Jurisdiction - India
Reports and Analysis
India – Trends In Cartel Enforcement.

9 April, 2014

 

 

Introduction


Antitrust laws in India are primarily captured in the Competition Act, 2002 (‘Act’), with their enforcement and administration entrusted to the Competition Commission of India (‘CCI’).


CCI is ably equipped to investigate anti-competitive practices, and is aided by its investigative arm, the Director General (‘DG’). CCI’s powers of investigation extend to the ability to summon and enforce the attendance of any person, examine him on oath, receive evidence on affidavit and issue commissions for the examination of witnesses and documents. Decisions of CCI may be challenged before the three-member Competition Appellate Tribunal (‘COMPAT’). A further appeal from the decision of COMPAT may lie before the Supreme Court of India.


CCI may initiate an inquiry in relation to an anti-competitive agreement1, including cartels,of its own volition (suo motu), on receipt of any information, or on the basis of a reference from the Central or a State Government, or a statutory authority. Any person, consumer or their association can provide information that triggers such inquiries. If CCI finds a prima facie case,it directs DG to carry out a detailed investigation. DG submits a report of its findings to which objections may be invited, and CCI may direct further investigation and conduct oral hearings.Finally, if CCI finds that an agreement is anti-competitive or that a cartel exists, it may impose penalties and pass any other order it deems appropriate.


Cartels – An Overview Of The Substantive Law


The Act regulates three types of practices: anti-competitive agreements, abuse of a dominant position and combinations (i.e. mergers, acquisitions, and amalgamations).
An anti-competitive agreement is one which causes an appreciable adverse effect on competition (‘AAEC’) in India. To determine an AAEC exists, CCI balances the possibility of: (a) creation of barriers to new entrants in the market; (b) ouster of existing competitors from the market; (c) foreclosure of competition by hindering entry, against (d) benefits to consumers; (e) improvements in production/distribution of goods; and (f) promotion of technical, scientific and economic development.


Section 3 of the Act deals with two types of potentially anti-competitive agreements: (i) agreements between/amongst competitors (horizontal agreements or cartels); and (ii) agreements between enterprises or persons at different stages or levels of the production chain (vertical agreements). Section 3(3) of the Act identifies four types of horizontal agreements, also called “cartel” agreements, which are presumed to cause an AAEC in India:

 

  • Price fixing agreements, i.e. agreements between competitors which directly or indirectly have the effect of fixing or determining purchase or sale prices;
  • Agreements between competitors which seek to limit or control production, supply or markets;
  • Market sharing agreements between competitors irrespective of the form that they may take; this includes market sharing by way of allocation of product(s), geographies or source of production; and
  • Bid-rigging agreements, i.e. agreements between competitors which have the effect of eliminating or reducing competition for bids or adversely affecting or manipulating the process of bidding.

CCI examines the evidence at hand and determines if there exists a horizontal “agreement” or a cartel. Once a cartel is found to exist, AAEC is presumed. Unless the presumption of AAEC is rebutted with the help of counter-evidence, orders prohibiting the cartel and/or imposing sanctions follow.


However, the presumption of AAEC does not attach to horizontal agreements if they are entered into by way of a joint venture, which increases efficiency in production, supply, distribution, storage, acquisition or control of goods or provision of services.
Given that Section 3(3) seeks to prohibit cartels on the basis of a presumption that they cause an AAEC and it is onerous to rebut such a presumption, the “standard of proof” required to establish the existence of a cartel agreement is a quintessential issue. Equally, once a cartel agreement is found to exist, the focus quickly shifts to the quantum of penalty that CCI may impose on cartel members. In the next section, we examine the nature of evidence that CCI has relied upon in the recent cases to establish the existence of a cartel agreement. Thereafter, we examine CCI’s approach to penalties for cartelization and the current leniency regime. Finally, the article outlines the proposed changes to the rules and procedure on conducting “dawn raids” which may provide a significant boost to CCI’s cartel enforcement endeavors.


‘Agreement’ – Standard Of Proof


The scope of the term “agreement”, as defined in the Act, extends to a mere “arrangement” or “understanding” or “action in concert”, none of which need be in writing or enforceable by law. This broad definition of the term “agreement” is no accident. Similar to other jurisdictions, the Indian legislators have intentionally defined the term in a broad manner because rarely, if ever, do cartels exist in explicit contractual form, and direct evidence is almost a myth. As a result, relatively less exacting and more achievable standards of proof are set as benchmarks.


