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EFTA01366868

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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 dui ng 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

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