Foreign Direct Investment in Retail-the implications of the new regime
"India remains a high potential market with accelerated retail growth of 15-20 per cent expected over the next five years”
Organised or modern retail consists of chain stores owned or franchised by a central entity, or a single store that is larger than some cut-off point, typically consisting of various formats like hypermarkets, supermarkets and department stores. Traditionally, the Indian retail space consists of unorganised retailers owning small family managed outlets or the local kirana (the so-called “mom and pop” stores), mainly selling food and other essential consumer goods. Organised retail at USD 28 billion presently constitutes only 6-7% of the total retail sales in the country. Total retail sales is projected to grow at USD 1.25 trillion by 2020, of which organised retail would constitute USD 260 billion, according to a recent study conducted by the Confederation of Indian Industries with the Boston Consulting Group.
The Global Retail Development Index 2012 of AT Kearney observes that international private equity firms are providing significant investment in the retail sector. However, in order to reach this promising sales estimate, the sector requires substantial capital investment in the form of foreign direct investment. However, foreign investment into retail trade has been severely opposed on the basis that the Indian retail sector is still at a nascent stage and opening up of the sector to foreign competition will have an adverse impact on the unorganised retail sector and eventually result in the death of this sector.
Contrary to this perception, studies have shown that the high rate of consumption spurred by the growth in organised retail sector will promote the growth of both the organised and unorganised retail sectors in India, and that both formats will continue to co-exist. The Indian Council for Research on International Economic Relations measured the impact of organised retail on the disorganised retail sector and concluded that the entry of large organised retailers would (i) promote competitive response from unorganised/small retailers through improved business practices and technology upgradation; (ii) generate better price realization for farmers who sell directly to organized retail averaging about 25% higher than sale to regulated government mandis etc.; (iii) transform the logistics industry and promote actions by manufacturers to reinforce their brand strength, increase their own retail presence, adopt small retailers and set up dedicated teams to deal with modern retailers etc.
Organised retail trading has various benefits including provision of better consumer choice, lower prices, promotion of employment, better supply chain efficiencies, increased investment in support industries etc. and does not suffer from the disadvantages of traditional retail stores i.e. high costs, shrinkage, inefficiencies, lack of scale economies, low product quality, limited variety, frequent stock-outs, high prices, unpleasant shopping environment and lack the organisational abilities (like financial, managerial & entrepreneurial) needed to change and develop.
India has seen progressive entry of foreign operators in retail since the past ten years in different formats, such as through: (i) franchising and commission agents’ services (Pizza Hut, Marks & Spencer); (ii) Cash And Carry Wholesale Trading (Metro) (iii) Strategic Licensing & Distribution Agreements (Mango-Piramyd) (iv) Manufacturing and Wholly Owned Subsidiaries (Nike India Private Limited) (v) liaison office (Gap through Gap International Sourcing India Pvt. Ltd) etc., concluding with the recent changes permitting foreign direct investment (FDI) of 100% into single brand retail and upto 51% in multi brand retail sector subject to the conditions specified, under what we may term the “new FDI Policy”. These changes are a step in the right direction.
This note attempts to detail the changes in the policy framework in relation to the retail sector in India introduced in September 2012, the likely issues faced and the way forward on the same.
Critique of the new regulatory framework:
“Trading” maybe “wholesale” or “retail”. Wholesale trading is the sale of goods/merchandise to retail, industrial, commercial, institutional or other professional business users or to other wholesalers and related subordinated service providers. It comprises of sale of goods/services for the purpose of trade, business and profession. 100% foreign direct investment is allowed for cash & carry wholesale trading as per paragraph 18.104.22.168.2 of the new FDI Policy.
Retail trading could be (i) Single brand or (ii) Multi-brand product retail. Under single brand trading, a retail company sells its own products to consumers for their personal consumption, through wholly-owned units in India. Where a retail company can sell multiple brands under one roof to consumers for personal consumption, it constitutes multi-brand retail. As per para 22.214.171.124 of the FDI policy, 100% foreign direct investment can be made in single brand retail and 51% in multi-brand retail trade in India, subject to adherence to the terms and conditions specified therein.
Retailers, both domestic and international, should formulate new business structures compliant with the new FDI policy, before which there are certain issues which require resolution, as discussed below.
