7 SEEPZ SPECIAL ECONOMIC ZONE ANDHERI (EAST), MUMBAI. AGENDA FOR | MEETING OF THE APPROVAL COMMITTEE FOR | SECTOR SPECIFIC SPECIAL ECONOMIC ZONE FOR IT/ITES AT PUNE OF M/S. EMBASSY PUNE TECHZONE PVT. LTD.-SEZ Via Video Conferencing DATE ६: 25.04.2023 TIME : 03.30 P.M. | KERR ERERERERERERER

MEETING OF THE APPROVAL COMMITTEE FOR SECTOR SPECIFIC SPECIAL ECONOMIC ZONE FOR IT/ITES AT PUNE, UNDER THE CHAIRMANSHIP OF DEVELOPMENT COMMISSIONER, SEEPZ-SEZ ON 25.04.2023 INDEX Agenda Item No. Subject Confirmation of the Minutes of Agenda Item No. 01 :- | the meeting held on 21.03.2023 ' Application for Approval of Leasing out built up space to vendors for providing telecommunication Facility and food court services submitted by M/s. Embassy Pune TechZone Pvt Ltd. (Developer) __ Agenda Item No. 02: Application for Approval of Additional office Space and Revision in Projections submitted M/s. Mercedes-Benz Research and Development India Pvt. Ltd. : Item No. 03 :- Application for Approval of Change in Shareholding pattern Agenda Item No. 04:- |and Change in Board of Directors submitted by M/s. Nitor Infotech Pvt Ltd. (Unit I& II Agenda Item No. 05 :- Monitoring of Performance for M/s. CalSoft Pvt Ltd.

71625/2023 File No.S-SEZ-MINSOEPTP/1/2022-JDCP 1 Minutes of the 84" Meeting of the Approval Committee held under the Chairmanship of Zonal Development Commissioner SEEPZ-SEZ, Mumbai for Sector Specific Special Economic Zone for IT/ITES of M/s. Embassy Pune TechZone Pvt. Ltd.-SEZ, Pune, held on 21.03.2023 via video conferencing. 1 | Name of the SEZ M/s. Embassy Pune TechZone Pvt. Lid.-SEZ 2 | Sector li?ATes | /ITES 3 | Meeting No. ॥: —COOC‘“‘(SN 4 | Date [210320238 ©. | Members present Name and Designation Department tr S/Shri. 1 | Smt. Mital Hiremath Pune Cluster SEZ, Pune Joint Development Commissioner 2 | Smt. Pradnya R. Gholap, Nominee of Income Tax, Pune DCIT (1195) Pune 3 | Dr. Dileeraj Dabhole Nominee of DGFT, Pune Dy. DGET 4 | Smt. Sunita Jagtap, Superintendent. | Nominee of Customs, Pune Special Invitee S | Name and Designation “हिU कब r 1 | Shri B. Ajay Kumar M/s. Embassy Pune — Pvt. Specified Officer Ltd.-SEZ Agenda Item No.01: Confirmation of Minutes of the 837 meeting held on 31.01.2023 After deliberation, the Committee confirmed the minutes of the 837 Approval Committee meeting held on 31.01.2023 Agenda Item No, 02: Application for Approval of Addition of area with Revision in Projections submitted by M/s. Access Healthcare Services Pvt Ltd. After deliberation, the committee approved the proposal of the Unit for Addition of Area with Revision in Projections, in terms of Rule 192) of SEZ Rules, 2006, as detailed below:

1. Addition of area admeasuring of 25,109 sq.ft. located at 3% Floor, Wing A, Mississippi, Embassy Pune Tech Zone Pvt Ltd.-SEZ, to the existing area of 69,7848q.ft located at 2४ Floor, Wing A, Block 1.2, & 6" Floor, Block Nile [1.11], Embassy Pune TechZone PVt Ltd.-SEZ, totaling to area of 94,893sq_ft and
2. Revision in Projections, as detailed below: (Rs. In Lakhs) 183

