Subscription   Feedback   New User   Login      
Tax Management India .com
TMI - Tax Management India. Com
Articles Highlights TMI Notes SMS News Newsletters Calendar Imp. Links Database Experts Contact us More....
Extracts
Home List
← Previous Next →

McAfee Software (India) Pvt. Ltd. Versus Dy. Commissioner of Income Tax

2015 (5) TMI 390 - ITAT BANGALORE

Transfer pricing adjustment - selection of comparable - Held that:- Tata Elxsi Ltd. (seg), Sasken Communication Technologies Ltd.,Persistent Systems Ltd., Zylog Systems Ltd.,Mindtree Ltd. (seg), Larsen & Toubro Infotech & Infosys Ltd. be excluded from the list of comparable as having turnover of more than ₹ 200 Crores from the list of comparables since the assessee's turnover was less than ₹ 200 Crores.

Bodhtree Consulting Ltd to be excluded as functionally different.

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

24-4-2015 - Shri N.V. Vasudevan And hri Jason P. Boaz JJ. For the Appellant : Shri K.R. Vasudevan, Advocate. For the Respondent : Shri Ganesh Rao, CIT (D.R) ORDER Per Shri Jason P. Boaz, A.M. : This appeal by the assessee is directed against the order of the Commissioner of Income Tax (Appeals) - IV, Bangalore dt.28.5.2014 for Assessment Year 2009-10. 2. The facts of the case, briefly, are as under :- 2.1 The assessee-company is engaged in the business of providing software development services .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

e had entered into international transactions with its Associated Enterprises (AEs) in the year under consideration, made a reference to the Transfer Pricing Officer (TPO) on 24.10.2011, after obtaining the approval of the concerned CIT, for working out the Arm s Length Price ( ALP ) of these transactions. The TPO passed an order under Section 92CA of the Act dt.8.1.2013 in respect of international transactions entered into by the assessee with its AEs and proposed an adjustment of ₹ 18,55 .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

al before the CIT (Appeals), the Assessing Officer passed the final order of assessment under Section 143(3) rws 144C(3) rws 144C(4) of the Act vide order dt.22.4.2013, wherein the income of the assessee was determined at ₹ 22,02,79,262. In this order, the Assessing Officer made the following additions / disallowances to the returned income of ₹ 2,22,73,157 :- (i) T.P. Adjustment : ₹ 18,55,44,708. (ii) Disallowance of Excess claim of deduction u/s.10A : ₹ 1,24,61,397. 2.3 .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

nsfer Pricing Officer - II), Bangalore and the Hon'ble CIT (Appeals) have erred in law and facts of the case in proposing a transfer pricing adjustment under Section 92CA of the Income Tax Act, 1961 amounting to ₹ 12,03,07,763 in relation to the provision of software development services to the Associated Enterprises. 2. The ld. A.O., TPO and the Hon'ble CIT (Appeals) erred in disregarding the economic analysis performed by the appellant in the Transfer Pricing documentation justif .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

e time of assessment proceedings, instead of that available as on the date of preparing the TP documentation for comparable companies while determining arm s length price. 6. The ld. A.O., TPO and the Hon'ble CIT (Appeals) have erred in rejecting companies selected as comparable by the appellant in the TP documentation and have erred in selecting / introducing companies which are not comparable to the appellant on conducting a fresh comparability analysis and on introduction of additional fi .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

round that the working capital adjustment for these companies are substantial. 9. The ld. A.O., TPO and the Hon'ble CIT (Appeals) have erred in restricting the working capital adjustment to the average cost of capital of the comparable companies selected instead of allowing the correct working capital adjustment in determination of arm s length price. In connection with the above, the ld. A.O. has erroneously computed the total taxable income by incorrectly computing the transfer pricing rel .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

12. The Hon'ble CIT (Appeals) has erred in not adjudicating on the ground of exclusion of travelling expenses form the export turnover while computing the eligible deduction under Section 10A of the Act. TRANSFER PRICING ISSUES (Grounds 1 to 11) 4.1 Before proceeding to deal with the above grounds of appeal on T.P. issues, the approach of the TPO vis-a-vis that of the assessee in its T.P. Study submitted before the TPO is briefly summarised hereunder. 4.2 The assessee is engaged in the prov .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

