Ultimate Strategy
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The General Manager
Foreign Exchange Department,
Reserve Bank of India
Hyderabad
Through the Authorized Dealer:
HDFC BANK LIMITED
Dwarka Nagar, Visakhapatman
Andhra Pradesh – 530016
Dear Sir,
RE: Filing of form FC-GPR by Apex Meadows Private Limited dated 22.10.2011
Ref. Your letter no. HY.FE.FID/2622/14.06.254/2011-12 dated November 16, 2011 and
Our letter dated November 24, 2011
We refer to the above mentioned correspondence related in relation to the filing of FC-GPR on 22.10.2011 for issuance of CCPs by us.
In this regards, our submission are as follows:
a. Declarations are incomplete.
Please find attached the revised form FC-GPR with correct declaration as applicable.
b. Main Business Activity:
We would like to submit that the Company has been incorporated for the main purposes of undertaking Construction and Development related activities. We would like to submit that the instant clause referenced by you has been there in the Main Objects of the Company before shares were allotted to the foreign investor. We would like to submit and reiterate that at no point in time, we would like or propose to undertake the activities of carrying on the business as house, land and estate agents, etc.
We would like to assure that we will have this particular clause deleted from the Object Clause of the Company. We will furnish you the revised Object Clause within 30 days from the date hereof.
We submit that, as common, the main object in the Memorandum of Association is kept wide to allow the company in future for any permitted activities. However, please note that as of today, Company has not started any activities of that nature. We are also in process of delete this clause from our main object clause. We therefore submit that we have not violated any provisions of FDI policy as no such activities have been either carried out or proposed to be carried out by the Company.
c. Post Issue Pattern and Inflow Report.
We are enclosing herewith the statement duly filled in along-with the reporting made and filing of FC-GPR for all 5 (five) inward remittances from SRS Investment (Mauritius) Ltd. this will clarify your queries.
Please note that it is only now that we have been informed by HDFC Bank, Dwarka Nagar, Visakhapatnam Branch that the FC-GPR pertaining to inflow received on 16.05.2007 has not been filed with the RBI. For your ease of reference, we are submitting the copy that was filed with HDFC and duly acknowledged.
Nontheless, please condone the delay in filing the same with the RBI. Please take on the record the above referenced FC-GPR.
d. Please note that as mentioned in the FC-GPR , all preference shares are fully and compulsorily convertible and hence are eligible to be issued under FDI policy. With regards to conversion in relation to the earlier FC-GPRs since the same was required to be determined, we have not mentioned the same. As regards, the last FC-GPR dated October 22, 2011, we have stated that the conversion will take place at a price not less than INR 447. please note that In any event, we propose to convert the CCPS into 1 equity share each.
e. the necessary clarification for the letters dated 29.01.2009 and 02.11.2009 are attached herewith. Please note that our representative in Visakhaptnam inadvertently did not forward the aforesaid letters to us and therefore we could not respond to the same. We apologise for the delay in responding to the same.