INFOR (INDIA) PRIVATE LIMITED ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-2(1), HYDERABAD

Per Shri D.S.Sunder Singh, Accountant Member :

1. On the facts and in the circumstances of the case and in law, the Ld. Transfer Pricing Officer i.e the Deputy Commissioner of Income-tax - Circle - 2(1), Hyderabad (hereinafter referred to as the Ld. TPO') and the Ld. AO under the directions issued by Hon'ble DRP, erred in making an addition to the Appellant's total income of INR 4,60,53,538 (based on the provisions of Chapter X of the Income-Tax Act, ('the Act') and the said additions being wholly unjustified are liable to be deleted.

2. On the facts and in the circumstances of the case and in law, the Ld. TPO erred and the Hon'ble DRP further erred in upholding/ confirming the action of the Ld. TPO in incorrectly including / selecting the following companies as comparables, without appreciating that the said companies were functionally dissimilar to the Appellant, which ought to have been excluded for the following reasons which are independent of and without prejudice to one another i.e. the said companies were engaged in product development, do not have required segmental Information, have huge turnover, presence of brand and intangibles, have incurred huge R & D Expenditure, have significant Onsite Expenses, hold significant inventory, have abnormal profits, have insufficient information in public domain, have significant Related Party Transactions, peculiar economic circumstances, and earn fluctuating margins: i) Infosys Limited ii) Larsen & Toubro Infotech Limited iii) Mindtree Limited iv) Tata Elxsi Limited (Seg)

S.A.No.98/Hyd/2020, A.Y.2015-16 M/s Infor (India) Private Limited, Hyderabad v) Persistent Systems Limited vi) Thirdware Solution Limited vii) Cybage Software Private Limited viii) Aspire Systems (India) Private Limited ix) Nihilent Technologies Limited x) Inteq Software Private Limited xi) Rheal Software Private Limited xii) R.S.Software (India) Limited xiii) Infobeans Technologies Limited

3. On the facts and in the circumstances of the case and in law, the Ld. TPO erred in and the Hon'ble DRP further erred in upholding / confirming the action of the Ld. TP0 in incorrectly rejecting the following companies which ought to have been included as they are engaged in software development services as comparables, without appreciating that the said companies fulfilled all the filters and were functionally comparable to the Appellant:

i) Evoke Technologies Private Limited ii) Infomile Technologies Limited iii) 12T2 India Limited iv) Kireeti Soft Technologies Limited v) SugarSoft India Limited vi) Akshay oftware Technologies Limited vii) Harbinger Systems Private Limited 4. Without prejudice to the above grounds on rejection of functionally dissimilar comparable companies, on the facts and in the circumstances of the case and in law, the Ld. TPO erred by incorrectly computing the margin of the following comparable companies i.e. (i) Nihilent Technologies Limited, (ii) Thirdware Solution Limited iii) Sasken Communication Technologies Ltd.

5. On the facts and in the circumstances of the case and in law, the Ld TPO erred in and the Hon'ble DRP further erred in upholding / confirming the action of the Ld TPO in rejecting the transfer pricing analysis / study prepared by the Appellant for the software development segment, without appreciating that none of the conditions mentioned in clauses (a) to (d) of Section 92C(3) of the Act were satisfied. The Ld. TPO further erred in and the Hon'ble DRP further erred in upholding / confirming the action of The Ld. TPO in applying inappropriate filters and conducting a fresh benchmarking which was erroneous and liable to be rejected.

6. On the facts and in the circumstances of the case and in law, the Ld TPO erred in and the Hon'ble DRP further erred in upholding / confirming the action of the Ld TPO in not allowing risk adjustment in accordance with the provisions of Rule 10B of the Income-tax Rules, 1962 to account for differences between the S.A.No.98/Hyd/2020, A.Y.2015-16 M/s Infor (India) Private Limited, Hyderabad international transactions undertaken by the Appellant, being a captive unit, and those undertaken by the comparables.

7. On the facts and in the circumstances of the case and in law, the Ld TPO erred in and the Hon'ble DRP further erred in upholding / confirming the action of the Ld. TPO in considering bad debts, provision for bad and doubtful debts and provision for warranty as non operating expenditure while computing the PLI of the comparables.

8. On the facts and in the circumstances of the case and in law, the Ld TPO erred in and the Hon'ble DRP further erred in upholding / confirming the action of the Learned TPO in not allowing Working Capital Adjustment in accordance with the provisions of Rule 10B of the Income-tax Rules.

