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          5     References of the exhaustive evidences to establish the above


 S. Description of           Explanation in brief on         How are            Benefits Derived                   Back-ups        available/
No. service                  the type of                     these                                                 Submitted on Sample Basis
                             services received               services
                                                             received

     Management
     Services

 1   Fostering and
     developing
     creativity
     1)Providing            - Assessee is provided          E-mail        and                                     The appellant has got access to
     assistance   on        access to case studies,         website / ftp site                                    research materials, presentations
     how to foster          reports and related material    access,                                               available on CMI facility. The
     creativity             which     reflect    creative   presentations,     Up to date news on global          appellant has received services in
                            capability at a world wide      research           accounts and provision of case     areas such as pharmaceutical and
                            level.                          materials          studies and examples to market     healthcare industry, information
                            - As and when requested,                           to clients, prospective clients    on trend reviews which covered
                            Assessee receives reels of                         and media. This leads to           consumer        mood,     shopping,
                            international work done                            decrease in the effort for local   advertising, brand attitudes etc.
                            by the network, and case                           management initiatives relating    All such research information has
                            studies on successful /                            to the creative direction and      enabled      the     appellant   in
                            award winning / pitch                              implementation       of    local   understanding various trends
                            winning campaigns to pass                          creative strategies.               prevailing in the market and thus
                            on to media and clients and                        Further, such information/         enabling it in presenting a better
                            an access to similar material                      expertise is not available with    offering to its clients.
                            on the McCann World                                the assessee and in order to
                            Group worldwide site.                              serve its clients better, the      This has helped the appellant in
                                                                               assessee has to leverage the       formulating creative strategies,
                                                                               information/ details/ news/        developing            competitive
                                                                               updates from the McCann            intelligence, thus adding value to
                                                                               Group.                             the work done by the appellant
                                                                                                                  for its clients.
                                                                                                                  As provided on pages 643 to
                                                                                                                  662 of paperbook,

     2)       Providing     Assessee employees get an        Workshops/                                            The agenda of workshop /
     regular training       opportunity and platform         Conferences                                           conference       and        the
     and           skills   to participate in global /                                                             presentations on Internal Audit
     development            regional brand meets, and                                                              Control process is attached.
     workshops       for    creative     brainstorming                                                             (Refer pages 372 to 410 of
     creative directors     workshops.                                                                             paperbook)

                                                                                                                   '- McCann India's executive
                                                                                                                   director, MrPrasoon Joshi had
                                                                                                                   participated in conferences held
                                                                                                                   in cities like London and Manila
                                                                                                                   amongst                   others.
                                                                                                                   The appellant has benefitted
                                                                                                                   from these conferences by way
                                                                                                                   of receiving following services:
                                                                                - These regular training and
                                                                                skill development workshops
                                                                                                                   - Information on how to
                                                                                provide Assessee's employees
                                                                                                                   maintain an effective internal
                                                                                an opportunity to share ideas
                                                                                                                   audit                  process
                                                                                and interact with creative
                                                                                heads at a global level, and
                                                                                                                   - Update/ information on how
                                                                                gain better understanding of
                                                                                                                   McCann India can benefit by
                                                                                global ideas, which eventually
                                                                                                                   way of receiving IT services
                                                                                assist in better adaptation.
                                                                                                                   from group company and how
                                                                                                                   to effectively utilize tools/
                                                                                                                   processes such as My project,
                                                                                                                   My timesheet, My workgroup
                                                                                                                   etc.

                                                                                                                   - IPG treasury services which
                                                                                                                   focus on effective management
                                                                                                                   of liquidity, capital structure,
                                                                                                                   cash and debt reporting etc.

                                                                                                                   - Such conferences/ seminars
                                                                                                                   were aimed at imparting them
                                                                                                                   with the latest insights in the
                                                                                                                   world of advertising and to help


                                                                                                            the local McCann offices serve
                                                                                                            their customers in a better
                                                                                                            manner.




