TaxTMI 
TaxTMI 
2023 (7) TMI 1593
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....nd IT consultancy services to the group companies. The functional analysis of assessee as carried out by the Ld.TPO is scanned and reproduced as under: SWD and ITeS segment has been captured by the Ld.TPO. 2.2. The Ld.TPO noted that assessee had following international transaction with its AE. 2.3. The Ld.TPO noted that assessee used TNMM as the most appropriate method for determining the arms length price and OP/OC as the PLI and computed its margin for both the segments to be at 15.2% 2.4. Under SWD segment, assessee selected following set of 13 comparables with average margin of 9.76%. Sr. No. Comparables Margin (OP/OC) 1 C G-V A K Software & Exports Ltd. 9.76% 2 DCIS Dot Com Solutions India Pvt. Ltd. 3.90% 3 EC Info Systems India Pvt. Ltd. 40.97% 4 Evoke Technologies Pvt. Ltd. 4.79% 5 Harbinger Systems Pvt. Ltd. 6.70% 6 Isummation Technologies Pvt. Ltd. 3.69% 7 OFS Technologies Ltd. 25.86% 8 Orion India Systems Pvt. Ltd. 21.97% 9 R Systems International Ltd. (Information Technology Services & Products) 21.32% 10 Rheal Software Ltd. -4.39% 11 Sagarsoft (India) Ltd....
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.... the Act towards delayed payment of PF & ESI amounting to Rs.22,61,943/-. 2.8. On receipt of the draft assessment order, the assessee filed objections before the DRP. 2.8.1. The DRP while considering the objections of the assessee, accepted exclusion of Thirdware Solutions Ltd. under the SWD segment and few inclusions sought by assessee were also approved. In respect of ITeS segment, the DRP upheld the exclusion of A G S Health Pvt. Ltd., Ultramarine & Pigment Ltd. and Access Healthcare Services Pvt. Ltd. The DRP also directed the recomputation of margin where there was arithmetical mistakes. 2.9. On receipt of the DRP directions, the Ld.AO passed the impugned order making addition under SWD and ITeS segment totaling to Rs.82,86,25,140/-. The Ld.AO also upheld the disallowance at Rs.22,61,943/-. Aggrieved by the order of the Ld.AO, assessee is in appeal before this Tribunal. 3. At the outset, the Ld.AR has submitted that assessee is seeking inclusion / exclusion of certain comparables under SWD and ITeS segment. He submitted that Ground nos. 1 to 3 are general in nature and therefore do not require any adjudication. 3.1. The Ld.AR submitted that Ground no. 14 & 17....
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.... company. 1. Infosys Limited. 1. Functionally different Infosys (' th e Company') is a leading provider of consulting, technology, outsourcing and next-generation services. Along with its subsidiaries, Infosys provides business IT services (comprising application development and maintenance, independent validation, infrastructure management,engineering services comprising product engineering and life-cycle solutions and business process management); consulting and systems integration services (comprising consulting, enterprise solutions, systems integration and advanced technologies); products, business platforms and solutions to accelerate intellectual property-led innovation including Finacle(r), its banking solution; and offerings in the areas of analytics, cloud, and digital transformation.(Page 2131 of PB-II- Part 2) These services are not comparable to the services provided by the Appellant. 2. Derives revenue from sale of products as well. The company has derived revenue from sale of product to the tune of INR 32 crores (Page 2161 of PB-II-Part 2), However, the Appellant does not derive any such revenue from sale of products imply....
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....ys is a high-risk bearing entrepreneur and the high revenues/ profits can be said to be commensurate to the kind o frisks undertaken by Infosys. Hence, Infosys should not be compared to a risk mitigated entity like NTT Data IPS.(Page 2091 of PB-II-Part 2) 9. Significant Foreign expenditure In this regard, we wish to submit that Infosys has incurred significant foreign expenditure which works out to 67%, 73.95% and 64.36% of total expenditure incurred for FY 2016-17, FY 2015- 16 and FY 2014-15 respectively. Considering this, it is clearly evident that Infosys has significant onsite activities outside India. Accordingly, given that the Appellant predominantly carries out its operations within India and does not incur any significant foreign expenses, it is evident that Infosys follows a different operating model (which also impacts the profitability) and hence, could not be compared with the Appellant.(Page 2072 of PB-II-Part 2, Page 60 of AR for FY 2015-16 and Page54 of AR for FY 2014-15) Judicial precedents relied upon: Functional comparability- 1) Yahoo Software Development India Pvt. Ltd.vs JCIT[IT(TP)A No. 178/Bang/2022 for AY 2017-18....
