M/s Sparkle Clean Tech Private Ltd

In the Reserve Bank of India Foreign Exchange Department Mumbai Regional Office Main Building, 3rd floor Shahid Bhagat Singh Marg, Fort Mumbai 400 001 Present Shri J.K. Pandey Chief General Manager March 27, 2019 CA No. MUM812/2018 In the matter of M/s Sparkle Clean Tech Private Ltd 5/C, Prem Kutir, 177 Marine Drive, Mumbai 400 020 (Applicant) In exercise of the powers conferred under section 15(1) of the Foreign Exchange Management Act, 1999 and the Regulations/Rules/Notifications/Orders made thereunder, I pass the following Order 1 The applicant has filed the compounding application dated December 03, 2018, received at the Reserve Bank on December 07, 2018, for compounding of contravention/s of the provisions of the Foreign Exchange Management Act, 1999 (the FEMA) and the regulations issued thereunder. The contraventions sought to be compounded are in respect of the following paragraphs under Schedule 1 to Foreign Exchange Management (Transfer or Issue of Security by a Person Resident outside India) Regulations 2000, notified vide Notification No. FEMA 20/2000-RB dated May 3, 2000 as amended from time to time (hereinafter referred to as Notification No. FEMA 20/2000-RB):

FED, MRO, CEFA, M/s Sparkle Clean Tech Private Limited, CA No: MUM 812/2018 a) Para 9 (1) (A) under Schedule I to Notification No. FEMA 20/2000- RB: Delay in reporting receipt of foreign inward remittance towards subscription to equity. b) Para 9 (1) (B): under Schedule I to Notification No FEMA 20/2000- RB: delay in filing Form FC GPR to Reserve Bank after issue of shares to person resident outside India. c) Para 8 under Schedule I to Notification No FEMA 20/2000- RB: Neither the equity instruments were issued, nor the money refunded to the foreign investor within 180 days from the receipt of the inward remittance. 2 Brief details of the company M/s Sparkle Clean Tech Private Ltd are as follows:

Date of Incorporation August 11, 2005 Its main activities are: Manufacturing and marketing of water treatment plant and water recycling plant.

3 The applicant received foreign inward remittances from non-resident investors towards equity shares / compulsorily convertible preference shares/ compulsorily convertible debentures and it reported the same to the Reserve Bank on dates as indicated below. Delay under 9(1)(A) &/or Para 8 (whereas, "Y" represents delay in number of years, "M" represents delay in number of months and "D" represents delay in number of days, and LSF stands for : Late Submission Fees S Date of amount received Date of Para 9 (1) (A) date of Para 8 No/ inward (in INR) reporting allotment LSF remittanc to RBI / refund e 1 21/06/06 454,000.00 17/03/15 8Y 7M 24D 12/10/17 10Y 9M 25D 2 12/07/06 684,104.00 17/03/15 8Y 7M 2D 12/10/17 10Y 9M 3D 3 02/08/06 459,500.00 17/03/15 8Y 6M 12D 12/10/17 10Y 8M 13D 4 15/09/06 159,355.00 17/03/15 8Y 4M 30D 12/10/17 10Y 7M 0D 5 28/09/06 1,365,225.00 17/03/15 8Y 4M 17D 12/10/17 10Y 6M 18D 6 12/10/06 609,478.00 17/03/15 8Y 4M 2D 12/10/17 10Y 6M 3D 7 31/10/06 1,103,960.00 17/03/15 8Y 3M 14D 12/10/17 10Y 5M 15D 8 17/11/06 444,905.00 17/03/15 8Y 2M 28D 12/10/17 10Y 4M 29D 9 05/12/06 1,130,944.00 17/03/15 8Y 2M 9D 12/10/17 10Y 4M 10D 10 11/01/07 1,029,476.00 17/03/15 8Y 1M 3D 12/10/17 10Y 3M 4D 11 10/02/07 1,128,105.00 17/03/15 8Y 0M 4D 12/10/17 10Y 2M 5D 12 10/02/07 152,600.00 17/03/15 8Y 0M 4D 12/10/17 10Y 2M 5D 13 28/02/07 1,859,984.00 17/03/15 7Y 11M 17D 12/10/17 10Y 1M 18D 14 31/03/07 1,069,437.00 17/03/15 7Y 10M 14D 12/10/17 10Y 0M 15D 15 26/04/07 814,592.00 17/03/15 7Y 9M 19D 12/10/17 9Y 11M 20D 16 29/05/07 644,397.00 17/03/15 7Y 8M 16D 12/10/17 9Y 10M 17D

