Indiabulls Housing Finance : Draft Shelf Prospectus (Draft filed with SE)

Draft Shelf Prospectus

June 20, 2023

INDIABULLS HOUSING FINANCE LIMITED

Our Company was incorporated as Indiabulls Housing Finance Limited under the Companies Act, 1956 on May 10, 2005, in New Delhi with the Registrar of Companies, National Capital Territory of Delhi and Haryana ("RoC") and received a certificate for commencement of business from the RoC on January 10, 2006. The CIN of our Company is L65922DL2005PLC136029. Our Company has obtained a certificate of registration dated December 28, 2005, bearing registration number 02.0063.05. from the National Housing Bank ("NHB") to carry on the business of a housing finance institution without accepting public deposits in accordance with Section 29A of National Housing Bank Act, 1987. The PAN of our Company is AABCI3612A. For details of changes to the name and registered office of our Company, see "History and other Corporate Matters" on page 169. Registered Office: 5th Floor, Building No. 27, KG Marg Connaught Place, New Delhi - 110 001, India; Telephone No.: [phone]; Facsimile No.: [phone]

Corporate Office: One International Centre, Tower 1, 18th Floor, Senapati Bapat Marg, Elphinstone Road, Mumbai - 400 013, Maharashtra, India Plot No. 422B, Udyog Vihar, Phase-IV,Gurugram, Haryana - 122 016;

Telephone No.: [phone] Facsimile No.: [phone]; Website: www.indiabullshomeloans.com; Email: [e-mail]

Company Secretary and Compliance Officer: Mr. Amit Kumar Jain; Telephone No.: [phone]; Facsimile No.: [phone]; E-mail: [e-mail]

Chief Financial Officer: Mr. Mukesh Kumar Garg; Telephone No.: 0124 6681199; Facsimile No.: 0124 6681240; Email: [e-mail]

Statutory Auditors: S.N. Dhawan & CO LLP, Chartered Accountants; Address: Plot No. 51-52, 2nd Floor, Sector - 18, Udyog Vihar, Phase IV, Gurugram, Haryana - 122 016; Telephone No.: [phone]; Email: [e-mail]; Contact Person: Mr. Rahul Singhal, Partner; and Arora & Choudhary Associates, Chartered Accountants; Address: Plot no. 8/28, W.E.A, Abdul Aziz Road, Karol Bagh, New Delhi - 110 005; Telephone No.: [phone] Email: [e-mail]; Contact Person: Mr. Vijay Kumar Choudhary, Partner

OUR COMPANY IS A PROFESSIONALLY MANAGED COMPANY AND DOES NOT HAVE AN IDENTIFIABLE PROMOTER

PUBLIC ISSUE BY INDIABULLS HOUSING FINANCE LIMITED, ("COMPANY" OR "ISSUER") OF SECURED REDEEMABLE NON-CONVERTIBLE DEBENTURES OF FACE VALUE OF ₹1,000 EACH, ("NCDs"), FOR AN AMOUNT UPTO ₹2,000 CRORES ("SHELF LIMIT"), HEREINAFTER REFERRED TO AS THE "ISSUE". THE NCDs WILL BE ISSUED IN ONE OR MORE TRANCHES UP TO THE SHELF LIMIT, IN THE RELEVANT TRANCHE PROSPECTUS FOR ANY TRANCHE ISSUE (EACH A "TRANCHE ISSUE"), WHICH SHOULD BE READ TOGETHER WITH THIS DRAFT SHELF PROSPECTUS AND THE SHELF PROSPECTUS (COLLECTIVELY THE "OFFER DOCUMENTS"). THE ISSUE IS BEING MADE PURSUANT TO THE PROVISIONS OF SECURITIES AND EXCHANGE BOARD OF INDIA (ISSUE AND LISTING OF NON-CONVERTIBLE SECURITIES) REGULATIONS, 2021 (THE "SEBI NCS REGULATIONS"), THE COMPANIES ACT, 2013 AND RULES MADE THEREUNDER, AS AMENDED AND TO THE EXTENT NOTIFIED.