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....ve' encapsulates the ability and willingness to solve complex challenges for the clients through your Company's real word expertise and technological prowess. The new brand is truly a brand for the converging world.(Page 3722 of PB-II-Part 4) Whereas the Appellant, being a captive service provider, does not own any brand value like L&T, the brand image if any is of the parent and the same has no impact on the revenue of the Appellant as the Appellant does not cater to 3rd parties. Further, the company owns huge intangibles including intangibles under development.(Page 3789, 3799 and 3800 of PB-II-Part 4) 5.Acquisition and Amalgamation During the year, the scheme of Amalgamation for "GDA Technologies Limited" was sanctioned by the High Court. Thus, we believe that the synergies obtained through this acquisition would have an impact on the overall margin of the company and thus L&T should not be considered as comparable to the Appellant for the FY 2016-17. The company was amalgamated with L&T with effect from September 2, 2016 and entire assets were transferred with effect from April 1, 2016 (relevant extracts reproduced below) Pursuant to the Scheme of Amalgamation....
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.... comparability- 1)Yahoo Software Development India Pvt. Ltd.vs JCIT[IT(TP)A No. 178/Bang/2022 for AY 2017-18](Page 6268-6272 of Paper book III) 2) SanDisk India Device Design Centre Pvt. Ltd vs JCIT [IT(TP)A No. 288/Bang/2021 for AY 2016-17(Page 6308 of Paper book III) 3) ADP Pvt. Ltd Vs. DCIT [ITA Nos. 227 & 228 /H/2021 for AY 2016-17](Page 6331-6333 of Paper book III) 4) Infor (India) Private Limited vs DCIT [I.T.A-TP. No. 198/HYD/2021 for AY 2016-17](Page 6416-6419 of Paper book III) 5) Citrix R&D India Pvt Ltd vs DCIT [ IT(TP)A No.2428/Bang/2019 for AY 2015-16](Page 6452-6458 of Paper book III) 6) Cypress Semiconductor Technology India Pvt Ltd [IT(TP)A No.2427/Bang/2019 for AY 2015-16](Page 6498-6499 of Paper book III) 7) M/s. Microsoft Research Lab India Pvt. Ltd.[IT(TP)A No.3131/Bang/2018 for AY 2014-15](Page 6525-6526 of Paper book III) 8) GlobalLogic India Pvt. Ltd. vs. DCIT [ITA No. 868 (Delhi) of 2021 for AY 2016-17]-(Page 6679-6681 of Paper book III) 9) M/s. Hewlett Packard (India) Software Operation Pvt. Ltd.,[IT(TP)A No.2866/Bang/2017 for AY 2013-141(Page 6585- 6595 of Paper book III) ....
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.... Given that no such transactions were undertaken in the case of NTT Data IPS which would impact the margins earned by the Appellant, considering the tainted margins of Mind tree would distort the benchmarking analysis. Accordingly, we humbly wish to submit that Mindtree be excluded from the final set of comparable companies. 5. Investment in Technology absorption We observed that Mindtree is focused on strategic and emerging technologies andinnovation and has continued to invest in technologies. During the FY 2016-17, these efforts have strengthened the Centre of Excellences ('CoEs') of Mindtree. In these CoEs, theemerging technologies such as Internet of Things, Cognitive Computing and Deep learning,Automation, Blockchain, Augmented/ Virtual Reality, Collaboration Solutions etc. wereexplored in depth and several re-usable assets were built to enable delivery (refer annual report extracts below). However, we wish to submit that no such activities were undertakenby the Appellant, accordingly, given that the above investments in technology would impact the profitability of Mindtree, the same could not be considered for comparability analysis.(Page 3474 to 3477 of....
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....le to NTT Data IPS since it is predominantly engaged in outsourced product development. The Annual Report of Persistent clearly mentions the key products and services which company deals with, which includes (i) Enterprise Digital Transformation (ii) Product engineering services and solutioning for Internet of things (iii)Product and Engineering services to ISV's and enterprises and (iv) IP products.(Page 1709 of PBII- Part 1) Given the above it is evident that the company's major portion of income is derived from both sale of software services and products. Further, page 302 of Annual Report FY 2016-17also clarifies that the company specializes in software products, services and technology innovation and that the company offers complete product life cycle services, as opposed to Appellant's routine software development services.(Page 1850 of PB IIPart 1) Notes forming part of consolidated financial statements 1. Nature of operations Persistent Systems Limited (the "Company" or "PSL"') is a public Company domiciled in india and incorporated under the provisions of the Companies Act, 1956 (the "Act"), The shares of the Company are listed on Bo....
