Agenda of Approval Committee meeting to be held on 25.11.2025 -MINDSPACE SEZ

सीÜज़ ͪवशेष आͬथ[क ¢ेğ SEEPZ SPECIAL ECONOMIC ZONE

अंधेरȣ (पूव[), मुंबई ANDHERI (EAST), MUMBAI

                                    काय[सूची के ͧलए 

AGENDA FOR मेसस[ माइंडèपेस ǒबजनेस पाÈस[ Ĥाइवेट ͧलͧमटेड के ͧलए ¢ेğ ͪवशेष ͪवशेष आͬथ[क ¢ेğ के ͧलए अनुमोदन सͧमǓत कȧ बैठक। MEETING OF THE APPROVAL COMMITTEE FOR SECTOR SPECIFIC SPECIAL ECONOMIC ZONE FOR IT/ITES OF M /s. MINDSPACE BUSINESS PARKS PRIVATE LIMITED. èथल : िȪतीय तल, बोडŊ ŝम, Ůशासिनक भवन, डीपी वʒŊ, Ɏावा शेवा िबजनेस पाƛŊ Ůाइवेट िलिमटेड, ɘॉट संƥा 5/1, ɘॉट संƥा 406/एफटीडɲूजेड1 के अंदर, सेƃर 4, जेएनपीए िवशेष आिथŊक Ɨेũ, Ťाम-सावरखार, उरण, रायगढ़, महाराʼŌ -400707 VENUE : 2nd Floor, Board Room, Admin Building, DP World, Nhava Sheva Business Parks Private Limited, Plot No. 5/1, In Plot No. 406/FTWZ1, Sector 4 JNPA SEZ, Village-Sawarkhar, Uran, Raigad, Maharashtra-400707 Ǒदनांक : मंगलवार, 25 नवंबर, 2025 DATE : Tuesday, 25th November, 2025 समय : 01:00 अपराéन TIME : 01:00 PM

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SEZ, Village-Sawarkhar, Uran, Raigad, Maharashtra-400707 Ǒदनांक : मंगलवार, 25 नवंबर, 2025 DATE : Tuesday, 25th November, 2025 समय : 01:00 अपराéन TIME : 01:00 PM

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25th नवंबर 2025 को ͪवकास आयुÈत, एसईईपीजेड-एसईजेड कȧ अÚय¢ता मɅ मेसस[ माइंडèपेस ǒबजनेस पाÈस[ Ĥाइवेट ͧलͧमटेड-एसईजेड के आईटȣ/आईटȣईएस के ͧलए ¢ेğ ͪवशेष ͪवशेष आͬथ[क ¢ेğ के ͧलए अनुमोदन सͧमǓत कȧ बैठक। Meeting of the Approval Committee for Sector Specific Special Economic Zone for IT/ITES of M/ s. Mindspace Business Parks Private Limited-SEZ under the Chairmanship of Development Commissioner, SEEPZ-SEZ on 25th November 2025.

सूचकांक /INDEX काय[सूची मद Đ. Agenda Item No. ͪवषय
Subject काय[सूची मद Đमांक 01:- Agenda Item No. 01: - 30.10.2025 को आयोिजत बैठक के काय[वृƣ कȧ पुिçट। Confirmation of the minutes of the meeting held on 30.10.2025 काय[सूची मद Đमांक 02:- Agenda Item No. 02: - मेसस[ एÈसɅचर सॉãयूशंस Ĥाइवेट ͧलͧमटेड के Ĥदश[न कȧ Ǔनगरानी Monitoring of performance of M /s. Accenture Solutions Pvt. Ltd.
काय[सूची मद Đमांक 03:- Agenda Item No. 03: - मेसस[ कोस[5 इंटेͧलजɅस ͧलͧमटेड (एलओए-49) के Ĥदश[न कȧ Ǔनगरानी Monitoring of performance of M /s. Course5 Intelligence Ltd. (LOA-49) काय[सूची मद Đमांक 04:- Agenda Item No. 04: - मेसस[ माइंडèपेस ǒबजनेस पाÈस[ Ĥाइवेट ͧलͧमटेड (डेवलपर) ɮवारा काया[लय ¢ेğ मɅ कमी के कारण यूǓनट से डेवलपर को ͩफट-आउɪस के èवाͧम×व हèतांतरण हेतु माल-सूची (ͧलèट ऑफ गुɬस) के ͧलए आवेदन। Application for List of Goods for transfer of ownership of fit-outs by unit to developer on account of decrease in office space of M /s.

वाͧम×व हèतांतरण हेतु माल-सूची (ͧलèट ऑफ गुɬस) के ͧलए आवेदन। Application for List of Goods for transfer of ownership of fit-outs by unit to developer on account of decrease in office space of M /s. Mindspace Business Parks Private Limited (Developer). काय[सूची मद Đमांक 05:- Agenda Item No. 05: - मेसस[ डÞãयूएनएस Êलोबल सͪव[सेस Ĥाइवेट ͧलͧमटेड के Ĥदश[न कȧ Ǔनगरानी Monitoring of performance of M /s. WNS Global Services Private Limited काय[सूची मद Đमांक 06:- Agenda Item No. 06: - मेसस[ ͧसंटेल Ĥाइवेट ͧलͧमटेड (एलओए-19) के Ǔनदेशकɉ/भागीदारɉ कȧ सूची मɅ पǐरवत[न हेतु आवेदन Application for change in list of directors/ partners of M/s. Syntel Private Limited (LOA-19) काय[सूची मद Đमांक 07:- Agenda Item No. 07: - मेसस[ ͧसंटेल Ĥाइवेट ͧलͧमटेड के Ǔनदेशकɉ/भागीदारɉ कȧ सूची मɅ पǐरवत[न हेतु आवेदन Application for change in list of directors/ partners of M/s. Syntel Private Limited

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Action Taken for Approval Committee held on 30-10-2025 Agenda Item No. Subject Remarks Agenda Item No. 01 Confirmation of the Minutes of the 137th Meeting held on 19-08-2025 Agenda Item No. 02 Application for change in list of directors/ partners(M /s. GeBBS Healthcare Solutions Private Limited. (LOA-42)) Letter dated 23.11.2025 issued to the unit Agenda Item No. 03 Application for change in list of directors/ partners(M /s. GeBBS Healthcare Solutions Private Limited. (LOA-33)) Letter dated 23.11.2025 issued to the unit Agenda Item No. 04 Application for change in list of directors/ partners(M /s. GeBBS Healthcare Solutions Private Limited.

utions Private Limited. (LOA-33)) Letter dated 23.11.2025 issued to the unit Agenda Item No. 04 Application for change in list of directors/ partners(M /s. GeBBS Healthcare Solutions Private Limited. (LOA-03)) Letter dated 23.11.2025 issued to the unit Agenda Item No. 05 Application for change in list of directors/ partners(M /s. GeBBS Healthcare Solutions Private Limited. (LOA-58)) Letter dated 23.11.2025 issued to the unit

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 performance of the M/s. Accenture Solutions Private Limited unit in terms of Rule 54 of SEZ Rules, 2006. b. Specific Issue on which decision of AC is required: -
Monitoring performance of the unit as specified in FSR. c. Relevant provisions of SEZ Act, 2005 & Rules, 2006/Instruction/
Notification :- In terms of 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: - FINAL SCRUTINY REPORT/2025

Name of the Unit: - M/s. Accenture Solutions Private Limited Address: - Ground to Fifth Level (Ground Floor, 1st to 4th Office Premises), Bldg. No. 12, Mindspace Business Parks Pvt.

