Agenda for Approval Committee meeting for Pune-Cluster to be held on 05-Dec.- 2023. — 04-4eon-kharadi-infrastructure-pvt-ltd-phase-1-sez

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. EON KHARADI INFRASTRUCTURE PVT. LTD.-SEZ, PHASE I.

Via Video Conferencing

DATE : 05.12.2023

TIME : 11:00 A.M.

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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 05.12.2023

INDEX

Agenda Item No.

Subject

Agenda Item No. 01 :- Confirmation of the Minutes of the meeting held on 21.09.2023 Agenda Item No. 02 :- Monitoring of Performance for M/s. Allianz Technology SE Agenda Item No. 03 :- Application for Approval of appointment of service provider in r/o cafeteria. submitted by
M/s. Mphasis Ltd. Agenda Item No. 04:- Application for approval of Change in shareholding of the Company pursuant to the Amalgamation. Submitted by M/s. Octaserv Technologies Pvt. Ltd.

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Minutes of the 113th 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. EON Kharadi Infrastructure Pvt. Ltd.–Phase-I SEZ, Kharadi, Pune, held on 21.09.2023. 1 Name of the SEZ M/s. EON Kharadi Infrastructure Pvt.
Ltd.-SEZ, Phase I 2 Sector IT/ITES 3 Meeting No. 113th 4 Date 21.09.2023 Members present Sr Name and Designation (S/Shri.) Department 1 Smt. Mital Hiremath Joint Development Commissioner Pune Cluster SEZ, Pune 2 Smt. Pradnya R. Gholap, DCIT (TDS) Pune Nominee of Income Tax, Pune 3 Dr. Dileeraj Dabhole Dy. DGFT Nominee of DGFT, Pune 4 Smt. Sunita Jagtap Superintendent Nominee of Customs, Pune Special Invitee S r Name and Designation Department 1 Shri Satbir Sharma Specified Officer M/s. EON Kharadi Infrastructure
Pvt. Ltd.-SEZ, Phase-I Agenda Item No.01: Confirmation of the Minutes of the 112 meeting held on 10.08.2023. After deliberation, the Committee confirmed the minutes of the 112th meeting of Approval Committee held on 10.08.2023 Agenda Item No.02: Application for Approval of Partial Deletion and Revision in projection submitted by M/s. Company3 Method Pvt. Ltd. After deliberation, the committee approved the proposal of the Unit for partial Deletion of Area with Revision in Projections, in terms of Rule 19(2) of SEZ Rules, 2006, as detailed below; File No.S-SEZ-MINS0EON1/1/2022-JDCP I/2857/2023 286

(i) Location / area proposed to be deleted: Existing address and are in sq.ft Proposed address and area in sq.ft. to be deleted Address and remaining area in sq.ft after deletion 7th Floor, Cluster D, Wing 2 and 3 and 7th Floor, Cluster E, Wing 2, EON Free Zone, EON Kharadi Infrastructure Pvt Ltd.-Phase-I-SEZ Admeasuring

area: 83,196.44 Sq.ft 7th Floor, Cluster E, Wing 2, EON Free Zone, EON Kharadi Infrastructure Pvt Ltd.-Phase-I-SEZ Admeasuring area: 27,100 Sq.ft 7th Floor, Cluster D, Wing 2 and 3, EON Free

Zone,

EON Kharadi Infrastructure Pvt Ltd.-Phase-I-SEZ Admeasuring area: 56, 096.44 Sq.ft. Approved Revision in Projections (Rs. In Crores) Sr.No Particular s 2021-22 Actual 2022- 23 Actual 2023-24 2024- 25 2025-26 Total 1. FOB Value of exports 172.60 182.64 152.25 163.38 179.51 850.38 2. Foreign Exchange outgo 37.10 1.38 5.09 5.36 5.64 54.57 3. Net Foreign Exchange 135.50 181.26 147.16 158.02 173.87 795.81 1. Investment in Plant & Machinery/Capital Good i. Indigenous 19.54 ii Imported 24.31 Total 43.85 2. Value of Services i. Indigenous 78.35 ii. Imported 1.25 Total 79.60 Employment(Men-1428, Women-147) 1575 Agenda Item No.03: Application for Approval of Change in Board of Directors submitted by M/s. LTIMindtree Ltd. Unit-10 The proposal of M/s. LTIMindtree Limited. Unit-10 located EON Kharadi Infrastructure Pvt. Ltd.-SEZ Phase- I for the LOA No SEEPZ/EKIPL-SEZ/LTIL/54/2021-22 Dtd. 18.01.2022 was placed before the Approval Committee File No.S-SEZ-MINS0EON1/1/2022-JDCP I/2857/2023 287

