Strategy | 25 March 2019
The 20 months of the GST regime
Key trends in the new era
Around 20 months ago, India ushered in the Goods & Services Tax (GST), which is billed as
one of the biggest indirect tax reforms in the country’s history. This was a major step
toward simplifying taxation and facilitating ease of doing business by rationalizing tax
rates, improving efficiency in the system and shifting trade in favor of the organized
segment. Although it is still early to evaluate whether the GST is really a ‘good and simple
tax’ – as reforms are said to be slow boring of hard boards – we, in this note, have
highlighted some of the key trends of this new tax era.
The Indian government over the past two years has taken many proactive steps to
streamline the GST by providing procedural relaxations and clarifications. However,
this has led to a deferment in the implementation of a few important anti-evasive
measures, and thus, the shift in trade toward the formal economy has been slower
than anticipated.
GST collections have increased YoY in FY19 (until February), but the monthly average
collection is lower than the target, slimming the prospects of achievement of the full-
year target. However, in our view, collections should improve once the anti-evasive
measures are put in place.
In the new tax regime, the manufacturing sector has witnessed an increase in working
capital requirements, while the services sector has had to comply with increased
state-level compliances and seen higher tax rates.
Clarity on including petroleum products and gas under the ambit of GST and anti-
profiteering norms is still awaited.
Please refer to our report on
Thematic report GST, July 2016
GST collections increase but still below target
Average monthly GST collection in FY19 (till February) stands at ~INR974b. This
is higher than the FY18 monthly average (August-March) collection of ~INR899b
but falls short of the monthly collection target of ~INR1,063b for this fiscal.
We attribute the shortfall in the targeted collection to (a) the deferment of anti-
evasion tax measures, such as bilateral validations of tax invoice, reverse charge
mechanism and the lack of on-ground surveillance for e-way bills, and (b) rate
cut on various products, mainly for those under the higher tax brackets.
Nevertheless, we believe that GST collection should improve going forward, led
by the rising compliance level from the broadening tax base and the
government’s increased focus on implementing anti-evasive tax measures.
We note that companies have been facing some teething issues in the GST
transitional phase due to their lack of preparedness, the technological glitches in
the GST platforms, and the lack of clarity about certain procedural issues.
However, the government over the past few months has provided clarifications
and procedural relaxations in a timely manner to facilitate a smooth transition.
Corporates face increased working capital, compliance requirements
Sandeep Ashok Gupta – Research Analyst
(; +91 22 6129 1551
Research Analyst: Umesh Jain
Mohit Baheti
(; +91 22 6129 1525
8 August 2016
Investors are advised to refer through important disclosures made at the last page of the Research Report.
Motilal Oswal research is available on, Bloomberg, Thomson Reuters, Factset and S&P Capital.
 Motilal Oswal Financial Services
Strategy | GST
The manufacturing sector witnessed a spike in working capital requirement. We
believe that capital needs may increase further due to the new notification on
the utilization of IGST credits effective Feb’19. The service sector, on the other
hand, has been impacted by rising state-level compliance. MSMEs/SMEs were
impacted by the lack of preparedness and the increased procedural
requirements; however, relaxations by the government have provided them
with some relief.
Oil & gas inclusion and anti-profiteering guidelines – key monitorables
Oil & gas is a critical input for most sectors in the economy. Non-inclusion of this
sector under the GST regime results in no input tax credit for the consuming
sector, and thus, increases costs.
Also, the lack of specific guidelines on anti-profiteering has created ambiguity in
the system. It may also turn out to be one of the biggest reasons for litigations
over the near term.
25 March 2019
 Motilal Oswal Financial Services
Strategy | GST
GST collection improves but below target
Focus now on implementation of anti-evasive measures
GST is a step toward simplifying taxation and facilitating ease of doing business by
rationalizing tax rates, improving efficiency in the system and shifting trade from the
unorganized to organized sector.
The implementation of this reform has led to broad-basing of the tax base, with the
total number of GST-registered assessees increasing significantly to more than 9
million (v/s ~7.2 million under the previous regime).
