branches into four categories viz., where the-
(a) Population figures and data on RBI licence are available;
(b) Population figures not available but data ... RBI licence available;
(c) No data at all available with regard to population figure & RBI licence
and (d) the rural branches in respect
considered as separate
centres in Delhi. However, for reporting of data to the RBI, all these centres
will continued to be classified as single Centre ... dbie.rbi.org.in may be referred to.
The link is also accessible from RBI's main website (www.rbi.org.in) under
processed."
Thus, the approval granted by RBI to SCB was only for
processing of data. Regarding Assessing Officer‟s objection that
assessee has provided ... interests are
protected. He again referred to the approval letter of RBI,
wherein RBI has clearly required SCB India to observe the
following terms
appellant and SPL
for data processing at SPL's Data Centre at Singapore vide letter of RBI dated
December 19, 2001 subject to conditions ... Agreement and
approval of the RBI referred to earlier, the appellant claimed that under the
agreement SPL was processing data for the appellant in Singapore
data processing at SPL's Data Centre at Singapore
4 ITA No. 4342&4392/Mum/2009
Standard Chartered Bank
vide letter of RBI ... appellant and SPL for data
processing at SPL's Data Centre at Singapore vide letter of RBI dated
December 19, 2001 subject to conditions
provided by the RBI would not constitute a valid CUP data, since the RBI does
not take into account the transfer pricing provisions to determine
provided by the RBI would not constitute a valid CUP data, since the RBI does
not take into account the transfer pricing provisions to determine
months of
the impugned RBI letter failing which its certificate of registration would lapse
unless otherwise approved by the RBI. The Assessing Officer opined that ... appellant has duly reported
operational status to RBI.
5.2.9 Accepting that the software for processing data was operational, it has
now to be seen whether
study assessee adopted on the basis of PLR data of Indian banks
maintained by RBI and it adopted the maximum interest rate
range at which
submissions that approval of royalty rates by SIA / RBI would constitute
CUP data and the transactions were to be considered at Arm's Length