After deliberation, the Approval committee approved Change in Board of Directors, for unit-10 in terms of Instruction No. 109 dated 18.10.2021, as detailed below: (i) Approved List of Board of Directors: Sr. No Name of the Director Designation Date

of Appointment 1 Mr. A. M. Naik Non-Executive Chairman 23.12.1996 2 Mr. S. N. Subrahmanayan Non-Executive

Vice Chairman 10.01.2015 3 Mr R Shankar Raman Non-Executive Director 28.10.2015 4 Mr. Sudhir Chaturvedi President –Sales & Whole Time Director 09.11.2016 5 Mr. Nachiket Deshpande Chief Operating Officer & Whole Time Director 02.05.2019 6 Mr. Sanjeev Aga Independent Director 09.11.2016 7 Mr.

James

Varghese Abraham Independent Director 18.07.2021 8 Mr. Rajnish Kumar Independent Director 26.08.2021 9 Mr. Vinayak Chatterjee Independent Director 01.04.2022 10 Mr. Debashish Chatterjee Chief Executive Officer & Managing Director 14.11.2022 11 Ms. Apurva Purohit Independent Director 14.11.2022 12 Mr. Bijou Kurien Independent Director 14.11.2022 13 Mr.

Chandrasekaran Ramakrishnan Independent Director 14.11.2022 The approval is subject to the conditions as laid down in Instruction No. 109, as applicable, issued by MOC&I
a. Seamless continuity of the SEZ activities with unaltered responsibilities and obligations for the altered entity; b. Fulfilment of all eligibility criteria applicable, including security clearances etc. by the altered entity and its constituents; c. Applicability of and compliance with all Revenue/Company Affairs/SEBI etc. Act/Rules which regulate issues like capital gains, equity change, transfer, taxability etc. d. Full financial details relating to change in equity/merger, demerger, amalgamation or transfer in ownership etc. shall be furnished immediately to Member (IT&R), CBDT, Department of Revenue and to the jurisdictional Authority. e. The assessing officer shall have the right to assess the taxability of the gain/loss arising out of the transfer of equity or merger, demerger, amalgamation, transfer in ownerships etc. as may be applicable and eligibility for deduction under relevant sections of the Income Tax Act, 1961. f. The applicant shall comply with relevant State Government laws, including those relating to lease of land, as applicable. g. The applicant shall furnish details of PAN and jurisdictional assessing office of the unit to CBDT. File No.S-SEZ-MINS0EON1/1/2022-JDCP I/2857/2023 288

h. The applicant shall be recognized by the new name or such arrangement in all the records. Meeting ended with a vote of thanks to the Chair. (Rajesh Kumar Mishra, IRS) Chairman-cum- Development
Commissioner File No.S-SEZ-MINS0EON1/1/2022-JDCP I/2857/2023 289

GOVT. OF INDIA, OFFICE OF THE ZONAL DEVELOPMENT COMMISSIONER, SEEPZ – SEZ (PUNE CLUSTER)

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AGENDA NOTE FOR CONSIDERATION OF THE APPROVAL COMMITTEE

a. Proposal: Monitoring of the performance of M/s. Allianz Technology SE., an IT/ITES unit located at 5th and 4th floor, wing 4 cluster C, plot No.-1 S.No.77 MIDC Kharadi Knowledge Park, EON Phase I, Kharadi, Pune-411014. for first 2nd block period i.e. for FY 2018-19 to FY 2022-23

b. Specific Issue on which decision of Approval Committee is required: Monitoring of the performance of the unit for 2nd Block period i.e. FY FY 2018-19 to FY 2022-23 in terms of Rule 54 of SEZ Rules, 2006

c. Relevant provisions: -

As per Rule 54 of SEZ Rules, 2006

“Performance of the Unit shall be monitored by the Approval Committee as per the guidelines given in Annexure appended to these rules”.