1625/2023 File No.S-SEZ-MINSOEPTP/1/2022-JDCP 2 Sr.No | Particulars | 2020-21 | 2021-22 | 2022- | 2023-24 | 2024-25 Total (Actual) (Actual) 23 1. FOB Value | 4544.49 | 5670.96| 9500.0 | 10000.0 1 10500.0 | 40215.4 of exports 0 0 0 5 2. Foreign 87.24 78.77 | 315.00) 270.00 230,00} 978.01 Exchange outgo 3. Net 4457.25 | 5595.19 | 9185.0) 9730.00} 10270,0 1 39237.4 Foreign ie) 0 4 Exchange Investment-Plant and Machinery/ Capital Goods (Rs. In Lakhs} 1. Indigenous Capital Goods 749.59 ii, Imported Capital Goods 729.07 Input of Services 1. Indigenous Services 9000.00 ii. Imported Services 248.94 Employment 1202 Men-668, Women-534) Agenda Item No.03: Application for Approval of Deletion of area with Revision in Projections submitted by M/s. Flextronics Technologies India Pvt Ltd. After deliberation, the committee approved the proposal of the Unit for Deletion of Area with Revision in Projections, in terms of Rule 192) of SEZ Rules, 2006 subject to submission of “No Dues Certificate” from the Specified Officer, as detailed below:

1. Deletion of area admeasuring of 27,159 Sq.ft. located at 6 Floor in Wing B of Block Rhine (1.5), Embassy Pune TechZone Pvt Ltd.-SEZ, from the existing area of 1,08,493 Sq.ft located at 3° Floor in Wing A, 6" Floor in Wing B and 7 Floor in Wing A and B of Building Rhine (1.5), Embassy Pune TechZone Pvt Ltd.-SEZ, remaining area of 81,334 Sq.ft. and
2. Revision in Projections, as detailed below: (Rs. In Lakhs) Sr.No | Particulars | 2018-19 | 2019- | 2020-21 | 2021- | 2022-23 Total (Actual) 20 (Actual) 22 (Actual) (Actual

FOB Value | 43847.8 | 13482.9 | 14367.7 | 17708.7 | 17710.0 | 77117.2 of exports 7 5 3 4 ie] 9 2. Foreign 147.14) 144.94 156.76 | 164.20) 2037.49 | 2650.53 Exchange outgo 3. Net 13700.7 | 13338.0 | 14210.9| 17544.5 | 15672.5 | 74466.7 Foreign 3 i 7 4 1 6 Exchange Employment 1521 Men-922, Women-599 184

File No.S-SEZ-MINSOEPTP/1/2022-JDCP 185 1625/2023 3 Agenda Item No.04: Monitoring of Performance of M/s. Mercedes-Benz Research and Development India Pvt Ltd. After deliberation, the committee noted the performance of the Unit: i, For FY 2019-20 from the 1* Block period i.e., 2015-16 to 2019-20. The unit has achieved Cumulative NFE of Rs. 57701.18 lakhs i.e., 88.94% And ii. For FY 2020-21 from 274 Block period ie., 2020-21 to 2024-25. The unit has achieved Cumulative NFE of Rs. 12130.13 lakhs i.e., 85.56% and has achieved Employment of 386 employees. Meeting ended with a vote of thanks to the Chair. Signed by Shri. Shyam Jagannathan ofan aah 18170 ChairmalftaterpAeRanedt Commissioner E-Mail- dcseepz~mah@nic.in

