CENTRAL ELECTRICITY REGULATORY COMMISSION

NEW DELHI

Petition No. 197/GT/2013

Coram:
Shri Gireesh B. Pradhan, Chairperson
Shri A.K.Singhal, Member
Date of Hearing:
Date of Order:

29.05.2014
10.07.2015

In the matter of
Approval of tariff for Circulating Fluidized Bed Combustion (CFBC) Technology based
Barsingsar Thermal Power Plant (2 x 125 MW) of Neyveli Lignite Corporation Ltd for the
period from the date of commercial operation of Unit-I and II till 31.3.2014.
And
In the matter of
Neyveli Lignite Corporation,
Neyveli House,
135, EVR Periyar Road, Kilpauk,
Chennai -600 010

Petitioner

Vs
1. Jodhpur Vidyut Vitran Nigam Ltd,

New Power House,

Heavy Industrial Area,
Jodhpur, Rajasthan
2. Jaipur Vidyut Vitran Nigam Ltd.
VidyutBhawan, Janpath,
Jaipur, Rajasthan 302 005
3. Ajmer Vidyut Vitran Nigam Ltd.
Old Power House Hathi Bhata,
Jaipur Road,
Ajmer, Rajasthan

Respondents

Parties present:
For Petitioner:

Order in Petition No. 197/GT/2013

Shri M.G Ramachandran, Advocate, NLC

Ms. Anushree Bardhan, Advocate, NLC
Shri K. Nambirajan, NLC
Shri N.Murthy, NLC

Page 1 of 39

ORDER
This petition has been filed by the petitioner, Neyveli Lignite Corporation Ltd (NLC)
for approval of tariff of Circulating Fluidized Bed Combustion (CFBC) Technology based
Barsingsar Thermal Power Plant (2 x 125 MW) (hereinafter referred to as the generating
station) for the period from the commercial date of operation of Units-I and II till 31.3.2014
based on the Central Electricity Regulatory Commission (Terms and Conditions of Tariff)
Regulations, 2009 (hereinafter referred as the 2009 Tariff Regulations).

2.

The generating station with an installed capacity of 250 MW comprises of two units of

125 MW each with Circulating Fluidised Bed Combustion lignite fired boilers feeding to
Turbines. The allocation of power to the respondents is based on the Energy department
Govt of Rajasthans letter dated 29.9.2011.
3.

Petition No.171/2009 was filed by the petitioner for approval of tariff of the generating

station from the anticipated date of commercial operation of the Units during the year 2011
based on the 2009 Tariff Regulations and the Commission by order dated 20.6.2011
disposed of the same as under:
8. Accordingly, this petition is disposed of with a direction that the petitioner is at liberty to
approach the Commission with a fresh petition for approval of tariff for the generating station
in accordance with the provisions of the 2009 regulations, taking into account the revised
capital expenditure on account rescheduling of the units of the generating station, which
would be considered in accordance with law. We also direct that the petition shall be posted
in the web-site of the petitioner and copy be served on the respondents/objectors, who are at
liberty to file their reply/objections thereafter.

4.

Since Units I and II of the generating station were commissioned on 20.1.2012 and

29.12.2011 respectively, the petitioner, in terms of the liberty granted by Commission's

order dated 20.6.2011 has filed this petition for fixation of tariff for Unit-II of the generating
station for the period from 29.12.2011 to 19.1.2012 and for Units I & II for the period from
20.1.2012 to 31.3.2014 in accordance with the provisions of the 2009 Tariff Regulations.

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5.

The Commission by order dated 4.10.2012 has granted provisional tariff considering

the opening capital cost of `87134.00 lakh as on 29.12.2011, subject to adjustment after
determination of final tariff of the generating station.
6.

The capital cost (as per affidavit dated 13.6.2014) and the annual fixed charges

claimed by the petitioner for the period from 29.12.2011 to 31.3.2014 is as under:
Capital Cost

(` in lakh)

Capital Cost as per RCE-II

Less: IDC on actual loan included in above
Less : Liabilities included
Add: IDC including interest. on Normative loan
Opening Capital Cost
Add: Additional Capital Expenditure.
Closing Capital cost

Unit-II (as on
29.12.2011)
93404.00
15117.00
6270.00
16892.79
88919.79
0.00
88919.79

Unit-I (as on
20.1.2012)
186871.00
30488.00
12011.00
35629.52
180001.50
101.00
180102.50

Annual Fixed Charges

Return on Equity
Interest on Loan
Depreciation
Interest on Working Capital
O&M Expenses
Secondary fuel oil cost
Compensation allowance
Special allowance
Total Annual Fixed Charges

7.

(` in lakh)

2011-12
29.12.2011
20.1.2012 to
to 19.1.2012
31.3.2013
6120
12393
6227
12460
7523
15206
802
1611
3353
6705
606
1212
24631
49589

2012-13

2013-14

12810
12156
14309
1615
7090
1209
49189

13224
11645
9560
1540
7495
1209
44673

Reply to the petition has been filed by the respondents. In addition to this, separate

comments on the petition have been filed by Shri Shanti Prasad and Shri G.L.Sharma,
Consumers from Jaipur. The petitioner has filed rejoinder to the replies filed by the
respondents and also the response to the comments filed by the said consumers.

Commissioning Schedule
8.

The petitioner has submitted that the project was sanctioned by the Govt of India on

15.12.2004 for an approved cost of `1114.18 crore with the scheduled date of commercial

Order in Petition No. 197/GT/2013

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operation of Unit-I in December, 2008 and Unit-II in June, 2009. The details of the
scheduled and the actual dates of commercial operation of the units of the generating
station as per the Investment Approval is summarised as under:
Unit

I
II

9.

Schedule COD as per

investment Approval
dated 15.12.2004
15.12.2008
15.6.2009

Actual COD

Time overrun
(months)

20.1.2012
29.12.2011

37
30.5

It is observed from the above that as against the schedule COD as per investment

approval, there is a time overrun of about 37 months for Unit-I and 30.5 months for Unit-II
of the generating station.

Admissibility of Additional Return on Equity

10. The actual COD of the Unit-I and Unit-II is 20.1.2012 and 29.12.2011 respectively.
Accordingly, Unit-II has been declared under commercial operation after 84.5 months and
Unit-I has declared under commercial operation after 85 months from the date of LOA
(15.12.2004). In order to avail additional ROE of 0.5%, the time line as specified in the
2009 Tariff Regulations for completion of different units of a green filed project for 125 MW
unit size (CFBC) is 33 months for the first Unit and subsequent Units at an interval of 4
months from the date of Investment Approval. Since the project has not been completed
within the time line specified by the Commission, these units of the generating station are
not entitled to additional return on equity of 0.5% in terms of the 2009 Tariff Regulations.
Time Overrun
11. As regards time overrun, the petitioner vide affidavit dated 16.3.2012 while justifying
the reasons for time overrun has submitted that the 125 MW CFBC boilers are being
installed for the first time and the Circulating Fluidised Bed Combustion (CFBC) boiler are
different from the conventional pulverized fuel boiler which are used in other power plants.
The petitioner has submitted that the delay of 36 months for Unit-I and 30 months for UnitII are mainly on account of:

Order in Petition No. 197/GT/2013

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(i) Increased work quantum specific to CFBC in respect of tonnage erection (about 2
times), site welding joints (about 3 times), refractory leading to more time consumption for
their erection and operation works as can be seen from the comparative table below:

Erection Quantity
Site Welding Joints
Refractory Application

CFBC Boiler Conventional

Boilers
30000 tons
16000 tons
56000 joints
19500 joints
4720 tons
50 tons

(ii) Delayed execution of works by the Main Plant Package contractor M/s BHEL in the
field of engineering, finalization of civil and erection sub-contractors for boiler island and
power house, supply of equipments and slow progress of erection works.
(iii)

Delay after synchronization (Unit-I synchronized on 27.10.2009 and Unit-II

synchronized on 5.6.2010) as a result of frequent and long shutdown of the units due to
various reasons such as repeated cyclone chokes, repeated failure of fluidized bed heat
exchanger tubes, differential temperature problem in the turbine top and bottom casings.
(iv) Complete replacement of bunker liners with stainless steel material.
12. In addition to the above, the problems faced and the reasons for time overrun as
submitted by the petitioner in Annexure-I of the said affidavit dated 16.3.2012 are as
under:

(i) Government of India had sanctioned the Barsingsar Mine cum Thermal

Power

Project on 15.12.2004 with the following stipulations:

GOI Sanction
Unit-I Synchronizing
Unit-II Synchronizing
Unit-I COD
Unit-II COD

Time stipulation
Zero date
45 months
51 months
48 months
54 months

Scheduled date
15.12.2004
14.9.2008
14.3.2009
14.12.2008
14.6.2009

(ii) However due to various delays in design & engineering, manufacture & supplies,
erection of equipments from by M/s BHEL units, there had been delay in commissioning

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of both the units and after liquidating the issues, the units could be commissioned
belatedly as shown under:
Occurrence
date
Unit-I Synchronizing
i. With oil firing
ii. With lignite firing
B Unit-II Synchronizing
i. With oil firing
ii. With lignite firing
C Unit-I COD
D Unit-II COD