INY REPORT/2025

Name of the Unit: - M/s. Accenture Solutions Private Limited Address: - Ground to Fifth Level (Ground Floor, 1st to 4th Office Premises), Bldg. No. 12, Mindspace Business Parks Pvt. Ltd., IT-ITES SEZ, Mindspace, Kalwa TTC Industrial Area, Airoli, Navi Mumbai-400708 Financial Year: - 2020-21(5th year of the 2 nd Block) & 2021-22 to 2023-24 (3 years of the 3 rd Block) As per FAQs related to SEZ Rules, 2006:

“Units, which have not completed one year of operation from the date of commencement of production, will not be monitored. In case a unit has completed less than five years from the date of commencement of production, it will be monitored for the number of completed years. Annual monitoring in the cases of old units which have completed more than five years will be undertaken for only such number of years which fall in the subsequent block/s of five years.”

Details of Previous Monitoring: - I. Previous UAC observations: The monitoring of performance of the APR for the period 2015-16 to 2018-2019 (1 st Block & 2 nd Block) was placed in the 86 th meeting of the Approval Committee held on 05.02.2020 & for FY 2019-20 (2nd Block) was placed in the 94 th meeting of the Approval Committee held on 06.04.2021 wherein the Committee noted the performance of the unit for the years 2015-16 to 2019-20, that the unit has achieved positive NFE on cumulative basis in terms of Rule 54 of SEZ Rules, 2006. (A): Observation on APR i. Approved Projections for the 2 nd block: (Rs.

years 2015-16 to 2019-20, that the unit has achieved positive NFE on cumulative basis in terms of Rule 54 of SEZ Rules, 2006. (A): Observation on APR i. Approved Projections for the 2 nd block: (Rs. in Crores)

1st year 2nd year 3rd year 4th year 5th year Total FOB value of export 113.25 453.00 453.00 453.00 453.00 1,925.25 FE Outgo 11.62 47.91 46.87 49.56 51.27 207.23 NFE 101.63 405.09 406.13 403.44 401.73 1,718.02 ii. Approved Projections for the 3 rd block: (Rs. in Crores)

Year Export F.E. OUTGO

Projected

Actual (As per APR) Raw Material (Goods/Services) C.G. import Other outflow Projected Actual (As per APR) As per NSDL Data Projected Actual (As per APR) As per NSDL Data Actual (As per APR)

2020-21 453.00 1,683.00

51.27 25.19 24.06 35.54

2021-22 1,109.04 2,285.20

70.54 6.90 7.11 3.48

2022-23 1,109.04 2,718.90

67.83 12.23 11.89 6.83 2023-24 1,109.04 2,483.30

74.57 9.12 9.22 0.79 Total 3,780.12 9,170.40

264.21 53.44 52.28 46.64 Year Cumulative Projections NFE Cumulative NFE Achieved As per APR (Column 9) Cumulative % NFE Achieved 2020-21 1,718.02 7,166.20 417.12% 2021-22 1,038.5 2,251.39 216.79% 2022-23 2,079.71 4,888.08 235.04% 2023-24 3,114.18 7,306.94 234.63%

1st year 2nd year 3rd year 4th year 5th year Total FOB value of export 1,109.04 1,109.04 1,109.04 1,109.04 471.28 4,907.44 FE Outgo 70.54 67.83 74.57 71.72 18.19 302.85 NFE 1,038.50 1,041.21 1,034.47 1,037.32 453.09 4,604.59

II.

year Total FOB value of export 1,109.04 1,109.04 1,109.04 1,109.04 471.28 4,907.44 FE Outgo 70.54 67.83 74.57 71.72 18.19 302.85 NFE 1,038.50 1,041.21 1,034.47 1,037.32 453.09 4,604.59

II. Performance as compared to projections for the period 2020-21 to 2023-24.
(Rs. in Crores)

III. Cumulative NFE achieved during the block period 2020-21 to 2023-24.

Cumulative NFE achieved as per APR (Rs. in Crores)

Capital Goods Amortized Values table: -

Year CG Imp. 4B(v) Amortized Value

Cumulative NFE achieved as per APR (Rs. in Crores)

Capital Goods Amortized Values table: -

Year CG Imp. 4B(v) Amortized Value

2014-2015 18.48 1.85

2015-2016 22.20 2.22

2016-2017 12.98 1.30

2017-2018 12.18 1.22

2018-2019 6.83 0.68

2019-2020 19.62 1.96

2020-2021 23.41 2.34

2021-2022 -11.16 -1.12

2022-2023 8.83 0.88

2023-2024 -19.43 -1.94

Total 93.94 9.39

(IV) Whether the Unit achieved Positive NFE : Yes

(D) Other Information: LOA No. & Date

1. SEZ/SERENE-THANE/20/LOA-20/2010-11/(38)/3706, Dated 04.08.2010 (Original LOA)

2. SEZ/SERENE-THANE/20/LOA-20/2010-11/(38)/3706/142, Dated 06.01.2016 (Renewal)

3. SEEPZ/NEWSEZ/SERENE-THANE/02/2011-12/(VOL-II)/08523, Dated 07.06.2021 (Renewal)

Validity of LOA 05.01.2026 Item(s) of manufacture/ Services Information Technology and Information Technology Enabled Services Date of commencement of production 06.01.2011 Execution of BLUT Yes
Pending CRA Objection, if any Yes (OBS No.- 1877685, 1871029, 1886945, 1892587). The unit has stated that they have provided replies to the Specified Officer, Mindspace w.r.t. all the audit observations addressed to their name. Pending Show Cause Notice/ Eviction Order/Recovery Notice/ Recovery Order issued, if any This office had issued a Show Cause Notice dated 22.05.2023 to the unit. The unit had submitted their reply on 12.04.2024. However, no further communication in this regard is seen in the file.

No.

This office had issued a Show Cause Notice dated 22.05.2023 to the unit. The unit had submitted their reply on 12.04.2024. However, no further communication in this regard is seen in the file.

No. of employees: As below Year Projected Men Projected Women Men Women Total Average % 2020-21 7,421 3,180 7,400 6,640 14,040 132.44% 2021-22 8,179 8,084 16,263 153.41% 2022-23 7,845 8,182 16,027 151.18% 2023-24 4,590 4,835 9,425 88.91% Area allotted (in sq. ft.) 1,86,839 Sq. Ft.

(Area Sq. Ft./No. of Employees) Area available for each employee per sq. ft. basis (area / no. of employees)

2020-21 2021-22 2022-23 2023-24 13.31 11.49 11.66 19.82 Investment till date (Rs. In Crores)

Building 102.30

Plant & Machinery 127.42 TOTAL 229.72 Per Sq. ft. Export during FY

(APR export/per sq. ft*Crores) 2020-21 2021-22 2022-23 2023-24 90,077.55 1,22,297.81 1,45,515.66 1,32,911.22

Quantity and value of goods exported under Rule 34 (unutilized goods) N.A. Value Addition during the monitoring period N.A. Whether all the APRs being considered now have been filed well within the time limit, or otherwise.

If no, details of the Year along with no of days delayed being given.

YES (E) Reconciliation of Export & Import data. a. EXPORT
(Rs.

