WEIR MINERALS (INDIA) PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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ITTPA 1786/BANG/2024Status: DisposedITAT Bangalore15 January 2025AY 2020-2113 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal addressed the grounds as follows: Regarding Ground 1 (Limitation): The judgment does not explicitly record a finding on this ground. The operative part of the order focuses on other grounds. Regarding Ground 2 (Transfer Pricing Adjustments - EDS Segment): The Tribunal directed the TPO to conduct a fresh TP study after including M/s. Satyam Venture Engineering Service Pvt. Ltd. as a comparable. The Tribunal noted that if this comparable alone is included, the assessee would achieve the desired Arm's Length Price (ALP), making the inclusion of other comparables academic. The Tribunal also directed the TPO to recompute the profit margins of Mahindra & Genesis by including bad debts as operating expenses, as per the DRP's directions which the TPO failed to follow. This was in line with the decision in Hitachi Energy Technology. The Tribunal noted that the DRP's directions are binding on the AO/TPO under Section 144C(10). Regarding Ground 3 (Interest on Delayed Receivables): The Tribunal held that LIBOR + 200 basis points is legally justifiable for interest on delayed receivables, accepting the assessee's concession. The assessee agreed not to press the issue of whether this constituted an international transaction. This ground was partly allowed. Regarding Ground 4 (Audit Fees - Section 40(a)(i)): The Tribunal held that although the issue did not strictly arise from the present proceedings, the proceedings under Section 143(1) merge with the assessment order under Section 143(3). Therefore, in the interest of justice and to avoid multiplicity of proceedings, the AO was directed to expeditiously dispose of the assessee's application under Section 154.

What were the facts?

This appeal by M/s. Weir Minerals (India) Pvt. Ltd. (the assessee) is against the order of the Assessing Officer (AO) dated July 19, 2024, for the assessment year 2020-21. The assessee challenges the AO's order, which was passed under Section 143(3) read with Sections 144C(13) and 144B of the Income Tax Act, 1961. The primary dispute revolves around transfer pricing adjustments made by the AO, Transfer Pricing Officer (TPO), and Dispute Resolution Panel (DRP). The total transfer pricing adjustment amounted to INR 2,54,55,857. The assessee also raised grounds related to corporate tax, specifically the disallowance of provision for audit fees.

What were the issues?

The Tribunal had to decide the following issues: 1. Whether the final assessment order passed by the AO is barred by limitation under Section 153 of the Act. - Assessee's contention: The order is barred by limitation and liable to be quashed. - Revenue's contention: Not recorded. 2. Whether the transfer pricing adjustment of INR 2,54,55,857 made by the AO, TPO, and DRP is erroneous. - Assessee's contention: The TP documentation was rejected, comparability analysis was flawed, and a non-transparent approach was followed. Specific objections were raised regarding filters applied for Engineering Design Service (EDS) segment comparables, including financial year availability, different year endings, EDS income threshold, export service income threshold, employee cost to total cost ratio, rejection of companies with losses, and lack of working capital and market risk adjustments. The assessee also argued that certain companies should have been rejected, and others should have been rejected for margin computation. - Revenue's contention: Relied on the orders of the authorities below. 3. Whether the transfer pricing adjustment of INR 59,55,857 in relation to interest on delayed receivables is erroneous. - Assessee's contention: Delayed receipts should not be considered as unsecured loans, interest should not be imputed. The outstanding receivables cannot be considered a separate international transaction as it does not fall under capital financing as per Section 92B. Imputing interest on delayed receivables is erroneous when the primary transaction was accepted as arm's length. The AO/TPO/DRP did not adopt prescribed methods and taxed notional income. The TP adjustment already subsumed excess credit period. An ad-hoc interest rate was applied without benchmarking. Delayed payables should be offset against delayed receivables. - Revenue's contention: Relied on the orders of the authorities below. 4. Whether the disallowance of provision towards audit fees under Section 40(a)(i) of the Act is erroneous. - Assessee's contention: The DRP erred in stating it had no jurisdiction. The payment was made to a resident entity, attracting Section 40(a)(ia) and not Section 40(a)(i), and only 30% should be disallowed. - Revenue's contention: The application for rectification under Section 154 is pending, so the issue cannot be raised.

