access to change applications operating system or databases in the production environment were granted only to authorized personnel. |
| IT application controls Because of the high level automation being used by the management and impact of the IT systems and related control environment on the Bank's financial reporting process we have identified testing of such IT systems and related control environment as a key audit matter. ||Other areas that were independently assessed under the Information Technology control environment included password policies security configurations and controls around change management to ensure there were no unauthorized changes made to the Information |
| ||Technology systems and applications during the year. |
| ||We also evaluated the design and tested operating effectiveness of key automated controls within various business processes. |
|Identification and provisioning for non-performing assets (NPAs') including implementation of COVID-19 related measures || |
|As at 31 March 2021 the Bank reported total gross advances of H 52820.13 crores gross NPAs of H 4142.87 crores and provision for non-performing assets of H 2365.61 crores. ||Our procedures included but were not limited to the following: |
|Refer note 3 in schedule 17 for the accounting policy for provision for NPAs and notes 5.1 and 5.3 in schedule 18 for the related financial disclosures. ||We tested the design and operating effectiveness of key controls including IT based controls focusing on the following: |
|The identification of NPAs and provisioning for advances is made in accordance with the RBI Prudential Norms on Income Recognition Asset Classification and Provisioning pertaining to Advances (RBI IRAC norms'). Based on our risk assessment the following are the significant factors in assessment of the provisions for NPAs: ||Identification of NPAs in line with the RBI IRAC norms and qualitative factors prescribed by the RBI; |
| Completeness and timing of recognition of defaults in accordance with the criteria set out in the RBI IRAC norms. In addition to this the management is also required to apply its judgement in identification and provision required for NPAs based on qualitative assessment; || Periodic internal reviews of asset quality; |
| The measurement of provision under RBI IRAC norms is also dependent on the ageing of overdue balances secured / unsecured status of advances stress and liquidity concerns in certain sectors and valuation of collateral. || Assessment and adequacy of NPA provisions; |
|COVID-19 || Periodic valuation of collateral for NPAs; |
|During the current year RBI has announced various relief measures for the borrowers which were implemented by the Bank such as "COVID 19 Regulatory Package- Asset Classification and Provisioning" announced by the RBI on 17 April 2020 and RBI circular on "Asset Classification and Income Recognition following the expiry of Covid-19 regulatory package" dated 7 April 2021 (collectively referred to as the RBI circulars') and "Resolution Framework for COVID-19 related Stress" (the Resolution Framework') issued by the RBI on 6 August 2020 which were collectively considered by the management in identification and provisioning of non-performing assets. || Implementation of the RBI circulars. |
|On the basis of estimates made by the management an additional provision to the tune of H 285.42 crores had been recognised by the Bank during the current year ended 31 March 2021 in addition to H 19.50 crores recognised in the previous year. From the above H 291.03 crores has been utilized as at 31 March 2021 towards provision for restructured accounts and NPA accounts. Such additional provisions were created on account of increase in default risk due to the impact of COVID-19 on recoverability of advances of the Bank and such basis of estimates and assumptions involved in arriving at the additional provisions are monitored by the Bank periodically which significantly depend on future developments in the economy due to COVID-19 including any new relief measures announcements by the RBI. ||To test the completeness of the identification of loans with default events and qualitative factors we selected a sample of performing loans including Special Mention Accounts (SMA) and recomputed the ageing of the advances to ascertain the accuracy of the ageing captured in the system generated reports and assessed as to whether there was a need to classify such loans as NPAs as per RBI IRAC norms. |
|Implementation of the RBI circulars also required the Bank to implement changes in its Information Technology systems. ||Returns from branches duly audited by statutory branch auditors were reviewed and their reports were properly dealt with by us in testing of NPA. |
|Considering significant efforts involved in identifying NPAs valuation of security/collaterals determining the provision for NPA additional complexities involved in the current year owing to the impact of COVID-19 and heightened regulatory inspections these matters are significant to the financial statements we have identified NPA identification and provision on advances as a key audit matter. ||We re-computed the provision calculations as per RBI IRAC norms and compared such outcome to that prepared by management and investigated the differences if any and challenged the assumptions and judgements which were used by the management. |
| ||Obtained Board's policies pursuant to RBI Circulars Resolution Framework and ensured such policies were in accordance with the RBI requirements. |
| ||With respect to those borrowers to whom a moratorium was granted in accordance with the RBI circulars on a sample basis we tested that such moratorium was granted and implemented in the systems in accordance with the board approved policy. On a test check basis we tested the loans to ensure that identification of NPAs provisions created and asset classification were in accordance with the requirements of the RBI circulars. |