ES (E) Reconciliation of Export & Import data. a. EXPORT
(Rs. in Crores) Year/Period Figures reported in APR (FOB Value) Figures as per SOFTEX Data Difference if any Reason for Difference/Remark

2020 – 21 1,683.00 1,657.00 26.00 Due to Exchange rate variation

Due to unbilled revenue (Rs. 4.67 crores)

2021 – 22 2,285.20 2,264.80 20.40 Due to Exchange rate variation

Due to unbilled revenue (Rs. 21.55 crores)

2022 – 23 2,718.90 2,708.40 10.50 Due to Exchange rate variation

Due to unbilled revenue (Rs. 0.93 crores)

2023 – 24 2,483.30 2,453.80 29.50 Due to Exchange rate variation

Due to unbilled revenue (Rs. 11.38 crores)

b. IMPORT (RM including procurement done on IUT (from SEZ) basis .
(Rs. In Crores)
Year/ Period Figures as per APR Figures as per Trade Data (NSDL) Difference if any Reasons for difference 2020 – 21 0.00 0.00

2021 – 22 0.00 0.00

2022 – 23 0.00 0.00

2023 – 24 0.00 0.00

c. IMPORT (Capital Goods including procurement done on IUT (from SEZ) basis . (Rs. In Crores) Year/Period Figures as per APR Figures as per Trade Data Difference if any Reasons for difference 2020 – 21 25.19

24.06 (1.13) Unit has inadvertently cancelled 1 BOE of INR 0.04 Crores CIF Value in APR.

Due to Exchange rate variation.

per Trade Data Difference if any Reasons for difference 2020 – 21 25.19

24.06 (1.13) Unit has inadvertently cancelled 1 BOE of INR 0.04 Crores CIF Value in APR.

Due to Exchange rate variation.

2021 – 22 6.9

7.11 0.21 Unit has inadvertently considered less values in 7 BOEs in APR amounting to Rs. 0.21 Crores. 2022 – 23 12.23

11.89 (0.34) Unit has inadvertently considered more value in 1 BOE in APR amounting to Rs. 0.34 Crores. 2023 – 24 9.12

9.22 0.10 Unit has inadvertently considered less value in 1 BOE in APR amounting to Rs. 0.10 Crores.

(D) Bond cum Legal Undertaking (BLUT)
1 Value of BLUT Executed (Duty foregone) (including CG / Raw Material / Services)

Value of Additional BLUT executed Year - BLUT Amount-

Value of Additional BLUT executed Year -

BLUT Amount-

Total Value of BLUT executed in Crores:

BLUT accepted vide F. No. SEEPZ-SEZ/NEWSEZ/SERENE0THANE/02/2011-12/VOL- VI/18064 dated 01.11.2021

Rs. 259.99 Crores

BLUT accepted vide F. No. SEEPZ-SEZ/NEWSEZ/SERENE0THANE/02/2011-12/VOL- VI/15062 dated 16.11.2023

Rs. 20.09 Crores

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.

FY Goods (imported and indigenous) Rs. in Crores Services (Rs. in Crores) 2020-21 14.38 8.07 2021-22 14.55 0.09 2022-23 6.61 0.18 2023-24 2.95 0.58 Total 38.49 8.92

each category of procurement.

FY Goods (imported and indigenous) Rs. in Crores Services (Rs. in Crores) 2020-21 14.38 8.07 2021-22 14.55 0.09 2022-23 6.61 0.18 2023-24 2.95 0.58 Total 38.49 8.92

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 4 Employment made as on date (As on end of block period / year up to which monitoring is being done) (March 2024) Gender As per LOA (Form F) As on 31.03.2024 Men 7,421 4,590 Women 3,180 4,835 Total 10,601 9,425

E Details of pending Foreign Remittance beyond Permissible period, if any To cross-check the same and verify whether necessary permission from AD Bank / RBI has been obtained. NO * Details of pending Foreign Remittance beyond permissible period, if any (As on 31st October 2025)

To cross-check the same and verify whether necessary permission from AD Bank/RBI has been obtained. NO F (a) Whether all SOFTEX has been filed for the said period. If not, 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, the unit declared that it has filed all the SOFTEX forms up to March 2024. (b) Whether all SOFTEX has been certified, if so till which month has the same been certified.

led such pending SOFTEX. YES, the unit declared that it has filed all the SOFTEX forms up to March 2024. (b) 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, the unit declared that it has filed all the SOFTEX forms up to March 2024. (c) Whether unit has filed any request for Cancellation of SOFTEX? NO G 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) YES FY INR (in crores) 2020-21 53.32 2021-22 92.83 2022-23 171.22 2023-24 191.14 H SO to verify and certify whether the unit has updated the BLUT ledger module in SEZ Online. YES I 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. FY Scrap INR (in crores) 2020-21 0.00 2021-22 4.46

oods procured duty free in DTA against payment of duty, or otherwise?

Full Details to be provided along with value of assets and duty discharged. FY Scrap INR (in crores) 2020-21 0.00 2021-22 4.46

2022-23 0.00 2023-24 3.08 J Is the unit sharing any of their infrastructures with other units or are utilizing infrastructure of another unit in the same or other SEZ. If so, details thereof, including the details of the unit with whom the sharing is being made, and the payment terms If approval for sharing of common infrastructure has been obtained from UAC / DC office, the date of UAC / Approval letter to be indicated NO K 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 L 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 M Details of the request IDs pending for OOC in respect of DTA procurement on the date of submission of monitoring report NIL N 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-free 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

YES

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

YES

Unit has declared that it has not availed any duty exempted goods/services for setting up such facility.

NA P Whether any violation of any of the provisions of law has been noticed / observed by the Specified Officer during the period under monitoring NO

Findings

This is 4 years’ performance scrutiny (2020-21) of the 2 nd Block & 2021-22 to 2023-24 of the 3 rd block periods. (Block period calculated from FY 2011-12 as their DCP is 06.01.2011) 2. i. The unit has achieved export revenue of Rs. 1,683.00/- Crores as against projected export of Rs. 453.00/- i.e. 371.52% during the period FY 2020- 21.

ii. The unit has achieved export revenue of Rs. 2,285.20/- Crores as against projected export of Rs. 1,109.04/- i.e. 206.05% during the period for FY 2021-22.

iii. The unit has achieved export revenue of Rs. 2,718.90/- Crores as against projected export of Rs. 1,109.04/- i.e. 245.16% during the period FY 2022-23.

iv. The unit has achieved export revenue of Rs. 2,483.30/- Crores as against projected export of Rs. 1,109.04/- i.e. 223.91% during the period FY 2023-24.

.e. 245.16% during the period FY 2022-23.

iv. The unit has achieved export revenue of Rs. 2,483.30/- Crores as against projected export of Rs. 1,109.04/- i.e. 223.91% during the period FY 2023-24.

Cumulative Net Foreign Exchange Rs. 7,166.20/- Crores is positive for FY 2020-21.

Cumulative Net Foreign Exchange Rs. 2,251.39/- Crores is positive for FY 2021-22.

Cumulative Net Foreign Exchange Rs. 4,888.08/- Crores is positive for FY 2022-23.

Cumulative Net Foreign Exchange Rs. 7,306.94/- Crores is positive for FY 2023-24.

The values mentioned in the APRs w.r.t. the import of Capital Goods (10 years including this yr) (4(B)(i)) for the FYs 2022-23 to 2025-26 (part) are incorrect. 5. There are 4 CRA Objections viz. OBS No.- (1877685, 1871029, 1886945, 1892587) raised against the unit. The unit has stated that replies to all of them have been submitted to the Specified Officer, Mindspace-SEZ.

An SCN dated 22.05.2023 was issued to the unit. The unit had submitted their reply dated 12.04.2024.

ated that replies to all of them have been submitted to the Specified Officer, Mindspace-SEZ.