1688/2023 AGENDA NOTE FOR CONSIDERATION OF THE UNIT APPROVAL COMMITTEE a) b) File No.S-SEZ-PROOEPTP/8/2022-JDCP 1 GOVT. OF INDIA, OFFICE OF THE DEVELOPMENT COMMISSIONER, SEEPZ-SEZ (PUNE CLUSTER) RRERKENEREREREE Proposal: Application submitted by M/s. Embassy Pune TechZone Pvt. Ltd-SEZ (Developer}.located at Plot No.03, Rajiv Gandhi Infotech Park, Phase-lIl, Hinjewadi, Pune-411 057, for approval for Leasing out of Built up Space to vendors for providing telecom facility and food court services in the SEZ premises. Specific issue on which decision of UAC is required: Approval of the UAC to lease out the built up space to vendors, as detailed below, to provide telecom facility and food court services, in terms of Rule 11 (5) of SEZ Rules, 2006, as detailed below: To provide Telecommunication infrastructure : Fl of the Vendor Location Area, M/s. Summit Digital; Mekong Building-1.6, Terrace 500 Sq.ft Infrastructure Pvt Ltd area, Embassy Pune TechZone Pvt Ltd. To provide food court services in SEZ premises, as detailed below: Sr. No. Name of the Vendor Location Area, 1, M/s. Maurya | A-Wing, Rio Grande 110 Sq.ft Hospitality, Pune Building-2.1, 1* Floor, Embassy Pune TechZone Pvt Ltd.-SEZ 2. M/s. Orange Events | A-Wing, Rio Grande 1005 Sq.ft and Hospitality, Pune | Building-2.1, Kiosk no.2, Ground Floor, Embassy Pune TechZone Pvt Ltd.- SEZ 3. M/s. Green Olive | A-Wing, Rio Grande 250 Sq.ft. Kitchens, Pune Building-2.1, Ground floor, Kiosk No. 4, Embassy Pune TechZone Pvt Ltd.- SEZ 4. M/s. Lockhart, Pune Rio Grande Building-2.1, 75 Sq.ft First Floor, Embassy Pune TechZone Pvt Ltd.-SEZ 5. M/s. Fresh Press | Rio Grande Building, 150 Sq.ft Bytes, Pune Ground Floor, Embassy Pune TechZone Pvt Ltd.- SEZ ai Dalawant Denrinine: 692

1/1688/2023 File No.S-SEZ-PROOEPTP/8/2022-JDCP 2 As per Rule 11 (5) of SEZ Rules, 2006 “(5) The land or Build up space in the processing area or Free Trade and Warehousing Zone shall be given on lease only to the entrepreneurs holding valid Letter of Approval issued under Rule 19 and jthe lese period shall not be less than five years but notwithstanding any other condition in the lease deed, the lease rights would cease to exist in case of the expiry or cancellation of the Letter of Approval:] PROVIDED that the Developer may, with the prior approval of the Approval Committee, grant on lease land or built-up space, for creating facilities such as canteen, public telephone booths, first aid centres, creche and such other facilities as may be required for the exclusive use of the Unit. d) Other information: » M/s. Embassy Pune TechZone Pvt. Ltd., located at Plot No.03, Rajiv Gandhi Infotech Park, Phase-Il, Hinjewadi, Pune-411 057 India has been granted Formal Approval bears No. F.2/365/2006-SEZ dated 25.06.2007 » Further, The Developer has submitted that: ० The services will be utilized by all their units’ employees and developers’ employees. o As a retail operator vendor Will not avail any direct or indirect tax benefits available under the SEZ scheme. o All above vendors are offering India Cuisine will carry out cooking inside the said allocated space during the kiosk operating hours o Developer have provided separate gas connections to all vendors o All necessary licenses and safety measures will be adhered to as required by authorities » The Developer has enclosed following document: o Online Application No.422300099465, 422300104030, 422300099432, 422300099362, 422300099395 and 422300099222 o Service provider request letter dated 28.02.2023, 13.03.2023, 02.03.2023, 04.03.2023, 25,02,.2023 and 24.02.2023 o Embassy Pune TechZone Pvt Ltd. Space availability confirmation letters dated 08.03.2023 and 17.03.2023 o Copy of Fire NOC dated 09.02.2019 ० Form B dated 06.01.2023 for specific area of Rio Grande- Food Court o FSSAI registration certificate of Service providers. e) ADC’s observations:

The proposal of the Developer for Leasing out Built up space to vendors to provide telecom facility and food court services, in the SEZ premises may be considered by the UAC ,in terms of Rule 11 (5) of SEZ Rules, 693

111699/2023 4 File No.S-SEZ-PROOEPTP/11/2022-JDGP 16: GOVT.OF INDIA, OFFICE OF THE ZONAL DEVELOPMENT COMMISSIONER, SEEPZ-SEZ (PUNE CLUSTER) RARER केक रे AGENDA NOTE FOR CONSIDERATION OF THE UNIT APPROVAL COMMITTEE a) Proposal: - Application filed by M/s. Mercedes-Benz Research and Development India Pvt. Ltd., an IT/ITES unit located at Embassy Pune TechZone Pvt. Ltd.-SEZ for additional office space admeasuring 49,089 Sq.ft. along with revision in projections. Specific Issue on which decision of UAC is required: - Approval of the UAC for 1) Additional Office Space admeasuring 49,089 sq.ft. to the existing area of 69,954 Sq.ft. with Revision of projection in terms of Rule 19(2) of SEZ Rules, 2006, as detailed below: {i) Location / area proposed to be added :