Quantified
delay

27.10.2009
29.12.2009

14 months
16 months

5.6.2010
25.8.2010
20.1.2012
29.12.2011

15 months
18 months
37 months
31 months

13. The petitioner has submitted that a delay of 16 to 18 months had occurred for
synchronizing the units with the designated fuel (lignite) due to unorganized supplies from
various manufacturing units of M/s BHEL on the supply fronts and due to non-availability
of skilled man power as well as extreme climatic conditions prevailing in this region on the
erection fronts. It has also submitted that even after synchronising the units with the
designated fuel (lignite), the performance of the units were far below expectations as both
the units had suffered setbacks in reaching the rated capacities of the machine. The
outages of the units on account of various constraints have been listed by the petitioner as
detailed under:
Unit-I
From
10.1.2010
30.1.2010
18.3.2010
31.3.2010
20.4.2010
7.8.2010
13.10.2010
14.4.2011
1.3.2011
26.4.2011

To
Days
Reasons for major outages in Unit-I
27.1.2010
18
Turbine HP Casing T/B DT high, Insulation changed to Spray
type Min wool with sodium silicate
17.3.2010
63
Right side cyclone Choke
30.3.2010
13
Left Side cyclone choke
18.4.2010
19
Left Side cyclone choke
26.4.2010
7
Left Side cyclone choke
8.10.2010
65
Lignite Bunkers SS Liners Replacement
1.11.2010
19
Right Side cyclone choke
17.2.2011
35
FBHE Evaporator Coils
Rifled Tubes Failure
17.4.2011
48
FBHE Evaporator Coils
Rifled Tubes Failure
29.7.2011
95
FBHE Evaporator Rifled Tubes 282 Tubes (47x6) cutting,
inspection, welding, hydro testing, HP Turbine angle rings
modification, FBHE/Seal pot partition water walls Riser Tubes
modification, (4 nos each left and right), Emergency Boiler
Feed Pump Repair etc.

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22.9.2011 19.10.2011

10.12.2011 28.12.2011

30.12.2011 31.12.2011

27

EBFP restoration (after repair from Sultzer, Caterpillar,

Enpro) & Its ARV, Engine servicing etc done. Minor refractory
repairs at SUB1 mouth, SA Duct inlet to combustor,
combustor to cyclone inlet expansion joint insulation blankets
packing done.
RT modification (1 No each side RT 63 & 76) of the SPWW
Manhole header, headers reorientation (for changing the RT
stub position from side to the top) carried out. (Both sides)
SPWW Panel SP1 to SH4 header cut, spool pieces added
and reorientation done.
Initial operation was completed and unit was shut down to
attend front MS line thermocouple right leak Thermowell
broken inside. Same was replaced.

Unit-II
From
29.6.2010
30.11.2010
31.3.2011

To
9.8.2010
15.1.2011
15.6.2011

Days
Reasons for major outages in Unit-II
42
Lignite Bunker SS Liner Replacement
47
Right Side Cyclone choking
77
Seal Pot Panel Water Wall Tubes starvation failure, Refractory
Damages, NMEJ Left side repairs, (Ash Cooler Vent bends
refractory relined)m Boiler License Renewal Inspection done on
5.5.2011
26.6.2011
13.7.2011
18
FBHE/Sealpot water wall (partition Wall) starvation failure.
(Riser Tubes of corresponding headers to drum are to be
modified with 1 positive slope towards drum)
18.7.2011
30.9.2011
75
Unit-II Seal pot (left) water wall puncture (hairline crack along
fin), Riser tubes slope modifications done. Supports were
strengthened in that area. Angle rings modification works in HP
Turbine.
1.10.2011 11.10.2011
11
Right side Cyclone Choke (Cyclone to seal pot pr.
measurement signal interference was being attended and the
same was in forced condition, the sudden drop in Combustor
Pressure led to emergency leading to cyclone accumulation).
Entire work of removal of choke was done by NLC.
28.10.2011 5.11.2011
10
Left side cyclone choke (dislodged by NLC from 29.11.2011 to
3.11.2011) Cleaning of Seal pot, FBHE, nozzles etc done
before light up FBHE1 grate Sync6.11.2011
26.11.2011 15.12.2011
20
Seal Pot water wall Left Side puncture. Due to repetitive nature
of the failure, BHEL was referred. BHEL suggested RT
modification.
29.12.2011 11.1.2012
13
Both PA fans 2A & 2B were not available due to bearing failure

14. The respondents JVVNL, JoVVNL and AVVNL have submitted that the delay of 37
months in the commissioning of the project is an indication of inefficiency / incompetency /
lack of seriousness on the part of generating company. The respondents have also
submitted that a similar project in Rajasthan involving more work than this project had
completed their units in a period of 36 months from the date of PPA. They have stated that
the delay has hit the discoms financially in many ways such as:

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(a)

Due to the delay in the energy was purchased at a higher rate.

(b)
Transmission charges have been borne for no use/partly use of transmission system
associated with the project.
(c)

The cash flow of the discoms was also affected adversely.

15. Shri G.L. Sharma, Consumer, in his comments has submitted that the principles laid
down by the Appellate Tribunal for Electricity in its judgment dated 27.4.2011 in Appeal
No.72/2010 may be considered while dealing the issue of time and cost overrun. He has
also submitted that the reasons given by the petitioner for delay are nothing but lame
excuses and that the petitioner should have foreseen these eventualities while adopting
the CFBC technology and giving the schedule for commissioning. Since there is
imprudence on the part of the petitioner, it has to bear the additional cost on this account.
He has further submitted that the penalties/LD recovered by the petitioner should be
deducted from the total capital cost of the project. Shri Shanti Prasad, Consumer, in his
comments dated 30.3.2012 has suggested that as part of prudence check, comparative
study of time and cost overrun may be carried out through expert bodies like CEA before
approving the project cost. He has also submitted that the capital cost to be considered for
the purpose of tariff may be reduced by the recovery of `129.88 crore as liquidated
damages by the petitioner from M/s BHEL and the amount received from the sale of infirm
power from the generating station. In response to the reply of the respondents and
comments of the consumers, the petitioner has clarified that (a) the increased quantum of
work specific to CFBC boilers in respect of tonnage erection (as against conventional
boilers) leading to more time consumption (b) delayed execution of works by the main
contractor M/s BHEL (c) delay after synchronisation as a result of frequent and long
shutdown of the units due to various reasons such as repeated cyclones chokes (d)
complete replacement of bunker liners and (d) frequent agitation by local villagers to meet
their various demands etc, had all resulted in the delay in COD which are beyond the

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control of the petitioner. It has also been submitted that despite these, the petitioner has
taken utmost care in the commissioning the project.

16. We have examined the matter. The Appellate Tribunal for Electricity in its judgment
dated 27.4.2011 in Appeal No. 72 of 2010 (MSPGCL v MERC & ors) has laid down the
following principles for prudence check of time over run and cost overrun of a project as
detailed under:
7.4. The delay in execution of a generating project could occur due to following reasons:
i.
Due to factors entirely attributable to the generating company, e.g., imprudence in
selecting the contractors/suppliers and in executing contractual agreements including terms
and conditions of the contracts, delay in award of contracts, delay in providing inputs like
making land available to the contractors, delay in payments to contractors/suppliers as per
the terms of contract, mismanagement of finances, slackness in project management like
improper co-ordination between the various contractors, etc.
ii
Due to factors beyond the control of the generating company e.g. delay caused due to
force majeure like natural calamity or any other reasons which clearly establish, beyond any
doubt, that there has been no imprudence on the part of the generating company in
executing the project.
iii.

Situation not covered by (i) & (ii) above.

In our opinion in the first case the entire cost due to time over run has to be borne by
the generating company. However, the Liquidated damages (LDs) and insurance proceeds
on account of delay, if any, received by the generating company could be retained by the
generating company. In the second case the generating company could be given benefit of
the additional cost incurred due to time over-run. However, the consumers should get full
benefit of the LDs recovered from the contractors/supplied of the generating company and
the insurance proceeds, if any, to reduce the capital cost. In the third case the additional cost
due to time overrun including the LDs and insurance proceeds could be shared between the
generating company and the consumer. It would also be prudent to consider the delay with
respect to some benchmarks rather than depending on the provisions of the contract
between the generating company and its contractors/suppliers. If the time schedule is taken
as per the terms of the contract, this may result in imprudent time schedule not in
accordance with good industry practices.
7.5 in our opinion, the above principle will be in consonance with the provisions of Section
61(d) of the Act, safeguarding the consumers interest and at the same time, ensuring
recovery of cost of electricity in a reasonable manner.

17. The petitioner in compliance with the directions of the Commission has submitted
additional information vide affidavit dated 19.7.2012 on the issue of time overrun and cost
overrun and has indicated the category-wise increase/decrease in the project cost from
the scheduled dates of commissioning upto the actual date of commissioning. It has also

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submitted that the actual amount of LD recovered from the EPC contractor M/s BHEL for
the delay in the project is Rs 68.36 lakh and Rs 61.52 lakh was released against the Bank
Guarantee equal to the LD amount.

18. The petitioner has submitted that the 125 MW CFBC boilers are being installed for
the first time by the petitioner and the CFBC boilers are different from the conventional
pulverised fuel boilers which are being used in other power plants. The reasons for delay
in completion of the project as submitted by the petitioner can be categorised as under:
(a) Delay of 16 months for Unit-I and 18 months for Unit-II for the period during construction till
the synchronization of the respective units; and
(b) Delay of 21 months for Unit-I and 13 months for Unit-II from synchronization to actual COD
of the respective units.