Appropriate Method ( MAM ) and conducted its search for comparable companies using the Prowess and Capitaline data bases. On this basis, the assessee chose the following 13 companies as comparable to it. S.No. Name of the comparable company 1. Akshay Software Technologies Ltd. 2 Helios & Matherson Information 3 iGate Global Solutions Ltd. 4 Mindtree Ltd. 5 Netripples Software Ltd. 6 Prithvi Information Solutions Ltd. 7 R S Software (India) Ltd. 8 Sagarsoft (India) Ltd. 9 Servealll Enterprise .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

final set of 11 comparable companies and their operating margins, the details of which are as under :- Sl.No. Name of the comparable Margin % 1 Kals Information Systems Ltd. 13.89 2 Akshay Software Technologies Ltd. 8.11 3 Bodhtree ConsultingLtd. 62.27 4 R S Software (India) Ltd. 9.97 5 Tata Elxsi Ltd. (seg) 20.28 6 Sasken Communication Technologies Ltd. 27.91 7 Persistent Systems Ltd. 41.40 8 Zylog Systems Ltd. 7.81 9 Mindtree Ltd. (seg) 5.52 10 Larsen & Toubro Infotech 24.72 11 Infosys Ltd .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

rder dt.18.6.2013 whereby the T.P. Adjustment was reduced from ₹ 18,55,44,708 to ₹ 12,71,38,857. 6. The assessee has preferred this appeal against the order of the CIT (Appeals) - IV dt.28.5.2014 for Assessment Year 2009-10. At the time of hearing, the learned Authorised Representative submitted that though the grounds raised in respect of T.P. issues are from S.Nos.1 to 11, the grounds relating to the comparability of some of the comparable companies chosen by the TPO alone need to .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ded as the turnover of these companies in excess of ₹ 200 Crores and therefore cannot be compared with the assessee whose turnover is less than ₹ 200 Crores (viz. ₹ 196.67 Crores). S.No. Name of Company Turnover (Rs. in Crores) 1 Infosys Technologies Ltd. 20264.00 2 Larsen & Toubro Infotech Ltd. 1950.83 3 Mindtree Ltd. 793.22 4 Persistent Systems Ltd. 519.69 5 Sasken Communication Technologies Ltd. 405.31 6 Tata Elxsi Ltd. 378.43 7 Zylong Systems Ltd. 734.93 7.1.2 In suppor .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

/Bang/2014 dt.10.10.2014 for Assessment Year 2009-10. It is submitted that in the above decisions it was held that companies having turnover in excess of ₹ 200 Crores cannot be comparable with companies whose turnover is less than ₹ 200 Crores. The learned Authorised Representative submitted that in view of the above factual situation and judicial pronouncements, the seven companies listed above ought to be excluded from the list of comparables to the assessee. 7.2 Per contra, the le .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

he TPO s final list of comparables) should be excluded from the list of comparables as the turnover of these companies is more than ₹ 200 Crores while that of the assessee is that case was only ₹ 31.83 Crores. 7.3.2 The relevant portion of the order in the case of Airbus India Operations Pvt. Ltd. (supra) at paras 17 & 18 thereof is extracted hereunder :- 17. We have considered the rival submissions. The provisions of the Act and the Rules that are relevant for deciding the issue .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

on the profits, income, losses or assets of such enterprises, and shall include a mutual agreement or arrangement between two or more associated enterprises for the allocation or apportionment of, or any contribution to, any cost or expense incurred or to be incurred in connection with a benefit, service or facility provided or to be provided to any one or more of such enterprises. Sec.92-A defines what is an Associated Enterprise. In the present case there is no dispute that the transaction bet .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

performed by such persons or such other relevant factors as the Board may prescribe, namely :- (a) comparable uncontrolled price method; (b) resale price method; (c) cost plus method; (d) profit split method; (e) transactional net margin method; (f) such other method as may be prescribed by the Board. (2) The most appropriate method referred to in sub-section (1) shall be applied, for determination of arm s length price, in the manner as may be prescribed: Provided that where more than one price .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

eding for the assessment of income, the Assessing Officer is, on the basis of material or information or document in his possession, of the opinion that- (a) the price charged or paid in an international transaction has not been determined in accordance with sub-sections (1) and (2); or (b) any information and document relating to an international transaction have not been kept and maintained by the assessee in accordance with the provisions contained in sub-section (1) of section 92D and the ru .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

uch material or information or document available with him: 18. Rule 10B of the IT Rules, 1962 prescribes rules for Determination of arm s length price under section 92C:- 10B. (1) For the purposes of sub-section (2) of section 92C, the arm s length price in relation to an international transaction shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely :- (a) ……. to (d) …….. (e) transactional net margin .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

e same base; (iii) the net profit margin referred to in sub-clause (ii) arising in comparable uncontrolled transactions is adjusted to take into account the differences, if any, between the international transaction and the comparable uncontrolled transactions, or between the enterprises entering into such transactions, which could materially affect the amount of net profit margin in the open market; (iv) the net profit margin realised by the enterprise and referred to in sub-clause (i) is estab .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

r transaction; (b) the functions performed, taking into account assets employed or to be employed and the risks assumed, by the respective parties to the transactions; (c) the contractual terms (whether or not such terms are formal or in writing) of the transactions which lay down explicitly or implicitly how the responsibilities, risks and benefits are to be divided between the respective parties to the transactions; (d) conditions prevailing in the markets in which the respective parties to th .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

e likely to materially affect the price or cost charged or paid in, or the profit arising from, such transactions in the open market; or (ii) reasonably accurate adjustments can be made to eliminate the material effects of such differences. (4) The data to be used in analysing the comparability of an uncontrolled transaction with an international transaction shall be the data relating to the financial year in which the international transaction has been entered into : Provided that data relating .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

