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TMI Blog2015 (3) TMI 401X X X X Extracts X X X X X X X X Extracts X X X X ..... f Income-tax (Transfer Pricing)-I, Bangalore ('Transfer Pricing Officer' or 'TPO'). 3. That the learned AO and the learned Panel erred both in facts and law in confirming the action of the learned TPO of making an adjustment to the transfer price of the Appellant in respect of its software development and support services segments, holding that the international transactions do not satisfy the arm's length principle envisaged under the Income Tax Act, 1961 (the 'Act') and in doing so grossly erred in: 3.1 Upholding the rejection of comparability analysis of the Appellant in the TP documentation and confirming the comparability analysis as adopted by the learned TPO in the TP Order. 3.2 Disregarding application of multiple year/prior year data as used by the Appellant in the TP documentation and holding that current year (i.e. Financial Year 2006-07) data for comparable companies should be used. 4. That the learned AO and the learned Panel erred in upholding the adjustment of Rs. 38 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y the Assessee and the TPO's analysis of the ALP was as follows:- B. Analysis of transfer pricing studies of the assessee and the TPO for software development services B.1. Net margin on cost earned by Logica (the Assessee): Operating Income Rs. 234,26,60,885/- Operating Expenses Rs. 214,92,30,171/- Operating Profit (Op. Income - Op. Expenses) Rs. 19,34,30,714/- Operating/Net margin (OP/TC) 9% B.2. Comparison of TP study done by Logica and TPO: LOGICA TPO Methodology adopted TNMM TNMM Profit Level Indicator (PLI) OP/TC OPATC Database used PROWESS& CAPITALINE PROWESS & CAPITALINE Comparables selected for software development services 18 26 B.3. Filters applied by Logicain its TP study: Step 1 Selection of universal set of companies 2 Companies with ratio of other operating income to sales greater than 50% to select companies engaged in services - retained 3 Companies with ratio of research and development expenses to sales greater than 3 % indicating possible ownership of intangibles and/or significant activities not involved in pure service provision -rejected 4 Companies with ratio of net fixed assets to sale ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by the TPO in his TP study: Prowess Database: Step Description No. of Companies Resulted No. of Companies Eliminated 1 No. of companies resulted by the key word "Computer Software" 801 2 The companies for which the data is available for the FY 2006-07 477 324 3 The companies which have service income 403 74 4 The companies whose turnover is more than Rs. 1 crore 302 101 5 The companies whose service income is more than 75% of the revenues 292 10 6 The companies whose export revenues are more than 25% of the revenues 168 124 7 The companies whose employee cost is greater than 25% of the revenues 132 36 8 Related Party Transactions < 25% of the revenues 82 50 Balance for review 82 Capitaline Pius Database: Step Description No. of Companies Resulted No. of Companies Eliminated 1 No. of companies resulted by the key word "Computer Software" and The companies for which the data is available for the FY 2006-07 243 2 The companies whose turnover is more than Rs. 1 crore 217 26 3 The companies whose export revenues are more than 25% of the revenues 150 67 4 The companies whose employee cost is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... The AO accordingly made the addition by way of TP adjustment to the total income of the assesse in the final assessment order. Against the order of the AO, the assessee has raised ground Nos. 2 to 4 before the Tribunal. 7. We have heard the submissions of the ld. counsel for the assessee and the ld. DR. The first and foremost submission of the ld. counsel for the assessee was that the TPO while working out the Profit Level Indicator (PLI) of the operating cost/total cost, arrived at a percentage of 6.88% as follows:- Revenue Rs.234,26,60,885/- Less: Operating expenses Rs.219,19,46,556/- Operating profit Rs.15,07,14,329/- Operating profit /total cost 6.88% 8. The ld. counsel for the assessee brought to our notice that a sum of Rs. 4,27,16,385 was reversal of expenses and these had to be reduced from the operating and other expenses. In this regard, the ld .counsel for the assessee pointed out that while making the adjustment to the ALP, the AO took the operating cost at Rs. 219,19,46,556 and further added a sum of Rs. 4,27,16,385 which was reversal of expenses received. He therefore arrived at an operating cost of Rs. 223,46,62,941. It was pointed out by him that the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Avani Cimcon Technologies Ltd. 39. As far as this company is concerned, the plea of the Assessee has been that this company is functionally different from the assessee. Based on the information available in the company's website, which reveals that this company has developed a software product by name "DX change", it was submitted