19. The major reasons for the delay of 16 months for Unit-I and 18 months for Unit-II in
construction of the project till synchronization of the units is mainly due to increased work
quantum specific to CFBC boiler as compared to conventional boilers of same capacity in
respect of tonnage erection (two times), site welding joints (there times) and refractory
application etc. It is also noticed that there were recurring problems in CFBC like failure of
fluidised bed heat exchanger tubes, differential temperature problem in turbine top and
bottom casings. Accordingly, the petitioner has submitted that the reason for such failures
is on account of the fact that CFBC boilers are being installed for the first time by the
petitioner and are different from the conventional pulverised fuel boilers used in other
power plants. It is observed that the petitioner had adopted the CFBC technology keeping
in view its suitability for low grade fuel like lignite apart from other advantages like the
technology being environment friendly and highly reliable, simplified fuel preparation and
feeding with compact plant design and sustainability under cyclic loading. The petitioner
having adopted a clean and new technology considering its merits and advantages
derived (which outweigh limitations) in the form of higher efficiency, lower environmental

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pollution and cheaper power and having engaged M/s BHEL which is the largest and
reliable indigenous manufacturer with experience in manufacture, supply and erection of
CFBC boiler as EPC contractor and fixed the time schedules accordingly, cannot, in our
view, be held fully responsible for the delay in completion of the project on account of
various problems faced during design, engineering and manufacturing stage and also in
stabilization of CFBC boiler under Indian conditions. According to us, the problems faced
in the construction stage could not have been foreseen considering the fact that the
development of the technology, apart from being new, is still at a very early stage. It is
noticed that the Commission in its order dated 22.8.2013 in Petition No. 28/2011,
pertaining to Sipat STPS-I of NTPC had condoned the time overrun considering various
factors associated with the execution of the project based on super critical technology.
Applying the said principle for this case, we find that the delay of 16 months for Unit-I and
18 months for Unit-II (i.e. during the construction of the project till the synchronisation of
the units) is for reasons associated with the adoption of new technology. Accordingly, we
are inclined to condone the said delay on this count.

20. It is observed that the delay of 21months for Unit-I and 13 months for Unit-II from the
synchronization of the units till the actual COD of the units as stated by the petitioner is on
account of the frequent and long shutdown of the units due to frequent cyclone chokes in
both the units, HP casing temperature differential problems, Evaporator coil rifled tubes
failure, PA fan 2A vibration problem. Also, being a new technology, the cause analysis and
remedial measures attempted by M/s. BHEL (by trying successive attempts) has
consumed more time leading to outages for longer periods. It is further noticed that other
problems like frequent shearing of polymer liners, refractory damages in both the units,
Emergency boiler feed pump failure, VFD drive problem in ID fans, frequent failure of SA
Fans, failure of excitation over voltage protection, turbine speed measurement problem,
compressors problem, over loading of SA fans, super heater problems, main ejector

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flange gasket failure, plate heat exchanger chocking, DMCW vibration, HFO pump failure
etc. have also contributed to the delay in the commissioning of the units. Accordingly, the
petitioner has submitted that in order to facilitate the modification / rectification of defects,
various measures / repairs were undertaken in both the units by M/s. BHEL and in all
occasions, BHEL had to fix up a suitable agency which took considerable time in
mobilizing the manpower from their sub-vendors. It is evident from the said submissions of
the petitioner that the delay from synchronization of units till actual COD of the units is on
account of a long time taken by the agency for fixing the problems and also the delay in
fault rectification. Though this can be attributed to the use of new technology and the
exposure of manpower available with petitioner and M/s. BHEL with lesser expertise, a
considerable extent of delay could have been avoided if there was proper planning and
project management with better co-ordination between the contractor and sub-contractors
involved in the project. The delay due to lack of project management, co-ordination,
planning, un-organised work structure during the execution of project is not beyond the
control of the petitioner and the petitioner cannot escape responsibility for the said delay.
In our view, the problems resulting in delay cannot be said to be associated with the
execution of new technology in the project. Accordingly, we find no reason to condone the
time overrun of 21 months for Unit-I and 13 months for Unit-II in the execution of the
project.
21. From the discussions above, it emerges that the problems faced by the petitioner in
design, construction and manufacture stage and in stabilisation of CFBC boilers was on
account of adoption of new environment friendly technology which was intended for better
utilization of the scarce resources. As the development of this technology was still at an
early stage, these problems could not have been foreseen by the petitioner. However, the
factors such as the delay in supply of equipments, execution of work and slow progress of
erection works by the main plant contractor faced during the commissioning of the units

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and the time taken for fixing/rectifying the defects by the contractors/sub-contractors were
attributable to the petitioner. The reasons such as the adoption of new technology by the
petitioner which was still in an early stage coupled with the lack of co-ordination with the
contractors /sub-contractors leading to delay in execution of the project when examined in
the background of the judgment of the Tribunal dated 27.4.2011 as stated above, lead us
to the conclusion that the situation does not fall under the principles laid down in para 7.4
(i) and (ii) of the said judgment. Hence, the principle laid down in situation (iii) of the said
judgment is applicable in the present case. Accordingly, the impact of time and cost
overrun of 37 months for Unit I and 31 months for Unit II along with LD and Insurance
proceeds are required to be shared equally by the petitioner and the respondents. We
hold accordingly.
Capital Cost
22. Regulation 7(1) of the 2009 Tariff Regulations, provides as follows:
"The expenditure incurred or projected to be incurred, including interest during construction
and financing charges, any gain or loss on account of foreign exchange risk variation during
construction on the loan- (i) being equal to 70% of the funds deployed, in the event of the
actual equity in excess of 30% of the finds deployed, by treating the excess equity as
normative loan, or (i) being equal to the actual amount of loan in the event of the actual
equal less than 30% of the funds deployed, up to the date of commercial operation of the
project, as admitted by the Commission, after prudence check;
Capitalized initial spares subject of the ceiling rates specified in regulation 8; and
Additional capital expenditure determined under regulation 9:
Provided that the assets forming part of the project, but in use shall be taken out of the
capital cost.
The capital cost admitted by the Commission after prudence check shall form the basis for
determination of tariff;
Provided that in case of the thermal generating station and the transmission system,
prudence check of capital cost may be carried out based on the benchmark norms to be
specified by the Commission from time to time.

23. The petitioner vide affidavit dated 20.7.2012 has submitted that the original estimated
capital cost including IDC is `1114.18 crore approved on 15.12.2004 is based on March,
2004 price level. The Revised Cost Estimate (RCE-I) of `1626.09 crore was approved by

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the Govt. of India on 25.8.2009 based on June, 2007 price level. The petitioner has also
submitted that the difference between original estimated cost and revised cost is due to
variations such as price escalation, FC variation, additional taxes and duties, increase in
IDC and additional scope changes. Apart from these variations, boom in the infrastructure
development in power sector, market forces and remote locations of the project, there is
increase in cost despite initiative of petitioner for competitive bidding. It has therefore
stated that the Revised Cost Estimate (RCE-I) is 45.9% higher than the approved cost.
The main plant package cost as on March, 2004 price level was at `669.39 crore whereas,
the cost surged to `909.26 crore at June, 2007 price level. This package alone accounts
for 21.53% increase. The petitioner has added that similarly, Lignite Handling System
accounts for 11.65% increase and the increase in other packages, overheads and IDC
accounts to 12.76% increase. The petitioner has further stated that the Revised Cost
Estimate (RCE-II) of `1868.71 crore as approved by the Board of the petitioner company
is `242.62 crore higher than RCE-I dated 25.8.2009, which is mainly due to increase in
IDC on account of the delay in commissioning.

24. The capital cost as per RCE-II after abatement of capital cost due to income from
sale of infirm power before COD, fly ash and miscellaneous receipts etc. is as under:
(` in crore)

Project cost excluding IDC

IDC
Project cost including IDC
Less abatement:
Infirm power sales & Fly ash
Interest on advance
Misc. receipts
Project cost including IDC after abatement of capital cost

1664.73
304.88
1969.61
88.23
7.85
4.82
1868.71

25. The category wise increase/decrease in project cost from the schedule date of
commissioning up to the actual date of commissioning as submitted in affidavit dated
20.7.2012 is as under:

Order in Petition No. 197/GT/2013

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(` in crore)

RCE-I
June, 2007
1626.09

Base
Project cost
Price escalation
Change in F.E.
Statutory levies
Scope Change/price increase
Time overrun
Net increase in Project Cost

RCE-II
April, 2011
1868.71

1.53
2.47
(-)11.44
11.37
304.88
242.62

26. The actual capital cost as certified by the Auditor as on COD of Unit-I and Unit-II and
considered for the purpose of tariff is as under:
(` in crore)

Unit-II as on COD
29.12.2011
720.16
151.17
871.34

Capital cost excluding IDC

IDC
Capital cost including IDC

Unit-I/ generating station

as on COD 20.1.2012
1447.34
303.30
1750.64

27. Considering the fact that the impact of time and cost overrun for 37 months for Unit-I
and 31months for Unit-II is to equally shared by the parties, the IEDC claimed by the
petitioner is to be adjusted on pro rata basis. Accordingly, the pro rata reduction in IEDC
due to time overrun of Unit-I and II is worked out as under:

Unit-II
Unit-I/ generating
station

Total
period
taken from
zero date
to actual
COD
(months)
84.5
85

Time
overrun
disallowed
(months)

Overheads(Esta
blishment,
Audit&
Accounts,
Design and
Contingencies)

Pro-rata
reduction
(Col. 4 X
Col. 5 /
Col.2)

Total
reduction

97.66
202.33

35.25
88.07

17.625
44.035

(` in crore)

(` in crore)

(` in crore)

30.5
37

Infirm power
28. The petitioner vide affidavit dated 16.3.2012 has submitted that the value of infirm
power and fly ash is `88.23 crore. In response to the directions of the Commission to
provide the details of revenue earned from sale of infirm power after accounting for the
fuel expenses and from sale of fly ash separately from the date of synchronization up to
COD of the generating station, the petitioner vide affidavit dated 20.7.2012 has submitted

Order in Petition No. 197/GT/2013

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that infirm power bills of August, 2010, December, 2011and January, 2012 are yet to be
paid by the respondent discoms and the details will be furnished after receipt of payment
of infirm power bills and excess rebate availed by the respondents. In view of this, the
revenue earned from sale of infirm power and fly ash amounting to `88.23 crore has been
deducted from the capital cost of the generating station as on COD of the generating
station subject to truing-up. The petitioner is directed to furnish the details of revenue
earned from infirm power and fly ash (unit-wise) at the time of revision of tariff based on
truing-up exercise in terms of Regulation 6(1) of the 2009 Tariff Regulations.

