power equipment. Did Adani invoice the power equipment purchases to UAE-based entities such as Electrogen Infra FZE? If so, why? 13/ (Allegation #76) Was there a markup from the original purchase price for the equipment? What services did the Vinod Adani-associated entities provide that would have justified a markup? 14/ (Allegation #77) The same DRI investigation found that inod Adani’s intermediary entity sent ~$900 million to a privately owned Adani entity in Mauritius. What is the explanation for these transactions? 15/ (Allegation #78) Where did the money from these transactions go after it was sent to a private Adani entity in Mauritius? 16/ (Allegation #79) The DRI investigation also documented many other transactions through the Vinod Adani intermediary entity, which were not probed further by investigators. What is Adani’s explanation for these other transactions? There were two DRI investigations initiated against us in respect of over-invoicing of power equipment. The first DRI investigation (initiated pursuant to show cause notice issued to Maharashtra Eastern Grid Power Transmission Company Limited & others) has been adjudicated before the courts and has been closed and dismissed in our favour. The second DRI investigation (initiated pursuant to show cause notice issued to Adani Power Maharashtra Limited, Adani Power Rajasthan Ltd. & others) has been decided in our favour both by the DRI (the same authority who issued the show cause notice) as well as in appeal before the CESTAT. It has been held by CESTAT that all the imports were genuine and being undertaken at arm’s length and concluded that the value declared is correct and the value is not required to be redetermined. Whilst another appeal in this respect has been preferred in November 2022 and is pending, we strongly believe this will be decided in our favour in line with the decision of CESTAT. Each of these investigations are part of disclosures already made by us in the public domain, including the below and our stakeholders are aware of the same for many years. i. Offering circular dated February 5, 2020 for the U.S.$1 bn Senior Secured Notes by Adani Electricity Mumbai Limited (page 34), and ii. Offering circular dated July 13, 2021 for the U.S.$2 bn Global Medium Term Note Programme by Adani Electricity Mumbai Limited (page 53) iii. Offering circular dated July 28, 2016 for the U.S.$500 mn Senior Secured Notes issued by Adani Transmission Limited (page 37 and149) iv. Offering circular dated November 14, 2019 for the U.S.$500 mn Senior Secured Notes issued by Adani Transmission Limited (page 32 and 182) The relevant excerpts from the above documents are annexed hereto in Annexure 2. The relevant orders are appended in Annexure 6 and Annexure 8. 17/ (Allegation #80) In yet another scandal, Adani was accused of over-valuing coal imports through shell entities in Dubai, the UAE, Singapore, and the BVI. Did Adani transact with entities in these jurisdictions? If so, which ones and why? DRI, Mumbai initiated an investigation against around 40 importers (40 Companies) of coal for import made during Oct. 2010 to Mar. 2016 and sought for various documents including Invoice of 31
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