TaxTMI 
TaxTMI 
2023 (4) TMI 224
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....AC'), be struck down as invalid, as the order is bad in law and on facts. 1.2. The Ld. Deputy Commissioner of Income-tax, Circle 6(1)(2)/ NFAC, erred in making a reference to the Ld. Deputy Commissioner of Income-tax, Transfer Pricing - 2(2)(1) (TP0') as the former has not recorded an opinion that any of the conditions in section 92C(3) of the Act, were satisfied in the instant case. The Hon'ble Dispute Resolution Panel ('DRP') erred in upholding the actions of the Ld. AO/ NFAC. 1.3. The Ld. Deputy Commissioner of Income-tax, Circle 6(1)(1) (the AO)/ NFAC/ Ld. TPO, erred in not providing an opportunity of being heard to the Appellant before rejection of the arm's length price computed in the Appellant's Transfer Pricing Study. The Hon'ble Dispute Resolution Panel ('DRP') erred in upholding the actions of the Ld. AO/ NFAC/ TPO. 1.4. The Ld. TPO/ NFAC erred in not demonstrating that the motive of the Appellant was to shift profits outside India by manipulating the prices charged in its international transactions, which is a pre-requisite condition to make any adjustment under the provision of Chapter X of the Act. The....
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....P Study and conducting fresh search on the basis that comparable data would be available only after one year of assessment is erroneous and inconsistent with Rule 10B(5) of the Rules, as Rule 10B(5) only provides for updating of current year data and not for conducting a fresh search identifying new comparables. The Hon'ble DRP erred in upholding the actions of the Ld. TPO/ NFAC. 4.3. The Ld. TPO/ NFAC erred in conducting a fresh comparability/ benchmarking analysis using "non-contemporaneous" data and substituting the Appellant's analysis with the fresh benchmarking analysis on mere conjectures and surmises. The Hon'ble DRP erred in upholding the actions of the NFAC/ Ld. TPO. 5. Application of arbitrary filters to arrive at a fresh set of companies as comparables The Ld. TPO/NFAC in applying the following arbitrary filters to arrive at companies as comparables to the Appellant: 5.1 Application of software development services income to sales more than 75% as against qualitative filter of Companies engaged in software/ IT services applied by the Appellant. 5.2 Application of export services to sales more than 75% as against filter of ....
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.... 7.5.1.Aptus Software Labs Private Limited 7.5.2.Nihilent Limited 7.5.3.ThreeSixty Logica Testing Services Private Limited 7.5.4.Cybage Software Private Limited 7.5.5.Consilient Technologies Private Limited The Hon'ble DRP erred in upholding the actions of the Ld. TPO/ NFAC. Functionally not comparable 7.6. The Ld. TPO/ NFAC erred in selecting the following companies as functionally comparable to the Appellant. 7.6.1.Great Software Laboratory Private Limited 7.6.2.Mindtree Limited 7.6.3.R Systems International Limited 7.6.4.Persistent System Limited 7.6.5.1nfoBeans Technologies Limited 7.6.6.Aptus Software Labs Private Limited 7.6.7.Nihilent Limited 7.6.8.OFS Technologies Limited -..----- 7.6.9.Cygnet Infotech Private Limited 7.6.10. Infosys Limited 7.6.11. ThreeSixty Logica Testing Services Private Limited 7.6.12. Cybage Software Private Limited 7.6.13. Consilient Technologies Private Limited The Hon'ble DRP erred in upholding the actions of the Ld. TPO/ NFAC. Extra-ordinary events ....
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....forward business losses and unabsorbed depreciation The Ld. NFAC has erred in not setting-off brought forward business losses and unabsorbed depreciation. 10. Erroneous non-set-off of MAT credit entitlement The Ld. NFAC has erred in law in not setting-off MAT credit entitlement pertaining to earlier AYs. The Hon'ble DRP has erred in not adjudicating this ground of objection raised by the Appellant before it. 11. Erroneous non-grant of Foreign Tax Credit The Ld. NFAC has erred in law in not granting Foreign Tax Credit. The Hon'ble DRP has erred in not adjudicating this ground of objection raised by the Appellant before it. 12. Erroneous short grant of interest under section 244A of the Act. The Ld. NFAC has erred in short grant of interest under section 244A of the Act. 13. Non-issuance of refund The Ld. NFAC/ AO, after having determined an income-tax refund due to the Appellant, has erred in not issuing the refund due to the Appellant. 14. Initiation of penalty proceedings under section 274 read with section 270A of the Act On the facts and in the circumstances of the case and....