FED, MRO, CEFA, M/s Sparkle Clean Tech Private Limited, CA No: MUM 812/2018

17 29/05/07 563,797.00 17/03/15 7Y 8M 16D 12/10/17 9Y 10M 17D 18 08/06/07 810,794.00 17/03/15 7Y 8M 6D 12/10/17 9Y 10M 7D 19 12/07/07 900,899.00 29/09/07 0Y 1M 17D 31/08/07 0 20 31/08/07 304,198.00 29/09/07 0 31/08/07 0 21 03/08/07 762,475.00 17/03/15 7Y 6M 11D 12/10/17 9Y 8M 12D 22 09/08/07 601,886.00 17/03/15 7Y 6M 5D 12/10/17 9Y 8M 6D 23 29/08/07 406,618.00 17/03/15 7Y 5M 16D 12/10/17 9Y 7M 17D 24 29/08/07 406,618.00 17/03/15 7Y 5M 16D 12/10/17 9Y 7M 17D 25 14/09/07 603,534.00 17/03/15 7Y 5M 0D 12/10/17 9Y 7M 1D 26 03/10/07 980,473.00 17/03/15 7Y 4M 11D 12/10/17 9Y 6M 12D 27 23/10/07 1,174,962.00 17/03/15 7Y 3M 22D 12/10/17 9Y 5M 23D 28 05/11/07 389,310.00 17/03/15 7Y 3M 9D 12/10/17 9Y 5M 10D 29 21/11/07 1,172,713.00 17/03/15 7Y 2M 24D 12/10/17 9Y 4M 25D 30 29/11/07 392,606.00 17/03/15 7Y 2M 16D 12/10/17 9Y 4M 17D 31 14/12/07 1,953,843.00 17/03/15 7Y 2M 0D 12/10/17 9Y 4M 1D 32 24/01/08 985,158.00 17/03/15 7Y 0M 21D 12/10/17 9Y 2M 22D 33 13/02/08 793,600.00 17/03/15 7Y 0M 1D 12/10/17 9Y 2M 2D 34 27/02/08 1,988,704.00 17/03/15 6Y 11M 18D 12/10/17 9Y 1M 19D 35 04/03/08 1,007,395.00 17/03/15 6Y 11M 10D 12/10/17 9Y 1M 11D 36 24/03/08 1,007,894.00 17/03/15 6Y 10M 21D 12/10/17 9Y 0M 22D 37 02/04/08 998,900.00 17/03/15 6Y 10M 12D 12/10/17 9Y 0M 13D 38 09/04/08 998,151.00 17/03/15 6Y 10M 5D 12/10/17 9Y 0M 6D 39 28/04/08 1,003,500.00 17/03/15 6Y 9M 17D 12/10/17 8Y 11M 18D 40 02/05/08 975,600.00 17/03/15 6Y 9M 12D 12/10/17 8Y 11M 13D 41 07/05/08 20,600,000.00 17/03/15 6Y 9M 7D 12/10/17 8Y 11M 8D 42 15/05/08 2,120,000.00 17/03/15 6Y 8M 30D 12/10/17 8Y 11M 0D 43 03/06/08 1,063,250.00 17/03/15 6Y 8M 11D 12/10/17 8Y 10M 12D 44 03/06/08 850,600.00 17/03/15 6Y 8M 11D 12/10/17 8Y 10M 12D 45 25/06/08 2,141,000.00 17/03/15 6Y 7M 20D 12/10/17 8Y 9M 21D 46 03/07/08 2,165,000.00 17/03/15 6Y 7M 11D 12/10/17 8Y 9M 12D 47 25/07/08 2,111,500.00 17/03/15 6Y 6M 20D 12/10/17 8Y 8M 21D 48 08/08/08 2,110,000.00 17/03/15 6Y 6M 6D 12/10/17 8Y 8M 7D 49 22/08/08 2,169,000.00 17/03/15 6Y 5M 23D 12/10/17 8Y 7M 24D 50 11/09/08 2,272,000.00 17/03/15 6Y 5M 3D 12/10/17 8Y 7M 4D 51 19/09/08 694,800.00 17/03/15 6Y 4M 26D 12/10/17 8Y 6M 27D 52 27/09/08 2,321,500.00 17/03/15 6Y 4M 18D 12/10/17 8Y 6M 19D 53 01/10/08 1,643,600.00 17/03/15 6Y 4M 13D 12/10/17 8Y 6M 14D 54 21/10/08 739,350.00 17/03/15 6Y 3M 24D 12/10/17 8Y 5M 25D 55 04/11/08 1,179,500.00 17/03/15 6Y 3M 10D 12/10/17 8Y 5M 11D 56 15/11/08 1,224,750.00 17/03/15 6Y 2M 30D 12/10/17 8Y 5M 0D 57 03/12/08 1,247,500.00 17/03/15 6Y 2M 11D 12/10/17 8Y 4M 12D 58 08/12/08 1,230,500.00 17/03/15 6Y 2M 6D 12/10/17 8Y 4M 7D 59 23/12/08 1,697,150.00 17/03/15 6Y 1M 22D 12/10/17 8Y 3M 23D 60 05/01/09 1,209,250.00 17/03/15 6Y 1M 9D 12/10/17 8Y 3M 10D 61 09/01/09 1,223,000.00 17/03/15 6Y 1M 5D 12/10/17 8Y 3M 6D 62 28/01/09 1,221,750.00 17/03/15 6Y 0M 17D 12/10/17 8Y 2M 18D 63 04/02/09 969,720.00 17/01/12 2Y 10M 13D 12/10/17 8Y 2M 11D

