Reassessing Core Investment Companies: Navigating Regulatory Ambiguities and Investment Implications in India’s NBFC Ecosystem

I. Introduction: The Evolving Role and Regulatory Classification of Core Investment Companies in India’s NBFC Ecosystem

The management of complex capital structures within India’s large, diversified corporate conglomerates hinges critically on the regulatory treatment of holding entities. Core Investment Companies (CICs) serve as specialized Non-Banking Financial Companies (NBFCs), playing a central role in structuring, holding, and managing investments in group entities.¹ These structures are vital for efficient capital allocation, risk segregation, and consolidation of control across various business lines. Given their importance in controlling vast corporate groups, CICs are subjected to specialized prudential oversight by the Reserve Bank of India (RBI) through the Master Direction – Core Investment Companies (Reserve Bank) Directions, 2016 (CIC Directions).² This regulatory framework aims to prevent systemic risk that could arise from highly leveraged or opaque holding structures.

However, the architecture of CIC regulation relies heavily on mechanical, balance-sheet-based classification tests. Specifically, classification requires satisfying two distinct, quantitative thresholds: the general NBFC Principal Business Criteria (PBC), widely known as the 50-50 Test, and the specialized CIC structural requirements, termed the 90-60 Criteria.³ The simultaneous application and interpretation of these dual criteria introduce significant legal ambiguities and compliance friction, often leading to the unintentional classification of purely operational holding companies as financial entities.

This article undertakes an expert analysis of these regulatory ambiguities, focusing on the unresolved definitional conflict between the RBI’s primary directions and its interpretive guidance. Furthermore, the analysis details the concrete consequences of CIC classification, particularly concerning mandated prudential norms, limitations on corporate financing flexibility, and the imposition of severe cross-border investment barriers. The resulting framework demands rigorous strategic navigation from corporate entities seeking optimal, compliant capital structures in India.

II. The Dual Threshold Conundrum: Analyzing Regulatory Ambiguities in CIC Definition

The process of classifying a holding company as a CIC involves navigating a two-part definitional gateway. The sequence and mandatory nature of these thresholds constitute the primary regulatory ambiguity facing practitioners today.⁴

2.1 The Foundational 50-50 Principal Business Criteria (PBC) for NBFCs

The prerequisite for any company to fall under the regulatory purview of the RBI as an NBFC is the satisfaction of the PBC.⁵ The purpose of this test is to ensure that only those companies predominantly engaged in financial activities—rather than industrial, agricultural, or trading activities—are subjected to financial sector regulation.³ The PBC, or the 50-50 Test, mandates two conditions, both based on the company’s last audited balance sheet ⁶:

1. Asset Test: Financial Assets must constitute more than 50% of the company's Total Assets.⁷

2. Income Test: Income derived from Financial Assets must constitute more than 50% of the company's Gross Income.⁸

An entity that satisfies both of these quantitative conditions is deemed an NBFC and is required to seek registration with the RBI.

2.2 The Specialized 90-60 Structural Criteria for CICs

A Core Investment Company is specifically categorized as an NBFC whose primary business is the acquisition of shares and securities, provided it meets highly restrictive structural conditions.¹⁰ These conditions confine the CIC almost exclusively to the role of a holding and financing entity for its group entities:

1. Asset Holding Threshold (90%): A minimum of 90% of the company’s net assets must be held as investments. These investments are specifically limited to equity shares, preference shares, bonds, debentures, debt instruments, or loans extended solely to group companies.¹¹ The remaining 10% of net assets may include operational fixed assets or real estate but must exclude financial investments or loans to non-group entities.¹²

2. Equity Investment Threshold (60%): Within the 90% mandated investments, equity shares (including instruments compulsorily convertible into equity shares within 10 years) and units of Infrastructure Investment Trusts (InvITs) held only as a sponsor must represent no less than 60% of the net assets.¹³

3. Trading Restrictions: The CIC is strictly barred from actively trading in its investments in group companies. The only permitted exception is a block sale conducted for the express purpose of dilution or disinvestment.¹⁴

4. Financial Activity Limitations: Beyond holding investments, the CIC’s financial activities are curtailed to a narrow range, including investment in bank deposits, money market instruments, government securities, providing loans to group companies, and issuing guarantees on their behalf.¹⁵