| ||On a test check basis we ensured that the restructuring was approved and implemented and provisions made on such restructured loans in accordance with the Bank's board approved policy and the Resolution Framework. |
| ||On account of the impact of the COVID-19 pandemic we understood and challenged the assumptions used by the Bank for provisions by considering our understanding of the risk profiles of the customers of the Bank belonging to COVID impacted industries and other relevant publicly available macro-economic factors pertaining to impact of COVID-19. |
| ||We also assessed the appropriateness and adequacy of disclosures as per relevant accounting standards and RBI requirements relating to NPAs including disclosures relating to RBI circulars and Resolution Framework. |
|Statutory tax litigations || |
|The Bank has H 371.57 crores of tax litigations pending as at 31 March 2021 for which no provision is made in the books of accounts. ||Our audit procedures included but were not limited to the following: |
|Refer note 15 in schedule 17 for the accounting policy and schedule 12 and notes 9.8 and 10.9 of schedule 18 for the related disclosure in financial statements. ||We tested the design and operating effectiveness of the Bank's key controls over the identification estimation monitoring and disclosure of tax litigations. |
|The tax litigations of the Bank involve varied degree of complexities. ||We involved our tax experts to assess the Bank's interpretation and application of relevant tax laws to evaluate the appropriateness of key assumptions used and the reasonableness of estimates made in relation to uncertain tax positions taking into account past precedents. Weexercisedourprofessionaljudgementtoassessthemanagement's assessment of the probability of the liability devolving upon the Bank as per principles of AS 29. |
|In accordance with the accounting criteria set under Accounting Standard 29 - Provisions Contingent Liabilities and Contingent Assets (AS 29') the management needs to evaluate whether an obligation exists and whether a provision should be recognised as at reporting date or whether it needs to be disclosed as a contingent liability. The most significant judgements include: ||We also compared the actual results to the management estimates made in prior period to determine the efficacy of the process of estimation by the management. |
| Assessment of liability: Judgement is involved in the determination of whether an outflow in respect of identified material matters are probable and can be estimated reliably; ||Further we assessed whether the disclosures in financial statements related to taxation matters were appropriate and adequate in terms of whether the potential liabilities and the significant uncertainties are fairly presented. |
| Adequacy of provisions: The appropriateness of assumptions and judgements used in the estimation of significant provisions; and || |
| Adequacy of disclosures of provision for liabilities and charges and contingent liabilities. Considering the materiality of the amounts involved significance of the above matter to the financial statements and significant judgments required to test such estimates we have identified this as a key audit matter. || |
Information other than the Financial Statements and Auditor's Report thereon
7. The Bank's Board of Directors is responsible for the other information. The otherinformation comprises the information included in the Annual Report including the PillarIII Disclosure under the New Capital Adequacy Framework (Basel III disclosures) but doesnot include the financial statements and our auditor's report thereon. The Annual Reportis expected to be made available to us after the date of this auditor's report.
Our opinion on the financial statements does not cover the other information and wewill not express any form of assurance conclusion thereon.
In connection with our audit of the financial statements our responsibility is to readthe other information identified above when it becomes available and in doing soconsider whether the other information is materially inconsistent with the financialstatements or our knowledge obtained in the audit or otherwise appears to be materiallymisstated.
When we read the Annual Report if we conclude that there is a material misstatementtherein we are required to communicate the matter to those charged with governance.
Responsibilities of Management and Those Charged with Governance for the FinancialStatements
8. The accompanying financial statements have been approved by the Bank's Board ofDirectors. The Bank's Board of Directors is responsible for the matters stated in section134(5) of the Act with respect to the preparation of these financial statements that givea true and fair view of the financial position financial performance and cash flows ofthe Bank in accordance with the accounting principles generally accepted in Indiaincluding the Accounting Standards prescribed under section 133 of the Act read with rule7 of the Companies (Accounts) Rules 2014 (as amended) and provisions of section 29 of theBanking Regulation Act 1949 and circulars and guidelines issued by Reserve Bank of India(RBI') from time to time. This responsibility also includes maintenance of adequateaccounting records in accordance with the provisions of the Act for safeguarding of theassets of the Bank and for preventing and detecting frauds and other irregularities;selection and application of appropriate accounting policies; making judgments andestimates that are reasonable and prudent; and design implementation and maintenance ofadequate internal financial controls that were operating effectively for ensuring theaccuracy and completeness of the accounting records relevant to the preparation andpresentation of the financial statements that give a true and fair view and are free frommaterial misstatement whether due to fraud or error.
