As news of the Enforcement Directorate (ED) action against Anil Ambani has become almost a regular feature in India’s financial headlines, a fresh investigation brings to light a detailed, document-backed complaint that has been in circulation for years, yet has met a wall of institutional silence.
>> NAME-CHANGE MAZE
Documents available with this author show that a chain of electricity companies such as Bombay Suburban Electric Supply Ltd. (BSES), Anil Ambani-led Reliance Energy Ltd (REL), and Reliance Infrastructure Ltd (RInfra) allegedly functioned through falsified incorporation records, serial illegal name changes, and the large-scale siphoning of public funds collected as taxes and duties from millions of Mumbai electricity consumers.
BSES Ltd. was incorporated under the Indian Companies Act, VII of 1913, with its registration dated October 1, 1929, and Corporate Identity Number (CIN) L99999MH1929PLC001530. Despite its century-old lineage, BSES received its Permanent Account Number (PAN) — AAACB2273R — only on April 3, 1996, raising the first question: how did the company operate for 67 years without a formal tax identifier under the Income-tax Act, 1961?
Around 2002, BSES was renamed Reliance Energy Ltd following its acquisition by Anil Ambani’s group. Yet REL retained the same CIN and incorporation date of October 1, 1929, as if it were the same legal entity formed in that year. REL’s own PAN, AADCR1886K, was issued only on January 6, 2006, four years after the acquisition.
REL was subsequently renamed Reliance Infrastructure Ltd on April 28, 2008, through a certificate issued by Deputy Registrar Shriram Motiram Saindane, while retaining the original 1929 CIN.
Parallel entities further deepen the confusion. Records show:
• Reliance Global Ltd, incorporated January 6, 2006 (CIN: U50102MH2006PLC158718), changed its name to REL on June 24, 2008.
• Another Reliance Infrastructure Ltd (CIN: U51909MH2005PLC158349), incorporated December 27, 2005, became Reliance Infraprojects Ltd on February 21, 2008.
The arithmetic of dates produces legal impossibilities. RInfra’s PAN — AACCR7446Q — bears an incorporation date of October 1, 1929, which predates the Income-tax Act, 1961, by more than three decades. The same PAN was generated on June 25, 2004, before the company’s formal existence in 2005.
Additionally, sales tax records obtained through an RTI from the Delhi government (dated August 26, 2010) reveal that M/s Reliance Infrastructure Ltd. held a VAT registration number (07760050591) from as far back as April 20, 1976. The question that follows is unavoidable: what business was a company yet to be incorporated conducting under a tax registration number in 1976?
Corporate lawyers familiar with Registrar of Companies (ROC) procedures, quoted without attribution, state plainly: a name change does not confer the predecessor’s date of incorporation. The legal and financial implications of misrepresenting incorporation timelines, particularly in a regulated sector such as electricity distribution, could include fraudulent utilisation of historical licences, legacy tariff structures, and preferential government agreements that would not have been available to a newly formed entity.
>> DIRECTORIAL OVERLAPS
Adding to the structural suspicion is a web of directorial and managerial overlaps. Anil D. Ambani and Satish Seth appear as directors across multiple entities simultaneously, including BSES Yamuna Power Ltd and BSES Kerala Power Ltd. Ramesh Ganpati Shenoy served as Company Secretary of BSES from 1994 and was later listed as manager/director of Reliance Infrastructure Ltd post-2007.
Corporate lawyers say these overlaps are “a form of misrepresentation” designed to project the appearance of independent, separate companies while functioning as a single consolidated entity. This structure, they argue, allowed the group to “evade tax obligations or circumvent statutory deposits” by ensuring financial flows were difficult to trace across the corporate chain.
Significantly, when the ROC was approached for documents relating to BSES, REL and RInfra, the authority confirmed it had no official records available, and instead forwarded the complainant’s query to RInfra itself, asking the company to supply the relevant documents. The fact that the regulator itself lacked basic incorporation records of companies operating in a critical public-utility sector raises troubling questions about the integrity of regulatory oversight.
>> GHOST POWER SUPPLY?
One of the most operationally specific anomalies involves electricity supply records sourced from Tata Power Company. These records document bulk power deliveries to BSES and REL, even during periods when, according to official corporate records, these entities had already ceased to exist under those names.
GFX 1: ELECTRICITY DELIVERIES (Tata Power Records)
| Period | Units (KWH) | Recipient | |
| April 2005–March 2006 | 3,923,681,327 | BSES | — |
| April 2006–March 2007 | 8,011,745,392 | BSES | |
| April 2007–June 2007 | 1,405,067,198 | BSES | |
| July 2007–March 2008 | 3,534,614,269 | REL | |
| April 2008–March 2009 | 2,973,905,773 | REL | |
| April 2009–March 2010 | 2,724,390,055 | REL | |
| April 2010–March 2011 | 1,270,158,476 | REL | |
| April 2014–March 2015 | 186,914,760 | BSES |
BSES was supposedly replaced by REL in 2002, yet Tata Power records show continued deliveries to BSES through mid-2007 and again in 2014–15. REL was officially renamed RInfra in April 2008, yet deliveries continued in REL’s name through March 2011.