FED, MRO, CEFA, M/s Sparkle Clean Tech Private Limited, CA No: MUM 812/2018

64 11/02/09 971,670.00 17/01/12 2Y 10M 6D 12/10/17 8Y 2M 4D 65 25/02/09 1,490,502.00 17/01/12 2Y 9M 22D 12/10/17 8Y 1M 21D 66 11/03/09 1,033,400.00 17/03/15 5Y 11M 3D 12/10/17 8Y 1M 4D 67 27/03/09 1,021,600.00 17/03/15 5Y 10M 18D 12/10/17 8Y 0M 19D 68 29/04/09 2,503,659.00 17/01/12 2Y 7M 18D 12/10/17 7Y 11M 17D 69 04/06/09 1,174,051.00 17/01/12 2Y 6M 13D 12/10/17 7Y 10M 11D 70 11/06/09 944,479.00 17/01/12 2Y 6M 6D 12/10/17 7Y 10M 4D 71 25/06/09 1,694,781.00 17/01/12 2Y 5M 22D 12/10/17 7Y 9M 21D 72 02/07/09 1,193,175.00 17/01/12 2Y 5M 15D 12/10/17 7Y 9M 13D 73 06/07/09 1,192,925.00 17/01/12 2Y 5M 11D 12/10/17 7Y 9M 9D 74 13/07/09 1,226,916.00 17/01/12 2Y 5M 4D 12/10/17 7Y 9M 2D 75 24/07/09 1,925,673.00 03/08/09 0 22/12/09 0 76 06/08/09 1,184,678.00 12/08/09 0 22/12/09 0 77 15/09/09 966,271.00 15/09/09 0 22/12/09 0 78 26/10/09 927,035.00 10/11/09 0 22/12/09 0 79 11/11/09 929,800.00 20/11/09 0 22/12/09 0 80 12/11/09 23,234,684.00 13/11/09 0 22/12/09 0 81 09/12/09 1,165,683.00 23/12/09 0 22/12/09 0 82 21/12/09 930,484.00 31/12/09 0 22/12/09 0 83 05/01/10 1,149,687.00 09/01/10 0 11/03/10 0 84 13/01/10 908,891.00 21/01/10 0 24/06/10 0 85 28/01/10 4,571,000.00 04/03/10 0Y 0M 4D 14/07/10 0 86 08/03/10 1,123,750.00 07/04/10 0 14/07/10 0 87 23/03/10 4,489,000.00 18/04/10 0 14/07/10 0 88 17/06/10 2,303,500.00 09/07/10 0 14/07/10 0 89 23/06/10 4,568,000.00 09/07/10 0 14/07/10 0 90 23/06/10 2,284,000.00 09/07/10 0 14/07/10 0 91 21/10/10 10,945,000.00 10/11/10 0 24/02/11 0 92 10/02/11 12,375,000.00 25/02/11 0 24/02/11 0 93 06/05/11 1,116,250.00 06/06/11 0 25/07/11 0 94 09/05/11 17,760,000.00 24/05/11 0 25/07/11 0 95 19/10/11 7,123,837.00 08/11/11 0 23/02/12 0 96 19/10/11 952,380.00 14/11/11 0 23/02/12 0 97 08/10/12 1,552,500.00 22/10/12 0 27/02/13 0 98 10/10/12 8,709,016.00 25/10/12 0 27/02/13 0 99 10/05/13 10,836,000.00 28/05/13 0 25/11/13 0Y 0M 19D 100 03/10/13 1,536,250.00 17/10/13 0 25/11/13 0 101 11/10/13 1,525,250.00 14/11/13 0Y 0M 3D 25/11/13 0 102 13/11/13 3,155,000.00 28/11/13 0 31/03/14 0 103 04/03/14 9,250,500.00 08/03/14 0 31/03/14 0 104 28/05/14 2,935,000.00 03/06/14 0 18/11/14 0 105 10/06/14 1,477,000.00 11/06/14 0 18/11/14 0 106 03/07/14 3,862,950.00 08/07/14 0 18/11/14 0 107 22/07/14 597,800.00 30/07/14 0 18/11/14 0 108 20/08/14 3,609,600.00 02/09/14 0 18/11/14 0 109 04/09/14 3,599,400.00 08/09/14 0 18/11/14 0 110 28/10/14 7,619,400.00 13/11/14 0 18/11/14 0

