11/09/2025 — 08-4-eon-kharadi-phase-ii

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 II.

DATE : 12.09.2025

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 12.09.2025 INDEX

Agenda Item No.

Subject

Agenda Item No. 01 :- Confirmation of the Minutes of the meeting held on 30.06.2025 Agenda Item No. 02 :- Action taken report for the Minutes of the meeting held on 30.06.2025 Agenda Item No. 03 :- Application for approval of Merger of LOAs submitted by M/s. Allianz Services Pvt Ltd Agenda Item No. 04:- Application for approval for Sharing of Common Infrastructure facilities submitted by M/s. CA(India) Technologies Pvt. Ltd. Agenda Item No. 05:- Application for approval for addition of area with Revision in Projections submitted by M/s. Synechron Technologies Pvt. Ltd Agenda Item No. 06:- Application for approval for Broad Banding of Services without Revision in Projections submitted by M/s, UBS Business Solution (India) Pvt. Ltd.

Agenda Item No. 07:- Monitoring of performance of M/s. Mphasis Limited.

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मैसस ईओएन खराडी इंाटचर ा. लिमटेड-चरण- II एसईजेड, खराड़ी, पुणे, के आईटी-आईटीईएस सेटर के िव#श% िवशेष आ'थक )े* के लए )ेीय िवकास आयु, सी-ज़-एसईजेड, मुंबई क0 अ2य)ता म4 30.06.2025 को आयो6जत अनुमोदन सिम8त क0 53 व9 बैठक का िववरण। 1 एसईजेड का नाम मैसस.ईओएन खराडी इंाटचर ा. लिमटेड-एसईजेड, चरण II 2 )े आईटी/आईटीईएस 3 मी<टग नं 53 वी 4 तारीख 30.06.2025

उप?थत सदय: @. नाम और पदनाम (एस/Bी.)
िवभाग 1 Bीमती िमतल िहरेमठ संयु, िवकास आयु, पुणे Eटर एसईजेड, पुणे 2 Bी अ#भनव राठी उप आयु,, आयकर िवभाग आयकर िवभाग से नािमत 3 Bी संजीव पािटल, उFोग अ8धकारी महारा% सरकार से नािमत 4 Bी. मंचक जाधव, उप-)ेीय अ8धकारी महारा% दूषण िनयंण बोड से नािमत 5 Bीमती पुIपा गंगावणे, एफटीडीओ पुणे डीजीएफटी िवभाग से नािमत 6 Bी शांत रोहणेकर, अधी)क सीमा शुKक िवभाग पुणे नािमत िवशेष आमंि*त : @. नाम एवं पदनाम(Bी/ Bीमती) िवभाग 1 Bी. शLभू दयाल मीना, िविनMद% अ8धकारी सी-ज़-एसईज़ेड, पुणे Eटर

एज4डा आइटम नंबर 01: िदनांक 09.05.2025 को आयो6जत 52 व9 बैठक के कायवृO क0 पुि%। िवचारिवमश के बाद, सिम8त ने 09.05.2025 को आयो6जत अनुमोदन सिम8त क0 52 व9 बैठक के कायवृO क0 पुि% क0। एज4डा आइटम नंबर 02: 09.05.2025 को आयो6जत बैठक के कायवृO के लए क0 गई कारवाई Pरपोट। िवचार-िवमश के बाद, सिम8त ने 09.05.2025 को आयो6जत बैठक के लए क0 गई कारवाई Pरपोट नोट क0 है। एज4डा आइटम नंबर 03: मेसस जेनसर टेनोलॉजीज लिमटेड के दशन क0 िनगरानी। िवचार-िवमश के बाद, सिम8त ने एसईजेड िनयम, 2006 के िनयम 54 के संदभ म4 िRतीय Sलॉक अव8ध के थम वष यानी िवO वष 2024- 25 के लए इकाई के दशन को नोट िकया। नीचे िवतृत Tप से बताया गया है:

इकाई ने िRतीय Sलॉक अव8ध के थम वष अथात् िवO वष 2024-25 के दौरान संचयी आधार पर 113.02 करोड़ Wपये के अनुमािनत िनयात के मुकाबले 70.72 करोड़ Wपये का िनयात राजव हा6सल िकया है। इकाई ने िवO वष 2024-25 म4 संचयी आधार पर 69.30 करोड़ Wपये यानी 97.99% का सकाराXमक एनएफई हा6सल िकया है। इकाई ने 286 के अनुमािनत रोजगार के मुकाबले 274 कमचाPरयY (पुWष-209 मिहला-65) को रोजगार ाZ िकया है। इकाई को लंिबत डीएसपीएफ दाखल करना आव[यक है। अ2य) को ध\यवाद ]ापन के साथ बैठक समाZ हुई।

