Moves by the Reserve Bank of India (RBI) to implement a version of Basel III's counter-cyclical capital buffer (CCB) fail to address the real issues facing the domestic financial system, and effectively amount to a "tax on banks", according to Ajay Shah, professor at the National Institute of Public Finance and Policy – a think-tank affiliated with the Ministry of Finance.

Credit grew quickly in the run-up to the financial crisis, so regulators wanted a provision for banks to put in additional