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3. Reactores Nucleares de Fisi´ on

3.2. Reactor nuclear TRIGA IAN-R1 Colombia

3.2.4. Blindaje biol´ ogico

A. BENEFITS AVAILABLE UNDER THE INCOME TAX ACT, 1961 I ) SPECIAL TAX BENEFITS :

We believe that there are no special tax benefits available to the Company and its shareholders.

II) GENERAL TAX BENEFITS AVAILABLE:

™ TO THE COMPANY

1. Dividend income (whether interim or final), in the hands of the Company as distributed or paid by

any other Company is completely exempt from tax in the hands of the Company, under section 10(34) of the Income Tax Act 1961.

2. As per the provisions of Section 112 of the Act, long term gains which are not exempt under section

10(38) of the Act would be subject to tax at a rate of 20 percent (plus applicable surcharge and education cess). However, as per the proviso to section 112 (1), if the tax on long term capital gains resulting on transfer of listed securities or units, calculated at the rate of 20 percent with indexation benefit exceeds the tax on long term gains computed at the rate of 10 percent without indexation benefit, then such gains are chargeable to tax at a concessional rate of 10 percent (plus applicable surcharge and education cess).

3. Long term capital gain arising from the sale of equity shares in any Company through a recognized

stock exchange or from the sale of units of an equity oriented fund shall be exempt from Income Tax,

if such sale takes place on and after 1st of October 2004 and such sale is subject to Securities

Transaction tax, as per the provisions of section 10(38) of the Income Tax Act.

4. Short term capital gains arising from the transfer of equity shares in any company through a

recognized stock exchange or from the sale of units of equity-oriented fund shall be subject to tax @ 15% provided such a transaction is subject to Securities Transaction Tax, as per the provisions of section 111A of the Income Tax Act.

5. In accordance with and subject to the conditions and to the extent specified in Section 54EC

of the Income Tax Act 1961, the Company would be entitled to exemption from tax on gains arising from transfer of the long term capital asset [not covered by section 10(36) and section 10 (38)], if such capital gain is invested in any of the long-term specified assets in the manner prescribed in the said section. However, if the long-term specified asset is transferred or converted into money at any time within a period of three years from the date of its acquisition, the amount of capital gains exempted earlier would become chargeable to tax as long term capital gains in the year in which the long-term specified asset is transferred or converted into money.

6. In accordance with and subject to the provisions of section 32 of the Income tax Act, the Company

will be allowed to claim depreciation on specified tangible and intangible assets as per the rates specified. Besides normal depreciation, the Company, in terms of section 32(1)(iia), shall be entitled to claim Additional depreciation @ 20% of actual cost on new plant and machinery for the period of

7. In accordance with and subject to the provisions of section 35D of the Income tax Act, the Company will be entitled to amortize, over a period of five years, all expenditure in connection with the proposed public issue subject to the overall limit specified in the said section.

8. Under Section 115 JAA (1A) of the Act, tax credit shall be allowed if any tax paid (MAT) under

Section 115 JB of the Act. Credit eligible for carry forward is the difference between MAT paid and the tax computed as per the normal provisions of the Act. Such MAT credit shall not be available for set-off beyond 7 years succeeding the year in which the MAT credit becomes allowable.

9. In accordance with the provisions of section 35(2AB) of the IT Act, 1961 the company will be allowed

to claim deduction at the rate one & half times of the amounts spent on in house research & development facility as approved by the prescribed authority.

™ TO RESIDENT SHAREHOLDERS

1. Dividend (whether interim or final) declared, distributed or paid by the Company is completely exempt from tax in the hands of the shareholders of the Company as per the provisions of section 10(34) of the Income Tax Act 1961.

2. Any income of minor children clubbed with the total income of the parent under section 64(1A) of the Income Tax Act 1961, will be exempt from tax to the extent of Rs. 1500 per minor child under section 10(32) of the Income Tax Act 1961.

3. As per the provisions of Section 112 of the Act, long term gains which are not exempt under section 10(38) of the Act would be subject to tax at a rate of 20 percent (plus applicable surcharge and education cess). However, as per the proviso to section 112 (1), if the tax on long term capital gains resulting on transfer of listed securities or units, calculated at the rate of 20 percent with indexation benefit exceeds the tax on long term gains computed at the rate of 10 percent without indexation benefit, then such gains are chargeable to tax at a concessional rate of 10 percent (plus applicable surcharge and education cess).

4. Long term capital gain arising from the sale of equity shares in any Company through a recognized stock exchange or from the sale of units of an equity oriented mutual fund shall be exempt from

Income Tax if such sale takes place after 1st of October 2004 and the sale is subject to Securities

Transaction tax, as per the provisions of section 10(38) of the Income Tax Act 1961.

5. Short term capital gains arising from the transfer of equity shares in any company through a recognized stock exchange or from the sale of units of equity-oriented fund shall be subject to

tax @ 15% provided such a transaction is entered into after the 1st day of October, 2004 and

the transaction is subject to Securities Transaction Tax, as per the provisions of section 111A of the Income Tax Act 1961.

6. In accordance with and subject to the conditions and to the extent specified in Section 54EC of the Income Tax Act 1961, the shareholders would be entitled to exemption from tax on long term capital gains arising on transfer of their shares in the Company (not covered by sections 10(36) and 10(38)), if such capital gain is invested in any of the long term specified assets in the manner prescribed in the said section. However, if the long-term specified asset is transferred or converted into money at any time within a period of three years from the date of its acquisition, the amount of capital gains exempted earlier would become chargeable to tax as long term capital gains in the year in which the long-term specified asset is transferred or converted into money.

7. According to the provisions of section 54F of the Act and subject to the conditions specified therein, in the case of an individual or a Hindu Undivided Family (‘HUF’), gains arising on transfer

of a long term capital asset example , equity shares , etc (not being a residential house), other than gains exempt under section 10(38), are not chargeable to tax if the entire net consideration received on such transfer is invested within the prescribed period in a residential house. If a part of such net consideration is invested within the prescribed period in a residential house, then such gains would not be chargeable to tax on a proportionate basis. For this purpose, net consideration means full value of the consideration received or accruing as a result of the transfer of the capital asset as reduced by any expenditure incurred wholly and exclusively in connection with such transfer.

™ TO NON-RESIDENT INDIAN SHAREHOLDERS (OTHER THAN MUTUAL FUNDS, FIIs,

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