Which sections of the Income-tax Act were involved?

Section 153,Section 143(3),Section 144C(13),Section 144B,Section 92C(3),Section 92B,Section 143(1),Section 40(a)(i),Section 40(a)(ia),Section 144C(10),Section 154

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A’’ BENCH: BANGALORE

Before: SHRI WASEEM AHMED & SHRI PRAKASH CHAND YADAV

For Respondent: Ms. Nandini Das, D.R
Hearing: 09.01.2025Pronounced: 15.01.2025

PER PRAKASH CHAND YADAV, JUDICIAL MEMBER:

Present appeal of the assessee is arising from the order of AO dated 19.7.2024 having DIN & Order No.ITBA/AST/S/143(3)/2024- 25/1066855799(1) and relates to assessment year 2020-21.

2.

The assessee has raised following grounds of appeal: The grounds hereinafter taken by the appellant are without prejudice to one another. 1. The Appellant submits that the final assessment order passed by the assessing officer under section 143(3) read with Section 144C(13) read with Section 144B of the Act is barred by limitation as the same is passed beyond the time limit prescribed under section 153 of the Act and hence, the order is barred by limitation and liable to be quashed.

IT(TP)A No.1786/Bang/2024 M/s. Weir Minerals (India) Pvt. Ltd., Bangalore Page 2 of 13 The learned Assessing Officer ('learned AO'), learned Transfer Pricing Officer (learned TPO') and the Honourable Dispute Resolution Panel ('Hon'ble DRP') grossly erred in law and on facts, in determining transfer pricing adjustment of INR 2,54,55,857 and adding the same to the returned income of the Appellant.

Grounds relating to Transfer Pricing:

2.

General grounds: 2.1 The learned Assessing Officer (‘Learned AO’), learned Transfer Pricing Officer (‘learned TPO’) and the Honourable Dispute Resolution Panel (‘Hon’ble DRP’) grossly erred in law and on facts, in determining transfer pricing adjustment of INR 2,54,55,857 and adding the same to the returned income of the appellant. 2.2 The learned AO/ learned TPO/ Hon'ble DRP grossly erred in rejecting the Transfer Pricing ('TP') documentation maintained by the Appellant by invoking provisions of sub-section (3) of section 92C of the Act. 2.3 The learned AO/ learned TPO/ Hon'ble DRP grossly erred in rejecting comparability analysis undertaken in the TP documentation and in conducting a fresh comparability analysis by introducing various filters for the purpose of determining the Arm's Length Price ('ALP') of the international transaction thereby following a non-transparent approach. 3. GROUNDS RELATED TO ENGINEERING DESIGN SERVICE SEGMENT: 3.1 The learned AO/ learned TPO/ Hon'ble DRP erred in making transfer pricing adjustment of INR 1,95,00,000 to the Engineering Design Service Segment of the Appellant. 3.2 The learned AO/ learned TPO/ Hon'ble DRP grossly erred in selecting companies only if the data pertaining to financial year ('FY') 2019-20 is available in the public databases. 3.3 The learned AO/ learned TPO/ Hon'ble DRP erred in rejecting companies having different financial year ending (i.e., year ending other than 31 March), or the companies whose data do not fall within 12 month period. 3.4 The learned AO/ learned TPO/ Hon'ble DRP erred in applying threshold of 75 percent in the engineering design service ('EDS') income filter and selecting only companies having income from EDS services > 75 percent of total sales as comparable. 3.5 The learned AO/ learned TPO/ Hon'ble DRP erred in the methodology applied for calculation of the related party transaction filter. 3.6 The learned / learned TPO/ Hon'ble DRP erred in applying threshold of 75 percent in export service income filter.