1. Local Sourcing:
The new FDI Policy imposes a requirement that at least 30% of the value of products purchased by a foreign investor should be from small & medium industries in India. This is a procurement condition imposed on the expectation that it would improve manufacturing capacity of domestic industries and provide the benefit of international technology and know-how to generate better incomes for local farmers. Those foreign companies which cannot satisfy the 30% mandate are required to set up own manufacturing facilities in India.
In order to accommodate the interests of various stakeholders in the present policy, the requirement has been spread out to a period of five (5) years and for the total value of the goods purchased. Despite this relaxation, some retailers like the Swedish home products store IKEA (proposing to invest INR 10,500 crores to set up single-brand retail stores in India under the “IKEA” brand) find it challenging to meet the local sourcing mandate. IKEA argues that for a small or medium enterprise to be competitive and able to supply the orders of foreign investors like IKEA, it would have to expand its manufacturing capacity and scale and thus would not remain within the definition of “small and medium industries” eligible for sourcing by global firms under the new FDI policy.
Another problematic issue is the basis for determination of the value of the manufactured product procured by the foreign investor from local sources. Under the consolidated FDI Policy of April 2012, there was lack of clarity on whether the basis of determination of the “value” was the cost price or the purchase price of the product sourced locally. Under the new FDI Policy, the Government has cleared this confusion by linking the procurement value to the purchase price of the product. This would however operate against the interests of the domestic consumers and generate phenomenal profits for the retailers who on the strength of their internationally recognizable brand value, could mark the selling price of products at a much higher price than the value at which they purchase the local products. Also, usually a large international multi-national corporation would enjoy unequal bargaining power in any price negotiation with a small manufacturer/farmer. The only protection, in so far as the local industries are concerned, is that the foreign investor would pay them an amount at least 30% of the value of the goods sourced from them.
There is also no clarity whether a retail investor can fulfill this condition by sourcing unrelated items, not integral to its business.
Large international luxury brands like Louis Vuitton, Canali (which already have a presence in India) are interested in launching their own stores in the country but, find that the sourcing requirement is a hindrance as it would require them to change their global manufacturing processes specifically for India and would face difficulties in finding quality raw materials, skilled labour and sales personnel, since the local salespeople are not adequately groomed to serve the luxury customer, especially in the earlier stages of retail expansion. According to experts, “….the scale of the Indian market is small at the moment for it to make sense of the luxury brands to start manufacturing in India, only for India”. However, this fails to consider that in the long run, it is the ability of an international retailer to localise its products to appeal to the various local markets and harness and develop the quality of the local talent pool, both of which are crucial to its success in such markets.
2. Back end infrastructure
The new FDI Policy imposes a requirement of a mandatory fresh investment of USD 100 million to be made by the foreign investor, of which 50% shall be invested in “backend infrastructure” within first three years of such investment. Back end infrastructure is defined to include processing, manufacturing, distribution, design improvement, quality control, packaging, logistics, storage, ware-house, agriculture market produce infrastructure etc. The purported aim is to improve storage infrastructure including cold chains, refrigeration, transportation, packing, sorting and processing; considerably reduce post harvest losses and bring remunerative prices to farmers and in other cases, to improve supply chain efficiency and promote investment into technology, all of which would lead to greater productivity in the manufacturing and agricultural sectors.
International retailers, including Walmart find this requirement onerous and have complained of the lack of clarity over issues such as whether existing investments in back-end cash & carry will be counted to meet the minimum investment obligation. Other companies face issues such as the existence of multi layered transportation & distribution networks in India adding to the cost of bringing products to the Indian market, concerns over the uncertain taxation regime and the lack of clarity in policy whether information technology outsourcing operations already established by them in India are included within the meaning of “back end infrastructure” etc. To ensure uninterrupted supply of their products to meet the ever increasing consumer demand, Apple Inc, for example, has developed vast sourcing networks in South-East Asian countries without the need to source for its products from India as a result of availability of better infrastructure, cheap labour, completeness of supply chains, ability to produce at scale and continually improving productivity in these countries.
The new FDI policy provides that the fresh investment does not include the expenditure incurred towards land cost and rentals, which would, in most cases, form a sizeable chunk of the investment brought in by the foreign investor. The Government has maintained that this requirement being part of a fresh proposal cannot be merged with the investment already made under the previous policy (i.e. the one existing before September 2012). Investment by a foreign retailer in existing Indian retail stores is permitted provided the investor does not exceed the 51% foreign holding requirement. However, it is not clear if a foreign investor would be required to make the additional investment if it were to acquire such existing Indian retail operator.