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.... be reasonably extrapolated without probing the Annual Reports of the two financial years of the comparable. We are also of the view that when other comparables arc available (when even one comparable is sufficient for comparability analysis) having same account year ending. there is no rationale to select such companies by curling out the figures based on the quarterly reports of the two financial years, authenticity and correctness of which cannot be accepted without further probe. The ITAT, Bangalore, in the case of M/s Hewlett-Packard (India) Globalsoft Pvt Ltd. vs. DCIT in IT(TP)A No.1031(Bang)/2011 and in the case of Core Objects India Pvt Ltd. vs. ITO, in IT (TP)A No. 1229 (Hang)/2011, upheld exclusion of the companies by application of the above filter. A similar view is taken by the Hon'ble Bombay High Court, in the case of CIT-11 Pune v/s PTC Software (India) Pvt. Ltd., in IT appeal No 732/2014. Accordingly, we do not find any infirmity in application of the above filter and rejection of the above company, the same is accordingly upheld. Ground rejected." 3.2 Further, it was observed by the Ld. DRP in page 16 with regard to R. Systems International Ld. as follows:-....
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....g 3 comparables on functional dissimilarity. The ld AR, at the time of argument submitted before us that other comparables are not pressed and dismissed accordingly. 1) Persistent Systems Ltd. 2) Nihilent Technologies Ltd. 3) OFS Technologies Ltd. Persistent Systems Ltd. 7. The ld. A.R. for the assessee submitted that Persistent Systems Ltd. is functionally dissimilar to the assessee. Persistent is inter-alia engaged in outsourced software development services. It builds software for Independent software vendor, platform partners and enterprise customers. The scope of services provided by Persistent includes Enterprise Digital Transformation, Product Engineering services and solution for Internet of Things, Product engineering and professional services to ISVs and enterprises, IP products. Further segmental data for Persistent is not available. Therefore, he prayed that this company Persistent Systems Ltd. should be excluded as comparable. (Page 55 of Annual Report - FY 2016-17) In this regard, the assessee relied on the following rulings: - SAP Labs India Pvt Ltd [TS-506-ITAT-2022(Bang)-TP]/ IT(TP)A No.606/Bang/2021 and IT(TP)A No.25....
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....ted that a careful perusal of the annual report by the Ld. DRP would indicate that the financial results of this stand-alone company is discussed only from page 228 onwards, and the discussion in the earlier pages related to the entire group. The ld DRP also noted that the information submitted under section 133(6) of the Act is totally in consonance with the information stated in the financial statements of this company. It would be totally incorrect to consider the information pertaining to the entire group as such, when the comparability is to be seen with reference to the stand-alone financials of Persistent Systems Ltd, which was examined and considered by us for comparable analysis and accordingly, the Ld. DRP found that this company is functionally comparable to the assessee. 8.3 In this regard it is the ld DRP noted that as per the consolidated annual report the revenue from software licence was Rs.688.99million for the entire group whereas, such revenue in the case of M/s Persistent Systems Ltd was only Rs.128.12 million (Ref. page 201 and page 265 of the annual report). It was also seen by the Ld. DRP that in the P&L account of the consolidated financial statement expe....
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....activity. There is no reference to any IPR or patent owned or developed by the company, in the stand-alone annual report. There is no acquisition of IPR during the year. Further as per note in page 243 of the annual report, costs are expensed as incurred unless the technical and commercial feasibility of the project enable to use or sell the software, they are not capitalized'. Such a development is not reflected in the Asset schedule. Thus, it can be inferred that the R&D activities and intangible assets owned are routine and do not have impact on the revenue and profitability of the company. The ld DRP also noted that, the assessee has failed to establish that such differences, if any, on account of R&D, and the presence of these intangible assets have materially affected the comparability or profitability as required in clause (i) of sub-rule (3) of Rule 10B of the Act. The said company also clarified u/s 133(6) that its intangible assets are in the nature of software licenses acquired for use in the operation of the company and it was seen that they are not in the nature of inbuilt IPR generating revenue for the company. Hence, the intangible assets as such have not affecte....
