IN FORCE SEZ / EOU / FTWZ

Agenda for Approval Committee meeting for EOU and SEZ under Pune Cluster scheduled on 01st July, 2026. — 05-manjri-sez

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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. MANJRI STUD FARMS. -SEZ

DATE : 01.07.2026

TIME : 11:00 A M.

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 01.07.2026

INDEX Agenda Item No. Subject

Agenda Item No. 01: - Confirmation of the Minutes of the meeting held on 07.05.2026 Agenda Item No. 02: - Action taken report for the Minutes of the meeting held on 07.05.2026 Agenda Item No. 03: - Monitoring of performance for M/s. Twopir Consulting Pvt Ltd. Agenda Item No. 04: - Application for amendment/correction of HSN Code submitted by M/s. Rheal Software Technology Solutions LLP (LOA 05)
Agenda Item No. 05: - Application for amendment/correction of HSN Code submitted by M/s. Rheal Software Technology Solutions LLP (LOA 16)

Solutions LLP (LOA 05)
Agenda Item No. 05: - Application for amendment/correction of HSN Code submitted by M/s. Rheal Software Technology Solutions LLP (LOA 16)

मेसस मांजरी टड फाम ाइवेट लिमटेड-एसईजेड, पुणे के आईटी/आईटीईएस सेटर के िवश िवशेष आ थक "े# के लए "े#ीय िवकास आयु%, सी&ज़-एसईज़ेड, मुंबई क) अ+य"ता म- 07.05.2026 को आयो/जत अनुमोदन सिम2त क) 112 व3 बैठक का कायवृ7 । 1 एसईजेड का नाम मेसस मांजरी टड फाम ाइवेट लिमटेड- एसईजेड 2 सेटर आईटी/आईटीईएस 3 बैठक 9मांक 112 वी 4 तारीख 07.05.2026

उप< थत सद य 9. नाम और पदनाम (एस/>ी.)
िवभाग 1

ीमती िमतल िहरेमठ, संयु% िवकास आयु% पुणे B टर एसईजेड, पुणे 2 ी. अभनव राठी उप आयु%, आयकर िवभाग आयकर िवभाग से नािमत 3 ी. संजीव पािटल, उCोग अ2धकारी, पुणे "े# महाराE सरकार से नािमत 4 ी. &लेटो लोबो, सहायक िवदेश Fयापार महािनदेशक पुणे डीजीएफटी िवभाग से नािमत 5 ी. नवनाथ अवताडे, उप "े#ीय अ2धकारी महाराE दूषण िनयं#ण बोड से नािमत 6 ी. शांत रोहणेकर, अधी"क सीमा शुIक िवभाग, पुणे से नािमत िवशेष आमंि#त

नाम एवं पदनाम(>ी/ >ीमती) िवभाग 1

ी. शJभू दयाल मीना, िविनKद अ2धकारी सी&ज़-एसईज़ेड, पुणे ल टर

एज-डा िवषय 9. 01 : िद. 30.03.2026 को आयो/जत 111 व3 बैठक के कायवृ7 क) पुि । िवचार-िवमश के बाद, सिम2त ने 30.03.2026 को आयो/जत 111 व3 अनुमोदन सिम2त क) बैठक के कायवृ7 क) पुि क)। एज-डा िवषय 9. 02: िद. 30.03.2026 को आयो/जत 111 व3 बैठक के कायवृ7 के लए क) गई कारवाई Mरपोट । िवचार-िवमश के बाद, सिम2त ने 30.03.2026 को आयो/जत बैठक के लए क) गई कारवाई Mरपोट नोट क) है। एज-डा िवषय 9. 03: मेसस Mरयल सॉOटवेयर टेनोलॉजी सॉIयूशंस एल.एल.पी.