Initial Spares
29. The petitioner has submitted that a sum of `22.83 crore towards cost of initial spares
is included in the project cost as on the actual date of commercial operation of the
generating station (20.1.2012) and there is no addition of cost on account of initial spares.
The cost of initial spares capitalised as on COD of the generating station works out to 1.3%
of the capital cost of `1750 crore claimed by the petitioner. Since the cost of spares
claimed is within the ceiling limit of 2.5% of the project cost as per Regulation 8 of the 2009
Tariff Regulations, the same has been allowed.

Liquidated Damages
30. The petitioner vide affidavit dated 20.7.2012 has submitted that an amount of
`129.88 crore (i.e LD for `68.36 crore and `61.52 crore for BG against LD amount) has
been recovered from M/s BHEL on account of the delay in the execution of the project.
Since the LD amount is to be equally shared by the petitioner and the respondents on
account of cost overrun due to time overrun, as decided above, the petitioner is at liberty
to retain only 50% of the amount recovered from the contractor.

Order in Petition No. 197/GT/2013

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31. Based on the above discussions and in consideration of the pro rata reduction of
IEDC and deduction of 50% of LD amount recovered, the capital cost (excluding IDC)
based on audited accounts works out as under:
(`in crore)

Capital cost Including IDC

IDC
Capital cost excluding IDC
Pro-rata reduction in IEDC (Overheads:
Establishment, Audit & Accounts, Design and
Contingencies)
Capital cost (excluding IDC) after pro rata
reduction in IEDC
Adjustment due to infirm power (provisional)
Adjustment of LD recovered (50%)
Capital cost for purpose of tariff

Unit-II as on
COD
29.12.2011
871.34
151.17
720.16
17.035

Unit-I / generating
station as on
COD 20.1.2012
1750.64
303.30
1447.34
44.035

703.125

1403.305

703.125

(-)88.23
(-)64.94
1250.135

Un-discharged liabilities
32. The amount of un-discharged liabilities as per Form-5B submitted vide affidavit dated
17.10.2012 is `118.08 crore and as per affidavit dated 13.6.2014 is `120.11 crore as on
COD of the generating station (20.1.2012). The petitioner was directed to furnish the
Balance Sheet as on COD of the generating station and the same has not yet been
furnished by the petitioner .Accordingly, the amount of `120.11 crore as on COD has been
considered towards un-discharged liabilities. The petitioner is however directed to submit
the actual details of un-discharged liabilities as on the COD of the units along with assetwise and party-wise details, the reconciliation of the un-discharged liabilities claimed vide
Form 5B with the balance sheet along with discharge of liabilities duly certified by the
Auditor at the time of revision of tariff based on truing up exercise in terms of Regulation
6(1) of the 2009 Tariff Regulations.

Loan position
33. The loan position as on COD of the generating station (20.1.2012) is as under:

Order in Petition No. 197/GT/2013

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(` in lakh)

Source of Loan
Amount of Gross Loan drawn upto COD as
per Form-7 and Form-8
Amount of gross loan drawn upto COD as
per the calculations of actual and normative
IDC furnished by the petitioner vide affidavit
dated16.3.2012 duly certified
Rate of Interest type
Rate of Interest as on the sanction date as
per loan agreement/ disclosure document
Reset of Interest rate

1st drawl date/ allotment date

RTL-I
RTL-II
Consortium of Banks
led by Canara Bank
67342.35
36632.00
67342.35

36000.00

Fixed
7.30%

Fixed
8.85%

Fixed for a
period of 5
years from
the date of
1st drawl
23.2.2006

Fixed for a
period of 3
years from
the date of
1st drawl
10.6.2010

NLC BOND

Total

14700.00

118674.35

14700.00

118042.00

Fixed
8.83%

23.1.2009

*-

34. It is evident from the above table that the total amount of loan drawn as on COD in
case of RTL-II differs from the details submitted in the Form and calculations for actual/
Normative IDC furnished by the petitioner.The bank statements furnished by the petitioner
provide the disbursals of loan amounts. As both the loans (RTL-I and RTL-II) are not
project specific loans but are only part of corporate loans allocated to the project,
therefore, the exact amount allocated to the project could not be ascertained from the
bank statement.The loan amount against RTL-II amounting to `36000.00 lakh as stated in
the Auditors certified statement has been considered for the purpose of tariff instead of the
amount of `36632.00 lakh furnished in Form-7 and Form-8. Since the details of repayment
of both the loans (RTL-I and RTL-II) from Canara Bank are available only upto 20.1.2012,
for the purpose of calculation of weighted average rate of interest, the repayments have
been considered as per the loan agreement for the period upto 31.3.2014. The petitioner
is directed to furnish the hard copies of loan agreement entered into with the bank, the
copies of all the correspondences/ communications with the bank regarding interest rate
reset / repayment rescheduling if any, interest calulation on the loan, indicating the exact
date of each drawal and repayment till 31.3.2014.

Order in Petition No. 197/GT/2013

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Rate of Interest
35. As per the documents submitted by the petitioner, the rate of interest applicable to
both the loans RTL-I and RTL-II is as under:
RTL-I

RTL-II

7.30% p.a.

8.85% p.a.

36. In case of RTL-I, the loan agreement provides that the loan shall carry a fixed rate of
interest @ 7.30% p.a. fixed for a period of 5 years from the date of 1 st drawl. Similarly, in
case of RTL-II, the rate of interest is subject to reset after 3 years from the date of 1st
drawl (10.6.2013). Though the petitioner has furnished a letter dated 12.2.2011 from the
Canara bank informing that the rate reset to 10.35% (BPLR-3.40%) with effect from
23.2.2011 with respect to RTL-I, no documentary evidence has been submitted by the
petitioner substantiating the actual rate reset in case of RTL-II. It is also observed that in
case of RTL-II, the petitioner has submitted the minutes of meeting dated 5.9.2012 held
between Canara bank and the petitioner in which the bank has requested the petitioner to
consider the reset of Interest as base rate + 0.85%, i.e. 11.35%. However, no subsequent
correspondences from the Bank have been furnished in confirmation of such reset of rate
of interest. The rate of interest as furnished by the petitioner in Form 7 and Form 8 is as
under:

Form-7
Form-8

RTL-I
8.97% p.a.
10.76% p.a.

RTL-II
9.36% p.a.
9.22%p.a.

37. While arriving at the Weighted Average Rate of Interest for calculation of actual IDC
and Normative IDC, it is observed that the rate of interest as applied by the petitioner is at
variance with the rates furnished in the documents available on record. The rate of interest
@ 7.30% (fixed for 5 years) as mentioned in the loan agreement and the reset rate of
interest @ 10.35% beyond 5 years with respect to RTL-I has been applied for the purpose
of calculation of weighted average rate. However, in the absence of any documentary

Order in Petition No. 197/GT/2013

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evidence in confirmation of the reset rate in case of RTL-II, the rate of interest as per loan
agreement @ 8.85% has been considered. For NLC bond, the rate of interest @8.83% as
per documents furnished by the petitioner has been considered for the purpose of tariff
calculations.

Interest During Construction (IDC)

38. The actual loans availed for the generating station and the interest during the
construction period on the debt availed for the project is calculated at the actual rates as
discussed in above paras. It is observed that the petitioner has not furnished the
methodology adopted for the unit-wise allocation of IDC and therefore, the ratio in which
the total IDC is apportioned by the petitioner between Units-I and II as on COD of the
generating station, has been applied for apportionment of IDC as of now. The petitioner is
however directed to furnish the details indicating the basis of the unit-wise allocation of
IDC at the time of revision of tariff through truing-up exercise. As such, in this order, 100%
of the accrued IDC has been considered till the scheduled COD of the units, whereas from
the scheduled COD of the units till the actual COD of the generating station only 50% of
the accrued IDC has been considered based on our observations at para 22 above.
Accordingly, the unit-wise IDC has been worked out and allowed for the purpose of tariff is
as under:
(`in lakh)

Units

IDC allowed up to scheduled

COD

IDC allowed during scheduled COD to

actual COD (time over-run)

Scheduled COD

100% of IDC
allowed

Scheduled COD to actual

COD

50% of the IDC

allowed

Unit-I

14.12.2008

2640.45

15.12.2008 to 20.1.2012

5804.42

Unit-II

14.6.2009

4120.34

15.6.2009 to 29.12.2011

4790.14

IDC allowed (a)

6760.79

IDC allowed (b)

10594.57

Total IDC allowed (a+b) = 17355.36

Order in Petition No. 197/GT/2013

Page 20 of 39

Normative IDC
39. The petitioner had not claimed Normative IDC in original petition vide affidavit dated
16.3.2012. However, the petitioner vide affidavit dated 13.6.2014 has submitted the
revised Form-14A showing the actual cash expenditure along with the calculation sheet
showing the calculations of actual as well as Normative IDC. The petitioner has claimed
the Normative IDC on the amount of equity in excess of 30% of the project cost on the
basis of the weighted average rate of interest of the loan portfolio of the project. It is
observed that the rate of interest considered by the petitioner while arriving at the
weighted average rate of interest is filled with inconsistencies. Accordingly, the rate of
interest for the calculation of Normative IDC considered and allowed is as under:

Rate of Interest
After reset of rate with effect from
23.2.2011(RTL-I)

40.