9. On the facts and in the circumstances of the case and in law, the Ld TPO erred in and the Hon'ble DRP further erred in upholding / confirming the action of the Ld TPO in: Considering the receivables from Associated Enterprise (AE) as a (i) separate international transaction, Making an adjustment with respect to interest on the receivables (ii) from AE.

S.A.No.98/Hyd/2020, A.Y.2015-16 M/s Infor (India) Private Limited, Hyderabad / appreciating the facts of the case and, the submissions made by the Appellant and therefore, the said impugned orders, being bad in law are liable to be quashed or alternatively set aside. The Appellant craves leave to add, alter, vary, omit, substitute and or amend the above grounds of appeal (which are without prejudice to one another) at any time before or at the time of hearing of the appeal so as to enable the Honorable Members to decide this appeal according to law.

3. Ground No.1, 5 and 13 are general in nature, hence no separate adjudication is considered necessary.

4. Ground No.6, 7 and 8 are not pressed by the Ld.A.R during the appeal hearing and hence ground No.6,7 and 8 are dismissed as not pressed.

5.2. The international transactions entered by the assessee as under:- Nature of transaction Amount (Rs.) Software distribution and related services 30,04,53,550 (product supply fee, one point support, PSO recharges, royalty expenses, customer support, management fee and annual maintenance fee) Software development services 46,69,84,481 Related IT services 87,99,18,654 Shared services 29,77,48,104 Reimbursement of expenses 1,22,99,059 Recovery of expenses 23,14,792

S.A.No.98/Hyd/2020, A.Y.2015-16 M/s Infor (India) Private Limited, Hyderabad 5.3. The assessee carried the economic analysis and has summarized the international transactions as under:- Nature of Amount (Rs.) MAM PLI Margin Margin of International of comparabl Transaction taxpayer es Software 30,04,53,550 RPM GPM 50.70% 6.94% distribution and related services Software 46,69,84,481 TNMM OP/OC 15.43% 10.70% development services Related IT services 87,99,18,654 TNMM OP/OC 15.32% 10.70% Share services 29,77,48,104 TNMM OP/OC 11.32% 9.05% ITES Reimbursement of 1, 22,99,059 NA NA NA NA expenses Recovery of 23,14,792 NA NA NA NA expenses 5.4. Now the dispute is with regard to adjustments on account of software development services (SDS) and the interest on receivables. The assessee has made the turnover of Rs. 46.69 crores in SDS and held that TNMM is the most appropriate method and arrived at the margin 15.43% i.e. OP/OC against the margin of comparables at 10.70%, hence, held that the assessee’s margin is at arm’s length and has proposed ‘NIL’ adjustments in respect of software development services (SDS). The TPO rejected the transfer pricing study in respect of software development services due to defects in filters as discussed in para 7.1.1 of the TPO’s order which reads as under:

S.A.No.98/Hyd/2020, A.Y.2015-16 M/s Infor (India) Private Limited, Hyderabad “7.1.1. Rejection of TP Study In the case of tax payer, the TPO is mainly concerned about whether the information or data used in the computation of the arm’s length price is reliable and correct. It is clear from the provisions of Sec.92C(3)(c) read with Sec.92CA that on the basis of material or information or documents in the possession of TPO, if he is of the opinion that the information or data used in computation of the arm’s length price is not reliable or correct, the TPO may proceed to determine the arm’s length price in relation to the international transactions in accordance with Sec.92C(1) and 92C(2) on the basis of such material or information or document available with him. The search criteria and the acceptance / rejection matrix applied by the company for screening the initially identified cases for arriving at a final comparable set are as under : S.No. Particulars Remarks of the TPO 1. Companies with Net sales more This is an appropriate than 1 Cr. filter 2. Companies with manufacturing A subjective filter. To income plus trading income less be seen on a case to than 50% of sales case basis.

