ESOP Pool Size Calculation: Benchmark, Formula, Examples

An ESOP pool is the block of fully diluted equity a company sets aside for current and future employee stock options, usually expressed as a percentage of fully diluted share capital. Getting this number right matters because it is set once at a term sheet stage but compounds through every future funding round. Founders who accept an investor’s requested percentage without running the underlying share count often find they gave away more equity than the number on paper suggested. This article works through the calculation, the formula behind it, current Indian benchmarks by funding stage, and worked examples so the next pool size decision rests on arithmetic rather than a rule of thumb.

What is the formula for calculating ESOP pool size?

To create a pool that equals a target percentage (P) of the fully diluted capitalisation after the pool exists, on a pre money basis: Pool shares = Existing fully diluted shares x [P / (1 – P)]. For a 10 percent pool, the factor is 0.10/0.90, or one ninth of existing shares. Add the pool shares to existing shares to get the new fully diluted total, and the pool now sits at exactly P percent (Treelife cap table modelling practice).

What is an ESOP pool and why does the sizing method matter?

An ESOP pool is a reserved, unallocated block of shares on the cap table, carved out for an Employee Stock Option Scheme (ESOS) so the company can grant options to employees without a fresh round of shareholder approval each time. The pool sits as a separate line item in the fully diluted cap table even before a single option is granted, because investors and later buyers price the company on a fully diluted basis that already assumes the pool will eventually be exercised (Section 62(1)(b), Companies Act 2013).

The mechanics of setting up the pool, board and shareholder approvals, and trust structure are a separate question from sizing. Treelife has covered the creation process in how to create an ESOP pool, and scheme design, vesting and taxation in ESOP scheme design in Indian startup tax. This article is only about the number: how it is calculated, what drives it, and what it costs the founder in real shares.

The sizing method matters because two pools carrying the identical headline percentage can leave founders with different final ownership, depending on whether the pool is created before or after the investor’s shares are issued, and whether it was sized off a benchmark or an actual hiring plan. Both variables are explained below.

How much should your ESOP pool be at each funding stage?

Indian startups typically reserve an ESOP pool between 8 and 20 percent of fully diluted equity, rising as the company moves from pre seed through to a pre IPO refresh, since later stage hiring plans are larger and more senior. There is no statutory minimum or maximum: the percentage is a negotiated commercial term, driven by headcount plan and investor portfolio norms, not a legal requirement.

Table 1: ESOP pool size benchmark by funding stage (India)

Funding stage	Typical pool size (fully diluted)	Primary driver	What investors typically ask for
Pre seed / seed	8 to 12 percent	First 5 to 10 key hires, founding team retention	Pool created pre money, before their investment
Series A	12 to 15 percent	Building out functional leadership (engineering, sales, finance)	Pool topped up to 15 percent as a closing condition
Series B	15 to 18 percent	Scaling middle management, specialist hires	Refresh calculated off the new post money base
Series C and beyond / pre IPO	15 to 20 percent	Senior leadership hires, retention grants, listing readiness	Refresh sized against a rolling three year hiring plan

A pool set too small forces a mid cycle top up on terms the company does not control, usually right when it needs investor goodwill for something else. A pool set too large sits on the cap table as unallocated dilution that nobody benefits from until it is granted. Both failure modes are avoidable with the calculation method in the next two sections.

How does the Indian benchmark compare with US and European pools?

Indian ESOP pools track closer to European norms at seed and converge towards US ranges from Series B onward, since later Indian rounds increasingly involve the same global investors who set pool expectations abroad.

Table 1a: stage wise pool size, India versus global norms (indicative, unverified market ranges, benchmark before relying on the exact figures)

Stage	India	United States	Europe
Seed	8 to 12 percent	10 to 15 percent	10 percent
Series A	12 to 15 percent	15 percent	10 to 12 percent
Series B	15 to 18 percent	15 to 20 percent	12 to 15 percent
Series D / growth	15 to 20 percent	20 to 25 percent	15 percent

A founder raising from a mixed India and international syndicate should ask which market’s convention an investor’s number is drawn from, since a US-benchmarked ask typically runs larger than a European one.

What is the actual formula behind ESOP pool size calculation?