The cumulative effect of these conditions would be to place an undue burden on international retailers vis-à-vis domestic operators, who are not subject to these requirements and to limit the flexibility of such international retailers to harness the investment already made by them in India. Practically, this would result in foreign retailers investing in a phased and calculated manner, thereby limiting the vast benefits that large scale foreign investment can bring to India.
3. Brand ownership implications
Brands could be for single or multiple products and manufacturer or own-label. Registration of a product under one or more relevant class(es) as per the Trademarks Act, 1999 provides the registered user with the exclusive right to use/apply the brand name in relation to the product and to obtain relief in case of an infringement.
Under the consolidated FDI Policy of April 2012, a foreign investor was required to own the brand in order to be able to invest. This requirement has been relaxed under the new FDI policy such that a non-resident entity, whether as the owner of the brand or otherwise, can undertake retail trading for the specific brand with the consent of the brand owner through a license/franchise/sub-licence agreement as required. Usually the choice of location for making foreign investment is based on consideration of tax issues, anti-trust regulation, foreign exchange control restrictions etc. As such, this is a welcome development as it would improve transaction structuring flexibility for international retailers.
The new Policy provides that a retailer may sell multiple products provided they are of the same brand and with the permission of the brand name holder. Also (consistent with the Trade Marks Act) the same joint venture partners could operate various brands, but under separate legal entities. Government approval is not required for a change in foreign equity or for selling additional goods as long as the brand continues to be owned/ used by the same non-resident entity, with the consent of the brand owner.
It is felt that the “brand ownership” requirement has been imposed in order to ensure the international quality standards for products are maintained. Due to the requirement for the products to be branded at the manufacturing stage, the policy appears to discourage domestic label products and is tilted heavily towards the foreign manufacturer brands. Also, the policy is unclear whether retailing of goods with sub-brands bunched under a parent brand falls within the scope of single-brand retailing. There is also no clarity on whether co-branded goods (specifically branded as such at the time of manufacturing) would qualify within single brand retail trading.
The requirement to enter into a binding legal agreement with the brand owner to be able to use the brand in India would entail increased paperwork and legal costs for the Indian party as the onus is on the Indian party to seek the consent of the brand owner, which may, in many cases, lead to a delay in the implementation of the project concerned. However, the new policy ensures that the brand is still held within the same group and licensed as per international practice.
4. Ban on electronic commerce activities
Broadly defined, electronic commerce encompasses all kinds of commercial transactions that are concluded over an electronic medium or network i.e. business-to-consumer (B2C) and business-to-business (B2B). Under the Information Technology Act, 2001, the term has not been precisely defined and electronic commerce is used to mean transactions carried out by means of electronic data interchange and other means of electronic communication, which involve the use of alternatives to paper-based methods of communication and storage of information.
With the growth of internet shopping and the increased use of online sites like e bay, Amazon etc. there is increasing comfort among Indian consumers towards e-commerce. India's electronic retail industry is likely to touch INR 7,000 crores in the next three years, up from the current estimate of INR 2,000 crores. However, ignoring the vast potential for development of India’s digital infrastructure which would directly result from foreign investment inflows, the new FDI Policy prohibits electronic commerce on the retail side (i.e. B2C) . On the wholesale side, B2B commerce including cash & carry outlets is allowed.
The stated intention of the ban on e-commerce in retail is to protect the nascent state of online trading companies in India from international competition and monopolization of the domestic market by big foreign retailers, and the general view is that it may take upto 10 years for this ban to be removed. This has however not stopped companies from finding innovative means around the policy mandate albeit acting with the prescribed policy. Companies like Flipkart are structured as a wholesale company, Flipkart Online Retail Services Private Limited and a retail company, WS Retail Services Private Limited. In late 2011, Flipkart Online Services transferred the “Flipkart” brand name to Flipkart India, a B2B entity, which was then licensed to WS Retail Services, a B2C entity. In August 2012, an investment of USD 150 million was made into the wholesale supplier entity, which would then supply to the retail company, which would sell the products to the final consumer, which is permitted under the FDI policy. It has also been observed that online retailers are providing loans or heavy discounts to their B2C arms only to ensure that their B2C operations survive and despite their B2B operations suffering huge losses in India.