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....uch. Besides under the TNMM, the net profit margins are compared and there is no requirement to make item to item comparison of expenses of the enterprises. Thus, the ld DRP did not find merit in the plea and accordingly he rejected the same. 8.10 The ld DR further stated that the ld AR for the assessee pleaded before ld DRP that this company had incurred brand building expenses, however, on verification of the annual report, the ld DRP noted that the company had incurred advertisement and sponsorship expenses to the tune of Rs.49.43 million, which constituted meagre 0.28% of total revenue and thus it is insignificant to materially affect comparability or profitability. Besides, under TNMM methodology, there is no requirement to make item to item comparable analysis of expenditure. Hence, these pleas were rejected by the ld DRP. 8.11 The ld DR further stated that with regard to the peculiar circumstances, at the outset, the ld DRP noted that there was no acquisition by this company, which is being compared. As per the information, both the acquisitions of PRM Cloud Solutions and Genwi are by its subsidiaries. Such acquisition by the subsidiary will not have any direct impact ....
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....2014 for assessment year 2009-2010 - order dated 22nd July, 2015. 6.1 We have carefully gone through the order of the coordinate Bench in the case of NXP Semiconductor India Pvt. Ltd. (supra) for the assessment year 2009-2010, wherein it was observed that Persystent Systems Limited 'was engaged in product development and product design and analysis services is functionally different from a pure software service provider and therefore, excluded it from the list of comparables for software development services. The same view was taken in the case of Saxo India Pvt. Ltd. in ITA No.6148/Del/2015 - order dated 05th February, 2016, by observing that Persystent Systems Limited is engaged in running software development services as well as sale of software products. Albeit the percentage of software products in the total revenue is less, as has been noted by the TPO, and also there is no precise information about the contribution made by such small sale of software products to the total profits of the company. As no segmental information is available in respect of this company and the figures have been adopted by the TPO at entity level, it was directed to exclude Persystent S....
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....sessee's case. We, therefore, direct the TPO to exclude Persystent Systems Limited from the list of comparables. LARSEN & TOUBRO INFOTECH LIMITED 7. The learned AR relied on the order of the ITAT Bangalore Benches in the case of CGI Information Systems and Management Consultants Private Limited in IT(TP)A No.586/Bang/2015 - order dated 11.04.2018 and submitted that it was excluded from the list of comparables for the reason that Larsen & Toubro Infotech Limited was a software product company and segmental information on SWD services was not available. In the present case, Larsen & Toubro Infotech Limited engaged in development of software onsite and its overseas revenue for the financial year 20112012 was Rs.27,838,752,995 and domestic revenue was Rs.1,756,792,454. Further in the case of Huawei Technologies India Put. Ltd. in IT(TP)A No.1939/Bang/2017 for assessment year 2012-2013 - order dated 31.10.2018 has taken the same view that it cannot be a comparable with that of the assessee. Being so, we direct the TPO to exclude the same from the list of comparables. INFOSYS LIMITED 8. The argument of the learned AR is that Infosys Limited is func....
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....elected by the TPO. Before the TPO, the assessee objected to the inclusion of the company in the set of comparables, on the grounds of turnover and brand attributable profit margin. The TPO, however, rejected these objections raised by the assessee on the grounds that turnover and brand aspects were not materially relevant in the software development segment. 11.2 Before us, the learned Authorised Representative contended that this company is not functionally comparable to the assessee in the case on hand. The learned Authorised Representative drew our attention to various parts of the Annual Report of this company to submit that this company commands substantial brand value, owns intellectual property rights and is a market leader in software development activities. whereas the assessee is merely a software service provider operating its business in India and does not possess either any brand value or own any intangible or intellectual property rights (IPRs). It was also submitted by the learned Authorised Representative that :- (i) the co-ordinate bench of this Tribunal in the case of 24/7 Customer.Com Pvt. Ltd. in ITA No.227/Bang/2010 has held that a company ow....