IT(TP)A No.1786/Bang/2024 M/s. Weir Minerals (India) Pvt. Ltd., Bangalore Page 3 of 13 3.7 The learned AO/ learned TPO/ Hon'ble DRP erred in applying the filter of employee cost to total cost ratio less than 25 percent. 3.8 The learned AO/ learned TPO/ Hon'ble DRP erred in rejecting companies having losses for two out of three years. 3.9 The learned AO/ learned TPO/ Hon'ble DRP erred in not providing working capital adjustment for determining the arm's length price. 3.10 The learned AO/ learned TPO/ Hon'ble DRP erred in not providing market risk adjustment for determination of arm's length price. 3.11 The learned AO/ learned TPO/ Hon'ble DRP has grossly erred in rejecting the following companies: i Satyam Venture Engineering Services Pvt Ltd ii Accuspeed Engineering Services India Ltd iii Axiscades Engineering Technologies Ltd iv MAY Softech Private Limited v Sphinx Worldbiz Ltd vi Tata Consulting Engineers Limited vii Tata Elxsi Ltd 3.12 The learned AO/ learned TPO/ Hon'ble DRP has grossly erred in not rejecting the following companies: i. Mahindra Consulting Engineers Ltd — should be rejected ii. Genesys International Corporation Ltd — should be rejected iii. Sikraft Infotech Pvt Ltd — should be rejected

3.13 The learned AO/ learned TPO/ Hon'ble DRP has grossly margin computation of the following companies: i. Mahindra Consulting Engineers Ltd — should be rejected ii. Genesys International Corporation Ltd — should be rejected ii. Sikraft Infotech Pvt Ltd — should be rejected 4. GROUNDS RELATED TO INTEREST ON DELAYED RECEIVABLES: 4.1 The learned AO/ learned TPO/ Hon'ble DRP erred in making transfer pricing adjustment of INR 59,55,857 in relation to Interest on Delayed Receivables. 4.2 The learned AO/ learned TPO/ Hon'ble DRP erred in considering the delayed receipts as unsecured loans and imputed notional interest with regard to trade receivables.

IT(TP)A No.1786/Bang/2024 M/s. Weir Minerals (India) Pvt. Ltd., Bangalore Page 4 of 13 4.3 The learned AO/ learned TPO/ Hon'ble DRP erred in not considering that the outstanding receivables cannot be considered as a separate international transaction as it does not fall within the purview of capital financing as stated by Sec.92B of the Act. 4.4 The learned AO/ learned TPO/ Hon'ble DRP grossly erred in imputing interest on delayed receivables once the primary transaction has been tested by the learned TPO and has been accepted to be at arm's length using the Transactional Net Margin Method ("TNMM"). 4.5 The Hon'ble DRP while upholding the order of the learned AO/ learned TPO erred in not appreciating that the learned AO/ learned TPO had not adopted any of the methods prescribed under the Income-tax Rules, 1962 ("Rules"). 4.6 The learned AO/ learned TPO/ Hon'ble DRP erred in not appreciating the fact that the Act provides for taxing only real income whether received or accrued under the regular provisions and does not provide for taxing notional income. 4.7 The learned AO/ learned TPO/ Hon'ble DRP erred in not appreciating the fact that the TP adjustment has already subsumed any excess credit period and hence no separate adjustment ought to be made for the same. 4.8 The learned AO/ learned TPO/ Hon'ble DRP erred in adopting an ad-hoc interest rate being the average six-month LIBOR + 450 basis points without providing any benchmarking analysis/ exercise in accordance with any of the methods prescribed under the Rules. 4.9 Without prejudice to the above grounds, the learned AO/ learned TPO/ Hon'ble DRP erred in not offsetting the delayed payables against the delayed receivables while computing interest on such net delayed receivables. GROUNDS RELATING TO CORPORATE TAX: 5. Disallowance of provision towards audit fees under section 40(a)(i) of the Act 5.1 The Hon'ble DRP erred in law and on facts in concluding that it has no jurisdiction with respect to the adjustments made in intimation issued under section 143(1) without appreciating that the assessed income is determined having regard to the income as per intimation under section 143(1) of the Act. 5.2 The Hon'ble DRP erred in not adjudicating the objections filed by the Appellant in relation to adjustments made in the intimation issued under section 143(1) of the Act by stating that the proceedings under section 143(3) and 143(1) are separate and cannot be merged without appreciating the current facts in case of the Appellant.

IT(TP)A No.1786/Bang/2024 M/s. Weir Minerals (India) Pvt. Ltd., Bangalore Page 5 of 13 5.3 The learned Assessing Officer erred in law and on facts in disallowing entire expenses of Rs.8,00,000/- for failure to deduct taxes at source under section 40(a)(i) vis-å-vis 30% of the expense to be disallowed as required under section 40(a)(ia) of the Act.