S.A.No.98/Hyd/2020, A.Y.2015-16 M/s Infor (India) Private Limited, Hyderabad within 12 month period i.e. 01.04.2014 to 31.03.2015, were rejected. c) Companies whose income was less than Rs. 1 crore, were excluded. d) Companies whose software development service income is less than 75% of its total operating revenues were excluded. e) Companies who have more than 25% related party transactions of the sales were excluded. f) Companies who have export service income less than 75% of the sales were excluded. g) Companies with employee cost less than 25% of turnover were excluded. 5.6. The TPO rejected the 11 comparables selected by the taxpayer and undertaken fresh search and finally selected 16 comparables as per page No.40 of the TPO’s order and arrived at margin of 20.55% at 35th percentile and 37.90% AT 65th percentile as under:- S. Financial Year wise OP/OC (%) Company name No. 2014-15 2013-14 2012-13 Average 1 Kals Information Systems 5.77 16.94 13.51 11.88 Ltd., 2 E-Zest Solutions Ltd., 12.59 15.80 - 14.05 3 CG-VAK Software & 19.87 13.81 22.07 18.50 Exports Ltd. 4 Tata Elxsi Ltd., (Seg) 23.33 22.02 11.24 19.34

S.A.No.98/Hyd/2020, A.Y.2015-16 M/s Infor (India) Private Limited, Hyderabad 5 Rheal Software Pvt. Ltd. 2.76 36.64 - 19.88 6 Mindtree Ltd., 20.55 21.18 19.75 20.55 7 Larsen & Toubro Infotech 24.22 23.54 25.10 24.21 Ltd. 8 R.S. Software (India Ltd.,) 32.66 24.14 17.44 24.82 9 Infobeans Technologies 20.70 41.95 29.22 29.91 10 Persistent Systems Ltd., 31.11 35.44 28.20 31.69 11 Nihilent Technologies Ltd., 29.19 35.72 - 32.21 12 Aspire Systems (India) Pvt. 30.98 38.04 - 34.18 Ltd., 13 Inteq Software Pvt. Ltd., 31.16 45.00 - 37.90 14 Infosys Ltd., 40.29 36.28 29.25 38.59 15 Thirdware Solutions Ltd., 43.69 44.68 32.65 41.12 16 Cybage Software Pvt. Ltd., 68.17 68.82 60.81 66.27 35th Percentile 20.55% Median 27.37% 65th Percentile 37.90% 5.7. The TPO computed the ALP adopting the median margin of 27.37% as under: SOFTWARE DEVELOPMENT SEGMENT Particulars Formula Amount (in Rs.) Taxpayers operating OR 46,44,04,588 revenue Taxpayers operating cost OC 40,42,15,932 Taxpayers operating profit OP 6,23,88,656 Taxpayers PLI PLI = OP/OC 15.43% 35th Percentile Margin of 20.55% Comparable set Adjustment Required (if PLI Yes < 35th Percentile Median Margin of M 27.37% comparable set Arm’s Length Price ALP =(I+M)*OC 51,48,49,833 Price Received OR 46,66,04,588 Shortfall being adjustment ALP – OR 4,82,45,245

S.A.No.98/Hyd/2020, A.Y.2015-16 M/s Infor (India) Private Limited, Hyderabad Accordingly the TPO suggested for adjustment of Rs.4,82,45,245/- on account of shortfall.

5.8. The Ld.DRP allowed part relief and consequently adjustment of Rs.3,54,72,020/- was made in the final assessment order passed u/s 143(3) r.w.s. 144C in respect of SDS.