ायवृ7 के लए क) गई कारवाई Mरपोट । िवचार-िवमश के बाद, सिम2त ने 30.03.2026 को आयो/जत बैठक के लए क) गई कारवाई Mरपोट नोट क) है। एज-डा िवषय 9. 03: मेसस Mरयल सॉOटवेयर टेनोलॉजी सॉIयूशंस एल.एल.पी. (इकाई -II) के दशन क) िनगरानी। िवचार-िवमश के बाद, सिम2त ने एसईजेड िनयम, 2006 के िनयम 54 के अनुसार, इकाई के पहले Pलॉक अव2ध के पांचव- वष यानी िव7 वष 2021-22 और दूसरे Pलॉक अव2ध के तीन वष यानी िव7 वष 2022-23 से िव7 वष 2024-25 तक के दशन को नोट िकया, /जसका िववरण नीचे िदया गया है:। इकाई ने पहले Pलॉक अव2ध के पांचव- वष म- अथात िव7 वष 2021-22 म- 9.84 करोड़ Rपये के अनुमािनत िनयात क) तुलना म- 3.51 करोड़ Rपये का िनयात राज व ाS िकया है और संचयी आधार पर 14.13 करोड़ Rपये अथात 98.85 % का सकाराTमक एनएफई (NFE) ाS िकया है। इकाई ने दूसरे Pलॉक अव2ध के तीन वष (अथात िव7 वष 2022-23 से िव7 वष 2024-25) म- 11.70 करोड़ Rपये के अनुमािनत िनयात क) तुलना म- 9.48 करोड़ Rपये का िनयात राज व ाS िकया है और संचयी आधार पर 9.11 करोड़ Rपये अथात 96.10% का सकाराTमक एनएफई (NFE) ाS िकया है। इकाई ने 31.03.2025 तक 26 कमचाMरयU (पुRष-21, मिहला-06) का रोजगार ाS िकया है।

करोड़ Rपये का िनयात राज व ाS िकया है और संचयी आधार पर 9.11 करोड़ Rपये अथात 96.10% का सकाराTमक एनएफई (NFE) ाS िकया है। इकाई ने 31.03.2025 तक 26 कमचाMरयU (पुRष-21, मिहला-06) का रोजगार ाS िकया है।

अ+य" को धVयवाद Wापन के साथ बैठक समाS हुई।

Minutes of the 112th 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. The Manjri Stud Farm Pvt. Ltd.-SEZ, Pune held on 07.05.2026. 1 Name of the SEZ M/s. The Manjri Stud Farm Pvt. Ltd.-SEZ 2 Sector IT/ITES 3 Meeting No. 112th
4 Date 07.05.2026 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, Pune Region Nominee of Govt. of Maharashtra 4 Shri Plato Lobo, Asstt. Director General of Foreign Trade Nominee of DGFT, Pune 5 Shri Navanath Awatade, Sub Regional Officer Nominee of Maharashtra Pollution Control Board 6 Shri. Prashant Rohanekar, 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 111th Meeting held on 30.03.2026. After deliberation, the Committee confirmed the minutes of the 111 th Approval Committee meeting held on 30.03.2026.
Agenda Item No. 02: Action taken report for the Minutes of the 111 th meeting held on 30.03.2026.

Committee confirmed the minutes of the 111 th Approval Committee meeting held on 30.03.2026.
Agenda Item No. 02: Action taken report for the Minutes of the 111 th meeting held on 30.03.2026. After deliberation, the Committee has noted the Action taken report for the meeting held on 30.03.2026. Agenda Item No. 03: Monitoring of Performance for M/s. Rheal Software Technology Solutions LLP (Unit

II). After deliberation, the Committee noted the performance of the unit for 5th year i.e. FY 2021-22 of the 1st Block period (FY 2017-18 to FY 2021-22) and 3 years i.e. FY 2022-23 to FY 2024-25 of 2 nd Block period (FY 2022-23 to FY 2026-27), in terms of Rule 54 of SEZ Rules, 2006. The unit has achieved export revenue of Rs. 3.51 Crores as against projected export of Rs. 9.84 Crores and has achieved Positive Cumulative NFE of Rs. 14.13 Crores i.e. 98.85% in 5th year i.e. FY 2021-22 of the 1st Block period (FY 2017-18 to FY 2021-22). The unit has achieved export revenue of Rs. 9.48 Crores as against projected export of Rs. 11.70 Crores and has achieved positive cumulative NFE of Rs. 9.11 Crores i.e. 96.10% in the 3 years (i.e. FY 2022-23 to FY 2024-25) of 2nd Block period (FY 2022-23 to FY 2026-27). As per SO report the unit has achieved employment of 26 employees (Male: 21, Female: 06) as on 31.03.2025. Meeting ended with a vote of thanks to the Chair.
signaturerectangle-1-186 (ानेर बी. पाटल, आयएएस) (Dnyaneshwar B.