The recently announced changes to the FDI Policy are highly controversial and fraught with many ambiguities and uncertainties. It is only an enabling policy and the various State Governments/Union Territories are free to implement the policy as per their requirements. Those states which oppose the implementation of the retail policy are specifically exempt from its application. It is therefore not surprising that despite the recent policy changes coming into effect, many international retailers are being cautious to embrace the changes in policy. Insofar as the policy is concerned, despite encouraging signs and subdued optimism among Indian suppliers to international retailers, there are so many details still to be worked out.
Expanding growth in food and non-food retail sectors in India is inevitable given the expanding middle class with higher disposable incomes, increased consumer confidence, exposure to global brands, rapid urbanization etc. Given the benefits of organised retail, greater clarity on the policy initiatives and a more robust implementation of the new policy would go a long way in improving the potential for growth of this sector in India.
# Hana Ben-Shabat, Mike Moriarty, Helen Rhim, Fabiola Salman, “AT Kearney: Global Retail Expansion: Keeps on moving”, http://www.atkearney.com/documents/10192/4799f4e6-b20b-4605-9aa8-3ef451098f8a; last accessed on October 3, 2012.
# Mathew Joseph, Nirupama Soundararajan, Manisha Gupta, Sanghamitra Sahu, “Impact of Organized Retailing on the Unorganized Sector”, The Indian Council for Research on International Economic Relations, May 2008, http://dipp.nic.in/english/publications/reports/icrier_report_27052008.pdf; last accessed on September 9, 2012.
# Chain stores are retail outlets that share a brand and central management and usually have standardized business methods and practices; Department Stores offer various kinds of quality products and services, not all full service category products and carry selective product lines; Hypermarket is a superstore combining a supermarket and a department store which carries enormous range of products under one roof, including full lines of groceries and general merchandise, http://www.scribd.com/doc/49364246/TYPES-OF-RETAIL-FORMATS; last accessed on October 5, 2012.
# The FDI notifications issued by the Government were recently challenged in the Supreme Court of India. The applicant quoted estimates that currently domestic retail sector (excluding villages and towns) is about USD 500 billion annually, which is expected to increase to USD 900 billion by 2014. This is consistent with a recent study conducted by the Confederation of Indian Industries and the Boston Consulting Group in August 2012.
# Pierre Mercier, Rune Jacobsen, Andy Veitch, “Retail 2020: Competing in a Changing Industry”, a report by the Confederation of Indian Industries and the Boston Consulting Group dated August 9, 2012, https://www.bcgperspectives.com/content/articles/retail_digital_economy_retail_2020_competing_in_changing_industry/; last accessed on 3 October 2012.
# The report states that of the 29 retail investment transactions completed in 2011, most were as a result of private equity funding, for example, L Capital’s acquisition of 8% stake in Fab India; TPG and Bain Capital’s proposals to invest in Indian kidswear brand Lilliput, TPG’s investment of around INR 200 crores into Vishal Retail etc.
# The Report of the Indian Council for Research on International Economic Relations, May 2008, http://dipp.nic.in/english/publications/reports/icrier_report_27052008.pdf; last accessed on October 3, 2012.
# The following conditions are prescribed for wholesale cash & carry business under the FDI Policy:
i. The trading entity is required to obtain the requisite licenses/ registration/ permits for carrying out trading activity;
ii. Wholesale trading should be made only to ‘valid business customers’ with whom wholesale transactions can be entered into;
iii. Full records indicating all the details of such sales should be maintained by the wholesale trading entity on a daily basis;
iv. For companies of the same group, the wholesale trade taken together cannot exceed 25% of the total turnover of the entity;
v. A wholesale trader cannot open retail shops to sell to the consumer directly.
