FDI Policy-Trading Activity of PROI and relevant Provisions of FEMA

6th August 2013 P. P. Shah & Associates 1
FDI Policy-Trading Activity of PROI and
relevant Provisions of FEMA
Presented by:
Mr. Paresh P. Shah
P.P. Shah & Associates
Chartered Accountants
Email: paresh@bom3.vsnl.net.in
BCAS FEMA Study Circle
Meeting

Overview of Discussion
 Foreign Investment and Trading activities of PROI – A
review
 Regulatory framework
 Government policy on Trading-Statistics etc
 Regulatory framework – comparison
 Nature of trading activities and its meaning
 Government of India’s Plan & Preparedness
 Retail trading – A rationale and critical analysis
 International scene
 Summary of issues at the study circle

Trading activities of PROI – A review
 Priority of sector and its rationale
 Foreign Investment in India & FDI
 Trading activities and entry option to PROI
 Trading activities under policy of the Government
 Trading activities permitted to NRIs only
 Prohibited activities to PROI

Foreign Investment in India
Foreign Investment
Foreign
direct
investment
(Sch 1)
Foreign
Portfolio
Investment
Foreign Venture
Capital Investment
(Sch 6)
Other
Investment(G-
sec, NCD)
(Sch 5)
Investment on
Non
repatriation
basis
Automatic
route
Government
route
FIIs
(sch 2)
NRIs, PIO
(Sch 3)
SEBI regd
FVCIs
VCF, IVCUs
FIIs NRIs, PIO
NRIs, PIO
(Sch 4)
Investment
made by
QFI (Sch 8)
IDR by
companies
resident outside
India (Sch 7)

Definition of FDI
 As per Consolidated FDI Policy- Investment by Non resident
entity/Person resident outside India in the Capital of an Indian
Company under Schedule 1 of Foreign Exchange Management
( Transfer or issue of Security by a person resident Outside India)
Regulation 2000
 As per Regulation 14 of Notification 20 of FEMA- Investment
received by an Indian Company from non-resident entities regardless of
whether the said investments have been made under Schedule 1,2,3,6
and 8 of Notification No. FEMA 20/2000- RB dated May 3,2000,as
amended from time to time.

Trading activities-Regulatory framework
 Trading activity and Entry options
 Liaison office, Branch and Project office of PROI – Notification No. 22/2000-RB, dt. 3rd
May
2000 . Cir. No. 29 dt. 30/12/2009
 Automatic route of FDI under Notification No. 20; Schedule I for companies ( Annex A inserted
vide notification No. 242 dt 19/10/2012 w.e.f 20/9/2012) .[A trading company incorporated in
India may issue shares or convertible debentures to the extent of 51% of its capital to PROI
[eligible persons as referred to in paragraph 1 to the schedule 1of the regulation 5 of the Notf.
20 of FEMA] subject to the conditions that remittance of dividend to the shareholders outside
India is made only after the company has secured registration as an Export Trading / Star
Trading / Super Trading House from the Directorate General of Foreign Trade, Ministry of
Commerce, Government of India, New Delhi. Annexure B refers that activity of such company
to be primarily Export activities.(Omitted- Notification No. 179/2008-RB)]
 Wholesale cash & Carry trade: Guidelines for Cash & Carry Wholesale Trading/Wholesale
Trading (WT):
(a)For undertaking WT, requisite licenses/registration/ permits, as specified under the relevant
Acts/Regulations/Rules/Orders of the State Government/Government Body/Government
Authority/Local Self-Government Body under that State Government should be obtained.
(b) Except in case of sales to Government, sales made by the wholesaler would be considered as
„cash & carry wholesale trading/wholesale trading‟ with valid business

Trading activities-Regulatory
framework
customers, only when WT are made to following entity:
(I) Entities holding Sales tax /VAT registration/ service tax /Excise duty registration; or
(II)Entities holding trade licenses i.e. license/ registration certificate /membership
certificate/registration under Shops and Establishment Act, issued by a Government Authority/
Government Body/ Local Self-Government Authority, reflecting that the entity/person holding
the license/ registration certificate/ membership certificate, as the case may be, is itself/
himself/herself engaged in a business involving commercial activity; or
(III) Entities holding permits/license etc. for undertaking retail trade (like tehbazari and similar
license for hawkers) from Government Authorities/Local Self Government Bodies; or
(IV) Institutions having certificate of incorporation or registration as a society or registration as
public trust for their self consumption.
Note: An Entity, to whom WT is made, may fulfill any one of the 4 conditions.
( c) Full records indicating all the details of such sales like name of entity, kind of entity,
registration/license/permit etc. number, amount of sale etc. should be maintained on a day to
day basis.

