TaxTMI 
TaxTMI 
2019 (8) TMI 1888
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....( i.e. controlled transactions) which involved receipts of INR 1,77,88,045/- the components of which are stated below: Sales to AE Nature of International Transaction Amount Received, or receivable (INR) Percent- age to AE sales Provision of software development services to AE 1,76,53,360 99.24% Provision of engineering design services to Gulf Lime, LLC (unrelated customer in the overseas market) through AE 1,34,685 0.76% Total 1,77,88,045 The arm's length price of the international transactions representing software services provided to the associated enterprises (AE) is determined by applying transactional net margin method (TNMM), stating to be the most appropriate method. The operating profit to operating cost ratio is taken as the profit level indicator (PLI) in TNMM analysis. The PLI of the company is arrived at 37.68% (based on segmentation made on controlled and uncontrolled transaction) on cost whereas the overage PLI of the comparables is arrived at 23.45% as per the analysis in the TP document. As the price charged in its international transactions was higher than the arithmetical mean price, the price charged in the inter....
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....ure containing the segment reporting referred to hereinabove were duly signed by the independent Statutory Auditor of the assessee company on 11th August, 2010, having been the same date as that at which the 'Auditors' Report to the Members of NetGuru Limited', 'Balance Sheet as at 31st March, 2010' and 'Profit & Loss Account for the year ended 31st March, 2010' were signed by the same auditor as aforesaid.The assessee company incorporated the financial information contained in the segment reporting in its Transfer Pricing Study Report (TPSR) along with notes in support of segment working. The assessee company submitted the 'TPSR' and a copy of the auditor's certificate (including segment reporting being enclosed to the certificate as its annexure) to the TPO during the course of proceedings under section 92CA(3) of the Income-tax Act,1961. In the 'TPSR', the net profit indicator of the assessee company (cash profit margin on cost)was worked at 37.68%, whereas the arithmetic mean of the net profit indicators of the comparable companies selected from public domain was worked at 23.45%. In view of the above computation, the assessee company concluded t....
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....PLI of Comparable 40.34% The price charged by the taxpayer to its Associate Enterprise is compared to the Artm's Length price as under : This way the ld. TPO worked out the transfer pricing adjustment to the tune of Rs. 1,16,82,709/-. 7. Aggrieved by the order of the ld. TPO / A.O. the assessee carried the matter in appeal before the ld. CIT(A) who has deleted the addition made by the transfer pricing officer. Aggrieved by the order of the ld. CIT(A), the Revenue is in appeal before us and raised the following revised grounds of appeal: 1. That in the facts and circumstances of the case, the Ld. CIT(A) has erred in law by deleting an adjustment of Rs.1,16,82,709/-, of international transaction of the assessee with its associated enterprise ('AE'). 2. That in the facts and circumstances of the case, the Ld. CIT(A) has erred in accepting the segmental profitability statement of the assessee because of the following reasons: a) Segmental profitability statement same is not....
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....e case, the Ld. CIT(A) has erred in accepting the segmental profitability statement of the assessee because of the following reasons: a) Segmental profitability statement is not a part of the audited financial / statement. b) Now working notes was provided in support of the segmental profitability. c) The cost allocation has been done without any proper allocation keys. 10. Brief facts qua the issue are that during the TPO proceedings, the ld. TPO asked the assessee to submit the segmental information and data. In response to that the assessee submitted the information about segmental data, which is reproduced below: "......the income from software development activities constitutes 99.24% of the aggregate value of the controlled transactions. Therefore, the assessee has benchmarked the controlled transactions by selecting comparable companies engaged in software development activities. On the other hand, the uncontrolled domestic transactions involve a large variety of activities the main component whereof is receipt of drawing consultancy charges. The income from software development activities (INR 5,74,038.00) constitutes 1.76% of the aggr....
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....eracity of the same cannot be relied upon. * The assessee has not produced the details of Project value, Total Man hour worked by the employee in each project and the total resource utilized, the stages of project development and the employee utilized. * The assessee in its 3CEB report has mentioned that it has urged Cost Plus method for benchmarking the transaction, but when the case is referred to TPO the assessee in its transfer pricing report has used TNMM method. * The assessee submitted that the uncontrolled domestic transaction are largely varied innature but the same time given a statistics that 99.24% of such transaction is drawing and Consultancy charges. However, it is to state here that the software development activities and software consultancy are one and the same and is classified under information technology sector. * From the segment report submitted when the per employee cost is calculated it is found that for controlled transaction the per employee cost per month is Rs 26,159/- while that for uncontrolled transaction the per employee cost is Rs 15,025/-. This gives an indication that the number of employees of the company on t....