FED, MRO, CEFA, M/s Sparkle Clean Tech Private Limited, CA No: MUM 812/2018

111 10/11/14 6,110,000.00 22/12/14 0Y 0M 11D 18/11/14 0 112 07/01/15 3,775,800.00 11/02/15 0Y 0M 4D 20/01/15 0 113 12/01/15 3,088,000.00 10/02/15 0 20/01/15 0 114 24/03/15 3,087,500.00 06/04/15 0 18/05/15 0 115 14/05/15 3,165,125.00 18/05/15 0 09/06/15 0 116 05/06/15 3,160,000.00 15/06/15 0 25/11/15 0 117 01/07/15 1,887,300.00 07/07/15 0 25/11/15 0 118 14/07/15 3,137,500.00 16/07/15 0 25/11/15 0 119 02/12/15 18,180.00 07/12/15 0 25/11/15 0 A 119 02/12/15 3,282,320.00 07/12/15 0 29/01/16 0 B 120 02/12/15 3,300,500.00 08/12/15 0 29/01/16 0 121 21/12/15 3,287,500.00 30/12/15 0 29/01/16 0 122 21/12/15 3,287,500.00 30/12/15 0 02/01/16 0 123 05/02/16 3,350,000.00 20/02/16 0 01/03/16 0 124 16/02/16 3,384,500.00 20/02/16 0 01/03/16 0 125 16/02/16 3,384,500.00 20/02/16 0 01/03/16 0 126 29/08/16 3,325,500.00 07/09/16 0 08/09/16 0 127 29/08/16 3,325,500.00 06/09/16 0 08/09/16 0 128 29/08/16 3,325,500.00 06/10/16 0Y 0M 7D 08/09/16 0 129 30/09/16 3,292,500.00 03/11/16 0Y 0M 3D 17/11/16 0 130 30/09/16 3,292,500.00 03/11/16 0Y 0M 3D 17/11/16 0 131 18/10/16 3,300,000.00 03/11/16 0 17/11/16 0 132 18/10/16 3,300,000.00 03/11/16 0 17/11/16 0 133 26/10/16 3,308,500.00 03/11/16 0 17/11/16 0 134 18/11/16 1,075,360.00 01/12/16 0 31/12/16 0 A 134 18/11/16 2,283,640.00 01/12/16 0 11/01/17 0 B 135 18/11/16 3,359,000.00 01/12/16 0 11/01/17 0 136 06/12/16 3,357,500.00 08/12/16 0 11/01/17 0 137 12/01/17 3,360,000.00 19/01/17 0 14/02/17 0 138 12/01/17 3,360,000.00 19/01/17 0 14/02/17 0 139 15/02/17 3,305,000.00 08/03/17 0 15/03/17 0 140 08/03/17 3,292,500.00 15/03/17 0 15/03/17 0 141 08/03/17 987,750.00 15/03/17 0 15/03/17 0 142 13/11/17 1,620,500.00 14/12/17 0 11/01/18 0 143 09/02/18 3,187,500.00 23/02/18 0 07/04/18 0 144 22/02/18 3,221,453.00 03/03/18 0 07/04/18 0 145 22/02/18 3,221,453.00 03/03/18 0 07/04/18 0 146 09/03/18 3,225,000.00 15/03/18 0 07/04/18 0 147 09/03/18 3,225,000.00 15/03/18 0 07/04/18 0 148 27/03/18 3,208,966.00 06/04/18 0 07/04/18 0 149 05/06/18 3,323,840.00 13/06/18 0 08/06/18 0 150 12/06/18 3,325,000.00 20/06/18 0 26/06/18 0 TOTAL 395,261,524.00