5.4 The learned Assessing Officer ought to have observed that the Appellant had not deducted taxes at source on provision for audit fees payable to Price Waterhouse Chartered Accountants, LLP Bangalore i.e., a resident entity and thereby the provisions of section 40(a)(ia) would be attracted and not section 40(a)(i). 5.5 The learned AO ought to have considered the submission of the Appellant to note that the disallowance reported under clause 21(b) of the Form 3CD has been erroneously disclosed under section 40(a)(i) of the Act as payments to non-residents instead of section 40(a)(ia) as payment to resident which can be affirmed by the PAN and address of the party furnished by the Appellant. 5.6 The learned AO failed to appreciate the fact that the Appellant has already disallowed a sum of Rs. 2,40,000/- (i.e., 30% Rs.8,00,000) in return of income under section 40(a)(ia) and hence, the disallowance would result in double disallowance. 6. Arithmetical error in aggregation of interest levied under the provision of the Act: 6.1 The learned AO ought to have observed that the total interest computed under section 234A (Rs. 89,139), 234B (Rs. 27,99,928) and 234C (Rs. 2,55,041) aggregates to Rs. 31,44,108 vis-å-vis Rs. 34,33,740 considered while computing the total interest liability. 7. Levy of interest under section 234A of the Act 7.1 The learned AO erred in law and on facts by levying interest under section 234A of the Act. 7.2 The learned AO ought to have observed that the Appellant filed its return of income well within the statutory timeline (i.e., on 15 February 2021) as extended by the Central Board of Direct Taxes ('CBDT') vide notification number S.O. 4805(E) dated 31 December 2020. 7.3 Without prejudice to the above, the interest levied under section 234A of the Act is consequential to the above grounds of appeal. 8. Levy of interest under section 234B of the Act

8.1 The interest levied under section 234A of the Act is consequential to the above grounds of appeal.

IT(TP)A No.1786/Bang/2024 M/s. Weir Minerals (India) Pvt. Ltd., Bangalore Page 6 of 13 9. Levy of interest under section 234C of the Act 9.1 The learned AO erred in law and on facts by levying interest under section 234C of the Act on the assessed income. 9.2 Without prejudice to the above, the interest levied under section 234C of the Act is consequential to the above grounds of appeal.

3.

Brief facts of the case as coming out from the orders of authorities below are that the assessee is a company and engaged in the manufacturing and sale of pump valve and related components. It has filed its return of income for the impugned year on 15.2.2021 declaring an income of Rs.1,10,06,98,050/-. The return of income filed by the assessee was processed u/s 143(1) of the Income Tax Act, 1961 (in short “The Act”) and thereafter selected for scrutiny. During the course of assessment proceedings, the AO observed that the assessee has entered into international transaction with its AE. Hence, he made a reference to the TPO for computing the Arm’s length price (“ALP”) of international transactions. Pursuant to the directions of the AO, the ld. TPO vide its order dated 25.7.2023 has made following adjustments:

1.

Engineering consultancy services 4,14,16,565/- Segment 2. Interest on Delayed Receivables 59,55,857/- Total adjustment u/s 92CA 4,73,72,422/-

3.1 Accordingly, the AO made an addition of Rs.4,73,72,422/- and passed the draft assessment order. Aggrieved with the draft order of AO, the assessee preferred its objection before the ld. DRP. The ld. DRP vide its order dated 6.6.2024 directed the TPO for making certain adjustments and passed the order accordingly. However, the ld. TPO without considering the directions of the ld. DRP framed a fresh TP order on 10.7.2024, modifying the addition of Rs.4,73,72,422/- to Rs.2,54,55,857/- and thereafter, the AO framed the assessment accordingly.

IT(TP)A No.1786/Bang/2024 M/s. Weir Minerals (India) Pvt. Ltd., Bangalore Page 7 of 13

3.2 Aggrieved with the order of the AO, assessee has come up in appeal before us and has raised the above mentioned grounds.

4.

So far as ground No.1 is concerned, i.e. with respect to the limitation issue of the impugned order, the counsel for the assessee has drawn the attention of the bench towards letter dated 22.12.2024 and contended that the assessee has already withdrawn this ground. Therefore, the ground No.1 is dismissed as withdrawn.

5.

Ground No.2 is general in nature.