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.... produced a segment report, duly verified and certified by the Statutory Auditor of the assessee, in its Transfer Pricing Documentation Report ( vide paper book page no. 24) and duly submitted to the TPO during the course of hearing. Proper allocation key has been mentioned in the segment report prepared by the assessee. However, the TPO rejected the aforementioned segment reporting and computed the net profit indicator / profit level indicator of the assessee (i.e. OP / TC) at (-) 15.30% on aggregate basis (i.e. profit level indicator at enterprise level considering international transactions as well as domestic transactions). The TPO computed the arithmetic mean of the profit level indicators of the comparable companies at 37.18% in the letter No. DDIT (TPO-III)/KOL/NL/92CA(1)/2013-14/77, dated 06.01.2014 and subsequently at 40.34% in the order dated 23/01/2014 u/s 92CA(3) of the Act. Based on the computation made in the aforesaid order, the Transfer Pricing officer recommended an adjustment to income amounting to INR 1,16,82,709/- which is not acceptable. 15. We have heard both the parties and perused the material available on record. We note that during the financial year en....
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....rked at 23.45%. It indicated that the international transactions undertaken by the assessee during the financial year ended 31st March, 2010, adhered to the arm's length standard prescribed by the Indian Transfer Pricing Regulations. This way, ld Counsel for the assessee submitted before the Bench that the assessee has submitted a detailed working of Segment Report before the ld TPO, as mentioned above, therefore, the allegation of the Ld DR that assessee does not have proper segmental report, is baseless. 16. We note that the first grievance of the ld DR for the Revenue is that the segment profitability was not part of the audited financial statements of the assessee company. It is pertinent to note that the dispute arising from this segment reporting issue has already been adjudicated by the Coordinate Bench of ITAT in assessee`s own case, vide ITA No. 1799/Kol/2018, order dated 24.04.2019, wherein it was held as follows: "11. We have heard both the parties and perused the material available on record, we note that in ground No.1, the Revenue alleged that the segment reporting was prepared by the assessee company without having regard to the nature of business. Acc....
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....same were maintained in the ordinary course of business. On perusal of, inter alia, the aforesaid decisions, the Coordinate Bench Delhi in the matter of CSR Technology (India) (P.) Ltd vs. ACIT (supra) held that the AO/TPO/DRP erred in disregarding the segmental result of the taxpayer by proceeding to consider the margin of the taxpayer at the entity level for the transfer pricing analysis. In view of above judgments of coordinate benches, we note that there was valid reason for non-disclosure of segment reporting in the audited accounts of the assessee company and submission of segment reporting before the TPO. Therefore, the allegation made by the Revenue in this regard needs to be rejected. 12. So far nature of business is concerned, we note that the assessee company was primarily engaged in seven different types of revenue- generating functions such as (i) provision of software development services to AE, (ii) provision of engineering services to unrelated domestic customers, (iii) CD sales to unrelated domestic customers, (iv) sale of software products to unrelated domestic customers, (v) digital media sales to unrelated domestic customers, (vi) website devel....
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....d that the lower authorities were not justified in not excluding profit or loss in respect of domestic transactions for determining the profit declared by the assessee in respect of AE transactions. The Tribunal further held that the lower authorities were not justified in adopting the profit level achieved by the assessee in respect of all its transactions including domestic transactions as the profit level declared in respect of AE transactions. The Tribunal, noted that the rate of profit achieved in other comparable cases were to be compared with profit level declared by the assessee in respect of its AE transactions after excluding domestic transactions. Therefore, on comparing the same, the Tribunal held that the profit level declared by the assessee in respect of its AE transactions was more than the profit level in respect of comparable cases found by the TPO. In the above circumstances, in the considered view of the Tribunal, the lower authorities were not justified in making addition to the income of the assessee. The Tribunal deleted the addition and allowed the ground of appeal of the assessee. 13. We note that the Coordinate Bench of ITAT, Pune in the matter of....