I. Performance as compared to projections: i. Approved Projections (Rs. in Crores)

2018-19 2019-20 2020-21 2021-22 2022-23 Total FOB Value of Exports 118.19 127.65 136.82 147.01 158.21 687.88 FE Outgo 5.11 0.15 0.15 0.2 0.2 5.81 NFE 113.08 127.50 136.67 146.81 158.01 682.07

Performance as compared to projections:
(Rs. in Crores)

Year Export F.E. OUTGO

Projected

Actual Raw Material (Goods/Services) C.G. import Other outflow Projected Actual Projected Actual Actual 2018-19 118.19 152.55 0 0 5.81

1.06 0.00 2019-20 127.65 216.10 0 0 0.21 25.23 2020-21 136.82 170.08 0 0 2.01 31.03 2021-22 147.01 163.97 0 0 0.00 95.63 2022-23 158.21 139.54

-0.27 118.00 File No.S-SEZ-MONT0EON1/2/2023-JDCP I/3300/2023 44

Total 687.88 842.26 0.00 0.00 5.81 3.01 269.91 [[[ (II) Cumulative NFE achieved: (Rs. in Crores)

Year Cumulative NFEA Achieved Cumulative % NFE Achieved 2018-19 151.83 99.53% 2019-20 341.95 92.76% 2020-21 480.06 89.11% 2021-22 547.46 77.91% 2022-23 568.08 67.45%

(III) Employment Achievement (Direct): FY 2022-23

The Unit has achieved employment of 363 employees (Men-564, Women-201) as on 31.03.2023.

d. Relevant provisions: Rule 54 of SEZ Rules, 2006 “Performance of the Unit shall be monitored by the Approval Committee as per the guidelines given in Annexure appended to these rules”

e. Other Information:

LOA NO & Date SEEPZ-SEZ/EKIPL- SEZ/AMO&s/20/2012-13/4585 Dated 23.11.2018 Location of Unit 13th to 16th Floor, Tower A, EON Free Zone-II, EON Kharadi Infrastructure Pvt. Ltd.-SEZ, Phase-II, Sr. No.72/2/1, Kharadi, Pune-411014 Validity of LOA 22.09.2023 Item(s) of manufacture/ Services IT & ITES Date of commencement of production 23.09.2013 Execution of BLUT Rs. 69.66 Crores Outstanding Rent dues NA Labour Dues NA I/3300/2023 45

Validity of Lease Agreement 10 years Pending CRA Objection, if any NA Pending Show Cause Notice/ Eviction Order/Recovery Notice/ Recovery Order issued, if any NA Projected employment for the block period No. of employees as on 31.03.2023 714 (Men 466, Women -248)

564 (Men-363, Women-201) Area allotted (in sq.ft.) 57975 Sq.ft Area available for each employee per sq.ft. basis (area / no. of employees) 102.79 Sq. ft. Investment till date

Building NIL
Plant & Machinery 9.50 Crores Quantity and value of goods exported under Rule 34 (unutilized goods) NA Value Addition during the monitoring period NA Whether all the APRs being considered now has been filed well within the time limit, or otherwise.

If no, details of the Year along with no of days delayed to be given. Yes

The Specified Officers vide letter dated 04.12.2023 has submitted APR verification report for the period FY 2018-19 to FY 2022-23, in the prescribed which is as detailed below;

(A) EXPORT (Rs. In Crores)
Year/Pe riod Figures reported in APR Figures as per Softex/Customs Records Difference if any Reason for Difference/Remark (1) (2) (3) (4) (5) 2018- 2019 152.55 152.55

-- 2019- 2020 216.10 216.10

-- 2020- 2021 170.08 207.03 36.95 For the Difference of Rs 36.95 Crores Credit Note was raised during the said period. I/3300/2023 46

2021- 2022 163.97 175.09 11.12 For the Difference of Rs 11.12 Crores Credit Note was raised during the said period. 2022- 2023 139.54 225.55 86.01 For the Difference of Rs 86.01 Crores Credit Note was raised during the said period.

B. IMPORT i. (Capital Goods including procurement done on IUT (from SEZ, EOU, STPI, EHTP) basis.) (Rs. In Crores) Year/Period Figures reported in APR (FOB Value) Figures as per Customs Records Difference if any Reason for Difference/Remark (1) (2) (3) (4) (5) 2018-2019 1.06 1.06 0.00

2019-2020 Actual and not cumulative 0.21 0.08 0.13 Rs. 0.13 crores Zone to Zone Transfer CIF Value for year 2018-19 & the unit has Considered in 2019-20 2020-2021 (Actual and not cumulative) 2.37 2.37 0.00

2021-2022 (Actual and not cumulative) 0.00 0.00 0.00

2022-2023 (Actual and not cumulative) 0.07 0.07 0.00

ii. Raw Material (Rs. In Crores)