Trading activities-Regulatory
framework
(d) WT of goods would be permitted among companies of the same group. However, such
WT to group companies taken together should not exceed 25% of the total turnover of
the wholesale venture
(e) WT can be undertaken as per normal business practice, including extending credit
facilities subject to applicable regulations
(f) A Wholesale/Cash & carry trader cannot open retail shops to sell to the consumer
directly.
 Automatic route of FDI under Notification No. 20; Schedule 4 for Non Resident
Indians. Paragraph 1: “No purchase of shares or convertible debentures of an Indian
company shall be made under this scheme if the company concerned is a Chit fund or
a Nidhi company or is engaged in agricultural/plantation activities or real estate
business or construction of farm houses or dealing in TDRs
 Trading activity through proprietary and partnership concern in India. Notification No.
24 states, the firm or the proprietary concern is not engaged in any
agricultural/plantation activity or real estate business or print media sector

Trading activities-Regulatory framework
 Activity of a branch or unit in SEZ
 Permitted Trading activity & Government Policy
www.dipp.nic.in
 Statistics & History
 Types of Activities
 Prohibited Activities
 Condition, Benefits, Challenge & Issues
 Direct & Indirect Investment
 Meaning of Trading & its types

Branch Activities under FEMA
Permitted activities for a branch in India of a person resident outside India-
i) Export/Import of goods(1)
ii) Rendering professional or consultancy services.
iii) Carrying out research work, in which the parent company is engaged.
iv) Promoting technical or financial collaborations between Indian companies and parent or
overseas group company.
v) Representing the parent company in India and acting as buying/selling agent in India.
vi) Rendering services in Information Technology and development of software in India.
vii) Rendering technical support to the products supplied by parent/group companies
viii) Foreign airline/shipping company.
[Notf. 22 of FEMA
(1) Procurement of goods for export and sale of goods after import are allowed only on
wholesale basis [Master circular 07/2013-14 dt 01/07/2013 ]

Branch Activities & SEZ
 Reserve Bank has given general permission to foreign companies for
establishing branch/unit in Special Economic Zones (SEZs) to undertake
manufacturing and service activities. The general permission is subject to
the following conditions:
i) such units are functioning in those sectors where 100 per cent FDI is
permitted;
ii) such units comply with part XI of the Companies Act,1956 (Section 592
to 602);
iii) such units function on a stand-alone basis.

As per SEZ Act 2005 :
Export: Export means-
i) Taking goods , or providing Services, out of India , from a SEZ , by land a or air or
by any other mode , Whether physical or otherwise or
ii) Supplying goods , or providing services , from the Domestic Tariff Area to a Unit or
Developer ;or
iii ) Supplying goods, or providing services, from one Unit to another Unit or
Developer in the same or different SEZ
Import: Import means-
i) Bringing goods or receiving services, in a Special Economic Zone, by a Unit or
Developer from a place outside India by land, sea or air or by any other mode ,
whether physical or otherwise or;
ii) Receiving goods, or services by, Unit or Developer from another Unit or Developer
of the same Special Economic Zone or a different Special Economic Zone;

 Entrepreneur: Entrepreneur means a person who has been granted a letter of
approval by the Development Commissioner under sub-section (9) of section 15;
 Person: Person includes an individual, whether resident in India or outside India,
a Hindu undivided family, co-operative society, a company, whether
incorporated in India or outside India, a firm, proprietary concern, or an
association of persons or body of individuals, whether incorporated or not, local
authority and any agency, office or branch owned or controlled by such
individual, Hindu undivided family, co-operative, association, body, authority or
company;
 Sec 51 of SEZ Act 2005-The provisions of this Act shall have effect
notwithstanding anything inconsistent therewith contained in any other law for
the time being in force or in any instrument having effect by virtue of any law
other than this Act.