9. In preparing the financial statements management is responsible for assessing theBank's ability to continue as a going concern disclosing as applicable matters relatedto going concern and using the going concern basis of accounting unless management eitherintends to liquidate the Bank or to cease operations or has no realistic alternative butto do so.
10. Those Board of Directors are also responsible for overseeing the Banks's financialreporting process.
Auditor's Responsibilities for the Audit of the Financial Statements
11. Our objectives are to obtain reasonable assurance about whether the financialstatements as a whole are free from material misstatement whether due to fraud or errorand to issue an auditor's report that includes our opinion. Reasonable assurance is a highlevel of assurance but is not a guarantee that an audit conducted in accordance withStandards on Auditing will always detect a material misstatement when it exists.Misstatements can arise from fraud or error and are considered material if individuallyor in the aggregate they could reasonably be expected to influence the economic decisionsof users taken on the basis of these financial statements.
12. As part of an audit in accordance with Standards on Auditing we exerciseprofessional judgment and maintain professional skepticism throughout the audit. We also:
Identify and assess the risks of material misstatement of the financialstatements whether due to fraud or error design and perform audit procedures responsiveto those risks and obtain audit evidence that is sufficient and appropriate to provide abasis for our opinion. The risk of not detecting a material misstatement resulting fromfraud is higher than for one resulting from error as fraud may involve collusionforgery intentional omissions misrepresentations or the override of internal control.
Obtain an understanding of internal control relevant to the audit in order todesign audit procedures that are appropriate in the circumstances. Under section 143(3)(i) of the Act we are also responsible for explaining our opinion on whether the Bank hasadequate internal financial controls with reference to financial statements and theoperating effectiveness of such controls.
Evaluate the appropriateness of accounting policies used and the reasonablenessof accounting estimates and related disclosures made by management.
Conclude on the appropriateness of management's use of the going concern basisof accounting and based on the audit evidence obtained whether a material uncertaintyexists related to events or conditions that may cast significant doubt on the Bank'sability to continue as a going concern. If we conclude that a material uncertainty existswe are required to draw attention in our auditor's report to the related disclosures inthe financial statements or if such disclosures are inadequate to modify our opinion.Our conclusions are based on the audit evidence obtained up to the date of our auditor'sreport. However future events or conditions may cause the Bank to cease to continue as agoing concern.
Evaluate the overall presentation structure and content of the financialstatements including the disclosures and whether the financial statements represent theunderlying transactions and events in a manner that achieves fair presentation.
Obtain sufficient appropriate audit evidence regarding the financial informationof the Bank to express an opinion on the financial statement. We are responsible for thedirection supervision and performance of the audit of financial information of the Bankand such branches included in the financial statements of which we are the independentauditors. For the other branches included in the financial statements which have beenaudited by the statutory branch auditors such branch auditors remain responsible for thedirection supervision and performance of the audits carried out by them. We remain solelyresponsible for our audit opinion.
13. We communicate with those charged with governance regarding among other mattersthe planned scope and timing of the audit and significant audit findings including anysignificant deficiencies in internal control that we identify during our audit.
14. We also provide those charged with governance with a statement that we havecomplied with relevant ethical requirements regarding independence and to communicatewith them all relationships and other matters that may reasonably be thought to bear onour independence and where applicable related safeguards.
15. From the matters communicated with those charged with governance we determinethose matters that were of most significance in the audit of the financial statements ofthe current period and are therefore the key audit matters. We describe these matters inour auditor's report unless law or regulation precludes public disclosure about the matteror when in extremely rare circumstances we determine that a matter should not becommunicated in our report because the adverse consequences of doing so would reasonablybe expected to outweigh the public interest benefits of such communication.