FED, MRO, CEFA, M/s Sparkle Clean Tech Private Limited, CA No: MUM 812/2018

The applicant reported receipt of remittances to the Reserve Bank of India on dates indicated above with a delay ranging from 0Y 0M 3D to 8Y 7M 24D. Further the applicant company delayed in reporting in 80 out of 150 total remittances beyond the stipulated time of 30 days. Whereas, in terms of Paragraph 9 (1) (A) of Schedule 1 to Notification No. FEMA 20/2000-RB, an Indian company issuing shares or convertible debentures in accordance with these Regulations should report to the Reserve Bank of India as per the prescribed procedure not later than 30 days from the date of receipt of the amount of consideration. 4 In respect of remittances amounting to Rs.112,576,471 (Rupees Eleven Crore Twenty Five Lakh Seventy Six Thousand Four Hundred Seventy One and Zero Paise Only ), indicated in the table above the company allotted shares after 180 days from the date of receipt of investment, with a delay ranging from: 0Y 0M 19D to 10Y 9M 25D. Whereas in terms of paragraph 8 of Schedule 1 to Notification No. FEMA 20/2000-RB, an Indian company is required to issue shares or refund the amount within 180 days from the date of receipt of inward remittance. 5 The company allotted equity shares/compulsorily convertible preference shares/compulsorily convertible debentures and filed FC-GPRs as indicated below:

Contravention under Para 9(1)(B) (whereas, "Y" represents delay in number of years, "M" represents delay in number of months and "D" represents delay in number of days, LSF stands for : Late Submission Fees and FV stands for Face Value) Sno Date of number of FV+ Amount (FV*no Date of Para 9 (1) / allotment shares premium of shares) reporting (B) LSF (in INR) (in INR) 1 31/08/07 120500 10 1,205,000.00 29/09/07 0 2 22/12/09 120247 260 31,264,220.00 05/01/10 0 3 24/06/10 3495 260.0546 9 08,890.83 07/07/10 0 4 14/07/10 61200 260 15,912,000.00 22/07/10 0 5 14/07/10 13181 260 3,427,060.00 22/07/10 0 6 24/02/11 89692 260 23,319,920.00 04/03/11 0 7 25/07/11 4293 260 1,116,180.00 16/08/11 0 8 25/07/11 68307 260 17,759,820.00 16/08/11 0 9 23/02/12 3663 260 9 52,380.00 29/02/12 0 10 23/02/12 27399 260 7,123,740.00 29/02/12 0 11 27/02/13 5971 260 1,552,460.00 20/03/13 0 12 27/02/13 33496 260 8,708,960.00 20/03/13 0 13 25/11/13 53451 260 13,897,260.00 27/12/13 0Y 0M 1D 14 31/03/14 47713 260 12,405,380.00 02/05/14 0Y 0M 1D 15 18/11/14 114637 260 29,805,620.00 19/01/15 0Y 1M 1D 16 20/01/15 26399 260 6,863,740.00 05/08/15 0Y 5M 15D 17 18/05/15 11875 260 3,087,500.00 02/12/15 0Y 5M 14D 18 09/06/15 12173 260 3,164,980.00 02/12/15 0Y 4M 23D 19 25/11/15 31571 260 8,208,460.00 20/02/16 0Y 1M 26D