S.A.No.98/Hyd/2020, A.Y.2015-16 M/s Infor (India) Private Limited, Hyderabad 6.1. In respect of the remaining comparables in ground No.2, i.e. Infosys Ltd., Larsen & Toubro Infotech Ltd., Mindtree Ltd., Tata Elxsi Ltd. (Seg), Persistent Systems Ltd., Thirdware Solution Ltd., the Ld.AR argued that exclusion of the above companies are covered by the order of this Tribunal in assessee’s own case and other cases decided by the ITAT, Hyderabad for the A.Ys. 2013-14 & 2014-15 on identical facts. Therefore submitted that the issue is squarely covered in favour of the assessee. The comparable companies covered for exclusion by the order of this Tribunal are discussed as under : 1) Infosys Ltd. 2) Larsen& Toubro Infotech Ltd. 3) Mindtree Ltd., Tata Elxsi Ltd. (Seg) 4) Persistent Systems Ltd. and 5) Thirdware Solution Ltd. 6.2. In respect of Infosys Ltd., Larsen & Toubro Infotech Ltd. and Mindtree Ltd., this tribunal has considered the issue in assessee’s own case for the A.Y.2013-14 to 2014-15 and excluded the comparables with a finding that these companies are giant companies in the area of development of software. For the sake of clarity and convenience, we extract paras 7.3 to S.A.No.98/Hyd/2020, A.Y.2015-16 M/s Infor (India) Private Limited, Hyderabad 7.6 in assessee’s own case for the A.Ys. 2013-14 &2014-15 in & 2307/HYD /2018 dated 06/08/2019 which reads as under:- “7.4 As regards exclusion of Infosys Ltd, Larsen & Toubro Infotech Ltd and Mindtree Ltd, the common ground of the assessee is that they have huge turnover of Rs.42,531 crores, Rs.4,648.38 crores and Rs.3,031.6 crores respectively as against the assessee’s turnover of Rs.116.00 crores only. The learned Counsel for the assessee also argued that they are functionally dissimilar and own intangibles etc. 7.5. The learned DR argued that unless the assessee demonstrates as to how the huge turnover impacts the margin of the said companies, they should not be excluded from the final list of comparables. 7.6. Having regard to the rival contentions and the material on record, we find that the Hon'ble Delhi High Court in the case of CIT vs. Agnity India Technologies (P) Ltd(2013) 36 Taxmann.com 289 (Delhi H.C) has held Infosys Ltd as not comparable as it is a giant company in the area of development of software. The same ratio applied to both L&T and Mindtree as well. Thus, we direct exclusion of all these three companies on account of huge turnover.” 6.2.1. Both the Ld.AR and the Ld.DR have agreed that there is no change in the facts of the case for the year under consideration. The assessee’s turnover was Rs.46.69 crores whereas the turnover in the above companies is huge and uncomparable. Therefore, respectfully following the view taken by this Tribunal in the assessee’s own case (supra), we hold that the above companies are not comparables and direct the TPO/AO to delete the above companies from the list of final comparables.

S.A.No.98/Hyd/2020, A.Y.2015-16 M/s Infor (India) Private Limited, Hyderabad 6.3. With regard to Tata Elxsi Ltd., Thirdware Solutions Ltd. and Persistent Systems Ltd., are concerned for the A.Ys. 2013-14 & 2014-15, this Tribunal directed the TPO (AO) to exclude the 03 companies from the list of final list comparables for non-availability of segmental details. For the sake of clarity and convenience, we extract para Nos. 7.7 & 7.8 which reads as under:- “7.7. As regards Tata Elxsi Ltd, Thirdware Solutions Ltd and Persistent Systems Ltd are concerned, we find that their comparability to the assessee has been considered in the assessee’s own case for the A.Y 2007-08 and it is submitted that there is no change of activities of either the assessee or the comparables during the relevant A.Y before us i.e. A.Y 2014-15. 7.8. The learned DR has not rebutted this contention of the assessee. Therefore, respectfully following the decision of the Coordinate Bench at Mumbai in dated 4.12.2018, in the case of Infor Global Solutions India (P.) Ltd. v.Deputy Commissioner of Income Tax, we direct the exclusion of these three companies from the final list of comparables. For the sake of ready reference, the relevant paras are reproduced hereunder: “29. We have considered rival submissions and perused materials on record. The primary and fundamental reason on the basis of which assessee seeks rejection of the aforesaid comparable is, it is also engaged in the development of product and segmental details are not available. Notably, in case of LSI Technologies India (P.) Ltd. (supra), the Co-ordinate Bench while examining the comparability of the aforesaid company to a software development service provider, has rejected this company as a comparable considering the fact that it is engaged in product development and product design services. The same view has been reiterated by the Tribunal in the other decisions cited by the learned Authorised Representative. Since, many of these decisions pertain to the impugned assessment year, respectfully following the aforesaid decisions of the Tribunal, we direct the Assessing Officer to exclude this company from the list of comparables.

6.3.2. Both the Ld.AR and Ld.DR submitted that there is no change in the facts either in the case of assessee’s company or in the case of comparables. No major changes in the activities of the comparables of the assessee’s have been brought to our notice. Therefore, respectfully following the view taken by the coordinate bench of the tribunal in the earlier years, we direct the S.A.No.98/Hyd/2020, A.Y.2015-16 M/s Infor (India) Private Limited, Hyderabad TPO (AO) to exclude the Tata Elxsi Ltd., Thirdware Solutions Ltd. and Persistent Systems Ltd. from the final list of the comparables.