The core formula converts a target pool percentage into an actual number of shares, and it is simpler than most cap table tools make it look. If a company wants the pool to equal P percent of the fully diluted capitalisation once the pool exists, and it currently has N fully diluted shares outstanding (no pool yet), the formula is:

Pool shares = N x [P / (1 – P)]

The new fully diluted total becomes N / (1 – P), and dividing pool shares by this new total returns exactly P, which is the check every calculation should pass before it goes into a term sheet.

Table 2: pool shares required for common target percentages (per 9,000,000 existing shares)

Target pool % (P)	Multiplier [P / (1-P)]	Pool shares needed	New fully diluted total
10 percent	0.1111	1,000,000	10,000,000
12 percent	0.1364	1,227,273	10,227,273
15 percent	0.1765	1,588,235	10,588,235
20 percent	0.25	2,250,000	11,250,000

The pattern to notice: the multiplier grows faster than the percentage itself. Moving the target from 10 to 20 percent does not double the pool shares needed relative to the smaller base, it more than doubles the founder’s dilution, because the denominator is shrinking founders’ own share at the same time. This is the arithmetic reason investors negotiate pool size as hard as they negotiate valuation.

Worked example: creating a 10 percent ESOP pool pre money

A Series A company has 9,000,000 fully diluted shares outstanding, held by founders and a seed investor, with no ESOP pool yet. The incoming investor requires a 10 percent pool to exist before their investment lands, calculated pre money, meaning the dilution falls entirely on existing shareholders and not the new investor.

• Existing fully diluted shares (N) = 9,000,000
• Target pool percentage (P) = 10 percent
• Pool shares = 9,000,000 x (0.10 / 0.90) = 1,000,000
• New fully diluted total = 9,000,000 + 1,000,000 = 10,000,000
• Verification: 1,000,000 / 10,000,000 = 10 percent, matches target

Existing shareholders, who held 100 percent of 9,000,000 shares before the pool, now hold 9,000,000 out of 10,000,000, or 90 percent, having absorbed the full 10 percent dilution themselves. The investor’s own shares are issued after this, against the enlarged 10,000,000 share base, which is what “pre money pool creation” means in practice.

Why does a pool created pre money cost founders more than the same pool created post money?

A pool created pre money is added to the cap table before the investor’s shares are issued, so only existing shareholders absorb the dilution, while the investor’s ownership is fully protected. A pool created post money is added after the investor’s shares are issued, so the investor also absorbs a share of the dilution. The difference is typically 2 to 4 percentage points of founder ownership, and depends only on timing, not the headline pool percentage.

This single variable, whether the pool sits before or after the investment in the waterfall, is frequently glossed over because both versions get described identically as “a 15 percent option pool.” The worked comparison below shows why founders should ask which one is on the table.

Table 3: pre money pool creation versus post money pool creation (same 15 percent target, same 20 percent investor ask)

Step	Pre money pool creation	Post money pool creation
Starting fully diluted shares	9,000,000	9,000,000
Method	Solve simultaneously: founders retain (1 – pool% – investor%) of final total	Investor shares issued first, pool added after on the enlarged base
Final fully diluted total	13,846,154	13,235,294
Founder final ownership	65.0 percent	68.0 percent
Who absorbed the pool dilution	Founders and existing shareholders only	Founders and the new investor, pro rata

The pre money method solves three unknowns together: total fully diluted shares after the round = existing shares / (1 – pool% – investor%), so 9,000,000 / (1 – 0.15 – 0.20) = 9,000,000 / 0.65 = 13,846,154. Pool shares = 15 percent of that total, investor shares = 20 percent of that total, and founders retain the remaining 65 percent. In the post money version, investor shares are calculated first off the pre pool base (0.20/0.80 x 9,000,000 = 2,250,000, giving 11,250,000 total), and only then is the pool layered on top of the enlarged 11,250,000 share base (0.15/0.85 x 11,250,000 = 1,985,294), leaving founders at 68.0 percent instead of 65.0 percent.

How do you size an ESOP pool from a hiring plan instead of a benchmark?

A bottom up ESOP pool calculation adds up the equity needed for every planned hire over the next 18 to 24 months, plus a buffer for unplanned hires and retention grants, rather than copying an industry average percentage. This method produces a defensible number in a term sheet negotiation because it is backed by a named hiring plan, not a market convention the investor can push against.