GENERAL RISKS

Investment in debt securities involve a degree of risk and investors should not invest any funds in such securities unless they can afford to take the risk attached to such investments. Investors are advised to take an informed decision and to read the risk factors carefully before investing in this offering. For taking an investment decision, investors must rely on their examination of the issue including the risks involved in it. Specific attention of investors is invited to statement of risk factors contained under "Risk Factors" and "Material Developments" on page 20 and 210, respectively. These risks are not, and are not intended to be, a complete list of all risks and considerations relevant to the debt securities or investor's decision to purchase such securities. This Draft Shelf Prospectus has not been and will not be approved by any regulatory authority in India, including the Securities and Exchange Board of India ("SEBI"), the Reserve Bank of India ("RBI"), the NHB, RoC or any stock exchange in India nor do they guarantee the accuracy or adequacy of this document.

ISSUER'S ABSOLUTE RESPONSIBILITY

The Issuer, having made all reasonable inquiries, accepts responsibility for, and confirms that this Draft Shelf Prospectus read together with the Shelf Prospectus and relevant Tranche Prospectus for a Tranche Issue does contain and will contain all information with regard to the Issuer and relevant Tranche Issue which is material in the context of the Issue. The information contained in this Draft Shelf Prospectus read together with Shelf Prospectus and relevant Tranche Prospectus is true and correct in all material respects and is not misleading in any material respect, that the opinions and intentions expressed herein are honestly stated and that there are no other facts, the omission of which makes this Draft Shelf Prospectus as a whole or any of part of such information or the expression of any such opinions or intentions misleading, in any material respect. This Issue is not underwritten.

COUPON RATE, COUPON PAYMENT FREQUENCY, REDEMPTION DATE, REDEMPTION AMOUNT & ELIGIBLE INVESTORS

For the details relating to Coupon Rate, Coupon Payment Frequency, Redemption Date and Redemption Amount of the NCDs, see "Terms of the Issue" on page 305. For details relating to Eligible Investors please see "Issue Related Information" on page 300.

	CREDIT RATING AGENCIES
CRISIL Ratings Limited (a subsidiary of CRISIL Limited)		ICRA Limited
CRISIL House, Central Avenue, Hiranandani Business Park, Powai, Mumbai - 400 076		Electric Mansion, 3rd Floor, Appasaheb Marathe Marg, Prabhadevi, Mumbai - 400 025
Telephone: [phone]		Telephone: [phone]
Email: [e-mail]		Email: [e-mail]
Contact Person: Ajit Velonie		Contact Person: L Shivakumar
	CREDIT RATINGS

The NCDs proposed to be issued under this Issue have been rated "CRISIL AA/Stable" (pronounced as CRISIL double A rating with stable outlook) by CRISIL Ratings Limited vide their letter dated September 23, 2022 and further revalidated vide letters dated November 7, 2022, December 7, 2022 and February 6, 2023, read with rationale dated September 22, 2022, and "[ICRA]AA (Stable)" (pronounced as ICRA double A rating with a stable outlook) by ICRA Limited vide their letter dated April 3, 2023 read with rationale dated April 4, 2023. For the rationale and press release for these ratings, see "General Information", Annexure A and Annexure B of this Draft Shelf Prospectus. These ratings are not a recommendation to buy, sell or hold securities and investors should take their own decision. These ratings are subject to suspension, revision or withdrawal at any time by the assigning rating agencies and should be evaluated independently of any other ratings.

LISTING

The NCDs offered through this Draft Shelf Prospectus along with the Shelf Prospectus and relevant Tranche Prospectus are proposed to be listed on BSE Limited ("BSE") and National Stock Exchange of India Limited ("NSE" along with BSE, the "Stock Exchanges"). Our Company has received an 'in-principle' approval from BSE vide its letter no. [●] dated [●] and NSE vide its letter no. [●] dated [●]. For the purposes of the Issue BSE shall be the Designated Stock Exchange.

PUBLIC COMMENTS

This Draft Shelf Prospectus dated June 20, 2023 shall be filed with BSE and NSE, pursuant to Regulation 27(2) of the SEBI NCS Regulations and will be open for public comments for a period of seven Working Days (i.e., until 5 p.m.) from the date of filing of this Draft Shelf Prospectus with the Designated Stock Exchange. All comments on this Draft Shelf Prospectus are to be forwarded to the attention of the Company Secretary and Compliance Officer of our Company. Comments may be sent through post, facsimile or e-mail. However, please note that all comments by post must be received by the Issuer by 5:00 p.m. (Indian Standard Time) on the seventh Working Day from the date on which this Draft Shelf Prospectus is hosted on the website of the Designated Stock Exchange. All comments received on this Draft Shelf Prospectus will be suitably addressed prior to filing of the Shelf Prospectus with the RoC.