FED, MRO, CEFA, M/s Sparkle Clean Tech Private Limited, CA No: MUM 812/2018

20 29/01/16 50607 260 13,157,820.00 10/03/16 0Y 0M 10D 21 01/03/16 38919 260 10,118,940.00 22/04/16 0Y 0M 21D 22 08/09/16 38371 260 9,976,460.00 03/11/16 0Y 0M 25D 23 17/11/16 63436 260 16,493,360.00 14/03/17 0Y 2M 25D 24 31/12/16 4136 260 1,075,360.00 27/04/17 0Y 2M 24D 25 11/01/17 34615 260 8,999,900.00 27/04/17 0Y 2M 16D 26 14/02/17 25846 260 6,719,960.00 20/03/17 0Y 0M 3D 27 15/03/17 29174 260 7,585,240.00 27/04/17 0Y 0M 12D 28 12/10/17 18507 260 4,811,820.00 25/10/17 0 29 12/10/17 51391 260 13,361,660.00 23/10/17 0 30 12/10/17 321409 260 83,566,340.00 23/10/17 0 31 11/01/18 6232 260 1,620,320.00 09/02/18 0 LSF 07/04/18 74189 260 19,289,140.00 04/06/18 LSF Paid LSF 08/06/18 12784 260 3,323,840.00 19/07/18 LSF Paid 34 26/06/18 12788 260 3,324,880.00 19/07/18 0 TOTAL 394,108,610.83 The applicant filed form FC-GPRs as indicated above with a delay ranging from 0Y 0M 1D to 0Y 5M 15D. Whereas, in terms of Paragraph 9(1) (B) of Schedule 1 to Notification No. FEMA 20/2000-RB, an Indian company issuing shares in accordance with these Regulations has to submit to Reserve Bank a report in Form FC-GPR along with documents prescribed therein within 30 days from the date of issue of shares to person resident outside India.

In case of allotments amounting to Rs. 2,26,12,980.00 (Rupees Two Crore Twenty Six Lakh Twelve Thousand Nine Hundred and Eighty Only) indicated in the above table as "LSF Paid", they were also reported with a delay, In terms of Regulation 13.2 of Foreign Exchange Management (Transfer or Issue of Security by a Person Resident outside India) Regulations 2000, notified vide Notification No. FEMA 20R/2017-RB dated November 07, 2017 as amended from time to time, the person/ entity responsible for filing the reports stipulated in Regulation 13.1 shall be liable for payment of late submission fee, as may be decided by the Reserve Bank, in consultation with the Central Government, for any delays in reporting. Since the applicant has already deposited the LSF amount, this delay has not been taken into consideration for computing the amount for compounding the contraventions. 6 The applicant was given an opportunity for personal hearing, for further submission in person and/or for producing documents, if any, in support of the application vide e-mail dated March 12, 2019. The applicant appeared for personal hearing on March 15, 2019. During which Mr Nilesh Lilani, Consultant, Mr Dhirajkumar Pandey, Consultant and Mr Chetan Shah, representative from the company, represented the applicant in the cabin of Shri J.K.

Pandey, Chief General Manager, Mumbai Regional Office. The representatives of the applicant admitted the contraventions for which compounding has been sought. During the hearing it was submitted that delay was inadvertent and unintentional. The representatives of the applicant requested that in view of the foregoing a lenient view may be taken in disposal of the application. The application for compounding is, therefore, being considered on the basis of the averments made in the application as well as other documents and submissions made in this context by the applicant during personal hearing and thereafter.