    3)       Providing    The Assessee is provided      Client e-mails   - Local team obtains more          - Presentation depicting the
    assistance       in   with big ideas on foreign                      clarity on the larger picture      print commercials received from
    developing            brands. Access to similar                      with assistance from the           McCann World Group for
    creative concepts     case studies, brand idea                       group      on      developing      L'oreal    advertisements     is
    and ideas for use     documents,         creative                    creative concepts and ideas        attached as pages 457 to 461
    when      servicing   examples,                                      enables                quality     of paperbook.
    clients.              sharing      of   common                       production,      which      is
                          creative or elements.                          sometimes, not affordable by
                                                                         local clients or available
                                                                         locally.
                                                                         For example: Loreal creatives
                                                                         were shared with the assessee
                                                                         which were used in India with
                                                                         very minor modifications/
                                                                         customization to suit the
                                                                         Indian market.
2   New Business
    Targeting
    Assistance

    (1) Assistance on     McCann World Group            Emails                                              The     detailed    presentations
    targeting       of    creates template of E-                                                            shared by the group companies
    potential             mails     communication,                                                          are attached as pages 412 to
    multinational         which Assessee localises                                                          431 of paperbook.'-           The
    clients               for targeting clients in                                                          appellant received client pitch
                          India.                                                                            presentations for targeting Intel
                                                                                                            and Barclays from its group
                                                                                                            company.- Such presentations
                                                                                                            were developed by its group
                                                                         - Assessee has received
                                                                                                            company        specifically    for
                                                                         assistance on targeting of
                                                                                                            McCann India chalking out
                                                                         potential        multinational
                                                                                                            plans with respect to awareness,
                                                                         clients such as Intel, Barclays,
                                                                                                            engagement and national level
                                                                         Compaq etc
                                                                                                            promotion for such potential
                                                                                                            clients. - Getting assistance by
                                                                                                            way of sharing of work
                                                                                                            methodologies         such      as
                                                                                                            establishing demand chain and
                                                                                                            how that leads to creation of
                                                                                                            innovative ideas for McCann
                                                                                                            India's clients.


    (2) Provision of     - Assessee is provided        E-mails, Online                                    During the relevant year, the
    material for use     access to global case         access.                                            appellant     has     downloaded
    in       targeting   studies,       credentials,                                                      reports focusing on retail
    potential            category information etc.                                                        industry and in particular the
    business                                                                                              buying habits of consumers in
                         - Assessee participates in                                                       India     and      other      Asia-
                         global            business                                                       paccountries.Refer page 141
                         development      meetings                                                        to    147      of    paperbook.
                         which identify new areas                                                         - The appellant has downloaded
                         of opportunity which can                                                         research materials available
                         be applied to the Indian                                                         through the CMI. One of such
                         market.                                                                          reports related to the fast
                                                                                                          changing      trends    in     that
                         -    Access  to    global                                                        industry. Details of reports
                         information     databases                       -enriching pitches for new       downloaded are attached as
                         such as the Gun Report                          clients, better servicing of     pages 201 to 431 of paperbook.
                         library, WARC, CMI on-                          existing    clients,   better    '- The Assessee has access to
                         line and offline etc.                           understanding of trends in       Center       for      marketing
                                                                         the markets                      intelligence
                         - Case studies done by                                                           information(CMI)
                         brands in other countries,                                                       database.          CMI      facility
                         category       information,                                                      provides access to McCann
                         research,    studies    are                                                      India      with     respect       to
                         received by the Assessee.                                                        background research materials
                                                                                                          regarding potential clients.
                                                                                                          - Through CMI, McCann India
                                                                                                          has access to research materials
                                                                                                          with respect to particular
                                                                                                          industries/ sectors which help
                                                                                                          in targeting potential clients and
                                                                                                          serving the existing clients
                                                                                                          better.