Indian courts and quasi-judicial bodies like CCI are usually called upon to choose between two different standards of proof while determining the existence of a conduct or an agreement. For instance, to prove the existence of a cartel on the standard of balance of probabilities, CCI will merely have to show that it is more likely than not, that such an agreement exists. On the other hand, if CCI adopts the significantly higher beyond reasonable doubt standard of proof, it will have to ensure that its decision leaves no reasonable doubt as to the existence of such an agreement.


“Agreement” – Standard Of Proof – Trends


CCI flagged off its cartel enforcement endeavors by adopting something close to the beyond reasonable doubt standard. However, over time, CCI appears to have lowered the standard of proof required for establishing the existence of an “agreement”. In two of the early cases, the Tyre cartel2 and Deutsche Bank3, CCI held that the existence of an agreement must be established “unequivocally”, which appeared to be in line with the “beyond reasonable doubt” standard. However, in the more recent Soda Ash4 cartel and Shoe cartel5 cases, CCI has laid down that the standard of proof required for establishing the existence of an “agreement” is one of a “balance of probabilities”. In other words, CCI can reach a finding that an “agreement” exists, if the evidence suggests it to be more likely than not.


Rebutting The Presumption Of Appreciable Adverse Effect On Competition (‘AAEC’) – Standard Of Proof


The issue of standard of proof is particularly important in cartel cases because once it is established that a cartel agreement exists, the presumption of AAEC automatically applies. The burden then shifts to the defendants to adduce counter evidence to try and establish that their agreement does not cause an AAEC. Once CCI has considered the balance of probabilities to reach its decision on the existence of a cartel agreement, it is likely that a similar standard may be used to examine whether the counter evidence submitted by the defendants is sufficient to rebut the presumption of AAEC. While CCI is yet to rule on this issue, the Supreme Court of India has consistently held that the rebuttal of a presumption requires refutation on the balance of probabilities.6


Agreement – Nature Of Evidence


Cartels, by their very nature, rarely leave direct evidence of their presence, leading CCI to repeatedly hold that direct evidence is not necessary to establish the presence of an “agreement”.Instead, CCI relies on circumstantial evidence, both economic and conduct-based to reach its decision on existence of a cartel agreement.


Often, CCI examines economic evidence such as level of market concentration, parallel movement of prices, trends in capacity utilisation and variations in cost-structures across firms while conducting cartel inquiries. In terms of conduct-based evidence, CCI relies on evidence of meetings between competitors, similar or identical bidding prices, membership of trade associations, any history of cartelisation in other jurisdictions, and suspicious sharing of documents.


Agreement – Nature Of Evidence – Economic And Conduct-Based Evidence – Trends


CCI And Economic Evidence – A Movement Toward More Detailed Analysis


From the initial skeletal treatment of economic evidence, CCI has moved on to a more detailed and sophisticated analysis of economic evidence at hand. This is evident from a closer analysis of its cartel decisions starting from the Cement cartel case8 until the more recent Tyre cartel case.


For one, in the Cement cartel case, it failed to look at market share volatility, i.e. changes in market share over the period of alleged cartelisation. Presence of significant market share volatility generally goes against a narrative of cartelisation in any industry. This was subsequently acknowledged by CCI in the later Soda Ash cartel case where volatile market share was seen as negating inferences of cartelisation. CCI also adopted a similar approach in the Tyre cartel case.


Second, in the Cement cartel case, CCI gave significant weight to the concentrated nature of the Indian cement market and indicated that the oligopolistic nature of the market facilitates collusion. However, CCI subsequently recognised in the Soda Ash cartel case that while the oligopolistic nature of a market may lead to interdependence, such interdependence does not necessarily imply collusion.


Third, CCI’s analysis of cost-structures of firms to gauge whether there has been an artificially fixed price via collusion has also matured with time. In the Cement cartel case, cost-analysis was basic, with CCI factoring the costs of only two amongst many raw materials. CCI gave cost analysis much more weight in the Tyre cartel case where it refuted DG’s finding of high prices, being an indicator of cartelisation, as DG had not carried out detailed cost versus price analysis for all input materials.