RTL-I
7.30% p.a.
10.35% p.a.

RTL-II
8.85% p.a.
-

NLC Bond
8.83%
-

For the calculation of Normative IDC allowed in tariff, the excess equity is

calculated by deducting the cumulative gross loan availed from 70% of the cumulative
total expenditure.

41.

Regulation 16(5) of the 2009 Tariff Regulations provides as under:

(5) The rate of interest shall be the weighted average rate of interest calculated on the basis
of the actual loan portfolio at the beginning of each year applicable to the project.
Provided that if there is no actual loan for a particular year but normative loan is still
outstanding, the last available weighted average rate of interest shall be considered.
Provided further that if the generating station or the transmission system, as the case may
be, does not have actual loan, then the weighted average rate of interest of the generating
company or the transmission licensee as a whole shall be considered.

42. In terms of above regulations, the petitioner has claimed the Normative IDC on the
expenditure incurred till December, 2004 and thereafter. The first drawl of actual loan was
made in February, 2006. The petitioner has worked out the Normative IDC for the period
prior to February, 2006 by considering the rate of interest @ 7.30% p.a. applicable to the

Order in Petition No. 197/GT/2013

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first drawl of loan. However, there was no actual loan for the generating station prior to
February, 2006. Hence, no weighted average rate of interest is available to work out the
Normative IDC prior to the actual drawl of the loan. Accordingly, no IDC has been allowed
prior to the actual drawl of the loan. The petitioner is directed to submit the weighted
average rate of interest for the company as a whole for the period prior to February, 2006
at the time of revision of tariff based on truing-up in order to work out the Normative IDC.
The cost overrun due to time overrun involved in the commissioning of the project has
been disallowed to the extent of 50% and this has been considered in respect of
Normative IDC allowed. Accordingly, the unit-wise Normative IDC is worked out and
allowed as under:
(` in lakh)

Units

Normative IDC allowed up to

scheduled COD
Scheduled COD

100% of IDC
allowed

Normative IDC allowed during time

over-run
Scheduled COD to
actual COD

50% of the IDC

allowed

Unit-wise
Total

Unit-I

14.12.2008

564.96

15.12.2008 to
20.1.2012

223.07

788.03

Unit-II

14.6.2009

592.99

15.6.2009 to
29.12.2011

190.84

783.83

Normative IDC
allowed (a)

1157.94

Normative IDC
allowed(b)

413.92

1571.86

Total Normative IDC allowed (a+b)= 1571.86

43. Interest on normative loan is to be treated as income in the Financial Statement i.e
Profit & Loss A/c and Balance Sheet by the petitioner as it form part of capital cost for the
purpose of allowing tariff.

Comparison of Capital Cost (Hard Cost) with benchmark capital cost

44. The capital cost worked out in para 31 above is based on the data submitted by the
petitioner which works out to `5.08 crore/MW. For the 125 MW unit (CFBC) no benchmark
cost has been specified by Commission. In respect of a Green field project of 500 MW unit
size with conventional boilers, the benchmark capital cost is `5.07 crore for the first unit

Order in Petition No. 197/GT/2013

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and `4.71 crore for the second unit. Since, the capital cost of `1750.64 crore incurred by
the petitioner is within the limits of the approved RCE of `1868.71 crore, the capital cost of
the generating station is acceptable.
Additional Capital Expenditure
45. Regulation 9 of the 2009 Tariff Regulations, as amended on 21.6.2011 and
31.12.2012, provides as under:
9. Additional Capitalization.(1) The capital expenditure incurred or projected to be incurred,
on the following counts within the original scope of work, after the date of commercial operation
and up to the cut-off date may be admitted by the Commission, subject to prudence check:
(i) Un-discharged liabilities;
(ii) Works deferred for execution;
(iii) Procurement of initial capital spares within the original scope of work, subject to the
provisions of regulation 8;
(iii) Liabilities to meet award of arbitration or for compliance of the order or decree of a court;
and
(v) Change in law:
Provided that the details of works included in the original scope of work along with estimates of
expenditure, un-discharged liabilities and the works deferred for execution shall be submitted
along with the application for determination of tariff.
(2) The capital expenditure incurred or projected to be incurred on the following counts after the
cut-off date may, in its discretion, be admitted by the Commission, subject to prudence check:
(i) Liabilities to meet award of arbitration or for compliance of the order or decree of a court;
(ii) Change in law;
(iii) Deferred works relating to ash pond or ash handling system in the original scope of work;
(iv) In case of hydro generating stations, any expenditure which has become necessary on
account of damage caused by natural calamities (but not due to flooding of power house
attributable to the negligence of the generating company) including due to geological reasons
after adjusting for proceeds from any insurance scheme, and expenditure incurred due to any
additional work which has become necessary for successful and efficient plant operation; and
(v) In case of transmission system any additional expenditure on items such as relays, control
and instrumentation, computer system, power line carrier communication, DC batteries,
replacement of switchyard equipment due to increase of fault level, emergency restoration
system, insulators cleaning infrastructure, replacement of damaged equipment not covered by
insurance and any other expenditure which has become necessary for successful and efficient
operation of transmission system:

Order in Petition No. 197/GT/2013

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Provided that in respect sub-clauses (iv) and (v) above, any expenditure on acquiring the minor
items or the assets like tools and tackles, furniture, air-conditioners, voltage stabilizers,
refrigerators, coolers, fans, washing machines, heat convectors, mattresses, carpets etc.
brought after the cut-off date shall not be considered for additional capitalization for
determination of tariff w.e.f. 1.4.2009.
(vi)In case of gas/liquid fuel based open/ combined cycle thermal generating stations, any
expenditure which has become necessary on renovation of gas turbines after 15 year of
operation from its COD and the expenditure necessary due to obsolescence or non-availability
of spares for successful and efficient operation of the stations.
Provided that any expenditure included in the R&M on consumables and cost of components
and spares which is generally covered in the O&M expenses during the major overhaul of gas
turbine shall be suitably deducted after due prudence from the R&M expenditure to be allowed.
(vii) Any capital expenditure found justified after prudence check necessitated on account of
modifications required or done in fuel receipt system arising due to non-materialisation of full
coal linkage in respect of thermal generating station as result of circumstances not within the
control of the generating station.
(viii) Any un-discharged liability towards final payment/withheld payment due to contractual
exigencies for works executed within the cut-off date, after prudence check of the details of
such deferred liability, total estimated cost of package, reason for such withholding of payment
and release of such payments etc.
(ix) Expenditure on account of creation of infrastructure for supply of reliable power to rural
households within a radius of five kilometres of the power station if, the generating company
does not intend to meet such expenditure as part of its Corporate Social Responsibility.

46. The petitioner has claimed additional capital expenditure under Regulation 9 (1) (i) of
the 2009 Tariff Regulations as under:
(` in lakh)

2011-12
101.00

2012-13
12011.00

47. The petitioners claim of additional capital expenditure amounting to `101.00 lakh
during 2011-12 is towards expenditure on certain infrastructure facilities such as
residential accommodation, vehicles etc., to be provided to CISF deployed at the
generating station the cost of which is to be borne by the petitioner. The petitioner has
submitted that considering the remote location of the project and its proximity to the border
CISF is mandated to provide security and the cost incurred for providing infrastructural
facilities may be allowed as additional capital expenditure for 2011-12. In view of the
submissions the expenditure of `101.00 lakh in 2011-12 is allowed. For the period 201213, the petitioner has claimed an amount of `12011.00 lakh towards discharge of liabilities

Order in Petition No. 197/GT/2013

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on projected basis in respect of the balance work within original scope of work to be
completed within the cut-off date of 31.3.2015. This claim has been considered and
allowed for the purpose of tariff. The petitioner is however directed to submit the assetwise, party-wise and year-wise details of discharge of liabilities at the time of revision of
tariff based on truing-up exercise in terms of Regulation 6(1) of the 2009 Tariff
Regulations.
48. Based on the above, the capital cost considered for the purpose of tariff is as under:
(` in lakh)

Capital Cost on cash basis (excluding IDC)

Add: IDC
Add: Normative IDC
Opening Capital Cost (including IDC)

Unit-II
(as on 29.12.2011)
70312.50
8910.48
788.03
80011.01

Unit-I & II
(as on 20.1.2012)
125013.50
17355.36
1571.86
143940.71

Debt-Equity Ratio
49. Regulation 12 of the 2009Tariff Regulations provides as under:
(1) For a project declared under commercial operation on or after 1.4.2009, if the equity
actually deployed is more than 30% of the capital cost, equity in excess of 30% shall be treated
as normative loan.
Provided that where equity actually deployed is less than 30% of the capital cost, the actual
equity shall be considered for determination of tariff.
Provided further that the equity invested in foreign currency shall be designated in Indian
rupees on the date of each investment.
Explanation.-The premium, if any, raised by the generating company or the transmission
licensee, as the case may be, while issuing share capital and investment of internal resources
created out of its free reserve, for the funding of the project, shall be reckoned as paid up
capital for the purpose of computing return on equity, provided such premium amount and
internal resources are actually utilised for meeting the capital expenditure of the generating
station or the transmission system.
(2) In case of the generating station and the transmission system declared under commercial
operation prior to 1.4.2009, debt-equity ratio allowed by the Commission for determination of
tariff for the period ending 31.3.2009 shall be considered.
(3) Any expenditure incurred or projected to be incurred on or after 1.4.2009 as may be
admitted by the Commission as additional capital expenditure for determination of tariff, and
renovation and modernisation expenditure for life extension shall be serviced in the manner
specified in clause (1) of this regulation.