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....nd hence Infosys Technologies Ltd. cannot be comparable to the assessee ; (ii) the observation of the ITAT, Delhi Bench in the case of Agility India Technologies Pvt. Ltd. in ITA No.3856 (Del)/2010 at para 5.2 thereof, that Infosys Technologies Ltd. being a giant company and market leader assuming all risks leading to higher profits cannot be considered as comparable to captive service providers assuming limited risk ; (vii) the company has generated several inventions and filed for many patents in India and USA ; (viii) the company has substantial revenues from software products and the break up of such revenues is not available ; (ix) the company has incurred huge expenditure for research and development; (x) the company has made arrangements towards acquisition of IPRs in `AUTOLAY', a commercial application product used in designing high performance structural systems. In view of the above reasons, the learned Authorised Representative pleaded that. this company i.e. Infosys Technologies Ltd.. be excluded form the list of comparable companies. 11.3 Per contra, opposing the contentions of the assessee, the learned Departme....
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.... owns high brand value at Rs.56,286 crore in the year 2012 and percentage of brand value to revenue is 1.67% and brand value as a percentage of market capitalization is 34.2%, and also incur huge amount for research and development at Rs.5 crore as a capital expenditure and Rs.655 crore as a revenue expenditure for the year ended 31st March, 2012. Therefore, it cannot be said to be a comparable. We, therefore, direct the TPO to exclude Infosys Limited from the list of comparables." 12.2 Further we note that Coordinate Bench of this Tribunal in case of LG Soft India Pvt. Ltd. vs. DCIT in IT(TP)A No. 2412/Bang/2019 dated 31/05/2022 observed as under: "I. Mind Tree Limited: 5. The Ld. A.R. submitted that this company is not functionally comparable as it is engaged in providing service in diverse areas such as analytics, information management, application development business process management, business technology consulting, infrastructure management services, product engineering & SAP services. It was also contended that this company is engaged in sale of product and also engaged in outsourcing IT services in banking and financial services and insurance s....
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..... By incurring R&D expenses, it was able to deliver IP based video surveillance management, recording and analytic products and solutions. It has filed 4 patents in India and US so far in the area of Video analysis. - Ownership of intangibles in the form of intangible property. Significant onsite activity: - 46% of revenue earned under Onsite model. - Incurred overseas branch office expenses amounting to INR 1582 crores - Receives incentives from State of Florida in relation to the development center located overseas. Lack of segmental data - Does not maintain segmental information in respect of profitability reported from business activities in the nature of infrastructure management services, technology consulting and SAP services. - Acquisition of subsidiary - Discoverture Solutions LLC 42. The DRP while dealing with the aforesaid objections has merely taken the view that the presence of IPR revenue was insignificant and so also expenses of brand value, R&D & intangibles. More importantly, the DRP did not dispute the presence of 46% of revenue from onsite model, but went on to hold that the presence of revenue is not sufficie....
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....functionally comparable to the assessee. Accordingly, the plea that the company is engaged in diversified activities was rejected by Ld. DRP. 7.2 A plea was raised before Ld. DRP by the assessee that this company also provides data analytic services which is high end and hence, cannot be compared to the assessee. Ld. DRP did not find merit in the plea, as undoubtedly, provision of data analytic services is not functionally different from software development activity. The data analytic services also use only certain software and tools, write codes to perform certain tasks. Like any other software application, these tools also facilitate and enables business enterprises for informed management and decision. Therefore, Ld. DRP did not find merit in the plea. Further, there cannot be any distinction between high end software activity and low end activity, so long as it falls within the purview of software development services. Besides, under the TNMM, such differences are tolerable and there is no requirement that the services / activities performed are identical. It is enough that that the services are similar and fall within the same domain of software development. Accordin....
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.... of brand and intangibles have material effect on the margin of the above company, in terms of clause (i) of sub-rule (3) of Rule 10B, which provides that an uncontrolled transaction shall be comparable to an international transaction if none of the differences, if any, between enterprises entering into business transactions or likely to materially affect the profit arising from such transactions in the open market. Further, as discussed in para 2.6.2.3 above, the assessee also performs R&D functions. Hence, these pleas were rejected by Ld. DRP. 7.5 On the plea as to difference in the scale & size of operations and consequent abnormal profits, Ld. DRP noted that turnover does not influence the margins in the service sector: Ld. DRP already held that turnover cannot be a criteria for selection of comparables. In this regard it is relevant to note that the coordinate bench of Bangalore in the case Advice America Software Development Centre Private Limited (in ITA (TP) No. 2531/Bang/2017 dated 23.05.2018 relating to A.Y. 2013-14) rejected the plea of the assessee to exclude a company comparable on the ground of size and level of operations. Hence, these pleas were rejected by....