History Statistics-Retail
Trade
The Indian retail industry has experienced growth of 10.6% between 2010 and 2012 and is
expected to increase USD 750-800 billion by 2015. Food and grocery is the largest category
within the retails sector with 60% share followed by Apparels and mobile Segment.
6th August 2013 P. P. Shah & Associates
14

Government Policy
 Background:
 1995- WTO’s general agreement on trade in services, which include both wholesale and
retailing service , come into effect
 1997- 100 % FDI In cash and carry (Wholesale) allowed under Govt. approval route
 2006- FDI in cash and carry (Wholesale) brought under automatic route
Up to 51% investment in Single brand retail outlet permitted
 2011- 100% FDI in Single brand retail permitted
 2012-- 51% FDI in Multi Brand Retail permitted
 2013-August- FDI in Single Brand retailing up to 49% brought under Automatic Route. Press
release dt 2nd Aug 2013,MOC,GOI.
Type of Trading Activities: Wholesale, Retail- Single & Multi Brand, Business Supply, Social
Sector, Test Marketing, Bulk Import for Exports, B2B, B2C, E- Commerce

Prohibited Sector -Press note No. 5
(2012 series) & Con.Policy.
 FDI is prohibited in:
A) Lottery Business, including Government/Private Lottery, Online Lotteries etc.
B) Gambling and betting, including casinos etc.
C) Chit fund
D) Nidhi Company
E) Trading in Transferable Development Rights (TDRs)
F) Real Estate Business or Construction of Farm Houses
G) Manufacturing of Cigars, Cheroots, Cigarillos and Cigarettes, of tobacco or of
tobacco substitutes
H) Activities / Sectors not open to private sector investment e.g. Atomic Energy
and railway Transport ( Other than Mass Rapid Transport System)
Foreign Technology Collaboration in any form, including licensing for
franchise, trademark, brand mark, management contract, is also prohibited for
lottery business and Gambling and Betting activities.

Single Brand Retailing
 Product to be sold should be ‘Single Brand’ only.
 Products should be sold under the same brand internationally i.e. products should be sold
under the same brand in one or more countries other than India.
 ‘single brand’ product-retail would cover only products which are branded during
manufacturing
 A non-resident entity or entities, whether owner of the brand or otherwise shall be permitted to
undertake ‘Single Brand’ product retail trading in the country for the specific brand, directly or
through a legally tenable agreement with the brand owner for undertaking single brand
product retail trading.”
 However, the onus for ensuring compliance with above condition will rest with the Indian
entity carrying out single brand product retail trading in India.
 The investing entity shall provide evidence to this effect at the time of seeking approval,
including a copy of the licensing/ franchise/sub-license agreement, specifically indicating
compliance with the above condition.
 The requisite evidence should be filed with the Reserve Bank of India (RBI) for the automatic
route and Secretariat for Industrial Assistance (SIA)/Foreign Investment Promotion Board
(FIPB) for cases involving approval of the Government i.e. where the investment in single-
brand retail is between 49 percent and 100 percent.(P.note 1 of 2013 and PR Dt 2 nd Aug 13)

Single brand retailing(contd.)
 In respect of proposal involving FDI beyond 51%, sourcing of 30% of the value of goods
purchased, will be done from India, preferably from MSMEs, village and cottage industries,
artisans and craftsman, in all sectors. this procurement requirement would have to be met,
in the first instance, as an average of 5 years’ total value of the goods purchased,
beginning 1st April of the year during which the first tranche of FDI received.
 Retail trading, in any form, by means of e- commerce, would not be permissible, for
companies with FDI, engaged in the activity of single-brand retail trading.
 Application seeking permission of the Government for FDI exceeding 49% in a company
which proposes to undertake single brand retail trading in India would be made to the
Secretariat for Industrial Assistance (SIA) in the Department of Industrial Policy and
Promotion (DIPP).”
 “The applications would specifically indicate the product/ product categories which are
proposed to be sold under a ‘Single Brand’. Any addition to the product/ product categories
to be sold under ‘Single Brand’ would require a fresh approval of the Government. In case
of FDI up to 49% the product/ product categories proposed to be sold except food products
would be provided to the RBI

