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Competition Commission of India

Enforcement

Competition Commission of India finds Debenture Trustees and their association guilty of cartelisation; no monetary penalty imposed

Competition Commission of India penalises HP India Sales Private Limited and its resellers for bid-rigging cartel

Competition Commission of India penalises sales agents of leading tyre manufacturers for bid-rigging cartel

Competition Commission of India penalises agri-input dealers’ associations for boycotting online platforms

Competition Commission of India dismisses separate complaints filed against the following companies for alleged anti-competitive practices:

• Hensel Electric India Private Limited
• Eternal Limited (Zomato)
• Jindal Stainless Limited and its raw material suppliers
• Nissan Motor India Private Limited
• Godrej & Boyce Co. Ltd. and others

 

Merger control

Competition Commission of India approves twelve combinations in July and August 2026

 

Miscellaneous

Competition Commission of India amends Competition Commission of India (Commitment) Regulations, 2024

 

Competition Commission of India

Enforcement

Competition Commission of India finds Debenture Trustees and their association guilty of cartelisation; no monetary penalty imposed

On September 2, 2026, the Competition Commission of India (“CCI”) passed an order holding IDBI Trusteeship Services Limited (“IDBI Trustee”), Axis Trustee Services Limited (“Axis Trustee”), SBI CAP Trustee Company Limited, Trustees’ Association of India (“TAI”) and their respective employees (collectively referred to as “OPs”) guilty of cartelisation, in contravention of Sections 3(3)(a) and 3(3)(d) of the Competition Act, 2002 (“Competition Act”). However, the CCI refrained from imposing any monetary penalty on the OPs.

 

Background

The complaint was filed by Muthoot Finance Limited, a public listed company, engaged in raising working capital through debt securities by issuance of non-convertible debentures. It was inter alia alleged that TAI had prescribed a floor pricing structure (“Minimum Fee Structure”) for its member Debenture Trustees (“DTs”), stipulating the minimum trusteeship fees that could be charged by DTs to issuers. It was alleged that member DTs were not permitted to charge fees below the rates prescribed under the Minimum Fee Structure.

The Director General (“DG”), inter alia, found that TAI had prescribed a Minimum Fee Structure for providing DT services to the issuers at its meeting held on March 23, 2021, which its member DTs were expected to follow. According to the DG, the Minimum Fee Structure operated as a floor price below which member DTs were generally not permitted to charge trusteeship fees, subject to limited discretion to deviate by up to 20%. The DG further noted that ‘adverse repercussions’ were contemplated for non-adherence to the prescribed fee structure.

 

CCI findings

Concurring with the DG’s findings, the CCI, inter alia, noted that such collective fixing of minimum fees, coupled with active monitoring and enforcement against members and non-members alike, amounted to cartelisation, in contravention of Sections 3(3)(a) and 3(3)(d) of the Competition Act.

Considering the mitigating factors, including that TAI had no income during the relevant period and that the relevant OPs had, in several instances, charged fees below the Minimum Fee Structure, the CCI decided not to impose any monetary penalty on the OPs. The CCI instead directed the OPs to cease and desist from the anti-competitive practices.

JSA represented IDBI Trustee, Axis Trustee, TAI and their respective employees before the CCI.

(Source: CCI Order dated September 2, 2026)

 

CCI penalises HP India Sales Private Limited and its resellers for bid-rigging cartel

On July 13, 2026, the CCI passed 2 (two) related orders and found HP India Sales Private Limited (“HP India“) and several of its resellers guilty of indulging in a bid-rigging cartel, in contravention of Section 3(3) of the Competition Act.

 

Background

The CCI initiated the investigation pursuant to a lesser penalty application filed by HP India, inter alia, disclosing the existence of a bid-rigging cartel between HP India and its resellers who participated and competed in the tenders floated on the Government e-marketplace platform for procurement of the following products:

• laptops, desktops and other personal system products, involving HP India and 10 (ten) resellers, exceeding INR 1 crore (Indian Rupees one crore)[1] (referred to as the “Personal Systems Inquiry”); and
• ink and toner cartridges and other consumables, involving HP India and 16 (sixteen) resellers, exceeding INR 20 lakh (Indian Rupees twenty lakh)[2] (referred to as the “Supplies Products Inquiry”).

