Avenue Asia Advisors Pvt. Ltd. v. DCIT

Fireeye Cybersecurity Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result, the appeal filed by the assessee stands partly allowed

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuit(Tp)A No. 292/Bang/2021 Assessment Year : 2016-17 M/S. Mandiant Cyber Security Pvt. Ltd. (Formerly Known As Fireeye The Deputy Cybersecurity Pvt. Commissioner Of Ltd.), Income Tax, No. 5, Front Wing Circle – 3(1)(1), Salarpuria Infinity, Vs. Bengaluru. 2Nd Floor, Bannerghatta Road, Bengaluru – 560 029. Pan: Aaccf1341A Appellant Respondent : Shri T. Suryanarayana, Assessee By Senior Advocate Revenue By : Shri Vilas Shinde, Cit Dr Date Of Hearing : 26-09-2022 Date Of Pronouncement : 10-11-2022 Order Per Beena Pillaipresent Appeal Arises Out Of Order Passed By National E- Assessment Centre, Delhi Dated 30/04/2021 On Following Revised Grounds Of Appeal:

…he supplies made to an AE, the arrangement reflected an international transaction intended to benefit the AE in some way. Similar matter once again came up for consideration before the Hon'ble Delhi High Court in Avenue Asia Advisors Pvt. Ltd. vs. DCIT (2017) 398 ITR 120 (Del). Following the earlier decision in Kusum Healthcare (supra), it was observed that there are several factors which need to be considered before holding that every receivable is an international transaction and it requires an assessment on the working capital of the assessee. Applying the decision in Kusum Health Care (supra), the Hon'ble Hig…

Medreich Limited, Bangalore vs. Assistant Commissioner of Income Tax, Central Circle-1(2), Bangalore

In the result, the appeal filed by the assessee stands allowed as indicated hereinabove

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 451/Bang/2022 Assessment Year : 2017-18 M/S. Medreich Ltd., No. 12/8, Medreich The Assistant House, Commissioner Of Saraswati Ammal Income Tax, Street, Central Circle – Maruti Seva Nagar, 1(2), Vs. Bangalore – 560 033. Bangalore. Pan: Aabcm1458Q Appellant Respondent : Shri Padam Chand Assessee By Khincha, Ca : Shri Praveen Karanth, Revenue By Cit-Dr Date Of Hearing : 27-07-2022 Date Of Pronouncement : 21-10-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Passed By The Ld.Acit, Central Circle – 1(2), Bangalore Dated 26/04/2022 For A.Y. 2017-18 On Following Grounds Of Appeal: “General Ground 1.1 The Learned Assistant Commissioner Of Income Tax, Central Circle-1(2), Bangalore (`A0') Erred In Passing The Assessment Order Under Section 143(3) R.W.S 144C(13) Of The Income Tax Act, 1961 (`The Act) In The Manner Passed

…he supplies made to an AE, the arrangement reflected an international transaction intended to benefit the AE in some way. Similar matter once again came up for consideration before the Hon'ble Delhi High Court in Avenue Asia Advisors Pvt. Ltd. vs. DCIT (2017) 398 ITR 120 (Del). Following the earlier decision in Kusum Healthcare (supra), it was observed that there are several factors which need to be considered before holding that every receivable is an international transaction and it requires an assessment on the working capital of the assessee. Applying the decision in Kusum Health Care (supra), the Hon'ble Hig…

M/.S Synamedia India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle- 6(1)(2), Bangalore

In the result, the appeal filed by assessee stands allowed in respect of the issues argued and considered hereinabove

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 2595/Bang/2019 Assessment Year : 2015-16 M/S. Synamedia India Pvt. Ltd., Block 9A & 9B, The Deputy Pritech Park, Commissioner Of Survey No. 51-64/4, Income Tax, Sarjapur Outer Ring Circle – 6(1)(2), Road, Bengaluru. Vs. Bellandur Village, Bengaluru – 560 103. Pan: Aaccn1140K Appellant Respondent Assessee By : Shri Ankur Pai, Advocate : Shri Praveen Karanth, Revenue By Cit-Dr Date Of Hearing : 28-07-2022 Date Of Pronouncement : 21-10-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Dated 29/10/2019 Passed By The Ld.Dcit, Circle – 6(1)(2), Bangalore For A.Y. 2014-15 On Following Grounds Of Appeal:

…he supplies made to an AE, the arrangement reflected an international transaction intended to benefit the AE in some way. Similar matter once again came up for consideration before the Hon’ble Delhi High Court in Avenue Asia Advisors Pvt. Ltd. vs. DCIT (2017) 398 ITR 120 (Del). Following the earlier decision in Kusum Healthcare (supra), it was observed that there are several factors which need to be considered before holding that every receivable is an international transaction and it requires an assessment on the working capital of the assessee. Applying the decision in Kusum Health Care (supra), the Hon’ble Hig…

M/S. Tivo Tech Private Limited (Formerly Known As Veveo (India) Private Limited), Bangalore vs. Deputy Commissioner of Income Tax, Circle-7(1)(1), Bangalore

In the result, the appeal by the assessee is partly allowed

Bench: Shri George George K. & Ms. Padmavathy S

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH : BANGALORE BEFORE SHRI GEORGE GEORGE K., JUDICIAL MEMBER AND Ms. PADMAVATHY S, ACCOUNTANT MEMBER IT(TP)A No.237/Bang/2021 Assessment year : 2016-17 M/s. TiVo Tech Private Limited Vs. The Deputy Commissioner [formerly Veveo (India) Private Ltd.), of Income Tax, 10th Floor, Primrose 7B, Circle 7(1)(1), Embassy Tech Village, Bangalore. Outer Ring Road, Devarabisanahalli Village, Bangalore – 560 103. PAN: AABCV 9504G ASSESSEE RESPONDENT Assessee by : Smt. Tanmayee Rajkumar, Advocate Respondent by : Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru. Date of hearing…

Wipro Ge Healthcare Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle-7(1)(1), Bangalore

In the result, the appeal filed by the assessee in IT(TP)A No

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…the supplies made to an AE, the arrangement reflected an international transaction intended to benefit the AE in some way. Similar matter once again came up for consideration before the Hon'ble Delhi High Court in Avenue Asia Advisors Pvt. Ltd v. DCIT [2017] 398 ITR 120 (Del). Following the earlier decision in Kusum Healthcare (supra), it was observed that there are several factors which need to be considered before holding that every receivable is an international transaction and it requires an assessment on the working capital of the assessee. Applying the decision in Kusum Health Care (supra), the Hon'ble Hig…

Wipro Ge Healthcare Private Limited (Earlier Known As Ge Medical Systems India Private Limited), Bangalore vs. Deputy Commissioner of Income Tax, Circle-7(1)(1), Bangalore

In the result, the appeal filed by the assessee in IT(TP)A No

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…the supplies made to an AE, the arrangement reflected an international transaction intended to benefit the AE in some way. Similar matter once again came up for consideration before the Hon'ble Delhi High Court in Avenue Asia Advisors Pvt. Ltd v. DCIT [2017] 398 ITR 120 (Del). Following the earlier decision in Kusum Healthcare (supra), it was observed that there are several factors which need to be considered before holding that every receivable is an international transaction and it requires an assessment on the working capital of the assessee. Applying the decision in Kusum Health Care (supra), the Hon'ble Hig…

Ntt Data Fa Insurance Systems (India) Private Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result, appeal of the assessee is partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.261/Bang/2021 Assessment Year: 2016-17

…the supplies made to an AE, the arrangement reflected an international transaction intended to benefit the AE in some way. Similar matter once again came up for consideration before the Hon'ble Delhi High Court in Avenue Asia Advisors Pvt. Ltd v. DCIT [2017] 398 ITR 120 (Del). Following the earlier decision in Kusum Healthcare (supra), it was observed that there are several factors which need to be considered before holding that every receivable is an international transaction and it requires an assessment on the working capital of the assessee. Applying the decision in Kusum Health Care (supra), the Hon'ble Hig…

Hewlett Packard (India) Software Operation Private Limited, 2016-17 vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.213/Bang/2021 Assessment Year: 2016-17

…the supplies made to an AE, the arrangement reflected an international transaction intended to benefit the AE in some way. Similar matter once again came up for consideration before the Hon'ble Delhi High Court in Avenue Asia Advisors Pvt. Ltd v. DCIT [2017] 398 ITR 120 (Del). Following the earlier decision in Kusum Healthcare (supra), it was observed that there are several factors which need to be considered before holding that every receivable is an international transaction and it requires an assessment on the working capital of the assessee. Applying the decision in Kusum Health Care (supra), the Hon'ble Hig…

M/S. Harman Connected Services Corporation India Private Limited, Bengaluru vs. Assistant Commissioner of Income Tax, Circle- 3(1)(2), Bengaluru