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....3.09.2021 for A.Y. 2015- 16 observed as under: "8. We notice that M/s. Infobeans Technologies Ltd. have been directed to be excluded by the coordinate bench in the case of Metric Stream Infotech (India) Pvt. Ltd. with the following observations: "14.3. Infobeans Technologies Ltd., Ld.AR submitted that this comparable was selected by authorities below as it passes all filters, based upon response received from this company under section 133 (6) of the act. He submitted that this observation is contrary to the facts and figures appearing in annual report. Referring to page 1015 Ld.AR submitted that this company is operating at CMMI Level 3 and-is a software service company specialising in business application development for web and mobile. In the company overview this company has been stated to be primarily engaged in providing custom developed services to offshore clients and it provides software engineering services primarily in custom application development, content management systems, enterprise mobility, Big Data analytics. Ld.AR thus submitted that this company is functionally not at all similar with a captive service provider like assessee that this providi....
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.... various other areas such as analytics, big data, internet of things, etc. In this regard he referred page nos. 763 to 767 of the paperbook. 10.1 The assessee relied on the following rulings, wherein Nihilent Ltd. has been excluded as a comparable: - SanDisk India Device Design Centre Pvt. Ltd., vs. JCIT IT(TP)A No. 288/Bang/2021dated 30.6.2022 - Extracts from the annual report are provided below by the ld AR: 10.2 The Appellant also submitted screenshots from the official website of Nihilent Ltd., which evidences the fact that it is engaged into diverse activities other than software development services. 11. The Ld. D.R. submitted that the ld DRP, on perusal of the annual report, noted that this company is engaged primarily in rendering software services and other related IT services. As per information at page 73 the company is a service company primarily rendering software services. Accordingly, it does not hold any physical inventories. As per the background information given at page123 of the annual report, the company is engaged in rendering software services, business consulting in the area of enterprise transformation, change and performance mana....
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....and its wholly owned subsidiary, no consideration was payable". This acquisition was not made by Nihilent, which is being compared. During the year the Group through holding company i.e., Nihilent Technologies Limited has acquired 100% stake in a India base subsidiary Analytics Nihilent with effect from 8th October 2016. The acquisition by a subsidiary will not have any impact on the profitability of this company especially when it is acquired from O8 October 2016. Further, the group company through the holding company has acquired 51% stake in case of Intellect Bizware Services pvt Ltd, which would not affect the profitability of the company in the near term. Further, the assessee also could not point to any information to show, that on account of such acquisition, the profit margin of this company was materially affected. The increase in business or turnover on account of such acquisition will be reflected in the financial statement of such subsidiary. Thus, the ld DRP was of the view that the acquisition as such has not materially affected the profitability of the company, and hence, it cannot he excluded as comparable. 11.2 The ld DR further stated that with regard to pleas ....
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....#39;the Act' for short]of the Income-tax Act,1961 ['the Act' for short] g opportunity of being heard to the assessee. So this comparable is remitted back to the Ld. TPO to decide afresh." ........................ ........................ Nihilent Ltd. 44. The assessee sought exclusion of Nihilent Ltd. as a comparable on the ground that it is functionally dissimilar vis-à-vis assessee. This objection was also raised before the Ld. DRP but rejected. The assessee relied upon website of the company which is made available at page A412 of the paper book wherein Nihilent Ltd. is shown to be engaged in providing advanced analytics, artificial intelligence, blockchain, business intelligence, data signs, cloud services etc. The annual financials of this company available at page A412 & A413 of the paper book shows that it is rendering Enterprise transformation and change management, Digital transformation services and Enterprise IT services but segmental financials are not available as is apparent from its financials available at page A305, A412 & A413 of the paper book. When this company is into various segments but segmental ....
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....uct development which is different from software development activity carried out by the assessee. The Company is also engaged in independent testing. The assessee further submitted that OFS is into diverse activities and there is no segmental data available in the financial statements. Accordingly, based on the above, the assessee submitted that OFS should be rejected as a comparable. Additionally, the assessee placed reliance on the following ruling wherein exclusion of the comparables engaged in outsourced product development was upheld: - SAP Labs India Pvt Ltd [TS-506-ITAT-2022(Bang)-TP]/ IT(TP)A No.606/Bang/2021 and IT(TP)A No.2510/Bang/2019 dated 21.7.2022. The assessee placed reliance on the following ruling wherein it was upheld that testing services are distinct from the software development life cycle and cannot be considered to be akin to software development services and comparables engaged in testing services have been excluded: - M/s. Advice America Software Development Center Pvt. Ltd. vs. The Income Tax Officer, Ward 1(1)(1)(1) [IT(TP)A No.2531/Bang/2017 dated 23.5.2018] Extracts from the annual report are provided below: (Page....