An SCN dated 22.05.2023 was issued to the unit. The unit had submitted their reply dated 12.04.2024. However, no further action taken is seen in the records. 7. APRs for the FY 2020-21 to 2023-24 have been submitted and filed within the prescribed time. 8. All SOFTEXs have been filed and certified. 9. All DSPFs have been certified. 10. The discrepancy observed between the export value recorded by Customs authorities and the value declared in the Annual Performance Report (APR) arises from certain unbilled amounts indicated by the unit in the covering letters submitted along with the hard copies of the APR to this office. Subsequently, the unit has confirmed that these amounts represent expenditure incurred towards partial completion of certain projects undertaken by them. The said amounts are included in the export value only upon full completion of the respective projects and consequent billing thereof. 11. The calculation of the Block Period in the Annual Performance Reports (APRs) submitted by the unit is incorrect. As a result, the cumulative Net Foreign Exchange Earnings (NFE) figures reflected therein are inaccurate and show variations. 12. The unit has applied for renewal of the Letter of Approval (LOA) for a further block period of five years. The performance of the unit up to Financial Year 2023-24 has been examined and detailed in this Final Scrutiny Report. Monitoring of performance for Financial Year 2024-25 is yet to be completed and remains pending.

e.

unit up to Financial Year 2023-24 has been examined and detailed in this Final Scrutiny Report. Monitoring of performance for Financial Year 2024-25 is yet to be completed and remains pending.

e. Recommendation: The proposal of the Unit is based on the Final Scrutiny Report in terms of Rule 54 of SEZ Rules, 2006 is submitted to the Approval Committee for consideration.

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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 : Monitoring performance of the unit in terms of Rule 54 of SEZ Rules, 2006. b. Specific Issue on which decision of AC is required: -
Monitoring performance of the unit as specified in FSR. c. Relevant provisions of SEZ Act, 2005 & Rules, 2006/Instruction/
Notification :- In terms of 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: -

FINAL SCRUTINY REPORT /2025 Name of the Unit: - M /s. Course5 Intelligence Ltd. (LOA-49) Address: - Unit No. 02, 8 th Floor, Building No. 03, Mindspace Business Parks Pvt. Ltd.-SEZ, Thane Belapur Road, Airoli, Navi Mumbai-400708 Block period: - 2020-21 to 2024-25 (2nd Block) & (2025-26 to 2029-30) (3 rd Block) Financial Year: - 2024-25 (last year of 2nd Block) & 2025-26 (part) (1 st Year of the 3rd Block) Details of Previous Monitoring: - I.

020-21 to 2024-25 (2nd Block) & (2025-26 to 2029-30) (3 rd Block) Financial Year: - 2024-25 (last year of 2nd Block) & 2025-26 (part) (1 st Year of the 3rd Block) Details of Previous Monitoring: - I. Previous UAC observation The monitoring performance of the unit for the years 2015-16 to 2018-19 and 2019-20 to 2023-24 had been monitored in the Approval Committee meeting held on 28.09.2020 and 30.01.2025 respectively. Accordingly, it was concluded that the unit had achieved positive NFE of Rs. 5,058.25 Lakhs (with amortization) on cumulative basis for the period of 4 years i.e. 2015-16 to 2018-19, Rs. 6,679.29/- Lakhs on cumulative basis for the FY 2019-20 & Rs. 6,546.64 Lakhs on cumulative basis for the FYs 2020-21 to 2023-24. (A): Observation on APR: i. APPROVED Projections for the 2nd Block- (Rs. In Crores)

1st year 2nd year 3rd year 4th year 5th year Total FOB value of export 13.64 16.85 17.70 18.58 19.51 86.28 FE Outgo 0.25 0.25 0.25 0.25 0.25 1.25 NFE 13.39 16.60 17.45 18.33 19.26 85.03

ii. APPROVED Projections for the 3 rd Block- (Rs. In Crores)

1st year 2nd year 3rd year 4th year 5th year Total FOB value of export 26.18 20.50 21.00 21.00 21.50 110.18 FE Outgo 0.07 0.13 0.14 0.15 0.30 0.79

1st year 2nd year 3rd year 4th year 5th year Total FOB value of export 26.18 20.50 21.00 21.00 21.50 110.18 FE Outgo 0.07 0.13 0.14 0.15 0.30 0.79

Year Export F.E. OUTGO

Projected

Actual (As per APR) Raw Material (Goods/Services) C.G. import Other outflow Projected Actual (As per APR) As per NSDL Data Projected (CG Import + Other outflow) Actual (As per APR) As per NSDL Data Actual (As per APR) 2024-25 19.51 19.33

0.25 0.00 0.00 0.00 2025-26 (part) 26.18 9.34

0.07 0.00 0.00 0.00 Total 45.69 28.67

0.32 0.00 0.00 0.00 Year Cumulative Projections NFE Cumulative NFE Achieved As per APR (Column 9) Cumulative % NFE Achieved 2024-25 85.03 84.73 99.65 % 2025-26 (part) 26.11 9.27 35.50 % NFE 26.11 20.37 20.86 20.85 21.20 109.39

II. Performance as compared to projections for the period 2024-25 and 2025-26 (part). (Rs. In Crores)

(III) Cumulative NFE achieved during 2024-25 and 2025-26 (part) . (A) Cumulative NFE achieved as per APR (Rs. In Crores)

(ii) Capital Goods Amortized Values table: -

Year CG Imp. 4B(v) Amortized Value

2017-2018 0.05 0.01

2018-2019 0.01 0.00

2019-2020 0.05 0.01

2020-2021 -0.73 -0.07

2021-2022 0.65 0.07

2022-2023 0.00 0.00

2023-2024 0.00 0.00

2024-2025 0.00 0.00

2025-2026 (part) 0.00 0.00

2018-2019 0.01 0.00

2019-2020 0.05 0.01

2020-2021 -0.73 -0.07

2021-2022 0.65 0.07

2022-2023 0.00 0.00

2023-2024 0.00 0.00

2024-2025 0.00 0.00

2025-2026 (part) 0.00 0.00

Total 0.03 0.02

(IV) Whether the Unit achieved Positive NFE : Yes (D) Other Information: LOA No. & Date SEEPZ/NEW-SEZ/SERENE-THANE/49/2014-15/13423 dated 12.11.2014 (Original LOA)

SEEPZ/NEW-SEZ/SERENE-THANE/49/2014-15/VOL-I/16443 dated 24.12.2020 (Renewed LOA)

SEEPZ/NEW-SEZ/SERENE-THANE/49/2014-15/VOL-I/02944 dated 03.03.2025 (Renewed LOA) Validity of LOA 14.12.2029 Item(s) of manufacture/ Services Information Technology Enabled Services, Market Research, Analytics Date of commencement of production 31.07.2015 Execution of BLUT YES Pending CRA Objection, if any NO Pending Show Cause Notice/ Eviction Order/Recovery Notice/ Recovery Order issued, if any NO No. of employees: As below Year Projected Men Projected Women Men Women Total Average % 2024-25 100 50 57 25 82 54.67 2025-26 (part) 57 25 82 54.67 Area allotted (in sq. ft.) 11,308 Sq ft

(Area Sq. Ft./No. of Employees) Area available for each employee per sq. ft. basis (area / no. of employees)

2024-25 2025-26 (part) 137.90 137.90 Investment till date (Rs. In Crores)

Building

Plant & Machinery 64.91 TOTAL 64.91 Per Sq. ft. Export during the FYs

(APR export/per sq.

o. of employees)

2024-25 2025-26 (part) 137.90 137.90 Investment till date (Rs. In Crores)

Building

Plant & Machinery 64.91 TOTAL 64.91 Per Sq. ft. Export during the FYs

(APR export/per sq. ft*Crores) 2024-25 2025-26 (part) 17,094.09 8,259.64 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 have been filed well within the time limit, or otherwise.

If no, details of the Year along with no of days delayed being given. YES

(E) Reconciliation of Export & Import data. a. EXPORT

(Rs. In Crores) Year/Period Figures reported in APR (FOB Value) Figures as per SOFTEX Data/SB/Customs Records Difference if any Reason for Difference/Remark

2024-25 19.33 20.04 0.71 Due to Exchange Rate Variation

2025-26 (part) 9.34 9.39 0.05

b. IMPORT (RM):
(Rs. In Crores) Year/ Period Figures as per APR Figures as per Trade Data (NSDL) Difference if any Reasons for difference 2024-25 0.00 0.00

2025-26 (part) 0.00 0.00

c. IMPORT (Capital Goods including procurement done on IUT (from SEZ) basis .
(Rs.