=e and Area a to be Total ss after area added addition 4" to 6" Floors, Wing-B, | 7" Floor, (A & B Wing), | 7 Floor- Wing A, 4" to 77 Building Congo, Block | Building Congo, Embassy | Floor Wing-B, Building 1.3, Embassy Pune | Pune TechZone Pvt Ltd Congo, Block 1.3, TechZone Pvt Ltd. Embassy Pune TechZone Pvt Ltd.-SEZ Admeasuring area of|Admeasuring area of | Admeasuring area of 69,954 Sq.ft 49,089 Sq.ft. 1,19,042 Sq.ft. (ii) Revision in Projection: Projections of Investment and Employment: (Rs. In Lakhs) Sr.No | Item Existing Projection | Total Revised Projection 1. Employment Men Women Men Women 345 47 551 116 Total 392 667 2. Investment-Plant and Machinery/Capital Goods (Rs. in lakhs 1. Indigenous 500.00 900.00 ii. Imported 1700.00 1900.00 Total 2300.00 2800.00 3. Services 1. Indigenous Services 1854.42 15100.00 ii. Imported Services 10720.00 10800.00 Total 12574.42 25900.00

1699/2023 2 File No.S-SEZ-PROOEPTP/11/2022-JDCP Approved Projection: (Rs. In Lakhs) Sr.No | Particulars | 2020-21 | 2021-22 2022-23 | 2023-24 | 2024-25 Total 1. FOB Value; 17158 00 17309.00 17655.00 18185.00 | 18730.00 | 89017.00 of exports 2. Foreign 2383.43 2213.82 1681.19 2835.71 3305.85 | 12420.00 Exchange outgo 3. Net Foreign | 14754.57 | 15095.18 15973.81 15349.29 | 15424.15 | 76597.00 Exchange Proposed Projection: (Rs. In Lakhs) He ak

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{Actual} _ _{Actual) - 1. FOB Value of |.14012.81 | 16958 97 19577.07 | 24571.00 | 25777.15 100900.00 exports | 2. Foreign 1882.68 | 1946.37 2480.78 | 2948.99 3443.11 12700,00 Exchange outgo 3. Net Foreign | 12130.13 | 15012.60 | 17096.99 | 31625.01 22.334.04 88200.00 Exchange Relevant Provisions: - As per First Proviso to Rule 19(2) of SEZ Rules,2006 “PROVIDED that the Approval Committee may also approve proposals for broad banding, diversification, enhancement of capacity of production, change in the items of manufacture or service activity, if it meets the requirements of rule 18”

d) Other Information: - M/s. Mercedes-Benz Research and Development India Pvt. Ltd. Company was granted LOA No.SEEPZ-SEZ/ PEPPL-SEZ/ MBRDIPL/18/2014- 15/5297 dated 25.03.2015 Location: 4" to 6" Floor, Wing B, Congo Building, Pune TechZone Pvt. Ltd.-SEZ, Plot No. 03, RGIP, Pune-411 057 DCP: 01.07.2015 LOA valid upto: 30.06.2025 Block 1.3, Embassy Hinjewadi, Phase-II, Reason for additional area: The unit has submitted that, considering the growing business requirements and future business prospects, their management has decided to expand office space and obtain additional office space approval. In view of increase in office space of the SEZ unit, they have 16:

1699/2023 3 File No.S-SEZ-PROUVEPTP/11/2022-JDCP submitted revised projections for Exports, investments and Employment w.r.t., balance 2 years period for addition of area in existing LOA The unit has submitted the following documents with the application: 0 दर Copy of Form F3 for additional location filed through SEZ online system Letter of Intent signed with Developer of SEZ for proposed additional Location Revised Foreign Exchange Balance sheet for Five years Form F1 submitted for renewal of LOA Copy of all LOAs obtained till date Copy of Board Resolution List of Imported and Indigenous Capital Goods Copy of APRs for FY 2020-21 and 2021-22 e) ADC Scrutiny report: -

There is an increase in the area by 70.17%; Increase in Export Revenue by 13.34%; Increase in Investment in Imported Capital Goods by 11,76% and Increase in Employment by 70.15% UAC may like to consider the proposal of the unit for approval of additional office space with revision in projection in terms of Rule 19(2) of SEZ Rules, 2006. REMI RIA RK ER ARIK 16!