Minutes of the 53h 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-II SEZ, Kharadi, Pune, held on 30.06.2025 1 Name of the SEZ M/s. EON Kharadi Infrastructure Pvt. Ltd.-SEZ, Phase II 2 Sector IT/ITES 3 Meeting No. 53th 4 Date 30.06.2025

Members present:

Sr No. Name and Designation(S/Shri.) Department 1 Smt. Mital Hiremath Jt. Development Commissioner Pune Cluster SEZ, Pune 2 Shri. Abhinav Rathi Dy. Commissioner, IT Nominee of Income Tax, Pune 3 Shri. Sanjiv Patil, Industries Officer Nominee of Govt. of Maharashtra 4 Shri. Manchak Jadhav Sub-Regional Officer Nominee of Maharashtra Pollution Control Board 5 Smt. Pushpa Gangawane. FTDO Nominee of DGFT, Pune 6 Shri. Prashant Rohnekar Superintendent Nominee of Customs, Pune

Special Invitee: Sr Name and Designation Department 1 Shri. Shambhu Dayal Meena Specified Officer SEEPZ-SEZ, Pune Cluster

Agenda Item No.01: Confirmation of the Minutes of the 52th meeting held on 09.05.2025

After deliberation, the Committee confirmed the minutes of the 52th meeting of Approval Committee held on 09.05.2025. Agenda Item No.02: Action taken report for the minutes of the meeting held on 09.05.2025 After deliberation, the Committee has noted the Action taken report for the meeting held on 09.05.2025. Agenda Item No.03: Monitoring of Performance for M/s Zensar Technologies Ltd. After deliberation, the committee noted the performance of the unit for First year of 2nd Block period. i.e. FY2024- 25., in terms of Rule 54 of SEZ Rules, 2006. As detailed below:
The unit has achieved export revenue of Rs 70.72 Cr. against the projected export of Rs.113.02 Cr. on cumulative basis during 1st year of 2nd Block period i.e FY 2024-25. The unit has achieved positive NFE of Rs. 69.30 Cr. i.e. 97.99 % in FY 2024-25 on cumulative basis. The unit has achieved employment of 2 4 7 employees (Men-209, Women-65) against the projected employment of 286. The Unit is required to file the pending DSPF. Meeting ended with a vote of thanks to the Chair.

(]ाने^र बी. पाटील, आईएएस) (Dnyaneshwar B. Patil, IAS) अ2य) एवं िवकास आयु, Chairman-cum- Development Commissioner signaturerectangle-1-186 Digitally signed by Dnyaneshwar Bhalchandra Patil Date: 2025.07.04 14:04:18 IST % DSUnknown q 1 G 1 g 0.1 0 0 0.1 9 0 cm 0 J 0 j 4 M []0 d 1 i 0 g 313 292 m 313 404 325 453 432 529 c 478 561 504 597 504 645 c 504 736 440 760 391 760 c 286 760 271 681 265 626 c 265 625 l 100 625 l 100 828 253 898 381 898 c 451 898 679 878 679 650 c 679 555 628 499 538 435 c 488 399 467 376 467 292 c 313 292 l h 308 214 170 -164 re f 0.44 G 1.2 w 1 1 0.4 rg 287 318 m 287 430 299 479 406 555 c 451 587 478 623 478 671 c 478 762 414 786 365 786 c 260 786 245 707 239 652 c 239 651 l 74 651 l 74 854 227 924 355 924 c 425 924 653 904 653 676 c 653 581 602 525 512 461 c 462 425 441 402 441 318 c 287 318 l h 282 240 170 -164 re B Q

Action Taken for Approval Committee held on 30-06-2025 Agenda Item No. Subject Remarks Agenda Item No. 01 Confirmation of the Minutes of the 52nd Meeting held on 09-05-2025 Committee confirmed the minutes of meeting held on 09.05.2025 Agenda Item No. 02 Application for Monitoring of Performace(M/s. Zensar Technologies Limited) Approval letter is issued to the Unit on 04.07.2025.