Difference if any Reasons for difference 2024-25 0.00 0.00

2025-26 (part) 0.00 0.00

c. IMPORT (Capital Goods including procurement done on IUT (from SEZ) basis .
(Rs. In Crores) Year/Period Figures as per Annexure (Amortized Value) Figures as per Trade Data Difference if any Reasons for difference 2024-25 0.00 0.00

2025-26 (part) 0.00 0.00

(D) Bond cum Legal Undertaking (BLUT)
1 Value of BLUT Executed (Duty foregone) (including CG / Raw Material / Services)

Value of Additional BLUT executed Year - BLUT Amount-

Value of Additional BLUT executed Year -

BLUT Amount-

Total Value of BLUT executed in Crores:

Rs. 10.46 Crores

NIL

2025-26

BLUT accepted vide F. No. SEEPZ-SEZ/NEW-SEZ/SERENE-THANE/49/2014-15/VOL- I/45131 dated 18.06.2025 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.

FY Goods (imported and indigenous) Rs. in Crores Services (Rs. in Crores)

ased on BLUT worksheet which provides for estimated value and duty foregone separately for each category of procurement.

FY Goods (imported and indigenous) Rs. in Crores Services (Rs. in Crores)

2024-25 1.05 376.53 2025-26 (part) 1.53 46.97 Total 2.58 423.47 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 4 Employment made as on date (As on end of block period / year up to which monitoring is being done) (March 2024) Gender As per LOA (Form F) As on 31.03.2024 Men 100 57 Women 50 25 Total 150 81

E Details of pending Foreign Remittance beyond Permissible period, if any To cross-check the same and verify whether necessary permission from AD Bank / RBI has been obtained. NO * Details of pending Foreign Remittance beyond permissible period, if any (As on 31st October 2025)

To cross-check the same and verify whether necessary permission from AD Bank/RBI has been obtained. NO F (a) Whether all SOFTEX has been filed for the said period.

if any (As on 31st October 2025)

To cross-check the same and verify whether necessary permission from AD Bank/RBI has been obtained. NO F (a) Whether all SOFTEX has been filed for the said period. If not, 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, the unit declared that it has filed all the SOFTEX forms up to 31 st October 2025.

1 SOFTEX request ID is in process of condonation, unit has been directed to submit relevant documents for condonation & for further certification in SEZ-NSDL.

(b) 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, All SOFTEX Forms have been certified up to Oct 2025 except 1 which is pending for condonation (c) Whether unit has filed any request for Cancellation of SOFTEX? NO, as declared by the unit. G 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, as declared by the unit. H SO to verify and certify whether the unit has updated the BLUT ledger module in SEZ Online. Yes

the period. If yes, details thereof (year wise details to be provided) NO, as declared by the unit. H SO to verify and certify whether the unit has updated the BLUT ledger module in SEZ Online. Yes

I 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. FY Year Amount (in Lakhs) Duty Discharged (in Lakhs) 2024-25 0.38 0.12 2025-26 (part) 0.94 0.31 J Is the unit sharing any of their infrastructures with other units or are utilizing infrastructure of another unit in the same or other SEZ. If so, details thereof, including the details of the unit with whom the sharing is being made, and the payment terms If approval for sharing of common infrastructure has been obtained from UAC / DC office, the date of UAC / Approval letter to be indicated NO, as declared by the unit. K 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, the unit has submitted all the DSPF for the said period and the same has been certified in SEZ-NSDL Online. L Whether unit has filed all DTA procurement w.r.t.

sed for approval by the SO Office. Yes, the unit has submitted all the DSPF for the said period and the same has been certified in SEZ-NSDL Online. L 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, as declared by the unit. M Details of the request IDs pending for OOC in respect of DTA procurement on the date of submission of monitoring report NIL N 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 free 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 P Whether any violation of any of the provisions of law has been noticed / observed by the Specified Officer during the period under monitoring NO

Findings 1. This is 2 years’ performance scrutiny (2024-25) of the 2 nd Block & 2025-26 (part) of the 3 rd block period. (Block period calculated from FY 2015-16 as their DCP is 31.07.2015) 2. i. The unit has achieved export revenue of Rs. 19.33/- Crores as against projected export of Rs. 19.51/- i.e. 99.08% during the period for FY 2024-25 ii. The unit has achieved export revenue of Rs. 9.34/- Crores as against projected export of Rs. 26.18/- i.e. 35.68% during the period FY 2020-21 3. Cumulative Net Foreign Exchange Rs.

for FY 2024-25 ii. The unit has achieved export revenue of Rs. 9.34/- Crores as against projected export of Rs. 26.18/- i.e. 35.68% during the period FY 2020-21 3. Cumulative Net Foreign Exchange Rs. 84.73/- Crores is positive for FY 2024-25. Cumulative Net Foreign Exchange Rs. 9.27/- Crores is positive for FY 2025-26 (part). 4. The values indicated in the Annual Performance Report (APR) in respect of imports of capital goods for the 10-year period (including the reference year) are incorrect for all financial years subsequent to FY 2023-24. 5. There is no CRA Objection pending to be investigated.

There is no SCN pending. 7. APRs for the FY 2024-25 and 2025-26 (part) have been submitted and filed within the prescribed time. 8. All SOFTEXs have been certified except 1 which is under process for condonation. 9. All DSPFs have been certified. 10. The unit has applied for EXIT from SEZ Scheme.

e. Recommendation: The proposal of the Unit is based on the Final Scrutiny Report in terms of Rule 54 of SEZ Rules, 2006 is submitted to the Approval Committee for consideration.

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l of the Unit is based on the Final Scrutiny Report in terms of Rule 54 of SEZ Rules, 2006 is submitted to the Approval Committee for consideration.

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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 : Request for List of Goods for transfer of ownership of fit-outs by unit to developer on account of decrease in office space of M/s. Mindspace Business Parks Pvt. Ltd (Developer) as Plot No. 03, Kalwa TTC MIDC Industrial Area, MIDC, Airoli (E), Navi Mumbai, Maharashtra. b. Specific Issue on which decision of AC is required: -
Approval for List of Goods for transfer of ownership of fit-outs by unit to developer on account of decrease in office space of M/s. Mindspace Business Parks Pvt. Ltd as Plot No. 03, Kalwa TTC MIDC Industrial Area, MIDC, Airoli (E), Navi Mumbai, Maharashtra. c. Relevant provisions of SEZ Act, 2005 & Rules, 2006/Instruction/
Notification :- Instruction No. 50 dated 15.03.2010 issued by MOC&I. and Rule 38 of SEZ rules, 2006 d. Other Information: - M/s. Mindspace Business Parks Private Limited has been granted Formal Approval No. F.2/94/2005-EPZ dated 23.10.2006.

   The Co-Developer vide letter dated 03.11.2025 has submitted the List of Goods for transfer of ownership of fit-

outs by unit to developer on account of decrease in office space. The Assessable Value of Rs.