 

CCI findings

Concurring with the DG’s findings, the CCI, inter alia, noted the following:

• Personal Systems Inquiry:
  • Dictating bid prices and cover bidding: HP India instructed resellers on the prices to quote and arranged cover bids to ensure that a designated reseller emerged as the successful bidder. In a few tenders, HP India participated in the very tenders in which its resellers were bidding. Since HP India had access to confidential reseller bid information, it was able to emerge as the successful bidder.
  • Restricting participation through Manufacturer’s Authorisation Form (“MAF”): Since the resellers required a MAF and a price from HP India to participate in tenders, HP India was able to control participation of resellers by controlling bid prices and selectively withholding the MAFs.
  • Existence of a vertical relationship is not a defence: The CCI rejected the argument that HP India and its resellers could not be liable under Section 3(3) of the Competition Act because they were in a vertical relationship and noted that when HP India and its resellers participated in the same tender, they acted as competitors.
• Supplies Products Inquiry:
  • Facilitating coordination among resellers: Unlike the Personal Systems Inquiry, HP India did not bid directly in these tenders but rather facilitated coordination among competing resellers by allocating ‘most valuable customer’ accounts, arranging cover bids through sister concerns, and enforcing price hygiene.
  • Existence of a hub and spoke cartel: The resellers contended that since the conduct pertains to the period from 2018 to 2020, the amendment in the Competition Act in 2023, expanding the scope of Section 3(3) of the Competition Act to include “hub and spoke arrangements”, must not be applied retrospectively. Rejecting this contention, the CCI held that notwithstanding the amendment, HP India’s conduct of facilitating coordination among resellers can be examined under Section 3(1) of the Competition Act, which has an existence independent of Section 3(3) or Section 3(4) of the Competition Act.
  • Restricting participation through the MAF: Similar to the Personal Systems Inquiry, HP India’s control over the issuance of MAFs enabled it to determine which resellers could participate in the tenders.

Accordingly, the CCI held that HP India, its resellers and their relevant employees engaged in anti-competitive activities and directed them to cease and desist from such practices and undertake competition law compliance training.

On penalties, despite HP India being the first lesser penalty applicant in both cases, and in a significant departure from its practice, the CCI did not grant a full waiver of the penalty and only provided it with a reduction, given its prominent role in the cartel. Accordingly, the CCI imposed penalties of: (a) approx. INR 127 crore (Indian Rupees one hundred and twenty-seven crore)[3] on HP India and approx. INR 12,000 (Indian Rupees twelve thousand)[4] to INR 87 lakh (Indian Rupees eighty-seven lakh)[5] on its resellers and relevant employees in the Personal Systems Inquiry; and (b) approx. INR 12 crore (Indian Rupees twelve crore)[6] on HP India and approx. INR 11,000 (Indian Rupees eleven thousand)[7] to approx. INR 78 lakh (Indian Rupees seventy-eight lakh)[8] on its resellers and relevant employees in the Supplies Products Inquiry.

(Source: CCI Orders dated July 13, 2026 and July 13, 2026)

 

CCI penalises sales agents of leading tyre manufacturers for bid-rigging cartel

On August 21, 2026, the CCI found Rekha Agencies and SS Marketing, the authorised representatives of JK Tyre and Industries Limited (“JK Tyre”) and CEAT Limited (“CEAT”), respectively, guilty of indulging in a bid-rigging cartel, in contravention of Section 3(3)(d) of the Competition Act.

 

Background

A reference was filed by the Director, State Transport, Haryana, before the CCI in relation to a tender issued by Haryana Roadways in September 2018 for the procurement of new steel radial tyres and other categories of tyres. It was inter alia, alleged that JK Tyre:

• quoted prices 34-39% higher than the previous year’s approved rates, despite a comparatively lower increase in raw material costs; and
• refused to reduce its quoted prices or match the rates previously offered to the Karnataka State Road Transport Corporation, despite repeated requests from the High Powered Purchase Committee.

During the course of investigation, the CCI expanded the scope of the investigation to include CEAT and other leading tyre manufacturers, along with Rekha Agencies, and SS Marketing.

The DG examined the tenders floated by various State Transport Undertakings (“STUs”) and inter alia found that:

• JK Tyre and CEAT regularly participated in tenders floated by various STUs, whereas other tyre manufacturers only participated in these tenders sporadically;
• in a 2013 tender issued by the Himachal Road Transport Corporation (“HP Tender”), JK Tyre through Rekha Agencies and CEAT through SS Marketing exchanged bid prices and quoted identical prices;
• JK Tyre increased its bid price by approx. 23.74-34.95% in the Haryana Tender (“Haryana Tender”) compared to the previous year, significantly exceeding the increase in its cost of raw material during the same period; and
• there was insufficient evidence to establish the involvement of the other tyre manufacturers in cartelisation or other anti-competitive practices.