mployment of 26 employees (Male: 21, Female: 06) as on 31.03.2025. Meeting ended with a vote of thanks to the Chair.
signaturerectangle-1-186 (ानेर बी. पाटल, आयएएस) (Dnyaneshwar B. Patil, IAS) अय -सह- "वकास आयु% Chairman-cum- Development Commissioner Digitally signed by Dnyaneshwar Patil Date: 2026.05.26 10:59:32 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 07-05-2026 Agenda Item No. Subject Remarks Agenda Item No. 01 Confirmation of the Minutes of the 111st Meeting held on 30-03-2026 Minutes of the meeting held on 07.05.2026 confirmed by the Approval Committee. Agenda Item No. 02 Application for Monitoring of Performance(M/s. Rheal Software Technology Solutions LLP) Approval Letter was issued to the unit on 26.05.2026

6 confirmed by the Approval Committee. Agenda Item No. 02 Application for Monitoring of Performance(M/s. Rheal Software Technology Solutions LLP) Approval Letter was issued to the unit on 26.05.2026

Year Export F.E. OUTGO

Projected

Actual Raw Material (Goods/Services) C.G. import Other outflow Projected Actual Projected Actual Actual 2016-17 2.40 4.26 0.00 0.00

15.00 0.00 0.00 2017-18 2.64 3.28 0.00 0.00 0.00 0.00 2018-19 3.15 6.53 0.00 0.00 0.00 0.0048 2019-20 3.46 5.44 0.00 0.00 0.00 0.0053 2020-21 4.10 7.16 0.00 0.00 0.00 0.0057 Total 15.75 26.67 0.00 0.00 15.00 0.00 0.0158 GOVERNMENT OF INDIA, OFFICE OF THE DEVELOPMENT COMMISSIONER, SEEPZ SPECIAL ECONOMIC ZONE, GOVT. OF INDIA, ANDHERI (EAST), MUMBAI

AGENDA NOTE FOR CONSIDERATION OF APPROVAL COMMITTEE

a. Proposal : Monitoring of the performance of M/s. Twopir Consulting Pvt. Ltd. , an IT/ITES unit located in The Manjri Stud Farm Pvt. Ltd.-SEZ, Pune, for 5 years of the 1st Block Period (FY 2016-17 to FY 2020-21) and 4 years i.e. FY 2021-22 to FY 2024-25 of the 2nd Block Period (FY 2021-22 to FY 2025-26). b. Specific Issue on which decision of AC is required: -
Monitoring of the performance of the unit for 5 years of the 1 st Block Period (FY 2016-17 to FY 2020-21) & 4 years i.e. FY 2021-22 to FY 2024-25 of the 2 nd Block Period (FY 2021-22 to FY 2025-26), in terms of Rule 54 of SEZ Rules, 2006. c.

for 5 years of the 1 st Block Period (FY 2016-17 to FY 2020-21) & 4 years i.e. FY 2021-22 to FY 2024-25 of the 2 nd Block Period (FY 2021-22 to FY 2025-26), 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 5 years of 1 st Block Period (FY 2016-17 to FY 2020-21) Approved Projections for 1st Block Period (Rs. In Crores) 2016- 17 2017- 18 2018- 19 2019- 20 2020- 21 Total FOB Export 2.40 2.64 3.15 3.46 4.10 15.75 FE Outgo 0.04 0.02 0.01 0.00 0.00 0.07 NFE 2.36 2.62 3.14 3.46 4.10 15.68 Performance as compared to projections: (Rs. In Crores)