6.4. Ld.AR requested for exclusion of Cybage Software Pvt. Ltd. from the final list of comparables and argued that though Cybage Software Pvt. Ltd. is comparable functionally, the profit margin is very high as much as 60.81 to 68.17% which is not possible in normal conditions. Ld.AR submitted that the assessee company’s margin is 15.32% against the average margin of comparables selected by the assessee at 10.70%. Therefore, requested to exclude the Cybage Software Pvt. Ltd. from the final list of comparables. The Ld.AR argued that the average margin of other companies is ranging from 11.88% - 41.12% as evidenced from the final list of comparables selected by TPO and average of Cybage Software Pvt. Ltd. worked out to 66.27% which is more than 1/3rd average of the rest of the companies. Therefore, argued that Cybage Software Pvt. Ltd. is not a comparable in view of highest margins. The assessee also objected before the AO for taking Cybage Software Pvt. Ltd. as comparable stating that it is functionally dissimilar and diversified activities engaged in product development and insufficient information available in the public domain. Both the Ld.TPO and the Ld.DRP rejected the contentions of the assessee. The Ld.DR supported the orders of the lower authorities.

S.A.No.98/Hyd/2020, A.Y.2015-16 M/s Infor (India) Private Limited, Hyderabad 6.4.1. We have considered the rival submissions and observe that Cybage Software Pvt. Ltd., though comparable company, the margin declared by the Cybage Software Pvt. Ltd. is abnormally high which is as much as 68.17% in the year under consideration and average margin is at 66.27%. The Ld. TPO has excluded the loss companies and also the companies which are with lowest margins as argued by the Ld.AR and which was not disputed by the department. Following the same analogy Cybage Software Pvt. Ltd. required to be excluded. The TPO or DRP has not gone into the reasons for such huge margins. Without having complete information we are unable to accept the contention of the Ld.TPO and DRP to include Cybage Software Pvt. Ltd. as comparable, therefore we direct the TPO / AO to exclude Cybage Software Pvt. Ltd. from the final list of comparables.

S.A.No.98/Hyd/2020, A.Y.2015-16 M/s Infor (India) Private Limited, Hyderabad 7.1. The Ld. AR requested for inclusion of the above companies who fulfill all the filters and were functionally similar to that of the assessee-company. During the appeal hearing, Ld.AR did not press for inclusion of Akshay Software Technologies Ltd. and Harbinger Systems Pvt. Ltd., therefore the assessee’s ground for inclusion of comparables in respect of Akshay Software Technologies Ltd. and Harbinger Systems Pvt. Ltd. is dismissed as not pressed.

7.2. In respect of Evoke Technologies Pvt. Ltd., Kireeti Soft Technologies Ltd., InfoMile Technologies Ltd. 12T2 India Ltd., Ld.AR did not make any argument for inclusion of companies, therefore assessee’s ground for inclusion of the said companies as comparables is dismissed as not pressed.

7.3. The assessee vehemently argued for inclusion of SagarSoft India Ltd. as comparable in the final list of comparables. However, we observe that SagarSoft India Ltd. is persistent loss company and the DRP has rejected the assessee’s request for inclusion of the said company for the following reasons:- “2.25.1 Having considered the submissions and on perusal of the annual report, we note that as per the information in the profit & loss account, the company has revenue from software development services. The TPO rejected due to persistent losses. We note that this company has persistent losses at operating level as evident from the annual reports and also in the assessee’s submissions in page No. 313 of the Application. Consistently, we

S.A.No.98/Hyd/2020, A.Y.2015-16 M/s Infor (India) Private Limited, Hyderabad are upholding the application of persistent loss filter and accordingly, we uphold the action of the TPO.” 7.3.1. The assessee has requested for exclusion of Cybage Software Pvt. Ltd. since, the margin of Cybage Software Pvt. Ltd. is persistently abnormal and very high which is considered in favour of the assessee in this order. Following the same reason, since, SagarSoft India Ltd,. is persistent loss company, the assessee’s request for inclusion of SagarSoft India Ltd. as comparable company deserves to be rejected. Therefore, following the reason given in the case, Cybage Software Pvt. Ltd., the assessee’s ground for inclusion of SagarSoft India Ltd. being persistent loss company is dismissed.