Sr. No. Description Existing Approved Projections of Unit I Existing Approved Projections of Unit II Revised Projections Post-Merger

LOA No. SEEPZ-SEZ/EKIPL- SEZ/ACISPL/44/2019- 20/1495 dt. 02.05.2019 SEEPZ-SEZ/EKIPL- SEZ/ACISPL/45/2019- 20/1492 dt. 02.05.2019 SEEPZ-SEZ/EKIPL- SEZ/ACISPL/44/2019- 20/1495 dt. 02.05.2019 1. Area (Built up area) Sq. ft Office 1A, 5th floor, Tower-B, EON Kharadi Infrastructure Pvt Ltd SEZ. Area Admeasuring (17856 Sq. Ft.) Office 1B, 5th floor, Tower- B, EON Kharadi Infrastructure Pvt Ltd SEZ. Area Admeasuring (17856 Sq. Ft) Office 1A and 1B,5th floor, Tower-B EON Kharadi Infrastructure Pvt Ltd. Total Area Admeasuring (35712 Sq. Ft.) 2. Employment Men Women Men Women Men Women

215 127 183 85 375 213

342 228 588 3. Investment-Plant and Machinery

Indigenous Capital Goods 2.49 1.66 5.10

Imported Capital Goods 1.10 0.44 1.00 GOVERNMENT OF INDIA, OFFICE OF THE DEVELOPMENT COMMISSIONER, SEEPZ SPECIAL ECONOMIC ZONE, GOVT. OF INDIA, ANDHERI (EAST), MUMBAI

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AGENDA NOTE FOR CONSIDERATION OF APPROVAL COMMITTEE

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a. Proposal : Proposal dated 14.08.2025 and 28.08.2025 submitted by M/s. Allianz Services Pvt Ltd., IT/ITES Units for Merger of LOAs of their 2 existing units located at EON Kharadi Infrastructure Pvt Ltd – SEZ. b. Specific Issue on which decision of AC is required: -
Approval of the Committee for merger of both the LOAs of M/s. Allianz Services Pvt Ltd. Units located at EON Kharadi Infrastructure Pvt Ltd – SEZ, in terms of 4th proviso of Rule 19(2) of SEZ Rules, 2006. c. Relevant provisions of SEZ Act, 2005 & Rules, 2006/Instruction/
Notification :- As per the 4th proviso of Rules 19 (2) of SEZ Rules, 2006; “Provided also that the Approval Committee may also approve proposal for merger of Letter of approvals of two units of the same company or firm subject to the conditions that these Units falls within the same Special Economic Zone and after merger, Block Period for calculation of Net Foreign Exchange shall be from the date of commencement of production of Unit which commenced operation first and the Income tax exemption period shall be considered from the date start of operation of the first Unit.” d. Other Information: - In view of the above M/s. Allianz Services Pvt Ltd. who are having 2 units within the same SEZ has submitted application for merger of the units. Approved projections (Unit I & Unit II) (Rs. In Cr.)

Input of Services

Indigenous Services 29.88 18.31 48.19

Imported Services 0 0 0

The LOA of Unit I & II was renewed on 03.05.2025 for 2 nd block period (i.e FY 2025-26 TO FY 2029-30) which will be considered for the purpose of calculation of Net Foreign Exchange, after the merger. Approved Projections: (Unit I – 2nd Block Period) (Rs. In Cr)

2024-25 2025-26 2026-27 2027-28 2028-29 TOTAL FOB Value of Exports 77.01 81.67 86.70 91.96 97.63 434.98 FE Outgo 7.48 7.16 7.52 7.90 8.31 38.37 NFE 69.53 74.51 79.18 84.06 89.32 396.61 Approved Projections: (Unit II – 2nd Block Period) (Rs. In Cr)

2024-25 2025-26 2026-27 2027-28 2028-29 TOTAL FOB Value of Exports 51.34 54.45 57.80 61.31 65.09 289.99 FE Outgo 4.55 4.78 5.02 5.27 5.54 25.16 NFE 46.79 49.67 52.78 56.04 59.55 264.83 POST MERGER - Proposed Projections: (Unit I) (Rs. In Cr)

2024-25

2025-26 2026-27 2027-28 2028-29 Total FOB Value of Exports 127.29 135.48 144.31 154.09 165.18 726.35 FE Outgo 11.86 11.94 13.04 13.17 13.85 63.85 NFE 115.43 123.54 131.27 140.93 151.33 662.49 Information: - M/s. Allianz Services Pvt Ltd. are having 2 units located at M/s. EON Kharadi Infrastructure Pvt Ltd. In terms of 4th proviso to Rule 19(2) units with two or more LOAs of the same company and falling within the same SEZ can merge their LOAs with the approval of the Approval Committee and after merger the block period for calculation of NFE shall be from the date of commencement of production of the Unit which commenced operation first. In view of the above M/s. Allianz Services Pvt Ltd., having 2 units located at EON Kharadi Infrastructure Pvt Ltd. have submitted their application for merger of both the units. Unit I was issued Letter of Approval No. SEEPZ- SEZ/EKIPL-SEZ/ACISPL/44/2019-20/1495 dt. 02.05.2019. Their date of Commencement of Business is 02.01.2020. Hence, post-merger the operation of both the units viz Unit I and Unit II will not be operational and will be merged with Unit I. The details of both the units are as detailed below:

Unit LOA NO. and Date Date of Commence- ment LOA Valid upto Block Period Located at Area Sqft 1 SEEPZ-SEZ/EKIPL- SEZ/ACISPL/44/2019-20/1495 dt. 02.05.2019 02.01.2020 01.01.2030 2nd

Office No. 1A,5th Floor, Tower B, EON Kharadi Infrastructure Pvt. Ltd.-SEZ, Phase- II, S. No. 72/2/1, Kharadi Pune- 411014. 17856 Sq. Ft. 2 SEEPZ-SEZ/EKIPL- SEZ/ACISPL/45/2019-20/1492 dt. 02.05.2019 26.02.2020 25.02.2030 2nd

Office No. 1B, 5th Floor, Tower B, EON Kharadi Infrastructure Pvt. Ltd.-SEZ, EON Phase-II, S. No. 72/2/1, Kharadi, Pune-411014. 17856 Sq. Ft. Reason for Merger: The unit has submitted the following reasons for merger; Due to the increase in Business and increase in headcount, the unit is considering the option of merging both units. The unit informed that, due to seating capacity constraints and limitations on employee movement between the two units. The unit has informed that clubbing the operation and working in shifts aligned with different time zones will help mitigate capacity constraints, facilitate administrative convenience, and reduce compliance requirements. Documents Enclosed The unit has submitted the following documents: a. Form F3 filed through SEZ Online System b. Copy of Board resolutions authorized persona as authorized signatory c. Copy of all LOA of both the units d. Revised Foreign Exchange Balance Sheet e. List of imported and Indigenous capital goods f. Copy of revised application for merger e. Recommendation: As Date of Commencement of Unit-I is 02.01.2020, upon merger of both the LOAs of the unit, the block period of Unit-I will be considered for calculating NFE of the merged units i.e., FY 2025-26 to FY 2029-30. The Projections of Exports, NFE and Employment after Post merger of both the units is higher than the projections approved by the units prior to merger. The Approval Committee may kindly consider the proposal of the units for merger of their LOAs, in terms of 4th proviso of Rule 19(2) of SEZ Rules, 2006.

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GOVERNMENT OF INDIA, OFFICE OF THE DEVELOPMENT COMMISSIONER, SEEPZ SPECIAL ECONOMIC ZONE, GOVT. OF INDIA, ANDHERI (EAST), MUMBAI

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AGENDA NOTE FOR CONSIDERATION OF APPROVAL COMMITTEE

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a. Proposal : Proposal dated 13.08.2025 submitted by M/s.CA(India) Technologies Pvt. Ltd., located at M/s. EON Kharadi Infrastructure Pvt. Ltd.-SEZ Phase-I, Kharadi Pune-411014. for approval w.r.t. Sharing of Common Infrastructure facilities (Internet Connectivity) with their other SEZ unit. M/s. LSI India Research & Development Pvt. Ltd. b. Specific Issue on which decision of AC is required: -
Approval for sharing of Common Infrastructure facilities (Internet Connectivity) with their other SEZ unit namely, M/s. LSI India Research & Development Pvt. Ltd. located at 3rd Floor, Part B, wing 2, Plot No.1. S.No. 77, MIDC Kharadi Knowledge Park Pune-411014.under Rule 27(5) of SEZ Rules, 2006. c. Relevant provisions of SEZ Act, 2005 & Rules, 2006/Instruction/
Notification :- As per Rule 27(5) of SEZ Rules, 2006 which prescribes : “A unit may import or procure from Domestic Tariff Area, all types of goods and services, without payments of duty, taxes or cess for creating a central facility for use by units in Special Economic Zone and where such facility is created for software development, the same may also be accessed by software exporters of Domestic Tariff Area.” d. Other Information: - Details of Proposed Sharing of Common infrastructure facilities (Internet Connectivity): - M/s. CA (India) Technologies Pvt. Ltd. , located at Ground to 3rd Floor, Wing-2, Cluster–B, Plot No.1, Survey No.77, MIDC, Kharadi Knowledge Park, Pune–411014 (LOA No. SEEPZ-SEZ/CAITPL/46/EKIPL-SEZ/19-20 dated 15.02.2025), proposes to temporarily share its internet leased line with its affiliate company M/s. LSI India Research & Development Pvt. Ltd., located at 3rd Floor, Wing-2, Part-B of the same premises (LOA No. SEEPZ- SEZ/EKIPL-SEZ/LSI/75/2024-25/1222 dated 18.12.2024). LSI has acquired a portion of space and duty-paid assets from CA India and registered a new unit under GSTIN:27AAECM1677N3ZW. Both entities are owned by M/s. Broadcom. As LSI is in the process of setting up its own internet infrastructure, this sharing arrangement will support its SEZ operations at EON Kharadi, which commenced from 1st March 2025, and will continue until October 2025 or until their setup is completed, whichever is earlier. Details of infrastructure facilities to be shared are as detailed below: Sr. No. Location of the infrastructure facility Location of the unit who intend to share the infrastructure Facility to be shared