Order in Petition No. 197/GT/2013

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50. In line with the above regulations, the debt equity ratio as on COD is worked out as
under:
(` in lakh)

Actual Loan
Equity
Project Cost as on COD

118042.00
57022.00
175064.00

67.43%
32.57%

However, the debt equity ratio of 70:30 has been considered on the capital cost and
the admitted additional capital expenditure.
Return on Equity
51. Regulation 15 of the 2009 Tariff Regulations, as amended on 21.6.2011, provides as
under:
(1) Return on equity shall be computed in rupee terms, on the equity base determined in
accordance with regulation 12.
(2) Return on equity shall be computed on pre-tax basis at the base rate of 15.5% to be grossed
up as per clause (3) of this regulation.
Provided that in case of projects commissioned on or after 1st April, 2009, an additional return
of 0.5% shall be allowed if such projects are completed within the timeline specified in
Appendix-II.
Provided further that the additional return of 0.5% shall not be admissible if the project is not
completed within the timeline specified above for reasons whatsoever.
(3) The rate of return on equity shall be computed by grossing up the base rate with the
Minimum Alternate/Corporate Income Tax Rate for the year 2008-09, as per the Income Tax
Act, 1961, as applicable to the concerned generating company or the transmission licensee, as
the case may be.
(4) Rate of return on equity shall be rounded off to three decimal points and be computed as
per the formula given below:
Rate of pre-tax return on equity = Base rate / (1-t)
Where t is the applicable tax rate in accordance with clause (3) of this regulation
(5) The generating company or the transmission licensee, as the case may be, shall recover the
shortfall or refund the excess Annual Fixed charges on account of Return on Equity due to
change in applicable Minimum Alternate/Corporate Income Tax Rate as per the Income Tax
Act, 1961 (as amended from time to time) of the respective financial year directly without
making any application before the Commission:
Provided further that Annual Fixed Charge with respect to tax rate applicable to the generating
company or the transmission licensee, as the case may be, in line with the provisions of the
relevant Finance Acts of the respective year during the tariff period shall be trued up in
accordance with Regulation 6 of these regulations.

Order in Petition No. 197/GT/2013

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52. The petitioner has claimed corporate tax for grossing up the Return on Equity. In this
context, it is observed that in Petition No.521/MP/2014 filed by the petitioner, the petitioner
has submitted that the income was subject to Minimum Alternate Tax for the period 201213. As such, for the period 2012-13, MAT has been considered for grossing-up of the
Return on Equity. The petitioner is however granted liberty to approach the Commission
with the Tax Audit Reports for each of the financial year for which tariff is being claimed
(2011-14) at the time of revision of tariff based on truing-up exercise in terms of
Regulation 6(1) of the 2009 Tariff Regulations. Accordingly, return on equity has been
worked out as under:
(` in lakh)

Gross Normative Equity

Addition due to Additional
Capitalisation
Closing Equity
Average Equity
Return on Equity (Base
Rate )
Tax rate (Corp. Tax/ MAT*)
Rate of Return on Equity
(Pre Tax )
Return on Equity (PreTax)

2011-12
29.12.2011
20.1.2012 to
to 19.1.2012
31.3.2012
24003.30
43182.21
30.30

2012-13

2013-14

43182.21
3,603.30

46785.51
-

24,003.30
24,003.30
15.500%

43,212.51
,197.36
15.500%

46,785.51
44,983.86
15.500%

46,785.51
46,785.51
15.500%

32.450%
22.946%

32.450%
22.946%

20.008%
19.377%

32.450%
22.946%

331.07

1949.91

8716.50

10735.39

Interest on loan
53. Regulation 16 of the 2009 Tariff Regulations provides as under:
(1) The loans arrived at in the manner indicated in regulation 12 shall be considered as gross
normative loan for calculation of interest on loan.
(2) The normative loan outstanding as on 1.4.2009 shall be worked out by deducting the
cumulative repayment as admitted by the Commission up to 31.3.2009 from the gross
normative loan.
(3) The repayment for the year of the tariff period 2009-14 shall be deemed to be equal to
the depreciation allowed for that year.
(4) Notwithstanding any moratorium period availed by the generating company or the
transmission licensee, as the case may be the repayment of loan shall be considered from

Order in Petition No. 197/GT/2013

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the first year of commercial operation of the project and shall be equal to the annual
depreciation allowed.
(5) The rate of interest shall be the weighted average rate of interest calculated on the basis
of the actual loan portfolio at the beginning of each year applicable to the project.
Provided that if there is no actual loan for a particular year but normative loan is still
outstanding, the last available weighted average rate of interest shall be considered.
Provided further that if the generating station or the transmission system, as the case may
be, does not have actual loan, then the weighted average rate of interest of the generating
company or the transmission licensee as a whole shall be considered.
(6) The interest on loan shall be calculated on the normative average loan of the year by
applying the weighted average rate of interest.
(7) The generating company or the transmission licensee, as the case may be, shall make
every effort to re-finance the loan as long as it results in net savings on interest and in that
event the costs associated with such re-financing shall be borne by the beneficiaries and the
net savings shall be shared between the beneficiaries and the generating company or the
transmission licensee, as the case may be, in the ratio of 2:1.
(8) The changes to the terms and conditions of the loans shall be reflected from the date of
such re-financing.
(9) In case of dispute, any of the parties may make an application in accordance with the
Central Electricity Regulatory Commission (Conduct of Business) Regulations, 1999, as
amended from time to time, including statutory re-enactment thereof for settlement of the
dispute.
Provided that the beneficiary or the transmission customers shall not withhold any payment
on account of the interest claimed by the generating company or the transmission licensee
during the pendency of any dispute arising out of re-financing of loan.

54. Interest on loan has been worked out as mentioned below:

(i) The weighted average rate of interest has been worked out on the basis of the
actual loan portfolio at the beginning of respective year applicable to the project.
(ii) The repayment for the year of the tariff period 2009-14 has been considered equal
to the depreciation allowed for that year.
(iii) Interest on loan has been calculated on the normative average loan of the year by
applying the weighted average rate of interest. The calculation of weighted Average
Rate of Interest on loan is enclosed as Annexure-I to this order.
55. The necessary calculations for the interest on loan are as under:
(` in lakh)

2011-12
29.12.2011 to
20.1.2012 to
19.1.2012
31.3.2012

Gross Notional loan

Cumulative Repayment of
Loan upto previous year
Net Opening loan
Addition due to Additional
Capitalisation
Repayment of loan during the
period

Order in Petition No. 197/GT/2013

2012-13

2013-14

56007.71
-

100758.50
393.05

100758.50
2707.50

109166.20
13873.03

56007.71
-

100365.45
70.70

98051.00
8407.70

95293.17

393.05

2314.45

11165.53

7759.23

Page 28 of 39

Net Closing loan

Average Loan
Weighted Average Rate of
Interest on Loan
Interest on Loan

55614.66
55811.18
9.71%

98121.70
99243.57
9.71%

95293.17
96672.08
9.71%

87533.94
91413.55
9.70%

325.71

1895.47

9384.22

8870.46

Depreciation
56. Regulation 17 of the 2009 Tariff Regulations provides as under:
(1) The value base for the purpose of depreciation shall be the capital cost of the asset
admitted by the Commission.
(2) The salvage value of the asset shall be considered as 10% and depreciation shall be
allowed up to maximum of 90% of the capital cost of the asset.
Provided that in case of hydro generating stations, the salvage value shall be as provided in the
agreement signed by the developers with the State Government for creation of the site.
Provided further that the capital cost of the assets of the hydro generating station for the
purpose of computation of depreciable value shall correspond to the percentage of sale of
electricity under long-term power purchase agreement at regulated tariff.
(3) Land other than the land held under lease and the land for reservoir in case of hydro
generating station shall not be a depreciable asset and its cost shall be excluded from the
capital cost while computing depreciable value of the asset.
(4) Depreciation shall be calculated annually based on Straight Line Method and at rates
specified in Appendix-III to these regulations for the assets of the generating station and
transmission system.
Provided that, the remaining depreciable value as on 31st March of the year closing after a
period of 12 years from date of commercial operation shall be spread over the balance useful
life of the assets.
(5) In case of the existing projects, the balance depreciable value as on 1.4.2009 shall be
worked out by deducting 3[the cumulative depreciation including Advance against Depreciation]
as admitted by the Commission up to 31.3.2009 from the gross depreciable value of the assets.
(6) Depreciation shall be chargeable from the first year of commercial operation. In case of
commercial operation of the asset for part of the year, depreciation shall be charged on pro rata
basis.