File No.S-SEZ-PROOEPTP/19/2022-JDCP i GOVT. OF INDIA, OFFICE OF THE ZONAL DEVELOPMENT COMMISSIONER, SEEPZ - SEZ (PUNE CLUSTER) SREKRHREAEREAES AGENDA NOTE FOR CONSIDERATION OF UNIT APPROVAL COMMITTEE 9) Proposal: - Applicationssubmitted by M/s. Nitor Infotech Pvt Ltd. Unit-I and IIT/ITES units located in Embassy Pune TechZone Pvt Ltd.- SEZ for Change in Shareholding pattern andChange in Board of Directors. b) Specific Issue on which decision of UAC is required: - Approval of the Unit Approval Committee for

1. Change in Shareholding pattern and
2. Change in Board of Directors., in terms of Instruction No. 109 dated 18.10.2021, as detailed below: Existing Shareholding Pattern: pene of ee Class of Equity ee Shares ee as in 2016 Eclipse Investments LLC Class A 39,48,439 Mr. C. E. Patnis Class A 4,05,174 _Mr. Sanjeev Fadanvis | Class A 1,35,058 Proposed Shareholding Pattern: Name of Shareholders Class of Equity Shares | Shareholding as in 2016 Eclipse Investments LLC Class A 39,48 439 Mr, C. E. Potnis Class A 18,42,604 Mr. Sanjeev Fadanvis Class A 4,62,374 Mr. Sanjeev Fadanvis Class B 6,54,630 Proposed change of Directors: Existing List of Directors Sr. Name of the Director 1 Mr. Chandrashekhar EknathPotnis 2 Mr. Sanjeev Sharad Fadanvis 3 Mr. Rashad Muhammad Al Zubair List of Directors who has resigned / who have been appointed;

File No.S-SEZ-PROGEPTP/19/2022-JDCP 2 Sr.No | Name of Director | Resignation | Name of Date of who has resigned | Date Director who Appointment has been appointed 1 Mr.S.Mr. Rashad | 22/09/2016 Mr. Sultan Said| 11/09/2021 Muhammad Al Al Ghaithi Zubair List of Director after the change: Sr. Name of the Director —_ = of Appointment No. 1 Mr, Chandrashekhar EknathPotnis 08/09/2006 2 Mr. Sanjeev Sharad Fadanvis 08/09/2006 3 Mr. Sultan Said Al Ghaithi 11/09/2021 ०) Relevant provisions: - As per para (i) of Instruction no. 109, dated 18.10.2021, “Reorganization including change of name, Change of Shareholding pattern, business transfer arrangements, court approved mergers and demergers, change of constitution, Change of Directors, etc. may be undertaken by the Unit Approval Committee (UAC) concerned subject to the condition that the Developer/Co-developer/ Unit shall not apt out or exit out of the Special Economic Zone and continues to operate asa going concern. All liabilities of the Developer/Co-Developer/Unit shall remain unchanged on such reorganization.”... d) Other Information: -

» M/s. Nitor Infotech Pvt Ltd. Unit-I and Il has submitted application for following LOA Nos. o Unit 1-LOA No. SEEPZ/PEPPL-SEZ/NIPL/20/2016-17/25809 dated 29.08.2016 o Unit 2 LOA No. SEEPZ/PEPPL-SEZ/NIPL/21/2016-17/25806 dated 29.08.2016 » Units have submitted following documents: o Online Application 9". List of Existing and Proposed Directors ० Form DIR 12 for Appointment of Directors with ROC along with its challan o Form DIR 12 for Resignation of Directors with ROC along with its challan ० CA/CS certified shareholding pattern before and after allotment of shares o Form PAS-3 for allotment of shares with ROC along with its challan o Form SH-7 for increase in authorized share capital with its challan ० Copy of all LOAs eo Undertaking in terms of Instruction no. 109