2.3 The Sequencing Conflict: Ambiguity and Prevailing Legal Consensus

A fundamental regulatory ambiguity arises from the definition’s syntax, generating persistent interpretive uncertainty for corporate counsel and auditors.¹⁶ The CIC Directions state explicitly that they apply to "every NBFC" carrying on the business of acquisition of shares and securities.¹⁷ This literal drafting suggests a sequencing conflict: a company must first satisfy the general 50-50 PBC to qualify as an NBFC, and only then would the specialized 90-60 Criteria determine if it is a CIC.¹⁸

This statutory interpretation, however, is complicated by the RBI’s subsequent guidance. The Frequently Asked Questions (FAQs) on Core Investment Companies historically offered a differing perspective, clarifying that "CICs need not meet the PBC for NBFCs".¹⁹ This FAQ position implies that the specialized 90-60 structural test alone could be sufficient to classify an entity as a CIC, regardless of whether its income streams meet the 50-50 threshold.²⁰

The conflict rests between the explicit wording of the primary binding regulation (the Master Directions) and the less formal interpretive guidance (the FAQs).²¹ If the FAQ interpretation prevails, holding companies with substantive operating income (and thus a failure to meet the 50% income test) could still be mechanically pulled into the CIC framework solely based on their subsidiary relationships.²² The regulatory objective of the PBC confining RBI oversight to predominantly financial entities—would be undermined, potentially expanding the CIC framework beyond its intended scope.²³

Despite the FAQ clarity, the prevailing consensus among legal practitioners and compliance professionals remains cautious. They often advise that satisfying the 50-50 Test is still maintained as a prerequisite for an entity to establish NBFC status, and consequently, CIC status, thereby adhering to the stricter interpretation of the Master Direction’s text.²⁴This lingering interpretational uncertainty demands legislative harmonization by the RBI to provide clarity on the definitional hierarchy.

Table 1 provides a comparison of these foundational criteria:

Table 1: Comparison of NBFC Principal Business Criteria (PBC) and CIC Structural Criteria

Criteria	NBFC 50-50 Test (PBC)	CIC 90-60 Test
Purpose	General NBFC Classification	Specialized Holding Company Classification
Asset Threshold	Financial Assets > 50% of Total Assets 25	Investments in Group Companies 90% of Net Assets
Income Threshold	Income from Financial Assets > 50% of Gross Income 26	Equity Investments in Group Companies 60% of Net Assets
Regulatory Conflict	Ambiguous Prerequisite for CIC Status 27	Structural Definition (May supersede PBC according to FAQs) 28

2.4 Registration Status and Systemic Importance

Not all CICs are required to register with the RBI. Registration under Section 45-IA of the RBI Act, 1934, is conditional upon two factors: asset size and access to public funds. This distinction creates two categories of entities:

• Unregistered CICs: These include entities whose asset size is below ₹100 crore, irrespective of their access to public funds, and those entities with assets above ₹100 crore but which do not access public funds.²⁹ Unregistered CICs are still permitted to issue guarantees on behalf of group entities, provided they utilize only their own funds and not public funds to discharge any resultant liability

• Registered CICs (Systemically Important): Companies with an asset size of ₹100 crore or more and access to public funds must mandatorily register with the RBI and are consequently classified as systemically important (CIC-ND-SI).¹ These registered entities are subject to the comprehensive prudential and governance norms detailed in the subsequent sections.

III. The Predicament of Inadvertent Classification and Operational Impact

The objective, mechanical nature of the 50-50 and 90-60 quantitative tests means that a company's regulatory classification is determined purely by the numerical composition of its assets and income as reflected in its last audited balance sheet, often leading to unintended regulatory capture.

3.1 Unintentional Classification in Operational Structures

The reliance on objective balance-sheet metrics poses a significant risk for holding companies established primarily for commercial or operational management, rather than financial intermediation. Even temporary holdings or certain inter-group transactions occurring near the financial year-end can mechanically shift the required ratios. For instance, a temporary liquidity surplus invested in group securities or a large operational loan advanced to a subsidiary at the end of the year could inadvertently trigger the NBFC 50-50 test and the subsequent 90-60 CIC test, regardless of the holding company’s overarching commercial intent.