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....curred significant foreign expenditure which works out to 37.94%, 22.15% and 26.83% of total expenditure incurred for FY 2016-17, FY 2015-16 and FY 2014-15 respectively. Considering this, it is clearly evident that Persistent has significant onsite activities outside India. Accordingly, given that the Appellant predominantly carries out its operations within India and does not incur any significant foreign expenses, it is evident that Persistent follows a different operating model (which also impacts the profitability) and hence, could not be compared with the Appellant.(Page 1641 of PBIIPart 1) 5. Significant RPT With respect to modified application of the RPT filter. Please find below the workings of RPT filter below: Particulars FY 2016-17 FY 2015-16 FY 2014-15 Total revenue (A) 17,329,640,000 14,471,360,000 12,424,980,000 Related party transaction (B) 6,576,800,000 4,636,950,000 3,891,930,000 Percentage to total revenue (B/ A) 37.95% 32.04% 31.32% As captured above, during the FY 2016-17, FY 2015-16 and 2014-1....
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....r of operations - FY 2015-16 - It has witnessed a growth in revenue around 76% and growth in PAT of around 14.7% in FY 2015-16 d) Full pledged risk bearing entity. 14.4 The ld.AR further submitted that Info beans Technologies Ltd has launched 2 New Segments viz. Automation engineering and not functionally similar in FY 2015-16 and 2014-15. 14.5 Accordingly the Nihilent Technologies Private Limited & Info beans Technologies Ltd should be excluded from the comparables. The ld. AR of the assessee also requested that the matter may be send back to the ld. TPO for re-examination on the basis of functional profile & in the light of the case law cited by him in his written synopsis and chart submitted." There is nothing brought on record by the Ld. DR contradicting the above observations. Respectfully following the above view, we direct exclusion of the 5 comparables from the final list. (A) Threesixty Logica Testing Services Pvt. Ltd. The Ld.AR submitted that, this comparable fails RPT filter as its RPT is 30.42%. It is also submitted that, this comparable is functionally not similar with that of assessee as it owns certain brand names "SAQAMA" & "S....
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....on and functional dissimilarities with assessee. (B) Great Software Laboratory Pvt. Ltd. The Ld.AR submitted that this company is engaged in the business of design and development services of software applications including customisation and packaged software. She further submitted that the primary service of the Company are cloud products and operations management, IDM and connected experience practice, big data analytics and support services. The Company has also earned revenue from sale of products. The company is engaged in diverse activities for which no segmental details is available. It is further submitted that the company owns significant intangibles and that this company earned significant onsite revenue which demonstrates that it operates on a different model and therefore functionally not comparable with the assessee. The Ld.AR placed reliance on the decision of Coordinate Bench of this Tribunal in case of Sprinklr India Pvt. Ltd. in IT(TP)A No. 713/Bang/2022 by order dated 11.01.2023. The Ld.DR on the contrary, relied on the observations of the authorities below. We have perused the submissions advanced by both sides in the light of records placed before....
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..../2022 by order dated 17.05.2023. On the contrary, the Ld.DR placed reliance on orders passed by authorities below. We have perused the submissions advanced by both sides in the light of records placed before us. We note that the Coordinate Bench of this Tribunal rejected this comparable by observing as under: "14.10 Regarding the comparable Cybage Software Pvt. Ltd., the assessee had objected before the TPO and DRP that the same is not functionally comparable, lacks segmental information and has extra ordinary high margins. However, the TPO and DRP rejected the objections of the assessee. The Pune Tribunal in the case of Optiva India Technologies Pvt Ltd in ITA 194/Pun/2021 dt.21.07.2022 has directed to exclude comparable Cybage Software Pvt. Ltd on the ground of functional dissimilarity. Relevant portion is extracted hereunder: "Cybage Software 17.1 The assessee contends that this company is mainly Onsite service provider whereas the assessee is offsite service provider and therefore, functionally different. Further, there is incorrect reporting figures which are unreliable. This company is product development as well as R & D Intensive Company.....
