JEFFERIES SINGAPORE LTD,SINGAPORE vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) - 3(1)(1), MUMBAI

Per Bench:

Captioned appeals by the same assessee arise out of a consolidated order dated

20.03.2024 of learned Commissioner of Income Tax (Appeals), Mumbai (‘ld.CIT(A) for

short), pertaining to the assessment years (A.Ys.) 2014-15, 2015-16, 2016-17, 2017-18 and

2018-19.

to take up ITA No. 2757/Mum/2024 for A.Y. 2014-15 as the lead appeal.

2 ITA Nos. 2757/Mum/2024 & others Jefferies Singapore Ltd. vs. Dy. CIT (IT) ITA No. 2757/Mum/2024 (A.Y. 2014-15)

research management support services as Fees for Technical Services (‘FTS’) under the

India-Singapore Double Taxation Avoidance Agreement (‘DTAA’).

engaged in the business of providing advisory services. The assessee is incorporated under

the laws of Singapore and is a tax resident of Singapore. On 01.10.2012, the assessee had

entered into an intra group support services agreement with Jeffries India Pvt. Ltd., a group

company in India. As per the terms of the agreement, the scope of work of the assessee is

to review the research activity undertaken by the Indian group entity to ensure that the

research activities are in line with global standard of the group.

Rs.7,92,83,445/- from Jefferies India Private Limited (‘JIPL’ for short) towards rendition

of research management support services. However, in the return of income filed for the

year under dispute on 26.11.2014, the assessee offered nil income, claiming refund of

Rs.84,18,416/-. While verifying the return of income, audited accounts etc. Assessing

Officer (A.O. for short) having found that the assessee has not offered to tax the amount

received from JIPL towards research management support services fees and called upon

the assessee to explain why it should not be brought to tax as it is in the nature of FTS. In

response to the query of the A.O., the assessee furnished a detailed reply explaining the

reason why receipt should not fall within the ambit of FTS under India-Singapore DTAA.

Without prejudice, the assessee submitted that the make available condition under Article

12(4)(b) of the Treaty is not satisfied. The A.O., however, did not find merit in the

3 ITA Nos. 2757/Mum/2024 & others Jefferies Singapore Ltd. vs. Dy. CIT (IT) submissions of the assessee. He observed, not only the fee received by the assessee falls

within the definition of FTS under Article 12(4) of DTAA, but also u/s. 9(1)(vii) of the

Act. He further observed that in course of rendition of such service, the assessee did transfer

technical knowhow, experience, skill, etc. to the Indian entity which satisfies the make

available condition. Thus, ultimately, he held that the receipts towards Research

Management support services are in the nature of FTS under Article 12(4) of India-

Singapore DTAA, hence, taxable at the hands of the assessee. Accordingly, he framed the

draft assessment order. Since, the assessee did not file any objection before ld. Dispute

Resolution Panel (‘ld. DRP’ for short) within the stipulated time period, the assessment

was finalized in terms of section 144C(3) of the Act.

First appellate authority.

expressed by the A.O. with regard to the nature and character of the receipts as FTS.

appearing for the assessee submitted that, firstly, the nature of services rendered, by any

means, cannot be considered as either managerial, technical or consultancy services. He

submitted, the assessee merely reviews the research activities undertaken by the Indian

group company to ensure that the research activity carried on are in accordance with the

global standards of Jefferies Group. He submitted, neither the assessee itself carries out

any research activity, nor it provides any technical assistance to the Indian group company

4 ITA Nos. 2757/Mum/2024 & others Jefferies Singapore Ltd. vs. Dy. CIT (IT) while carrying out the research activity. He submitted, assessee's role is merely restricted

to reviewing the research done by the Indian entity. Drawing our attention to the Intra

Group services agreement, as also the submissions made before learned first appellate

authority, learned counsel for the assessee submitted, after execution of the agreement, the

assessee is providing identical nature of services since assessment year 2013-14 and is

continuing to provide such services even now. Thus, he submitted, the services are

provided on year-on-year basis. These facts itself proves that in course of rendition of

services, the assessee has not transferred any technical know-how, knowledge, skill, etc.

to the Indian entity so as to enable the Indian entity to utilize such technical knowledge,

know-how, skill, etc. in its research activities independently without requiring the aid and

assistance of the assessee. To establish the nature and character of the services rendered by

the assessee, learned counsel drew our attention to the unilateral Advance Pricing