Once these thresholds are breached, the compliance obligations become immediate and stringent. Auditors are mandated to report such non-compliance directly to the RBI. This mandatory reporting effectively compels the company to immediately seek registration and comply with the continuous periodic filings and prudential norms applicable to systemically important CICs.

3.2 Case Study: The Infrastructure Sector and SPV Governance

The infrastructure sector offers a clear and recurrent example of how structural necessity can lead to accidental CIC classification. Infrastructure developers typically employ a sectoral practice involving the execution of projects through separately incorporated Special Purpose Vehicles (SPVs). This structure is often mandated by government tender requirements, creating a practical necessity for the parent/holding company to sponsor and hold multiple SPVs.

The holding company's balance sheet inevitably reflects this structure through significant holdings of equity and provision of inter-group loans to the SPVs. Although the parent's core business purpose is operational infrastructure delivery, the sheer volume and composition of these holdings mechanically satisfy the RBI’s CIC asset and income thresholds, thus triggering unintended regulation.

The imposition of strict financial sector regulations, which are designed for prudent lending and financial institutions, upon an operational developer company creates considerable economic friction and regulatory overreach. Project financing in sectors like infrastructure relies on the optimal use of leverage and flexible capital structures to manage long gestation periods and high capital costs. The sudden imposition of constraints such as the 2.5 times leverage cap or rigid Adjusted Net Worth (ANW) requirements significantly interferes with core commercial operations, imposing unnecessary hurdles and delays. This elevates investment risk and can potentially deter capital inflows into critical infrastructure projects where complex, layered holding structures are often unavoidable for efficient project execution.¹¹ The mechanical application of the structural test, therefore, risks misaligning prudential regulatory goals with broader economic development imperatives.

IV. Prudential Norms and Financial Structuring Implications for Registered CICs

Once an entity is classified and registered as a CIC, it faces a suite of stringent prudential norms that materially restrict its financial flexibility, particularly regarding leverage, capital structure, and governance compared to conventional corporate holding companies.

4.1 Capital Structure Constraints and Investment Capacity

Registered CICs must adhere to strict requirements concerning capital adequacy, risk weighting, and leverage.

Risk Adequacy and Investment Ceiling

Registered CICs are required to maintain their Adjusted Net Worth (ANW) at a minimum of 30% against the aggregate sum of risk-weighted assets and risk-adjusted off-balance sheet items. This requirement establishes a strict limit on asset expansion. Specifically, this 30% minimum translates directly into a maximum allowed investment capacity of approximately 3.3 times the ANW. Furthermore, the specific risk weightings applied to assets vary—high-risk instruments like equity and private debt often carry a 1:1 weightage, while sovereign bonds and cash equivalents receive zero weightage.² This variance means that the actual investment ceiling is intrinsically linked to the portfolio composition, thereby constraining the flexibility of strategic capital allocation within the group.

Leverage Cap and Financing Restriction

The constraints on borrowing are particularly severe. Registered CICs cannot borrow in excess of 2.5 times their Adjusted Net Worth. This strict debt-to-equity ratio restriction substantially limits the use of leverage as a capital formation tool.

The impact on tax efficiency is profound. Conventional corporate financing models often utilize inter-group debt (loans or debentures) to optimize tax liabilities, as interest paid on debt is typically tax-deductible. The regulatory environment for CICs, however, eliminates this flexibility. The stringent leverage cap, coupled with the explicit prohibition of shareholder loans, forces the company to rely more heavily on fresh equity financing or complex, compliant debt instruments. The result is a materially less flexible and less tax-efficient capital structure for the entire conglomerate compared to what a conventional, unregulated corporate structure would afford. This increases the effective cost of group capital, potentially making large-scale funding less efficient.