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.... employed or to be employed by the enterprise or having regard to any other relevant base; (ii) the net profit margin realized by the enterprise or by an unrelated enterprise from a comparable uncontrolled transaction or a number of such transactions is computed having regard to the same base; (iii) the net profit margin referred to in sub-clause (ii) arising in comparable uncontrolled transactions is adjusted to take into account the differences, if any, between the international transaction [or the specified domestic transaction] and the comparable uncontrolled transactions, or between the enterprises entering into such transactions, which could materially affect the amount of net profit margin in the open market; (iv) the net profit margin realized by the enterprise and referred to in sub-clause (i) is established to be the same as the net profit margin referred to in sub-clause (iii); (v) the net profit margin thus established is then taken into account to arrive at an arm's length price in relation to the international transaction [or the specified domestic transaction." We note that the mandate in clause (e) of sub-rule (1) of ....
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....of the aforesaid decisions, we note that while determining the arm's length nature of the international transaction under the TNMM, the TPO erred in adopting the entity level TNMM approach because the assessee company had undertaken broadly seven different types of revenue generating transactions with varied risks and returns and the provision of software development service to AE was only one of them. The assessee company correctly prepared the segment reporting for the purpose of computing net profit indicator that arose solely from the international transaction under consideration and applied the TNMM only in respect thereof. Hence, we accept the ALP analysis undertaken by the assessee company under the TNMM based on the segment report submitted by the assessee company to the TPO which is duly verified and certified by the independent Statutory Auditor of the assessee company. Therefore, we are of the view that the erroneous benchmarking approach adopted by the TPO needs to be rejected, and therefore, the ground No.1 raised by the Revenue is dismissed." 17. The second grievance of the Ld DR is that no working note was provided by the assessee company in support of the seg....
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....assessee was rejected by the TPO on the ground that in allocation of manufacture expenses like employees' remuneration, rent, etc., the allocation key used was sales whereas according to the TPO, the ideal allocation key in the instant case could have been - number of employees, space utilised, etc." It may be noted that space utilised can be selected as an appropriate allocation key for the purpose of allocation of rent because the amount of rent depends on the area used by the tenant and the rent per square feet. Similarly, the electricity consumption in an office and the amount of electricity charge depend on the area covered and price per unit of electricity. In view of this, the assessee company, in the instant case, selected area / space as an appropriate allocation key for dividing the electricity charges between the respective segments. In view of this, we note that there is proper allocation key and the statutory auditor verified and certified in the segment report that out of the total number of employees (154 persons), the AE-sales segment used 21 employees whereas the domestic sales segment used 133 employees. All the remaining allocable expenses were divided bet....
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....mined the arm's length nature of the international transaction under the TNMM based on segmental accounts duly certified and verified by the independent statutory auditor of the assessee dated 11th August 2010 (date of signature of annual financial statements). In the aforesaid segmental accounts, one segment is 'Sales to AE and associated expenses' and the other segment is 'Sales to Non-AEs and associated expenses'. We note that Ld. TPO rejected the segmental accounts and the arm's length analysis undertaken by the assessee based on the segmental accounts under the transaction-by-transaction approach, primarily based on the allegation that the segmental accounts had not formed part of audit report and hence, the same was not reliable. We note that that the Coordinate Benches of ITAT, as explained above, have accepted segmental accounts for the purpose of arm's length analysis of international transactions under the TNMM where the functions performed by the assessee under the AE-segment are different from the functions performed by the assessee under the non-AE segment, though the segmental accounts do not form part of the audit report. Having regard to ....
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....ompany was engaged in provision of software services to Netguru Inc. USA. Netguru Inc. outsourced the assignments to the assessee company for the previous year relevant to the AY 2010-11. Placing reliance on the aforesaid decision, the CIT(A) rejected Spry Resources India Ltd. Based on the above factual position, we decline to interfere in the order of Ld CIT(A), his order on this issue is hereby accepted. (ii). E-Infochips Bangalore Ltd We note that Coordinate Bench of Kolkata Tribunal in the matter of Labvantage Solutions Pvt. Ltd vs. DCIT reported in [2016] 76 taxmann.com 152 (Kolkata- Trib.). wherein it was noted that the assessee was engaged in execution of software development and coding of software services (software services) outsourced to it by its associated enterprise namely, LVS US. The Tribunal rejected E-Infochips Bangalore Ltd as functionally not comparable to the assessee on the ground that the said company was engaged in software development and IT-enabled services and no segmental income break-up was available for the respective segments in the audited financial statements. In the instant case, the assessee company was engaged in provision of sof....
