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In the transfer pricing study report, the FAR analysis of assessee under the segment are as under:

"4.4 Provision of IT enabled services Pursuant to the merger of Red Hat Software Services Private Limited into Red Hat India, the Support Services Agreement with Red Hat US and Red Hat Ireland for the provision of support services was assigned to Red Hat India. As per the agreement, the support services provided by Red Hat India include support to customers in relation to the Red Hat subscriptions, including Red Hat Linux and Red Hat Enterprise Linux.
Red Hat India is remunerated on a cost plus 15% model for these services.
4.4.1 Functions performed Red Hat India Private Limited A summary of the functions performed and risks assumed by Red Hat India in relation to international transaction, as we have been given to understand by Red Hat India is given below:
Functions performed by Red Hat US Red Hat US is a premier provider of Linux and open source solutions, making high-quality, low-cost technology accessible. Red Hat US provides operating system platforms along with middleware, applications, and management solutions, as well as support, training and consulting services to customers worldwide and through top-tier partnerships. Red Hat US' open source strategy offers customers a long- term plan for building infrastructures that are based on open source technologies with a focus on security and ease of management. With its open source solutions, Red Hat US enables enterprises to integrate their operating system, middleware and hardware to develop an operating platform which is stable, secure and scalable. Red Hat US develops solutions using open source code technology and provides the same to its customers through a subscription model (i.e. customers have access to certain source codes available in the community after they buy subscriptions from the Red Hat Group companies). The services and products provided by Red Hat US are as follows: Red Hat Enterprise Linux: Red Hat Enterprise Linux is the leading platform for open source computing. It is sold by subscription, delivers continuous value and is certified by top Enterprise hardware and software vendors. From the desktop to the datacenter, Enterprise Linux couples the innovation of open source technology and the stability of a true enterprise-class platform. Red Hat Enterprise Messaging, Real time Grid ('MRG): Red Hat Enterprise MRG is a next-generation IT infrastructure incorporating Messaging. Realtime, and Grid functionality. It offers increased performance, reliability, interoperability, and faster computing for enterprise customers.
Red Hat Global Support Services: It is an around-the-clock around- the-world network of the most experienced, motivated and knowledgeable Linux and open source software support engineers. It allows customers to plan, deploy and scat with confidence that the systems have the resources behind them. Red Hat Group serves organisations that are increasingly looking to Linux and open source technologies and standard to deliver the cost savings. security, capabilities, performance, portability and stability they need to compete in today's market. Red Hat Group is the world's foremost expert in Linux and open source and has accumulated staff knowledge and experience around delivering and supporting those technologies. Red Hat Global Support Services allows customers to virtually extend their in-house expertise and deploy Linux with confidence.
Red Hat Training Programs: Red Hat training programs offer the most current and accurate hands-on training courses and the most respected certifications in the Linux space. Red Hat Consulting Services: The employees and engineers of Red Hat US and its affiliates bring substantial experience and expertise in a number of areas to enable solutions that leverage Red Hat Enterprise Linux. Red Hat Global Professional Services ('GPS') offers a full set of consulting services for each phase of an IT deployment from assessment and implementation right through to upgrade planning. GPS also offers custom engineering and support services for a wide range of technologies, including the GNU Pro suite of Red Hat India Private Limited development tools, the Cygwin Linux emulation package, and custom embedded Linux solutions for a variety of target platforms. Red Hat Industry Solutions: Red Hat US provides industry specific solution to boost the application of open source tools and products. Red Hat US is a leader in open source solutions for Financial Services companies, supports open source architecture, provides security offerings, etc. Red Hat US provides specific solutions to the Government department, in the education field, telecommunication and other industries.