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....is company is functionally not at all similar with that of the assessee. D.2. On the contrary, the Ld.DR relied on the observations of the authorities below. We have perused the submission advanced by both sides in light of records placed before us. D.3. We note that this company is in the business of Chip and semiconductor design services where as the assessee before us is into basic SWD services of coding an documentation, Testing and quality assurance, software patches and maintenance. There is no similarity between the functions performed by the assessee vis-à-vis that of this company. We therefore at the threshold reject this company being functionally not similar with that of the assessee. Accordingly, the Ld.TPO is directed to exclude this company from the final list of comparables. Accordingly, ground no. 15 raised by assessee stands partly allowed. 5. In Ground no. 16 assessee seeks inclusion of only two comparables out of the 7 comparables raised as under: 1) Sasken Technologies Ltd. - seg 2) Evoke Technologies Pvt. Ltd. 5.1 The Ld.AR submitted that these comparables have not been disputed to be functionally not similar with that....
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....frameworks India Pvt. Ltd. vs. ACIT in ITA No. 674/PUN/2022 for A.Y. 2018-19 which is placed at pages 171 more particularly in para 6 at page 175 of paper book. It the observation of Hon'ble Pune Tribunal that this comparable is not functioning in ITeS segment. (C) MPS Ltd. The Ld.AR submitted that this comparable is functionally not similar with that of assessee as it is engaged in end to end publishing solutions and provides services including content development, print and digital publishing services etc. It is submitted that this comparable also undertakes R&D for development of tools and enhancement of cloud based digital publishing platform. The Ld.AR submitted that this comparable owns intangibles in the form of computer software and therefore it cannot be considered to be a back end ITeS service provider. Further it is submitted that during the assessment years 2013-14 to 2018-19, this comparable has undertaken six acquisitions thereby announcing itself to be a full-fledged entrepreneur. He also placed reliance on the observations of Hon'ble Mumbai Tribunal in case of Red Hat India Pvt. Ltd. vs. NFAC reported in (2022) 136 taxmann.om 52. (D) Domex E Data Pvt. Lt....
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....ve four comparables contested for exclusion under the ITeS segment have been found to be engaged in high end services and these comparables are full-fleged entrepreneurs. The Ld.TPO while analyzing the functions of the assessee under ITeS segment has very categorically noted that assessee provides services to the insurance companies of the AE wherein it carries out filling up the claim entry form and patient registration, eligibility verification, claim submission and adjudication etc. under healthcare services under insurance and banking services, assessee provides record processing services, KYC update services accounting services etc. It has been observed by the Ld.TPO that assessee before us neither directly pitches nor provides support in pitching work from customers. It is noted that assessee only provides assistance / advise from operations stand point to the solutions team in USA who in turn approaches the customer for work. In our opinion, based on such limited functions of the assessee in ITeS segment all the above four comparables cannot be considered comparable with that of assessee with high end activities. Further nothing contrary has been brought to our notice by the....
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....4(2) of the Act, as follows: "Scope of the Power of Rectification 12. As stated above, in this case we are concerned with the application under section 254(2) of the 1961 Act. As stated above, the expression "rectification of mistake from the record" occurs in section 154. It also finds place in section 254(2). The purpose behind enactment of section 254(2) is based on the fundamental principle that no party appearing before the Tribunal, be it an assessee or the Department, should suffer on account of any mistake committed by the Tribunal. This fundamental principle has nothing to do with the inherent powers of the Tribunal. In the present case, the Tribunal in its Order dated 10.9.2003 allowing the Rectification Application has given a finding that Samtel Color Ltd. (supra) was cited before it by the assessee but through oversight it had missed out the said judgment while dismissing the appeal filed by the assessee on the question of admissibility/allowability of the claim of the assessee for enhanced depreciation under section 43A. One of the important reasons for giving the power of rectification to the Tribunal is to see that no prejudice is caused to either ....
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....it, TDS credit and MAT credit in accordance with law. Accordingly, these grounds raised by assessee stands allowed for statistical purposes. 10. Ground nos. 24-26 are consequential in nature and therefore do not require any adjudication. In the result, the appeal filed by assessee stands partly allowed. Order pronounced in the open court on 17th July, 2023. ============= Document 1 Transfer Pricing 1. 1. The order passed by the Assessing Officer, received through the National e-Assessment Centre. Delhi ['the learned AO'] under section 143(3) read with sections 144C(3) and 144B of the Income- tax Act, 1961 ('the Act') is bad in law and on facts. 2. The learned Assessing Officer ("AO") learned Transfer Pricing Officer ("TPO") and the Honourable Dispute Resolution Panel ("DRP") grossly erred in making an adjustment of INR 82.26,25,140 /- with respect to the international transaction rendered by the Appellant under section 92CA of the Income-tax Act. 1961 ("the Act"). 3. The learned AO/ learned TPO/ Hon'ble DRP erred in rejecting the Transfer Pricing ("TP") documentation maintained by the Appellant by invoking provisions of sub-section (3) of section 92C of....