Table 4: bottom up pool sizing example for a 40 person Series A hiring plan

Role band	Planned hires	Average grant (% FD per hire)	Subtotal
VP / director level	3	0.75 percent	2.25 percent
Senior manager / lead	7	0.30 percent	2.10 percent
Mid level (engineering, sales)	20	0.12 percent	2.40 percent
Junior / early career	10	0.05 percent	0.50 percent
Subtotal, planned hires	40		7.25 percent
Buffer for unplanned hires and retention (25 percent of subtotal)			1.81 percent
Recommended pool size			9.06 percent, rounded to 10 percent

A pool sized this way, at roughly 10 percent, sits comfortably inside the Series A benchmark range in Table 1, but the founder now has a hiring plan to point to if the investor pushes for 15 percent instead. Rounding up to a clean 10 percent, rather than 9.06 percent, also leaves room for a modest overshoot in the plan without triggering an immediate top up conversation.

What is a typical individual grant range by seniority band?

The average grant percentages used in Table 4 are drawn from the pool level backwards. Sizing an individual offer works the other way, starting from the candidate’s seniority band and checking the resulting number against the pool’s remaining capacity.

Table 4a: illustrative individual grant range by seniority band (fully diluted, single grant, India)

Seniority band	Typical single grant range (% FD)
Co-founder equivalent hire, joining pre Series A	1.0 to 3.0 percent
VP / director	0.4 to 1.0 percent
Senior manager / team lead	0.15 to 0.4 percent
Mid level individual contributor	0.05 to 0.15 percent
Junior / early career	0.01 to 0.05 percent

These ranges are illustrative, drawn from Treelife’s advisory practice, and vary by sector, city and hiring market pressure. Treat them as a starting point, not a fixed rule, and benchmark against the company’s own recent comparable grants first.

What happens to the pool percentage if it is never refreshed?

The pool’s share count stays fixed once created, but its percentage shrinks automatically every time new shares are issued in a later round, because the pool sits in the denominator without growing alongside it. A pool that is 10 percent at Series A can fall to under 6 percent by Series C purely from later rounds issuing new shares, with no options granted or exercised in between (Treelife cap table modelling across multi round companies).

Table 3a: pool percentage decay without a refresh (1,000,000 pool shares fixed throughout)

Stage	New shares issued this round	Fully diluted total	Pool as % of total
Series A (pool created)	(pool created here)	10,000,000	10.0 percent
Series B	3,000,000	13,000,000	7.7 percent
Series C	4,000,000	17,000,000	5.9 percent

This is why a pool percentage quoted at one round cannot be compared directly to a pool percentage quoted two rounds later without checking whether a refresh happened in between. The refresh formula below is what restores the percentage back to the target.

How is an ESOP pool refresh or top up calculated in a later round?

A pool refresh is calculated the same way as the original creation, except the existing fully diluted base already includes options previously granted, and shares still unallocated in the old pool are subtracted from the new requirement. The formula: Additional pool shares = [Target% / (1 – Target%)] x fully diluted shares excluding the pool, minus shares still unallocated in the existing pool.

For example, if a Series B company has 20,000,000 fully diluted shares excluding its pool, an existing pool with 400,000 shares still unallocated, and wants to refresh to a 15 percent post money target: required pool shares at 15 percent = 20,000,000 x (0.15/0.85) = 3,529,412. Subtracting the 400,000 already unallocated leaves 3,129,412 new shares to add, which is the actual dilution the round needs to absorb, not the full 3,529,412 figure that a naive calculation would suggest.

What does Indian company law actually say about ESOP pool size?

The Companies Act 2013 and the Companies (Share Capital and Debentures) Rules, 2014 govern how a private or unlisted company grants employee stock options, but neither prescribes a minimum or maximum pool size, that figure is left entirely to commercial negotiation between the company and its shareholders. What Rule 12 does require is a minimum one year gap between the grant of an option and its vesting, and specific disclosures in the explanatory statement to the resolution approving the scheme (Rule 12, Companies (Share Capital and Debentures) Rules, 2014).