that this company would have revenue from software product sales apart from rendering of software services and therefore is functionally different from the assessee. It was further submitted that the Mumbai Bench of the Tribunal to the decision in the case of Telcordia Technologies Pvt. Ltd. v. ACIT - ITA No.7821/Mum/2011 wherein the Tribunal accepted the assessee's contention that this company has revenue from software product and observed that in the absence of segmental details, Avani Cincom cannot be considered as comparable to the assessee who was rendering software development services only and it was held as follows:- "7.8 Avani Cincom Technologies Ltd. ('Avani Cincom'): Here in this case also the segm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ly a research & development company. In this regard, the following submissions were made:- * In the Director's Report (page 20 of PB-Il), it is stated that "the company has applied for Income Tax concession for in-house R&D centre expenditure at Hyderabad under section 35(2AB) of the Income Tax Act." * As per the Notes to Accounts - Schedule 15, under "Deferred Revenue Expenditure" (page 31 of PB-II), it is mentioned that, "Expenditure incurred on research and development of new products has been treated as deferred revenue expenditure and the same has been written off in 10 years equally yearly installments from the year in which it is incurred." * An amount of Rs. 11,692,020/- has been debited to the Profit and Loss Account as "Deferred Revenue Expenditure" (page 30 of PB-II). This amounts to nearly 8.28 percent of the sales of this company. It was therefore submitted that the acceptance of this company as a comparable for the reason that it is into pure software development activities and is not engaged in R&D activities is bad in law. 43. Further reference was also made ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or which patenting process was also being pursued. As explained earlier it is a diversified company and therefore cannot be considered as comparable functionally with that of the Assessee. There has been no attempt made to identify and eliminate and make adjustment of the profit margins so that the difference in functional comparability can be eliminated. By not resorting to such a process of making adjustment, the TPO has rendered this company as not qualifying for comparability. We therefore accept the plea of the Assessee in this regard." 44. It was submitted that the learned DR in the above case vehemently argued that this company is into research in pharmaceutical products. The ITAT concluded that this company is owner of IPR, it has software for discovery of new drugs and has developed molecule to treat cancer. In the ultimate analysis, the ITAT did not consider this company as a comparable in clinical trial segment, for the reason that this company has diverse business. It was submitted that, however, from the above extracts it is clear that this company is not into software development activities, accordingly, th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng the funds garnered though the Initial Public Offer (IPO) and thus in no way connected with business operations of the company during FY 06-07. We are of the view that in the light of the submissions made by the Assessee and the fact that this company was basically/admittedly in clinical research and manufacture of bio products and other products, there is no clear basis on which the TPO concluded that this company was mainly in the business of providing software development services. We therefore accept the plea of the Assessee that this company ought not to have been considered as comparable. (d) KALS Information Systems Ltd. 46. As far as this company is concerned, the contention of the assessee is that the aforesaid company has revenues from both software development and software products. Besides the above, it was also pointed out that this company is engaged in providing training. It was also submitted that as per the annual repot, the salary cost debited under the software development expenditure was Rs. 45,93,351. The same was less than 25% of the software services revenue and therefore the salary cost f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... omplaint of the assessee is that this company is not a pure software development service company. It is further submitted that in a Mumbai Tribunal Decision of Capgemini India (F) Ltd v. Ad. CIT 12 Taxman.com 51, the DRP accepted the contention of the assessee that Accel Transmatic should be rejected as comparable. The relevant observations of DRP as extracted by the ITAT in its order are as follows: "In regard to Accel Transmatics Ltd. the assessee submitted the company profile and its annual report for financial year 2005-06 from which the DRP noted that the business activities of the company were as under. (i) Transmatic system - design, development and manufacture of multifunction kiosks Queue management system, ticket vending system (ii) Ushus Technologies - offshore development centre