FED, MRO, CEFA, M/s Sparkle Clean Tech Private Limited, CA No: MUM 812/2018

7 I have given my careful consideration to the documents on record and submissions made by the applicant during the personal hearing and thereafter. Accordingly, I hold that the applicant has contravened the following FEMA provisions issued in terms of: a) Paragraph 9(1) (A) of Schedule 1 to Notification No. FEMA 20/2000-RB due to the delay in reporting of receipt of foreign inward remittance towards subscription towards shares as detailed above. The contravention relates to an amount of Rs.128,533,920 (Rupees Twelve Crore Eighty Five Lakh Thirty Three Thousand Nine Hundred Twenty and Zero Paise Only ) and with a delay ranging from minimum 0Y 0M 3D to maximum 8Y 7M 24D approximately. b) Paragraph 9(1) (B) of Schedule 1 to Notification No. FEMA 20/2000-RB, due to the delay in submission of Form FC-GPR to the Reserve Bank after issue of shares to persons resident outside India and the contravention relates to an amount of Rs.151,559,980 (Rupees Fifteen Crore Fifteen Lakh Fifty Nine Thousand Nine Hundred Eighty and Zero Paise Only ) and with a delay ranging from minimum 0Y 0M 1D to maximum 0Y 5M 15D approximately. c) Paragraph 8 of Schedule 1 to Notification No. FEMA 20/2000-RB, since the shares were neither issued nor the amount was refunded to the person resident outside India within 180 days from the date of receipt of the inward remittance.

The contravention relates to an amount of Rs.112,576,471 (Rupees Eleven Crore Twenty Five Lakh Seventy Six Thousand Four Hundred Seventy One and Zero Paise Only ) and with a delay ranging from minimum 0Y 0M 19D to maximum 10Y 9M 25D approximately. 8 It has been declared in the compounding application dated December 03, 2018 that the particulars given by the applicant in the application are true and correct to the best of their/his/her knowledge and belief.It has also been declared in a declaration attached to the compounding application that the applicant was not under any enquiry/investigation/adjudication by any agency as on the date of the application and has, in this regard, not informed of initiation of any such enquiry/investigation/ adjudication proceedings against it/him/her thereafter. It has further been declared that the applicant has not filed any appeal under section 17 or section 19 of FEMA, 1999. Accordingly, the above contraventions which are being compounded in this Order are subject to the veracity of the above declarations made by the applicant and this order is without prejudice to any other action which may be taken by any authority under the extant laws if the said declarations are subsequently discovered to be false and/or incorrect.

9 In terms of section 13 of the FEMA, any person contravening any provision of the Act shall be liable to a penalty up to thrice the sum involved in such contravention upon adjudication. However, taking into account the relevant facts and circumstances of the case as stated in the foregoing paragraphs, I am persuaded to take a lenient view on the amount for which the contraventions are to be compounded and I consider that an amount of Rs.2,081,895 (Rupees Twenty Lakh Eighty One Thousand Eight Hundred Ninety Five and Zero Paise Only ) will meet the ends of justice.

FED, MRO, CEFA, M/s Sparkle Clean Tech Private Limited, CA No: MUM 812/2018

10 Accordingly, I compound the admitted contravention/s namely, the contravention/s of Para 9 (1) (A), Para 9 (1) (B) and Para 8 under Schedule 1 of Notification No. FEMA 20/2000-RB, by the applicant, on the facts discussed above in terms of the Foreign Exchange (Compounding Proceedings) Rules, 2000 on payment of an amount of Rs. 2,081,895 (Rupees Twenty Lakh Eighty One Thousand Eight Hundred Ninety Five and Zero Paise Only ) which shall be deposited by the applicant with the Reserve Bank of India, Foreign Exchange Department, Mumbai Regional Office, Main Building, 3rd floor, Shahid Bhagat Singh Marg, Fort, Mumbai-400001 by a demand draft drawn in favour of the "Reserve Bank of India" and payable at Mumbai within a period of 15 days from the date of this order. In case of failure to deposit the compounded amount within the above-mentioned period, Rule 10 of the Foreign Exchange (Compounding Proceedings) Rules, 2000 dated May 3, 2000 shall apply. 11 The above order is passed only in respect of contraventions of Para 9 (1) (A), Para 9 (1) (B) and Para 8 under Schedule 1 of Notification No. FEMA 20/2000-RB and does not restrict the right of any other authority to proceed against the Company for any other violations/contraventions noticed at any point of time.

12 The application is disposed of accordingly. Dated: March 27, 2019 Compounding Authority (J.K. Pandey) Chief General Manager