०) File No.S-SEZ-PROUEPTP/19/2022-JDCP 3 o Undertaking regarding personal liability arising, if any against the outgoing director Reason for change in Shareholding pattern: The unit has informed that, due to internal restructuring there is change in Shareholding and Directorship of Company. The Company has increased Authorized Capital from Rs.5,00,00,000 to Rs.7,00,00,000 and subsequently, made allotment of shares by way of right issue on 20.03.2019.Further, Company is amalgamated with Spoton Software Pvt Ltd. {transferor Company) and order relating to this amalgamation was passed by Regional Director, Mumbai on 11/04/2022 w.e.f 01.04.2021, due to which Authorized Capital of the Company is further increased to Rs.7,01,00,000. ADC’s Recommendations: The units have informed that they have not submitted the prior intimation as required under Instruction No. 109 of MOC&I as previously it was inadvertently missed out from their end with respect to change in Shareholding pattern and change in directors as per Rule 22 of SEZ Rules, 2016 and Instruction 89 of MOC&I they didn’t submit intimation with respect to change in director, considering the above units have requested to condone the delay in submission of intimation of change in Shareholding pattern and Directors of Company UAC may like to consider the proposal of Unitsfor Change in Shareholding pattern and Change in Board of Directors.,in terms of Instruction no. 109 issued by MOC&l. RRA REAR ER IKK के से

OPFICE OF THE ZONAL DEVELOPMEN: i GOVT. OF INDIA, SEEPZ ~ SEZ (PUNE CLUSTER) eeBREE ERE EERE / COMMISSIONER, AGENDA NOTE FOR CONSIDERATION OF THE UNIT APPROVAL COMMITTEE a) Proposal: Monitoring of the performance of M/s. Ca located in Embassy Pune TechZone Pvt. Ltd-: 2022-23 of 284 block period i.e. 2018-19 to 20: b) Specific Issue on which decision of UAC Monitoring of the performance of the unit block period ie. 2018-19 to 2022-23, in 2006. है) Relevant provisions: - As per Rule 54 of SEZ Rules, 2006 terms of Rule 54 of SEZ Rules, “Performance of the Unit shall be monitored by the Approval Committee as per the guidelines given in Annexure appended to these rules”. I, Approved export Projections for 2°4 Block Period: (Rs. in Lacs) eee 20 eae 2020-21 cere os FOB Export | 2834.22 | 4178.22 | 4850.22 6194, 243 | 23579.12 FE Outgo 60.12 63.45 68.85 20.45 | 362,52 NFE 2774.10 | 4114.77 | 4781.37 23216.58 (A) Por 2-4 Block Period i.e. from 2018-19 to 2021-22 font of 2018-19 to 2022-23} Performance as compared to projections: (Rs. In Lacs) Export BLE. OUTGO Raw Material . Other Year Projected Actual Goods/Services) C.G. import outilow Projected | Actual | Projected | Actual : 2018-19 2834.22 6965.24 0.00 0.00 261,80 6.36 2019-20 4178.22 6218.49 0.00 9.00 110.6 2020-21 4850.22 3789.97 0.00 ot 6.19 2021-22 $522.22 4345.63 0.00 0.60 74.40 2022-23 6194.22 5015.80 0.00 0.00 6.00 os. | 14 Total 23579.12 | 36335.13 6.00 0,00 261.80) 197.55 3180.00 (B) Cumulative NFE Achieved is. In Lakhs} Paneer Cumulative NFE Achieved Caumulative Yo NPE Achieved 2018-19 6915.82 99.29% 2019-20 13089.57 99.29%

