CERTAIN UNITED STATES FEDERAL INCOME TAX CONSIDERATIONS

The following is a general description of certain material United States federal income tax consequences to U.S. Holders under
present law of an investment in the Equity Shares. This summary applies only to investors that hold the Equity Shares as capital
assets (generally, property held for investment). This discussion is based on the tax laws of the United States as in effect on the
date of this Placement Document; U.S. Treasury regulations in effect or, in some cases, proposed, as of the date of this
Placement Document; judicial and administrative interpretations thereof available on or before such date; and the Convention
Between the Government of the United States of America and the Government of the Republic of India for the Avoidance of
Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (the “US India Treaty”). All of the
foregoing authorities are subject to change, which change could apply retroactively and could affect the tax consequences
described below.

The following discussion does not address alternative minimum tax considerations or state, local, non-United States or other
tax laws, or the tax consequences to any particular investor or to persons in special tax situations such as:

. banks;

° certain financial institutions;

. insurance companies;

° dealers in stocks, securities, currencies or notional principal contracts;

. U.S. expatriates and former long-term residents of the United States;

. regulated investment companies and real estate investment trusts;

. tax-exempt entities, including companies classified as foreign governments for U.S. federal income tax purposes;

. U.S. Holders that have a functional currency other than the U.S. dollar;

° persons holding an Equity Share as part of a straddle, hedging, conversion or integrated transaction;

. persons that actually or constructively own 10% or more of the Bank’s voting stock;

. persons who acquired Equity Shares pursuant to the exercise of any employee share option or otherwise as
consideration;

. persons holding Equity Shares who are not U.S. Holders (defined below); or

. persons holding Equity Shares through partnerships or other pass-through entities.

For purposes of this summary, a “U.S. Holder” is a beneficial owner of Equity Shares that is for United States federal income
tax purposes,

° an individual who is a citizen or resident of the United States;

. a corporation organized under the laws of the United States, any state thereof or the District of Columbia;

° an estate whose income is subject to United States federal income taxation regardless of its source; or

. a trust that (1) is subject to the primary supervision of a court within the United States and the control of one or more

U.S. persons for all substantial decisions of the trust, or (2) has a valid election in effect under the applicable U.S.
Treasury regulations to be treated as a U.S. person.

If you are a partner in a partnership, or other entity taxable as a partnership for United States federal income tax purposes, that
holds Equity Shares, your tax treatment generally will depend on your status and the activities of the partnership. Prospective
purchasers of Equity Shares that are partnerships should consult their tax advisors.

PROSPECTIVE PURCHASERS ARE URGED TO CONSULT THEIR TAX ADVISORS REGARDING THE
APPLICATION OF THE UNITED STATES FEDERAL TAX RULES TO THEIR PARTICULAR
CIRCUMSTANCES AS WELL AS THE STATE AND LOCAL, FOREIGN AND OTHER TAX CONSEQUENCES
TO THEM OF THE PURCHASE, OWNERSHIP AND DISPOSITION OF EQUITY SHARES.

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