    (3) Provision to     Assessee is provided with     E-mail and        - Enriches business and          The name of personnel who
    assessee of          constant training through     online access.    category understanding           travelled during the year is
    training/            E-mail, online access, new                      which is invaluable in new       attached as page 434 of
    techniques on        techniques which enrich                         business acquisition.            paperbook.
    new business         both new business and                           - For example: Roll out of       '-The employees of appellant
    development.         existing client activity.                       new planning toolkits. Series    attended series of workshops/
                                                                         of workshops and training        training programmes during the
                                                                         programmes were conducted        financial year 2006-07.
                                                                         for local employees that
                                                                         facilitated in adding value to
                                                                         the new business process.
3   Strategic
    Planning
    Assistance
    (1) Provision of     - Assessee is provided        Online      web                                    - The reports shared by McCann
    background           access    to    centralised   access                                             Group/ downloaded from the
    research             Online      web      access                                                      database on the retail and
    materials for use    marketing      intelligence                     - This background research       tourism sector on a sample basis
    in       targeting   online.                                         material on potential clients    are attached as pages 153 to
    potential     new    -       This      includes                      helps Assessee to have           371       of       paperbook.
    clients              information, background                         superior consumer, industry
                         and knowledge research                          and trends understanding.        - The appellant has received
                         on companies, industry,                         - For example: Assessee was      research materials on medical
                         consumer trends, reports                        provided research material on    tourism industry in India which
                         and white papers.                               the local and regional retail,   highlights the good growth
                                                                         tourism, health markets etc      prospects of that industry.
                                                                         for customers like Dabur, LG     Refer pages 192-195 of
                                                                         etc                              paperbook. Such research
                                                                                                          materials have helped the
                                                                                                          appellant     in     targeting


    2) Provision of        - Research material on           Online      web                                       clients which benefit out of
    research               industries             like      access      and                                       growth prospects in this
    materials related      ad/marketing,     apparel,       emails              - Availability of such material   industry.
    to       particular    beverages, drugs, finance,                           helps Assessee to have
    industries      and    food,    home    products,                           superior consumer industry        - Further, McCann Group
    markets          to    leisure, personal care,                              and trends understanding.         has    developed    several
    facilitate             retailing,     technology,                           - It also enables Assessee        unique proprietary tools,
    targeting         of   travel and other are done                            to gain information from          some    of   them     being
    potential clients      by the group and are made                            vendors          such       as    'McCann Demand Chain',
    in            those    available to the group                               eMarketer,          Forrester,    'Demand Health Check',
    industries      and    members          including                           Gartner,                  IDC     'Brand Clout', 'Demand
    markets.               Assessee.                                            &Euromonitor etc. at              Dashboard',    'Media     in
                                                                                discounted rates.                 mind',   'McCann     Pulse',
                                                                                                                  'Fusion    3.0    '     etc.
                           - Online access to global        Online access
                                                                                                                  - McCann World group provides
                           case studies across the
                                                                                                                  access to the aforementioned
                           McCann offices in order to
                                                                                                                  tools to its group companies
                           illustrate the application                           - Understanding of different      around the world including
                           and approach of high value                           approaches and learning from      McCann India. The tools help
                           ideas & high value works.                            high value ideas assist the       the Indian team in developing
                           This     covers    different                         Assessee to service its clients   appropriate creatives and other
                           categories and varying                               in accordance with global         materials which would have
                           marketing problems that                              standards.                        persuasive impact on consumers
                           can      be    solved     by
                                                                                                                  and in creating customer
                           communication.
                                                                                                                  demand in a cohesive, effective
                                                                                                                  and optimized manner etc.
                           -    World     Advertising       Online access
                           Research Centre- Online
                           access to WARC portal.
                           Provides access to a fully
                           searchable   archive    of
                           specific advertising and                              - Helps Assessee learn form
                           marketing          related                           other companies' mistakes
                           material.                                            through research reports and
                                                                                provide                 better
                           - The content includes                               recommendations      to     its
                           over 25,000 articles,                                clients.
                           case studies, research                               - This enables Assessee to
                           reports            and                               have better understanding of
                           summaries     covering                               target audience, global trend
                           all areas of marketing                               etc.
                           communications
                           drawn from more than
                           30 leading content
                           sources worldwide.