Developer vide letter dated 03.11.2025 has submitted the List of Goods for transfer of ownership of fit- outs by unit to developer on account of decrease in office space. The Assessable Value of Rs. 18,18,47,166.39/- and Duty Foregone of Rs. 2,67,95,077.24/- the same has been certified by Chartered Engineer Certificate vide his certificate dated 30.09.2025. The Specified Officer, Mindspace Business Parks Private Limited vide letter dated 20.11.2025 has stated that the approval for transfer of ownership of the assets as per Annexure I & II originally procured by M/s. Wipro Limited to the SEZ Developer under Bond-to Bond Transfer. The approval of aforesaid material appears to be just and proper. A Copy of letter dated 03.11.2025 is enclosed. e. Recommendation: The proposal for List of Goods for transfer of ownership of fit-outs by unit to developer on account of decrease in office space of M/s. Mindspace Business Parks Pvt. Ltd in terms of instruction No. 50, dated 15.03.2010 is placed before the Approval Committee for consideration.

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f M/s. Mindspace Business Parks Pvt. Ltd in terms of instruction No. 50, dated 15.03.2010 is placed before the Approval Committee for consideration.

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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 : Monitoring performance of the M/s. WNS Global Services Private Limited unit in terms of Rule 54 of SEZ Rules, 2006. b. Specific Issue on which decision of AC is required: -
Monitoring performance of the unit as specified in FSR. c. Relevant provisions of SEZ Act, 2005 & Rules, 2006/Instruction/
Notification :- In terms of 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: -

FINAL SCRUTINY REPORT/2025 Name of the Unit: - M/s. WNS Global Services Private Limited Address: - 1st and 2nd Floor, Building No. 14, M /s. Mindspace Business Parks Private Limited-SEZ, Thane- Belapur Road, Airoli, Navi Mumbai-400708 Financial Year: - 2020-21 (5th year of the 2nd block) & 2021-22 to 2025-26 (part) (existing block)

(A): Observation on APR i. APPROVED Projections for the 2nd Block (previous block)-
(Rs.

the 2nd block) & 2021-22 to 2025-26 (part) (existing block)

(A): Observation on APR i. APPROVED Projections for the 2nd Block (previous block)-
(Rs. In Crores)
PARTICULARS 1st Year 2nd Year 3rd Year 4th Year 5th Year TOTAL FOB Value of Exports 36.52 40.17 44.19 48.61 53.47 222.96 FOB Outgo 5.60 6.16 6.78 7.45 8.20 34.19 Net Foreign Exchange 30.92 34.01 37.41 41.16 45.27 188.77

ii. APPROVED Projections for the 3rd Block (existing block)-
(Rs. In Crores)

Year Export F.E. OUTGO

Projected

Actual (As per APR) Raw Material (Goods/Services) C.G. import Other outflow Projected Actual (As per APR) As per NSDL Data Projected (CG Import

• Other outflow) Actual (As per APR) As per NSDL Data Actual (As per APR) 2020- 21 53.47 110.78

8.20 0.00 0.00 0.00 2021- 22 110.00 133.46

2.21 1.01 1.01 0.02 2022- 23 112.20 152.26

2.23 1.31 1.31 0.14 2023- 24 114.44 106.99

2.26 1.71 1.71 0.36 2024- 25 116.73 89.05

2.28 0.03 0.03 0.35 2025- 26 (part) 119.07 13.78

2.31 0.00 0.00 0.00 Total 625.91 606.32

19.49 4.06 4.06 0.87 Year Cumulative Projections NFE Cumulative NFE Achieved As per APR (Column 9) Cumulative % NFE Achieved 2020-21 188.77 494.21 261.81% 2021-22 107.79 132.75 123.16% 2022-23 217.76 284.09 130.46% 2023-24 329.94 389.79 118.14% 2024-25 444.39 477.60 107.47% 2025-26 (part) 516.15 490.64 95.06% PARTICULARS 1st Year 2nd Year 3rd Year 4th Year 5th Year TOTAL FOB Value of Exports 110.00 112.20 114.44 116.73 119.07 572.44 FOB Outgo 2.21 2.23

39 477.60 107.47% 2025-26 (part) 516.15 490.64 95.06% PARTICULARS 1st Year 2nd Year 3rd Year 4th Year 5th Year TOTAL FOB Value of Exports 110.00 112.20 114.44 116.73 119.07 572.44 FOB Outgo 2.21 2.23 2.26 2.28 2.31 11.29 Net Foreign Exchange 107.79 109.97 112.18 114.45 116.76 561.15 (I) Performance as compared to projections for the period FY 2020-21 to FY 2025-26 (part):

(Rs. In Crores)

(II) Cumulative NFE achieved during the block period/s. (2020-21 to 2025-2026 (part)).

(A) Cumulative NFE achieved as per APR (Rs. in Crores)

Capital Goods Amortized Values table: - (In Crores) Year CG Imp. 4B(v) Amortized Value

2016-17 0.2 0.02

2017-18 1.69 0.17

2018-19 2.20 0.22

2019-20 0.13 0.01

2020-21 0.00 0.00

2021-22 0.51 0.05

2022-23 1.42 0.14

2023-24 2.30 0.23

2024-25 0.19 0.02

2025-26 (part) -0.31 -0.03

Total 8.33 0.83

(III) Whether the Unit achieved Positive NFE : YES (B) Other Information: LOA No. & Date SEZ/SERENE/(04)/LOA-04/2009-10/(19)/3531 dated 19.05.2009 (Original LOA) Validity of LOA 20.05.2026 Item(s) of manufacture/ Services Information Technology and Information Technology Enabled Services (BPO and Call Centre Services) Date of commencement of production 21.05.2011 Execution of BLUT YES Pending CRA Objection, if any NIL Pending Show Cause Notice/ Eviction Order/Recovery Notice/ Recovery Order issued, if any NIL No.

ate of commencement of production 21.05.2011 Execution of BLUT YES Pending CRA Objection, if any NIL Pending Show Cause Notice/ Eviction Order/Recovery Notice/ Recovery Order issued, if any NIL No. of employees: As below (As per NSDL)

Year Projected Men Projected Women Men Women Total Average % 2020-21 590 293 590 293 883 100% 2021-22 848 451 1,299 147.11% 2022-23 832 439 1,271 143.94% 2023-24 517 264 781 88.45% 2024-25 433 240 673 76.22% 2025-26 (part) 117 55 172 19.48% Area allotted (in sq. ft.) 87,264 Sq. ft.

Area available for each employee per sq ft basis (area / no. of employees) 2020-21 2021-22 2022-23 2023-24 2024-25 2025-26 (part)

98.83 67.18 68.66 111.73 129.66 507.35 Investment till date (Rs. In Crores) Building 0

Plant & Machinery 837.81 TOTAL 837.81 Per Sq. ft. Export during FY

(APR export/per sq. ft*Crores) 2020-21 2021-22 2022-23 2023-24 2024-25 2025-26 (part) 12,694.81 15,293.82 17,448.20 12,260.50 10,204.67 1,579.12 Quantity and value of goods exported under Rule 34 (unutilized goods) N.A. Value Addition during the monitoring period N.A. Whether all the APRs being considered now have been filed well within the time limit, or otherwise.

If no, details of the Year along with no of days delayed being given. YES

(C) Reconciliation of Export & Import data. a. EXPORT
(Rs.

(C) Reconciliation of Export & Import data. a. EXPORT
(Rs. in Crores) Year/Period Figures reported in APR (FOB Value) Figures as per SOFTEX Data Difference if any Reason for Difference/Remark

2020-21 110.78 110.78 0.00 NA

2021-22 133.46 133.46 0.00 NA

2022-23 152.26 153.15 0.89 Invoices worth 11.07 cr for which SOFTEX were not filed are filed now. They have considered book value of invoices for filing revised APRs, Exchange Rate per USD is considered as 81.82

2023-24 106.99 107 0.00 Invoices worth 11.8 cr for which SOFTEX were not filed are filed now. They have considered book value of invoices for filing revised APRs, Exchange Rate per USD is considered as 83.39

2024-25 89.05 89.05 0.00 NA

2025-26 (part) 13.78 15.03 1.25 NA

b. IMPORT (RM).