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.... of the distinguishing features of the functional profile of the company. Thirdware Solutions Ltd was engaged in software product development, implementation and consulting based on ERP and Business Intelligences. In the instant case, the assessee company was engaged in provision of software services to Netguru Inc. USA. Netguru Inc. outsourced the assignment to the assessee company for the previous year relevant to the AY 2010-11. Placing reliance on the aforesaid decision, the CIT(A) rejected Thirdware Solutions Ltd. Based on the above factual position, we decline to interfere in the order of Ld CIT(A) his order on this issue is hereby accepted. (v). Intech Software Pvt Ltd We note that as per paragraph no.12 of schedule 15-Notes to Accounts to the audited financial statements of Inteq Software Pvt Ltd, the said company for the FY 2009-10 was engaged in development of computer software. i.e. production and sale of software. We note that Coordinate Bench of Kolkata Tribunal in the matter of DCIT v. Nomura Research Institute & Financial Technologies (P.) Ltd reported in [2017] 87 taxmann.com 169 (Kolkata-Trib.). In the aforesaid case, the assessee was engaged in t....
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....e filter namely, 'companies who have less than 75% of the revenue as export sales were excluded.' Assessee has furnished below the aforesaid ratio for Cherrytec Intelisolve Ltd, Cigniti Technologies Ltd and Secure Earth Technologies Ltd: Export turnover to total turnover ratio for Cherrytec Intelisolve Ltd, Cherrytec Intelisolve Ltd and Secure Earth Technologies Ltd. are as under: Cherrytec Intelisolve Ltd (page no. 211 of paper book) INR Export turnover 5,27,70,014 Total turnover 8,94,71,520 Export turnover to total turnover ratio 58.98% Cigniti Technologies Ltd (Chakkilam Infotech Ltd) (page no. 215 and 216 of paper book). INR Export turnover 2,77,00,101 Total turnover 5,05,58,955 Export turnover to total turnover ratio 54.79% Secure Earth Technologies Ltd (Globsyn Infotech Ltd) (page no. 219 and 220 of paper book) INR in Lacs Export turnover 249.30 Total turnover 429.80 Export turnover to total turnover ratio 58.00% We note that the TPO in the assessee company's own case for the AY 2011-12 applied the filter 'companies who have less....
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....enue is dismissed. 24. Ground No. 5 raised by the Revenue reads as under: "5. That on the facts and in the circumstances of the case, the Ld. CIT(A) has erred in accepting Kireeti Soft Technologies Ltd. even though it failed the employee cost filter applied by the Ld. TPO." 25. We note that the ground No. 5 raised by the Revenue, is directed against the action of the Ld. CIT(A) in accepting Kireeti Soft Technologies Ltd, even though it failed the employee cost filter applied by the TPO. We note that for the A.Y. 2011-12, the CIT(A) accepted Kireeti Soft Technologies Ltd as comparable to the assessee company though the TPO rejected this company by applying the same employee cost filter as that applied for the AY 2010-11. However, the Revenue accepted the decision of the CIT(A) and did not prefer any ground of appeal before the Tribunal against the decision of the CIT(A) for the A.Y. 2011-12.The department has to have some consistency in its views and in this connection, we rely on the decision of the Hon'ble High Court of Calcutta in the matter of CIT vs. Britannia Industries Ltd reported in [2003] 132 TAXMAN 16 (CAL.), wherein it was held as follows: "Th....
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.... the different heads like software package cost or operating expenses etc. As a result of which the filter cannot be uniformly and objectively applied for selection of comparables." "In. view of the aforesaid, we uphold the decision of the CIT (A) in not sustaining the rejection of comparables selected by the assessee by applying 'employee cost to sale' filter as relevant data/information for this filter are not available. Moreover, it is also a fact that part of the employee cost is included by many companies under different other heads." In view of the above decision, we note that employee cost filter is not amenable to be used as a filter in the selection or rejection of comparables because it is extremely difficult to track or identify actual employee costs which may be included in different heads of expenses disclosed in the Profit & Loss Account. It is also important to note that miniscule difference may be ignored if the company is otherwise comparable, for that we rely on the Judgment of the Coordinate Bench of ITAT Ahmedabad in the matter of effective Teleservices Pvt Ltd vs ACIT reported in ITA No. 2411/ AHD/2014, wherein the Tribunal placed reliance on....