 

CCI findings

The CCI inter alia noted the following:

• HP Tender: The exchange of bid prices between Rekha Agencies and SS Marketing indicated coordination between the 2 (two) agencies. However, there was no evidence of communication between JK Tyre and CEAT. The bid prices were exchanged independently by the 2 (two) agencies, without the involvement of JK Tyre or CEAT.
• Haryana Tender: Although JK Tyre was the sole bidder, there was no evidence of any coordination between tyre manufacturers. Accordingly, merely quoting higher prices, in the absence of any evidence of collusion, does not establish a contravention of Section 3(3) of the Competition Act.

Accordingly, the CCI exonerated JK Tyre and CEAT, while holding Rekha Agencies, SS Marketing and their relevant employees guilty of indulging in a bid-rigging cartel. It also imposed monetary penalties of: (a) INR 1.29 lakh (Indian Rupees one lakh twenty-nine thousand)[9] on Rekha Agencies; (b) INR 2.23 lakh (Indian Rupees two lakh twenty-three thousand)[10] on SS Marketing; and (c) INR 6.40 lakh (Indian Rupees six lakh forty thousand)[11] on the employee of Rekha Agencies. No monetary penalty was imposed on the relevant employee of SS Marketing on humanitarian grounds since the relevant employee recently passed away.

(Source: CCI Order dated August 21, 2026)

 

CCI penalises agri-input dealers’ associations for boycotting online platforms

On August 21, 2026, the CCI found Agro Input Dealers Association (“AIDA“) and Agro Input Welfare Association (“AIWA“) guilty of indulging in anti-competitive practices, in contravention of Section 3(3)(b) of the Competition Act.

 

Background

The complaint was filed by Ulink Agritech Private Limited, an agri-tech start-up operating the AgroStar platform and a network of ‘AgroStar ki Laal Dukaan’ stores. It was inter alia alleged that AIDA and AIWA pressured agri-input manufacturers to stop supplying agri-input products to online platforms and threatened retailers dealing with such online platforms with termination of their dealerships. The associations also allegedly circulated misleading messages against such online platforms.

The DG found that AIDA and AIWA had actively urged agri-input manufacturers to stop supplying agri-input products to online platforms and retailers to terminate their dealerships with the complainant. Several retailers subsequently ended their dealerships and agri-input manufacturers stopped supplies, resulting in the closure of several offline stores.

 

CCI findings

Concurring with the DG’s findings, the CCI inter alia noted that AIDA and AIWA: (a) coordinated and implemented a boycott of online platforms; and (b) communications sought to influence agri-input manufacturers’ and retailers’ commercial decisions, and that subsequent dealership cancellations and supply stoppages demonstrated that the boycott was effectively implemented in the market.

Accordingly, the CCI held that AIDA, AIWA and their respective employees guilty of indulging in anti-competitive practices and directed them to cease and desist from such practices and undertake competition law compliance training. It also imposed monetary penalties of approximately INR 81,000 (Indian Rupees eighty-one thousand)[12] on AIDA, INR 3.92 lakh (Indian Rupees three lakh ninety-two thousand)[13] on AIWA, and INR 5.91 lakh (Indian Rupees five lakh ninety-one thousand)[14] collectively on their relevant employees.

 (Source: CCI Order dated August 21, 2026)

 

CCI dismisses complaint against Hensel Electric India Private Limited for alleged anti-competitive practices

The CCI received a complaint against Hensel Electric India Private Limited (“Hensel“) for indulging in alleged anti-competitive practices, in contravention of Sections 3(4) and 4 of the Competition Act.

 

Background

The complaint was filed by an exclusive distributor of Hensel for industrial grade cable junction boxes in Andhra Pradesh, who had executed a Distribution Agreement (“Agreement“) dated January 1, 2025 with Hensel. It was inter alia alleged that: (a) the Agreement permitted the distributor to decide the price, but stipulated that Hensel was entitled to decide margins through which discount control is enforced, thereby constituting a resale price maintenance agreement; (b) the Agreement prohibited the distributor from offering, selling, advertising, or marketing products of Hensel’s competitors, thereby constituting an exclusive distribution agreement; and (c) Hensel entered into a direct sale transaction with a customer at a discount of 48% on the list price, bypassing the complainant who had offered the product at 38% discount on the list price, thereby indulging in predatory pricing.