GST collection has increased over time, with aggregate GST revenue in FY19 till
February at ~INR10.71t, as against ~INR7.19t over Aug’17 to Mar’18. However, the
monthly average of ~INR973b in FY19 remains below the target of ~INR1,063b, which
dims the prospect of achievement of the FY19 target of ~INR12.75t.
We primarily attribute the lower-than-expected monthly GST collection to (a) the
deferment of the implementation of anti-evasion tax measures, such as bilateral
validations of tax invoice, reverse charge mechanism and the lack of on-ground checks
for e-way bills and (b) rate cut on various products, mainly for those under the higher
tax brackets. According to the Finance Ministry, the rate rationalization is estimated to
have impacted GST revenue collection by ~INR415b.
Nevertheless, the GST collection outlook appears promising, given the improved
compliance level/broad-basing of the tax base, the government’s focus on
implementing anti-evasion tax measures over time and with most of the rate
rationalization measures (from higher to lower tax slabs) now behind.
Better tax compliance in GST regime but room for improvement
Total number of returns
filed has increased from 6.5
million in Jul’17 to ~7.8m in
recent months
We note that the tax compliance levels have improved gradually over the last 20
months. The total number of returns filed has increased from 6.5 million in
Jul’17 to ~7.8m in recent months.
Also, the total number of returns for the relevant months filed before 1st press
release date (normally released within a month from relevant month) has
increased from 3.8 million in Jul’17 to 7.3 million in Jan’18.
While there were many delayed returns filed in the initial period of GST rollout –
primarily due to the technological hurdles faced by the assessees (discussed
later in this report) – the system now appears to have largely stabilized.
Exhibit 1: GSTR3B return filing has picked up over time (m)
Returns filled within 1st press release
Delayed return
Cumulative return filled
25 March 2019
 Motilal Oswal Financial Services
Strategy | GST
Average monthly GST
collections for FY19
improved to INR973b (FY18:
INR899b), but remain below
the target of INR1,063b
We note that the GST revenue collection trend has been improving over the
past 20 months. Aggregate revenue has inched up from ~INR7.19t (monthly
average: ~INR899b) in FY18 (July to March) to ~INR10.71t in FY19 (till February
19). However, monthly average revenue collection of ~INR973b (until February)
in this fiscal is below the target of ~INR1,063b.
FY19 collection target stands at ~INR12.75t, which requires Mar’19 tax
collection of ~INR2.05t. We believe that FY19 revenue collection may fall short
of the target by close to INR1t if the same revenue trend continues for the last
month of FY19.
Exhibit 2: GST collection may fall short of target, recovery rate spikes
GST collection (INRb)
FY18 monthly actual
FY19 monthly target
FY19 monthly actual*
FY19 required*
Note: 1. *FY19 actuals are up to Feb’19.
2. *FY19 required monthly target for Mar’19
Source: Press Information Bureau, MOFSL
The trend of GST collection suggests that:
In the first three months of the GST rollout (Aug’17 to Oct’17), re-stocking of
goods had led to higher collection. This followed de-stocking of goods in the pre-
GST period in order to avail benefit of the lower tax rate.
Over Nov’17 to Feb’18, muted consumption and rate rationalization led to lower
Over Mar’18 to Apr’18, the collection trend improved due to the year-end
Uptrend continued into FY19 owing to stable consumption demand and the
broadening compliance base.
25 March 2019
 Motilal Oswal Financial Services
Strategy | GST
Exhibit 3: GST collections remain muted in FY18; marginal uptick in FY19
GST collection (INRb)
1,007 976
1,025 972
Source: PIB, MOFSL
Deferment of anti-evasive measures/rate cuts take toll on collections
Based on our discussion with experts, we note that the lower-than-expected
monthly average collection was due to:
The delay in the implementation of anti-evasive tax measures, such as
bilateral validation of tax invoice, reverse charge mechanism (temporarily
deferred in order to extend relief to businesses for smooth transition under
GST) and the lack of on-ground checks for e-way bills (though this bill has
led to a marginal shift in trade in favor of the organized sector),
Tax rate cut over the period, mainly under the highest tax bracket of 28%,
which could have impacted revenue collection by ~INR415b, according to
the Finance Ministry estimates, and
Lower-than-anticipated consumption demand.