| 2020-21

98.15% 2021-22 054.21 94.07% 2022-23 2297490 87.24% {As per Provisional APR) For year 2022-23 the they have submitted for exit the perform cumulative NFE for projected export re ite: Rs.22974.90 Lakhs i.e., 87.24% (C} Other Information: e said period, ait is in the process of finalizing the APR however, visional APR in hard copy. As the unit has applied e for the year is being taken for arriving at the During the period the unit had : of Rs. 6194.22 lakhs as against which the actual export of Rs, 5015.80. Accordingly, the unit has achieved positive NFE of LOA No. & Date [Eon No. No. SEEPZ-SEZ/FIPL- SEZ/CPL/29/2012-13/6121 dated 4 13 Location of Unit 7k Floor, Wing-B, Building Congo, Block 1.3, Embassy Pune TechZone Pvt Lid-SEZ, RGIP, Hinjewadi, Phase- Il, Pune-411057 Validity of LOA 29.11.2023 Item(s) of manufact IT/ITES Date of commencement of pre 30.11.2013 Execution of BLUT Outstanding Rent dues NA Labour Dues ~ NA aes of Lease Agreement Pending CRA Objection, if any NA Pending Show Cause Notice/ Eviction | NA Order / Recovery Notice/ Reece issued, if any sry Order a) No, of employees as on “ia a ee 1.03.2022 207 (Male: 159, Female:48} Area allotted (in sq.ft.) Area available for each exaployee per sq.ft. basis (area / no. of employees) Investment till | Building NA date Plant & Machinery | NA किyक ee and value of goods exported NA under Rule 34 (unutilized goods} . Value Addition during the monitoring NA Whether all the APRs being considered Yes now has been filed well within the time

| limit, or otherwise. or otherwise. 128४ no, details of the Year along ee no of days delayed to be given. The Specified Officer vide letter dated 21.04.2023 has reported as under: a. Export: (Pigeres INR in Lakhs} Year Figures | Figure as Difference | Reason for as per per (if any) Difference / APR Customs 2018-19 | 6965.24 6972.04 6.80 |; 6.80 Lakhs Excess reporting in Softex 2019-20 | 6218.49 6218.49 ~

2020-21 | 3789.97 | 3739.97 49.96 27.86 Lakchs- The invoices considered in ex, but inchided in APR .09-Punching Error in Condonation for Softex have | fled on 07.02.2023 2021-22 | 4345.63 8282.9 3937.27 546,98 Lakhs- Double request ID approved kis. 40.69 Lakhs- Credit note considered as Invoice & filed as SOFTEX Rs. 30.78 Lakhs- SOFTEX need to be filed after seeking Condonation 3318.81 Lakhs- There softex filed for receipt of b. Import: Ufigures INR in Lakhs} Year Figures | CIF Difference | Reasons for | as per | Figures as | (if any) — /Remark APR per Customs Records 2018-19 0 OF

• |'

2019-20) OO]

2020-21 6.19 6.19

7

2021-22 Q Q ~

e. BLUT (Rs. In Lakhs) 1 Value of BLUT Executed | 87.43 (Duty foregone) (Including for CG/Raw Material/ Services) Value of Additional BLUT | 425.23 Executed TOTAL Duty velue of BLUT | $13.66 Executed in Lakh 2 Total Duty foregone on goods BY Goods Services & services procured category Imported wise: & Indigenous Year Wise 2018-19 3.94 53.59 2019.20 21.15 | 123.66 2020-21 0.036 88.80 2021-22 13.59 67.74 Total 38.72 | 334.09 3 Has the unit हु: cd goods or services without having sufficient balance in their BLUT, NO UW yes Month & Y when the BLUT was exhausted Details of the Consignments and total value of Goods procured withuut having sufficient or nil balance in BLUT d. Employment made as on date (as on end of | As on 31st March 2022: block periad/ year up to which monitoring | Men: 159 is being done Women: 48 Total: 207 e. Detaiis of p z foreign remittance | No beyond permissible period, if any (as on 31.12.2022} To Cross Check the same and. verify whether necessary permission from AD | | bank/ RBI bas heen obtained fg Whether all softex. has been filed for the Yes. Except few cases of said period, if no, cletails thereof condonation applied to JDC office SO to also check whether unit has obtained SOFT! condonation from DC ae / RBI and if approved, whether they have filecl such pending softex g- Whether all SOFTEX has been certified, if | All the SOFTEX forms till so til which month has the same been certified. If Not, provide details of the SOFTEX and reasons for pendency Feb, 2023 has been certified