In the result, the appeal is partly allowed

Bench: Shri N.V. Vasudevan & Ms. Padmavathy S

…the supplies made to an AE, the arrangement reflected an international transaction intended to benefit the AE in some way. Similar matter once again came up for consideration before the Hon'ble Delhi High Court in Avenue Asia Advisors Pvt. Ltd v. DCIT [2017] 398 ITR 120 (Del). Following the earlier decision in Kusum Healthcare (supra), it was observed that there are several factors which need to be considered before holding that every receivable is an international transaction and it requires an assessment on the working capital of the assessee. Applying the decision in Kusum Health Care (supra), the Hon'ble Hig…

Arm Embedded Technologies Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle- 1(1)(1), Bengaluru

In the result, appeal of the assessee stands partly allowed

…he supplies made to an AE, the arrangement reflected an international transaction intended to benefit the AE in some way. Similar matter once again came up for consideration before the Hon'ble Delhi High Court in Avenue Asia Advisors Pvt. Ltd. vs. DCIT (2017) 398 ITR 120 (Del). Following the earlier decision in Kusum Healthcare (supra), it was observed that there are several factors which need to be considered before holding that every receivable is an international transaction and it requires an assessment on the working capital of the assessee. Applying the decision in Kusum Health Care (supra), the Hon'ble Hig…

M/S Infineon Technologies India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-3(1)(1), Bangalore

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 3355/Bang/2018 Assessment Year : 2014-15 M/S. Infineon Technologies India Pvt. The Deputy Ltd., Commissioner Of 9Th Floor, Prestige Income Tax, Thirulakshmi, Circle – 3(1)(1), No. 11, Mg Road, Vs. Bangalore. Bangalore. Pan: Aabcs6967N Appellant Respondent : Shri K.R. Vasudevan, Assessee By Advocate : Shri Sumer Singh Meena, Revenue By Cit Dr Date Of Hearing : 12-07-2022 Date Of Pronouncement : 25-08-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Assessment Order Dated 26/10/2018 By The Ld.Dcit, Circle – 3(1)(1), Bangalore On Following Grounds Of Appeal: “A. Transfer Pricing The Grounds Mentioned Hereinafter Are Without Prejudice To One Another. 1. The Learned Assessing Officer ('Learned Ao'), Learned Transfer Pricing Officer ('Learned Tpo') & The Honourable Dispute Resolution Panel ('Hon'Ble Drp') Grossly Erred In Adjusting The Transfer Price By Inr 9,56,93,721/- With Respect To The International

…the supplies made to an AE, the arrangement reflected an international transaction intended to benefit the AE in some way. Similar matter once again came up for consideration before the Hon'ble Delhi High Court in Avenue Asia Advisors Pvt. Ltd. v. DCIT [2017] 398 ITR 120 (Del). Following the earlier decision in Kusum Healthcare (supra), it was observed that there are several factors which need to be considered before holding that every receivable is an international transaction and it requires an assessment on the working capital of the assessee. Applying the decision in Kusum Health Care (supra), the Hon'ble Hig…

M/S. Meritor C vs. India Private Limited, Bangalore

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…he supplies made to an AE, the arrangement reflected an international transaction intended to benefit the AE in some way. Similar matter once again came up for consideration before the Hon’ble Delhi High Court in Avenue Asia Advisors Pvt. Ltd. vs. DCIT (2017) 398 ITR 120 (Del). Following the earlier decision in Kusum Healthcare (supra), it was observed that there are several factors which need to be considered before holding that every receivable is an international transaction and it requires an assessment on the working capital of the assessee. Applying the decision in Kusum Health Care (supra), the Hon’ble Hig…

M/S Quicklogic Software (India) Pvt. Ltd., Bangalore vs. Deputy Commissioner of Income-Tax, Circle-3(1)(1), Bengaluru

In the result, the appeal filed by the assessee stands partly allowed

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 181/Bang/2022 Assessment Year : 2017-18 M/S. Quicklogic Software (India) Pvt. Ltd., No. 10 Brindavan, The Deputy 3Rd Floor, Commissioner Of Yashoda Nagar Main Income Tax, Road, Circle 3(1)(1), Jakkur Plantation, Vs. Bangalore. Bengaluru – 560 064. Pan: Aaacq0656P Appellant Respondent Assessee By : Shri Mahaveer C Jain, Ca : Shri Sumer Singh Meena Cit Revenue By Dr Date Of Hearing : 12-07-2022 Date Of Pronouncement : 27-07-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Order Dated 25/01/2022 By The National Faceless Assessment Centre For A.Y. 2017-18 On Following Revised Grounds Of Appeal:

…he supplies made to an AE, the arrangement reflected an international transaction intended to benefit the AE in some way. Similar matter once again came up for consideration before the Hon’ble Delhi High Court in Avenue Asia Advisors Pvt. Ltd. vs. DCIT (2017) 398 ITR 120 (Del). Following the earlier decision in Kusum Healthcare (supra), it was observed that there are several factors which need to be considered before holding that every receivable is an international transaction and it requires an assessment on the working capital of the assessee. Applying the decision in Kusum Health Care (supra), the Hon’ble Hig…

M/S Ingersoll-Rand Technologies and Services Private Limited, Bangalore vs. The Assistant Commissioner of Income Tax Circle-3(1)(1), Bangalore

Bench: Shri George George K. & Ms. Padmavathy S

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH : BANGALORE BEFORE SHRI GEORGE GEORGE K., JUDICIAL MEMBER AND Ms. PADMAVATHY S, ACCOUNTANT MEMBER IT(TP)A Nos.728/Bang/2017 Assessment year : 2012-13 Ingersoll-Rand Technologies & Services Vs. The Assistant Pvt. Ltd., Commissioner of Income PAN: AAACI 2961B Tax, Circle 3(1)(1), 8th Floor, Tower D, IBC Knowledge Bengaluru. Park, No.4/1, Bannerghatta Main Road, Bengaluru – 560 029. APPELLANT RESPONDENT Appellant(s) by : Shri Ankur Pai, CA Respondent by : Shri Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru. Date of hearing : 13.07.2022 Date of Pronouncement : 25.07.202…

Cisco Systems Capital (India) Private Limited, Bengaluru vs. Joint Commissioner of Income Tax, Circle- 2(1)(1), Bangalore

In the result, the assessee’s appeal is partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…the supplies made to an AE, the arrangement reflected an international transaction intended to benefit the AE in some way. Similar matter once again came up for consideration before the Hon'ble Delhi High Court in Avenue Asia Advisors Pvt. Ltd v. DCIT [2017] 398 ITR 120 (Del). Following the earlier decision in Kusum Healthcare (supra), it was observed that there are several factors which need to be considered before holding that every receivable is an international transaction and it requires an assessment on the working capital of the assessee. Applying the decision in Kusum Health Care (supra), the Hon'ble Hig…

M/S Subex Limited, Bangalore vs. Income Tax Officer Ward-6(1)(4), Bangalore

In the result, the appeal filed by the assessee stands partly allowed

Bench: Smt. Beena Pillai & Shri. Laxmi Prasad Sahuit(Tp)A No. 107/Bang/2019 Assessment Year : 2014-15 M/S. Subex Ltd., Rmz Ecoworld, The Income Tax Outer Ring Road, Officer, Devarabisanahalli, Ward – 6 (1)(4), Bangalore – 560 103. Bangalore. Vs. Pan: Aabcs9255R Appellant Respondent Assessee By : Shri Ajay Rotti, Ca : Shri Sunil Kumar Singh, Cit- Revenue By Dr Date Of Hearing : 07-06-2022 Date Of Pronouncement : 14-07-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Order Dated 26/10/2018 Passed By Ld.Ito, Ward – 6(1)(4), Bangalore For A.Y. 2014-15 On Following Grounds Of Appeal: “The Grounds Stated Hereunder Are Independent Of & Without Prejudice To One Another. The Appellant Submits As Under: 1. Assessment & Reference To Learned Transfer Pricing Officer Are Bad In Law 1.1. The Income Tax Officer. Ward — 6(1)(4), Bangalore (Learned Assessing Officer Or 'Ld. Ao') Erred In Making A Reference To The Deputy Commissioner Of Income-Tax, Transfer Pricing —Range 2(2)(1) (Learned Transfer Pricing Officer' Or 'Ld. Tpo'), Inter Alia, Since He Has Not Recorded