Agreement between the assessee and Central Board of Direct Tax (CBDT). Thus, in sum

and substance, learned counsel for the assessee submitted that the fee received by the

assessee does not fall within the ambit of FTS under Article 12(4) of India-Singapore

DTAA. In support of such contentions, learned counsel relied upon the following

decisions:

a) Shell India Markets (P.) Ltd. vs. Union of India [2024] 160 taxmann.com 175 (Bom) b) CIT vs. Bio-Rad Laboratories (Singapore) Pte. Ltd. [2023] 155 taxmann.com 646

(Del) c) Bain & Company Inc vs. Dy/ACIT(IT) [2023] 156 taxmann.com 401 (Delhi-Trib.) d) Dy.CIT(IT) vs. Sun Pharmaceutical Laboratories Ltd. [2018] 96 taxmann.com 105

(Ahd-Trib.)

5 ITA Nos. 2757/Mum/2024 & others Jefferies Singapore Ltd. vs. Dy. CIT (IT) 10. Learned Departmental Representative strongly relied upon the observations of the

AO and learned first appellate authority.

perused materials on record. The short issue arising for consideration is ‘Whether the fee

received by the assessee towards rendition of research management support services would

qualify as FTS under Article 12(4) of India-Singapore DTAA?’. As discussed earlier, in

the year 2012, the assessee had entered into an agreement with JIPL for providing research

management support services. The scope of services under Article 2.1 is as under:

“2.1 JSL shall oversee the research activity undertaken by JIPL to ensure that the research activities of JIPL are in line with the global standards of Jefferies.”

Board of India (‘SEBI’ for short), as a stockbroker and merchant banker. JIPL undertakes

research activities with respect to securities and other markets in India and worldwide.

Thus, as can be seen from the terms of the agreement, JIPL is engaged in research activity,

whereas, the role of the assessee is to oversee and review the research done by the JIPL to

ensure that it is in sync with the global standard maintained by the Group. Thus, the role

of the assessee is that of oversight to ensure that the global standards are maintained with

regard to the research activity undertaken by the Indian group entity. It is evident, in course

of assessment proceeding, the assessee had furnished the entire details relating to the

services rendered covering Compliance, Controllers (Finance), Corporate Services, Human

Resources, Information Technology, Internal audit, Legal, Operations, Risk, Tax,

Treasury, etc. Under Compliance, the assessee establishes the policy framework to ensure

compliance with local legal rules and regulations and laws by JIPL, to provide monitoring

6 ITA Nos. 2757/Mum/2024 & others Jefferies Singapore Ltd. vs. Dy. CIT (IT) and support services to JIPL management, to provide regulatory and compliance advice to

broader business monitoring and new regulatory changes. In relation to Controllers

(Finance), the assessee performs finance services including various financial analyses such

as gathering financial reporting, regulatory reporting, accounting and regional lead and

coordination for controls and compliance, banking and cash management. It also provides

services relating to procedures and policies for general accounting and budgetary purposes.

With regard to Corporate Services, the assessee manages various statutory compliances

which are required to be complied by JIPL. It also provides services in respect of office

security, furnishing, general office equipment, housekeeping and maintenance of office

building and office moves and relocations. Under Human Resources, the assessee

establishes HR policies, hiring strategies, staff information requests on matters pertaining

to fit and proper criteria, supporting and administering payroll and benefit functions,

designing employee retention policies and personnel related enquiries, etc. Under

Information Technology, it provides IT support services for both infrastructure and

software applications used by the JIPL in their day-to-day conduct of business. Under

Internal Audit, the assessee performs internal audit of systems, processes, and controls in

place. In so far as, Legal service is concerned, the assessee is responsible for providing

enforcements and opinions and other legal support services to JIPL. The Legal Department

of the assessee is responsible for coordinating, managing, and implementing worldwide

legal support and assisting JPL with legal matters which might arise, including

enforcement and opinions on routine legal matters and for assisting JIPL with any local

country legal issues. Under Operations, the assessee performs client and anti-money

laundering due diligence and new client on-boarding including account creation and review

within the framework of global guidelines. The assessee provides risk management

7 ITA Nos. 2757/Mum/2024 & others Jefferies Singapore Ltd. vs. Dy. CIT (IT) support, including market, credit and operational risk functions. The assessee also provides

tax advice and support, including review of tax provisions and filings. For Treasury related

services, the assessee provides support of cash management, funding and bank/network

management. Keeping in view the nature of services rendered in the context of Article