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....nologies Ltd. even though it is functionally dissimilar to that of the assessee." 27. We note that the ground No. 6 raised by the Revenue is directed against the action of the ld. CIT(A) in accepting Akshay Software Technologies Ltd. Ld. D.R. for the Revenue argued before us that Akshay Software Technologies Ltd. is functionally dissimilar to that of the assessee company, therefore, the ld. CIT(A) ought not to have accepted this company as comparable. We note that for the A.Y. 2011-12, the ld CIT(A) accepted Akshay Software Technologies Ltd, as comparable to the assessee company. The Revenue accepted the decision of the CIT(A) and did not prefer any ground of appeal before the Tribunal against the decision of the CIT(A) for the A.Y. 2011-12, there is no reason for the Revenue to reject it for the AY 2010-11, for that we rely on the decision of the Hon'ble High Court of Calcutta in the matter of CIT vs. Britannia Industries Ltd reported in [2003] 132 TAXMAN 16 (CAL.), wherein it is held as follows: "The order of the Commissioner (Appeals) in the assessment year 1980-81 had not been challenged by the department. Once the order had been accepted and when the facts were....
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....tivity which is quite evident from the income schedule of the said comparable. We find that the USA based subsidiary of the company i.e. Akshay Software International Inc. (Akshay US) is a registered partner of SWIFT selling SWIFT solutions and products as an extended arm of SWIFT in North America. Thus, the contention of the Id. TPO/ld.AO is erroneous since it is clearly evident from the annual report of the comparable company itself that it is engaged in rendering software development activity only. We find that this comparable i.e Akshay Software Technologies Ltd had been accepted as comparable in IT sector in the Co-ordinate Bench decision of Delhi Tribunal in the case of Qualcomm India (P.) Ltd. (supra) .... " On similar facts, the coordinate Bench of ITAT Bangalore in the matter of LSI India Research & Development (P.) Ltd v. ITO reported in [2019] 101 taxmann.com 288 (Bangalore-Trib.), wherein the facts were that the assessee was engaged in rendering software development services for AY 2009-10. The assessee selects 17 companies as comparable out of which the Ld. TPO accepts two companies as comparable to assessee, one of them being Akshay Software Technologies Ltd. There....
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....rabad in the matter of CNO IT Services (India) (P.) Ltd. v. ACIT reported in [2018] 90 taxmann.com 407 (Hyderabad-Trib.). The facts of this company are that this assessee company was engaged in the business of exporting software development services. The TPO selected Avani Cimcon Technologies Ltd as comparable against which the assessee filed an appeal before the CIT(A). The Tribunal, however, accepted Avani Cimcon Technologies Ltd as comparable. The relevant extract of the judgment is given below: "15. As regards Avani Cimcon Technologies Ltd is concerned, the assessee submitted that this company is also into the product development and that no segmental details as to product development and IT Services are available and therefore,this should be excluded from the list of comparables. He has drawn our attention to the financial results of this company which are from page 309 of the Paper Book. We have gone through the financials of the said company and we do not find any reference to development of software products. In reply to the proceedings u/s. 92CA of the Act, the said company has replied that it is pure Software Development Service Provider and that the expenditure ....
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....on the ground that the related party transactions are not disclosed in the annual report. We note that normally a comparable company is rejected if the value of the related party transactions disclosed in the audited financial statements is significantly high. For that we rely on the judgment of the Coordinate Bench of ITAT Pune in the matter of ACIT vs M/s Synechron Technologies Pvt Ltd reported in ITA No. 536/PUN/2015. In the instant case, the assessee was engaged in rendering software development services to its associated enterprise during the AY2010-11. The assessee selected CAT Technologies Ltd as comparable company. CAT Technologies Ltd. was rejected by the TPO as it was found to be engaged in three types of businesses i.e. medical transcription, training and software development and consultancy. The TPO also reported that no segmental data was provided by the learned Authorized Representative for the assessee. Before the DRP, the assessee pointed out that from the website of CAT Technologies Ltd., it was clear that the said company was mainly engaged in the provision of software development and consultancy services and during the said year, the company had earned around 91%....