For listed companies, the Securities and Exchange Board of India (Share Based Employee Benefits and Sweat Equity) Regulations, 2021 govern option schemes, share purchase schemes and stock appreciation rights, again without capping the pool percentage. These regulations were last amended by the Second Amendment Regulations, 2025, effective 2 January 2026, moving sweat equity valuation from a merchant banker to an independent registered valuer, a change to process, not pool size (Securities and Exchange Board of India (Share Based Employee Benefits and Sweat Equity) (Second Amendment) Regulations, 2025). Founders sometimes confuse pool size with the separate statutory cap on sweat equity shares, limited to 15 percent of paid up equity issued in a year and 25 percent at any time under Section 54 of the Companies Act 2013 read with Rule 8 of the Companies (Share Capital and Debentures) Rules, 2014, a cap that applies to sweat equity, not the ESOP pool. Note too that the Corporate Laws (Amendment) Bill, 2026, introduced in the Lok Sabha in March 2026 and still before a Joint Parliamentary Committee, proposes widening Section 62(1)(b) to cover RSUs and SARs alongside ESOPs; it is not yet enacted and does not change the pool sizing calculation, but is worth tracking if the company plans instruments beyond a standard option pool.

The taxation of options once exercised sits outside the pool sizing question and is covered in Treelife’s dedicated guide on ESOP scheme design. Note that the Income-tax Act, 1961 has been replaced by the Income-tax Act, 2025 for income earned from 1 April 2026 onward, so exercises in the current financial year fall under the new Act. The substantive rule, taxing the gap between fair market value and exercise price as salary income at exercise, is unchanged, and the deferred TDS relief for DPIIT recognised eligible startups also continues, but the provisions have been renumbered and secondary commentary is not yet consistent on the exact new section numbers. Confirm the current section references against the gazetted text of the Income-tax Act, 2025 before citing them in scheme documents, rather than relying on the old Section 17(2)(vi) and Section 192(1C) references from the 1961 Act.

How do you negotiate ESOP pool size with an investor?

Negotiate pool size and timing together, not separately: compare the investor’s ask against your bottom up number, and if the gap cannot close on size, move the pool from pre money to post money creation instead, which recovers several points of founder ownership without changing the headline number.

A useful sequence looks like this. First, run the bottom up calculation from Table 4 before the term sheet conversation starts, so the founder walks in with a number, not just an objection. Second, when the investor’s ask is materially higher, ask what it is benchmarked against; it is often a portfolio wide convention or a US style benchmark (see Table 1a) rather than a number tied to this company’s hiring plan, and naming that gap usually opens a real conversation. Third, if the investor will not move on size because it is firm wide policy, shift the negotiation to timing, since a 15 percent pool created post money costs founders 2 to 4 percentage points less than the same pool created pre money, as shown in Table 3.

Whatever number is agreed, it should go into the term sheet as an explicit share count, not only a percentage. A standard clause states that the company shall carve out an option pool equal to a stated percentage of fully diluted share capital immediately after completion of the round, calculated against the capitalisation table annexed between the parties, which removes room for the percentage to be reinterpreted once the round documents are drafted.

See how we structure this negotiation alongside the rest of the round. Read cap table for startups for the founder’s complete guide to keeping the underlying cap table clean enough that this calculation never has to be redone from scratch.

How do you track ESOP pool utilisation once it is created?

Track four numbers every quarter: total pool, cumulative granted, cumulative forfeited or returned, and net available, since net available, not the original pool size, tells the board whether a refresh conversation needs to start.

Table 4b: quarterly ESOP pool tracking template

Metric	What it captures	Why it matters
Total pool (shares)	The pool as last created or refreshed	The fixed reference point for all other metrics
Cumulative granted	Options issued to date, vested and unvested	Shows how fast the pool is being consumed
Forfeited / returned	Unvested options that lapsed on employee departure	Adds back to available capacity, often missed in manual tracking
Net available	Total pool minus granted, plus forfeited	The real remaining capacity for new hires
Utilisation rate	Cumulative granted divided by total pool	The single number the board should watch each quarter

As a working rule, start the refresh conversation once utilisation crosses 70 to 75 percent, since approvals and documentation typically take 4 to 8 weeks, and a pool that runs out mid negotiation is a weaker position than one refreshed ahead of need.

Common mistakes that cost founders time and money

1. Accepting the investor’s percentage without asking pre money or post money. As Table 3 shows, the same headline percentage can differ by several points of real founder ownership depending on where in the round waterfall the pool sits. Always ask which method applies, and for the actual share count, not just the percentage.

2. Copying a benchmark instead of running a hiring plan. A benchmark percentage tells an investor the company is following convention. A bottom up number, built off named roles and headcount, tells the investor the founder has modelled the business, and is far easier to defend in negotiation.