LEAD MANAGERS TO THE ISSUE

EDELWEISS FINANCIAL SERVICES LIMITED	ELARA CAPITAL (INDIA) PRIVATE LIMITED	TRUST INVESTMENT ADVISORS PRIVATE LIMITED
801 - 804, Wing A, Building No 3, Inspire BKC, G Block, Bandra	One International Centre, Tower 3, 21st Floor, Senapati Bapat Marg,	109/110, Balarama, Bandra Kurla Complex, Bandra East,
Kurla Complex, Bandra East, Mumbai - 400 051	Elphinstone Road West, Mumbai - 400 013	Mumbai - 400 051
Telephone No.: [phone]	Telephone No.: [phone]	Telephone No.: [phone]
Email: [e-mail]	Email: [e-mail]	Email: [e-mail]
Contact Person: Lokesh Singhi / Saili Dave	Contact Person: Ms. Astha Daga	Contact Person: Ms. Hani Jalan
DEBENTURE TRUSTEE**	REGISTRAR TO THE ISSUE

IDBI TRUSTEESHIP SERVICES LIMITED

Universal Insurance Building, Ground Floor, Sir P.M. Road, Mumbai - 400 001, Maharashtra, India Telephone No.: [phone]

Email: [e-mail]/[e-mail]

Investor Grievance Email: [e-mail]

Contact Person: Ashish Naik

Website: www.idbitrustee.com

KFIN TECHNOLOGIES LIMITED (formerly known as KFIN Technologies Private Limited) Selenium Tower B, Plot No - 31 & 32, Financial District, Nanakramguda, Serilingampally, Hyderabad Rangareddi, 500 032, Telangana, India

Telephone No.: [phone]

Facsimile No.: [phone]

Email: [e-mail]

Website: www.kfintech.com

	ISSUE PROGRAMME*
ISSUE OPENS ON: As specified in the relevant Tranche Prospectus		ISSUE CLOSES ON: As specified in the relevant Tranche Prospectus

• The Issue shall remain open for subscription on Working Days from 10 a.m. to 5 p.m. during the period indicated in the relevant Tranche Prospectus, except that the Issue may close on such earlier date or extended date as may be decided by the Board of Directors of our Company or Securities Issuance and Investment Committee thereof, subject to compliance with Regulation 33A of the SEBI NCS Regulations and receipt of necessary approvals. In the event of an early closure or extension of the Issue, our Company shall ensure that notice of the same is provided to the prospective investors through an advertisement on or before such earlier or extended date of Issue closure in which pre-issue advertisement and advertisement for opening or closure of the Issue have been given. Applications Forms for the Issue will be accepted only from 10:00 a.m. to 5:00 p.m. or such extended time as may be permitted by BSE and NSE, on Working Days, during the Issue Period. On the Issue Closing Date, the Application Forms will be accepted only between 10 a.m. to 3 p.m. (Indian Standard Time) and uploaded until 5 p.m. or such extended time as may be permitted by BSE and NSE. Further, pending mandate requests for bids placed on the last day of bidding will be validated by 5 p.m. (Indian Standard Time) on one Working Day post the Issue
  Closing Date. For further details please refer to the section titled "Issue Related Information" on page 300.
• IDBI Trusteeship Services Limited under Regulation 8 of SEBI NCS Regulations has by its letter dated June 19, 2023 has given its consent for its appointment as Debenture Trustee to the Issue and for its name to be included in Offer Document and in all the subsequent periodical communications sent to the holders of the Debentures issued pursuant to this Issue. For further details, please see Annexure C of this Draft Shelf Prospectus.
  A copy of the Shelf Prospectus and relevant Tranche Prospectus(es) shall be filed with the Registrar of Companies, National Capital Territory of Delhi and Haryana, in terms of section 26 and 31 of the Companies Act, 2013, along with the endorsed/certified copies of all requisite documents. For further details please see "Material Contracts and Documents for Inspection" on page 379.