Year/Per iod Figures reported in APR (FOB Value) Figures as per Customs Records Difference if any Reason for Difference/Remark (1) (2) (3) (4) (5) 2018- 2019 0.00 0.00 0.00

I/3300/2023 47

2019- 2020 0.00 0.00 0.00

2020- 2021 0.00 0.00 0.00

2021- 2022 0.00 0.00 0.00

2022- 2023 0.00 0.00 0.00

(‘C) BLUT (Amount in ‘Crores’)

1 Value of BLUT Executed (Duty foregone) (including for CG/ Raw Material/ Services)

Value of Additional BLUT executed • Year: Date of acceptance • BLUT amount:

TOTAL value of BLUT Executed

1. F.No. SEEPZ-SEZ/EKIPL- SEZ/AMO&S/20/2012- 13/8146 dated 25.07.2013 Rs. 0.37 Crores
2. SEEPZ-SEZ/EKIPL- SEZ/AMO&S/20/2012- 13/13324 dated 20.11.2013 Rs. 2.32 Crores
3. SEEPZ-SEZ/EKIPL- SEZ/AMO&S/20/2013- 14/VOL-II/9203 dated 12.06.2015 Rs. 01.83 Crores
4. SEEPZ-SEZ/EKIPL- SEZ/AMO&S/20/2013- 14/VOL-III/1755 dated 08.07.2019 Rs. 65.14 Crores Total: Rs. 69.66 Crore 2 Total Duty Foregone on goods & services procured Category Wise:

Year Wise:

I/3300/2023 48

FY Import Goods Ind. Goods Services 18-19 0.43 0.61 6.66 19-20 0.03 0.15 6.95 20-21 0.44 0.15 4.60 21-22 0.00 0.03 5.20 22-23 0.01 0.20 3.90 3 Has the Unit procured goods and or services without having sufficient balance in their BLUT, If Yes, Month & year when the BLUT was exhausted Details of the consignments and Total value of Goods procured without having sufficient or nil balance in BLUT No (d) Employment made as on date (31.03.2023) (as on end of block period/ year up to which monitoring is being done) Men:363 Women: 201 Total No Employment : 564 (e) Details of Pending Foreign Remittance beyond Permissible period, if any

(as on 31.03.2023)

To cross-check the same and verify whether necessary permission from AD Bank/ RBI has been obtained. Customer Name Date of Invoice Amount in INR Crores Reason Allianz Insurance Lanka Ltd 17-12- 21 0.63 Sri Lanka crises due to which Customer not able to send the money. This will be recovered in

I/3300/2023 49

coming days. Allianz Technology SAS 31-12- 22 0.16

Allianz Technology SAS 31-10- 22 0.05

Allianz Technology SAS 30-09- 22 0.29

Total 1.13

(f) Whether all Softex has been filed for the said period. If no, details thereof.

SO to also check whether unit has obtained Softex condonation from DC office / RBI and if approved, whether they have filed such pending Softex. Yes (g) Whether all Softex has been certified, if so till which month has the same been certified. If not, provide details of the Softex and reasons for pendency. No, All SOFTEX were filed on time however due to non- mapping of GOC’s the SOFTEX are pending for Certification. The unit is in the process of completing the mapping of GOC’s and submitting the SOFTEX for certification. The unit has given an Undertaking that they will be completing the filling of pending SOFTEX, for the Monitoring period, within a month’s time. (h) Whether unit has filed any request for Cancellation of softex No (i) Whether

any

Services

provided

in DTA/SEZ/EOU/STPI etc. against payment in INR in r/o IT/ITES Unit during the period. If yes, details thereof (year wise details to be No

I/3300/2023 50

provided) (j) SO to verify and certify whether the unit has updated the BLUT ledger Module in SEZ Online. NA (k) Has the unit cleared any Capital Goods procured duty free in DTA against Payment of Duty, or otherwise. Full details to be provided along with value of assets and duty discharged No (l) Is the unit sharing any of their infrastructure 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 If approval for sharing of common infrastructure has been obtained from UAC/DC office, the date of UAC/ Approval letter to be indicated No (m ) 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.
Filling of DSPF is Under Process (n) 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 Filling of DTA is Under Process (o) Details of the request IDs pending for OOC in respect of DTA procurement on the date of submission of monitoring report No (p) Has the unit set up any cafeteria/ canteen/ food court in unit premises. If yes, whether permission from UAC/DC office has been issued, or otherwise. Whether unit has availed any duty paid goods/services for setting up such facility? If yes, whether unit has discharged such duty/ tax benefit availed? details to be given including amount of duty/ tax recovered or yet to be recovered No cafeteria. However, only Breakout area for the employees to come and eat their own meals brought from home (q) Whether any violation of any of the provisions of law has been noticed/ observed by the Specified Officer during the period under monitoring. No