Implementation of several anti-evasion tax measures deferred
Deferment of anti-evasive
measures for smooth roll
out of GST impacts
The Indian government has deferred/eased a lot of regulatory measures to
provide relief and time to businesses (to upgrade and equip their IT system) to
comply with the GST law. However, this has also meant a temporary derailment
of the modalities built to keep non-compliance under check.
Some of the popular measures that were deferred include:
Bilateral validation of tax invoice:
The essence of the GST is to allow tax
credit based on matching of the tax invoice of the supplier with that of the
buyer – the intent is to plug loopholes in the supply chain. However, due to
technological issues and the lack of preparedness, GSTR 2 and 3 were
postponed, and GSTR 3B (which is essentially a summary return) was
introduced (continues even now), which allow GST credit on a self-
admissible basis. However, the lack of this validation has made it difficult for
the government to track spurious input tax credit claims.
Reverse charge mechanism system:
RCM mandates a recipient to pay a tax
on goods/services bought from unregistered suppliers – the intent here is to
track such suppliers. It will encourage unregistered suppliers to register
under the GST in order to claim input tax credit on tax paid on purchases,
which will increase the tax base. The implementation of RCM is deferred
until 30
25 March 2019
 Motilal Oswal Financial Services
Strategy | GST
E-way bill helping, but major benefits yet to come:
The e-way bill was
proposed to be rolled out from 1
Feb’18 but was deferred due to
technology led problems. It was introduced only from 1
April 2018 in a
phased manner. Till 11
Mar’19, ~519.2 million e-way bills have been
generated, according to the GST network. However, the shift to formal trade
– the main motive of the e-way bill – has been slower than anticipated due
to the lack of on-ground checks and continued malpractices.
We, nevertheless, believe that the following proposed changes in the e-way bill
will make the supply chain mechanism more efficient and provide a much-
needed boost to GST collections:
Implementation of a radio frequency identification device (RFID), which will
make tracking of movement of goods easy.
Integration of the e-way bill system with GSTN to reconcile their supplies,
which will make the supply chain more efficient.
Post the roll out of GST, there has been a spike in detection and recovery of
tax-evasion cases. Total indirect tax (central excise, service tax and GST)
evasion is estimated at INR486b until Dec’19 v/s INR322b in FY18 and
INR236b in FY17. The amount of tax evasion from the central GST is
estimated at ~INR153b until Dec’19.
Source: Press Information Bureau , MOFSL
Exhibit 4: Tax evasion detection and recovery spiked in FY19 (INRb)
FY19 (*till Dec)
Fake invoices, under-
invoicing and sales without
invoice are the few ways
being followed to evade tax
post GST
Based on our discussion with experts, we list below some of the ways of tax
evasions that still persist under the GST regime:
Fake bills:
Over the last 20 months, the government has caught many
rackets who were involved in issuing fake invoices. These violators have
registered multiple companies, got GST numbers and issued fake invoices to
defraud companies. This has led to a massive loss to government revenue,
as enterprises are claiming input tax credit on the basis of fake invoices,
which are difficult to track. However, we believe that once the system for
matching of credit stabilizes, the number of fake invoices will reduce to a
great extent.
Sales without invoice:
Our discussions with experts suggest that businesses
have continued transacting without a valid invoice, primarily due to the lack
of on-ground check and the deferment in the implementation of anti-
evasion tax measures.
Under invoicing:
It is one of the major concerning areas for the government.