57. The weighted Average Rate of depreciation as considered by the petitioner has been
considered for the purpose of tariff. The necessary calculations in support of depreciation
are as shown below:
(` in lakh)

2011-12
29.12.2011 to
19.1.2012

Opening Gross Block

Addition during 2009-14 due
to Actual/ Projected Additional
Capitalisation
Closing Gross Block
Average Gross Block
Rate of Depreciation

Order in Petition No. 197/GT/2013

2012-13

2013-14

20.1.2012 to
31.3.2012

80011.01
-

143940.71
101.00

143940.71
12011.00

155951.71
-

80011.01
80011.01
0.49%

144041.71
143991.21
1.61%

155951.71
149946.21
7.45%

155951.71
155951.71
4.98%

Page 29 of 39

Depreciable Value
Depreciation (for the period)
Cumulative Depreciation (at
the end of the year)

71932.51
393.05
393.05

129438.19
2314.45
2707.50

134797.69
11165.53
13873.03

140202.64
7759.23
21632.26

Operation & Maintenance Expenses

58. The 2009 Tariff Regulations provides for the following O&M expense norms in
respect of 125 MW sets for lignite fired generating station as under:
(`in lakh)

O&M expenses
(annualised)

2011-12
29.12.2011 to
20.1.2012 to
19.1.2012
31.3.2012
26.82
26.82

2012-13

2013-14

28.36

29.98

59. The O&M expenses claimed by the petitioner based on above norms and is allowed
as under:
(` in lakh)

O&M expenses
(annualised)
O&M expenses
(pro rata)

2011-12
29.12.2011 to
20.1.2012 to
19.1.2012
31.3.2012
3352.50
6705.0
201.52

1319.02

2012-13

2013-14

7090.00

7495.00

7090.00

7495.00

Additional expenditure incurring to the work of Operation and Maintenance and

Security Patrolling activities to External water carrier system
60. The petitioner vide affidavit dated 16.3.2012 has submitted that the generating
station is located about 25 km southwest of Bikaner town and is totally devoid of any
natural surface water resources. It has submitted that the table water occurs at about
120m below surface and the source of ground water is only precipitation which is meagre
and sporadic. It has also submitted that infiltration to the zone of saturation is minimum
because the average rainfall in the area is very little and the rate of evaporation of
precipitated water is high. Accordingly, it has submitted that the amount of ground water is
insufficient to meet the water requirement of the entire project and it is therefore necessary
to bring water from outside source. The petitioner has also submitted that the outside

Order in Petition No. 197/GT/2013

Page 30 of 39

source should have potential to ensure a continuous supply of about 20-22 cusecs of
water to the project site and the average water requirement is 1250 m3/hr. Considering 18
hours working of the pump houses, the flow rate will be 1667m3/hr. However during
reservoir filling period of about 40 days the flow rate will be 2000m3/hr. The petitioner has
stated that Indira Gandhi Nahar Panyojana (IGNP) is the only source of water for this
project. It has also submitted that Piping corridor (30m wide and 56 km long) from RD-800
(IGNP) to the power plant is used for laying the pipeline for raw water and a jeepable
Kuchcha road is also provided all along the corridor for maintenance of pipeline. It has
further submitted that three pump houses are provided along the piping route and security
patrolling activities of water carrier system is a necessity for such a long distance to
ensure un-interrupted water supply to the power plant. Hence, it has submitted that a
contract was awarded for Security patrolling activities round the clock along with Operation
and Maintenance activities for a total value of ` 54604054/- to M/s IVRCL Limited, Jaipur
for a period of 3 years. Accordingly, the petitioner has prayed that this expenditure may be
allowed as a special case over and above the normative Operation and Maintenance
expenses taking into consideration the security concerns (close to International Border)
involving patrolling round the clock. The petitioner vide affidavit dated 12.7.2012 and
20.7.2012 has reiterated the above submissions and has prayed that the expenditure on
Raw water drawn from IGNP canal and O&M expenditure of water carrier system may be
allowed as additional O&M expenses as claimed in the petition.
61. The respondents and the Consumers have objected to the claim of the petitioner for
additional O&M expenses and have submitted that the expenses should be borne from the
normative O&M expenses allowed to the generating station under the 2009 Tariff
Regulations.

62. We have examined the matter. Considering the fact that IGNP is the only source of
water for this project and that the security patrolling activities of water carrier system is a

Order in Petition No. 197/GT/2013

Page 31 of 39

necessity to ensure un-interrupted water supply to the power plant, we are inclined to
allow the expenditure claimed by the petitioner over and above the normative O&M
expenses allowed to the generating station. We order accordingly.

Interest on Working Capital

63. Regulation 18(1)(a) of the 2009 Tariff Regulations provides that the working capital
for coal based generating stations shall cover:
(i) Cost of coal for 1.5 months for pit-head generating stations and two months for non-pithead
generating stations, for generation corresponding to the normative annual plant availability
factor;
(ii) Cost of secondary fuel oil for two months for generation corresponding to the normative
annual plant availability factor, and in case of use of more than one liquid fuel oil, cost of fuel oil
stock for the main secondary fuel oil;
(iii) Maintenance spares @ 20% of operation and maintenance expenses specified in regulation
19.
(iv) Receivables equivalent to two months of capacity charge and energy charge for sale of
electricity calculated on normative plant availability factor; and
(v) O&M expenses for one month.

64. Clause (3) of Regulation 18 of the 2009 Tariff Regulations as amended on 21.6.2011
provides as under:
"Rate of interest on working capital shall be on normative basis and shall be considered as
follows:
(i)
SBI short-term Prime Lending Rate as on 01.04.2009 or on 1st April of the year in which
the generating station or unit thereof or the transmission system, as the case may be, is
declared under commercial operation, whichever is later, for the unit or station whose date of
commercial operation falls on or before 30.06.2010.
(ii) SBI Base Rate plus 350 basis points as on 01.07.2010 or as on 1st April of the year in
which the generating station or a unit thereof or the transmission system, as the case may be, is
declared under commercial operation, whichever is later, for the units or station whose date of
commercial operation lies between the period 01.07.2010 to 31.03.2014.
Provided that in cases where tariff has already been determined on the date of issue of this
notification, the above provisions shall be given effect to at the time of truing up.

65. Working capital has been calculated considering the following elements :

Order in Petition No. 197/GT/2013

Page 32 of 39

Fuel components in working capital

66. The petitioner has submitted that the year-wise Lignite Transfer Price has been fixed
based on the GOI, Ministry of Coal (MOC) guidelines dated 11.6.2009 and the Transfer
Price so determined has been certified by the Statutory Auditor. The Lignite Transfer Price
as determined by the petitioner and certified by Auditor are as under:2009-10
Production at 100% capacity (LTs)
Production at 85% capacity (LTs)
Lignite Price (Rs/Ts)

2010-11

443

2011-12
21.00
17.85
696* 837**

631

2012-13

2013-14

853

890

*Lignite price before commissioning of the generating station. **Lignite price after commissioning of the generating station.
67. The petitioner has claimed the fuel component in working capital based on price and
GCV of Lignite & Oil for the preceding three months i.e. for the year 2011-12 and the
Landed Price of Limestone based on the procurement price of Limestone inclusive of
royalty, taxes & duties and transportation charges as under:
(` in lakh)

2011-12

2012-13 2013-14

29.12.2011 to 20.1.2012 to
19.1.2012
31.3.2012

Cost of Lignite for 1 months

Cost of Limestone for 2 months
Cost of Secondary Fuel oil for 2 months

644.79
84.47
101.03

1289.58
168.94
202.07

1286.06 1286.06
168.48 168.48
201.52 201.52

68. The petitioner has claimed the cost of limestone for 2 months. However as per the
2009 Tariff Regulations, cost of limestone for 1 months is only applicable. Based on the
norms specified, the cost of fuel components in working capital, based on price and GCV
of Lignite, Limestone & Oil for the preceding three months is worked out as under:(` in lakh )

2011-12
Cost of Lignite for 1 months (annualised)
Cost of Lignite for 1 months (pro rata)
Cost of Limestone for 11/2 months (annualised)
Cost of Limestone for 11/2 months (pro rata)
Cost of Secondary Fuel oil for 2 months
(annualised)
Cost of Secondary Fuel oil for 2 months (pro
rata)

Order in Petition No. 197/GT/2013

2012-13

2013-14

29.12.2011
to 19.1.2012

20.1.2012 to
31.3.2012

638.76
38.40
63.35
3.81

1277.52
251.32
126.70
24.93

1274.03 1274.03
1274.03 1274.03
126.36
126.36
126.36
126.36

101.03

202.07

201.52

201.52

6.07

39.75

201.52

201.52

Page 33 of 39

O&M Expenses for 1 month

69. O & M expenses for 1 month claimed by the petitioner in Form-13 B and allowed for
the purpose of computation of interest on working capital (pro-rata) are as under:
(` in lakh)

O & M for 1 month (annualized)

O & M for 1 month (pro rata)

2011-12
29.12.11 to
20.1.2012 to
19.1.2012
31.3.2012
279.38
558.75
16.79
109.92

2012-13

2013-14

590.83
590.83

624.58
624.58

Maintenance Spares
70. The petitioner has claimed the following maintenance spare in the working capital:
(` in lakh)

Maintenance spares (annualised)

Maintenance spares (pro rata)

2011-12
29.12.11 to
20.1.2012 to
19.1.2012
31.3.2012
670.50
1341.00
40.30
263.80

2012-13

2013-14

1418.00
1418.00

1499.00
1499.00

71. The 2009 Tariff Regulations provides for maintenance spares @ 20% of the
operation & maintenance expenses as specified in Regulation 19. Accordingly, the
maintenance spares as claimed by the petitioner as above are in order and hence
considered for the purpose of tariff.
Receivables
72. Receivables on the basis of two months (pro rata) of fixed and energy charges have
been worked out as under:
(` in lakh)

2011-12

Fixed Charges (pro-rata)