I/3300/2023 51

ADC’s observations:

• The Unit has achieved export revenue of Rs. 842.26 Crores as against projected export of Rs. 687.88 Crores which is 122.44% and achieved cumulative positive NFE of Rs. 568.08 Crores which is 67.45% the 1st block period i.e. during FY 2018-19 to FY 2022-23. • The Unit has achieved employment of 564 (Men-363, Women-201) as on 31.03.2023. • Unit has not correctly mentioned the import data for FY 2019-20 and hence needs to revise their APR. • Approval Committee may monitor the performance of the Unit for the 1st Block i.e. FY 2018-19 to FY 2022-23 in terms of Rule 54 of SEZ Rules, 2006. I/3300/2023 52

GOVT. OF INDIA, OFFICE OF THE ZONAL DEVELOPMENT COMMISSIONER, SEEPZ – SEZ (PUNE CLUSTER)

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AGENDA NOTE FOR CONSIDERATION OF APPROVAL COMMITTEE

a. Proposal: - Proposal submitted by M/s. Mphasis Limited an IT/ITES unit located in M/s. EON Kharadi Infrastructure Pvt. Ltd.-Phase-I-SEZ, for appointment of service provider in the cafeteria.

b. Specific Issue on which decision of Approval Committee is required: Approval of the Committee for appointment of service provider in the cafeteria, as detailed below:

Sr. No. Facility Vendor Name Location Area in Sq.ft. 1 Cafeteria Services • Snacks • MRP product • Mini Meals • Tea & Coffee • Fruits & Juices Amit Enterprises Plot no. 1, Wing 3 Ground Floor, Cluster C EON Kharadi Phase-I SEZ 100 sq.ft.

c. Relevant provisions: - As per para 3 of Instruction No.95 dated 11.06.2019 ‘3. The issue was examined in this department and with the approval of competent authority, it is conveyed that the same could be allowed subject to the following conditions. The facilities as envisaged under the proviso to Rule 11(5) of the SEZ Rules could also be created by a Unit for its exclusive use subject to obtaining a NOC from the Developer as well as necessary NOCs/ clearances/approvals from the relevant statutory authorities. The units shall not be eligible for any exemptions, drawback, concessions or any other benefits available under Section 7 or Section 26 of SEZ Act, for creating of operating such facilities.

d. Other Information: - • M/s. Mphasis Limited has been granted LOA No. SEEPZ/NEW/SEZ/EON- PUNE/05/2007-08/6721 Date 13.09.2007 • Location of the Unit: Ground to Fourth Floor, 7th Floor, of Wing 3, Ground Floor of Wing 2 In cluster C, Plot No.1 Sr. no. 77, MIDC, EON Kharadi Infrastructure Pvt. Ltd.-SEZ Pune-411014. • Date of commencement of authorized operation: 04.01.2008 File No.S-SEZ-PRO0EON1/2/2022-JDCP

• LOA valid up to: 03.01.2023 • The unit vide their letter dated 22.01.2021, requested for approval of setting up of cafeteria and appointment of service provider. The same was approved by the approval committee in its meeting held on 23.03.2021. Accordingly, the unit was issued approval letter dated 30.03.2021. • The unit has submitted that:

1. The service provider will not avail any GST/Customs duty benefits on the said returnable Items/ equipment.
2. The returnable items/equipment shall remain in the M/s. Mphasis Ltd unit until agreement is valid. On expiry/ termination of the agreement the said returnable items/ equipment shall be returned to the service provider.
3. The unit shall provide space as mentioned above.
4. The vendor will bring the pre-cooked food on cash and carry module. • In support of the above unit has submitted the following documents: • New café vendor-GST copy • Copy of food corporation certificate • Copy of cafeteria floor plan • Copy of Fire NOC of the building • Copy of Letter of intent from Developer • Copy of Shop Act Certificate from Vendor

d. ADC’s Recommendations:
• Approval Committee may consider the proposal for appointment of service provider in the cafeteria, in terms of para 3 of Instruction No.95 dated 11.06.2019 issued by MOC&I.