Experts suggest that the unorganized sector continues under reporting their
transactions, even in the GST regime. However, the e-way bill would entail
businesses to report their supplies. However, fair invoicing will always be a
grey area as multiple factors such as specialty of goods and pricing power
are to be considered, which makes it difficult to assess in the preliminary
stage. Experts believe that with advanced data analytics (once the system
stabilizes), some checks can be implemented to control this.
25 March 2019
 Motilal Oswal Financial Services
Strategy | GST
The government has also set up fraud analytics & risk management (DGARM)
under CBIC. Going forward, DGARM may contribute significantly toward raising
red flags for tax evasion cases through data analytics based on (1) reconciling e-
way bill system with GSTN and (2) benefits from anti-evasion tax measures. We
believe that this will encourage businesses to have a better check to comply
with the GST laws.
Continued rate rationalization impacted GST collection by INR415b
Rate rationalization done
for ~200 products from
highest tax slab
Over the last 20 months, the GST Council has continuously reduced the tax
rates, primarily for the items in the 28% tax bracket. Now only ‘luxury and sin
goods’ remain in the highest tax bracket. We note that tax rates on ~200
products were slashed from 28% to 12% and 18%, impacting the tax revenue by
~INR415b, according to the Finance Ministry estimates.
The government is considering the convergence of two standard rates of 12%
and 18% to a tax neutral rate of 15% or 16%. This will ease compliance for
industry across segments and the economy will shift toward a single tax rate
Exhibit 5: Tax rates on ~200 goods slashed from highest tax bracket of 28%
Exp. Revenue loss (INRb)
Dec 18
Source: MOFSL
25 March 2019
 Motilal Oswal Financial Services
Strategy | GST
Corporates facing teething issues
Working capital impacted, new credit utilization rule in focus
GST is certainly a move focused on ease of doing business. However, the lack of
preparedness, the technology glitches in the GST platform and the non-clarity over
certain procedural issues have made the transition phase tough. The government has
remained active in facilitating smooth transitioning, deferring certain (anti-evasive)
compliance procedures and issuing clarifications in a timely manner. While compliance
cost for corporates has increased, it should reduce as processes are streamlined. Our
discussion with experts suggests that during the transition the service sector, MSMEs
and SMEs were more impacted by the rising compliance levels; while, the
manufacturing sectors saw a surge in working capital requirements.
The service sector was impacted by (a) the need to comply to additional state-wise
norms (v/s centralized compliance earlier), (b) higher tax incidence (generally at 18%
in GST v/s 14% in the service tax regime) and (c) procedural difficulties such as
determining the jurisdiction for rendering of service.
MSMEs and SMEs were impacted by their lack of preparedness to comply with the
stringent procedural norms (monthly returns/low threshold for being subject to
indirect taxation) and the requirement to file detailed digitized returns under the GST.
However, the government has provided some relief by (a) increasing the threshold for
mandatory registering under the GST, (b) increasing the threshold to register under
the composition scheme, (c) simplifying the returns filing procedure, and (d) reducing
the frequency of filings.
For the manufacturing sector, the transition has led to a spike in working capital
requirement. This may again increase for some corporates due to the recent
notification on utilizing IGST credits (w.e.f. Feb’19). Further, the sector faces an issue
in the form of limited clarity/guidelines on anti-profiteering. This, in our view, can turn
out to be a major reason for disputes/litigations. Moreover, the shift in trade toward
the organized sector is yet to gain traction.
Also, the industry awaits a decision on the inclusion of oil & gas under the GST and a
clarification on specific guidelines or methods to calculate anti-profiteering.
Government issues several clarifications ensuring smooth transition
The GST law has evolved over the period based on feedbacks from various
industry wide stakeholders. To ensure a smooth transition and avoid ambiguity,
the government has till now issued ~327 notifications, circulars and orders to
address industry concerns.
Exhibit 6: Several notifications/circulars issued during 20-month period
Central Tax
Central Tax (Rate)
Circular (Central)
25 March 2019
 Motilal Oswal Financial Services
Strategy | GST
Technology to be backbone of GST; initial period saw some hiccups
Initially, GSTN network
faced challenges in handling
data load; government
deferred the rule to file
detailed GST returns &
extended timelines
whenever deemed
Technology is considered to be a backbone of the GST regime as all compliances
are electronic and automated, marking a shift toward digitalization. However,
we note that the initial journey was not as smooth as originally envisaged.