3. Forgetting that granted, unexercised options still count in fully diluted math. Founders sometimes calculate ownership on issued shares only, forgetting that granted but unexercised options sit inside the fully diluted denominator from the moment they are granted, not exercised.

4. Sizing the pool without a vesting and departure policy in place. A pool that looks correctly sized on paper can run out faster than planned without a clear forfeiture mechanism returning unvested options when an employee departs, a gap that shows up only at the next hiring cycle.

5. Treating the pool refresh as a fresh calculation rather than a top up. As shown above, subtracting shares still unallocated in the existing pool before calculating the new requirement avoids a refresh that is larger, and more dilutive, than the company actually needs.

6. Ignoring FEMA implications when the pool includes overseas or NRI hires. An Indian company issuing options to an employee outside India, or a resident who later becomes non-resident, brings the Foreign Exchange Management Act 1999 into play as a foreign investment, requiring a Form ESOP filing with the Reserve Bank of India through the company’s authorised dealer bank under the Foreign Exchange Management (Non-Debt Instruments) Rules, 2019, a step often missed at the pool sizing stage (Foreign Exchange Management Act, 1999; Foreign Exchange Management (Non-Debt Instruments) Rules, 2019).

In the ESOP pool sizing engagements we have run at Treelife

In the ESOP pool sizing engagements we have run at Treelife, the recurring pattern is a founder who has already agreed to a pool percentage in a term sheet before asking how it translates into shares. By the time the calculation reaches us, the pre money versus post money question is usually already settled in the investor’s favour, since the term sheet defaulted to the pre money method as market convention, and not every founder realises they can push back if a hiring plan supports a smaller pool.

One pattern worth flagging: founders raising a bridge round between priced rounds often forget that options granted during the bridge still sit inside the fully diluted base when the next round’s pool refresh is calculated, quietly increasing the refresh requirement beyond what a simple percentage comparison across two term sheets would suggest. We now run the full reconciliation, not just the headline percentage, before any refresh number goes back to the founder, since a mismatch here surfaces exactly when the company can least afford it, mid negotiation with a new investor.

Before your next term sheet, see how a well modelled cap table changes the pool conversation. Read cap table restructuring for startups for the pre-fundraise checklist we use with clients.

FAQs on ESOP Pool Size Calculation

Q: Is ESOP pool size taxable to the company or the employees when it is created?
A: No. Creating the pool is a cap table event, not a taxable one. Tax arises only when an employee exercises a vested option, taxed as a salary perquisite on the gap between fair market value and exercise price, charged under Section 17(2)(vi) of the Income-tax Act, 1961, and continued on the same basis under the renumbered provisions of the Income-tax Act, 2025 for exercises from 1 April 2026 onward.

Q: How much does it cost to get an ESOP pool sized and structured professionally?
A: Advisory fees for pool sizing and scheme design in India are typically structured as a fixed project fee covering the cap table modelling, term sheet review and board resolution drafting, rather than an hourly rate, since the scope is usually well defined upfront.

Q: How long does it take to size and formally create an ESOP pool?
A: The calculation itself takes a few hours once the fully diluted cap table is clean. The formal creation, including board approval and, for private companies, shareholder approval under the company’s articles, typically takes 1 to 2 weeks end to end.

Q: What documents are needed before an ESOP pool size can be calculated?
A: A current fully diluted cap table (all classes of shares, convertible instruments and any existing options), the term sheet or investor’s pool request, and, for a bottom up calculation, a role by role hiring plan for the next 18 to 24 months.

Q: Does an ESOP pool need separate structuring if the company plans to hire outside India?
A: Yes. Options granted to an employee resident outside India, or an Indian resident who later moves abroad, are treated as foreign investment and require a Form ESOP filing with the Reserve Bank of India through the company’s Authorised Dealer bank, a step that should be flagged at the pool sizing stage rather than left until the option is exercised (Foreign Exchange Management Act, 1999; Foreign Exchange Management (Non-Debt Instruments) Rules, 2019).

Q: How should a co-founder’s share of the pool be treated differently from an employee’s?
A: Co-founders typically hold direct equity from incorporation rather than options from the pool, since options are structured for employees joining after the company has meaningful value. A co-founder joining later, or converting from an advisory role, can be granted from the pool, but the calculation should still model this separately from the employee hiring plan.

