71. Compliance with provisions of Foreign Account Tax Compliance Act may affect payments on the Equity
Shares.

The U.S. “Foreign Account Tax Compliance Act” (or “FATCA”) imposes a new reporting regime and potentially,
imposes a 30% withholding tax on certain “foreign passthru payments” made by certain non-U.S. financial
institutions (including intermediaries).

If payments on the Equity Shares are made by such non-U.S. financial institutions (including intermediaries), this
withholding may be imposed on such payments if made to any non-U.S. financial institution (including an
intermediary) that is not otherwise exempt from FATCA or other holders who do not provide sufficient identifying
information to the payer, to the extent such payments are considered “foreign passthru payments”. Under current
guidance, the term “foreign passthru payment” is not defined and it is therefore not clear whether and to what
extent payments on the Equity Shares would be considered “foreign passthru payments”. The United States has
entered into intergovernmental agreements with many jurisdictions (including India) that modify the FATCA
withholding regime described above. It is not yet clear how the intergovernmental agreements between the United
States and these jurisdictions will address “foreign passthru payments” and whether such agreements will require
us or other financial institutions to withhold or report on payments on the Equity Shares to the extent they are
treated as “foreign passthru payments”. Prospective investors should consult their tax advisors regarding the
consequences of FATCA, or any intergovernmental agreement or non-U.S. legislation implementing FATCA, to
their investment in Equity Shares.

72. U.S. holders should consider the impact of the passive foreign investment company rules in connection
with an investment in our Equity Shares.

A foreign corporation will be treated as a passive foreign investment company (“PFIC”) for U.S. federal income
tax purposes for any taxable year in which either: (i) at least 75% of its gross income is “passive income” or (ii)
at least 50% of its gross assets during the taxable year (based on of the quarterly values of the assets during a
taxable year) are “passive assets,” which generally means that they produce passive income or are held for the
production of passive income.

There can be no assurance that our Company will or will not be considered a PFIC in the current or future years.
The determination of whether or not our Company is a PFIC is a factual determination that is made annually after
the end of each taxable year, and there can be no assurance that our Company will not be considered a PFIC in
the current taxable year or any future taxable year because, among other reasons, (i) the composition of our
Company’s income and assets will vary over time, and (ii) the manner of the application of relevant rules is
uncertain in several respects. Further, our Company’s PFIC status may depend on the market price of its Equity
Shares, which may fluctuate considerably.

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