Initially, the GSTN network faced challenges in handling data load, and
businesses struggled to make major changes required under the process to
comply with the new online data filing requirements.
As a result, the government deferred the implementation of the rule to file
detailed GST returns and a summary return rule was introduced to streamline
compliance. Also, the roll out of the matching concept to claim GST credits was
deferred and credits were allowed to be taken on a self-admissible basis.
Further, the deadlines to file GST returns were extended whenever deemed
Post the implementation of GST, the working capital requirement for corporates
has been on the rise. Our analysis of the Nifty top 100 companies suggests that
the balance with government authority and ITC receivables of mining and
mineral products, steel and FMCG increased by 120%, 65% and 59% YoY,
respectively in FY18. The aforementioned sectors were among those most hit,
followed by pharmaceuticals, refineries and automobiles. We attribute this to:
Transaction within group:
Applicability of the GST on stock transfer has
impacted working capital requirement; as businesses now have to pay a tax
on goods transferred to a direct location (stock transfers). This has been
resulting in cash outflows for entities and the amount gets blocked until
goods subsequently sold from such other place, although the actual
quantum depends on the turnaround time at warehouses, holding time,
credit time to customers, and the quantity of stock transfer.
Exports refund delayed:
Export refunds were delayed in the initial period of
rollout, which impacted working capital requirements of companies. Export-
oriented industries that acquire input goods by paying taxes and
subsequently claim refund have been impacted by delayed refunds.
Mismatching of invoice:
According to the GST law, the buyer of goods will
be denied credit if the supplier fails to upload supplies or pay tax thereon.
This has increased the compliance burden for the buyer to follow up with
the supplier to get supplies uploaded on the GSTN portal. Although ITC is
allowed on a self-admission basis, some organizations are matching their
purchase invoices with suppliers’ uploaded details to avoid the consequence
of ITC reversal and interest thereon. Our discussion with various experts
suggests that the ITC mismatch of businesses in some cases is close to 20-
30% of the total input tax credit available.
Increase in working capital needs for manufacturing sector
GST applicability on stock
transfers, delays in exports
refund and mismatching
invoices led to an increase
in working capital
25 March 2019
 Motilal Oswal Financial Services
Strategy | GST
Exhibit 7: ITC receivables and balance with government authority grew significantly post GST (INR b)
Source: Capital line , MOFSL
YoY Growth
Mining & Mineral
Change in method of
utilizing IGST credits to
further stretch working
The recent notification on the change in methodology for utilizing IGST
(applicable w.e.f 1
Feb’19) is likely to further increase working capital
requirement for some businesses, in our view. The change suggests that the
IGST credits need to be first exhausted in paying the output IGST and the output
CGST liability (without utilizing the CGST input tax credits) and then the further
balance can be utilized for the payment of SGST. Even when the CGST ITC is
available, the IGST ITC has to be first used for the payment of CGST liability and
only then the CGST ITC can be utilized. This will create a situation where the
IGST ITC will not be available for the payment of SGST. In some cases, the SGST
liability (net of SGST ITC) will have to be paid in cash. This scenario can be
understood with the illustrations presented below.
Source: MOFSL
Source: MOFSL
Exhibit 8: Illustrative table – NIL net cash outgo before amendment
Tax Liability
ITC balance (first set off individually)
Net liability
Net excess credit available
Cross utilization of IGST credit
Net cash outgo
Exhibit 9: Illustrative table – Net cash outgo; CGST credit will accumulate after amendment
Tax Liability
ITC balance
ITC balance utilized (IGST can only be utilized first)
Net excess credit available
Cross utilization of IGST credit
Net liability
Net excess credit available
Utilization of SGST
Final excess credit carry forward
Final Net liability to be paid in cash
Service sector facing higher tax liability with need for multiple registrations
The GST has brought about an increased level of compliance for the service
sector. Companies rendering services now also need to register and file returns
in all states where they operate; in the earlier regime, companies had to follow
a single central registration process. This has led to a significant increase in
compliance and administrative cost for the service industry.
