EFTA01366868.pdf

Amendment #4 Page 439 of 868 7: f:, c The Cc panes have recognized tax benefits cry for tax posbons that me more likely than not to be sustaned upon examinatcn by tax 8i-tonnes. As of March 31. 2015 and 2014, the total urrecognized tax tenet es amounted to INR 13,900,766 and NR 13,900366, respectively, towards tax benefes and deductibilny of expenses which resat n a reduction or unabsorbed deprecation caryfawards These trrecograed tax benefits, t recognised, would affect the effective tax rate. Given the expectation that the carryforwards would be expected to be ut feed duing the tax holday pencds, the unrecognized tax benefitsweed have no overall ',vett 9. Related parties Management and Technical Fees Tts CallaalbaS entered trio a Tetanal and Management Services Agreement wth FERSA Spain and FERSA Inda, whereby above eMdieswil provide technical and meteventwit services such as prevision of financial services, terming and supporting on day to day operational issues and provsion and coordnaton of legal and tax advice, primarily on a cost-reimbursement bass, plus a 7 5% fee on arm length's basal Costs incurred fa these services were INR 7,312,483 and NR 2.668,220 for the three-month periods ended Marc', 31 2015 and 2014, respectively Related amounts were reported as cost of operators in the combined statements of income and were reflected in operating a:woes in the combined statements of cash flows. Amounts payable to FERSA included in Due to related parties) in respect of the atom management and technical tees s INt 5,882,026 and MR 6,412 042 as at Match 31. 2015 and December 31, 2014, respectwety Not parent Investment Net parert investment account represents common stock and additional paid in capital of ENRE. GEI and ENWP. net of intercompany investments. Hades of common stock are elated to one vote per store. and lo receive dividends and, upon liquidaton or issoluton, are enteed to receive an assets avatatle lot dtSlablaiCla to stockroders The racers have no preempts* or omer subscription nghts and there are no redemption a mneng tuna prOYSIORS with respect to such shares 10. Commitments and contingencies From time to time, the Companies have become invaded in CIEHMS and legal matters ansng in the °riflery course of Ousness Management is neat currently aware of any matters that wal have a metered adverse effect on the 'named patron, rends of operations. of Cash flows of the Companies Contingency There are certain pencbng matters relating to the sublease of bights n certain POI1C41$ or lands for one of the protects in which the lessor holds lease rights The Sub lease is sutiect approvals from certain government authorities The project company believes that there are no irregularibes in its richt to use the and and baSed on the opinion of its legal counsel behaves that the likelihood Wan untiovourstie outcome of rights of the said lend is not probable In addition. the CuMmrq believes that no further settlement or any 'Ordinal edebtonal liability is expected on r00:401M such matters dendn9 renoknon F.119 http://cfdocs.btogo.com:27638/cf/drv7/pub/edgar/2015/07/20/0001193125-15-256461/d78... 7/20/2015 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0058396 CONFIDENTIAL SDNY_GM_00204580 EFTA01366868