Table 2: Key Prudential Norms and Leverage Constraints for Registered CICs

Prudential Norm	Requirement	Implication for Investment
Risk Adequacy Ratio	Adjusted Net Worth (ANW) $\ge$ 30% of Risk-Weighted Assets	Limits aggregate investment capacity to 3.3x ANW
Leverage Cap	Borrowing Cap $\le$ 2.5x Adjusted Net Worth (ANW)	Eliminates flexible, tax-efficient debt/equity structures
Financing Restriction	Shareholder Loans Prohibited	Forces reliance on compliant debt instruments or fresh equity

4.2 Structural Restrictions and De-leveraging of Conglomerates

The RBI has implemented recent guidelines aimed at simplifying and de-leveraging complex corporate group structures, particularly those involving multiple CICs. These structural restrictions directly address the risk of systemic instability arising from layered lending practices.

Layering Restriction

To curtail complexity and enhance transparency, the number of CIC layers within a corporate group (including the parent CIC) has been restricted to a maximum of two. This rule was introduced to remove the prior exemption enjoyed by NBFCs under the Companies Act, 2013, which had inadvertently facilitated the proliferation of multiple, opaque layers of CICs within large groups.

Cross-Investment Deduction

A crucial measure to prevent "multiple gearing" (the practice of borrowing against capital invested in an underlying CIC, which then borrows further against that capital) has also been introduced. The RBI mandates that when computing the Adjusted Net Worth (ANW) of an investing CIC, any direct or indirect capital contribution made by it in another group CIC must be deducted from the ANW, to the extent that such amount exceeds 10% of the Owned Funds of the investing CIC.¹³ This measure strategically targets the internal architecture of the conglomerate, directly mitigating systemic leverage risk by forcing simplification and reducing the scope for compounding debt across internal layers.

4.3 Governance and Control

The regulatory regime also imposes elevated governance oversight. Any significant change in control, or any shareholding modification that exceeds the threshold of 26%, requires explicit prior approval from the RBI.² This level of oversight significantly impacts investor exit strategies and the marketability of shares, introducing regulatory complexity and potential delays in major corporate restructuring or mergers and acquisitions.

V. Navigating Cross-Border Investment: Policy Inconsistencies and Compliance Rigour

The classification of a holding entity as a CIC creates substantial policy inconsistencies in cross-border capital flow regulation, affecting both capital entry (FDI) and capital exit (ODI).

5.1 Foreign Direct Investment (FDI) Inconsistency (Entry Barrier)India’s foreign investment policy exhibits a notable paradox when differentiating between categories of regulated financial entities

• Treatment of Registered NBFCs: Foreign investment into Non-Banking Financial Companies that are registered with the RBI is generally permitted up to 100% under the automatic route. This route requires no prior Government approval, recognizing that these entities are already subject to comprehensive prudential regulation.

• Treatment of CICs (Registered and Unregistered): Conversely, all CICs—regardless of whether they are registered and systemically important or unregistered—are explicitly subject to the prior Government approval route. This requirement originates from earlier policy frameworks designed to screen investing companies and prevent indirect investment into sectors otherwise prohibited to foreign capital.

The requirement for registered CICs to seek government approval, despite being under rigorous RBI prudential oversight, creates a pronounced regulatory paradox. The principle guiding the liberalization of FDI was to grant the Automatic Route to all activities regulated by a financial sector regulator, recognizing that sector-specific regulatory safeguards already exist. By retaining the prior government approval mandate for registered CICs, the policy undermines this liberalization goal, effectively imposing an unnecessary friction point on capital entry. This inconsistency increases the perceived risk and time horizon for foreign investors, penalizing the choice of a fully regulated and compliant structure.

5.2 Overseas Direct Investment (ODI) Compliance (Exit/Expansion Barrier)

When a CIC seeks to undertake overseas expansion or direct investment  in a foreign entity engaged in financial services activity, the regulatory requirements become complex and highly stringent, governed by the Foreign Exchange Management (Overseas Investment) Rules, 2022 (FEMA/OI Rules).

Compliance Path Based on Foreign Entity Activity

The entire compliance path whether requiring prior approval or post-facto reporting is dictated by whether the foreign entity is engaged in "financial services activity". A foreign entity is deemed to be carrying on financial services activity if its operations are of a kind that would require mandatory registration or formal regulation if undertaken in India.

• Investment in Financial Sector: Where the foreign entity is engaged in financial services, Mandatory Prior Approval from the RBI is required. A crucial regulatory gatekeeper mechanism is enforced here: unregistered CICs cannot seek this approval directly. They must first obtain a Certificate of Registration (CoR) and will then be treated as regulated CICs for the purpose of the investment application. This effectively uses the ODI mechanism as leverage to bring large, previously unregulated unregistered CICs under the RBI’s prudential supervision if they venture into international financial services.