25 March 2019
 Motilal Oswal Financial Services
Strategy | GST
GST rates applicable on services have also increased (to ~18% v/s 14% under
service tax), leading to higher consumer-level cost, though part of this has been
offset by the higher ITC available on purchase of goods (which was not available
Further, the service sector continues facing challenges on determining the place
of service for due discharge of their liabilities.
The GST aims to bring the entire supply chain in the indirect tax net and track
the movement of goods in the entire supply chain.
To pursue this, initially the threshold limit for the applicability of the GST was
kept low at INR2m (v/s INR15m for excise and INR1m under the service tax
regime). The intent was to broaden the tax base and shift trade in favor of
organized players.
However, the MSME and SME sectors were not prepared to comply with the
stringent procedural requirements (monthly returns) and the need to file
detailed digitized returns. Also, these sectors were facing the pressure of
increased compliance cost.
However, the government provided some relief by:
Increasing the threshold for mandatory registration under the GST from
INR2m to INR4m (from INR1m to INR2m in the north eastern hilly states).
This is likely to benefit more than two million taxpayers.
Increasing the threshold for the composition scheme from INR7.5m to
Allowing service providers with a turnover up to INR5m to opt for the
composition scheme. This will benefit a large number of service providers as
services constitute a large part of India’s economy.
Introducing one annual return option for composition dealers (v/s quarterly
return earlier).
Deferring detailed GST return 2 and 3, and introducing a summary return
Non-inclusion of the oil & gas sector under the GST regime is leading to
significant ITC for the consuming sector, and thus, an increase in cost. Our
discussions with various experts and industry participants suggest that this
remains one of the critical links in improving the efficiency and effectiveness of
the GST.
Anti-profiteering provisions in the central GST legislation mandate that any
reduction in the tax rate on supply of goods or services, or the benefit of input
tax credit should be passed on to consumers by a commensurate reduction in
prices. The objective here is to boost consumption.
However, no specific guidelines or method to calculate anti-profiteering have
been provided. This has led to a lot of ambiguity in the system.
We note that anti-profiteering wing of the GST has already sent notices to large
corporates including HUL, Honda, Lifestyle retailer and McDonald’s franchisees.
We believe that the lack of clear mechanism may lead to a long list of disputes
and litigations in the near future.
Easing procedural requirements to provide relief to MSMEs/SMEs
Increased compliances and
lack of preparedness impact
SMEs during transition;
Govt. provided relief
Clarity awaited on inclusion of oil & gas under GST…
…and on anti-profiteering norms
25 March 2019
 Motilal Oswal Financial Services
Strategy | GST
25 March 2019
 Motilal Oswal Financial Services
Strategy | GST
25 March 2019
 Motilal Oswal Financial Services
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Strategy | GST
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This report is distributed in Hong Kong by Motilal Oswal capital Markets (Hong Kong) Private Limited, a licensed corporation (CE AYY-301) licensed and regulated by the Hong Kong Securities and Futures Commission (SFC) pursuant to the Securities
and Futures Ordinance (Chapter 571 of the Laws of Hong Kong) “SFO”. As per SEBI (Research Analyst Regulations) 2014 Motilal Oswal Securities (SEBI Reg No. INH000000412) has an agreement with Motilal Oswal capital Markets (Hong Kong)
Private Limited for distribution of research report in Hong Kong. This report is intended for distribution only to “Professional Investors” as defined in Part I of Schedule 1 to SFO. Any investment or investment activity to which this document relates is only
available to professional investor and will be engaged only with professional investors.” Nothing here is an offer or solicitation of these securities, products and services in any jurisdiction where their offer or sale is not qualified or exempt from
registration. The Indian Analyst(s) who compile this report is/are not located in Hong Kong & are not conducting Research Analysis in Hong Kong.