 

CCI findings

The CCI noted that the relevant market had several significant players and no single entity had the ability to influence market conditions. Accordingly, Hensel was not found to be dominant. On the allegations, the CCI, inter alia, noted the following:

• the Agreement only prohibited the distributor from selling products above the maximum retail price, while allowing it to independently determine resale prices and other terms;
• restricting an exclusive distributor from dealing in competing products can promote brand specialisation and enable better marketing and customer support, and the same is a common commercial arrangement; and
• Hensel’s right to sell directly to certain customers where market conditions did not permit distributor involvement was a legitimate commercial arrangement and did not raise competition concerns.

Accordingly, the CCI dismissed the complaint.

(Source: CCI order dated August 5, 2026)

 

CCI dismisses complaint against Eternal Limited (Zomato) for alleged anti-competitive practices

The CCI received a complaint against Eternal Limited, formerly known as Zomato Limited (“Zomato”), for indulging in alleged anti-competitive practices, in contravention of Sections 3 and 4 of the Competition Act.

 

Background

The complaint was filed by an individual wherein it was inter alia alleged that: (a) Zomato’s arrangements with restaurants, particularly the high commissions and requirement to advertise, amount to agreements that harm competition; and (b) Zomato is dominant in the online food delivery market and abuses it by: (i) charging excessive commissions from restaurants, (ii) inflating menu prices, and following ‘drip pricing’. Drip pricing is a practice where the initial price shown is low, but additional fees are gradually revealed as the consumer proceeds towards payment on the Zomato platform.

 

CCI findings

The CCI inter alia noted the following:

• ordering food online costs more than buying it directly from a restaurant because online food delivery platforms are ‘multi-sided’ businesses as they provide services to consumers (the app, search, delivery) and to restaurants (listing, visibility, logistics). These extra services naturally come with additional charges such as delivery fees and platform fees;
• the complainant chose a sample of a single food item to establish that Zomato was charging a higher price however, if the price of the food item is high, the percentage difference in price would accordingly decline as the delivery charge is a fixed charge and may vary depending on distance; and
• drip pricing, where extra fees like platform charges, delivery fees, and taxes are added progressively during checkout, is a real sales practice. However, the CCI noted that the extra charges correspond to real additional services, and consumers have the option to abandon their order at any point before completing it. Therefore, drip pricing did not raise a competition issue.

Accordingly, the CCI dismissed the complaint.

(Source: CCI Order dated July 23, 2026)

 

CCI dismisses complaint against Jindal Stainless Limited and its raw material suppliers for alleged anti-competitive practices

The CCI received a complaint against Jindal Stainless Limited (“JSL”)[15], PT Qing Feng Ferrochrome (“PT Qing”), PT Indonesia Guang Ching Nickel & Stainless-Steel Industry (“PT Indonesia Guang”), and PT Indonesia Ruipu and Chrome Alloy Nickel (“PT Indonesia Ruipu”), for indulging in alleged anti-competitive practices, in contravention of Sections 3(4) and 4 of the Competition Act.

 

Background

India does not have nickel production and thus, imports it from Indonesia. In 2020, Indonesia banned the export of nickel as a raw material and therefore, as an alternative, stainless steel manufacturers began importing nickel-rich Stainless-steel Slabs (“SS Slabs”) and Stainless-steel Hot Rolled Coils (“SS HRC”) used in the manufacture of stainless steel.

The complainant, an Indian Stainless Steel Market Participant, trades in stainless steel products for which nickel is a crucial raw material. It was inter alia alleged that JSL:

• entered into exclusive agreements with Indonesian suppliers, PT Qing, PT Indonesia Guang and PT Indonesia Ruipu, for the supply of raw materials to the exclusion of any other Indian manufacturers, constituting exclusive dealing and refusal to deal;
• is dominant in the market for wide Cold Rolled Stainless Steel (“CRSS”) products in India with a market share of more than 60%, and abused its dominant position by securing exclusive access to essential raw materials, thereby denying market access to potential competitors and foreclosing the CRSS supply chain; and
• executed memorandums of understanding (“MoU”) with its dealers such that they were compelled and locked-in for sourcing almost all their requirements exclusively from JSL, thereby excluding competing manufacturers.

