Pursuant to the Scheme of Amalgamation, the business undertaking of Ritemed comprising its retail trading of medicines and
general items business together with inter-alia, all the assets, liabilities, rights, title, interest, obligations, risks and rewards
relating to and arising out of the business undertaking was transferred to Optival as on April 1, 2016 (“Appointed Date”). All
legal proceedings in relation to the said business undertaking, pending as on the Appointed Date or in respect of which, the
cause of action had arisen on or prior to the Appointed Date, shall be managed by Optival and that all claims, liabilities,
obligations etc., arising out of such legal proceedings shall be borne by Optival.

1.

DMPL

The Income Tax Officer, Income Tax Department Hyderabad (“AO Hyderabad”) issued a show-cause notice and
assessment order on December 31, 2016 to Ritemed, wherein the AO, Hyderabad had alleged failure on the part of
Ritemed to substantiate with sufficient or relevant supporting documents, the claims of expenditure in the financial
statements of Ritemed for the Assessment Year 2013—14 from Ritemed. The net profit margin in the medicinal industry
was assessed by the officer in other pharmaceutical stores, and based on the assessment of the officer, the income was
as assessed at 3% of the total turnover of Ritemed, instead of the value disclosed by Ritemed. For the assessment year
2014-15, the total tax payable by Ritemed as calculated by the AO Hyderabad was 226.07 million. On January 25,
2017, Ritemed filed a rectification application, requesting the AO Hyderabad to consider set off of unabsorbed losses
and depreciation from previous years which Ritemed is eligible to claim, thus eliminating the entire tax liability for
the assessment year 2014-15. On February 15, 2017, Ritemed filed an appeal before the Commissioner of Income Tax
(Appeals), Hyderabad — 3 (“CIT (A) Hyderabad”) against the order dated December 31, 2016 issued by the AO
Hyderabad, stating that the submissions and certified accounts submitted to AO, Hyderabad were not considered, that
AO Hyderabad also did not account for set off of unabsorbed losses and depreciation, and that further, it calculated
income on the basis of estimation and seeking, among others, deletion of addition of estimated profit and quashing of
penalty proceedings initiated by AO, Hyderabad. Post due hearing on February 20, 2020, the case was remanded back
to the AO Hyderabad. On August 4, 2020, Optival sought complete relief in the matter before the CIT (A) Hyderabad,
and further requested for a hearing date to be fixed. This matter is currently pending.

The Income Tax Officer, Income Tax Department Hyderabad (“AO Hyderabad”) issued a show-cause notice and
notice of demand to Ritemed on February 28, 2015 wherein the AO, Hyderabad had alleged that certain capital
expenses such as purchase of storage boxes, fans, cycles, repair costs and loan processing charges were claimed as
revenue expenses by Ritemed and were therefore being disallowed. Rent paid for certain stores, advances paid, credit
card commission and home delivery expenses were also disallowed due to lack of supporting documents. Manpower
expenses including service tax inputs claimed as a loss was further disallowed with the reasoning that Ritemed is not
a service providing business or in the business of manpower deployment. The total disallowed expense was 218.36
million. On May 5, 2015, Ritemed preferred an appeal with the Commissioner of Income Tax (Appeals), Hyderabad
~ IV (“CIT (A) Hyderabad”), among others stating that purchase of storage boxes, loan processing charges, drug
license processing, credit card commission, home delivery charges, etc. are expenses incurred in the ordinary course
of business and should be considered revenue expenses; that rent expenses disallowed was incorrect as business has
commenced in such stores; that no opportunity of being heard was provided before disallowing the manpower expenses
etc. On November 1, 2019, the CIT (A) Hyderabad duly passed an order, allowing the said appeal partly and allowing
the claim of expenses of 210.16 million and confirming the disallowance for the remaining expenses. Against the said
order of CIT, on January 17, 2020, Optival has further preferred an appeal with the Income Tax Appellate Tribunal,
claiming that the remaining expenses of %8.19 million were also revenue in nature as they were incurred in the ordinary
course of business and accordingly, should be allowed. The matter is currently pending.

The Office of the Assistant Commissioner of Income Tax, Hyderabad (“ACIT Hyderabad”) issued an assessment
order and notice of demand on December 31, 2019 among others disallowing depreciation on goodwill of 3208.16
million and treating the goodwill balance as nil as opposed to 2829.95 million, alleging that the valuation of goodwill
arising out of the amalgamation of Ritemed and Optival is incorrect due to being unverified and artificial. The
disallowed depreciation was added to the income of Optival, giving rise to a demand of %121,073. On January 29,
2020, Optival preferred an appeal with the Commissioner of Income Tax (Appeals), Hyderabad — 4 (“CIT (A)
Hyderabad”), among others seeking relief to not treat goodwill value as nil and to allow depreciation on goodwill on
the ground that goodwill transferred on amalgamation is a depreciable intangible asset and the law on assets not in the
books of accounts permits such valuation of goodwill. Pending the appeal, a show-cause notice for levy of penalty for
non-payment of demand amount was served upon Optival by the ACIT Hyderabad on February 4, 2020. Optival filed
a response to the show-cause notice with the DCIT on February 5, 2020 stating that a rectification application of the
assessment order and an appeal with the CIT (A) Hyderabad has been filed, during the pendency of which such penalty
cannot be imposed. On August 21, 2020, Optival requested the DCIT to take into account the rectification application
filed before it and pass a revised order. The matter is currently pending.

The Income Tax Officer, Income Tax Department, Bangalore issued a final assessment order and a notice of demand
on November 28, 2019 with a demand for 2192.53 million due to the difference of 2420.37 million in the turnover
of the Company as per VAT returns and as per financials of the Company for the financial year 2016 - 2017, alleging
that Deccan’s response that the VAT returns are based on maximum retail price (“MRP”) and the financials are based
on the discounted prices of the products sold has not been substantiated. Aggrieved by the order, on December 13,
2019, Deccan filed an appeal with the Commissioner of Income Tax (Appeals), Bangalore (“CIT(A) Bangalore”)
seeking relief from paying the additional amount. On January 23, 2020, the written submissions for the appeal were

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