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....reat Software Laboratory Private Limited e) Black Pepper Technologies Private Limited f) Mindtree Limited ) Nihilent Limited 1) Aptus Software Labs Private Limited i) Infobeans Technologies Limited j) Wipro Limited k) Threesixty Logica Testing Services Private Limited 1) Infosys Limited m) Cybage Software Private Limited n) CG - VAK Software & Exports Limited 0) Sagarsoft (India) Limited The learned AO/ learned TPO/ Hon'ble DRP has erred in not rejecting the following comparable companies in the SWD segment: 15. a) Exilant Technologies Pvt. Ltd. b) Larsen & Toubro Infotech Ltd. c) Great Software Laboratory Pvt. Ltd. d) Black Pepper Technologies Pvt. Ltd. e) Elveego Circuits Pvt. Ltde f) Mindtree Ltd. g) Nihilent Ltd. - h) Aptus Software Labs Pvt. Ltd. = Persistent Systems Ltd. j) Infobeans Technologies Ltd k) Wipro Ltd. 1) Tata Elxsi Ltd m) Threesixty Logica Testing Services Pvt. Ltd. n) Infosys Ltd. 0) Cybage Software Pvt. Ltd~ p) Tech Mahindra Limited The learned AO/ learned TPO/ Hon'ble DRP has erred in rejecting the following comparable companies that ought to have been accepted in the ....
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.... amendments to sections 36(1)(va) and 43B of the Act which restrict the claim of such amount are prospective and applicable w.e.f. AY 2021-22, as specifically provided for in the Memorandum to the Finance Bill, 2021 and affirmed by subsequent judicial precedents. d) Without prejudice to the above, the learned AO erred in not recomputing the deduction under section 10AA of the Act, to the extent the disallowance relates to eligible units. 21. Without prejudice to the aforesaid grounds, the learned AO erred in not recomputing Foreign Tax Credit on the assessed income, given that the assessed tax liability is determined under normal tax provisions as against the MAT liability determined in the ROI. 22. The learned AO erred in not granting Tax Deducted at Source ('TDS') credit to the extent of INR 1.03.456 in the Order, without specifying any reasons for not granting appropriate TDS credit. 23. The learned AO erred in not granting set off of brought forward MAT credit against the tax liability determined under the normal tax provisions as against tax liability determined under the MAT provisions in the ROI. 24. Consequent to the above grounds, the learned AO erred in lev....
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....ce desk, production support, and user support), application maintenance and application enhancement and upgrades. application enhancement and upgrades. Enterprise Application Services: NTT DATA IPS provides ERP implementation uchas SAP / Oracle. h as SAP 7 Oracle. Network Infrastructure Services Mobile technology services: NTT DATA IPS provides development, porting and testing services for mobile applications on the J2ME & BREW platforms. · Content management services: NTT DATA IPS provides services relating to Web Content Management Systems (WCMS) and development of WCMS product itself which inter-alia includes defining and designing content workflows, publishing and processing, fe-engineering and testing Cloud services: Under the cloud services, the Company assesses cloud maturity architects cloud transformation. The Company is engaged i strategizes, plans and architects cloud tra cloud security. cloud advisory, cloud migration, managed private cloud onsite, virtual workspace services.E Strategic Management functions: Strategic Management functions such a corporate strategy/treasury ete, involves decision making on business strategy, corporate strategy/treasury etc....
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.... business as and when new opportunities are identified with their respective clients. For new clients, the sales organization identifies new opportunity/client and assigns a client relationship client relationship manager. The 'client relationship manager becomes the contact nctional requirements and execution. NTT DATA IPS, being a software development services provider to NTT DATA Group companies, is not involved in any marketing/ business development activity. Conceptualization of the service: Service conceptualization is the process by which ides what service characteristics are needed to meet the market demands to satisfy these demands and the selection of inputs and processes that will create these services. The client management team of NTT DATA Group continuously engage with clients to understand the current business trends and in order to identify any future requirements. Based on the discussions, feedback from clients and developments in the market NTT DATA Group undertake the conceptualization and design of the software updation / service to be provided to the clients. NTT DATA Group has a strategic service management team that is responsible for genera....