TABLE OF CONTENTS
SECTION I: GENERAL	3
DEFINITIONS AND ABBREVIATIONS	3
CERTAIN CONVENTIONS, USE OF FINANCIAL, INDUSTRY AND MARKET DATA AND
CURRENCY OF PRESENTATION	17
FORWARD LOOKING STATEMENTS	19
SECTION II: RISK FACTORS	20
SECTION III: INTRODUCTION	66
GENERAL INFORMATION	66
CAPITAL STRUCTURE	77
OBJECTS OF THE ISSUE	92
STATEMENT OF TAX BENEFITS	95
SECTION IV: ABOUT OUR COMPANY	112
INDUSTRY OVERVIEW	112
OUR BUSINESS	141
HISTORY AND OTHER CORPORATE MATTERS	169
REGULATIONS AND POLICIES	173
OUR MANAGEMENT	189
RELATED PARTY TRANSACTIONS	208
SECTION V: FINANCIAL INFORMATION	209
FINANCIAL STATEMENTS	209
MATERIAL DEVELOPMENTS	210
FINANCIAL INDEBTEDNESS	211
SECTION VI: LEGAL AND OTHER INFORMATION	250
OUTSTANDING LITIGATIONS AND DEFAULTS	250
OTHER REGULATORY AND STATUTORY DISCLOSURES	276
SECTION VII: ISSUE RELATED INFORMATION	300
ISSUE STRUCTURE	300
TERMS OF THE ISSUE	305
ISSUE PROCEDURE	323
SECTION VIII: MAIN PROVISIONS OF ARTICLES OF ASSOCIATION OF OUR COMPANY	353
SECTION IX: MATERIAL CONTRACTS AND DOCUMENTS FOR INSPECTION	379
DECLARATION	381
ANNEXURE A - CREDIT RATINGS AND RATIONALE FROM CRISIL RATINGS	382
ANNEXURE B - CREDIT RATING AND RATIONALE FROM ICRA LIMITED	383
ANNEXURE C - CONSENT FROM DEBENTURE TRUSTEE	384

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SECTION I: GENERAL

DEFINITIONS AND ABBREVIATIONS

Unless the context otherwise indicates, all references in this Draft Shelf Prospectus to "the Issuer", "our Company", "the Company" or "IHFL" are to Indiabulls Housing Finance Limited, a public limited company incorporated under the Companies Act, 1956, as amended and replaced from time to time, having its registered office at 5th Floor, Building No. 27, KG Marg Connaught Place, New Delhi - 110001, India. Unless the context otherwise indicates, all references in this Draft Shelf Prospectus to "we" or "us" or "our" are to our Company and its Subsidiaries (collectively referred to as the "Group") and OakNorth, as may be applicable, on a consolidated basis.

Unless the context otherwise indicates or implies, the following terms have the following meanings in this Draft Shelf Prospectus, and references to any legislation, act, regulation, rules, guidelines or policies shall be to such legislation, act, regulation, rules, guidelines or policies as amended from time to time.