• Investment in Non-Financial Sector: If the foreign entity operates in the non-financial sector, no prior approval is necessary, even for registered CICs. Compliance is limited to mandatory Post-facto Reporting to the concerned Regional Office of the RBI within 30 days in the prescribed form. Unregistered CICs are exempt from the requirement to register for this type of investment but must still comply with general FEMA/OI reporting obligations.

Table 3 summarizes the compliance path for cross-border investments:

Table 3: Compliance Path for CIC Overseas Direct Investment

CIC Registration Status	Foreign Entity Activity	Mandatory Requirement
Registered CIC	Financial Sector	Mandatory Prior RBI Approval 2
Registered CIC	Non-Financial Sector	Post-facto Reporting within 30 days 2
Unregistered CIC	Financial Sector	Must first obtain RBI CoR; treated as Registered CIC 2
Unregistered CIC	Non-Financial Sector	Exempt from registration, but subject to FEMA/OI reporting 2

Stringent Eligibility Metrics

Irrespective of the approval route, CICs seeking to invest overseas must meet rigorous financial eligibility criteria designed to ensure capital flight is only undertaken by financially sound entities with strong asset quality.²

• Profitability Track Record: The Indian entity must demonstrate that it has recorded net profits continuously during the preceding three financial years prior to the date of the intended investment.²

• Asset Quality: The Net Non-Performing Assets (NNPA) level of the CIC must not exceed 1% of its net advances as of the last audited balance sheet date.²

• Capital Adequacy: The Adjusted Net Worth must be maintained at no less than 30% of its risk-weighted assets post-investment.²

• Quantitative Limits: Total overseas investment is capped at 400% of the Owned Funds of the CIC (the overall limit). A more stringent limit applies to investments in the financial sector, which cannot exceed 200% of its Owned Funds.²

VI. Strategic Mitigation and Structural Alternatives for ComplianceTo manage or preempt the significant financial constraints and regulatory hurdles associated with CIC classification, corporate groups employ several proactive structuring and relief strategies.

6.1 The Temporary Relief Route for Regulatory Transition

For holding companies that find themselves at risk of accidental CIC classification due to temporary balance sheet fluctuations, the RBI provides a crucial temporary relief mechanism: the application for exemption from mandatory registration.²

This pathway requires the holding company to submit a formal application to the RBI, outlining a clear and definitive plan to reorganize its operations.² The explicit goal of the plan must be to restructure the company such that it can qualify as an 'unregistered CIC' typically by falling below the ₹100 crore asset threshold or divesting non-group financial assets to meet the 90-60 criteria without public funds access.² This mechanism provides domestic holding companies with essential time and regulatory flexibility to restructure their financial position without immediate penalization, a transitional measure not generally extended to other types of NBFCs.²

6.2 Proactive Structuring: Deliberately Failing the 50-50 PBC

One of the most effective strategies for corporate holding companies whose intent is purely operational, rather than financial, is to ensure the company deliberately fails the foundational 50-50 Principal Business Criteria.² By failing this prerequisite test, the entity never acquires the status of an NBFC, thereby staying entirely outside the purview of the CIC Directions.

This avoidance can be achieved through two primary mechanisms:

1. Leveraging Operational Income: The holding company can strategically increase its non-financial income by routing operational contracts, management fees, or comprehensive service arrangements through the parent entity to swell its gross income from non-financial activities.² This elevation of operational income prevents the company from meeting the 50% income test.²

2. Maintaining Non-Financial Assets: The holding company can strategically maintain or acquire non-financial fixed assets, such as real estate, operational facilities, or land parcels.² By swelling the non-financial asset base, the company ensures that its financial assets remain below the 50% threshold of total assets, thereby successfully preventing NBFC classification.²

6.3 Leveraging Limited Liability Partnerships (LLP) as Holding VehiclesStructuring project vehicles or intermediate holding entities as Limited Liability Partnerships (LLPs) instead of conventional companies presents a route for regulatory arbitrage regarding CIC classification.² Since CIC regulations are explicitly directed at "companies" incorporated under the Companies Act, LLPs are statutorily excluded from the CIC framework.²