S.A.No.98/Hyd/2020, A.Y.2015-16 M/s Infor (India) Private Limited, Hyderabad is remitted back to the file of the TPO (AO) to compute correct margins of comparable companies after giving opportunity to the assessee. Accordingly, the issue in respect of Nihilent Technologies Ltd. and Sasken Communication Technologies Ltd. is remitted back to the file of TPO (AO) for limited purpose of computing the correct margins and this ground is allowed for statistical purpose.

S.A.No.98/Hyd/2020, A.Y.2015-16 M/s Infor (India) Private Limited, Hyderabad 9.1. On the other hand, Ld.DR supported the orders of the authorities below.

9.2. We have heard rival contentions and find that this issue came up for adjudication in the assessee’s own case for the A.Ys. 2013-14 & 2014-15. After the amendment of law inserting Explanation to section 92B of the Act, the interest on trade receivables also became an international transaction and therefore, the ALP adjustment is required to be made in respect of trade receivables also. Accordingly ITAT has decided the issue against the assessee in the earlier years in assessee’s own case for the A.Y.2013-14 and 2014-15 (supra). For the sake of clarity and convenience, we extract the relevant part of the order of this tribunal in para 86 & 87 which reads as under:-

“86. The common grounds of appeal for the A.Ys 2013-14 and 2014-15 are against the ALP adjustment of interest on trade receivables. Though the learned Counsel for the assessee has relied upon the assessee’s own case for the A.Y 2011-12, we find that after the amendment to section 92B of the Act, the interest on trade receivables has become an international transaction and therefore, the ALP adjustment is required to be made. The assessee’s contention that it has not paid any interest on outstanding payables and therefore, the interest should not be charged on the trade receivables is not sustainable for these A.Ys. The argument that it is a debt free company and therefore, no interest is also to be charged is not acceptable.

87. The learned Counsel for the assessee has placed reliance upon various case law. However, we find that they are relating to the A.Ys prior to the amendment of section 92B of the Act. However, the interest on trade receivables should be calculated at the interest rate applicable for the relevant period as is charged by SBI on the short term deposits. The AO has allowed the credit period of 60 to 90 days as per the agreement for A.Y 2013- 14 but for the A.Y 2014-15 he has allowed only 30 days as credit period. This S.A.No.98/Hyd/2020, A.Y.2015-16 M/s Infor (India) Private Limited, Hyderabad action of the AO cannot be upheld. If there is a clause in the agreement about credit period, the interest should be calculated only on the period exceeding such credit period in the agreement, but if there is no credit period specified in the agreement, then the credit period of 90 days or the industry average credit period should be considered with the assessee’s own credit period and any deviation alone should be considered for ALP adjustment. The AO/TPO is directed accordingly. The assessee’s grounds of appeal for both the A.Ys 2013- 14 and 2014- 15 are treated as allowed for statistical purposes accordingly.”

9.2.1. Since there are no changes in the facts, we hold that this issue squarely covered by the decision of this Tribunal. Accordingly, we direct the TPO (AO) to allow credit period of 90 days or the industry average and only in respect of the deviation, the interest to be considered for ALP adjustment.

9.2.2. With regard to interest whether to be charged as per Libor or SBI interest rate, the issue has already been considered by the Tribunal in the earlier year and held that interest to be charged as per SBI short term deposit rates. Since there are no changes in the facts, respectfully following the view taken by this tribunal in assessee’s own case, we hold that interest is to be charged at the rates of short term deposits of SBI as decided by the ITAT in it’s earlier year orders. Accordingly, this issue is remitted back to the file of TPO (AO) to recompute the interest. Appeal of the assessee on this ground is treated as allowed for statistical purposes.

S.A.No.98/Hyd/2020, A.Y.2015-16 M/s Infor (India) Private Limited, Hyderabad 10. In the result, appeal filed by the assessee is partly allowed and stay application is dismissed.

Order Pronounced in open Court on this 19th day of October, 2020.

Sd/- Sd/- (श्री धि.एस. सुन्दर धसंह) (पी. मािवी देवी) (P. MADHAVI DEVI) (D.S. SUNDER SINGH) न्याधयक सदस्य/JUDICIAL MEMBER लेखा सदस्य/ACCOUNTANT MEMBER Dated: 19th October, 2020. vr/- Copy to:

1. 1. The Assessee -M/s. Infor (India) Pvt. Ltd., 4th Floor, Block-B, Q-City, Survey no. 109, 110, 111/2, Nanakramguda (Vs.), Serilingampally (M), R.R. District, Hyderabad.