The central question, therefore, is: to whom was the electricity actually supplied, and where did the money go? Without a named, legally registered recipient, the financial settlements for billions of units of electricity become impossible to audit. The mismatch between corporate names on record and names on utility delivery documents does not appear to be a clerical error but a possible case of deliberate obfuscation.
>> TAX COLLECTED BUT NEVER REMITTED?
The most financially staggering allegation concerns the collection of electricity duties and sales taxes from Mumbai consumers over nine years, from 2007 to 2016. The analysis, based on official government forms submitted by companies and cross-referenced against Reserve Bank of India records, indicates a significant shortfall between taxes collected and taxes deposited.
Under the applicable legal framework, electricity companies that collect taxes and duties from consumers are required to deposit these amounts through RBI challans into the government treasury. This author filed RTI applications to the RBI to verify these deposits. The RBI’s replies, dated June 11, 2018, and August 9, 2019, confirmed it had no record of such remittances.
GFX 2: Tax on Sale of Electricity (2007–2016)
| Year (ending March) | Total Units | Amount (Rs.) |
| Nov-07 to Mar-08 | 2,956,114,932 | 87,46,61,270 |
| Mar-09 | 8,191,225,053 | 1,48,12,98,859 |
| Mar-10 | 8,283,239,341 | 1,52,53,87,578 |
| Mar-11 | 7,411,732,645 | 1,34,34,99,090 |
| Mar-12 | 6,358,149,738 | 1,12,64,07,619 |
| Mar-13 | 6,031,804,726 | 1,09,36,38,092 |
| Mar-14 | 5,788,510,645 | 87,58,43,108 |
| Mar-15 | 7,579,110,893 | 1,44,42,73,735 |
| Mar-16 | 8,376,510,351 | 1,54,81,65,518 |
| TOTAL | 60,976,398,324 | Rs. 1,131.32 crore |
GFX 3: Electricity Duty (2007–2016)
| Year (ending March) | Total Units | Amount (Rs.) |
| Mar-07 | 7,268,476,603 | 3,85,89,87,680 |
| Mar-08 | 7,475,066,806 | 4,84,99,15,124 |
| Mar-09 | 7,991,837,666 | 6,05,23,39,517 |
| Mar-10 | 8,036,012,713 | 6,03,12,50,977 |
| Mar-11 | 7,195,906,465 | 6,77,29,62,268 |
| Mar-12 | 6,189,179,186 | 6,21,09,51,675 |
| Mar-13 | 6,007,300,503 | 6,62,83,07,297 |
| Mar-14 | 6,256,073,137 | 7,61,69,81,045 |
| Mar-15 | 7,409,039,330 | 9,83,44,53,226 |
| Mar-16 | 8,261,908,890 | 11,89,28,45,940 |
| TOTAL | 72,090,801,299 | Rs. 6,974.90 crore |
Although the collections in taxes and duties from Mumbai’s electricity consumers ran into several crores, the RBI’s own records show no evidence of corresponding deposits into government accounts.
Does this mean the money never reached the treasury? It appears that while the duty was shown to consumers as calculated on the full payable amount, it may have been remitted to the government only on the energy-charge component, a method that, when applied across crores of consumers over a decade, produces the enormous shortfall cited above.
>> INSTITUTIONAL DEFLECTION
This author first approached the ROC in August 2008, after which the assistant registrar forwarded the complaint to REL itself, effectively asking the accused party to supply the documentary evidence. A second complaint filed on April 6, 2009, met the same fate: the ROC disclosed it had no records of its own about BSES, REL or RInfra.
The January 2021 omnibus complaint was dispatched to the CBI, the Director General of Income-tax Investigation, the Comptroller and Auditor General of India, the corporate affairs ministry, SEBI, the Commissioner of Sales Tax, Mumbai, the power ministry, and Adani Electric, with copies to the defence minister and the chief of defence staff.
What followed was a bureaucratic relay race. The Union power ministry transferred the complaint to the principal secretary of Maharashtra’s energy department, who in turn directed it to a PWD departmental hearing in Bandra East.
In July last year, a formal complaint was sent to the Enforcement Directorate posing several questions that have awaited official response for nearly two decades:
• How much money BSES received in connection with its acquisition by REL in 2000;
• When and how REL and RInfra were actually registered between 2000 and 2005;
• How many name changes were executed between 2005 and 2008 across REL, RInfra, Reliance Global Ltd and Reliance Infraprojects Ltd;
• And whether consumer-collected tax revenue was ever properly deposited with the government.
(Manoranjan Roy is a Mumbai-based RTI activist)