Fourth, capacity utilisation analysis was not looked into in any degree of detail in the Cement cartel case where CCI simply assumed that a decrease in capacity utilisation was strong evidence of cartelisation without any heed to extraneous factors that might account for such a decrease. The treatment in the Tyre cartel case, however, was far more extensive as CCI examined and found that the declining capacity utilisation was a result of factors such as a fall in demand due to an overall economic recession.


Economic And Conduct-Based Evidence: Complementarity

CCI generally uses both economic and conduct-based evidence to determine whether an agreement exists or not.9 A closer look at some of the decisions of CCI supports this understanding. In the Aluminum Phosphide cartel case10, which looked into bid-rigging by manufacturers of aluminum phosphide tablets, all three companies participating in the tender process floated by the Food Corporation of India (‘FCI’) quoted an identical bid price. This was despite a marked difference in each company’s cost of production. The entries in the visitors’ register at the offices of FCI show all three participants entering the premises at the same time, with one signing in for the entire group. CCI inferred that the bidders had the opportunity to discuss the prices, and when combined with the other factors listed above, such evidence was sufficient to prove the existence of an agreement to maintain prices at a certain level.


In the Medical Equipment cartel case,11 concerning the supply and installation of medical equipment to Sports Injury Centre at Safdarjung hospital, CCI identified a cartel based on evidence from the bid documents themselves. Only three firms participated in the tender process and the contract was awarded to MDD Medical Systems Pvt. Ltd. (‘MDD’) as the lowest bidder. The initial estimated cost for the equipment was approximately USD 1.5m, but MDD was awarded the work for approximately USD 2.4m. This rather large difference between the initial estimate and final bid raised CCI’s suspicion. CCI also discovered many common typographical errors in the separate bids submitted by PSE Installations Pvt. Ltd. (‘PSE’), MDD, and Medical Products Services (‘MPS’). The companies tried to explain the identical errors by claiming they all visited the same cyber café to type out their respective bid letters, and unsurprisingly, CCI did not accept this explanation. CCI also analysed the bid patterns of these three companies and found that PSE won a contract for similar work at JPNA Hospital with MDD and MPS submitting higher bids. This indicated a typical case of rotating bids when all firms, except one, quote artificially inflated prices, and this process is repeated with different bidders winning each time.


Under somewhat similar circumstances in the bid-rigging case filed by Coal India Limited (‘CIL’) against 10 explosives manufacturers, two manufacturers (Gulf Oil Corporation Limited and Blastec India Limited) wrote identical letters to CIL explaining their reasons for not taking part in the auction.12 To CCI, these letters were proof of a “meeting of minds”.
In the Shoe cartel case, CCI levied a cumulative penalty of approximately USD 0.9m on 11 rubber shoe manufacturers for bid-rigging in the supply of rubber shoe soles to the Directorate General of Supplies & Disposals under Section 3(3) of the Act. The allegations were based on the evidence that; (i) the bids made by the shoe manufacturers were in a very narrow range; (ii) most of them had restricted the quantity they would supply; and (iii) most had also fixed the maximum quantity they would supply to a particular Direct Demanding Officer (‘DDO’).


CCI examined the bidding pattern in light of, (a) the near-identical prices, and (b) the limited range in terms of quantities, quoted by each of the alleged colluders, despite differences in, inter alia, their operations, production capacities, costs, geographies and profits. For instance, the cost of raw materials (latex and rubber) was subject to significant fluctuations, yet the accused generated near-identical estimations of the average cost of raw materials. Moreover, they gave uniform reasons for near-identical bids to DG, whereas while the submissions to CCI differed.


CCI viewed the Federation of Industries of India, the industry’s trade association, as providing the shoe-makers the necessary platform to hold meetings. Commercially sensitive performance statements in relation to the other accused were found in the possession of one of the accused, which led CCI to infer sharing and exchange of information amongst bidders prior to participating in the bid.


The accused had restricted their production to less than half their installed capacity, and a majority of them had restricted their supply-commitment to each DDO. The Opposite Parties were unable to give any valid justification for these actions. These factors allowed CCI to reach a finding of bid-rigging, in violation of the Act.


Economic And Conduct-Based Evidence: Which One Prevails?