6.

In ground No.3, the assessee has basically challenged the action of the lower authorities i.e. TPO/DRP regarding non-inclusion of Satyam Venture Engineering Service Pvt. Ltd. as a comparable. Ld. Counsel for the assessee has contended that the ld. TPO/DRP have rejected Satyam Venture Engineering Service Pvt. Ltd. on the ground that it fails to testify the export filter. The ld. Counsel for the assessee pointed out that the financial statements of the said comparable were duly produced before the ld. TPO and the same are placed in paper book at page nos.1641 to 1660.

6.1 Ld. Counsel for the assessee contended that if the financial statements of the comparable Satyam Venture Engineering Service Pvt. Ltd would be seen on stand alone basis, then it would be abundantly clear that there was export income of that comparable and hence, the lower authorities have erred in concluding that the comparable does not have any export income. It is contended by the counsel for the assessee that the ld. DRP/TPO have wrongly relied upon the total income from operations as per the consolidated statement of profit & loss account of the comparable company namely Satyam Venture Engineering Service Pvt. Ltd. Ld. Counsel

IT(TP)A No.1786/Bang/2024 M/s. Weir Minerals (India) Pvt. Ltd., Bangalore Page 8 of 13 for the assessee has drawn the attention of the bench towards pages 1679 & 1698 of the paper book to demonstrate that the ld DRP and ld. DRP have considered the consolidated result of the comparable instead of considering the results on standalone basis. Lastly, it is contended by the ld. Counsel for the assessee that in subsequent year i.e. assessment year 2021-22, the ld. TPO while conducting the TP study in the case of present assessee has accepted the Satyam Venture Engineering Service Pvt. Ltd. as functionally comparable company.

7.

Ld. D.R. appearing on behalf of the revenue has contended that the average result of the comparable are to be considered and hence, the order of TPO is correct in law.

8.

We have heard the rival submissions and perused the materials available on record. We observe that the stand alone result of the comparable are as under:

IT(TP)A No.1786/Bang/2024 M/s. Weir Minerals (India) Pvt. Ltd., Bangalore Page 9 of 13 8.1 Perusal of the above results would show that there were export sales of the comparable to the tune of 76.24% and therefore, the authorities below have erred in concluding that there were no export sales in the sales in the case of M/s. Satyam Venture Engineering Service Pvt. Ltd. It is worthy to note that consolidated results, which have been considered by the ld. DRP and TPO are not for M/s. Satyam Venture Engineering Service Pvt. Ltd. alone, rather have contained the result of its subsidiaries also. Further, it is settled position of law that if a contention has been accepted by the revenue in subsequent year, then the same is to be applied in the previous year also because there has to be certainty and uniformity in the approach of revenue in respect of matters which can effect FDI. Reference can be made to the judgement of Hon’ble Delhi High Court in the case of Crane UK Holdings Ltd. Vs. DIT (359 ITR 268), wherein the Hon’ble Delhi High Court in para 35 has categorically observed as under:

8.2 Therefore, we are of the view that M/s. Satyam Venture Engineering Service Pvt. Ltd. shall be included in comparable list. We further observe that if this comparable alone is included in the list of comparables relied upon by the assessee, then the assessee will get desirable ALP and there is no need to include the other comparables (as contended by the AR of the assessee). Therefore, we

IT(TP)A No.1786/Bang/2024 M/s. Weir Minerals (India) Pvt. Ltd., Bangalore Page 10 of 13 direct the TPO to conduct a fresh TP study after including this comparable for determining the ALP. So far as the inclusion of other comparables mentioned in ground No.3.11 running from sl.nos.(ii) to (vii), we observe that the inclusion of these comparables will become academic, therefore, we deem it not to comment upon them.

9.

In ground No.3.13, the counsel for the assessee has pointed out that the ld. TPO has erred, by considering bad debts as non- operational expenses, while selecting Mahindra & Genesis as a comparable. In other words, the counsel for the assessee has contended that the TPO ought to have considered bad debts as operating expenses while selecting both these comparables for computing the ALP. Ld. Counsel for the assessee contended that the ld. DRP while adjudicating the objections of the assessee categorically directed the TPO that while computing the margin of Mahindra & Genesis the TPO must include bad debts as operating expenses. Ld. Counsel for the assessee further drawn the attention of the bench towards pages 1760 & 1772 of the paper book to contend that Mahindra & Mahindra have written off the bad debts as operating expenses under the head “Expense – Other Expenses”. Further, ld. Counsel for the assessee placed reliance on the judgement of the coordinate bench in the case of Hitachi Energy Technology in IT(TP)A No.1529/Bang/2024 and contended that the Hon’ble ITAT has categorically held that while computing PLI, the TPO should include the bad debts written off as operating expenses.