1 M/s. CA (India) Technologies Pvt. Ltd. Location:- Ground to 3 rd Floor, wing-2, Cluster –B, Plot No.1, Survey No.77, MIDC, Kharadi Knowledge Park, Kharadi Pune- 411014. M/s. LSI India Research & Development Pvt. Ltd. Location: - 3rd Floor, Wing-2, Part-B, Plot No.1, Survey No.77,MIDC, Kharadi Knowledge Park, Kharadi Pune-411014. Internet Connectivity Information: - M/s. CA (India) Technologies Pvt. Ltd. has been granted LOA No. SEEPZ-SEZ/CAITPL/46/EKIPL- SEZ/2019-20 Dated 28.10.2019 Location: Ground to 3rd Floor, wing-2, Cluster –B, EON Kharadi Infrastructure Pvt. Ltd.-SEZ Plot No.1, Survey No.77, MIDC, Kharadi Knowledge Park, Kharadi Pune- 411014. LOA valid up to: 14.02.2030 The Unit has submitted following document: i. Application for sharing of internet connection with M/s. LSI India Research & Development Pvt. Ltd. e. Recommendation: The proposal of the units, sharing of Common infrastructure facilities (Internet Connectivity) between M/s. CA (India) Technologies Pvt. Ltd. and M/s. LSI India Research & Development Pvt. Ltd. located at EON Kharadi Infrastructure Pvt. Ltd. Phase-I may be considered by the Approval Committee in terms of Rule 27(5) of SEZ Rules, 2006.

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GOVERNMENT OF INDIA, OFFICE OF THE DEVELOPMENT COMMISSIONER, SEEPZ SPECIAL ECONOMIC ZONE, GOVT. OF INDIA, ANDHERI (EAST), MUMBAI

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AGENDA NOTE FOR CONSIDERATION OF APPROVAL COMMITTEE

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a. Proposal : Proposal dated 14.08.2025 submitted by M/s. Synechron Technologies Pvt. Ltd., an IT/ITES unit located in M/s. EON Kharadi Infrastructure Pvt. Ltd. SEZ, Phase – II, Kharadi, Pune for approval for addition of area with Revision in Projections. b. Specific Issue on which decision of AC is required: -
Approval of the Committee in terms of Rule 19(2) of SEZ Rules, 2006 for Addition of area admeasuring 71,426 Sq. ft. with Revision in projection. c. Relevant provisions of SEZ Act, 2005 & Rules, 2006/Instruction/
Notification :- 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: - Location / area proposed to be added: Existing address and area Area proposed to be Added Total area after Addition Office 1, 6th Floor & 11th Floor at Tower-B, EON Kharadi Infrastructure Pvt. Ltd.-SEZ, Phase-II,Kharadi Pune-411014. 3rd Floor at Tower-B, M/s. EON Kharadi Infrastructure Pvt. Ltd.- SEZ, Phase-II,Kharadi Pune- 411014. Office1, 3rd ,6th and 11th Floor at Tower-B, M/s. EON Kharadi Infrastructure Pvt. Ltd.-SEZ, Phase-II,Kharadi Pune-411014. Admeasuring area of 94,345 Sq.ft. Admeasuring area of 71,426 Sq.ft. Admeasuring area of 1,65,771 Sq.ft. Revision in Projection: Projections of Investment and Employment: (Rs. In Cr.)
Sr. No Item Existing Projection Total Revised Projection A Investment in Capital Goods I Indigenous CG 29.26 52.89 Ii Imported CG 5.01 5.01

TOTAL 34.27 57.90 B Input Services i Indigenous Services 78.01 97.97 ii Imported Services 0.13 2.65