19
Multi Brand Retailing
 A)Fresh agricultural produce, including fruits, vegetables, flowers, grains, pulses, fresh poultry, fishery and
meat products may be unbranded
 B) Minimum amount to be brought in, as FDI ,by the foreign investor, would be US$ 100 million
 C) At least 50% of total FDI brought in the first tranche of US$ 100 million, shall be invested in 'backend
infrastructure' within three years, where 'back-end infrastructure' will include capital expenditure on all
activities, excluding that on front-end units. For instance, back-end infrastructure will include investment
made towards processing, manufacturing, distribution, design improvement, quality control, packaging,
logistics, storage, ware-house, agriculture market produce infrastructure etc. Expenditure on land cost and
rentals, if any, will not be counted for purposes of backend infrastructure. Subsequent investment in the
back-end infrastructure would be made by the MBRT retailer as needed, depending upon his business
requirements”.
 D) At least 30% of the value of procurement of manufactured/ processed products purchased shall be
sourced from Indian micro, small and medium industries which have a total investment in plant & machinery
not exceeding 2.00 million. This valuation refers to the value at the time of installation, without providing for
depreciation. The 'small industry' status would be reckoned only at the time of first engagement with the
retailer and such industry shall continue to qualify as a 'small industry' for this purpose even if it outgrows the
said investment of 2.00 million, during the course of its relationship with the said retailer. Sourcing from
agricultural co-operatives and farmers cooperatives would also be considered in this category. The
procurement requirement would have to be met, in the first instance, as an average of five years' total value
of the manufactured/ processed products purchased, beginning 1st April of the year during which the first
tranche of FDI is received. Thereafter, it would have to be met on an annual basis”.

Multi Brand Retailing(Contd.)
 E)Self-certification by the company, to ensure compliance of the conditions at serial no B,C and
D above which could be cross-checked, as and when required.
 F) Retail sales outlets may be set up only in cities with a population of more than 10 lakh as per
the 2011 Census or any other cities as per the decision of the respective State Governments,
and may also cover an area of 10 kms around the municipal/urban agglomeration limits of such
cities; retail locations will be restricted to conforming areas as per the Master/Zonal Plans of the
concerned cities and provision will be made for requisite facilities such as transport connectivity
and parking”.
 G) Govt. will have first right to procurement of agricultural products.
 H) the policy is an enabling policy only and the state governments/Union Territories would be
free to take their own decision in regard to implementation of the policy.
 I) Retail trading, in any form, by means of e-commerce, would not be permissible, for companies
with FDI, engaged in activity of multi brand retailing
 J) Applications would be processed in the DIPP , to determine whether the proposed investment
satisfies the notified guidelines, before being considered by the FIPB for govt. approval.
(Note: The amendment has been made by Union Cabinet in point C,D & F to extend the benefits of
the FDI policy in multi-brand retail trading to a larger constituency of small industries. The
amendment in the provision regarding 'back-end infrastructure' will give more clarity to the
policy. The amendment to the provision regarding location of retail outlets will bring in parity in
the policy as it is proposed to extend such dispensation to all States.

Execution Challenge
The advent of FDI Policy of September 2012 can pave the way of modernization of Indian
Retail sector. However journey ahead is challenging
 Availability of Retail Space: Hypermarket require more than 60,000 sq. ft. and Departmental
store requires more than 20,000 sq. ft.
 High Rental Cost: According to Industry estimate , rental comprise approx 40% of total cost
to sales in the retail sector
 Political risk: The opposition party have opposed FDI in retail and some of its leader have
indicated that they will scrap the policy if their party comes to power.
 Currency fluctuation:
 Infrastructure Challenge:

Factors- FDI in Retail Industry
Land & Space Requirements: According to the Land and Property Law only the Indians
have right to land and property in India and this law has in a way inhibited the entry of
foreign players in India.
Taxation: Tax structure of India is also unfavorable for the foreign players. The Corporate
tax rate for the domestic Companies is 30% whereas it is 40% for the foreign Companies.
In India, VAT is a state levy and Companies operating across the country find it difficult to
configure different state tax rates for the same product. The changing Sales tax as well as
Value added Tax is also not favorable.
Transfer Pricing litigation : Transfer Pricing(TP) has become the single largest topic of tax
litigation for MNC’s in India. One of the main point of contention is determining who should
bear the expense and enjoy the fruits of creating marketing intangibles in the country of
operation of the distributors.