12(4) of India-Singapore DTAA and even assuming that a part of the fee received is

towards services of managerial, technical or consultancy nature, however, as per Article

12(4)(b), to qualify as FTS, the requirement is, in course of rendition of such services, the

service provider must have made available technology, knowledge, skill, know-how, or

processes which enables the service recipient to apply the technology contained therein.

Article 12(4)(c) also covers fees received for development of technical plan and technical

designing to be regarded as FTS if it enables the person to use the services contained

therein. In the facts of the present appeal, the assesse, indeed, had started providing

research management support services since the year 2013 immediately upon execution of

the agreement and is continuing to do so in the subsequent assessment years. The materials

on record reveal that the assessee is not only continuing with rendition of such services to

the Indian entity, but also earning revenue from A.Y. 2013-14 onwards. The details of the

same are as under:

A.Y. Amount (in Rs.) 2013-14 2,09,49,952 2014-15 7,92,83,445 2015-16 5,74,21,323 2016-17 5,39,07,195 2017-18 5,99,72,890 2018-19 5,69,78,872 2019-20 4,66,50,215 2020-21 3,75,91,628 13. Thus, as could be seen from the aforesaid facts and figures, from the date of

execution of the agreement, the assessee is providing research management support

8 ITA Nos. 2757/Mum/2024 & others Jefferies Singapore Ltd. vs. Dy. CIT (IT)

services to JIPL on year-on-year basis without any disruption. These facts clearly

demonstrate that the Indian entity is dependent upon the assessee for the nature of services

provided by the assessee and it is not capable of performing such services on its own. Had

it been the case of the assessee making available the technical knowledge, experience,

technical know-how or processes or transfer of technical plan or technical designing to the

Indian entity, certainly it would have enabled the Indian entity to perform its activities

applying such technical knowledge, know-how, skill, technical plan, design, etc., on its

own without depending upon the assessee. The very fact that the assessee has continued to

provide such services over the years indicates the incapacity of Indian entity to perform

such services on its own. In case of CIT vs. Bio-Rad Laboratories (Singapore) Pte. Ltd.

(supra), the Hon'ble Delhi High Court, while taking note of the fact that the services are

being provided on year-on-year basis, held as under:

14.1 Notably, this aspect is adverted to in paragraphs 17 to 23 of the impugned order. For convenience, the relevant paragraphs are extracted hereafter. "17. A perusal of the aforementioned provision shows that in order to qualify as FTS, the services rendered ought to satisfy the 'make available' test. Therefore, in our considered opinion, in order to bring the alleged managerial services within the ambit of FTS under the India-Singapore DTAA, the services would have to satisfy the 'make available test and such contained therein. 18. As mentioned elsewhere, the agreement is effective from 1-1-2010 and we are in Assessment Years 2018-19 and 2019-120 (sic...20]. In our considered opinion, if the assessee had enabled the service recipient to apply the technology 208 As mentioned elsewhere, the agreement is effective from 1-1-2010 and we are in Assessment Years 2018- 19 and on its own, then why would the setered opinion, if there such service year after year every year since 20107 19. This undisputed fact in itself demolishes the action of the Assessing Officer/DRP. Facts on record show that the recipient of the services is not enabled to provide the same service without recourse to the service provider, i.e., the assessee. 20. In our humble opinion, mere incidental advantage to the recipient of services is not enough. The real test is the transfer of technology and on the given facts of the case, there is no transfer of technology and what has been appreciated by the Assessing Officer/ld. CIT(A) is the incidental benefit to the assessee which has been considered to be of enduring advantage.