4   Media Support
    Services

    (1) Development        - Assessee receives tools        -     Assessee's                                      - Medialab which is a media
    and provision of       and guidance on their            employees have                                        planning     software      helps
    planning      and      implementation            and    been provided                                         McCann India in organising
    research     tools     usage.-      For    example:     username and                                          media spends for its clients.
    and information        Media       and      strategic   password       to                                     These unique proprietory tools
    about media in         planning tools (Awareness        access        the                                     help McCann India in coming to
    the     Assessee's     Planning Software). This         website        to                                     an estimate for the advertising
    target markets.        software allows to do            download the        - Better media planning for       budgets for its clients and also
                           mathematical modelling of        tools. - After      existing clients helps in         helps in measuring the market
                           the        input        media    installation, the   getting new clients by            response to such advertisment
                           investment and the market        users get the       showcasing the advanced           spends.
                           response in terms of the         license     from    tools.
                           consumers         awareness      these sites via                                       Screen  shots   of   website
                           parameters. This aids in         email.                                                enclosed as pages 136 to 138
                           establishing the return on                                                             of paperbook.
                           investments of clients'
                           media investments and
                           deciding on the investment
                           levels in the future.


                         - Assessee is provided          CDs, DVDs and
                         access    to     McCann         training
                         Planning     CDs    and                            - There is a significant value
                         training.                                          addition to the process of
                                                                            brand media analysis with
                         - Toolkits - A set of tools                        help of McCann Planning
                         to address various brand                           Toolkits.
                         strategy issues.
                         - Assessee is provided          -     Assessee's
                         access      to     infocentre   employees have
                         website          proprietary    been provided
                         information.                    with username      - This enables Assessee to
                                                                            address international client
                         - This website is a global      and password
                         repository      of     media    to access this     requests   for   data   and
                         planning              related   site        and    information with the help of
                         information and is a portal     download     all   study tools manuals and
                                                                            updates.
                         of access to the documents      information
                         on all available tools.         required.

5   Financial
    Administration
    Services

    (1) Assistance on    Assessee     is    provided     E-mails,                                            - The employees of Assessee
    general              templates      for   overall    presentations,                                      have attended several work-
    accounting           control of all revenues and     meetings,                                           shops   during   the   year.
    methods,      cost   expenses. These include         phone
    accounting                                           conferences,                                        - On sample basis, a detailed
    methods,             -    Centralised    capital     workshops and                                       itiniary of the work-shop
    preparing     and    expenditure      budgeting      online access.                                      attended by Manoj Singh, the
    monitoring           system and monitoring of                                                            CFO of the assessee company is
    periodic             expenses against budget.                                                            attached on pages 372 to 373 of
    profitability                                                                                            stay    petition    paperbook.
    analyses,            - Forward Plan calendar
    budgeting     and    year budget & three                                                                 - Further, certain emails
    business             revisions are there to take                                                         substantiating the receipt of
    planning             cognizance of change in                                                             services has also been attached
    methods,capital      the environment & its                                                               as pages 660 to 710 of
    expenditure          effect on the business plan.                                                        paperbook.
    requirements,and     Centralised        extensive
    financial            annual budget preparation
    forecasts            exercise for each calendar
                         year, including manpower
                         numbers & updating the
                         same.                                              - This assistance helps
                                                                            Assessee      in   improving
                         - Monthly & quarterly                              corporate        governance,
                         accounting   information                           transparency and effective
                         directly into Hyperion.                            reporting systems along with
                                                                            assisting in aligning with
                         - Comparison with budgets                          international     accounting
                         and     seeking   sensible                         standards.
                         commentaries           on
                         variations.

                         - Assisting & examining
                         accounts receivable based
                         on data submitted &
                         raising   queries   where
                         amounts are substantially
                         old.

                         - Input of unit profitability
                         data for each Assessee
                         division into Khalix on a
                         monthly                basis.

                         -      Preparing      client
                         profitability as per the
                         Khalix       format      for
                         Hyperion            clients.

                         - Prescribing a COA &
                         SP&P reduces leeway for


                       unit managers in reporting
                       their              results.
                       - Local management uses
                       IPG policies to inculcate
                       proper           corporate
                       governance. Internal audit
                       compliance & test on our
                       internal control system
                       through           Regional
                       Monitoring Control (RMC
                       team representative from
                       the      Asia      Pacific)

                       -             Mandatory
                       monthly/quarterly
                       statement  book   close
                       checklist.

                       - Monitoring on a monthly
                       basis all client contracts.

                       - Discipline enforce to the
                       entire organisation as
                       senior management has to
                       sign off detailed quarterly
                       management
                       representation      letters.

                       - New system for recording
                       WIP & aging analysis.