Benefits of FDI
 India’ s retail market is majorly dominated by unorganized sector. Organized sector
segment account for 8% of retail landscape
 Fear of Inflation & Price rise etc.- Some Politician say price will go up : Is this possible?
Before telecom sector was opened up, the cost of long distance call was 20/min, which
translate into 60 at today's value of the rupee . And we have to wait for 3 days to get call
connected . What is the cost of the same call today? 50 paisa/min , less than1 % freeing up
of market and increased competition leads to reduction in price not increment in price – no
matter what form of economics one follow

Benefits (Contd.)
 Better infrastructure will wipe out inefficiencies of our system; Colossal losses of Perishable
goods, Lack of processing and storage facility, Supply Chain Mgt etc.
 Curb the inflation: The gap between gate price of agricultural produce and retail price(In
India) are amongst the highest in the world as also amongst the emerging market. A farmer
can be approached by retailers directly not through intermediaries, which will also help
bring down price by 25%.
 India gets modern storage and warehousing infrastructure using funds brought from FDI.
 In both single and multi brand retail, e- commerce is not permitted. This in effect means
creating of more real estate infrastructure and front end showroom sales that bring more
employment and local taxes.

Issues of FDI in Single brand
Single
Brand
Who shall be
permitted to
undertake single
brand retail
trading-FDI by
MFGs /Licencee
Products to be sold
should be of ‘Single
Brand ‘ only
Product should
be branded
during
manufacturing
FDI allowed up to 100 %with
conditions -comparison
30% of Value of goods
purchased to be sourced
from SME ,if FDI is
beyond 51%
Up to 49% - Automatic
route, 2ND
Aug 2013(PR)
Transaction
with Whole
sale Trader

Issues of FDI in Multi brand
MBRT
$100
million
Front
end
store
Population/
Non FDI state
Stores owned
& Operated
by Multi
Brand
Retailer
Back end
Infrastructure of
Whole sale Trader
An independent
from Whole sale
Trading
Transaction
with Wholesale
Trader30% of input
manufactured/processed
products

Clarification on FDI in Multi Brand Retail
Trading
 The DIPP on June 6, 2013 has issued a clarification on the queries of the prospective investors
with respect to the provision on Multi Brand Retail Trading
 Certain key Clarifications :
1. Mandatory Local sourcing: 30% of procurement of manufactured goods and products from small
industry ….. Such procurement has to be sold through the ‘front end retail , and not through
wholesale (B2B) or cash and carry approach.
2.50% of the FDI to be invested in Back end infrastructure: FDI in MBRT will require fresh
investment in back end infrastructure rather than buying an existing one.
3.Franchise arrangement: It is now clarified that franchisee model is not permissible by MBRT
entities and the front end stores set up by MBRT entity will have to be company owned and
company operated only.
4.State Discretion: The States/Union territories which have agreed to allow FDI in MBRT in their
States/Union territories cannot amend the main policy on MBRT as the same is under the domain
of central government . However states shall have the prerogative of imposing additional
conditions under the applicable state laws and regulation.
5.Non FDI agreeing states/Union territories: If foreign investor approaches a state
government/union territories that is not included in list of the states/union territories supporting FDI
in MBRT , as per the prevalent FDI policy ,consent given by such states will be acceptable , and a
suitable amendment will be undertaken by Central govt. Further, investment in back end
infrastructure can be made in any state even if such states may not have agreed to FDI policy on
MBRT
27

Bharti Walmart Case
 Investment of Rs. 455.8 crore made by Walmart in Cedar
support service, a subsidiary of Bharti venture and holding of
Bharti Retail by way of unsecured CCD was termed to be illegal
and went against FDI rules under FEMA and Prevention of
money laundering act . The allegation is that while FDI was
obtained for Cedar support service ,which was suppose to
operate in service and real estate consultancy sector, the
investment was later channelised to Bharti Retail, which was in
the business of MBRT not opened for FDI .