9 ITA Nos. 2757/Mum/2024 & others Jefferies Singapore Ltd. vs. Dy. CIT (IT)

on identical issue, has held as under:

10 ITA Nos. 2757/Mum/2024 & others Jefferies Singapore Ltd. vs. Dy. CIT (IT)

(b) payments of any kind received as consideration for the use of, or the right to use, any industrial, commercial or scientific equipment, other than income derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic 4. For the purposes of paragraph (2) of this Article, and subject to paragraph (5), of this Article, the term "fees for technical services" means payments of any kind to any person in consideration for the rendering of any technical or consultancy services (including the provisions of services of technical or other personnel) which: (a) are ancillary and subsidiary to the application or enjoyment of the right, property or information for which a payment described in paragraph (3)(a) of this Article is received; or (b) are ancillary and subsidiary to the enjoyment of the property for which a payment described in paragraph (3)(b) of this Article is received; or (c) make available technical knowledge, experience, skill, know-how or processes, or consist of the development and transfer of a technical plan or technical design." 16. From the bare words of the Article, it is clear that income of SIPCL will be chargeable to tax in India only if the payment by Petitioner is towards fees for 'technical services'. Under Article 13(4), the term 'fees for technical services' means payments of any kind in consideration for the rendering of any technical or consultancy services. Sub-para (c) to Article 13(4) further restricts the meaning of the term to only that which makes available technical knowledge, experience, skill, know-how or processes, or consists of the development or transfer of a technical plan or technical design. 17. The principle of noscitur a sociis mandates that the meaning of a word is to be judged by the company of other words which it keeps. The word 'consultancy' services follows 'technical' which is further followed by the phrase "which make available technical knowledge, experience, skill, know-how or processes, or consist of development and transfer of a technical plan or technical design." A clear reading indicates that even if consultancy services is 'stand alone', the bunch of words indicate that the said 'consultancy' necessarily relates to consultancy which makes available technical or any other knowledge, experience, skill, know- how or processes and does not relate to consultancy on managerial issues. 18. The Appendix 2 of CCA contains the General BSS. The list of services availed are as follows: EXAMPLES OF GENERAL BUSINESS SUPPORT SERVICES: • Management Support • Development and Provisions of Support and Business Tools • Provision of Marketing Support. • Development, Communication and Audit of Standards of Performance • Promotion of Professional Competence • Information Technology Advice and Services • General Financial Advice and Services • Taxation Advice and Services • Legal Services • Employee Relations and Public Affairs/Media Advice and Services • HR Advice and Services • Contracting and Procurement Services • Other Business Support Services A perusal of the list of services relate to managerial services not involving anything of a technical nature. The AAR has discussed the services appearing in the CCA and has concluded that these activities in a retail business are at the core of retail marketing and hence advice tendered in taking a decision of commercial nature is a consultancy service. The AAR has further considered the definition of the word 'Consultancy' as defined in the Oxford English dictionary and has observed that a consultant is a person who gives professional advice or

11 ITA Nos. 2757/Mum/2024 & others Jefferies Singapore Ltd. vs. Dy. CIT (IT)

services in a specialized field. However, the AAR failed to appreciate that the word 'Consultancy' appearing in the Article is to be interpreted in the context of consultancy which makes available technical knowledge, etc. and not of managerial nature. The reading of the Article clearly indicates that the consultancy service must be which makes available technical knowledge, etc. Sub-para (c) to Article 13(4) restricts such services to those which make available technical knowledge or consist of development and transfer of a technical plan or technical design. Thus, a harmonious reading of the provision of Article 13 in its entirety, clearly establishes the intent of the DTAA in making income chargeable to tax only if the services availed pertain to technical services or consultancy services. Technical services in this context mean services requiring expertise in a technology. By Consultancy Services, in this context, would mean advisory services. The categories of technical and consultancy services are to some extent, overlapping. Under paragraph 4, technical and consultancy services are considered included services only to the following extent: (1) as described in paragraph 4(a), if they are ancillary and subsidiary to the application or enjoyment of a right, property or information for which a payment described in paragraph (3)(a) of Article 13 is received; (2) are ancillary and subsidiary to the enjoyment of the property for which a payment described in paragraph (3)(b) of Article 13 is received; or (3) as described in paragraph 4(c), if they make available technical knowledge, experience, skill, know-how, or processes, or consist of the development and transfer of a technical plan or technical design. Thus, under paragraph 4(c), consultancy services which are not of a technical nature cannot be included services. Thus, the services availed by Petitioner cannot be said to be technical services and Article 13 is wholly inapplicable in the facts and circumstances of the present case. 19. It will be useful to refer to a decision of the Madras High Court in the case of Skycell Communications Ltd and Anr. v. Deputy Commissioner of Income-Tax and Ors.8 which held as follows:

"8. Thus while stating that "technical service" would include managerial and consultancy service, the Legislature has not set out with precision as to what would constitute "technical" service to render it "technical service". The meaning of the word "technical" as given in the New Oxford Dictionary is adjective 1. of or relating to a particular subject, art or craft or its techniques : technical terms (especially of a book or article) requiring special knowledge to be understood : a technical report. 2. of involving, or concerned with applied and industrial sciences : an important technical achievement. 3. resulting from mechanical failure : a technical fault. 4. according to a strict application or interpretation of the law or the rules : the arrest was a technical violation of the treaty. 9. Having regard to the fact that the term is required to be understood in the context in which it is used, "fee for technical services" could only be meant to cover such things technical as are capable of being provided by way of service for a fee. The popular meaning associated with "technical" is "involving or concerning applied and industrial science".

12 ITA Nos. 2757/Mum/2024 & others Jefferies Singapore Ltd. vs. Dy. CIT (IT)

person travels by train or in an aeroplane, it cannot be said that the railways or airlines is rendering a technical service to the passenger and, therefore, the passenger is under an obligation to deduct tax at source on the payments made to the railway or the airline for having used it for travelling from one destination to another. When a person travels by bus, it cannot be said that the undertaking which owns the bus service is rendering technical service to the passenger and, therefore, the passenger must deduct tax at source on the payment made to the bus service provider, for having used the bus. The electricity supplied to a consumer cannot, on the ground that generators are used to generate electricity, transmission lines to carry the power, transformers to regulate the flow of current, meters to measure the consumption, be regarded as amounting to provision of technical services to the consumer resulting in the consumer having to deduct tax at source on the payment made for the power consumed and remit the same to the Revenue. 15. The use of the internet and the world wide web is increasing by leaps and bounds, and there are hundreds of thousands, if not millions, of subscribers to that facility. The internet is very much a product of technology, and without the sophisticated equipment installed by the internet service providers and the use of the telephone fixed or mobile through which the connection is established, the service cannot be provided. However, on that score, every subscriber of the internet service provider cannot be regarded as having entered into a contract for availing of technical services from the provider of the internet service, and such subscriber regarded as being obliged to deduct tax at source on the payment made to the internet service provider. 20. Thus, it is clear from the said decision that any service is construable as technical but one has to see the true import of the service actually rendered and the determination must be made in this context. There is no such discussion in the Impugned order and the finding is based on a generic reference to the meaning of the word 'consultancy' as given in the Oxford English Dictionary. The AAR further holds that the list of services mentioned in the CCA is not an exhaustive list and may include other technical services. Thus Petitioner is correct in contending that the AAR has proceeded on conjectures and surmises to render the finding in the impugned order.