(Rs. In Crores)
Year/ Period Figures as per APR Figures as per Trade Data (NSDL) Difference if any Reasons for difference 2020-21 0.00 0.00

2021-22 0.00 0.00

2022-23 0.00 0.00

2023-24 0.00 0.00

2024-25 0.00 0.00

2025-26 (part) 0.00 0.00

c. IMPORT (Capital Goods including procurement done on IUT (from SEZ) basis .
(Rs.

-23 0.00 0.00

2023-24 0.00 0.00

2024-25 0.00 0.00

2025-26 (part) 0.00 0.00

c. IMPORT (Capital Goods including procurement done on IUT (from SEZ) basis .
(Rs. In Crores)
Year/Period Figures as per APR Figures as per Trade Data Difference if any Reasons for difference 2020-21 0.00 0.00 0.00 NA 2021-22 1.01 1.01 0.00 2022-23 1.31 1.31 0.00 2023-24 1.71 1.71 0.00 2024-25 0.03 0.03 0.00 2025-26 (part) 0.00 0.00 0.00

(D) Bond cum Legal Undertaking (BLUT)

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

Value of Additional BLUT executed -Year 20-21 BLUT Amount- 102,17,18,582

Value of Additional BLUT executed -Year 20-21 BLUT Amount- 102,17,18,582

Total Value of BLUT executed in Crores:

June 2009

Rs. 5.005 Crores

June 2022 Rs. 3.13 Crores

Rs. 8.135 Crores 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.

FY Goods (imported and indigenous) Rs. in Crores Services (Rs. in Crores) 2020-21 0.00 2.03 2021-22 0.09 2.98 2022-23 0.24 3.88 2023-24 0.05 5.28 2024-25 0.11 5.90 2025-26 (part) 0.00 2.70 Total 0.49 22.77

s (imported and indigenous) Rs. in Crores Services (Rs. in Crores) 2020-21 0.00 2.03 2021-22 0.09 2.98 2022-23 0.24 3.88 2023-24 0.05 5.28 2024-25 0.11 5.90 2025-26 (part) 0.00 2.70 Total 0.49 22.77

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

Further, the unit stated that as per Circular No. K. 43013 (18)/2/2022-SEZ dated 15th February 2023, issued by the Ministry of Commerce, attention is drawn to Rule 22 (1) (iv) (b) of the SEZ Rules, 2006, which stipulates that no debit or credit shall be made in the BLUT. Accordingly, it is clarified that an additional BLUT is required only when the scale of operations increases from the initial level, and not as a routine requirement if the unit/developer continues operating at the same scale of activities. 4 Employment made as on date (As on end of block period / year up to which monitoring is being done) (March 2024) Gender As per LOA (Form F) As on Sept 2025 Men 590 117 Women 293 55 Total 883 172

E Details of pending Foreign Remittance beyond Permissible period, if any To cross-check the same and verify whether necessary permission from AD Bank / RBI has been obtained. NO (a) Details of pending Foreign Remittance beyond permissible period, if any (As on 31st October 2025)

To cross-check the same and verify whether necessary permission from AD Bank/RBI has been obtained. NA F (a)

f pending Foreign Remittance beyond permissible period, if any (As on 31st October 2025)

To cross-check the same and verify whether necessary permission from AD Bank/RBI has been obtained. NA F (a) Whether all SOFTEX has been filed for the said period. If not, 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, Unit had submitted that there were 19 nos. of SOFTEX forms they found that not timely submitted and accordingly, they have applied for condonation of SOFTEX to DC Office & SO Office vide their letter dated 30.10.2025 (list of SOFTEXs as per attached verification report received from SO) (b) 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, there are some SOFTEXs pending for condonation (list of SOFTEXs as per attached verification report received from SO) (c) Whether unit has filed any request for Cancellation of SOFTEX? NO

dency. No, there are some SOFTEXs pending for condonation (list of SOFTEXs as per attached verification report received from SO) (c) Whether unit has filed any request for Cancellation of SOFTEX? NO

G 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 H SO, to verify and certify whether the unit has updated the BLUT ledger module in SEZ Online. YES I 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. FY Amount paid Duty paid 2023-24 0.15 0.045 2024-25 0.10 0.032 Total 0.25 0.07 J Is the unit sharing any of their infrastructures with other units or are they 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 K 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 L Whether unit has filed all DTA procurement w.r.t.

nitoring period under consideration has been filed by the unit and whether the same has been processed for approval by the SO Office. YES L 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 M Details of the request IDs pending for OOC in respect of DTA procurement on the date of submission of monitoring report There are no requests are pending for Out of Charge

N 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-free 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

P Whether any violation of any of the provisions of law has been noticed / observed by the Specified Officer during the period under monitoring NO

Findings 1. This 6 year’s performance scrutiny, (2020-21) of the 2nd Block Period and (2021-22 to 2025- 26 (part)) the 3rd block period. 2. i. The unit has achieved export revenue of Rs. 110.78/- Crores as against projected export of Rs. 53.47/- Crores i.e. 207.18% during the period for FY 2020-21. ii. The unit has achieved export revenue of Rs. 133.46/- Crores as against projected export of Rs. 110.00/- Crores i.e. 121.33% during the period for FY 2021-22. iii. The unit has achieved export revenue of Rs.

t has achieved export revenue of Rs. 133.46/- Crores as against projected export of Rs. 110.00/- Crores i.e. 121.33% during the period for FY 2021-22. iii. The unit has achieved export revenue of Rs. 152.26/- Crores as against projected export of Rs. 112.20/- Crores i.e. 135.70% during the period for FY 2022-23. iv. The unit has achieved export revenue of Rs. 106.99/- Crores as against projected export of Rs. 114.44/- Crores i.e. 93.49% during the period for FY 2023-24. v. The unit has achieved export revenue of Rs. 89.05/- Crores as against projected export of Rs. 116.73/- Crores i.e. 76.29% during the period for FY 2024-25. vi. The unit has achieved export revenue of Rs. 13.78/- Crores as against projected export of Rs. 119.07/- Crores i.e. 11.57% during the period for FY 2025-26 (part). 3. Cumulative Net Foreign Exchange Rs. 494.21/- Crores is positive for FY 2020-21. Cumulative Net Foreign Exchange Rs. 132.75/- Crores is positive for FY 2021-22. Cumulative Net Foreign Exchange Rs. 284.09/- Crores is positive for FY 2022-23. Cumulative Net Foreign Exchange Rs. 389.79/- Crores is positive for FY 2023-24. Cumulative Net Foreign Exchange Rs. 477.60/- Crores is positive for FY 2024-25. Cumulative Net Foreign Exchange Rs. 490.64/- Crores is positive for FY 2025-26 (part). 4. There is no CRA Objection pending to be looked into. 5. There is no SCN pending. 6. All other APRs from FY 2020-21 to 2025-26 (part) have been submitted and filed within the prescribed time.

rt). 4. There is no CRA Objection pending to be looked into. 5. There is no SCN pending. 6. All other APRs from FY 2020-21 to 2025-26 (part) have been submitted and filed within the prescribed time.

All SOFTEXs except 19 (as per the list attached in the verification report pending for condonation) have been certified. 8. All DSPFs have been filed and endorsed.

e. Recommendation: The proposal of the Unit is based on the Final Scrutiny Report in terms of Rule 54 of SEZ Rules, 2006 is submitted to the Approval Committee for consideration.

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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 of M /s. Syntel Private Limited (LOA-19) for change in the list of Board of Directors. b. Specific Issue on which decision of AC is required: -
Approval for Change in list of Board of Directors of the Company. c. Relevant provisions of SEZ Act, 2005 & Rules, 2006/Instruction/
Notification :- MOC&I Instruction No. 109 of MOC&I dated 18.10.2021. MOC&I Instruction No. 109 dated 18.10.2021 states that: “ In suppression of Instruction No.