for embedded software, network system, imaging technologies, outsourced product development (iii) Accel IT Academy (the net stop for engineers)-training services in hardware and networking, enterprise sys ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... involved in development of software product. The learned AR has tried to distinguish by pointing out that product development expenditure in this case is around 39% of the capital employed by the said company, and, therefore, such a company cannot be considered as tested party. Even as per the information received in response to notice under Section 133(6), the company has described its business as software development company or pure software development service provider. This information itself is very vague as the segmental details of operating revenue has not been made available to examine how much is the ratio of sale from software product and sale of software service and development. Looking to the fact that it has developed a software product named as "Muulam" which is used for civil engineering structures and the product development expenditure itself is substantial vis-a-vis the capital employed by the said company, this criteria for being taken as comparable party, gets vitiated. For the purpose of comparability analysis, it is essential that the characteristics and the functions are by and large similar as that of the assessee company and T.P. analysis/study can be made ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d' (ITA No.3856/Delhi/2010), wherein it was held that lnfosys is a giant in the area of development of software and it assumes all risks, leading to higher profit and cannot be compared with the company which is a captive unit of its parent company assuming only limited currency risk. In view of the above finding, we hold that the Infosys cannot be taken as a comparable for determining the arms length price in the case of the assessee. 7.5 Wipro Ltd.-IT Services Seqment ('Wipro'): This company is also a global IT Company having varieties of service and products and looking to the magnitude of its operations, sales and expenses, the same cannot be taken into consideration for comparability analysis. Moreover, 67% of its sales relates to its product which are sold on premium resulting into higher profitability, therefore, cannot be compared with the assessee company at all. There are several judgments of ITAT which have been referred in para 6.5 above, that Wipro cannot be taken as comparable case for comparable case with the company like assessee. In view of these facts and the reasoning given in the case of lnfosys, we hold that Wipro also cannot be considered as a co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he above, the ld. counsel for the assessee fairly admitted that comparable company at Sl.No.6 viz., Flextronics Software Systems Pvt. Ltd. should be taken as a comparable, while comparable at Sl.No.24 viz., Tata Elxsi Ltd. should be rejected as a comparable. 16. On the above submissions of the ld. counsel for the assessee, the ld. DR submitted that as far as functional comparability is concerned, it is not enough only to look at the fact that in the decisions relied upon by the ld. counsel for the assesse, also dealt with the case of software development and the assessee is also a software developer rendering software development services. It was his submission that the aforesaid companies even if they are engaged in providing software services, can be engaged in different sectors to which they cater, like software development in telecommunication, automobile manufacturing sector, etc. It was his submission that it was also necessary to consider as to whether the sectors in which the comparable chosen by the TPO belong and the sector to which the Assessee caters. 17. We have considered the submissions of the ld. counsel for the assessee and the ld. DR. We are of the view that the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the company to customize products or reconfigure products to fit into their business environment. Thereupon the company takes up the job of customizing the packaged software. The company also explained that 30 to 40% of the product software would constitute packaged product and around 50% to 60% would constitute customized capabilities and expenses related to travelling, boarding and lodging expense. Based on the above reply, the TPO proceeded to hold that the comparable company was mainly into customization of software products developed (which was akin to product software) internally and that the portion of the revenue from development of software sold and used for customization was less than 25% of the overall revenues. The TPO therefore held that less than 25% of the revenues of the comparable are from software products and therefore the comparable satisfied TPO's filter of more than 75% of revenues from software development services. The basis on which the TPO arrived at the PLI of 60.23% is given at page-115 and 116 of the order of the TPO. It is clear from the