13 ITA Nos. 2757/Mum/2024 & others Jefferies Singapore Ltd. vs. Dy. CIT (IT)

the future without depending upon the provider. Technology will be considered "made available" when the person acquiring the service is enabled to apply the technology. The fact that the provision of the service that may require technical knowledge, skills, etc., does not mean that technology is made available to the person purchasing the service, within the meaning of paragraph (4)(b). Similarly, the use of a product which embodies technology shall not per se be considered to make the technology available. In other words, payment of consideration would be regarded as "fee for technical/included services" only if the twin test of rendering services and making technical knowledge available at the same time is satisfied." (emphasis supplied) 22. Similarly, the Delhi High Court in the CIT (International Taxation)-1, Delhi v. M/s Bio-rad (Supra) has discussed the said concept accordingly. Paragraphs 14 and 15 read as under: 14. According to the Tribunal, the agreement between the respondent/assessee and its Indian affiliate had been effective from 01.01.2010, and if, as contended by the appellant/revenue, technical knowledge, experience, skill, and other processes had been made available to the Indian affiliate, the agreement would not have run its course for such a long period. 14.1 Notably, this aspect is adverted to in paragraphs 17 to 23 of the impugned order. For convenience, the relevant paragraphs are extracted hereafter: "17. A perusal of the aforementioned provision shows that in order to qualify as FTS, the services rendered ought to satisfy the 'make available' test. Therefore, in our considered opinion, in order to bring the alleged managerial services within the ambit of FTS under the India-Singapore DTAA, the services would have to satisfy the 'make available' test and such services should enable the person acquiring the services to apply the technology contained therein. "18. As mentioned elsewhere, the agreement is effective from 01.01.2010 and we are in Assessment Years 2018-19 and 2019-120.[sic.....20]. In our considered opinion, if the assessee had enabled the service recipient to apply the technology on its own, then why would the service recipient require such service year after year every year since 2010? 19. This undisputed fact in itself demolishes the action of the Assessing Officer/DRP. Facts on record show that the recipient of the services is not enabled to provide the same service without recourse to the service provider, i.e, the assessee. 20. In our humble opinion, mere incidental advantage to the recipient of services is not enough. The real test is the transfer of technology and on the given facts of the case, there is no transfer of technology and what has been appreciated by the Assessing Officer/ld. CIT(A) is the incidental benefit to the assessee which has been considered to be of enduring advantage. 21. In our understanding, in order to invoke make available clauses, technical knowledge and skill must remain with the person receiving the services even after the particular contract comes to an end and the technical knowledge or skills of the provider should be imparted to and absorbed by the receiver so that the receiver can deploy similar technology or techniques in the future without depending upon the provider. " [Emphasis is ours] 15. We tend to agree with the analysis and conclusion arrived at by the Tribunal." (emphasis supplied) 23. Therefore, even if it is fees for technical or consultancy services, it can be only where fees are paid in consideration for making available technical knowledge, experience etc. Thus the view of the AAR that SIPCL works closely and advises the employees of Petitioner and hence makes available the services is not correct. This view in fact suffers from fallacy since the agreement continues to operate till date. If the view of AAR is to be held as correct then the contract must stand concluded as once the services and the know how, skill etc is

14 ITA Nos. 2757/Mum/2024 & others Jefferies Singapore Ltd. vs. Dy. CIT (IT) transferred to Petitioner, the need of continuing to render said services must end. This is factually not so as the CCA is in effect till date. 24. Considering the above discussion it is clear that the AAR has interpreted the requirements to be satisfied for 'make available' based on its own general notion of the said term without appreciating the applicable law on the subject and also reached an erroneous conclusion that the services availed are technical services.

the ratio laid by the Hon'ble High Court. Whereas, the departmental authorities while

concluding that the fees received are in the nature of FTS, have relied upon the decision of

Authority For Advance Ruling in case of Porfetti Van Melle Holdings B.V. Advance Ruling

(AAR No. 869 of 2010), which subsequently stood overruled by the Hon'ble Delhi High

Court. Thus, on overall consideration of facts and materials on record, we are of the view

that the conditions under Article 12(4)(b) and (c) of India-Singapore DTAA having not

been fulfilled, the fees received cannot be treated as FTS. Thus, if the fee received is held

not to be in the nature of FTS, it can only be treated as income from business and

profession. However, in absence of PE in India, it cannot be brought to tax in India. In view

of the aforesaid, we direct the AO to delete the addition.

raised in the rest of the appeals. In some of the appeals, the assessee has challenged the

validity of the assessment on the ground that it is barred by limitation having not been

passed within the period of limitation prescribed u/s.153 of the Act.

is not acceptable in view of the provision contained u/s. 153B r.w.s. 144C(13A) & (13B)

brought to the statute with retrospective effect from 01.04.2009. Accordingly, we dismiss

the grounds raised on the issue.

15 ITA Nos. 2757/Mum/2024 & others Jefferies Singapore Ltd. vs. Dy. CIT (IT) 18. In so far as the issue relating to reopening of the assessment and absence of

Document Identification Number (DIN), we keep them open. The other grounds relating

to levy of interest and initiation of penalty proceedings being consequential or premature

are dismissed.

Order pronounced in the open court on 15.07.2026

Sd/- Sd/-

(Bijayananda Pruseth) (Saktijit Dey) Accountant Member Vice President Mumbai; Dated : 15.07.2026 Roshani, Sr. PS

Copy of the Order forwarded to : 1. The Appellant 2. The Respondent 3. The CIT(A) 4. CIT - concerned 5. DR, ITAT, Mumbai 6. Guard File BY ORDER,

(Dy./Asstt. Registrar) ITAT, Mumbai