                       - Revenue recognition
                       concepts examine   in
                       depth.

                       - Conference calls with US
                       &        Asia       Pacific
                       controllers/RMC Team to
                       comprehend requirements
                       & comply with the same.

                       - Coaching through web
                       conference.

(2) Arrangement        - McCann World Group           Corporate                                            - During the said period the
of         financing   provides McCann India          Guarantee/                                           guarantee provided to McCann
facilities      with   treasury support in the        financial          - Guarantee given by McCann       India amounts to INR 8.8
banks and other        form of credit lines,          assistance         Group to CitiBank for the         Crores with respect to Citibank's
institutional and      guarantees etc as and                             credit facility   availed by      Overdraft facility being availed.
governmental           when needed.                                      McCann India                      Refer pages 436 to 440 of
bodies                                                                                                     paperbook.


3) Assistance on       - Advice and direction are     Conference         MEM and IPG assisted              Treasury        Management
treasury               provided to Assessee for       calls & visit by   Assessee in the following:        presentation attached  on
management             monitoring and investing       MEM/IPG                                              pages 404 to 410 of
procedures and         surplus funds.                 teams              • Met with two multinational      paperbook.
techniques                                                               banks, Citibank and HSBC to
                       -   For     this    support,                      see what capabilities and
                       Assessee team enters into                         services they could provide to
                       discussions            with                       Assessee
                       IPG/MEM Treasury &
                       various          investment                       • Met twice with their Merrill
                       advisors in India.                                Lynch investment advisor
                                                                         and reviewed the investment
                                                                         portfolio for appropriate risk,
                                                                         conformity to IPG policy and
                                                                         duration.

                                                                         •      Provided     portfolio
                                                                         information and valuation
                                                                         data to PwC for annual audit


    (4)     Financial      Assessee personnel are         Web                                                  "Closing Process" Presentation
    awareness/             provided        education      conference,        Assessee      employees are       attached as pages 443 to
    education      of      through web conference &       training           provided ongoing training         446 of paperbook.
    personnel              personnel sent abroad for                         and     understanding    on
                           training.                                         financial issues.

6   Human
    Resource
    Management



    1)       Providing     - Assessee is provided         Conference call,   - This enables Assessee to        - Presentation on McCann
    assistance     for     assistance when recruiting     on         line    standardise      and       have   Worldgroups'    objectives  to
    recruiting    new      new       personnel      by    demonstration      consistent           evaluation   develop strong talent and
    personnel              providing         Assessee's   of the tool,       parameters       for      every   provide them with various
                           human resource team            access to the      candidate through multiple        trainings through seminars and
                           access to job portal, which    website    with    rounds of interviews              e-learning     programs      is
                           help in understanding the      multiple user                                        attached as pages 447 to
                           job requirements and           ids        and                                       456        of      paperbook.
                           establishing the candidates    passwords.
                           ability to match the                                                                -     It    provides       people
                           requirement.                                                                        management skills programs,
                           - The access to this portal                                                         better negotiation skills, project
                           helps    in    Recruitment                                                          management etc.
                           Architect where users can
                           view, create, download and
                           use the interview guides -
                           interview          prompts,
                           appropriate      evaluation
                           questions etc.




    (2)     Providing      - Assessee is provided with    Conference         Additional protection from
    assistance   with      draft contracts on code of     Calls              employee misconduct and
    structuring and        conduct       which      all                      subsequent liability thereof.
    implementing           employees need to sign.
    employment             These contracts abide the
    contracts              employees to a superior
                           code of conduct.




                         Explanation in brief                                                                       Back-ups available/
Description of              on the type of                 How are these                                           Submitted on Sample
   service                services received               services received          Benefits Received                    Basis


Coordination
Services
Providing
Assessee with the
opportunity    to
service McCann
Group's
multinational
clients in its
local market.