perusal of the same that the TPO has proceeded to determine the PLI at the entity level and not on the basis of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... total revenues of the entity. Considering margins of Megasoft at the entity level would be inconsistent with the TPO's position in case of other comparables. It was submitted that a different approach was adopted in case of Megasoft possibly because in case of Megasoft, the margins at the entity level are higher than that at the segment level; whereas in case of other comparables (Eg: Kals, Sasken, Tata Elxsi, Geometric, R Systems) margins at the segment level were higher. It was submitted that learned TPO's approach is arbitrary and without basis. The Assessee therefore submitted that if at all Megasoft is considered as comparable then only the segmental margins, if at all, should be used for comparability purpose. Both the segments being substantially different, considering the margins at entity level would vitiate the comparability. 30. Alternatively it was submitted that the profit margin of 60.23% was abnormally high and deserves to be rejected on this ground, as not within the parameters of comparability. In this regard, reference was made to the decision of Special Bench of ITAT Chandigarh in the case of Quark Systems Pvt. Ltd. (supra) besides several other tribunal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f them are having very low margin rate, not only less than 10 or 5, even below that. We have already considered that the agreement entered into by the assessee with its German associate concern has contemplated a compensation of cost plus 6 per cent, or 1.5 times of the total wages bill, whichever is higher. This point we have to consider in the light of the fact that the assessee is working in a risk mitigated environment. That is why we have agreed with the argument of the assessee-company that there may not be extreme profits in the case of the assessee. When extremes are excluded from the samples, all sorts of extremes should be avoided. Otherwise, samples selected for comparative study may not be representative." 33. Even in the aforesaid decision the point that has been emphasized is that when the margins of comparable companies are either extremely low or high, the approach should be to eliminate both and not consider only the high or low margin comparables as it suits either the TPO or the Assessee. 34. As far as the provisions of the Act are concerned, they lay down that the comparable companies should be functionally comparable to the tested party. There are no specific ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ted in OECD guidelines but cannot be said to be in tune with Indian TP regulations. However, if there are specific reasons for abnormal profits or losses or other general reasons as to why they should not be regarded as comparables, then they can be excluded for comparability. It is for the Assessee to demonstrate existence of abnormal factors. 36. In the present case factors for abnormal profits have not been highlighted by the Assessee. In such circumstances it is not possible to accept the submission of the Assessee to exclude this company for the purpose of comparison. 37. The next plea of the Assessee is that if at all this company is considered as a comparable then the segmental margin of 23.11% (which is the margin for software service segment) alone should be considered for comparability. On the above submission, we find that the TPO considered the segmental margin (Software service segment) in the case of Geometric, Kals Info systems, R Systems, Sasken Communication and Tata Elxsi. Before DRP the Assessee pointed out that the segmental margin of 23.11% alone should be taken for comparability. The DRP has not given any specific finding on the above plea of the Assessee. P ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nbsp; 38. Neither the TPO nor the DRP have noticed that there is bound to be a difference between the Assessee and Megasoft and the profit arising to the Megasoft as a result of the existence of the software product segment and no finding has been given that reasonably accurate adjustments can be made to eliminate the material effects of such differences. For this reason, we are inclined to hold that the profit margin of 23.11% which is the margin of the software service segment be taken for comparability. In view of the above conclusion, we do not wish to go into the question as to whether less than 25% of the revenues of the comparable are from software products and therefore the comparable satisfied TPO's filter of more than 75% of revenues from software development services.' 19. As far as comparables at Sl.No.7 & 11 are concerned, it is not in dispute before us that the related party transaction in the case of companies exceed 15% and in view of the decision of the Tribunal in the case of 24/7 Customer.Com (P.) Ltd. v. Dy. CIT [2013] 21 ITR 514/28 taxmann.com 258 (Bang.), that where the RPT exceeds 15%, such companies sh ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... addition to the total income will be a sum of Rs. 17,32,27,953 and the AO is directed to restrict the addition accordingly. Thus Gr.No.2 to 4 raised by the Assessee are partly allowed. 