Company related terms

Term			Description
"we" or "us" or "our"		Unless the context otherwise indicates or implies, refers to our Company together
			with our Subsidiaries. In addition to the above, the following trusts were
			consolidated in the Reformatted Consolidated Financial Information (i) ICCL
			Lender Repayment Trust; (ii) IBHFL Lender Repayment Trust; and (iii) Pragati
			Employee Welfare Trust, formed on December 3, 2019. Subsidiaries for the
			purpose of financial data as at and for the years ended March 31, 2021, 2022 and
			2023 would mean subsidiaries and the trusts during and as at year end/period end
			respectively as applicable
₹/Rs./INR/Rupees/Indian	The lawful currency of the Republic of India
Rupees
Articles/	Articles	of	Articles of Association of our Company
Association/AoA
Assets	Liability	Assets Liability Management Committee of the Board of Directors
Management Committee
or ALCO
Audit Committee		Audit committee of the Board of Directors
"Auditors" or "Statutory	The joint statutory auditors of the Company, S. N. Dhawan & CO LLP, Chartered
Auditors"	or "Joint	Accountants and Arora & Choudhary Associates, Chartered Accountants.
Statutory Auditors"
Board/	Board	of	Board of Directors of our Company or a duly constituted committee thereof
Directors
Chairman			The chairman of our Board of Directors, Mr. Subhash Sheoratan Mundra
CEO			Chief Executive Officer of our Company, Mr. Gagan Banga
Company	Secretary	and	The company secretary and compliance officer of our Company, Mr. Amit Kumar
Compliance Officer		Jain
Corporate Office		One International Centre, Tower 1, 18th Floor, Senapati Bapat Road, Mumbai -
			400013, Maharashtra, India and Plot No. 422B, Udyog Vihar, Phase-IV,
			Gurugram, Haryana - 122 016
Corporate	Social	Corporate Social Responsibility Committee of the Board of Directors
Responsibility
Committee
Director(s)			Director of our Company, unless otherwise specified
DSA			Direct Selling Agent
Equity Shares		Equity shares of our Company of face value of ₹2 each
Erstwhile Auditors		The erstwhile statutory auditors of our Company, S.R. Batliboi & Co. LLP,
			Chartered Accountants
Group Companies		Includes such companies, other than Subsidiary/Subsidiaries, with which there
			were related party transactions, during the period for which financial information
			is disclosed in this Draft Shelf Prospectus, as covered under the applicable
			accounting standards and also other companies as considered material by the Board
			of the Company
IBFSL			Indiabulls Financial Services Limited
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Term			Description
IBFSL-IHFL Scheme	Scheme of amalgamation for the amalgamation of Indiabulls Financial Services
			Limited with our Company
IBFSL	Stock Option	IHFL- IBFSL Employee Stock Option Plan 2006, IHFL- IBFSL Employee Stock
Schemes			Option Plan II 2006 and IHFL- IBFSL Employee Stock Option Plan 2008
IHFL			Indiabulls Housing Finance Limited
IHFL	Stock	Option	IHFL- IBFSL Employee Stock Option Plan 2006, IHFL- IBFSL Employee Stock
Schemes			Option Plan II 2006, IHFL- IBFSL Employee Stock Option Plan 2008, the
			Indiabulls Housing Finance Limited Employee Stock Option Scheme 2013, the
			Indiabulls Housing Finance Limited Employee Stock Benefit Scheme 2019 and the
			Indiabulls Housing Finance Limited - Employee Stock Benefit Scheme 2021.
Independent Director	A Non-executive, independent Director as per the Companies Act, 2013 and the
			SEBI Listing Regulations, who are currently on the Board of our Company
IT Strategy Committee	IT Strategy Committee of the Board of Directors
Key	Managerial	The key managerial personnel of the Company appointed in accordance with the
Personnel		provisions of SEBI ICDR Regulations and the Companies Act, 2013
Material Subsidiary	Indiabulls Commercial Credit Limited
Memorandum/		Memorandum of Association of our Company
Memorandum	of
Association/ MoA
Net worth		As defined in Sec 2(57) of the Companies Act, 2013, as follows:
			"Net worth means the aggregate value of the paid-up share capital and all reserves
			created out of the profits, securities premium account and debit or credit balance
			of profit and loss account, after deducting the aggregate value of the accumulated
			losses, deferred expenditure and miscellaneous expenditure not written off, as per
			the audited balance sheet but does not include reserves created out of revaluation
			of assets, write back of depreciation and amalgamation."
Nomination	and	Nomination and Remuneration Committee of the Board of Directors
Remuneration
Committee
Preference Shares	Authorised preference share capital of 1,000,000,000 preference shares of face
			value of ₹10 each as on March 31, 2023.
Erstwhile Promoter	Mr. Sameer Gehlaut
			Mr. Sameer Gehlaut (founder and Erstwhile Promoter), Inuus Infrastructure
			Private Limited and Sameer Gehlaut IBH Trust (Erstwhile Promoter Group
			Members) vide a letter dated March 14, 2022 addressed to the Board of Directors
			of our Company, had requested to be re-classified from the 'promoter and promoter
			group' category to 'public' category of Shareholders of our Company, in
			accordance with Regulation 31A of the SEBI Listing Regulations, subject to
			receipt of requisite approvals. Thereafter, the Board, at its meeting held on March
			15, 2022, considered and approved the request. Further, the Shareholders of the
			Company, at their extraordinary general meeting held on April 18, 2022, approved
			said re-classification, subject to Stock Exchanges and other approvals. On April
			19, 2022, the Company filed the relevant applications with National Stock
			Exchange of India Limited and BSE Limited for approval of this re-classification
			and received the approvals from both Stock Exchanges vide their letters dated
			February 22, 2023.
Erstwhile	Promoter	Includes the Erstwhile Promoter, Inuus Infrastructure Private Limited and Sameer
Group			Gehlaut IBH Trust
Reformatted	Financial	Collectively, the Reformatted Consolidated Financial Information and the
Information		Reformatted Standalone Financial Information of our Company as at and for the
			years ended March 31, 2023, March 31, 2022 and March 31, 2021.
Reformatted		The Reformatted Consolidated Statement of Assets and Liabilities as at March 31,
Consolidated	Financial	2023, March 31, 2022 and March 31, 2021, the Reformatted Consolidated
Information		Statement of Profit and Loss, the Reformatted Consolidated Statement of Cash
			Flows and the Reformatted Consolidated Statement of Changes in Equity and the
			4