Furthermore, LLPs generally offer significant tax advantages, as profits distributed to partners are often tax-free, unlike dividends distributed by companies to shareholders, which may be taxable.²⁰

However, this structural mitigation strategy is fraught with regulatory and practical friction:

1. Corporate Law Hurdles: Despite the legal loophole in RBI regulation, Registrars of Companies have historically demonstrated reluctance in permitting LLPs to conduct financial services business or act as pure investment holding vehicles.² This resistance appears to stem from a concern regarding the creation of large, unregulated pools of investment capital, which runs counter to the spirit of financial regulation.¹⁹

2. FDI Constraints: The use of LLPs is also complicated by Foreign Direct Investment policy. While FDI is generally permitted in LLPs under the automatic route, this permission is strictly limited to sectors where 100% FDI is allowed and, crucially, where there are no FDI-linked performance conditions.² This complex interplay limits the utility of the LLP structure for large, foreign-backed, capital-intensive ventures that might necessitate specific performance metrics or sectoral compliance.²¹

VII. Conclusion: Policy Synthesis and Recommendations for Regulatory Rationalization

The regulatory framework governing Core Investment Companies in India is defined by a necessary tension: the imperative to maintain financial stability through stringent prudential norms against the need to support efficient corporate structuring and capital formation in the real economy. While the RBI has successfully mitigated systemic risk by imposing constraints such as the two-layer restriction, the 30% ANW requirement, and the 2.5 times leverage cap ², the framework suffers from critical ambiguities and policy inconsistencies that impose unnecessary compliance burdens and investment barriers.

The persistent uncertainty surrounding the sequencing of the 50-50 Principal Business Criteria and the 90-60 CIC Structural Criteria is the central source of friction. The divergence between the text of the Master Direction, which implies the PBC is a prerequisite, and the FAQs, which suggest the structural test is sufficient, leaves holding companies and their counsel in a state of continuous legal exposure.² This forces conservative compliance that may not reflect the true commercial nature of the holding company.

Furthermore, the inconsistency in the FDI regime, which subjects already RBI-registered and regulated CICs to the cumbersome Government Approval route—in stark contrast to other NBFCs—actively penalizes transparency and compliance.² This policy paradox unnecessarily deters foreign capital entry into structures that are otherwise designed for prudential safety.

Based on this analysis, the following policy recommendations are synthesized to rationalize the CIC framework:

1. Formal Resolution of the Classification Hierarchy: The RBI must formally amend the Master Direction – Core Investment Companies (Reserve Bank) Directions, 2016, to unequivocally align the statutory text with the interpretive guidance. If the intent is for the 90-60 structural criteria to suffice for CIC classification, this must be explicitly stated in the binding regulations, thereby eliminating the ambiguity of whether the 50-50 PBC remains a prerequisite.

2. Rationalization of the FDI Regime: The policy inconsistency mandating the prior Government Approval route for registered CICs must be immediately eliminated. Registered CICs, subject to comprehensive RBI oversight, should be granted access to the 100% Automatic Route for FDI, consistent with other systemically important NBFCs. This alignment is necessary to eliminate the regulatory deterrent currently placed upon foreign investment into prudentially regulated holding structures.

3. Introduction of Sector-Specific Exemptions: To prevent the unintentional imposition of financial sector norms on legitimate operational holding companies—particularly evident in the infrastructure sector—the RBI should explore introducing targeted exemptions or revised thresholds. These exemptions could apply to companies whose dominant income stream and capital utilization are demonstrably tied to non-financial operational assets, even if their balance sheets temporarily reflect high inter-group financial holdings required for operational efficiency.² This would ensure that the prudential framework remains focused on financial intermediation risks without impeding capital formation in key commercial sectors.