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File No.S-SEZ-PRO0EON1/2/2022-JDCP

GOVT. OF INDIA, OFFICE OF THE ZONAL DEVELOPMENT COMMISSIONER, SEEPZ – SEZ (PUNE CLUSTER)

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AGENDA NOTE FOR CONSIDERATION OF APPROVAL COMMITTEE

a. Proposal: - Application submitted by M/s. Octaserv Technologies Pvt Ltd., IT/ITES unit located in EON Kharadi Infrastructure Pvt.Ltd-SEZ, Phase - I for Change in shareholding of the Company pursuant to the Amalgamation. b. Specific Issue on which decision of Approval Committee is required: -Approval of the Committee for Change in shareholding of the Company pursuant to the Amalgamation, in terms of Instruction No. 109 dated 18.10.2021, as detailed below:

M/s. Octaserv Technologies Pvt Ltd. is wholly owned subsidiary of Plantir Economic Solutions India Pvt. Ltd. (Palantir India). The entire shareholding of Palantir India (except 1 share) is owned by 3ES Innovation Inc.

Name of the Shareholders Existing shareholding pattern prior to the Amalgamation Shareholding pattern after the Amalgamation

No. of Shares Value (INR) % No. of Shares Value (INR) % Palantir Economic Solution India Pvt. Ltd. 1,81,00,099 18,10,00,900 99.99

--

Octagon

IT Holding 2 AS (as a nominee of

Palantir Economic Solution India Pvt. Ltd. 1 10 0.01

--

3ES Innovation Inc.

--

1,81,49,620 18,14,96,200 99.99 Aucerna Intermediate Holdings

--

1 10 0.01 Total 1,81,00,100 1,81,00,100 100 1,81,49,621 18,14,96,210 100

c. 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 File No.S-SEZ-PRO0EON1/12/2022-JDCP

undertaken by the Unit Approval Committee (UAC) concerned subject to the condition that the Developer/Co-developer/ Unit shall not opt out or exit out of the Special Economic Zone and continues to operate as a going concern. All liabilities of the Developer/Co-Developer/Unit shall remain unchanged on such reorganization.” … d. Other Information: - M/s. Octaserv Technologies Pvt Ltd. is granted LOA No. SEEPZ/EKOPL- SEZ/OTPL/52/2021-22/1004 dated 03.11.2021 is located at 5th Floor, Wing 4, Cluster D, EON Free Zone, Plot No.1, S. No 77 MIDC Kharadi Knowledge Park, Phase I, Pune-411 014. • DCP: 01.01.2022 • LOA valid till: 31.12.2026 • Reason for amalgamation and change in Shareholding pattern:

Palantir India vide their Board Resolutions passed at their respective meetings held on 24.03.2023 have got approved the scheme of amalgamation under section 233 of the company’s act.

The unit has submitted that, the Amalgamation will, inter-alias, provide for optimal utilization of existing resources, overall operational synergies, improved organizational capacity and streamlining of the group structure and developing stronger base for future growth. • The Unit has submitted following documents: Copy of Certificate of Registration of Regional Director order for Change of State Copy of Certificate of Incorporation Copy of MOA of Palantir economics solution India Pvt. ltd Copy of Board Resolution Copy of Scheme of Amalgamation Copy of Form No. CAA.129 Copy of INC -28 Copy of Letter of approval Copy of Deceleration of No Change in Directors
d. ADC’s Observation:
Prior to the Amalgamation, the company was ‘indirectly’ owned by 3ES Innovation Inc., however, after the Amalgamation, the Company will be directly owned by 3 ES Innovation Inc.

The Unit has obtained the confirmation order of the Amalgamation dated 30.08.2023 in Form CCA-11 from the Regional Director, Western Region, Ministry of Corporate Affairs sanctioning the Amalgamation and also submitted copy of INC – 28.

Pursuant to the Amalgamation, the SEZ unit of the company i.e. M/s Octaserv Technologies Pvt. Ltd. will continue to operate as a going concern and in the manner as it is currently operating in accordance with the SEZ Act, 2005. Subsequent to the Amalgamation, the name of the company/ SEZ Unit will remain same.

Approval Committee may kindly consider the proposal of the unit for Change in shareholding of the Company pursuant to the Amalgamation, in terms of Instruction no. 109 issued by MOC&I. File No.S-SEZ-PRO0EON1/12/2022-JDCP

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File No.S-SEZ-PRO0EON1/12/2022-JDCP