22. Apart from rendering software development services to its AE, the assessee also rendered marketing support services to its AE. The assessee received a sum of Rs. 8,26,30,922 as service charges from its AE. In respect of the marketing support services the assessee filed a TP study, justifying the price that it had received as at arm's length. The stand of the assessee and the AO in this regard were as follows:- C. Analysis of transfer pricing studies of the assessee and the TPO for marketing support services C.1. Net margin on cost earned by Logica: Operating Income Rs.8,26,30,992/- Operating Expenses Rs.7,49,82,500/- Operating Profit (Op. Income - Op. Expenses) Rs.76,48,422/- Operating/Net margin (OP/TC) 10% C.2. Comparison of TP study done by Logica and TPO: LOGICA TPO Methodology adopted TNMM TNMM Profit Level Indicator (PLI) OP/TC OP/TC Database used PROWESS & CAPITALINE PROWESS & CAPITALINE Comparables selected for support services 7 4 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1 Access Global Solutions Ltd 3.94% 2 Priya International Ltd 15.71% 3 ICC International Agencies Ltd (Seg) 78.67% 4 Empire Industries Ltd 23.98% ARITHMETIC MEAN 30.57% C.7. Computation of arm's length price by TPO and the adjustment made: Arm's Length Mean Margin 30.57% Operating Cost 7,49,82,500/- Arms Length Margin (30.57% of Operating Cost) Arms Length Price (ALP)130.57% of Operating Cost 9,79,04,650/- Price Received 8,26,30,922/- Short fall being adjustment u/s. 92CA 1,52,73,728/- 23. The AO in his draft assessment order suggested an addition to the adjustment suggested by the TPO. The Assessee filed objections to the addition as suggested in the draft assessment order before the DRP. The DRP however, confirmed the addition suggested by the TPO. The AO accordingly in the fair order made an addition by way of TP adjustment a sum of Rs. 1,52,73,728 suggested by the TPO. Aggrieved by the aforesaid order of the AO, the assessee has raised grounds 5 & 6, which reads as follows:- "5. That the learned AO and the learned Panel erred in upholding the adjustment of Rs. 15,273,728 by the learned TPO in the Support ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rk-up of 9%. Further, such compensation would be adjusted to provide an arm's length return adequate to compensate for the functions performed, assets employed and risk assumed by the Assessee. The Assessee pointed out yet another significant difference between the entrepreneurial commission agent and the Assessee. LogicaGroup would compensate the Assessee irrespective of the materialisation of its marketing efforts whereas, a commission agent necessarily have to effect a sale to earn a commission." 25. The ld. counsel for the assessee focused his attention on comparability chosen by the TPO viz., ICC International Agencies Ltd. The functional profile of this company has been dealt with by the TPO at page No.260 of his order. In his objection before the TPO, the assessee submitted as follows:- "International Agencies Ltd is primarily engaged in trading of embroidery accessories, embroidery spares and embroidery machines. The company also provides indenting services to the textile industry. Your goodself in the Notice considered the indenting services segment of ICC International Agencies Ltd as a comparable t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... functions and risk analysis, it is not possible to compare the assessee with ICC International Agencies Ltd. If ICC International Agencies Ltd. is not taken as a comparable, then the margin of the assessee would be well within the OP/Cost PLI of the other comparable companies chosen by the TPO. We accordingly hold that in respect of the international transactions of rendering marketing support services, the price received by the assessee is at arm's length and no adjustment is called for. Ground No.5 raised by the assessee is accordingly allowed. 29. Grounds 7 & 8 raised by the assessee reads as follows:- "7. The learned AO and learned Panel has erred in proposing that the expenditure incurred by the Company has to be apportioned between 10A Unit and non 10A Unit based on the turnover of the respective units; 8. The learned AO and learned Panel has erred in proposing to reduce the deduction under section 10A of the Income-tax Act, 1961 ('Act') with respect to 10A Unit from Rs. 12,288,462 to Rs. 9,012,411 and thereby increasing the profits of non 10A Unit from Rs. 174,739,357 to Rs. 178,015,408." ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... unit. The AO's objection to the above basis of allocation is that STPI unit i.e., the Sec.10-A unit was started in July 2006 and therefore majority of employees recruited would be only for the STPI unit. Therefore the AO held that allocating only 25% of total expenditure on training to Sec.10-A unit was not correct. Secondly, the AO held that the details of employees recruited in STPI unit and Non-STPI unit could not be provided by the Assessee and therefore adverse inference had to be drawn. (e) Travelling and Conveyance The travel and subsistence included under the head 'Travelling and Conveyance expenses' are allocated based on the employees travelled for the project of 10A unit. The per diem expenses included under the head 'Travelling and Conveyance expenses' are allocated based on the employees travelled for the project of 10A unit. & ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the head 'Repair and maintenance' is allocated based on the actual bills/consumption. The computer maintenance and computer consumables are allocated based on the ratio of average head count of the 10A unit to the average head count of all units as a whole. Accordingly, 25% of the total expenditure of is allocated to 10A unit. On the above basis of allocation, the AO was of the view that premises of the STPI and Non STPI units were different and therefore there can be no difficulty in identifying actual cost and allocating costs accordingly. (j) Communication expenses The telephone/mobile expenses and internet charges included under the head 'Communication expenses' is allocated based on the ratio of average head count of the 10A unit to the average head count of all units as a whole. On the above ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Rs. 17,80,15,408 Add: income from other sources Rs. 10,58,175 Total income Rs. 17,90,73,583" 32. The allocation of expenses as done by the AO was incorporated in the draft assessment order of the AO. The Assessee filed objections on the above allocation done by the AO in the draft assessment order before the DRP. The DRP however, confirmed the order of the AO. The allocation of expenses was accordingly made in the fair assessment order. Aggrieved by the said order of the AO, the Assessee has raised Gr.No.7 & 8 before the Tribunal. 33. Before us, the ld. counsel for the assessee submitted that the reallocation of the entire expenses on the basis of turnover as done by the AO is unreasonable and unjustified and the allocation done by the assessee on the basis of number of employees is proper and should be accepted. In this regard, reliance was placed on the decision of the Hon'ble Delhi High Court in the case of CIT v. EHPT India (P.) Ltd. in ITA Nos. 1172 & 1194/2008 dated 14.12.2011. It was also submitted that the reallocation done by the AO was misconceived because the assessee was a captive service provider and providing services only to its AE and the revenue ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... adopted so that any distortion is avoided. In all cases arising under Section 10A, where the question of apportionment of common/indirect expenses between the taxable and the exempt units arises, the head-count method cannot be said to be the most appropriate method. The question will have to depend, in the very nature of things, on the nature of the business and the facts of the particular case. 37. After giving a careful consideration to the explanation for allocation as made by the Assessee and the reasons given by the AO for rejecting the same, we are of the view that in the present case will have to be decided on the basis of facts as the STPI unit commenced only in AY 06-07 and there is no past history of allocation of common expenses. As far as recruitment charges are concerned, the AO's reasons for rejecting the same is on the ground that the STPI unit i.e., the Sec.10-A unit was started in July 2006 and therefore majority of employees recruited would be only for the STPI unit. Therefore the AO held that allocating only 25% of total expenditure on training to Sec.10-A unit was not correct. Secondly, the AO held that the details of employees recruited in STPI unit and N ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... se expenses on the basis of turnover is only accepted method. We therefore are of the view that the AO's basis of allocation has to be upheld. 41. Thus Grounds No.7 & 8 is partly allowed. 42. Ground No.9 raised by the assessee reads as follows:- "9. That the learned AO and learned Panel erred in treating the computer software expenses amounting to Rs. 29,428,480 as capital in nature." 43. The assessee claimed a deduction of sum of Rs. 2,94,24,480 as expenses incurred towards charges of licence for computer software used primarily as application software for various projects undertaken by it. The details of software purchased by the assessee are as follows:- Details of software expenses for financial year 2006-07 Purpose of expenditure Amount (Rs.) Period of usage (in years/months) Microsoft license 1,65,50,559 Yearly Agresso software license 63,98,367 Yearly PGP Software license 10,695 Project based L-UK CBOP visa base 12 node 2,66,277 Pur of crystal Report Developer for RBI project 2,60,000 Project based Being BOB AML Lic cost transf to Adv 31,29,649 Proj ..... X X X X Extracts X X X X X X X X Extracts X X X X
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