(1) Client specific   - In the case of many           E-mails,                                               - The appellant received
strategies    and     global brands, appellant        presentations,                                         assistance from global
account plans         is provided a strategy for      meetings,      phone,                                  account      teams      for
                      the Indian market for           conversations,                                         servicing its international
                      adaptation / execution.         conferences,                                           clients. These services
                      - Appellant also receives       workshops etc.                                         helps the appellant in
                      strategic       guidelines,                              - This helps appellant to     discussing with the global
                      templates, direction and                                 have        a      better     account team, various
                      guidance to build client                                 understanding of what         issues       faced       by
                      specific strategies.                                     is likely to work / not       international clients in
                                                                               work for the brand            India and any remedial
                                                                               leading to ease of            measures that need to be
                                                                               operations, synergy in        taken.
                                                                               strategy along with           - The appellant has also
                                                                               efficiency in operations.     received guides for its
                                                                               - The examples are            global client Nestle. This
                                                                               information received for      helps the appellant in
                                                                               L'Oreal brands, GM            communicating           the
                                                                               brands , Coca Cola and        benefits      of     Nestle
                                                                               Maybelline.                   products better in its
                                                                                                             advertisements.

                                                                                                             Email on sample basis
                                                                                                             submitted before the TPO
                                                                                                             vide Submission dated
                                                                                                             September 21, 2010.
                                                                                                             Refer pages 746 to 756
                                                                                                             of paperbook.



(2)   Worldwide       - Some of the brands are        Links,        e-mails,   - Monthly status report
account               globally run, for which,        presentations,           on the work carried out       - The global account
management            the account management          meetings,      phone,    for these clients by the      management team of
                      team of McCann India            conversations,           group is shared within        L'oreal shared certain
                      report to the regional or       conferences,             the network. These            advertisements with the
                      global              account     workshops etc.           services     are      good    appellant which were
                      management             team.                             'thought starters' for        used by it in releasing
                      Hence,       the      global                             creative development of       advertisment prints for
                      account       management                                 Assessee. Additionally,       L'oreal    in     India.
                      team is a single point of                                it helps in generating        Such presentations are
                      contact         for       all                            revenues,       improving     attached as pages 457
                      information on these                                     agency ratings, helps in      to 461 of paperbook.
                      brands all over the world.                               providing             good
                      - Assessee leverages on                                  exposure and growth to
                      the brand work done in                                   Assessee     staff     and
                      other     regions.      This                             brings in efficiency in
                      information is sourced                                   operations.
                      from the global account                                  - Examples: Print, radio
                      management team and                                      and              television
                      other group companies.                                   commercials           were
                      Strategic        guidelines,                             shared with Assessee for
                      templates,        direction,                             the above mentioned
                      discussions with senior                                  global clients.
                      level clients is carried out
                      by the global account
                      management team.


(3)Providing         - Assessee works with        E-mails,               - There is increase in       - The appellant benefits
centralised          teams in London, Paris,      presentations,         revenues, agency             by getting access to
creative direction   New York and Bangkok         meetings, phone,       ratings, exposure and        global contracts
and creative co-     who provide inputs and       conversations,         growth of the Assessee       entered by McCann
ordination to        direction in the             conferences,           staff, ease of operations,   Worldgroup with its
facilitate the       development of strategy,     workshops etc.         synergy in strategy,         international clients. It
provision of         creative guidelines,                                efficiency in operations.    helps the appellant in
cohesive,            direction etc.                                      - For example- Assessee      finalising the terms of
coherent and                                                             worked with McCann           contracts with such
consistent                                                               teams in other regions       international clients in
creative content                                                         for L'Oreal, Nestle, GM      India.
in a                                                                     and Coca Cola.
multinational                                                                                         Sample attached as
client's                                                                                              pages 462 to 465 of
worldwide                                                                                             paperbook.
advertising
strategy

(4)Performing        - Global client fee          E-mails, meetings,     - Better negotiation         Sample attached as
centralised          structure, information on    phone conversations,   platform and increase in     pages 462 to 465 of
commission and       total hours / resource       etc.                   revenue for Assessee.        paperbook.
fee negotiations     allocation on clients is                            Example: Nestle fee
                     disclosed. Such                                     structure in other
                     information helps to                                markets is made
                     build the basis of fee                              available to Assessee.
                     negotiations.                                       - The L'Oreal-McCann
                                                                         Fee is discussed and
                                                                         agreed between L'Oreal
                                                                         Paris and McCann Paris
                                                                         and the same is
                                                                         subsequently rolled out
                                                                         to all the McCann
                                                                         offices.