# Press Note 4/2012 imposes the following conditions for single brand retail trading:
i. Products sold by the retailer should be of a 'Single Brand' only. Retailing of goods of multiple brands, even if such products were produced by the same manufacturer is not allowed;
ii. Products should be sold under the same brand internationally;
iii. 'Single Brand' product-retail trading should cover only products which are branded during manufacturing;
iv. A non-resident entity, whether owner of the brand or otherwise, can undertake single brand product retail trading for the specific brand, with the consent of the brand owner, in the form of a licensing/franchise/sub-licence agreements specifically indicating compliance with the above condition;
v. For proposals involving foreign direct investment beyond 51%, sourcing of at least 30% of the value of products purchased should be from India, preferably from medium & small industries, village and cottage industries, artisans and craftsmen in all sectors. The procurement requirement should 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 should be met on an annual basis;
vi. Quantum of local sourcing should be self-certified by the company, which could be cross-checked as and when required. The Indian company receiving the FDI shall maintain accounts duly certified by statutory auditors;
vii. E-commerce would not be permissible for companies with FDI engaged in the activity of single-brand retail trading;
viii. The application for retail trade should specifically indicate the product/product categories which are proposed to be sold under the 'Single Brand'. Any addition to product categories to be sold under ‘single-brand’ would require fresh approval from the government;
# 'Small industries' are defined as industries which have a total investment in plant and machinery not exceeding USD 1 million. That valuation refers to the value at the time of installation, without providing for depreciation. “Village Industry” has the meaning as defined under the Khadi and Village Industries Commission Act, 1956. Small & Medium Enterprises are defined under the Micro, Small and Medium Enterprises Development Act 2006 as companies with an investment upto INR 10 crores, http://dipp.nic.in/English/acts_rules/Press_Notes/pn4_2012.pdf.
# The following conditions have been imposed for multi-brand trading:
i. Fresh agricultural produce, including fruits, vegetables, flowers, grains, pulses, fresh poultry, fishery and meat products, may be unbranded;
ii. Minimum amount to be brought in as FDI by the foreign investor would be USD 100 million;
iii. At least 50% of total FDI brought in shall be invested in 'backend infrastructure' within first three years, where 'back-end infrastructure' includes 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 are not counted therefor;
iv. At least 30% of the value of manufactured/processed products purchased shall be sourced from Indian “small industries” which have a total investment in plant & machinery not exceeding USD 1 million. This 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;
v. Self-certification by the company to ensure compliance of the conditions above which would be regularly cross-checked by the Government, as and when required. Accordingly, the investors shall maintain accounts duly certified by statutory auditors;
vi. Retail sales outlets may be set up only in cities with a population of more than 10 lakh as per 2011 Census and may also cover an area of 10 kms around the municipal/urban agglomeration limits of such cities;
vii. Retail trading in any form by means of e-commerce would not be permissible;
# According to the Ministry of Commerce press release dated December 22, 2011 “….the safeguards pertaining to a minimum of 30% procurement from Indian small industries would provide the necessary scales for these entities to expand capacities in manufacturing thereby creating more employment and also strengthening the manufacturing base of the country. Rural economy will benefit as large-scale investment in the retail sector especially in backend infrastructure will provide substantive gainful employment opportunities in the entire range of activities from the backend to the frontend retail business…”; http://commerce.nic.in/pressrelease/pressrelease_detail.asp?id=2877, last accessed on October 5, 2012.
# http://www.fashionunited.in/news/fashion/fdi-spillover-luxury-brand-wagon-to-roll-into-india-080220123125 , last accessed on October 5, 2012.
# http://economictimes.indiatimes.com/tech/hardware/apple-plans-to-set-up-its-own-stores-in-india-if-govt-eases-local-sourcing-norms/articleshow/16618793.cms , last accessed on October 1, 2012.
# Section 2(m) of the Trade Marks Act, 1999 provides that "mark" includes a device, brand, heading, label, ticket, name, signature, word, letter, numeral, shape of goods, packaging or combination of colours or any combination thereof. Case law has expanded the definition of mark to include sub-brands. See, Hem Corporation v ITC Limited, Notice of Motion No. 3940 of 2009 in Suit No. 2808 of 2009. The Trade Marks Act provides for what marks are not registrable under Section 9 (Absolute grounds for refusal of registration) and Section 11 (Relative grounds for refusal of registration) and the circumstances in which the mark may be registered as a trade mark.
# In June 2012, the FIPB had rejected an application made by the Netherlands-based international fashion chain Zara Holding on the view that the investment was made by the holding company rather than Inditex, the registered owner of the brand. However, recently the FIPB has indicated that Zara may re-apply to set up its single-brand retail “Masimo Dutti” stores in India. http://profit.ndtv.com/news/corporates/article-zara-can-set-up-massimo-dutti-brand-stores-dipp-310954, last accessed on September 17, 2012.