Energy Charges (annualised)
Energy Charges (pro-rata)

Order in Petition No. 197/GT/2013

29.12.11 to
19.1.2012
222.15
936.15
56.27

20.1.2012 to
31.3.2012
1333.05
1872.30
368.32

2012-13

6495.37
1867.18
1867.18

2013-14

6243.32
1867.18
1867.18

Page 34 of 39

73. SBI Base Rate plus 350 basis points as on 1.4.2011 amounting to 11.75% p.a.
(8.25% + 350 basis point) has been considered on all the above components of working
capital for the purpose of calculating interest on working capital on pro rata as under:
(` in lakh)

2011-12

O&M expenses (1 month)

Receivables (Fixed Charges)
Receivables (Energy charges)
Maintenance Spare
Secondary fuel oil cost
Fuel cost
Total Working Capital
Interest Rate
Interest on Working Capital

29.12.11 to
19.1.2012
16.79
222.15
56.27
40.30
6.07
42.20
383.79
11.75%
45.10

20.1.2012 to
31.3.2013
109.92
1333.05
368.32
263.80
39.75
276.24
2391.09
11.75%
280.95

2012-13

590.83
6495.37
1867.18
1418.00
201.52
1400.39
11973.29
11.75%
1406.86

2013-14

624.58
6243.32
1867.18
1499.00
201.52
1400.39
11835.99
11.75%
1390.73

Operational Norms
74. The following norms of operation have been considered by the petitioner:
Normative Annual Plant Availability Factor (NAPAF) %
Gross Station Heat Rate (GSHR) (kcal/kWh)
Auxiliary Power Consumption (APC ) %
Specific Fuel Oil Consumption (ml/kwh)

75
2620.97
11.5
1.25

75. The operational norms considered by the petitioner towards NAPAF, APC and
Specific Fuel Oil Consumption are in accordance with the 2009 Tariff Regulations and
hence allowed. However, the Gross Station Heat Rate (GSHR) of 2620.97 kcal/kWh
considered by the petitioner is at variance with the 2009 Tariff Regulations. The petitioner
has considered the normative heat rate as per the ceiling limit of maximum heat rate. Shri
G.L.Sharma, Consumer has submitted that in respect of unit where the boiler feed pumps
are electrically operated the maximum design unit heat rate shall be 40 kcal/kWh lower
than the maximum design unit heat rate specified with turbine driven BFP. He has also
submitted that the maximum design unit heat rate specified with turbine driven BFP is
2294 kcal/kWh and therefore in the present case, it should be 2254 (2294 40).
Accordingly, the Consumer has submitted that the GSHR works out as 2400.51 kcal/kWh

Order in Petition No. 197/GT/2013

Page 35 of 39

and by applying the correction factor of 1.07 the GSHR works out as 2568.55 kcal/kWh
which may be considered. We have examined the matter. The maximum ceiling heat rate
is considered only if the design heat rate along with the deviation allowed is more than the
ceiling value. In the present case, the Guaranteed Turbine Cycle Heat Rate as submitted
by petitioner is 1994.60 kCal/kWh and the guaranteed boiler efficiency is 81.81%. Hence,
the design GSHR would be 2438.08 kCal/kWh. Considering the multiplying factor of 1.065
in respect of the generating station which has achieved COD after 2009, the GSHR works
out to 2596.56 kcal/kWh (1.065x2438.08). Accordingly, the Gross Station Heat Rate of
2596.56 kCal/kWh has been considered for the generating station.

Fixed Charges
76. Accordingly, the fixed charges allowed for the generating station (pro rata) for the
period 2011-14 is summarised as under:
(` in lakh)

Return on Equity
Interest on Loan
Depreciation
Interest on Working
Capital
O&M Expenses
Secondary fuel oil cost
Total Annual Fixed
Charges

2011-12
29.12.11 to
20.1.2012 to
19.1.2012
31.3.2012
331.07
1949.91
325.71
1895.47
393.05
2314.45
45.10
280.95
201.52
36.44
1332.88

1319.02
238.51
7998.31

2012-13

2013-14

8716.50
9384.22
11165.53
1406.86

10735.39
8870.46
7759.23
1390.73

7090.00
1209.11
38972.21

7495.00
1209.11
37459.91

Energy Charge Rate (ECR)

77. The petitioner has claimed Energy Charge Rate (ECR) of `0.777/ kWh based on the
weighted average price and GCV of lignite and coal procured and burnt for the preceding
three months i.e. October, November and December, 2011 and the landed price of
limestone as per the 2009 Tariff Regulations. ECR is worked out and allowed as under:

Order in Petition No. 197/GT/2013

Page 36 of 39

Capacity
Gross Station Heat Rate
Aux. Energy Consumption
Weighted average GCV of oil
Weighted average GCV of Lignite
Weighted average price of oil
Landed price of Lime stone
Weighted average price of Lignite
Rate of energy charge ex-bus

Unit
MW
Kcal/kWh
%
Kcal/lit
Kcal/kg
`/KL
Rs/MT
Rs/MT
Paise/kWh

2011-14
2X125
2596.56
11.50
10000
2898.33
58891
1099
696
77.07

78. The Energy Charge on month to month basis shall be billed by the petitioner as per
Regulation 21 (6) (a) of the 2009 Tariff Regulations due to monthly variation in actual GCVs
as the Lignite Transfer Price (Primary Fuel) is determined year-wise.
Supply of electricity within 5km radius
79. The petitioner has submitted that the Ministry of Power, Government of India has
notified a Scheme for implementation of the provision for supply of electricity within 5 km
radius around the Central Power generating stations and for this purpose the petitioner
has to create infrastructure for supply of power. It has also submitted that the Detailed
Project Report (DPR) for implementation of the said scheme is under preparation and it is
not possible to estimate the projected expenditure at this stage. The petitioner has
submitted that the expenditure incurred towards implementation of the said scheme may
be considered in tariff. Admittedly, the petitioner is yet to incur any expenditure on the said
scheme. Though the scheme for supply of electricity in 5 km area around central power
plants was launched by the Ministry of Power, Govt. of India during 2010 (27.4.2010), the
Ministry of Power, GOI vide notification dated 25.3.2013 has withdrawn the scheme.
Considering this, the prayer of the petitioner has not been considered.
Application fee and the publication expenses
80. The petitioner has prayed for recovery of expenditure incurred towards filing fees and
publication expenses from the respondents in respect of the petition filed by the petitioner.
The petitioner has also incurred an amount of `455312/- for publication of tariff in the

Order in Petition No. 197/GT/2013

Page 37 of 39

newspapers in terms of Regulation 3(6) of the CERC (Procedure for making of application
for determination of tariff, publication of application and other related matters) Regulations,
2004. In terms of Regulation 42 of the 2009 Tariff Regulations and based on our decision
contained in order dated 11.1.2010 in Petition No.109/2009, the expenses towards filing of
tariff application and the expenses incurred on publication of notices are to be reimbursed.
Accordingly, the expenses incurred by the petitioner for petition filing fees for the period
from 2011-14 and the expenses incurred for publication of notices in connection with the
petition shall be directly recovered from the beneficiaries, on pro rata basis based on
documentary proof.
81. The petitioner is already billing the respondents on provisional basis in accordance
with the provisional tariff granted vide order dated 4.10.2012. The provisional billing of
tariff shall be adjusted in terms of proviso to Regulation 5(3) of the 2009 Tariff Regulations
as amended on 21.6.2011.
82. Petition No. 197/GT/2013 is disposed of in terms of the above.

-Sd/(A.K.Singhal)
Member

Order in Petition No. 197/GT/2013

-Sd/(Gireesh B Pradhan)
Chairperson

Page 38 of 39

Annexure-I
Calculation of Weighted Average Rate of Interest on Loan
31.3.2005
Opening loan Balance
Canara-1
0
Rate of
7.30%
Interest

( ` in Lakh)
1.4.2012
1.4.2013
to
to
31.3.2013 31.3.2014

1.4.2005 to
22.2.2006

23.2.2006 to
31.3.2006

1.4.2006 to
31.3.2007

1.4.2007 to
31.3.2008

1.4.2008 to
31.3.2009

1.4.2009
to
31.3.2010

1.4.2010 to
31.3.2011

1.4.2011 to
28.12.2011

29.12.2011
to
19.1.2012

20.1.2012 to
31.3.2012

0
7.30%

6242
7.30%

7642
7.30%

16042
7.30%

50942
7.30%

67342
10.35%

63974.88
10.35%

57240.64
10.35%

53873.52
10.35%

53873.52
10.35%

50506.4
10.35%

43772.16
10.35%

Canara-2
Rate of
Interest

0
8.85%

0
8.85%

0
8.85%

0
8.85%

0
8.85%

0
8.85%

0
8.85%

11562.5
8.85%

18050.5
8.85%

25187.2
8.85%

25187.2
8.85%

22823.9
8.85%

18097.3
8.85%

NLC
Bond
Rate of
Interest

14700

14700

14700

14700

14700

14700

8.83%

8.83%

8.83%

8.83%

8.83%

8.83%

8.83%

8.83%

8.83%

8.83%

8.83%

8.83%

8.83%

6242

7642

16042

50942

67342

90237.38

89991.14

93760.72

93760.72

88030.3

76569.46

0.00%

7.30%

7.30%

7.30%

7.30%

10.35%

9.91%

9.80%

9.71%

9.71%

9.71%

9.70%

Total Op.
Loan
Weighted
Average
Rate of
Interest
on
Opening
Balance

Order in Petition No. 197/GT/2013

Page 39 of 39