For U.S.
Motilal Oswal Securities Limited (MOSL) is not a registered broker - dealer under the U.S. Securities Exchange Act of 1934, as amended (the"1934 act") and under applicable state laws in the United States. In addition MOSL is not a registered
investment adviser under the U.S. Investment Advisers Act of 1940, as amended (the "Advisers Act" and together with the 1934 Act, the "Acts), and under applicable state laws in the United States. Accordingly, in the absence of specific exemption
under the Acts, any brokerage and investment services provided by MOSL, including the products and services described herein are not available to or intended for U.S. persons. This report is intended for distribution only to "Major Institutional
Investors" as defined by Rule 15a-6(b)(4) of the Exchange Act and interpretations thereof by SEC (henceforth referred to as "major institutional investors"). This document must not be acted on or relied on by persons who are not major institutional
investors. Any investment or investment activity to which this document relates is only available to major institutional investors and will be engaged in only with major institutional investors. In reliance on the exemption from registration provided by Rule
15a-6 of the U.S. Securities Exchange Act of 1934, as amended (the "Exchange Act") and interpretations thereof by the U.S. Securities and Exchange Commission ("SEC") in order to conduct business with Institutional Investors based in the U.S.,
MOSL has entered into a chaperoning agreement with a U.S. registered broker-dealer, Motilal Oswal Securities International Private Limited. ("MOSIPL"). Any business interaction pursuant to this report will have to be executed within the provisions of
this chaperoning agreement.
The Research Analysts contributing to the report may not be registered /qualified as research analyst with FINRA. Such research analyst may not be associated persons of the U.S. registered broker-dealer, MOSIPL, and therefore, may not be subject
to NASD rule 2711 and NYSE Rule 472 restrictions on communication with a subject company, public appearances and trading securities held by a research analyst account.
For Singapore
In Singapore, this report is being distributed by Motilal Oswal Capital Markets Singapore Pte Ltd (“MOCMSPL”) (Co.Reg. NO. 201129401Z) which is a holder of a capital markets services license and an exempt financial adviser in Singapore,
as per the approved agreement under Paragraph 9 of Third Schedule of Securities and Futures Act (CAP 289) and Paragraph 11 of First Schedule of Financial Advisors Act (CAP 110) provided to MOCMSPL by Monetary Authority of Singapore.
Persons in Singapore should contact MOCMSPL in respect of any matter arising from, or in connection with this report/publication/communication. This report is distributed solely to persons who qualify as “Institutional Investors”, of which some of
whom may consist of "accredited" institutional investors as defined in section 4A(1) of the Securities and Futures Act, Chapter 289 of Singapore (“the SFA”). Accordingly, if a Singapore person is not or ceases to be such an institutional investor, such
Singapore Person must immediately discontinue any use of this Report and inform MOCMSPL.
The report and information contained herein is strictly confidential and meant solely for the selected recipient and may not be altered in any way, transmitted to, copied or distributed, in part or in whole, to any other person or to the media or reproduced
in any form, without prior written consent. This report and information herein is solely for informational purpose and may not be used or considered as an offer document or solicitation of offer to buy or sell or subscribe for securities or other financial
instruments. Nothing in this report constitutes investment, legal, accounting and tax advice or a representation that any investment or strategy is suitable or appropriate to your specific circumstances. The securities discussed and opinions expressed in
this report may not be suitable for all investors, who must make their own investment decisions, based on their own investment objectives, financial positions and needs of specific recipient. This may not be taken in substitution for the exercise of
independent judgment by any recipient. Each recipient of this document should make such investigations as it deems necessary to arrive at an independent evaluation of an investment in the securities of companies referred to in this document
(including the merits and risks involved), and should consult its own advisors to determine the merits and risks of such an investment. The investment discussed or views expressed may not be suitable for all investors. Certain transactions -including
those involving futures, options, another derivative products as well as non-investment grade securities - involve substantial risk and are not suitable for all investors. No representation or warranty, express or implied, is made as to the accuracy,
completeness or fairness of the information and opinions contained in this document. The Disclosures of Interest Statement incorporated in this document is provided solely to enhance the transparency and should not be treated as endorsement of the
views expressed in the report. This information is subject to change without any prior notice. The Company reserves the right to make modifications and alternations to this statement as may be required from time to time without any prior approval.