Analysing CCI’s cartel jurisprudence, one trend becomes apparent – the clinching evidence in a cartel case is rarely economic. This is not to deny the importance of economic evidence but CCI acknowledges the necessity of conduct-based evidence over economic evidence to come to a finding of cartelisation. This seems to flow from CCI’s realisation that economic evidence such as price parallelism can also be rational conscious parallelism which is distinguished from concerted/collusive parallelism. CCI’s reliance on some critical conduct-based evidence is apparent from its decisions in the Cement cartel case (where cartelisation was found) and the Tyre cartel case (where cartelisation was not found).
Both cases concentrated on allegations of price fixing through either:

 

  • direct co-ordination on retail prices; or
  • indirect methods of co-ordination, such as limiting production, restricting supplies, or controlling dispatch.

In both cases, the price fixing was alleged to have taken place under the auspices of the particular industry’s trade association Cement Manufacturers’ Association of India (‘CMAI’) and All India Tyre Manufacturers’ Association (‘AITMA’). Trade associations have come under repeated scrutiny of CCI. It perceives them to be a fertile ground for collusive behavior because of the opportunities for repeated interaction among competitors that such a forum provides. The focus of both investigations was the possible existence of parallel pricing and whether this was conclusive of cartel activity. CCI opted for a two-step approach in both cases:

 

  • first, it examined whether prices, production and dispatch moved in tandem; and
  • where prices, production and dispatch did move in tandem, it then considered the roles of the CMAI and the AATMA in facilitating parallel pricing.

Neither case had the quintessential “smoking gun”, generally key to the swiftest “violation” decisions, and in certain jurisdictions, criminal convictions as well. The cases hinged on the inference of an agreement and it came down to parallel pricing to establish just that.


However, this is where the similarity between the two cases ends. A finding of parallel pricing in the Cement cartel case was enough to assure CCI of conscious co-ordination rather than a possible non-collusive consequence of oligopolistic market conditions. The tyre manufacturers on the other hand, also guilty of having displayed parallel pricing, were not found to have entered into anti-competitive agreements under Section 3(3) of the Act. Instead, CCI relied on factors such as high volume of imports (which limited the ability of tyre manufacturers to limit supply or under-utilise capacity) and the global economic slowdown to justify the parallel movement of prices.


The difference that probably led to a positive finding on the existence of a cartel in the Cement Decision was a simultaneous price increase in cement prices right after the CMAI meetings on two occasions. If one were to speculate, this could have been the critical factor that swung CCI’s opinion, despite economic evidence to the contrary. Thus we see reliance on a combination of economic evidence coupled with conduct-based evidence for determining cartelisation, with the conduct-based evidence being the factor that finally tips the scales.


Standard Of Proof And Nature Of Evidence: Lowered Evidentiary Thresholds?


Looking at the evolving decisional practice of CCI, in the context of determining whether an agreement exists, a rather interesting pattern emerges. As noted earlier, CCI has moved towards a lower standard of proof in judging the existence of cartels, i.e. from “beyond reasonable doubt” to “balance of probabilities”. At the same time, CCI has started to examine evidence, especially economic evidence, in a much more detailed and sophisticated manner.


Observing the two trends, it appears that the increased risk of being held guilty for cartelisation due to CCI’s reliance on “balance of probabilities” as the standard of proof may to some extent have been offset by the more nuanced scrutiny of both economic and conduct-based evidence.

 

Punishments For Cartelisation – Trends


The Act prescribes significant penalties for the violation of its provisions. In the case of cartels, CCI may impose a penalty up to the higher of three times the total profits of the enterprise responsible for the contravention or 10% of turnover such an enterprise for each year of the continuance of the agreement. Turnover is defined to include the value of sale of goods or services. An “enterprise”13 is the legal entity within which an economic activity is undertaken, including its units, divisions and subsidiaries. Consequently, when the penalty is computed on the basis of an enterprise’s turnover, the resultant amount is usually substantial.


CCI has come a long way since its first cartel decision (published in May, 2011), when three associations of film producers got away with a mere slap on the wrist.14 Despite seemingly concrete evidence of meetings and written instructions to orchestrate a coordinated boycott, some of the biggest names in the Indian film industry were asked to pay nominal fines (FICCI-Multiplex Association case). However, CCI has taken a stricter approach in subsequent decisions. For example, large fines were imposed on cement manufacturers involved in the Cement cartel case in June, 2012. CCI has also passed cease and desist orders without imposing a penalty such as in the Orissa Concrete and Allied Industries case.15 CCI has also begun examining the possibility of penalising persons responsible for the conduct of the company during the period of violation, such as in the Chemists and Druggists Association, Goa case.16 Here again though, what factors would lead to individual liabilities are not clear from CCI’s decisional practice.