5 Whether unit has filed any request for | cancellation Yes Whether any services provided in DTA/SEZ/EOU/STPI ete. against the payment in INR in r/o IT/ITES unit during the period FY Sales Value ce 266.83 2019-20 1273.75 2020-21 669.43 2021-22 549.40 2022-23 (As per APRs provisional 478,04 Total $237.45 Has the unit cleared any capital goods procured duty free in DTA against payment of Duty of otherwise? Full Details to be provided along with value | of assets and duty discharged NO Is the unit sharing any of their infrastructures with other units or are utilizing infrastructure of another unit. in the same or other SEZ, If so, details thereof, including the details of the unit with whom the sharing is being | made, and the payment terms Hf approval for sharing of common infrastructure has been obtained from UAC / DC office, the date of UAC / Approval letter to be indicated NO Whether all DSPF for services procured during the said monitoring period under consideration has been filed by the unit and whether the same has been processed for approval by the SO Office, Yes Whether unit has filed all DTA procurement w.r.t. the goods procured by them during the monitoring period for the relevant period. If no, details thereof Yes Details of the request IDs pending for OOC in respect of DTA procurement on the date of submission of monitoring report for OOC Has the unit set up any cafeteria / canteen / food court in unit premises. । rosea yes, whether permission from UAC / DC office has been issued, or otherwise office has been issued, or otherwise Whether unit has availed any duty paid goods / services for setting up such facility ? No

ES yes, whether unit has discharged such duty / tax benelit availed ? details to be given including amount of duty / tax recovered or yet tc recovered p. Whether any viclation of any of the provisions of law has been noticed / | NA observed by the Specified Officer during the period under monitoring “igures reported in APR & SOFTEX/Customs record for which the unit have filed application for delay in filling SOFTEX for Condonation. to JDC Pune for 6 Nos. of invoice & value Rs. 8074 Lakhs, Further, the unit 1 filed application for cancellation of SOFTEX (17 invoices and value 273.49 Lakhs) to JDC office There is difference in Export for the FY 2020-21 & 2021- ADC’s observations:

The unit has achieved export revenue of Rs. 26335.13 lakhs as against projected revenue of Rs. 23579.12 lakhs i.e. 111.68% in the 5 years of 2nd Block period. » The unit has achieved positive NFE of Rs. 22974.90 iLe., 87.24% in 2022-23 on cumulative basis As per SO report the unit has achieved Employment of 207 employees (Men 159, Women 48} » It is observed that the unit has provided services in DTA against the payments received in INR as detailed below: (Rs. In Lakhs ye | RY Sales i Value 2018-19 266.83 | 2019-20 1273.75 2020-21 669.43 21-22 549.40 2022-23 478.04 Tetal 3237.45 As per Section 2{z} of SWZ Act, 2005, the definition of Services is given as below : “Services means such tradable services which, - fj Are covered under the General Agreement on Trade in Services annexed as IB to the Agreement establishing the World Trade Organisation concluded at Marirakesh on the 15% day of April 1994 ; (ii) May be prescribed by the Central Government for the purpose of this Act; and {tii) Earn foreign exchange ; ® Since the unit had previded IT/ITES services in DTA against payment in INR, the said services provided by them cannot be considered as part of their authorized operations, and as such, they have viclated the provision of Rule 19 (6B)}{v} of the SEZ Rules, 2006. As per Rule 19(6B){(v} of SEZ Rules, 2006, “Undertaking of an activity not sanctioned or approved by the Development Commissioner”

» As the unit has been granted LOA for prov IT/ITES Services from their SEZ Unit, and since the services provided bv them to DTA against INR does not classify as a ‘Service’ as per definition as given in Section 2(z) of SEZ Act, 2005, the unit has violated the provisions of the SEZ Acts / Rules. As per Rule 54(2} of SEZ Rules, 2006 “(2)

Case the Approval Committee comes to the conclusion that a Unit has

not achieved positive Net Foreign Exchange Earning, or stipulated Value Addition as specified in rule 53 or fatied to abide by any of the term and conditions of the Letter of Approval or Bond-cum-Legal Undertaking, without prejudice to the action that may be taken under any other law for the time being in force, the said Unit shall be liable for penal action under the provisions of the Foreign Trade Development und Regulation) Act, 1992.” UAC may like to monitor the perforrnance of the Unit for 5 years from FY 2018-19 to 2022-23 of 24 block period and :-nitiate necessary action against the unit with regard to violation of provision of SEA Act / Rules, in terms of Rule 54 of SEZ Rules, 2006.