B Export 2.40 2.64 3.15 3.46 4.10 15.75 FE Outgo 0.04 0.02 0.01 0.00 0.00 0.07 NFE 2.36 2.62 3.14 3.46 4.10 15.68 Performance as compared to projections: (Rs. In Crores)

Year Cumulative NFE Achieved Cumulative % NFE Achieved 2016-17 4.26 100% 2017-18 7.54 100% 2018-19 14.07 99.97% 2019-20 19.50 99.95% 2020-21 26.65 99.94% Year Export F.E. OUTGO

Projected

Actual Raw Material (Goods/Services) C.G. import Other outflow Projected Actual Projected Actual Actual 2021-22 7.00 9.21 0.00 0.00

0.00 0.04 0.00 2022-23 7.50 12.31 0.00 0.00 0.00 0.00 2023-24 8.00 13.77 0.00 0.00 0.00 0.00 2024-25 8.50 10.49 0.00 0.00 0.00 0.00 Total 31.00 45.78 0.00 0.00 0.00 0.04 0.00 Year Cumulative NFE Achieved Cumulative % NFE Achieved 2021-22 9.21 99.96% 2022-23 21.51 99.96% 2023-24 35.28 99.98% 2024-25 45.77 99.97% Cumulative NFE achieved: (Rs. in Crores)

Approved Projections for 2 nd Block Period (Rs in Crores)

2021-22 2022-23 2023-24 2024-25 2025-26 TOTAL FOB Value of Exports 7.00 7.50 8.00 8.50 9.00 40.00 FE Outgo 0.005 0.005 0.005 0.005 0.005 0.025 NFE 6.995 7.495 7.995 8.495 8.995 39.98 Performance as compared to projections: (Rs in Crores)

Cumulative NFE achieved: (Rs. In Crores)

Employment Achievement as on 31.03.2025

Projected Achieved Men 15 15 Women 15 13 Total 30 28

Cumulative NFE achieved: (Rs. In Crores)

Employment Achievement as on 31.03.2025

Projected Achieved Men 15 15 Women 15 13 Total 30 28

Name of the Unit M/s. Twopir Consulting Pvt Ltd LOA No. & Date SEEPZ-SEZ/MSF-SEZ/TCPL/15/2015-16
dated 06.04.2016 Location of Unit Block 4 A, The Manjri Stud Farm Pvt Ltd-SEZ, S.P. Infocity, S.N No 209, Phursungi, Pune- 412308. Validity of LOA 01.05.2026 Item(s) of manufacture/ Services IT/ITES Date of commencement of production 02.05.2016 Execution of BLUT Rs. 0.47 Crs. 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 No. of employees as on 31.03.2025 Male-15 Female -13, Total- 28. Area allotted (in sq.ft.) 1290 Sq. ft. Area available for each employee per sq.ft. basis (area / no. of employees) 46.07 Sq. ft. Investment till date

Building 0.00 Crores Plant & Machinery 0.038 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. No APR for the year Due date of filing Actual date of Filing in SEZ Online Delay in no. of days Delay in no.

mit, or otherwise.

If no, details of the Year along with no of days delayed to be given. No APR for the year Due date of filing Actual date of Filing in SEZ Online Delay in no. of days Delay in no. of months 2016-17 30.09.2017 07.03.2018 158 5 Months 2017-18 30.09.2018 12.03.2019 163 5 Months 2018-19 30.09.2019 16.12.2019 77 3 Months 2020-21 31.12.2021 30.09.2022 273 9 Months

Total 671 22 Months

The Specified Officer vide letter dated 25.06.2021, 03.04.2025 and 21.04.2026 has submitted report in the prescribed format for the period from FY 2016-17 to FY 2024-25, as under: - Export (Rs. In crores)
Year/Period Figures as per APR Figures as per Softex/ SB / Customs Records Difference if any Reason for Difference/Remark (1) (2) (3) (4) (5) 2020-2021 7.16 7.16 0.00 NA 2021-2022 9.21 9.66 (0.45) Difference of Rs. (0.45) Crore is due to Exchange Rate variation. 2022-2023 12.31 12.35 (0.04) Difference of Rs. (0.04) Crore is due to Exchange Rate variation. 2023-2024 13.76 13.78 (0.01) Difference of Rs. (0.01) Crore is due to Exchange Rate variation. 2024-2025 10.49 10.58 0.09 Difference of Rs. 0.09 Crore is due to Exchange Rate variation. Import (Capital Goods including procurement done on IUT (from SEZ, EOU, STPI, EHTP) basis. (Rs.