TOTAL 78.14 100.62 C Employment Men Women Men Women 485 65 1164 356

TOTAL 550 1520 Approved Projection: (Rs. In Cr) Particulars 2021-22 2022-23 2023-24 2024-25 2025-26 Total FOB Value of exports 24.24 119.00 112.40 163.97 199.68 619.29 FE outgo 5.10 0.09 0.00 0.03 0.03 5.25 NFE 19.14 118.91 112.40 163.94 199.65 614.04 Proposed Projection: (Rs. In Cr) Particulars 2021-22 Actual 2022-23 Actual 2023-24 Actual 2024-25 2025-26 Total FOB Value of exports 24.24 119.00 112.40 277.00 270.23 802.87 FE outgo 5.10 0.09 0.00 0.00 1.24 6.43 NFE 19.14 118.91 112.40 277.00 268.99 796.44 Information: - M/s Synechron Technologies Pvt. Ltd., bearing LOA No. SEEPZ-SEZ/EKIPL-SEZ/STPL/51/2020-21, Dated 12.04.2021. located at 11th Floor, Tower-B, EON Kharadi Infrastructure Pvt. Ltd., SEZ, Phase-II, Kharadi, Pune-411014. Date of Commencement: 07.01.2022 LOA is valid upto: 06.01.2027 Reason for Additional Area and Projections: The unit has informed that they wish to expand their operations and propose to lease additional area and expand the unit to enable them to carry on their operations according to the revised business plans/projections and to achieve the revised Net Foreign Exchange (NFE). The unit has submitted the following documents with the application: i. Copy of Form F3 ii. Copy of Consent letter from Developer iii. Copy of letter of intent iv. Copy of Floor plan v. Copy of Balance Sheet vi. Copy of Financial Projection vii. Copy of Additional capital goods viii. Copies of LOA ix. Copy of Board Resolution x. Copy of list of Directors xi. Copy of Authority Letter e. Recommendation: Approval Committee may kindly consider the proposal of the unit for the Addition of Area with Revision in Projection, in terms of Rule 19(2) of SEZ Rules, 2006.

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GOVERNMENT OF INDIA, OFFICE OF THE DEVELOPMENT COMMISSIONER, SEEPZ SPECIAL ECONOMIC ZONE, GOVT. OF INDIA, ANDHERI (EAST), MUMBAI

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AGENDA NOTE FOR CONSIDERATION OF APPROVAL COMMITTEE

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a. Proposal : Proposal Dated 29.08.2025 Submitted by M/s.UBS Business Solutions (India) Pvt. Ltd., SEZ Unit located at EON Kharadi Infrastructure Pvt. Ltd.-SEZ, Phase - II for approval for Broad Banding of Additional Services without revision in projection. b. Specific Issue on which decision of AC is required: -
Approval of Approval Committee for Broad Banding of additional items of service in the existing LOA without revision in projection. As per 1st proviso to Rule No. 19(2) of SEZ Rules, 2006. c. Relevant provisions of SEZ Act, 2005 & Rules, 2006/Instruction/
Notification :- As per 1st proviso to Rule No. 19(2) of SEZ Rules, 2006 [“Provided that the Approval Committee may also approve proposals for broadbanding, diversification, enhancement of capacity of production, change in the items of manufacturing or service capacity, if it meets the requirements of rule 18”]. d. Other Information: - Proposal of the unit: broad banding of additional services in existing LOA as details Below:

ITC/HSN Existing Items of Services ITC/HSN Proposed Items of Services 998313

998311 Information technology IT consulting and support services Management consulting and management services 998315 Hosting And Information Technology IT Infrastructure Provisioning Services. (i.e. Network Access/Connectivity Infrastructure Services)

Information: - M/s. UBS Business Solutions(India) Pvt. Ltd. granted LOA NO. SEEPZ/EKIPL-SEZ/CSSAG/29/2017-18, Dated 24.08.2017. Location: 1st to 11th Floor, Building Tower A, M/s EON Kharadi Infrastructure Pvt. Ltd., - SEZ, Phase II, Survey No. 72, Hissa No. 2/1, Kharadi, Pune-411014.. DCP of the unit is 24.11.2017 LOA Validity up to 23.11.2027 The Unit has filed online application form F-3 for broad banding of services. Reason for Broad Banding of Services

The unit has submitted that, in addition to the existing services, they intend to engage in providing enterprise network access/connectivity setup as a service at the EON Phase-II location for use by other units/legal entities of the UBS Group in India. As stated, they have multiple UBS group entities that will use the enterprise network access/connectivity infrastructure held and to be provided by the EON SEZ unit. The hub at their UBS EON unit will be accessed by all other locations through local and international leased lines for delivery operations. This setup will also enable employees of such units/entities working remotely to access the required services of the unit for their operations/activities. Having such a common hub at EON, accessible to all India-based UBS users, will optimize resources by creating a single-point infrastructure for carrying and managing data traffic, thereby avoiding duplicate infrastructure setup at each location. These services will be categorized under ITC HSN 998315, and the unit will raise periodic invoices in foreign currency to such UBS units/legal entities along with GST, as applicable. The remittance will be received in the foreign exchange account of the SEZ unit for the provision of the referred services. Reason for No Changes in Projections on account of inclusion of additional Services: The unit informs that projections will not be revised due to the inclusion of this activity, as it does not require significant additional manpower. The services relate to network infrastructure support, which is largely self- operated. Moreover, the revenue expected from these services is minimal. However, the services are critical to support other units in carrying out their export and domestic operations efficiently. e. Recommendation: Approval Committee may consider the proposal of the unit for Broad Banding of Additional Services without revision in projections, in terms of Rule 19(2) of SEZ Rules, 2006

