Untitled Document

Initial Letter Date

Form filed

Market Capitalization

03/22/2012

20-F

$ 16,200 M

Your disclosure on page [xx] indicates that under Indian GAAP, a deferred tax asset is recognized and reassessed at each reporting date based on management's judgment as to  whether their realization is considered reasonably certain. This appears to differ from the  US GAAP requirement that a valuation allowance be recognized when it is more likely  than not that the deferred tax asset will not be realized. Please tell us whether you  consider this difference to be a reconciling item, and if not, tell us why not.