e to Exchange Rate variation. Import (Capital Goods including procurement done on IUT (from SEZ, EOU, STPI, EHTP) basis. (Rs. In crores)
Year/Period Figures as per APR Figures as per Customs Records / Bond Register Difference if any Reason for Difference/Remark 2020-2021 0.00 0.00 0.00

NA 2021-2022 0.00 0.00 0.00 2022-2023 0.00 0.00 0.00 2023-2024 0.00 0.00 0.00 2024-2025 0.00 0.00 0.00 Raw Material. Year/Period Figures as per APR (RM Imported) Figures as per Customs Records / Bond Register Difference if any Reason for Difference/Remark 2020-2021 NIL NIL NIL NA 2021-2022 NIL NIL NIL NA 2022-2023 NIL NIL NIL NA 2023-2024 NIL NIL NIL NA 2024-2025 0.00 0.00 Nil NA

BLUT 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 F.No. SEEPZ-SEZ/MSF-SEZ/TCPL/15/2015-16 dated 28.04.2016. Rs. 0.02 Crore F.No. SEEPZ-SEZ/MSF-SEZ/TCPL/15/2015-16/810 dated 07.11.2022. Rs. 0.45 Crore Total: Rs. 0.47 Crore 2 Total Duty Foregone on goods & services procured (Category-wise BLUT value utilized separately for imported and indigenous goods and services) This should be based on BLUT worksheet which provides for estimated value and duty foregone separately for each category of procurement. (Rs. In Crore) F.Y. Goods Services Imp.

us goods and services) This should be based on BLUT worksheet which provides for estimated value and duty foregone separately for each category of procurement. (Rs. In Crore) F.Y. Goods Services Imp. & Ind. 2020-2021 0.00 0.00 2021-2022 0.00 0.00 2022-2023 0.00 0.01 2023-2024 0.01 0.01 2024-2025 0.00 0.004 Total 0.01 0.024

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 (as on end of block period / year upto which monitoring is being done) As on 31st March 2025: Man: 15 Woman: 13 Total: 28 (e) Details of pending Foreign Remittance beyond Permissible period if any (as on 31/03/2024) To cross-check the same and verify whether necessary permission from AD Bank / RBI has been obtained. SO to certify that the same has been verified No.

d Permissible period if any (as on 31/03/2024) To cross-check the same and verify whether necessary permission from AD Bank / RBI has been obtained. SO to certify that the same has been verified No.

(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. Yes. (h) Whether unit has filed any request for Cancellation of Softex NA (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 provided) No. there is no services provided in DTA/SEZ/EOU/STPI against payment received in INR.

(j) SO to verify and certify whether the unit has updated the BLUT ledger Module in SEZ Online.

(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

eof, 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 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. (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 e. Recommendation: The Unit has achieved export revenue of Rs. 26.67 Crores as against projected export of Rs. 15.75 Crores and has achieved positive NFE of Rs. 26.65 Crores as against the projections of Rs. 15.68 Crores i.e.