Q: Does a DPIIT recognised startup get any pool size benefit?
A: DPIIT recognition does not change the pool size calculation, but eligible startups holding a valid Section 80-IAC certificate get deferred TDS on the perquisite value, a relief that ran under Section 192(1C) of the Income-tax Act, 1961 and continues under the renumbered provisions of the Income-tax Act, 2025. This affects employee cash flow at exercise, not the company’s pool sizing decision.

Q: What happens to unallocated pool shares if a funding round falls through?
A: Nothing changes to the pool itself if it was already created on the cap table before the round collapsed. If the pool was only proposed as part of the now-terminated term sheet and never formally created by board resolution, it simply does not come into existence and the fully diluted base reverts to its pre-negotiation figure.

Q: How does an investor verify the ESOP pool size stated in a term sheet is accurate?
A: Investors typically request the fully diluted cap table with the pool shown as a formula, not just a percentage, and re-run the arithmetic against the share count before signing, which is why founders should run the same check first.

Q: What is the difference between an allocated and an unallocated ESOP pool?
A: The allocated portion is shares already granted to specific employees under signed option agreements. The unallocated portion is the remaining pool capacity available for future grants. Both count identically in fully diluted ownership calculations, since both are assumed exercised for valuation purposes.

Q: Can promoters or founders be granted options from the ESOP pool?
A: Under Rule 12(1) of the Companies (Share Capital and Debentures) Rules, 2014, a promoter is excluded from receiving employee stock options, since the scheme is designed for employees who do not already hold a controlling stake. A related case: Regulation 9A, inserted into the SEBI SBEB Regulations by the Amendment Regulations, 2025 (effective 8 September 2025), lets a founder later reclassified as a promoter ahead of an IPO keep exercising options granted at least a year before the draft offer document. This is a listed company IPO readiness provision, separate from the private company pool sizing question this article addresses.

Q: What happens to an employee’s share of the pool if they leave before vesting?
A: Unvested options are typically forfeited on departure and return to the unallocated pool, while vested but unexercised options are usually subject to a defined exercise window, commonly 90 days, set out in the scheme document.

Q: Is a larger ESOP pool always better for attracting senior talent?
A: No. A pool sized above what the hiring plan requires sits as pure dilution with no offsetting benefit until granted, and an oversized pool becomes the founder’s negotiating weakness at the next round, since a subsequent investor expects remaining capacity used before further dilution is requested.

Q: How does ESOP pool size affect valuation in a term sheet negotiation?
A: The pool is typically included inside the pre money valuation for calculation purposes, meaning its dilution is absorbed by existing shareholders rather than reducing the headline pre money number itself, which is why the effective price per share for founders is lower than the quoted pre money valuation would suggest on its own.

Q: Should an Indian startup match global benchmarks if its investors are international?
A: Not automatically. An international investor’s requested percentage is often benchmarked against US or European portfolio norms, which run higher or lower than Indian stage wise practice depending on the market (see Table 1a), so it is worth clarifying which market’s convention is being applied before treating it as the standard number for this round.

Regulatory references

• Section 62(1)(b), Companies Act, 2013 (proposed to be widened by the Corporate Laws (Amendment) Bill, 2026, not yet enacted)
• Rule 12, including Rule 12(1) (promoter exclusion), Companies (Share Capital and Debentures) Rules, 2014
• Section 54, Companies Act, 2013, read with Rule 8, Companies (Share Capital and Debentures) Rules, 2014 (sweat equity cap, distinct from ESOP pool size)
• Securities and Exchange Board of India (Share Based Employee Benefits and Sweat Equity) Regulations, 2021, as amended by the Amendment Regulations, 2025 (Regulation 9A, promoter reclassification carve-out, effective 08/09/2025) and the Second Amendment Regulations, 2025 (effective 02/01/2026)
• Perquisite taxation on ESOP exercise: Section 17(2)(vi), Income-tax Act, 1961, continued under the renumbered Income-tax Act, 2025 (effective 01/04/2026); verify the current section number against the gazetted text
• Deferred TDS for DPIIT recognised eligible startups: Section 192(1C), Income-tax Act, 1961, continued under the renumbered Income-tax Act, 2025
• Foreign Exchange Management Act, 1999, and the Foreign Exchange Management (Non-Debt Instruments) Rules, 2019