10.

Ld. D.R. relied upon the orders of authorities below.

11.

After considering the rival submissions and perusing the material available on record, we observe that the ld. DRP has categorically directed the TPO to verify the accounts/financial results of both these comparables i.e. Mahindra & Genesis and directed the

IT(TP)A No.1786/Bang/2024 M/s. Weir Minerals (India) Pvt. Ltd., Bangalore Page 11 of 13 TPO to recompute profit margin of these companies. However, the ld. TPO failed to consider the directions of the ld. DRP. It is settled position of law in terms of section 144C(10) of the Act, which says that every directions of the ld. DRP shall be binding on the AO as well as TPO. Therefore, we direct the TPO to recompute the profit margins of both these comparables afresh in the light of the observations made by us and also by the coordinate bench in its decision in the case of Hitachi Energy Technology(Supra).

12.

With respect to ground No.4 i.e. interest on delayed receivables. Counsel for the assessee contended that LIBOR+200 basis points is acceptable to the assessee in place of LIBOR+450 points as computed by the ld. TPO. Ld. Counsel fairly conceded that he would not like to press the issue whether this transaction is an international transaction or not.

13.

Ld. D.R. relied upon the orders of authorities below.

14.

We have considered the rival submissions and perused the materials available on record. Considering the facts and circumstances of the case, we are of the view that LIBOR+200 basis points are legally justifiable with respect to the transaction of interest on delayed receivables. Our view is fortified by the judgement of coordinate bench in Bio Plus Life Science Vs. DCIT reported in 138 taxmann.com 297, Value Momentum Software Pvt. Ltd. Vs. ACIT 163 taxmann.com 14 (Hyd). Therefore, this ground of assessee is partly allowed as indicted above.

15.

In ground No.5, the ld. Counsel for the assessee has contended that the CPC while processing the return u/s 143(1) of the Act has made an adjustment of Rs.8 lakhs by disallowing the payments made to a non-resident for conducting the audit of the assessee company

IT(TP)A No.1786/Bang/2024 M/s. Weir Minerals (India) Pvt. Ltd., Bangalore Page 12 of 13 on the ground that the assessee failed to deduct TDS and hence as per the provisions u/s 40(a)(i) of the Act, the impugned sum is not deductible.

16.

Ld. Counsel for the assessee contended that the CPC has erred in assuming that payments have been made to a non-resident. He contended that fact of the matter is that the payments have been made to a resident as evident from the PAN number of the deductee. Ld. Counsel for the assessee further contended that if at all any sum is required to be disallowed, then 30% of the sum paid is only required to be disallowed.

17.

Ld. D.R. contended that the application for 154 filed by the assessee with the department is still pending and hence the assessee could not raise this issue in these proceedings.

18.

After considering the rival submissions, we are of the view that the contention of the assessee, though not emerging from the present proceedings, however, once the order of assessment is passed, the proceedings u/s 143(1) of the Act are also merged in that order. Therefore, in the interest of justice and to avoid multiplicity of the proceedings, we direct the AO to expeditiously dispose of the application u/s 154 of the Act, filed by the assessee and do the needful.

IT(TP)A No.1786/Bang/2024 M/s. Weir Minerals (India) Pvt. Ltd., Bangalore Page 13 of 13 19. In the result, appeal of the assessee is allowed as indicated above.

Order pronounced in the open court on 15th Jan, 2025

Sd/- Sd/- (Waseem Ahmed) (Prakash Chand Yadav) Accountant Member Judicial Member

Bangalore, Dated 15th Jan, 2025. VG/SPS

Copy to:

1.

The Applicant 2. The Respondent 3. The CIT 4. The DR, ITAT, Bangalore. 5 Guard file By order

Asst. Registrar, ITAT, Bangalore.

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