t has achieved export revenue of Rs. 26.67 Crores as against projected export of Rs. 15.75 Crores and has achieved positive NFE of Rs. 26.65 Crores as against the projections of Rs. 15.68 Crores i.e. 170% on cumulative basis in 5 years of the 1st Block Period (FY 2016-17 to FY 2020-21) . The Unit has achieved export revenue of Rs. 45.78 Crores as against projected export of Rs. 31.00 Crores and has achieved positive NFE of Rs. 45.77 Crores as against the projections of Rs. 30.98 Crores i.e. 147.74% on cumulative basis in the 4 years i.e. FY 2021-22 to FY 2024-25 of the 2nd Block Period (FY 2021-22 to FY 2025-26). As per the SO Report, the unit has achieved employment of 28 employees (Men-15, Women-13) as on 31.03.2025. It is observed that there is delay in filing of APRs for FY 2016-17 to FY 2018-19 and FY 2020-21. SCN may be issued for delay in filing of APRs. The unit is required to rectify the APR for the 5 th year i.e. FY 2020-21 of the 1 st Block Period for incorrect reporting of Cumulative Export & NFE Figures. The performance of the Unit for FY 2016-17 to FY 2019-20 was placed before the UAC for monitoring purpose in its meeting held on 30.11.2021. The Committee observed that export proceeds amounting to Rs. 63.64 Lakhs and Rs. 33.40 Lakhs pertaining to FY 2017-18 and FY 2018-19, respectively, had not been realized and were subsequently written off as bad debts by the unit. Although the write-offs were accepted by the Income Tax Department, the unit neither informed this office nor revised the APRs accordingly.

and were subsequently written off as bad debts by the unit. Although the write-offs were accepted by the Income Tax Department, the unit neither informed this office nor revised the APRs accordingly. Accordingly, after deliberation, the Committee deferred the monitoring of performance and directed that, as the unit’s LOA has expired, the DC office may consider the renewal of their LOA. The Committee directed the unit to revise the APRs from FY 2017-18 onwards within 15 days, as the same would have cumulative effect in the subsequent APRs. The Committee also directed to examine the admissibility of the write-off amount as per the RBI Guidelines. Upon submission of revised APRs for FY 2016-17 to FY 2019-20, the matter was again placed before the UAC on 28.12.2021. The Committee observed that the unit had written off export proceeds to the extent of 14.96% and 10.17% of the Total Export proceeds realized, in the FY 2017-18 and FY 2018-19 respectively, exceeding the limit prescribed by RBI for self write-off by the unit. While the unit representative stated that RBI approval had been obtained and submitted to this office, no such approval was available on record. The unit’s consultant, however, informed the Committee that the proposal was still pending with RBI through the AD Bank, namely Kotak Mahindra Bank.

office, no such approval was available on record. The unit’s consultant, however, informed the Committee that the proposal was still pending with RBI through the AD Bank, namely Kotak Mahindra Bank. In view of the contradictory submissions and non-submission of RBI approval, the Committee deferred the monitoring of performance and directed the unit to obtain and submit the requisite RBI approval. Subsequently, this office vide letters dated 10.01.2022, 23.02.2026, 05.03.2026, 08.04.2026, 24.04.2026 and 16.06.2026 issued reminders seeking the requisite permission obtained from RBI for writing off the unrealized export proceeds for FY 2017-18 & FY 2018-19 in compliance with directions of the UAC. However, no reply has been received from the unit till date.

The unit subsequently submitted application for renewal of LOA vide letter dated 27.02.2026, however, the compliance with respect to the directions of the UAC is still awaited. The LOA of the unit was valid till and has expired on 01.05.2026 subsequent to which the Unit has been granted two temporary extensions of 1 month to their LOA in SEZ Online portal. The last such extension was valid up to 30.06.2026. In view of the above, the matter is placed before the Approval Committee for further directions. The Approval Committee may like to monitor the performance of the Unit for 5 years of the 1 st Block Period (FY 2016-17 to FY 2020-21) and 4 years i.e.

the Approval Committee for further directions. The Approval Committee may like to monitor the performance of the Unit for 5 years of the 1 st Block Period (FY 2016-17 to FY 2020-21) and 4 years i.e. FY 2021-22 to FY 2024-25 of the 2 nd Block Period (FY 2021-22 to FY 2025-26), in terms of Rule 54 of SEZ Rules, 2006.