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH : BANGALORE BEFORE SMT. BEENA PILLAI, JUDICIAL MEMBER AND SHRI. LAXMI PRASAD SAHU, ACCOUNTANT MEMBER IT(TP)A No. 107/Bang/2019 Assessment Year : 2014-15 M/s. Subex Ltd., RMZ Ecoworld, The Income tax Outer Ring Road, Officer, Devarabisanahalli, Ward – 6 (1)(4), Bangalore – 560 103. Bangalore. Vs. PAN: AABCS9255R APPELLANT RESPONDENT Assessee by : Shri Ajay Rotti, CA : Shri Sunil Kumar Singh, CIT- Revenue by DR Date of Hearing : 07-06-2022 Date of Pronouncement : 14-07-2022 ORDER PER BEENA PILLAI, JUDICIAL MEMBER Present appeal is filed by assessee against order dated…

M/S. Subex Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle- 6(1)(2), Bangalore

In the result, the appeal filed by the assessee stands partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 2579/Bang/2019 Assessment Year : 2015-16 M/S. Subex Ltd., The Deputy Rmz Ecoworld, Commissioner Of Outer Ring Road, Income Tax, Devarabisanahalli, Circle – 6(1)(2), Bangalore – 560 103. Vs. Bangalore. Pan: Aabcs9255R Appellant Respondent Assessee By : Shri Ajay Rotti, Ca : Shri Sumer Singh Meena, Revenue By Cit-Dr Date Of Hearing : 11-07-2022 Date Of Pronouncement : 11-07-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Dated 23/10/2019 Passed By Ld.Dcit, Circle – 6(1)(2), Bangalore For A.Y. 2015-16 On Following Grounds Of Appeal: “The Grounds Stated Hereunder Are Independent Of & Without Prejudice To One Another. The Appellant Submits As Under: 1. Erroneous Transfer Pricing Adjustments Arising From Interest On Trade Receivables 1.1. The Deputy Commissioner Of Income Tax, Circle - 6(1)(2), Bangalore (Learned Assessing Officer' Or 'Ld. Ao') / Assistant Commissioner Of Income Tax, Transfer Pricing Circle - 1(3)(1) ('Learned Transfer Pricing Officer' Or 'Ld.

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH : BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER IT(TP)A No. 2579/Bang/2019 Assessment Year : 2015-16 M/s. Subex Ltd., The Deputy RMZ Ecoworld, Commissioner of Outer Ring Road, Income Tax, Devarabisanahalli, Circle – 6(1)(2), Bangalore – 560 103. Vs. Bangalore. PAN: AABCS9255R APPELLANT RESPONDENT Assessee by : Shri Ajay Rotti, CA : Shri Sumer Singh Meena, Revenue by CIT-DR Date of Hearing : 11-07-2022 Date of Pronouncement : 11-07-2022 ORDER PER BEENA PILLAI, JUDICIAL MEMBER Present appeal is filed by assessee against…

M/S. Outsourcepartners International Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle- 5(1)(2), Bangalore

In the result, the appeal by the assessee is partly allowed

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH : BANGALORE BEFORE SHRI N.V. VASUDEVAN, VICE PRESEIDENT AND SHRI PADMAVATHY S, ACCOUNTANT MEMBER IT(TP)A No.35/Bang/2020 Assessment year : 2015-16 Outsourcepartners International Pvt. Ltd., Vs. The Assistant Commissioner Tower 2D, Embassy Tech Village, of Income Tax, Devarabeesanahalli Outer Ring Road, Circle 5(1)(2), Bangalore – 560 037. Bangalore. PAN : AAACO 5734C APPELLANT RESPONDENT Appellant by : Shri K.R. Vasudevan, Advocate Respondent by : Shri V.S. Chakrapani, CIT(DR)(ITAT), Bengaluru. Date of hearing : 20.06.2022 Date of Pronouncement : 24.06.2022 O R…

M/S Applied Materials India Private Limited, Bangalore vs. Income Tax Officer Ward-1(1)(1), Bangalore

In the result, the appeal of the assessee is partly allowed

Bench: Shri George George K. & Ms. Padmavathy S

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH : BANGALORE BEFORE SHRI GEORGE GEORGE K., JUDICIAL MEMBER AND Ms. PADMAVATHY S, ACCOUNTANT MEMBER IT(TP)A No.3403/Bang/2018 Assessment year : 2014-15 Applied Materials India Pvt. Ltd., Vs. The Income Tax Officer, Unit 5, 3rd Floor, Explorer Building, Ward 1(1)(1), International Tech Park, Bangalore. Whitefield Road, Bangalore – 560 066. PAN: AAECA 2635C ASSESSEE RESPONDENT Assessee by : Smt. Tanmayee Rajkumar, Advocate Respondent by : Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bangalore. Date of hearing : 30.05.2022 Date of Pronouncement : 08.06.2022 O R D E R Pe…