What has been rather uncertain so far, and worryingly so, is the lack of any statutory or decisional guidelines on determining the quantum of penalty to be imposed. However, COMPAT quite recently introduced the concept of “relevant turnover” to Indian competition law jurisprudence17 in the Aluminum Phosphide cartel case. COMPAT criticised CCI’s approach in fixing the quantum of penalty at 9% of the average turnover for the previous three years on each of the appellants. COMPAT held that since CCI has an adjudicatory role, it must not only give reasons while imposing penalties but must also consider all relevant factors, including the financial health of the company and the likelihood of the company being closed down due to the imposition of a harsh penalty, before ruling on the quantum of penalty. The judgment also reiterated the doctrine of proportionality while imposing penalties, and in doing so, COMPAT upheld the quantum of penalty at 9% for two of the three Appellants, but for the third Appellant, it reduced the penalty by 90% because its production capacity was not comparable with the other two appellants.


Finally, COMPAT accepted the contention of the appellants that being multi-product companies, only the “relevant turnover” ought to be considered while imposing the penalty. COMPAT described the relevant turnover as one generated from the product under investigation (in this case aluminium phosphide tablets), rather than the turnover of the entire multi-product enterprise in question. Accordingly, it held that only the turnover from sale of aluminum phosphide tablet was “relevant” because “the other products of those companies have no connection and do not depend upon the product involved in this matter, that is, ALP Tablets.”


This decision of COMPAT appears to have hurt CCI’s cartel enforcement efforts and seemingly runs counter to the plain language of the statute itself. If upheld, then it is quite likely that several other cartel decisions by CCI would be contested on grounds of the calculation of the quantum of penalty. For a new regulator, such scrutiny perhaps does not augur well, particularly since it its enforcement efforts have been relatively constrained and it continues to struggle to create adequate incentives to promote the use of its leniency program.


Leniency Provisions


Similar to other jurisdictions, the Act also contains leniency provisions, which are aimed at inducing cartel participants to break rank and provide information on cartels. CCI has the power to impose lower penalties if a cartel participant has made a disclosure which is full, true and vital to bust the cartel. To implement the provisions of the Act, CCI formulated the Competition Commission of India (Lesser Penalty) Regulations (‘Lesser Penalty Regulations’) that came into effect from August 13, 2009.


The Lesser Penalty Regulations provide for reduction in penalty based on the sequence in which cartel participants approach CCI. The first cartel member to approach CCI may get a waiver extending up to 100% of the penalty amount. The second member may get its penalty reduced up to 50% and the third, up to 30%.


However, there have been very few, if any, publicised instances of the use of the leniency provisions. One of the possible reasons why leniency pleas have yet to gather momentum could be the significant discretion vested with CCI in deciding whether to grant leniency to an applicant. The information disclosed by the applicant has to be “vital”, i.e. it must allow CCI to form a prima facie view on a cartel’s existence, before leniency can be granted. This uncertainty in grant of leniency might be deterring enterprises from using the leniency mechanism. This lack of leniency pleas may also be grounded in cartel-members simply considering the risk of detection very low. However, this may change soon with upcoming changes in the cartel enforcement regime.


CCI And Evidence On Cartels: What Next?


So far, CCI has been faced with generally copious circumstantial evidence on the existence of cartels. However, as the competition law regime in India matures, cartel participants will resort to more sophisticated means, and CCI will be required to employ other tactical methods of investigation and enforcement. Internationally, dawn raids are a popular method for cartel discovery and enforcement. Thus far, CCI has yet to deploy its dawn raid powers, but with the enhanced powers of search and seizure that may be conferred to DG under the Competition (Amendment) Bill, 2012 (the ‘Bill’), dawn raids may become a popular tool for CCI.


The current text of Section 41 of the Act already empowers CCI’s investigative arm, DG, to carry out “search and seizure” (commonly known as “dawn raids”) operations. However, DG appears reluctant to use its powers under Section 41 of the Act, and this provision largely remains unutilised. The Bill makes certain small but important changes to the procedure with regard to dawn raids, namely:


First, the Bill empowers the Chairperson of CCI to sanction dawn raids. This power at present vests with the lower judiciary, and is perceived by many commentators as one of the key reasons why CCI has not yet been able to conduct dawn raids.