16. We did not audit the financial information of 807 branches and other officesincluded in the financial statements of the Bank whose financial information reflectstotal assets of H 32376.55 crores as at 31 March 2021 and total revenue of H3714.04 crores for the year ended on that date as considered in the financialstatements. The financial information of these branches have been audited by the statutorybranch auditors whose reports have been furnished to us by the management and our opinionon the financial statements in so far as it relates to the amounts and disclosuresincluded in respect of branches and our report in terms of sub-section (3) of Section 143of the Act in so far as it relates to the aforesaid branches is based solely on thereports of such statutory branch auditors. Out of the aforesaid branches in case of 8branches the statutory branch auditors have relied on alternative audit procedures onaccount of restrictions on physical visit to their branches as per their reports.
Our opinion on the financial statements and our report on other legal and regulatoryrequirements below are not modified in respect of the above matters with respect to ourreliance on the work done by and the reports of the statutory branch auditors.
Report on Other Legal and Regulatory Requirements
17. The Balance Sheet and the Profit and Loss Account have been drawn up in accordancewith the provisions of section 29 of the Banking Regulation Act 1949 and section 133 ofthe Act read with rule 7 of the Companies (Rules) 2014 (as amended).
18. As required by sub-section (3) of section 30 of the Banking Regulation Act 1949we report that:
a) we have obtained all the information and explanations which to the best of ourknowledge and belief were necessary for the purpose of our audit and have found them tobe satisfactory;
b) the transactions of the Bank which have come to our notice have been within thepowers of the Bank;
c) the returns received from the offices; and branches of the Bank have been foundadequate for the purposes of our audit.
19. With respect to the matter to be included in the auditor's report under section197(16) of the Act we report that since the Bank is a banking company as defined underthe Banking Regulation Act 1949; the reporting under section 197(16) in relation towhether the remuneration paid by the Bank is in accordance with the provisions of section197 of the Act and whether any excess remuneration has been paid in accordance with theaforesaid section is not applicable.
20. Further as required by section 143 (3) of the Act based on our audit and on theconsideration of the reports of the statutory branch auditors as referred to in paragraph16 above we report to the extent applicable that:
a) we have sought and obtained all the information and explanations which to the bestof our knowledge and belief were necessary for the purpose of our audit of theaccompanying financial statements;
b) in our opinion proper books of account as required by law have been kept by theBank so far as it appears from our examination of those books and proper returns adequatefor the purposes of our audit have been received from the branches not visited by us;
c) the reports on the accounts of the branch offices of the Bank audited under section143(8) of the Act by the statutory branch auditors of the Bank have been sent to us andhave been properly dealt with by us in preparing this report;
d) the financial statements dealt with by this report are in agreement with the booksof account and with the returns received from the branches not visited by us;
e) in our opinion the aforesaid financial statements comply with Accounting Standardsprescribed under section 133 of the Act read with rule 7 of the Companies (Accounts)Rules 2014 (as amended) to the extent they are not inconsistent with the accountingpolicies prescribed by RBI;
f) on the basis of the written representations received from the directors and taken onrecord by the Board of Directors none of the directors is disqualified as on 31 March2021 from being appointed as a director in terms of section 164(2) of the Act;
g) we have also audited the internal financial controls with reference to the financialstatements of the Bank as on 31 March 2021 in conjunction with our audit of the financialstatements of the Bank for the year ended on that date and our report dated 28 May 2021 asper Annexure A expressed unmodified opinion; and
h) with respect to the other matters to be included in the Auditor's Report inaccordance with rule 11 of the Companies (Audit and Auditors) Rules 2014 (as amended) inour opinion and to the best of our information and according to the explanations given tous:
i. the Bank as detailed in schedule 12 and notes 9.8 and 10.9 of schedule 18 to thefinancial statements has disclosed the impact of pending litigations on its financialposition as at 31 March 2021;
ii. the Bank as detailed in schedule 12 and note 9.8 of schedule 18 to the financialstatements has made provision as at 31 March 2021 as required under the applicable lawor accounting standards for material foreseeable losses if any on long-term contractsincluding derivative contracts;
iii. there has been no delay in transferring amounts required to be transferred tothe Investor Education and Protection Fund by the Bank during the year ended 31 March2021; and iv. the disclosure requirements relating to holdings as well as dealings inspecified bank notes were not applicable to the banking companies and pertained to theperiod from 8 November 2016 to 30 December 2016 which are not relevant to thesefinancial statements. Hence reporting under this clause is not applicable.