05 & Rules, 2006/Instruction/
Notification :- MOC&I Instruction No. 109 of MOC&I dated 18.10.2021. MOC&I Instruction No. 109 dated 18.10.2021 states that: “ In suppression of Instruction No. 89 dated 17.05.2018 of their Department on the subject cited above and in exercise of provisions of Section 10(10) of the SEZ Act, 2005, it is hereby conveyed that the guidelines for approval in the cases of reorganization including change of name, change of shareholding pattern, business transfer arrangements, court approved mergers and demergers, change of constitution, change of Directors, etc. of SEZ Developers/Co-Developers as well as SEZ unit shall be as follows. “ Re-organization including change of name, change of shareholding pattern, business transfer arrangement, court approved mergers and demergers, change of constitution, change of Directors etc. may be undertaken by Unit Approval Committee concerned subject to condition that the Developer/Co-Developer/Units 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 will remain unchanged on such re-organization.” d. Other Information: - 1. Name of the Unit M /s. Syntel Private Limited 2. Location of the Unit 6th, 9th, 10th (50%) and 11th Floor, Bldg No. 04, Mindspace Business Parks Private Limited-SEZ, Thane Belapur Road, Airoli, Navi Mumbai-400708 3. LOA No.

yntel Private Limited 2. Location of the Unit 6th, 9th, 10th (50%) and 11th Floor, Bldg No. 04, Mindspace Business Parks Private Limited-SEZ, Thane Belapur Road, Airoli, Navi Mumbai-400708 3. LOA No. & Date SEZ/SERENE-THANE/(19)/LOA-19/2010- 11/(37)/3703 dated 04.08.2010 (Original LOA) 4. Item of Manufacture/Service IT & IT Enabled Services 5. Date of Commencement 06.07.2011 6. Validity of LOA 05.07.2026

Details of the Directors of M /s. Syntel Private Limited: -

Existing List of Directors Sr. No. Name of the Person Designation DIN 1. RAKESH KHANNA Director 07669485 2. MINI SONY KOCHUPURAKAL Director 10837019

Proposed List of Directors and change in the composition of board Sr. No. Name of the Person Designation DIN 1. NEELUTHODI CHEERAKUZHI AJITH Director 11068248 2. NASIR USMAN SHAIKH Director 08771220

*There is change in the list of Directors.

The unit has submitted following documents/Information:

1. Duly certified copy of list of present and previous directors
2. Form No. DIR 12
3. Copy of Payment Challan to Ministry of Corporate Affairs for DIR 12
4. Undertaking signed by authorized signatory in terms of Instruction 109.
5. Shareholding pattern of Syntel Pvt. Ltd. pursuant to change in directors.
6. Board Resolution for Appointment of Mr. Neeluthodi Cheerakuzhi Ajith as an additional director.
7. Board Resolution for Appointment of Mr. Nasir Usman Shaikh as an additional director.
8. Board Resolution for Resignation of Mr. Rakesh Khanna as Director of the Company
9. Board Resolution for Resignation of Ms.

ion for Appointment of Mr. Nasir Usman Shaikh as an additional director. 8. Board Resolution for Resignation of Mr. Rakesh Khanna as Director of the Company 9. Board Resolution for Resignation of Ms. Mini Sony Kochupurakal as Director of the Company e. Recommendation: The proposal of M /s. Syntel Private Limited (LOA-19) is located at Mindspace Business Parks Private Limited – SEZ Airoli, Navi Mumbai for change in Composition of Board of Directors in terms of MoC&I Instruction No. 109 dated 18.10.2021 is submitted before the Approval Committee for consideration.

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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 of M /s. Syntel Private Limited for change in the list of Board of Directors. b. Specific Issue on which decision of AC is required: -
Approval for Change in list of Board of Directors of the Company. c. Relevant provisions of SEZ Act, 2005 & Rules, 2006/Instruction/
Notification :- MOC&I Instruction No. 109 of MOC&I dated 18.10.2021. MOC&I Instruction No. 109 dated 18.10.2021 states that: “ In suppression of Instruction No.

05 & Rules, 2006/Instruction/
Notification :- MOC&I Instruction No. 109 of MOC&I dated 18.10.2021. MOC&I Instruction No. 109 dated 18.10.2021 states that: “ In suppression of Instruction No. 89 dated 17.05.2018 of their Department on the subject cited above and in exercise of provisions of Section 10(10) of the SEZ Act, 2005, it is hereby conveyed that the guidelines for approval in the cases of reorganization including change of name, change of shareholding pattern, business transfer arrangements, court approved mergers and demergers, change of constitution, change of Directors, etc. of SEZ Developers/Co-Developers as well as SEZ unit shall be as follows. “ Re-organization including change of name, change of shareholding pattern, business transfer arrangement, court approved mergers and demergers, change of constitution, change of Directors etc. may be undertaken by Unit Approval Committee concerned subject to condition that the Developer/Co-Developer/Units 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 will remain unchanged on such re-organization.” d. Other Information: - 1. Name of the Unit M /s. Syntel Private Limited 2. Location of the Unit 10th (50%) Floor, Bldg No. 04, Mindspace Business Parks Private Limited-SEZ, Thane Belapur Road, Airoli, Navi Mumbai-400708 3. LOA No.

of the Unit M /s. Syntel Private Limited 2. Location of the Unit 10th (50%) Floor, Bldg No. 04, Mindspace Business Parks Private Limited-SEZ, Thane Belapur Road, Airoli, Navi Mumbai-400708 3. LOA No. & Date SEEPZ/NEWSEZ/GIGAPLEX-THANE/SPL/2020- 21/12063 dated 06.10.2020 (Original LOA) 4. Item of Manufacture/Service IT & IT Enabled Services 5. Date of Commencement 01.11.2020 6. Validity of LOA 31.10.2025

Details of the Directors of M /s. Syntel Private Limited: -

Existing List of Directors Sr. No. Name of the Person Designation DIN 1. RAKESH KHANNA Director 07669485 2. MINI SONY KOCHUPURAKAL Director 10837019

Proposed List of Directors and change in the composition of board Sr. No. Name of the Person Designation DIN 1. NEELUTHODI CHEERAKUZHI AJITH Director 11068248 2. NASIR USMAN SHAIKH Director 08771220

*There is change in the list of Directors.

The unit has submitted following documents/Information:

1. Duly certified copy of list of present and previous directors
2. Form No. DIR 12
3. Copy of Payment Challan to Ministry of Corporate Affairs for DIR 12
4. Undertaking signed by authorized signatory in terms of Instruction 109.
5. Shareholding pattern of Syntel Pvt. Ltd. pursuant to change in directors.
6. Board Resolution for Appointment of Mr. Neeluthodi Cheerakuzhi Ajith as an additional director.
7. Board Resolution for Appointment of Mr. Nasir Usman Shaikh as an additional director.
8. Board Resolution for Resignation of Mr. Rakesh Khanna as Director of the Company
9. Board Resolution for Resignation of Ms.

ion for Appointment of Mr. Nasir Usman Shaikh as an additional director. 8. Board Resolution for Resignation of Mr. Rakesh Khanna as Director of the Company 9. Board Resolution for Resignation of Ms. Mini Sony Kochupurakal as Director of the Company e. Recommendation: The Proposal of M /s. Syntel Private Limited is located at Mindspace Business Parks Private Limited – SEZ Airoli, Navi Mumbai for change in Composition of Board of Directors in terms of MoC&I Instruction No. 109 dated 18.10.2021 is submitted before the Approval Committee for consideration.

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