Second, the Bill increases the trigger points for conducting dawn raids. The current text of Section 41 of the Act empowers DG to carry out dawn raids only when it considers that certain evidence is likely to be destroyed, mutilated, altered, falsified or secreted. The Bill expands the trigger point for conducting dawn raids to also include instances where, in DG’s view, a person or enterprise has omitted or failed to provide the information or produce documents as required by the notice; or would not provide such relevant information.


Third, the Bill empowers DG to record statements of a wider group of people. The current text of the Act empowers DG to record statements, under oath, of only past and present officers, employees or agents of the company under investigation. To record the statement of any other person, DG requires the express prior permission of CCI. On the other hand, the Bill permits DG to record statements (under oath) of all persons having knowledge of such information or documents that it thinks are being withheld or are likely to be destroyed.


The proposed amendments to Section 41 of the Act if cleared by the Indian Parliament may possibly give a fillip to CCI’s cartel enforcement efforts.


Conclusion


A review of CCI’s decisions in cartel cases over the last four years indicates considerable progress towards more sophisticated analysis of economic evidence. CCI has tended to give primacy to conduct-based evidence over economic evidence. Once a cartel has been found, CCI has moved towards imposing significant, deterrent penalties. Admittedly, the recent COMPAT order introducing  the criterion of “relevant turnover” in calculating penalties seems to run counter to CCI’s approach. CCI is very likely to appeal against COMPAT’s order in the Supreme Court of India and the issue is far from resolved. The leniency regime has yet to kick-start effectively but that may change with the proposed changes to the competition regime which are set to widen the investigative powers of CCI.

 

End Notes:

 

1 Investigations against abuse of dominance may also be initiated in a similar fashion.

2 In re: All India Tyre Dealers’ Federation v. Tyre Manufacturers, MRTP Case: RTPE No. 20 of 2008.
3 Neeraj Malhotra v. Deutsche Post Bank Home Finance Limited &Ors., Case No. 5/2009.
4 Shailesh Kumar v. M/s Tata Chemicals Ltd. &Ors., Case No. 66 of 2011.
5 Reference Case No. 01 of 2012.
6 Vijay vs Laxman & Anr on 7 February, 2013, Criminal Appeal No. 261/2013, Arising out of SLP (Crl.) 6761/2010
7 See In re: All India Tyre Dealers’ Federation v. Tyre Manufacturers, MRTP Case: RTPE No. 20 of 2008., Builders Association of India vs Cement Manufacturers’ Association & Ors., Case No. 29/2010
8 Builders Association of India vs Cement Manufacturers’ Association & Ors., Case No. 29/2010

9 However, it must be noted that relying on both economic and conduct-based evidence does not mean that both
kinds of evidence are of the same persuasive value and we deal with this issue later in this article.
10 In re: Aluminium Phosphide Tablets Manufacturers, Suo-motu Case No. 02/2011.
11 A Foundation for Common Cause v. PSE Installations Pvt. Ltd. & Ors., Case No. 43 of 2010.
12 Coal India Limited v. Gulf Oil Corporation Ltd., Case No. 06/2011.

13 See Section 2(h) of the Act.
14 FICCI – Multiplex Association of India v. United Producers/Distributors Forum, Case No. 01 of 2009.
15 Re: Reference Case No. 05 of 2011 by Shri B.P. Khare, Principal Chief Engineer, South Eastern Railway, Kolkata v. Orissa Concrete and Allied Industries Ltd. and Ors, Ref. Case No. 05 of 2011.
16 Varca Druggist & Chemist & Ors .v. Chemists & Druggists Association, Goa, In Re: MRTP Case No. C-127/2009/DGIR (4/28).
17 M/s Excel Crop Care Limited v. CCI &Ors., Appeal No. 79 of 2012; M/s United Phosphorus Limited v. CCI &Ors., Appeal No. 81 of 2012; M/s Sandhya Organic Chemicals (P.) Limited v. CCI &Ors., Appeal No. 80 of 2012.

 

AZB

 

For further information, please contact:

 

Zia Mody, AZB & Partners
[email protected]

 

Abhijit Joshi, AZB & Partners 
[email protected]


Shuva Mandal, AZB & Partners 

[email protected]

 

Samir Gandhi, AZB & Partners
[email protected]


Percy Billimoria, AZB & Partners 
[email protected]

 

Aditya Bhat, AZB & Partners 
[email protected]

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