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....DATA IPS. Based on the objective and requirements outlined in the functional specifications NTT DATA Group along with NTT DATA IPS discusses and finalizes the operationa feasibility of the requirement. In certain instances, NTT DATA IPS provides its inputs on the functiona specifications document based on which the client management teams Group undertake detailed review and evaluation of the same before providing the necessary approval. NTT DATA Group is further responsible for provid providing the ip undertake detalle providing an overal I to the final functional requirement (post inputs from NTT DATA IPS). NTT DATA IPS provides staffing and maintenance services based on the requirements specified by the customers in India. Coding and documentation: Coding and documentation is the process of translating detailed design to statements in a programming lang programming language. In code generation phase, the design must be converted into a machine- readable form. The sprint team of NTT DATA IPS undertakes coding and documentation of the requirement/module based on the functional specifications and software requirement analysis agreed with NTT DATA up in the above....
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....ons document. The various levels of testing undertaken by NIT DATA Ins (at ditterent stages of sorware den tesinen while the said levels of testing happens off-shore at NTT DATA IPS's locations, NTT DATA said levels of testing happens off-shore at NTT DATA IPS's locations, NTT DATA Group companies undertake the User Acceptance Testing at a global level in order to employees of NTT DATA IPS also performs on site testi ents. In some cases, developed in order to avoid any technical issues or delay in delivery. NTT DATA Group is responsible for the final testing of the complete service/solution the complete servi deliverable to the customer. In the event. there are any issues with th Implementation, NTT TA IPS has to rework on the same to amend the problems identified. . Integration: Once all the software module(s) are fully tested and integrated, a team Within the glass ONTT DATA Group. In certain cases, NTT DATA IPS releases : e quality assurance department of NTT DATA IPS proceeds with the action release to NTT DATA Group, In certain cases, NTT DATA IPS releases the software on to the QA environment of the client for testing by the client. NTT DATA ent confir....
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....e of a new service and/or a new upgrade to an existing service, there are possibilities of certain bugs that may appea in the release. In such a case, the client(s) contacts the respective client manager and the client manager in turn contacts the development team in India to issue a software patch that would fix the bug in the software. Based on the specific request received from NTT DATA Group, the delivery team in NTT DATA IPS releases a software patch for the respective client. 2.2 Functions performed by the assessee in respect of ITES segment as per TR document: . Healthcare: Health care industry forms majority part of the ITeS segment of the Company. Medical coding - essentially Fentails the c sion of medica Company. Medical coding - essentially rentails the conversion of medica documents/data of patients into procedural and diagnostic codes for the purposes of na is done in line with and reference to the payer company. The medical coding is done in line with coding across specialties, insurance and government regulatory requirements, and ude transcription specific coding requirements. Medical Coding does not include transcripti services. Codes are developed on....
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.... clients for the purpose of getting new business communicating service capabilities, assuring service delivery and maintaining rewarding client relationships. NTT DATA Group Companies engages a specialized team of client service executives for management of contracts and client relationships. Such client service domain es are located in US and clients are assigned based on geography and/or domain expertise. The client service team is the first point of contact for potential and existing clients, and is responsible for representing professional capal DATA Group Companies' and also maintaining client relationships. The client services team is responsible for identification of potential clients and ion, responding to requests for proposal, and marketing/ DATA Group's servicing to requests for proposal, and marketing/presenting NTT vices at various tradeshows, conferences and other industry fora. A pre-requisite in providing effective services to the client is accurate critical pre-requisite in providing effective services to the client is accurate understanding of the client's existing processes and requirements. The client service executives undertake an in-depthing processe....
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....icing, payment terms, credit period etc.In establishing respect of each client, NTT DATA Group performs the ultimate deci respect of each client, NTT DATA Group performs the ultimate decision making functions. With regard to pricing. NTT DATA IPS's role is only limited to providing unctions. With regard to pricing. NTT DATA IPS's role is only limited to p Document 3 International Transactions Particulars Receivables/Received Payables/Paid Method Provision of software development services-reversal INCON ARTMENT 199 TNMM Provision of software development services 1251,23,20,596 TNMM Provision of IT enabled services 298,11,35,425 TNMM Receiving of software development services- reversal 101,23,164 TNMM Receiving of software development services 57,18,43,072 TNMM Receiving of IT enabled services 53,19,120 TNMM Reimbursement of expenses 178,90,945 TNMM Trade receivables from software development services 31,36,73,943 TNMM Advance for software development services 272,23,778 TNMM Trade receivable from IT enabled services 762,59,209 TNMM Advance for IT enabled services LACON 18.78,125 PARTMENT TNMM Trade payable for software d....