Annexure A to the Independent Auditor's report of even date to the members of the KarurVysya Bank Limited on the financial statements for the year ended 31 March 2021
Independent Auditor's Report on the internal financial controls with reference to thefinancial statements under Clause (i) of Sub-section 3 of Section 143 of the CompaniesAct 2013 (the Act')
1. In conjunction with our audit of the financial statements of The Karur Vysya BankLimited (the Bank') as at and for the year ended 31 March 2021 we have audited theinternal financial controls with reference to financial statements of the Bank as at thatdate.
Responsibilities of Management and Those Charged with Governance for Internal FinancialControls
2. The Bank's Board of Directors is responsible for establishing and maintaininginternal financial controls based on the internal financial controls with reference tofinancial statements criteria established by the Bank considering the essential componentsof internal control stated in the Guidance Note on Audit of Internal Financial Controlsover Financial Reporting issued by the Institute of Chartered Accountants of India. Theseresponsibilities include the design implementation and maintenance of adequate internalfinancial controls that were operating effectively for ensuring the orderly and efficientconduct of the Bank's business including adherence to the Bank's policies thesafeguarding of its assets the prevention and detection of frauds and errors theaccuracy and completeness of the accounting records and the timely preparation ofreliable financial information as required under the Act.
Auditor's Responsibility for the Audit of the Internal Financial Controls withReference to Financial Statements
3. Our responsibility is to express an opinion on the Bank's internal financialcontrols with reference to financial statements based on our audit. We conducted our auditin accordance with the Standards on Auditing issued by the Institute of CharteredAccountants of India (ICAI') prescribed under Section 143(10) of the Act to theextent applicable to an audit of internal financial controls with reference to financialstatements and the Guidance Note on Audit of Internal Financial Controls Over FinancialReporting (the Guidance Note') issued by the ICAI. Those Standards and the GuidanceNote require that we comply with ethical requirements and plan and perform the audit toobtain reasonable assurance about whether adequate internal financial controls withreference to financial statements were established and maintained and if such controlsoperated effectively in all material respects.
4. Our audit involves performing procedures to obtain audit evidence about the adequacyof the internal financial controls with reference to financial statements and theiroperating effectiveness. Our audit of internal financial controls with reference tofinancial statements includes obtaining an understanding of such internal financialcontrols assessing the risk that a material weakness exists and testing and evaluatingthe design and operating effectiveness of internal control based on the assessed risk. Theprocedures selected depend on the auditor's judgement including the assessment of therisks of material misstatement of the financial statements whether due to fraud or error.
5. We believe that the audit evidence we have obtained is sufficient and appropriate toprovide a basis for our audit opinion on the Bank's internal financial controls withreference to financial statements.
Meaning of Internal Financial Controls with Reference to Financial Statements
6. A company's internal financial controls with reference to financial statements is aprocess designed to provide reasonable assurance regarding the reliability of financialreporting and the preparation of financial statements for external purposes in accordancewith generally accepted accounting principles. A company's internal financial controlswith reference to financial statements include those policies and procedures that (1)pertain to the maintenance of records that in reasonable detail accurately and fairlyreflect the transactions and dispositions of the assets of the company; (2) providereasonable assurance that transactions are recorded as necessary to permit preparation offinancial statements in accordance with generally accepted accounting principles and thatreceipts and expenditures of the company are being made only in accordance withauthorisations of management and directors of the company; and (3) provide reasonableassurance regarding prevention or timely detection of unauthorised acquisition use ordisposition of the company's assets that could have a material effect on the financialstatements.
Inherent Limitations of Internal Financial Controls with Reference to FinancialStatements
7. Because of the inherent limitations of internal financial controls with reference tofinancial statements including the possibility of collusion or improper managementoverride of controls material misstatements due to error or fraud may occur and not bedetected. Also projections of any evaluation of the internal financial controls withreference to financial statements to future periods are subject to the risk that theinternal financial controls with reference to financial statements may become inadequatebecause of changes in conditions or that the degree of compliance with the policies orprocedures may deteriorate.
8. In our opinion and based on the consideration of the reports of the statutorybranch auditors as referred to in paragraph 16 of our report on the audit of the financialstatements the Bank has in all material respects adequate internal financial controlswith reference to financial statements and such controls were operating effectively as at31 March 2021 based on the internal financial controls with reference to financialstatements criteria established by the Bank considering the essential components ofinternal control stated in the Guidance Note on Audit of
Internal Financial Controls over Financial Reporting issued by the Institute ofChartered Accountants of India.
For Walker Chandiok & Co LLP
Firm's Registration No.: 001076N/N500013
Membership No.: 206229
Date: May 28 2021