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

AGENDA NOTE FOR CONSIDERATION OF APPROVAL COMMITTEE

a. Proposal : Proposal dated 09.06.2026 submitted by M/s. Rheal Software Technology Solutions LLP, an IT/ITES Unit located in The Manjri Stud Farm Private Limited – SEZ, for amendment/correction of SAC Code in the LOA.
b. Specific Issue on which decision of AC is required: -
Approval of the Committee for amendment/correction of SAC code in the LOA of the Unit, in terms of Rule 19(2) of SEZ Rules, 2006. Particulars Existing ITC HS/CPC Code/Description as per the LOA Proposed Modified SAC/CPC Code/Description in the LOA ITC HS/SAC Code 85238020 998314 CPC Code

83141 Description ITITES Information technology (IT) design and development services / IT Enabled Services. c.

Modified SAC/CPC Code/Description in the LOA ITC HS/SAC Code 85238020 998314 CPC Code

83141 Description ITITES Information technology (IT) design and development services / IT Enabled Services. c. Relevant provisions of SEZ Act, 2005 & Rules, 2006/Instruction/
Notification :- As per the Rule 19 (2) of SEZ Rules, 2006; “(2) The Letter of Approval shall specify the items of manufacture [along with the corresponding Indian Trade Classification (Harmonised System) of Export and Import Items, 2017] of particulars of service activity, including trading or warehousing, projected annual export and Net Foreign Exchange Earning for the first five years of operations, limitations, if any on Domestic Tariff Area sale of finished goods, by-products and rejects and other terms and conditions, if any, stipulated by the Board or Approval Committee: [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. Rheal Software Technology Solutions LLP
have been issued LOA No. SEEPZ-SEZ/MSF- SEZ/RSTS/05/2011-12/10030 dated 27.06.2011 to operate as an IT/ITES SEZ Unit at Wing A, Building No. 4, Ground Floor, The Manjri Stud Farm Pvt. Ltd.-SEZ, S.No. 209, SP Infocity, Phursungi, Pune-412308. DCP: 22.08.2011 LOA Valid up to: 21.08.2026 Reason for amendment: The unit in its application has stated that the unit is engaged exclusively in export of IT/ITES services.

y, Phursungi, Pune-412308. DCP: 22.08.2011 LOA Valid up to: 21.08.2026 Reason for amendment: The unit in its application has stated that the unit is engaged exclusively in export of IT/ITES services. However, the ITC HS code against the said IT/ITES services has been indicated as 85238020 in their LOA, owing to an inadvertent error in mention of the appropriate ITC HS code at the time of making an application for grant of LOA. The unit has added that the appropriate Service Accounting Code (SAC)/classification which needs to be mentioned in the LOA is SAC 998314- Information Technology (IT) design and development services/ IT Enabled Services. The unit has stated that this request is purely for rectification of the inadvertent error in mention of the ITC HS Code in the LOA. The Unit has confirmed that the proposed rectification does not involve any change in the constitution of the unit, shareholding pattern, location, authorized operations, capacity of production, approved projections of Export, Import, Investment, Employment, etc. or any other terms and conditions of the LOA.

nit, shareholding pattern, location, authorized operations, capacity of production, approved projections of Export, Import, Investment, Employment, etc. or any other terms and conditions of the LOA.

Specified Officer’s Verification Report The Specified Officer vide letter dated 23.06.2026 has submitted as under: The unit has correctly shown HSN/SAC code that is 998314- Information Technology (IT) design and development services and they are engaged in providing design and development services for applications to overseas clients which is appropriately covered under SAC Code 998314 and the same has been verified from the agreement copy and softex filed by the Unit. The unit has informed that there is no change in capacity of production in respect of the services they have been providing to overseas clients since inception of their SEZ Unit under the SAC Code No. 998314 and further reiterated that they are exporting only services viz. customized IT/IT enabled services and development of applications) and are not engaged in manufacture/export of goods viz. canned/packaged software on physical Media under HSN Code No. 85238020 which is found to be correct. As submitted by the unit, there are no changes in approved projections of Export, Import, Investment, Employment etc. in the LOA pursuant to the changes in ITC HS/SAC Code of the items of Service Activity viz.