Term		Description
		Summary of Significant Accounting Policies and explanatory notes for the years
		ended March 31, 2023, March 31, 2022 and March 31, 2021 (together referred as
		'Reformatted Consolidated Financial Information') have been extracted by the
		Management from the Audited Consolidated Financial Statements of the Group as
		at and for the years ended March 31, 2023, March 31, 2022 and March 31, 2021
		("Audited Consolidated Financial Statements") respectively.
		The Audited Consolidated Financial Statements as at and for the years ended
		March 31, 2023, March 31, 2022 and March 31, 2021, prepared in accordance with
		the Indian Accounting Standards notified under Section 133 of the Companies Act,
		2013, read with Companies (Indian Accounting Standards) Rules 2015 as amended
		and other accounting principles generally accepted in India, which were approved
		by our Board on May 22, 2023, May 20, 2022 and May 19, 2021, respectively,
		form the basis for such Reformatted Consolidated Financial Information.
Reformatted Standalone	The Reformatted Standalone Statement of Assets and Liabilities as at March 31,
Financial Information	2023, March 31, 2022 and March 31, 2021 and the Reformatted Standalone
		Statement of Profit and Loss and the Reformatted Standalone Statement of Cash
		flows and the Reformatted Standalone Statement of Changes in Equity and the
		Summary of Significant Accounting Policies and explanatory notes for the years
		ended March 31, 2023, March 31, 2022 and March 31, 2021 (together referred as
		'Reformatted Standalone Financial Information') have been extracted by the
		Management from the Audited Standalone Financial Statements of the Company
		as at and for the years ended March 31, 2023, March 31, 2022 and March 31, 2021
		("Audited Standalone Financial Statements"), respectively.
		The Audited Standalone Financial Statements as at and for the years ended March
		31, 2023, March 31, 2022 and March 31, 2021, prepared in accordance with the
		Indian Accounting Standards notified under Section 133 of the Companies Act,
		2013, read with Companies (Indian Accounting Standards) Rules 2015 as amended
		and other accounting principles generally accepted in India, which were approved
		by our Board on May 22, 2023, May 20, 2022 and May 19, 2021, respectively,
		form the basis for such Reformatted Standalone Financial Information.
Risk	Management	Risk management committee of the Board of Directors
Committee
Registered Office	5th Floor, Building No. 27, KG Marg Connaught Place, New Delhi - 110001, India
RoC		Registrar of Companies, National Capital Territory of Delhi and Haryana
Securities	Issuance and	The committee constituted and authorised by our Board of Directors to take
Investment Committee	necessary decisions with respect to the Issue by way a board resolution dated
		March 21, 2023.
Shareholder(s)	The holder(s) of Equity Shares of our Company, unless otherwise specified in the
		context thereof.
Stakeholders'	The stakeholders' relationship committee of our Company
Relationship Committee
Subsidiary/Subsidiaries	The subsidiaries of our Company, namely:
		1. Indiabulls Commercial Credit Limited;
		2. Indiabulls Collection Agency Limited;
		3.	Ibulls Sales Limited;
		4. Indiabulls Capital Services Limited;
		5. Indiabulls Advisory Services Limited;
		6. Indiabulls Insurance Advisors Limited;
		7.	Indiabulls Holdings Limited*;
		8. Indiabulls Asset Holding Company Limited;
		9.	Nilgiri Investmart Services Limited (formerly known as Nilgiri Financial

Consultants Limited);

10. Indiabulls Investment Management Limited (formerly known as Indiabulls Venture Capital Management Company Limited)

Subsidiaries of our Company as of the date of this Draft Shelf Prospectus, in accordance with the Companies Act, 2013, from time to time. For the purpose of

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