MOSL, its associates, their directors and the employees may from time to time, effect or have effected an own account transaction in, or deal as principal or agent in or for the securities mentioned in this document. They may perform or seek to perform
investment banking or other services for, or solicit investment banking or other business from, any company referred to in this report. Each of these entities functions as a separate, distinct and independent of each other. The recipient should take this
into account before interpreting the document. This report has been prepared on the basis of information that is already available in publicly accessible media or developed through analysis of MOSL. The views expressed are those of the analyst, and
the Company may or may not subscribe to all the views expressed therein. This document is being supplied to you solely for your information and may not be reproduced, redistributed or passed on, directly or indirectly, to any other person or
published, copied, in whole or in part, for any purpose. This report is not directed or intended for distribution to, or use by, any person or entity who is a citizen or resident of or located in any locality, state, country or other jurisdiction, where such
distribution, publication, availability or use would be contrary to law, regulation or which would subject MOSL to any registration or licensing requirement within such jurisdiction. The securities described herein may or may not be eligible for sale in all
jurisdictions or to certain category of investors. Persons in whose possession this document may come are required to inform themselves of and to observe such restriction. Neither the Firm, not its directors, employees, agents or representatives shall
be liable for any damages whether direct or indirect, incidental, special or consequential including lost revenue or lost profits that may arise from or in connection with the use of the information.
The person accessing this information specifically agrees
to exempt MOSL or any of its affiliates or employees from, any and all responsibility/liability arising from such misuse and agrees not to hold MOSL or any of its affiliates or employees responsible for any such misuse and further agrees to hold MOSL
or any of its affiliates or employees free and harmless from all losses, costs, damages, expenses that may be suffered by the person accessing this information due to any errors and delays.
Registered Office Address: Motilal Oswal Tower, Rahimtullah Sayani Road, Opposite Parel ST Depot, Prabhadevi, Mumbai-400025; Tel No.: 022-3980 4263; Correspondence Address: Palm Spring Centre, 2nd Floor, Palm
Court Complex, New Link Road, Malad (West), Mumbai- 400 064. Tel No: 022 3080 1000. Compliance Officer: Neeraj Agarwal, Email Id:,
Contact No.:022-30801085.
Registration details of group entities: MOSL: SEBI Registration: INZ000158836 (BSE/NSE/MCX/NCDEX); CDSL: IN-DP-16-2015; NSDL: IN-DP-NSDL-152-2000; Research Analyst: INH000000412. AMFI: ARN 17397. Investment Adviser:
INA000007100.Motilal Oswal Asset Management Company Ltd. (MOAMC): PMS (Registration No.: INP000000670) offers PMS and Mutual Funds products. Motilal Oswal Wealth Management Ltd. (MOWML): PMS (Registration No.: INP000004409)
offers wealth management solutions. *Motilal Oswal Securities Ltd. is a distributor of Mutual Funds, PMS, Fixed Deposit, Bond, NCDs, Insurance and IPO products. * Motilal Oswal Real Estate Investment Advisors II Pvt. Ltd. offers Real Estate
products. * Motilal Oswal Private Equity Investment Advisors Pvt. Ltd. offers Private Equity products
has been amalgamated with Motilal Oswal Financial Services Limited (MOFSL) w.e.f August 21, 2018 pursuant to order dated July 30, 2018 issued by Hon'ble National Company Law Tribunal, Mumbai Bench. The existing registration no(s) of
MOSL would be used until receipt of new MOFSL registration numbers.
Disclosure of Interest Statement
Analyst ownership of the stock
Companies where there is interest
25 March 2019