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2020-21 2021-22 2022-23 2023-24 2024-25 TOTAL FOB value of export 72.23 126.41 180.59 234.77 288.94 902.94 FE outgo 11.00 1.00 1.00 1.00 1.00 15.00 NFE 61.23 125.41 179.59 233.77 287.94 887.94 Year Export F.E. OUTGO

Projected

Actual Raw Material (Goods/Services) C.G. import Other outflow Projected Actual Projected Actual Actual 2020-21 72.23 0.44 0.00 0.00 15.00 2.99 0.00 2021-22 126.41 0.89 1.06 0.00 2022-23 180.59 1.41 0.39 0.02 2023-24 234.77 5.62 0.98 0.00 2024-25 288.94 27.21 0.00 0.05 TOTAL 902.94 35.57 0.00 0.00 15.00 5.41 0.7 GOVERNMENT OF INDIA, OFFICE OF THE DEVELOPMENT COMMISSIONER, SEEPZ SPECIAL ECONOMIC ZONE, GOVT. OF INDIA, ANDHERI (EAST), MUMBAI

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AGENDA NOTE FOR CONSIDERATION OF APPROVAL COMMITTEE

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a. Proposal : Monitoring of the performance of M/s. Mphasis Limited., an IT/ITES Enabled Services located at M/s. EON Kharadi Infrastructure Pvt. Ltd. Phase-II for 5 Years of 1st Block Period i.e. 2020-21 to FY 2024-25. b. Specific Issue on which decision of AC is required: -
Monitoring of the performance of the unit for 5 Years of 1st Block Period i.e. 2020-21 to FY 2024-25 in terms of Rule 54 of SEZ Rules, 2006. c. Relevant provisions of SEZ Act, 2005 & Rules, 2006/Instruction/
Notification :- 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”. d. Other Information: - Performance as compared to projections: for 1st Block Period FY 2020-21 to FY 2024-25
(Rs. In Cr.)

Performance as compared to projections: (Rs. In Cr.)

Cumulative NFE achieved: (Rs. in Cr.)

Year Cumulative NFE Achieved Cumulative % NFE Achieved 2020-21 0.13 31.84% 2021-22 0.62 46.94% 2022-23 1.57 57.38% 2023-24 6.65 79.56% 2024-25 33.28 93.52%

Employment Achievement

Approved Achieved Men 550 251 Women 250 138 Total 800 389

Reason for Less Export:

The unit stated that during the peak of the COVID-19 pandemic, they commenced operations and subsequently experienced significant changes in the business, which led to a reduction in export volumes. Furthermore, with respect to employment, a portion of EON Phase 2 was converted to MRLAD. The projected headcount was 800; however, the current employment stands at 398 in Mphasis and approximately 166 in MRLAD, bringing the total to 564.

LOA No. & Date SEEPZ-SEZ/EKIPL-SEZ/ML/47/2019-20 Dated 13.01.2020 Location of Unit 12th Floor in Tower B, EON- Kharadi Infrastructure Pvt Ltd-SEZ, Phase II, Sr No 72, Hissa No 2 by 1, Kharadi, Pune- 411014 Validity of LOA 31.08.2025 Item(s) of manufacture/ Services IT & ITES Date of commencement of production 01.09.2020 Execution of BLUT Rs. 17.55 Crores Outstanding Rent dues NA Labour Dues NA Validity of Lease Agreement

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 31.03.2025 389 (Men-251, Women-138)

Area allotted (in sq. ft.) 61641.97 Sq.ft. Area available for each employee per sq.ft. basis (area / no. of employees) 158.46 Sq.ft. Investment till date

Building

Plant & Machinery 11.70 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 Officer report vide letter dated 01.08.2025 has reported as detailed below:

EXPORT (Rs. In Cr)
Year/ Period Figures reported in APR Figures as per Softex/ Customs Records Difference if any Reason for Difference/Remark (1) (2) (3) (4) (5) 2020-21 0.44 0.44 0.00