References

1. RBI Guidelines for Core Investment Company (CIC) Compliance - RegisterKaro, accessed November 13, 2025, https://www.registerkaro.in/post/rbi-guidelines-for-core-investment-company

2. Non-Banking Financial Company (NBFC) - Reserve Bank of India, accessed November 13, 2025, https://www.rbi.org.in/commonman/english/scripts/FAQs.aspx?Id=1167

3. Investing in Indian infrastructure companies: The recurring NBFC/CIC classification issue, accessed November 13, 2025, https://trilegal.com/magazine/investing-in-indian-infrastructure-companies-recurring-nbfc-cic-classification-issue-insights-issue-12.html

4. May 08, 2025 - Core Investment Companies - Reserve Bank of India, accessed November 13, 2025, https://www.rbi.org.in/commonman/english/scripts/FAQs.aspx?Id=836

5. Master Direction - Core Investment Companies (Reserve Bank) Directions, 2016 | Lawrbit, accessed November 13, 2025, https://www.lawrbit.com/wp-content/uploads/2021/05/Master-Direction-Core-Investment-Companies-Reserve-Bank-Directions-2016.pdf

6. CIC Club: First Rule, Are We Even an NBFC? - DSK Legal, accessed November 13, 2025, https://dsklegal.com/cic-club-first-rule-are-we-even-an-nbfc/

7. Reserve Bank of India - Master Directions - NET, accessed November 13, 2025, https://avantiscdnprodstorage.blob.core.windows.net/legalupdatedocs/42283/RBI-issued-a-notification-regarding-an-update-in-the-Master-Direction-Core-Investment-Companies-Reserve-Bank-Directions-2016-May052025.pdf

8. Core Investment Company - MUDS Management and Consulting, accessed November 13, 2025, https://muds.co.in/core-investment-company/

9. How to Open an SPV in India? Process, Compliance, and Strategy, accessed November 13, 2025, https://www.3ecpa.co.in/blog/how-to-open-an-spv-in-india-process-compliance-and-strategy/

10. NBFC CIC Classification Issue - Maheshwari & Co., accessed November 13, 2025, https://www.maheshwariandco.com/blog/nbfc-cic-classification-issue/

11. Guidelines on Core Investment Companies (CIC) By RBI - Taxmann, accessed November 13, 2025, https://www.taxmann.com/research/fema-banking-insurance/top-story/105010000000018451/guidelines-on-core-investment-companies-cic-by-rbi-experts-opinion

12. RBI issues revised guidelines for core investment companies - Argus Partners, accessed November 13, 2025, https://www.argus-p.com/updates/updates/rbi-issues-revised-guidelines-for-core-investment-companies/

13. RESERVE BANK OF INDIA DEPARTMENT OF REGULATION CENTRAL OFFICE, 2ND FLOOR, MAIN OFFICE BUILDING, SHAHID BHAGAT SINGH MARG, FORT, - CAalley.com, accessed November 13, 2025, https://www.caalley.com/rbi_mc_md_24/39MD440D125D51C2451295A5CA7D45EF09B9.pdf

14. fdi-policycircular-2020-28october2020.pdf - Ministry of Food Processing Industries, accessed November 13, 2025, https://www.mofpi.gov.in/sites/default/files/fdi-policycircular-2020-28october2020.pdf

15. 2024 Investment Climate Statements: Sri Lanka - U.S. Department of State, accessed November 13, 2025, https://www.state.gov/reports/2024-investment-climate-statements/srilanka/

16. Revised overseas investment guidelines | EY - India, accessed November 13, 2025, https://www.ey.com/en_in/technical/alerts-hub/2022/08/revised-overseas-investment-guidelines

17. Comprehensive Guide to Overseas Direct Investment (ODI) – Key Statistics | Regulations | Insights - Taxmann, accessed November 13, 2025, https://www.taxmann.com/post/blog/comprehensive-guide-to-overseas-direct-investment-odi

18. Holding Vehicle -Company or an LLP? - Part 1 | lawstreetindia.com, accessed November 13, 2025, https://lsi-old.lawstreetindia.com/experts/column?sid=261

19. FDI in Limited Liability Partnership (LLP) | LLP Registration - BC Shetty Co, accessed November 13, 2025, https://bcshettyco.com/fdi-in-limited-liability-partnership.php

20. Foreign Direct Investment (FDI) in Limited Liability Partnership (LLP) - VJM Global, accessed November 13, 2025, https://www.vjmglobal.com/blog/foreign-direct-investment-fdi-ilimited-liability-partnership-llp