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....f Calcutta in the matter of CIT vs. Britannia Industries Ltd reported in [2003] 132 TAXMAN 16 (CAL.), wherein it was held as follows: "The order of the Commissioner (Appeals) in the assessment year 1980-81 had not been challenged by the department. Once the order had been accepted and when the facts were more or less similar in the assessment year at hand, there was no reason to disagree with the view taken by the Tribunal in the relevant assessment year 1979-80." In view of the aforesaid decision, we note that if the Revenue accepts the said cash profit margin ratio as PLI for the AY 2011-12, there is no reason for the Revenue to reject it for the AY 2010-11 on the same facts and circumstances of the case. We note that the term 'net profit' which is required to be computed for the purpose of application of the Transactional Net Margin Method (TNMM) under the Rule 10B(1)(e) of the Income-tax Rules, 1962, has not been defined by the Income Tax Act, 1961.At this juncture it is important to note that Coordinate Bench of Kolkata, in the matter of DCIT v. M/s EPCOS Ferrites Ltd bearing ITA No. 1597/Kol/2017 (AY 2002-03) and 1598/Kol/2017 (AY 2003-04), wherein the Tri....
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....We accept cash profit margin ratio as appropriate profit level indicator (PLI) in the assessee`s case under consideration. That being so, we decline to interfere in the order of ld CIT(A) and dismiss the ground No. 9 raised by Revenue. 34. In the result, the appeal of the revenue is dismissed. Order pronounced in the Court on 23.08.2019. ============= Document 1 S. No. Name of the comparable 1. Akshay Software Remarks The AR for FY 2009-10 is available. However the Related party Technologies Limited AvaniCimcon Technologies 2. Ltd 3. 4. 5. 6. 7. 8. 9. 10. CTIL Ltd CAT Technologies Ltd Cherrytecintellisolve Ltd Cigniti Technologies Ltd e- infochips Ltd En Pointe Technologies Ltd Green Fire Agri commodities Ltd ICRA Technoanalytics Ltd 11. Indium Software (India) Ltd 12. 13. 14. transaction details is not available. Moreover company is functionally not comparablebeing engaged in integrating swift software with that of client of the swift. The Annual Report of the company was not available. However from perusal of the data available in Prowess database, it is seen that t....
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....ble for FY 2009- 10.From perusal of the same the functionality of the company was not clear. However the data available with TPO it is seen that the company was mainly engaged in servicing clients in South East Asia as against European/US client and it was also submitted that the per hour billing cost was lower while the cost remained the same. Considering such differences which affect margins, it is not being considered as comparable. Kireeti Soft Technologies Ltd Manipal Digital Systems (P) Ltd 15. Persistent Systems & Solutions Ltd 16. Secure Earth Technologies Ltd The company fails employee cost filter. From the Annual Report available for FY 2009-10, it is seen that the company is engaged in providing ITES services. Since it is functionally incomparable, it is not being considered as comparable The AR for FY 2009-10 is not available. This company is a WoS of Persistent Systems Limited. In the absence of any data, it is not being considered as comparable. Fails Export filter Document 2 Evoke Technologies Pvt Ltd CTIL Ltd. Infinite Data Systems Pvt. Ltd. Sr No. 12345 Name of the company ....
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....t for 88,168 0.17% Hardware) Digital Media Sales (Training Activities) 42,440 0.08% Studio Sales (Video Editing & Hiring of Camera Equipment) 35,810 0.07% CD Sales 3,564 0.01% Sub-total (B) Income from Sales & Services as per Profit & Loss Account: (A)+(B) 3,26,24,676 64.72% 5,04,12,721 100% Document 8 Table No. 2 Segment Reporting (Financial Year 2009-10 / Assessment Year 2010-11) Particulars Controlled Transactions Uncontrolled Total Transactions (INR) Allocation Key Sales & Services (A) Schedule 11 1,77,88,045 3,26,24,676 5,04,12,721 Operating Expenses: Cost of software products 50,45,840 43,90,145 94,35,985 Actual Cost of other activities Sub-total 67,68,629 2,85,34,745 3,53,03,374 Actual (employee cost) 1,18,14,469 3,29,24,890 4,47,39,359 Schedule 13 Administrative and other expenses: Motor Vehicle Expenses 96,351 6,10,222 7,06,573 Manpower Telephone Expenses 72,057 4,56,363 5,28,420 Manpower Travelling & Conveyance 1,20,171 5,65,543 6,85,714 Actual Advertisement & Sales 1,15,654 ....