Taxation of Distributions on the Equity Shares

Subject to the Passive Foreign Investment Company (“PFIC”) rules discussed below, the gross amount of distributions to you
with respect to the Equity Shares generally will be included in your gross income in the year received as foreign source ordinary
dividend income, but only to the extent that the distribution is paid out of the Bank’s current or accumulated earnings and
profits (as determined under United States federal income tax principles). To the extent that the amount of the distribution
exceeds the Bank’s current and accumulated earnings and profits, it will be treated first as a tax-free return of your tax basis in
your Equity Shares, and to the extent the amount of the distribution exceeds your tax basis, the excess will be taxed as capital
gain. However, the Bank does not intend to calculate its earnings and profits under United States federal income tax principles.
Therefore, a U.S. Holder should expect that a distribution will generally be treated as a dividend. The dividends will not be
eligible for the dividends-received deduction allowed to corporations in respect of dividends received from other U.S.
corporations.

Subject to applicable limitations, with respect to non-corporate U.S. Holders (including individual U.S. Holders), dividends
may constitute “qualified dividend income” that is taxed at the lower applicable capital gains rate provided that (1) the Bank is
not a PFIC (as discussed below) for either the taxable year in which the dividend is paid or the preceding taxable year, (2) such
dividend is paid on the Equity Shares that have been held by you for at least 61 days during the 121-day period beginning 60
days before the ex-dividend date, and (3) the Bank is eligible for the benefits of the US India Treaty. The Bank expects to be
eligible to for the benefits of the US India Treaty. The Bank does not believe it was a PFIC for the taxable year ending March
31, 2020 and does not expect to be a PFIC for the current year or any future years. Non-corporate U.S. Holders are strongly
urged to consult their tax advisors regarding the availability of the lower rate for dividends paid with respect to the Equity
Shares.

The amount of any distribution paid by the Bank in a currency other than U.S. dollars (a “foreign currency”) will be equal to
the U.S. dollar value of such foreign currency on the date such distribution is received by the U.S. Holder, regardless of whether
the payment is in fact converted into U.S. dollars at that time. If the foreign currency so received is converted into U.S. dollars
on the date of receipt, a U.S. Holder generally will not recognize foreign currency gain or loss on such conversion. If the foreign
currency so received is not converted into U.S. dollars on the date of receipt, a U.S. Holder will have a basis in the foreign
currency equal to its U.S. dollar value on the date of receipt. Gain or loss, if any, realized on the subsequent sale or other
disposition of such foreign currency will generally be U.S. source ordinary income or loss. The amount of any distribution of
property other than cash will be the fair market value of such property on the date of distribution.

For foreign tax credit purposes, dividends distributed with respect to the Equity Shares will generally constitute “passive
category income”. A U.S. Holder will not be able to claim a U.S. foreign tax credit for Indian taxes for which the Bank is liable
and must pay with respect to distributions on the Equity Shares. The rules relating to the determination of the U.S. foreign tax
credit are complex and U.S. Holders should consult their tax advisors to determine whether and to what extent a credit would
be available in their particular circumstances.

Taxation of a Disposition of Equity Shares

Subject to the PFIC rules discussed below, you generally will recognize capital gain or loss on any sale or other taxable
disposition of an Equity Share equal to the difference between the U.S. dollar value of the amount realized for the Equity Share
and your tax basis (in U.S. dollars) in the Equity Share. If you are a non-corporate U.S. Holder (including an individual U.S.
Holder) who has held the Equity Share for more than one year, capital gain on a disposition of an Equity Share generally will
be eligible for reduced federal income tax rates. The deductibility of capital losses is subject to limitations. Any such gain or
loss that you recognize generally will be treated as U.S. source income or loss for foreign tax credit limitation purposes.

Because gains on a disposition of an Equity Share generally will be treated as U.S. source, the use of foreign tax credits relating
to any Indian income tax imposed upon gains in respect of the Equity Shares may be limited. U.S. Holders should consult their
tax advisors regarding the application of Indian taxes to a disposition of an Equity Share and their ability to credit an Indian tax
against their United States federal income tax liability.

A U.S. Holder that receives foreign currency from the sale or disposition of Equity Shares generally will realize an amount
equal to the U.S. dollar value of such foreign currency on the date of sale or disposition or, if such U.S. Holder is a cash basis
or electing accrual basis taxpayer and the Equity Shares are treated as being traded on an “established securities market” for
this purpose, the settlement date. If the Equity Shares are so treated and the foreign currency received is converted into U.S.
dollars on the settlement date, a cash basis or electing accrual basis U.S. Holder will not recognize foreign currency gain or loss
on the conversion. If the foreign currency received is not converted into U.S. dollars on the settlement date, the U.S. Holder will
have a basis in the foreign currency equal to its U.S. dollar value on the settlement date. Gain or loss, if any, realized on the
subsequent conversion or other disposition of such foreign currency will generally be U.S. source ordinary income or loss.

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