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....D in the profit and loss account statement. There is no indication in the annual report to show that the R&D had resulted in any distinct product development giving rise to source of separate revenue stream. The information on technology absorption on which the assessee relied states that R&D activities are integrated with software development process with objective of ensuring efficiency and quality. Therefore, they are to be taken as routine activities in enhancing the quality of delivery of services. In view of the above these pleas were rejected by the ld DRP. Subjected to the above discussion, the selection of this company was upheld by the ld DRP. 15. We have heard the rival submissions and perused the materials available on record. In our opinion, this comparable fails the functionality test and this company OFS Technologies Ltd. is not functionally similar and deserves to be excluded. 16. Now we come to ground No.7.9, which is reproduced as follows: Abnormally high margins 7.9. The Ld. TPO/ NFAC erred in selecting Threesixty Logica Testing Services Private Limited. Infosys Limited, Cybage Software Private Limited and Consilient Technologies Private Limited as co....
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....ign and development service. The ld. A.R. submitted that Consilient also owns copyrights and there is lack of segmental information. Hence, the ld. AR for the assessee requested for exclusion of this company from the list of comparables. 22. The Ld. D.R. relied on the observation of Ld. TPO/DRP. 23. We have heard the rival submissions and perused the materials available on record. We observe from the Ld. TPO's order that there were total 20 comparables that were finally considered for determining the Arm's length margin by applying Rule 10CA of the I.T. Rules, 1961. On a challenge before this Tribunal, the assessee is seeking exclusion of 4 comparables by way of Ground No.7.1 & 7.6 in which we have already excluded one of the comparable sought for exclusion in ground No.7.1 herein above. Coming to the comparables sought for exclusion in ground No.7.6 on functionality, assessee is seeking exclusion of 3 comparables being Persistent Systems Ltd., Nihilent Ltd. & OFS Technologies Ltd. which was argued and the exclusion has been upheld herein above. Even these 3 comparables are excluded, there remains 16 comparables, and as per Rule 10CA of the I.T. Rules, there has to be minimum....
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.....5% (as compared to 26.5% in FY 2015-16) and IP led revenues contributed 28% (as compared to 21.1% in FY 2015-16). The significant increase in IP led business is contributed by the alliance for IBM Watson loT platform.. Revenue from Enterprise customers also registered significant growth led by the growth in digital business with the focus on platforms and solutions. The share of ISV business as a percentage of total revenue declined, though in absolute terms there was a marginal growth in revenues. In the ISV business, many large software product companies continued to realign their business models to address the competition from new players. This resulted in volatility limiting the growth opportunities. The revenue contribution from the top customer increased to 28.3% as compared to 19.9% in FY 2015-16. Number of clients a with more than USD 1 Million in annual revenues grew from 42 to 55 whereas number of clients with more than USD 3 Million in annual revenues reduced from 18 to 15, accounted mainly by ISV customers. Document 2 Gross block (At Cost) As at April 1, 2012 Additions Disposals Software 1.26749 840% 1510 Acquired co....
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....ramming, the internet of things and predictive BI. (Page 20 of Annual report - FY 2016-17) Document 4 Nihilent India provides a comprehensive range of process and technology-led transformation services leveraging advanced analytics, artificial intelligence, blockchain, business intelligence, data science, cloud services, lot, and machine learning. We focus these services to Banking, Financial Services, Insurance, Retail, Manufacturing, Media, and Healthcare organizations. Document 5 Service Offerings Mobile App Development Data Analytics Independent Testing Commercial Product Development Digitalization DevOps Document 6 BUSINESS STRATEGY: Page 38 of 45 Product Strategy - Enterprise Resource Planning (ERP) Our ERP product development vertical is focused on addressing the specific needs of the supply chain and manufacturing industries. This focused approach would enable the company to research more on adding new features to Enterprise Resource Planning tools that help companies overcome their challenges in manufacturing and supply chain management. (Page 46 of Annual Report - FY 2016-17) Services Strategy - Outsourced Pro....