 

CCI findings

The CCI inter alia noted the following:

• Exclusive dealing and refusal to deal arrangements: The complainant did not furnish evidence that the Indonesian suppliers refused to supply the raw materials, i.e., SS Slabs or SS HRC to the manufacturers (including the complainant). In fact, the record showed that other Indian manufacturers imported such products from them.
• Abuse of dominance: JSL prima facie appeared to be dominant in the downstream market of CRSS, however, there was no evidence of abuse of dominance, demonstrating that any competing manufacturer was denied access to raw materials, suffered production constraints, or exited the market. On the contrary, evidence indicated several domestic manufacturers, independent processors and international suppliers continued to participate in the market and that imports of relevant products into India remained significant.
• Exclusivity and lock-in arrangements: The MoUs were voluntary, non-binding, incentive-based commercial arrangements that did not impose exclusivity obligations or minimum purchase commitments on JSL’s dealers. In fact, a substantial number of dealers either procured the material from other suppliers or purchased the material from JSL without executing MoUs.

Accordingly, the CCI dismissed the complaint.

(Source: CCI Order dated July 21, 2026)

 

CCI dismisses complaint against Nissan Motor India Private Limited for alleged anti-competitive practices

The CCI received a complaint against Nissan Motor India Private Limited (“Nissan”) for alleged anti-competitive agreement and abuse of dominant position, with regards to the termination of its dealership agreement with an authorised dealer, in contravention of Sections 3(4) and 4 of the Competition Act.

 

Background

The complaint was filed by one of the authorised dealers of Nissan, wherein it was inter alia alleged that Nissan: (a) in an arbitrary and unilateral manner, issued a termination notice, without a show cause notice, reasons, or a hearing, thereby terminating the dealership mid-term even though the agreement was valid until March 31, 2026; (b) abused its dominant position in the ‘market for distribution and sale of Nissan-branded passenger vehicles and related after-sales services in India’ by imposing resale price maintenance and controlling the price at which the dealer should sell the vehicles to end customers.

 

CCI findings

The CCI rejected the complainant’s proposed relevant market and delineated it as the ‘market for distribution and sale of passenger cars in India’. Given Nissan’s market share of less than 1% in the said relevant market, the CCI found that Nissan was not dominant.

The CCI inter alia noted that the 90 (ninety) day termination clause, which allowed either party to terminate the dealership agreement without assigning reasons, was a standard commercial term and did not raise competition concerns. It also found no resale price maintenance existed, as dealers were only prohibited from selling above the maximum recommended retail price and remained free to offer discounts and sell below that price.

Accordingly, the CCI dismissed the complaint.

(Source: CCI Order dated July 7, 2026)

 

CCI dismisses complaint against Godrej & Boyce Mfg. Co. Ltd. and others for alleged anti-competitive practices

The CCI received a complaint against Godrej & Boyce Mfg. Co. Ltd. (“Godrej”) and 15 (fifteen) public sector procuring entities (collectively referred to as “Procuring Entities”) for indulging in alleged anti-competitive practices, in contravention of Sections 3 and 4 of the Competition Act.

 

Background

The complaint was filed by individuals wherein it was inter alia alleged that: (a) the Procuring Entities issued tenders for institutional furniture and tailored the technical specifications to match the designs of Godrej, instead of drafting neutral and functional specifications as required for open competitive bidding, thereby favouring Godrej as a bidder. Thus, Godrej was influencing the tender terms thereby abusing its dominance; and (b) Godrej and the officials of one Procuring Entity, National Buildings Construction Corporation Limited, colluded such that the tenders set out technical specifications matching Godrej’s brand specifications.

 

CCI findings

On dominance, the CCI held that Godrej, with a market share of 15% in the ‘market for supply of institutional furniture in India’ cannot be held dominant under the Competition Act.

The CCI inter alia noted that: (a) the formulation of technical specifications and procurement terms falls within the commercial discretion of procuring entities, and mere correspondence of specifications with Godrej’s products does not infer collusion or anti-competitive conduct; (b) bid-rigging contemplates an agreement amongst competitors, and the complainants failed to place any material on record demonstrating the same between Godrej and other bidders; and (c) the complainants failed to disclose any agreement between Godrej and the Procuring Entities in the nature of an exclusive arrangement, refusal to deal, or any other vertical restraint.

Accordingly, the CCI dismissed the complaint.

