SecProbe.io

January 23, 2020
GR Arun Kumar
Director and Chief Financial Officer
Vedanta Ltd
1st Floor, C Wing, Unit 103
Corporate Avenue, Atul Projects
Chakala, Andheri (East)
Mumbai - 400 093, Maharashtra, India
Re:Vedanta Ltd
Form 20-F for the Fiscal Year Ended March 31, 2019
Filed July 15, 2019
File No. 001-33175
Dear Mr. Kumar:
            We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 20-F for the Fiscal Year Ended March 31, 2019
Item 8. Financial Information
Legal Proceedings, page 144
1.We note that you have several significant legal proceedings disclosed in this section that
are not disclosed in the notes to the financial statements.  Please revise to ensure that all
legal contingencies that meet the requirements of paragraph 86 of IAS 37 are disclosed in
the notes to the financial statements.

 FirstName LastNameGR Arun Kumar
 Comapany NameVedanta Ltd
 January 23, 2020 Page 2
 FirstName LastName
GR Arun Kumar
Vedanta Ltd
January 23, 2020
Page 2
Note 3(a) Significant Accounting Policies
C. Revenue Recognition, page F-14
2.Please revise to disclose the significant payment terms of your performance obligations
and how the timing of satisfaction of its performance obligations relates to the typical
timing of payment and the effect that those factors have on the contract asset and the
contract liability balances.  See guidance in paragraph 117 and 119 of IFRS 15.  Also, for
any remaining performance obligations as of year-end, please include the disclosures
required by paragraph 120 of IFRS 15.
3.We note your disclosure that revenue from oil, gas and condensate sales represent the
Group’s share of oil, gas and condensate production, recognized on a direct entitlement
basis, when control is transferred to the buyers.  In light of the fact that it appears your oil
and gas business is structured mostly with production sharing contracts, please provide us
more details on the nature of these arrangements and how you account for them in
accordance with IFRS 15.  As part of your response, please  tell us how you have
determined that these arrangements are in the scope of IFRS 15 and how you have
determined whether the other parties in this arrangement meet the definition of a customer
in IFRS 15.  Also, please tell us the nature of any principal versus agent considerations in
these transactions, such as those included in paragraphs B34-B38 of IFRS 15.
Note 6. Revenue, page F-44
4.We note your disclosure that revenue from contracts with customers for 2019 includes
37,867 million for which contract liabilities existed at the beginning of the year.  Please
revise to disclose the opening and closing balances of contract liabilities from contracts
with customers, and the nature of any material changes in the balance during the year, in
accordance with paragraph 116 and 118 of IFRS 15.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact Claire Erlanger, Staff Accountant, at (202) 551-3301 or Melissa
Raminpour, Accounting Branch Chief, at (202) 551-3379 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing