Income Tax Appellate Tribunal - Hyderabad
United Online Software Development ... vs Assessee on 20 June, 2014
IN THE INCOME TAX APPELLATE TRIBUNAL
HYDERABAD BENCH "B", HYDERABAD
BEFORE SHRI B. RAMAKOTAIAH, ACCOUNTANT MEMBER
AND SHRI SAKTIJIT DEY, JUDICIAL MEMBER
ITA No. 1500/Hyd/2010
Assessment Year : 2006-07
United Online Software ITO, Ward 3(2), IT Towers,
Development (India) Pvt. Ltd., Masab Tank, Hyderabad.
Hyderabad.
PAN - AAACJ9549G)
(Appellant) (Respondent)
Assessee by Shri Ravi Bharadwaj
Revenue by Shri D. Sudhakar Rao
Date of hearing 22-04-2014
Date of pronouncement 20-06-2014
O RDE R
PER SAKTIJIT DEY, J.M.:
This appeal of the assessee is directed against the order dated 11/10/2010 passed u/s 143(3) of the Act in pursuance of the directions issued by the Dispute Resolution Panel (DRP). The appeal pertains to the assessment year 2006-07.
2. Briefly the facts are, the assessee an Indian Company is wholly owned subsidiary of Juno Online Services Inc. (herein after referred to as 'Associated Enterprise' in short 'AE'). The assessee is engaged in providing software development services only to its AE in USA on cost plus basis. Assessee is registered under the Software Technology Parks of India's Scheme of Government of India as 100% export oriented unit. For the impugned assessment year, the assessee filed its return of income on 22/11/2006 declaring income of Rs. 3,62,908/- after claiming deduction u/s 10A of the Act. During the 2 ITA No. 1500/H/10 United On line Software Develop me nt (India ) Pvt. Ltd.
scrutiny assessment proceeding, AO noticing that assessee has entered into international transaction with its AE made a reference to the Transfer Pricing Officer (TPO) for determining Arm's Length Price (ALP) as per section 92CA of the Act. In course of the proceeding before him, the TPO on examining the TP study undertaken by the assessee through an external consultant as well as other documents submitted in course of proceeding noted that the assessee had received an amount of Rs. 18,25,29,242/- from provision of software development services to its AE. Assessee has adopted transaction net margin method (TNMM) as the most appropriate method and has selected 36 companies as comparables for bench marking its price charged for the international transaction. Since the average profit margin on cost of the 36 comparable companies is 12.06% as against assessee's margin of 9.67%, the price charged for international transaction was found to be within ALP. The TPO though agreed with the assessee so far as adoption of TNMM is most appropriate method, but, he nevertheless rejected the TP study of the assessee by pointing out various defects and deficiencies therein and primarily for the reason that the assessee has not used current year data in case of 27 companies and in respect of the rest 9 companies, assessee has considered current year data along with data relating to the preceding two years. After rejecting TP document furnished by the assessee, the TPO undertook a search in the data bases by adopting some of the filters applied by the assessee along with some other additional filters which yielded 20 comparables with average margin of 20.68%. After allowing working capital adjustment of 1.48%, TPO worked out ALP margin at 19.9% and applying that to the operating cost, he determined ALP at Rs. 19,83,82,459/- as against the price charged by the assessee of Rs. 18,25,29,242/-. Thus, the resultant short fall of Rs. 1,58,53,227/- was treated as adjustment to be made u/s 92CA of the Act. In consequence to the order passed by the TPO, the AO formulated a draft assessment order adding the transfer pricing adjustment of Rs. 1,58,53,227/-. Further, the AO also made 3 ITA No. 1500/H/10 United On line Software Develop me nt (India ) Pvt. Ltd.
adjustment to the deduction claimed u/s 10A of the Act by reducing communication charges of Rs. 8,00,1,768/- from the export turnover. Being aggrieved of the draft assessment order, the assessee raised objections before the DRP.
3. The DRP having rejected all objections raised before it, the AO passed final assessment order, which is under challenge in the present appeal.
4. Ground Nos. 1 to 12 are on transfer pricing issues. At the outset, the learned AR expressed his intention not to press Ground Nos. 1,2,3,4,5,6, 10 & 12. In respect of rest of the grounds including additional ground also, the learned AR restricted his submissions with regard to selection/rejection of comparables by the TPO and sustained by DRP as well as issue of risk adjustment. Out of the 20 comparables selected by the TPO, assessee has no objection in respect of 15 comparables. The assessee has objected to selection of 5 comparables, which are detailed hereunder:
I. Accel Transmatic Ltd.
i. Objecting to selection of this company, the learned AR submitted that this company is functionally different. It was submitted that during the year the company had sold IP rights in the software developed by it, which has impacted its profitability of the year. Hence, the company not only does not satisfy the 75% service revenue filter applied by the TPO, but, has an exceptional year of operations. It was submitted that the performance of the software segments clearly indicate that the company has income from sale of products. The learned AR further submitted that the company has a negative operating margin of 18.73% for FY 2004-05. Further, the learned AR submitted that as per the annual report submitted by the company in response to 133(6) related party transaction (RPT) also 4 ITA No. 1500/H/10 United On line Software Develop me nt (India ) Pvt. Ltd.
fails threshold limit applied by the TPO himself. In this regard, the learned AR submitted the following computation:
Particulars AE
Rendering of services 56,274,970
Receiving of services 10,011,622
Interest paid 1,513,025
Lease payments 1,830,084
Total RPT 69,629,701
RPT/Sales 60.60%
ii. It was therefore submitted that this company under no
circumstances can be considered as a comparable to the assessee, which is a purely software development service provider. The learned AR submitted that ITAT, Bangalore Bench in case of Huawei Technologies India Pvt. Ltd. Vs. ITO (ITA No. 1338/Bang/2010 dated 30/04/2013 has held the aforesaid company not to be a comparable in respect of a purely software development service provider. For the same reason Ld. AR sought exclusion of KALS Infosystems Ltd. He also relied upon the following other decisions:
1. Trilogy E Business Services Software Ld. Vs. DCIT (ITA No. 1054/Bang/2001.
2. CSR India Pvt. Ltd. (TS-68-ITAT-2013(Bang.-TP)
3. Intoto Software India Pvt. Ltd., (ITA No. 1196/Hyd/2010)
4. Transwhich India Pvt. Ltd. Vs. DCIT (ITA No. 948/Bang/2011) iii. The learned DR, on the other hand, supporting reasoning of the TPO and DRP submitted that there is no need to exclude the above said company.
iv. We have considered the submissions of the parties and perused the materials on record. As can be seen, the TPO at page 53 of his order has categorized the assessee as a pure software development service provider. The comments of the TPO in this regard are extracted hereunder for the sake of convenience:
"Software Product Company A company who develops a software product by following all the steps involved in creating software as explained above from Domain Analysis to Testing. In this case, intellectual property belongs to the company. The products are sold generally on 5 ITA No. 1500/H/10 United On line Software Develop me nt (India ) Pvt. Ltd.
license basis wherein the right to use the software is transferred without giving the source code. These types of companies are not similar to the taxpayer, who is a pure service provider.
Pure Software Development Service Provider A pure software development service provider does a portion of the described software development life cycle. It does not generate any intellectual property for its own. The intellectual property generated belongs to the customer and not to the service provider. The taxpayer falls in this category. Thus comparables are also to be chosen from companies whose significant activities (> 75% of the operating revenues) are in the nature of or relate to software development services."
As can be seen from the above extracted portion, the TPO has himself mentioned that a pure software development service provider does not generate any intellectual property for its own. He has further stated that, the companies which sell their products generally on license basis wherein the right to use the software is transferred without giving source code cannot be comparable to pure software development service provider like assessee. It is the specific contention of the learned AR that Accel Transmatic Ltd., has sold IP rights for the software developed by it. Further, it is also the contention of the assessee that this company fails the RPT filter of more than 25% applied by the TPO himself. In case of Huawei Technologies India Pvt. Ltd. Vs. ITO (supra), the ITAT Bangalore Bench while examining the issue of comparability of the aforesaid company to a purely software development service provider has held as under:
"In so far Kals Info Systems Ltd., and Accel Transmatics Ltd., chosen by the TPO as comparables, this Tribunal in the case of Trilogy E-Business Software India Pvt. Ltd. (supra) has taken a view that these companies are not comparable to the software service provider companies as they are functionally different. The following are the relevant observations of the Tribunal in this regard:-
46. As far as this company is concerned, the contention of the assessee is that the aforesaid company has revenues from both software development and software products. Besides the above, it was also pointed out that this company is engaged in 6 ITA No. 1500/H/10 United On line Software Develop me nt (India ) Pvt. Ltd.
providing training. It was also submitted that as per the annual report, the salary cost debited under the software development expenditure was Rs.45, 93,351. The same was less than 25% of the software services revenue and therefore the salary cost filter test fails in this case. Reference was made to the. Pune Bench Tribunal's decision of the ITA T in the case of Bind view India Private Limited Vs. DC/, ITA No. ITA No 1386/PN/10 wherein KALS as comparable was rejected for AY 2006-07 on account of it being functionally different from software companies. The relevant extract are as follows:
"16. Another issue relating to selection of comparables by the TPO is regarding inclusion of Ka/s Information System Ltd. The assessee has objected to its inclusion on the basis that functionally the company is not comparable. With reference to pages 185-186 of the Paper Book, it is explained that the said company is engaged in development of software products and services and is not comparable to software development services provided by the assessee. The appellant has submitted an extract on pages 185-186 of the Paper Book from the website of the company to establish that it is engaged in providing of I T enabled services and that the said company is into development of software products, ete. All these aspects have not been factually rebutted and, in our view the said concern is liable to be excluded from the final set of comparables, and thus on this aspect, assessee succeeds. "
Based on all the above, it was submitted on behalf of the assessee that KALS Information Systems Limited should be rejected as a comparable.
47. We have given a careful consideration to the submission made on behalf of the Assessee. We find that the TPO has dra wn conclusions on the basis of information obtained by issue of notice u/s.133(6) of the Act This information which was not available in public domain could not have been used by the TPO, when the same is contrary to the annual report of this company as highlighted by the Assessee in its letter dated 21.06.2010 to the TPO. We also find that in the decision referred to by the learned counsel for the Assessee, the Mumbai Bench of ITA T has held that this company was developing software products and not purely or mainly software development service provider. We therefore accept the plea of the Assessee that this company is not comparable.
(e) Accel Transmatic Ltd.
48. With regard to this company, the complaint of the assessee is that this company is not a pure software development service 7 ITA No. 1500/H/10 United On line Software Develop me nt (India ) Pvt. Ltd.
company. It is further submitted that in a Mumbai Tribunal Decision of Capgemini India (F) Ltd v Ad. c/T 12 Taxman.com 51, the DRP accepted the contention of the assessee that Accel Transmatic should be rejected as comparable. The relevant observations of DRP as extracted by the ITAT in its order are as follows:
"In regard to Accel Transmatics Ltd. the assessee submitted the company profile and its annual report for financial year 2005-06 from which the DRP noted that the business activities of the company were as under.
(i) Transmatic system - design, development and manufacture of multi function kiosks Queue management system, ticket vending system
(ii) Ushus Technologies - offshore development centre for embedded software, net work system, imaging technologies, outsourced product development
(iii) Accel lT Academy (the net stop for engineers)- training services in hardware and networking, enterprise system management, embedded system, VLSI designs, CAD/CAM/8PO
(iv) Accel Animation Studies software services for 2D/3D animation, special effect, erection, game asset development 4.3 On careful perusal of the business activities of Acce/Transmatic Ltd. DRP agreed with the assessee that the company was functionally different from the assessee company as It was engaged in the services in the form of ACCEL IT and ACC EL animation services for 2D and 3D animation and therefore assessee's claim that this company was functionally different was accepted DRP therefore directed the Assessing Officer to exclude ACCEL Transmatic Ltd. from the final/ist of comparables for the purpose of determining TNMM margin. "
49. Besides the above, it was pointed out that this company has related party transactions which is more than the permitted level and therefore should not be taken tor comparability purposes. The submission of the Id. counsel for the assessee was that If the above company should not be considered as comparable. The Id. DR, on the other hand relied on the order of the TPO.
50. We have considered the submissions and are of the view that the plea of the assessee that the aforesaid company should not 8 ITA No. 1500/H/10 United On line Software Develop me nt (India ) Pvt. Ltd.
be treated as comparables was considered by the Tribunal in Capgemini India Ltd (supra) where the assessee was software developer. The Tribunal, in the said decision referred to by the Id. counsel for the assessee, has accepted that this company was not comparable in the case of the assessees engaged in software development services business. Accepting the argument of the Id. counsel for the assessee, we hold that the aforesaid company should be excluded as comparables. "
13. In view of the aforesaid decision of the Tribunal, Kals Info Systems Ltd., and Accel Transmatics Ltd. are to be excluded for the purpose of comparison while determining the ALP of the impugned transaction in this appeal. It is ordered accordingly."
Facts being materially same and since it pertains to the same assessment year, following the view adopted by the ITAT, Bangalore Bench in the aforesaid case, we are also of the view that this company cannot be comparable to the assessee.
For the very same reasons, II. KALS Info. Systems Ltd. also cannot be a comparable to the assessee. We, therefore, direct the AO/TPO to exclude the aforesaid companies from the list of comparability analysis.
III. Megasoft Ltd.
i. Objecting to the aforesaid company being treated as comparable, the learned AR submitted that as per the information obtained from the said company u/s 133(6) of the Act, the annual report of the company clearly indicates that it is also engaged in selling of products, namely, XIUS suit of packaged products. It was submitted that since segmental financial results in respect of product and services are available in respect of this company, if at all this company is to be treated as comparable, the TPO may be directed to consider the profit margin of software development services segment alone which is 16.97%, In respect of such contention, the learned AR relied upon the following decisions:
9 ITA No. 1500/H/10United On line Software Develop me nt (India ) Pvt. Ltd.
1. Trilogy E Business Software India Pvt. Ltd. (ITA No. 1054/Bang/2011)
2. LG Soft India P. Ltd. (TS-64-ITAT-2013(Bang.-TP)
3. Bearing Point Business Consulting Pvt. Ltd. (ITA No. 1124/Bang/2011)
4. Intoto Software India Pvt. Ltd. (ITA No. 1196/Hyd/2010)
5. Transwhich India Pvt. Ltd. VS. DCIT (ITA No. 948/Bang/2011)
6. Mercedez Benz research & development India Pvt. Ltd., (ITA No. 1222/Bang/2011).
7. Huawei Technologies India Pvt. Ltd. Vs. ITO (ITA No. 1338/Bang/2010) ii. The learned DR, on the other hand, submitted that the TPO having correctly considered the profit margin of the company by examining the annual report there is no need to modify the order of the TPO in this regard.
iii. We have heard the parties and perused the materials on record. On a consideration of the contentions raised by the assessee vis-à- vis materials on record as well as decisions of different benches of the Tribunal placed before us, it is quite evident that this company has two separate segments i.e. product and services. Therefore, if at all, the AO/TPO considers the aforesaid company to be a comparable, then, he is directed to consider software development services segment alone for comparability analysis.
IV, Infosys Technologies Ltd.
i. Objecting to this company, the learned AR submitted that under no circumstances, This company can be considered as comparable, to a small captive service provider like assessee. It was submitted that Infosys is engaged in diversified activities including products, 10 ITA No. 1500/H/10 United On line Software Develop me nt (India ) Pvt. Ltd.
consultancy & solutions. It commands a premium in the pricing of its products and services due to its goodwill, reputation and brand value. Further, due to scale of operations, Infosys enjoys economies of scale, which results in lower cost of infrastructural facilities and overheads. Finally, the learned AR submitted that the issue of comparability of Infosys to a captive service provider is no longer RES INTEGRA, due to following decisions of the different benches of the Tribunal:
1. Telcordia Technologies India P. Ltd. (ITA No. 7821/Mum/2011-Para 7.4)
2. Adaptee (India) Pvt. Ltd. Vs. DCIT (ITA No. 1801/Hyd/2009)
3. Patni Telecom Solutions Pvt. Ltd., Vs. ACIT (ITA No. 1846/Hyd/2012)
4. Trilogy E Business Services Software Ltd. Vs. DCIT (ITA No. 1054/Bang/2011 - Para 20)
5. Agnity India Technologies Vs. ITO (ITA No. 3856/Del/2010)
6. Agnity India Technologies Pvt. Ltd. Vs. ITO (High Court decision) ITA No. 1204/2011
7. Huawei Technologies India Pvt. Ltd. Vs. IT) (ITA No. 1338/Bang/2010) (AY 2006-07
8. Cincom Systems India P. Ltd., Vs. ACIT (ITA No. 761/Del/2012 (AY 2006-07)
9. Adobe Systems India Pvt. Ltd. (TS-320-ITAT-2011 (Del.)
10. Virtusa India Pvt. Ltd., Vs. DCIT (ITA No. 1962/H/2011)
11. Intoto Software India Pvt. Ltd. (ITA No. 1196/H/2010) ii. The learned DR, on the other hand, supported the orders of the DRP & TPO.
iii. We have heard the parties and perused the materials on record as well as decisions relied upon by the learned AR. Undisputedly, the TPO has accepted the fact that the assessee is purely a software development service provider to its AE whereas Infosys is not a captive service provider like assessee. It is a fact that Infosys is engaged in diversified activities and also engaged in development of products consultancy and solution. That apart, the size, reputation and brand value of Infosys, in no way makes it comparable to a small captive service provider like assessee. Therefore, following 11 ITA No. 1500/H/10 United On line Software Develop me nt (India ) Pvt. Ltd.
consistent view of different benches of Tribunal, we exclude this company from the list of comparables.
IV. Tata Elxsi Ltd. (Seg.) i. Objecting to the aforesaid company being treated as comparable, the learned AR submitted that the said company shall be rejected as comparable since it is a specialized embedded software development company. Further, he submitted that as per the information obtained from the said company u/s 133(6) of the Act, it was stated that due to the complex segments in which they are operating, it is not comparable to any other software services company. The AR relied on the following precedents in support of his submissions:
1. Conexant Systems India Pt. Ltd., (ITA No. 1429/Hyd/2010 and 1978/Hyd/2011)
2. Telcordia Technologies India P. Ld., (ITA No. 7821/Mum/2011)
3. Logica Pvt. Ltd. (IT(TP)A No. 1129/Bang/2011)
4. Huawei Technologies India Pvt. Ltd. Vs. IT) (ITA No. 1338/Bang/2010) AY 2006-07 ii. The learned DR, on the other hand, supported the orders of the DRP & TPO.
iii. We have heard the parties and perused the materials on record as well as decisions relied upon by the learned AR. W e find that in case of Huawei Technologies India Pvt. Ltd. Vs. ITO (supra), ITAT Bangalore Bench excluded this company relying upon the decision of ITAT, Mumbai Bench in case of Telcordia Technologies India Pvt. Ltd. (supra) pertaining to the same assessment year i.e. 2006-07.
iv. Following the view expressed by Bangalore and Mumbai Benches, of the Tribunal, which is in relation to A.Y. 2006-07, we are of the view that Tata Elxsi Ltd. is also to be excluded 12 ITA No. 1500/H/10 United On line Software Develop me nt (India ) Pvt. Ltd.
from the list of comparables while determining the, ALP of the international transaction.
5. The assessee has also objected to rejection of following comparables by the TPO:
1. VMF Softech Ltd.
2. TVS Infotech Ltd.
3. PSI Data Systems Ltd. (Seg.)
4. Larsen & Toubro Infotech Ltd.
5. Birla Technologies Ltd.
6. Goldstone Technologies Ltd.
7. Quintegra Solutions Ltd.
6. So far as the VMF Softech Ltd. is concerned, the learned AR submitted that the TPO has rejected this company by applying the employee cost filter. However, it was submitted that the employee cost of the company is approximately 62% of the sales. In this connection, the learned AR referred to Schedule 12 & 13 from the annual report of the company. It was further submitted that as per the information provided u/s 133(6) of the Act, the company has clarified that the major portion of the company's activities is outsourcing receipts from clients and no work has been outsourced by the company in India, but, have received works from foreign clients as their outsourcing.
6.1 In respect of TVS Infotech Ltd., it is submitted that though the AO has excluded this company on the ground that it is a persistent loss making company, but, in reality it satisfies RPT filter of the TPO. It is further submitted that the company has operating profit for FY 2004-05 as per its annual report.
6.2 In respect of PSI Data Systems Ltd., it is submitted that the aforesaid company has been excluded on the ground that software services include sale of products developed on its own and also, the company is under loss over the year. Further, as the company did not respond to notice u/s 133(6), it was rejected. In this context, the 13 ITA No. 1500/H/10 United On line Software Develop me nt (India ) Pvt. Ltd.
learned AR submitted that the company's software services segment has turnover of Rs. 53 crores whereas the TPO has not brought any evidence to prove that this company has its own product. The fact that the company has no R&D expenditure, as can be seen from the annual report, is suggestive of the fact that it is not involved in the product development. It was submitted that since the company has operating profit from software services segment for the FY 2005-06, it is to be considered as a comparable.
6.3 In respect of L&T Infotech Ltd., it is submitted that the company is not involved in product development, hence, the conclusion drawn by the TPO while excluding this company is improper.
6.4 In so far as Birla Technology Ltd., is concerned, it is the contention of the learned AR that TPO has wrongly rejected by this company applying RPT filter, It is submitted that the RPT of this company is only 3.07% of the total revenue. It is submitted that TPO by including reimbursement transactions has calculated RPT.
6.5 In respect of Golden Stock Technology Ltd., it is submitted that TPO has rejected this company as BPO service provider. The learned AR submitted that the statement relied upon by the TPO in response to the notice issued u/s 133(6) is contrary to the disclosures in company's annual report. It was submitted that during the year the company has income from software services and satisfies all selection criteria adopted by the TPO, hence, this company should be selected as comparable.
6.6 In respect of Quintegra Solutions Ltd., it is submitted that this comp-any was rejected by the TPO on the ground that it is predominantly on site company, however, as per the annual report of the company, the foreign exchange expenditure incurred is only 14 ITA No. 1500/H/10 United On line Software Develop me nt (India ) Pvt. Ltd.
4.25% of the export turnover. Hence, there is no defect in selecting the aforesaid company as comparable.
7. The learned DR, on the other hand, submitted that the TPO having rejected the aforesaid companies after undertaking objective analysis, the assessee's contentions should not be entertained.
8. We have considered submissions of the parties in respect of the aforesaid companies. As can be seen, before the DRP though the assessee has advanced detailed submissions for inclusion of the aforesaid companies, but, the DRP has simply brushed aside the same without considering in proper perspective. Therefore, in our considered view assessee's contention in respect of these companies requires reconsideration. However, it is to be stated here that so far as L&T Infotech Ltd. is concerned, this company is having a huge turnover of 790 crores and unlike the assessee it is not captive service provider. Therefore, the reasons for which Infosys Technologies Ltd cannot be treated as comparable to the assessee also equally applies to this company. In the aforesaid circumstances, except L&T Infotech Ltd., the comparability of the other companies selected by the assessee, but, rejected by the TPO is restored back to the file of the AO/TPO for considering afresh after affording due opportunity of being heard to the assessee.
9. Ground No. 11 is in respect of allowance of risk adjustment. It is a fact that the assessee has raised the issue of risk adjustment before the TPO as well as the DRP. In our considered opinion, this issue may become academic if the assessee's contention in respect of comparables selected/rejected by TPO is accepted. Therefore, we restore this issue to the file of the AO/TPO for considering afresh if need be, after working out the margin in terms with our directions issued in respect of comparables selected/rejected by the TPO. If, after excluding/including the comparables as per our directions, 15 ITA No. 1500/H/10 United On line Software Develop me nt (India ) Pvt. Ltd.
hereinabove, the assessee's margin is found to be within Arm's length, then, issue of risk adjustment may not arise. This ground of the assessee is considered to be allowed for statistical purposes.
10. In Ground No. 13, the assessee has challenged the action of the AO in excluding communication expenses from the export turnover while computing deduction u/s 10A of the Act. This issue is squarely covered by the decision of the Hon'ble Bombay High Court in case of CIT Vs. Gemplus Jewellery, 330 ITR 175 and ITO Vs Saksoft Ltd (313 ITR AT 353 (Chennai) SB). Following the ratio laid down in the aforesaid judgments, we direct the AO to exclude the communication expenses from export turnover as well as total turnover while computing deduction u/s 10A of the Act.
11. Ground No. 14 is in respect of levy of interest u/s 234B of the Act. Levy of interest u/s 234B of the Act being consequential in nature is not required to be considered at this stage. Hence, this ground is dismissed as infructuous.
12. Ground No. 15 is in respect of initiation of proceeding u/s 271(1)(c) of the Act. In our view at this stage it is premature to consider this ground. Hence, it is dismissed as such.
13. In the result, this appeal is considered to be partly allowed.
Pronounced in the open court on 20/06/2014
Sd/- Sd/-
(B. RAMAKOTAIAH) (SAKTIJIT DEY)
ACCOUNTANT MEMBER JUDICIAL MEMBER
Hyderabad, Dated: 20 th June, 2014
kv
16
ITA No. 1500/H/10
United On line Software Develop me nt (India ) Pvt. Ltd.
Copy to:-
1) United Online Software Development (India) Pvt. Ltd., 6-3-
1099/1100, 1 st & 6 th Floors, Babukhan Millenium Centre, Somajiguda, Hyderabad.
2) ITO, Ward 3(2), IT Towers, Masab Tank, Hyderabad.
3)DRP, Hyderabad.
4) The Addl. CIT(TP), Hyderabad
5)The Departmental Representative, I.T.A.T., Hyderabad.