Sinha is listed as a minority shareholder while wife Rita Kishore Sinha is a director of SAPHL. Sinha is listed as a minority shareholder while wife Rita Kishore Sinha is a director of SAPHL.

Elected to Rajya Sabha from Bihar in 2014 as a BJP member and considered one of the richest in the House, Ravindra Kishore Sinha, a former journalist who founded the private security service firm SIS or Security and Intelligence Services, heads a group which has two offshore entities.

According to records of the Malta registry, SIS Asia Pacific Holdings Ltd (SAPHL), registered in Malta in 2008, is a subsidiary of SIS. Sinha is listed as a minority shareholder while wife Rita Kishore Sinha is a director of SAPHL. Records show that SIS International Holdings Limited (SIHL), a company incorporated in British Virgin Islands, holds 3,999,999 shares in SAPHL while 1 share is with Ravindra Kishore Sinha.

According to a document dated October 13, 2008, available on the Malta registry, SAPHL’s 1499 ordinary shares of Euro 1 each were transferred from PCL International Holdings Ltd, Malta to SIS International Holdings Ltd, British Virgin Islands. And one ordinary share was transferred by David Marinelli in favour of Ravindra Kishore Sinha. The directors of SAPHL are Malta-based Amicorp Malta Ltd, Amicorp Services Ltd, Ravindra Kishore Sinha and his wife Rita Kishore Sinha. SIHL directors are Sinha, wife Rita Kishore Sinha and son Rituraj Kishore Sinha.

In an affidavit submitted to the Election Commission during his nomination for the Rajya Sabha election in 2014, Ravindra Kishore Sinha made no mention of his and his wife’s association with SAPHL. He did not declare this link to the Rajya Sabha after becoming a member.

But in documents of SIS (India) Limited filed before the Securities and Exchange Board of India (SEBI) on August 4, 2017 – that’s the date mentioned on the final offer document on the SEBI website – Ravindra Kishore Sinha declared his interests in all these companies. The addresses of Sinha (East of Kailash, New Delhi; and Omaxe Forest, Sector-92, NOIDA) and his wife (East of Kailash, New Delhi) at the Malta registry are the same as mentioned in his declaration before the Election Commission.

EXPLAINED: Why the Paradise Papers matter

In the draft red herring prospectus of SIS India Ltd – the DRHP is a preliminary prospectus, a document submitted by a company as part of a public offering of securities – Ravindra Kishore Sinha declared that the SIHL is a “holding company for our international operations”. It was stated that the SAPHL is “currently the holding company of SAHL (SIS Australia Holdings Pty Limited)”. SIS (India) Limited was listed at the Bombay Stock Exchange on August 10, 2017.

The DRHP of the SIS (India) Limited stated: “A decision from the RBI (on multi-layered structures of overseas investments) is currently pending. Given that our holding of our Australian subsidiaries is structured in multiple layers (through intermediate companies incorporated in the British Virgin Islands, Malta and Australia), any adverse decision by the RBI in relation to multi-layered overseas investment structure may require us to re-examine or restructuring our holdings, and may adversely affect our cash flow, dividend income, results of operation and financial condition.”

Response from Ravindra Kishore Sinha:

These companies are indirect 100% subsidiaries of Security and Intelligence Services (India) Limited in which I am a shareholder. I have no direct interest in these companies except to the extent of my shareholding in Security and Intelligence Services (India) Limited. As these companies are indirect subsidiaries of Security and Intelligence Services (India) Limited, I am also a director in these entities. Due to the prevailing regulation in these countries, which require any company to have at least two shareholders, I hold 1 share each in these companies for which the beneficial interest has been declared in favour of Security and Intelligence Services (India) Limited and SIS International Holdings Limited, the 100% shareholders of SIS International Holdings Limited and SIS Asia Pacific Holdings Ltd respectively. These matters have been fully disclosed in the various filings with SEBI as a part of the IPO of Security and Intelligence Services (India) Limited.

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Security and Intelligence Services (India) Limited has a wholly owned subsidiary in Australia, by the name of MSS Security, which is the largest security services company in Australia carrying on a legitimate and reputed business there. We also have several operating businesses in India, incorporated and registered in India, which are market leaders in their own right. These subsidiaries in British Virgin Islands and Malta are the holding companies for the SIS Group’s Australian businesses, all of which are 100% owned by Security and Intelligence Services (India) Limited.

All disclosures required to be made in my personal income tax returns, in respect of my assets, have been made. As mentioned, I have no direct interest in these companies except to the extent of my shareholding in Security and Intelligence Services (India) Limited, which is the holding company for these above named companies.

All necessary permissions and consents required to incorporate these companies in their respective jurisdictions have been obtained. Security and Intelligence Services (India) Limited and its subsidiaries and associate companies have been recently subjected to a rigorous due diligence exercise by three reputed law firms and several reputed merchant bankers as part of its recent IPO and no non-compliance, in respect of permissions and consents required to incorporate these companies, has been noted by any of them as part of their diligence. Security and Intelligence Services (India) Limited and its subsidiaries and associate companies have also been subjected more than once in the past to a rigorous due diligence exercise by reputed law firms and Big 4 accounting firms as part of the private equity investments in Security and Intelligence Services (India) Limited and no non-compliance has been noted during those rounds too insofar as the incorporation of these companies is concerned.

All disclosures required to be made in the affidavit submitted with my nomination for Rajya Sabha elections in 2014 and in my periodic declaration of assets and liabilities in Rajya Sabha as a member of that House have been made. As mentioned, I have no direct interest in these companies except to the extent of my shareholding in Security and Intelligence Services (India) Limited, which is the holding company for these above named companies. Since the 1 share that I hold in these companies is only beneficially held by me on behalf of the respective 100% holding companies, and not in my personal capacity, these have not been declared separately. However, you would note that I have fully declared and disclosed my shareholding in Security and Intelligence Services (India) Limited, which is the 100% holding company for these above-named companies.

It is true that the directors of SIS International Holdings Limited are:

* Ravindra Kishore Sinha, by virtue of my capacity as promoter, Chairman-cum-Managing Director and significant shareholder of Security and Intelligence Services (India) Limited. * Rita Kishore Sinha, by virtue of her capacity as a long standing director of Security and Intelligence Services (India) Limited. * Rituraj Kishore Sinha, by virtue of his capacity as promoter and managing director of Security and Intelligence Services (India) Limited.

All of these directors are representing Security and Intelligence Services (India) Limited and to protect its interests as a 100% shareholder of SIS International Holdings Limited.

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