2021-22 0.89 0.88 0.01 Difference is due to Exchange Rate Variation 2022-23 1.41 1.54 -0.13 Difference is due to Exchange Rate Variation 2023-24 5.63 5.58 0.05 Difference is due to Exchange Rate Variation 2024-25 27.22 29.66 -2.44 Due to internal adjustments of the unit and their client the unit requested for the cancellation of Invoice No 2Z4IC250025, 2Z4IC250026 Dt. 06.05.2024 (amounting to Rs 2.27 Crores). The report in the matter is submitted. The remaining difference of Rs 0.17 Crores is due to Exchange Rate Variation. IMPORT (Capital Goods including procurement done on IUT (from SEZ, EOU, STPI, EHTP) basis.) (Rs. In Cr)

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) 2020-21 2.99 4.00 -1.01 Inadvertently the unit filed two B/E’s twice. The goods were received against one set of B/E’s and the in respect of other set of B/E’s the unit filed Freeform for cancellation.
2021-22 4.05 1.06 2.99 As per APR format the value reported is Cumulative Values. And the Actual Import Procurement of Rs 1.06 crores as per CUSTOMS Records for this Year 2022-23 4.44 0.43 4.01 As per APR format the value reported is Cumulative Values. And the Actual Import Procurement of Rs 0.43 crores as per CUSTOMS Records for this Year 2023-24 5.42 0.98 4.44 As per APR format the value reported is Cumulative Values. And the Actual Import Procurement of Rs 0.98 crores as per CUSTOMS Records for this Year 2024-25 5.42 0.00 5.42 As per APR format the value reported is Cumulative Values. And the Actual Import Procurement is Nil as per CUSTOMS Records for this Year Raw Material (Rs. In Cr) 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) 2020-21 To 2024-25

0.00 0.00 0.00

BLUT (Rs.in Cr.) 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

Date of Acceptance BLUT Amount 17.03.2020 17.55 Crore Total 17.55 Crore

2 Total Duty Foregone on goods & services procured Category Wise:

Year Wise:

FY Goods Imported & Indigenous Services Imported & Indigenous 20-21 2.07 0.00 21-22 0.51 0.00 22-23 0.17 1.54 23-24 0.46 2.31 24-25 0.05 2.23 Total 3.26 6.08

(d) Employment made as on date (31.03.2025) (as on end of block period/ year up to which monitoring is being done) Men: 251 Women: 138 Total No Employment :389 The unit submitted a declaration for the above staff strength dated 31.03.2025 (e) Details of Pending Foreign Remittance beyond Permissible period, if any (as on 31.03.2025) To cross-check the same and verify whether necessary permission from AD Bank/ RBI has been obtained. Except 28 Invoices pertaining to the period 2024-25, No other foreign remittance is pending.

(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. All SOFTEX forms are filled and Certified (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. Yes (h) Whether unit has filed any request for Cancellation of softex Yes.

(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 povided) Yes. Sr No FY Amount In Crores 1 2020-21 0.00 2 2021-22 0.00 3 2022-23 0.00 4 2023-24 0.00 5 2024-25 6.92 Total 6.92

(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 the 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. Yes (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 Yes (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 Yes. Approval Obtained vide UAC dated 23.03.2021 vide F.No. SEEPZ-SEZ/EKIPL-SEZ/ML/47/2019- 20/693 Dated: 04-08-2021. The unit submitted the worksheet for the indigenous goods used in cafeteria valued at Rs. 2,18,630/- and have agreed to discharge duty/tax benefit availed of Rs. 39,353/- at the earliest. (q) Whether any violation of any of the provisions of law has been noticed/ observed by the Specified Officer during the period under monitoring. NA

e. Recommendation: The Unit has achieved export revenue of Rs. 35.58 Crores as against the projected export of Rs 902.94 Crores and achieved positive NFE of Rs. 33.28 Crores which is 93.52 % on cumulative basis in 5 Years of 1st Block Period i.e. 2020-21 to FY 2024-25. As per SO report the unit has achieved employment of 389 employees (Men-251, Women-138) As per the SO report, it is observed that the Unit has provided services in DTA against payment received in INR during the monitoring period as follows: FY Amt in INR in Crores. 2024-25 6.92 TOTAL 6.92 Since providing of “Services” in DTA against payment received in INR does not qualify as ‘Services’ as per definition given in Section 2(z) of the SEZ Act, 2005, The unit has made violation of various provision of SEZ Act / Rules and under Foreign Trade (Development and Regulation) Act, 1992. Show Cause Notice may be issued to the Unit. The Unit is required to refund the duty benefit availed for setting up of cafeteria. Approval committee may kindly monitor the performance of the Unit for 5 Years of 1st Block Period i.e. 2020-21 to FY 2024-25, in terms of Rule 54 of SEZ Rules, 2006. in terms of Rule 54 of SEZ Rules, 2006

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