# See also, the case of “Pavers England”, the UK-based footwear major, which set up a USD 60 million Mauritian joint venture company Pavers Foresight Smart Venture Mauritius, in equal partnership with the Indian company, Foresight Group. In order to comply with the earlier FDI requirement that the foreign investor should “own” the brand, it transferred its brand ownership to the joint venture company, which would then invest in India. Pavers’ application to set up single brand retail stores in India has been recently cleared by the Foreign Investment Promotion Board; http://economictimes.indiatimes.com/news/news-by-industry/services/retail/fdi-in-retail-pavers-england-brooks-brothers-and-damiani-allowed-to-set-up-stores-in-india/articleshow/16886144.cms, last accessed on October 20, 2012.
# Usually companies hold their intellectual property including brands (i) in their holding company (centralized intellectual property ownership set up within a corporation) or (ii) in separate group entities by creating specific Intellectual Property Holding Companies (IPHC) (localised intellectual property ownership). The parent company, the original owner of the intellectual property transfers ownership of its intellectual property company to the IPHC.
# For instance see the wording in clause 2(b) of Press Note 4/2012 which provides that “the product should be sold under the same brand internationally…in one or more countries other than India”.
# http://www.indianmirror.com/indian-industries/2012/retail-2012.html, last accessed on October 22, 2012. See also, Aashish Bhinde, Karan Sharma, Sanchit Suneja, Anshu Agrawal, Kanchan Mishra, “India goes digital”, Avendus Capital, November 2011; http://www.avendus.com/Files/India_goes_Digital.pdf, last accessed on October 19, 2012.
# Para 126.96.36.199 of the FDI Policy provides that 100% FDI is allowed under the automatic route for companies that engage only in Business to Business (B2B) e-commerce and not retail trading, so that existing restrictions on FDI in domestic trading would be applicable to e-commerce as well.
# Para 188.8.131.52.1 of the FDI Policy defines wholesale trading to include resale, processing and thereafter sale, bulk imports with ex-port/ex-bonded warehouse business sales and B2B e-commerce.
# http://articles.economictimes.indiatimes.com/2011-08-17/news/29896669_1_e-commerce-private-equity-creative-accounting/2, last accessed on October 5, 2012. Similarly, the foreign funding into the online retailer Jabong was made into a company Jade eServices, which is a B2B wholesale operation. Xerion Retail Private Limited, B2C Indian company would market the product under its name and make the final sale to the customer; http://economictimes.indiatimes.com/news/news-by-industry/services/retailing/fdi-in-multi-brand-retail-foreign-players-worried-over-mandatory-100-mn-investment-in-first-3-years/articleshow/16563785.cms, last accessed on September 27, 2012.
# Shrutika Verma, “FDI Escapades”, Business World, October 1, 2012, http://businessworld.in/en/storypage/-/bw/fdi-escapades/546637.37489/page/0, last accessed on October 8, 2012.
# For instance, immediately after the announcement of liberalised investment policies, the opposition parties made a populist declaration to roll back the new policies if voted to power, justifying this on the basis of the “grave threat” to the traditional kirana shops, if foreign direct investment into retail was allowed; http://www.hindustantimes.com/India-news/Haryana/NDA-will-do-away-with-FDI-policy-if-comes-to-power-BJP/Article1-935929.aspx, last accessed on October 5, 2012.
# Annexure to Press Note 5/2012 lists the following states as having agreed to implement the new FDI Policy: Andhra Pradesh, Assam, Delhi, Haryana, Jammu & Kashmir, Maharashtra, Manipur, Rajasthan, Uttarakhand, Daman & Diu and Nagar Haveli.
# Carrefour chief’s letter to the Government whole heartedly congratulating the new FDI policy; http://economictimes.indiatimes.com/news/news-by-industry/services/retailing/government-flaunts-carrefours-gratitude-letter-on-fdi-in-multi-brand-retail/articleshow/16618689.cms, last accessed on October 1, 2012.
# http://economictimes.indiatimes.com/news/news-by-industry/cons-products/fashion-/-cosmetics-/-jewellery/luxury-brands-set-to-flaunt-made-in-india-tag-indian-suppliers-see opportunities/articleshow/16648036.cms , last accessed on October 3, 2012.
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