(Source: CCI Order dated July 2, 2026)

 

Merger control

CCI approves twelve combinations in July and August 2026, including:

• Acquisition of Acko Technology by General Atlantic Singapore.
• Acquisition of Bharti Life Insurance by Prudential Corporation.
• Acquisition of TM International Logistics by Tata Steel.
• Acquisition of shareholding of Kestrel Coal by Yancoal Australia.
• Acquisition of shareholding of Tao Digital Solutions by Cyient Limited.
• Acquisition of Anglo American Plc’s steelmaking coal portfolio by Dhilmar Limited.
• Acquisition of NCR Atleos Corporation by The Brink’s Company.
• Merger of 51 (fifty-one) Malabar Group Companies with Malabar Gold and Diamonds.
• Acquisition of units of Oaktree Capital Group Holdings, L.P. and Oaktree Equity Plan, L.P. by Brookfield Asset Management Limited.
• Amalgamation of Go Digit Infoworks Services Private Limited with and into Go Digit General Insurance Limited.
• Combination involving InterGlobe group and Accor group.

(Source: CCI website)

 

Miscellaneous

CCI amends CCI (Commitment) Regulations, 2024

In March 2024, the CCI introduced the CCI (Commitment) Regulations, 2024 providing a structured framework for enterprises to offer voluntary commitments in cases involving alleged anti-competitive vertical agreements and abuse of dominance. The framework enables parties to address the CCI’s competition concerns at an early stage of the proceedings, after the commencement of an investigation but before the DG submits its investigation report, thereby facilitating quicker market correction, reducing protracted litigation, and promoting efficient enforcement. The commitments mechanism is not available for cartel cases, which continue to be governed by the CCI’s leniency regime.

On August 18, 2026, the CCI published a notification through which it has brought into force the CCI (Commitment) Amendment Regulations, 2026 (“Amendment Regulations”), which amend the 2024 Commitment Regulations.

The Amendment Regulations inter alia provide as follows:

• Timeline for filing a commitment application: Under the existing regulations, a commitment application must be filed within 45 (forty-five) days from receipt of the CCI’s order under Section 26(1) of the Competition Act. The Amendment Regulations have extended this period to 60 (sixty) days.
• Timeline for conclusion of commitment proceedings: Under the existing regulations, commitment proceedings must be concluded within 130 (one hundred and thirty) working days of receipt of a complete commitment application. The Amendment Regulations have extended this period to 180 (one hundred and eighty) working days, excluding any time taken by parties in furnishing information, clarifications or responses, while retaining the CCI’s power to further extend the timeline by recording reasons in writing.
• Treatment of incomplete commitment applications: Under the existing regulations, the CCI may require an applicant to rectify defects in an incomplete commitment application within 10 (ten) working days, failing which the application may be treated as invalid. The Amendment Regulations have replaced this framework with a structured return-and-refiling mechanism, whereby defective applications will be returned to the applicant for rectification, may be refiled within 10 (ten) working days, and will be rendered invalid if the identified defects are not cured within the prescribed timeline. The Amendment Regulations also clarify that the fee paid with the original application will be adjusted upon refiling.

(Source: Amendment Regulations)

 

This Newsletter has been prepared by:

 

Vaibhav Choukse Partner	Ela Bali Partner	Aditi Khanna Principal Associate	Faiz Siddiqui Senior Associate
Aarathi R Menon Associate	Priyanshi Jain Associate	Yaatri Shah Associate

 

For more details, please contact km@jsalaw.com.

 

[1]      Approx. USD 105,418 (US Dollars one hundred five thousand four hundred and eighteen)

[2]      Approx. USD 21,083 (US Dollars twenty-one thousand eighty-three)

[3]      Approx. USD 13,390,000 (US Dollars thirteen million three hundred and ninety thousand)

[4]      Approx. USD 126 (US Dollars one hundred and twenty-six)

[5]      Approx. USD 91,714 (US Dollars ninety-one thousand seven hundred and fourteen)

[6]      Approx. USD 1,270,000 (US Dollars one million two hundred and seventy thousand)

[7]      Approx. USD 116 (US Dollars one hundred and sixteen)

[8]      Approx. USD 82,226 (US Dollars eighty-two thousand two hundred and twenty-six)

[9]      Approx. USD 1,360 (US Dollars one thousand three hundred and sixty)

[10]    Approx. USD 2,351 (US Dollars two thousand three hundred and fifty-one)

[11]    Approx. USD 6,747 (US Dollars six thousand seven hundred and forty-seven)

[12]    Approx. USD 854 (US Dollars eight hundred and fifty-four)

[13]    Approx. USD 4,132 (US Dollars four thousand one hundred and thirty-two)

[14]    Approx. USD 6,230 (US Dollars six thousand two hundred and thirty)

[15]    JSL owns integrated operations to run stainless steel manufacturing and processing facilities in India and across the world.