ed by the unit, there are no changes in approved projections of Export, Import, Investment, Employment etc. in the LOA pursuant to the changes in ITC HS/SAC Code of the items of Service Activity viz. customized services of design and development of applications for overseas clients. This office has verified the submissions made by the unit which is found to be correct and to say that as per the Central Product Classification (CPC) Code 2.1, the service activity undertaken by them (SAC Code No. 998314) is specifically covered under sub-code 83141-IT design and development services for applications under the broad CPC Code 8314 which covers Information technology (IT) design and development. It is seen that the services that unit provide to their overseas clients viz. customized design and development services for application is covered under CPC Code No. 83141. e. Recommendation: The Approval Committee may kindly consider the proposal of the unit for amendment/correction of SAC Code in their LOA, in terms of Rule 19(2) of SEZ Rules, 2006 .

ommittee may kindly consider the proposal of the unit for amendment/correction of SAC Code in their LOA, in terms of Rule 19(2) of SEZ Rules, 2006 .

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

AGENDA NOTE FOR CONSIDERATION OF APPROVAL COMMITTEE

a. Proposal : Proposal dated 09.06.2026 submitted by M/s. Rheal Software Technology Solutions LLP (Unit-II), an IT/ITES Unit located at The Manjri Stud Farm Private Limited – SEZ , for amendment/correction of SAC Code in the LOA.
b. Specific Issue on which decision of AC is required: -
Approval of the Committee for amendment/correction of SAC code in the LOA of the Unit, in terms of Rule 19(2) of SEZ Rules, 2006. Particulars Existing ITC HS/CPC Code/Description as per the LOA Proposed Modified SAC/CPC Code/Description in the LOA ITC HS/SAC Code 85238020 998314 CPC Code

83141 Description Off Shore Software Development Services ITITES Enabled Services Information technology (IT) design and development services / IT Enabled Services. c.

Code 85238020 998314 CPC Code

83141 Description Off Shore Software Development Services ITITES Enabled Services Information technology (IT) design and development services / IT Enabled Services. c. Relevant provisions of SEZ Act, 2005 & Rules, 2006/Instruction/
Notification :- As per the Rule 19 (2) of SEZ Rules, 2006; “(2) The Letter of Approval shall specify the items of manufacture [along with the corresponding Indian Trade Classification (Harmonised System) of Export and Import Items, 2017] of particulars of service activity, including trading or warehousing, projected annual export and Net Foreign Exchange Earning for the first five years of operations, limitations, if any on Domestic Tariff Area sale of finished goods, by-products and rejects and other terms and conditions, if any, stipulated by the Board or Approval Committee: [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. Rheal Software Technology Solutions LLP (Unit-II) have been issued LOA No. SEEPZ-SEZ/MSF- SEZ/RSTS/16/2016-17 dated 20.01.2017 to operate as an IT/ITES SEZ Unit at Wing A, Building No. 4, Ground Floor, The Manjri Stud Farm Pvt. Ltd.-SEZ, S.No. 209, SP Infocity, Phursungi, Pune-412308. DCP: 30.06.2017 LOA Valid up to: 29.06.2027 Reason for amendment: The unit in its application has stated that the unit is engaged exclusively in export of IT/ITES services.

y, Phursungi, Pune-412308. DCP: 30.06.2017 LOA Valid up to: 29.06.2027 Reason for amendment: The unit in its application has stated that the unit is engaged exclusively in export of IT/ITES services. However, the ITC HS code against the said IT/ITES services has been indicated as 85238020 in their LOA, owing to an inadvertent error in mention of the appropriate ITC HS code at the time of making an application for grant of LOA. The unit has added that the appropriate Service Accounting Code (SAC)/classification which needs to be mentioned in the LOA is SAC 998314- Information Technology (IT) design and development services/ IT Enabled Services. The unit has stated that this request is purely for rectification of the inadvertent error in mention of the ITC HS Code in the LOA. The Unit has confirmed that the proposed rectification does not involve any change in the constitution of the unit, shareholding pattern, location, authorized operations, capacity of production, approved projections of Export, Import, Investment, Employment, etc. or any other terms and conditions of the LOA.

nit, shareholding pattern, location, authorized operations, capacity of production, approved projections of Export, Import, Investment, Employment, etc. or any other terms and conditions of the LOA.

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