Direct & Indirect Foreign Investment
 Rules for computation of direct & indirect foreign investment in
Indian Companies (PN 2 of 2009 & Regulation 14 of Notification
20 –Inserted vide Notification No. 278 dt. 07/06/2013 )
 Direct Foreign Investment : Investment directly by a non resident
entity into Indian Company regardless of whether the said
investment have been made under Schedule 1,3,6 and 8 of
Notification No. FEMA 20/20000-RB dated May 3 2000, direct
foreign investment = % of equity held
 Indirect Foreign Investment: Investment through Indian Companies
 Owned and Controlled by resident Indian citizens and/or Indian
Companies which are owned and controlled by resident Indian
citizens, i.e. more than 50% equity and power to appoint majority of
directors with residents, Indirect FDI = Nil
 Owned and Controlled by non resident entities as
WOS: Indirect FDI = % of equity held in investing Indian Company
Other: Indirect FDI = % of equity held by investing Indian Company

Computation of Direct Foreign Investment
NRE
A
Co
B
Co
75%
26%
20%
Foreign Investment in B Co
Direct - 20%
Indirect – 26%
NRE: Non Resident Entity

Computation of Indirect Foreign Investment
NRE
A
Co
B
Co
49%
100%
NRE
A
Co
B
Co
75%
26%
NRE
A
Co
B
Co
75%
80%
NRE
A
Co
B
Co
75%
100%
Indirect FI NIL 26% 80% 75%
NRE: Non Resident Entity
FI: Foreign Investment

Trading - Activity of Branch &
Companies
 Differentiate between the activity of branch of PROI &
companies with FDI by PROI
 Permitted activities
 Approval or Auto route
 Branch is under auto route but types of the trading
activities available to company are wide
 Branch requires approval of RBI/ADs whereas Single
brand trading above 49% and other cases of trading
except whole sale trading requires FIPB approval
 Distinction is narrowed down after 30th
December
2009 [Refer AP (DIR Series) Cir. No. 23]

Meaning of ‘Trading’ & Nature of Activities
 “Wholesale” trading [P. No. dt. Feb 7, 2001]
The wholesale trader is a one who sells his/its goods
to retailers and not to consumers
 “Cash and carry wholesale”
Cash and carry implies “quick delivery of goods” but
not as distinguished from “credit” vis-à-vis cash
[Clarification dt. 6th
August 01]
Thus cash and carry wholesale includes credit
 “Retail trading”
The activity of buying and selling whereby dealer
sells the goods to consumers

Meaning & Nature of Activities
 Commonly known nature
 Wholesale & Retail
 Nature of activity & Regulatory framework
 Trading activity of the Export House (Schedule 1 to regulation 5 of
Notification No. 20), [ deleted vide Notification No. 179 dt.
22/08/2008]
 Trading in TDRs
 Cash & carry wholesale trading
 “Single brand” retail trading
 Multi Brand Retail trading
 Government Policy
 Exports
 Bulk imports with export/Ex bonded warehouse sales
 Cash & carry wholesale trading
 Other import of goods & services provided at least 75% is for
procurement and sale of goods & services among the companies of
the same group

Other Trading Activities subject to Exim Policy
 Companies providing after sale service
 Trading of High tech item/s requiring specialised after
sale service
 Trading of items for social sector
 Trading of items sourced from small scale sector
under its Brand name by companies
 Domestic sourcing of products for Exports
 Test marketing
 B2B E-commerce activities

Present Government Policy & rationale
 Trade deficit
 Thrust is priority on sector – Infrastructure & financial
sector
 Trading approval so far and fate of the applications
 Concept of “organised retail trade”
 Protection to small vendors in villages & town
 Proposal by Ministry of Food Processing industry,
GOI
 Working group in Ministry of consumer affairs

International factors – Retail trade
 Presence of MNCs in India – Supply chain
management & its impact
 WTO & Retail trade
 Brazil, China and major countries have opened up
the sector
 Flood Gate of Foreign Exchange Reserves

Trading Activity of PROI-Overall
 Trading activity of PROI
6th August 2013
P. P. Shah & Associates
38
Prohibited
Activities in
India
Non
Repatriation
basis
Repatriation basis
Schedule
4 of Notf.
20
Notf. 24 of
Fema
Single Brand
Retailing
Wholesale
Cash and
Carry
Branch,
Project
Office &
Branch in
SEZ
Multi
Brand
Retail
Trading
Other
Activiti
es51% allowed
from 10th
Feb.
2006
>51% with
Condition from
Sept 2012
Automatic route
upto 49% from
2nd
Aug 2013
FIPB from
20th
Sept
2012
Notf. 20 upto
Aug 2008 in case
of Star Export
house
•Branc
h
•Notific
ation
22
•Company
•Notif. 20
•Auto
Route
from 10th
Feb 2006

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FDI Policy-Trading Activity of PROI and relevant Provisions of FEMA

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