method for determining the ALP of the international transaction. The disputes are with regard to the comparability of the comparable relied upon by the TPO. 20. In this regard we find that the provisions of law pointed out by the ld. counsel for the assessee as well as the decisions referred to by the ld. counsel for the assessee clearly lay down the principle that the turnover filter is an important criteria in choosing the comparables. The assessee s turnover is ₹ 47,46,66,638. It would .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ables drawn by the TPO viz., Turnover Rs. (1)Flextronics Software Systems Ltd. 848.66 crores (2) iGate Global Solutions Ltd. 747.27 crores (3) Mindtree Ltd. 590.39 crores (4) Persistent Systems Ltd. 293.74 crores (5) Sasken Communication Technologies Ltd. 343.57 crores (6) Tata Elxsi Ltd. 262.58 crores (7) Wipro Ltd. 961.09 crores (8) Infosys Technologies Ltd. 13149 crores 18. Respectfully following the aforesaid decision of the Tribunal in the case of Trilogy EBusiness Software India Pvt.Ltd. ( .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

omparable. 7.3.3 Following the aforesaid decision of the co-ordinate bench of this Tribunal in the case of Airbus India Operations Pvt. Ltd. (supra) for Assessment Year 2009-10, we hold that the aforesaid seven companies (listed at S.Nos.5 to 11 of the TPO s final list of comparables in the order under Section 92CA of the Act) and also listed out at para 7.1.1 of this order (supra), should be excluded from the list of comparable companies as the turnover of these companies is in excess of ₹ .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

r Assessment Year 2009-10 was considered by a co-ordinate bench of this Tribunal in the case of Airbus India Operations Pvt. Ltd. (supra) wherein, following the decision of another co-ordinate bench of this Tribunal in the case of CISCO Systems India Pvt. Ltd. in IT(TP)A No.271/Bang/2014 for Assessment Year 2009-10 dt.14.8.2014, it was held as under at paras 15 & 16 thereof :- 15. The assessee company, Cisco Systems (India) Pvt. Ltd. is a wholly owned subsidiary of Cisco Group represented by .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

to its AEs. The segmental financials for the F.Y. 2008-09 were as under:- Description Software Development Marketing & Sales Services Product Replacement Services Admin & Other Support Services Management Services Other Revenue 9654304981 5270847929 2463723146 1491900613 1250254745 54441247 Total Cost 8904581852 4213518148 2413930963 1374404584 1136594862 51245935 Operating Profit 749723129 1057329781 49792183 117496029 113659883 3195312 Mark up on Cost 8.42% 25.09% 2.06% 8.55% 10.00% Ma .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ating profit to operating cost. The assessee proposed 17 comparable companies out of which the TPO accepted 5 comparable companies and rejected the 12 comparables. On his own, the TPO selected 6 companies and arrived at a final set of 11 comparables and their operating margins as follows:- Sl. No. Name of the Comparable Sales (in Rs.) Cost (in Rs.) Margin 1 Kals Information Systems Ltd 2,14,04,686 1,87.93,813 l3.89% 2 Akshay Software Technologies Ltd. 12,23,21,483 11,31,49,350 8.11% 3 Bodhtree C .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

1 Infosys Ltd. 2,02,64,00,00,000 1,39,17,00,00,000 45.61% Average Mean 24.32% 8.2 Following the decision of the co-ordinate bench of this Tribunal in the case of Airbus India Operations Pvt. Ltd. (supra), and after taking note that the facts and circumstances under which the aforesaid company was considered by the TPO as comparable to a software development service provider as is the assessee in the case on hand, for identical reasons, we direct the TPO to exclude this company i.e. Bodhtree Cons .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

, wherein, following the decision of another co-ordinate bench of this Tribunal in the case of Cisco Systems (India) Pvt. Ltd. (supra) for Assessment Year 2009-10, at paras 21 and 22 thereof it was held as under :- 21. KALS INFORMATION SYSTEMS LTD.: This company is listed at Sl.No.3 in the final list of comparables chosen by the TPO which is set out in para-4 of this order. The comparability of this company with a software development services company such as the Assessee for AY 09-10 was consid .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

g were the relevant observations of the Tribunal:- (d) KALS Information Systems Ltd. 46. As far as this company is concerned, the contention of the assessee is that the aforesaid company has revenues from both software development and software products. Besides the above, it was also pointed out that this company is engaged in providing training. It was also submitted that as per the annual repot, the salary cost debited under the software development expenditure was ₹ 45,93,351. The same .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ding inclusion of Kals Information System Ltd. The assessee has objected to its inclusion on the basis that functionally the company is not comparable. With reference to pages 185-186 of the Paper Book, it is explained that the said company is engaged in development of software products and services and is not comparable to software development services provided by the assessee. The appellant has submitted an extract on pages 185-186 of the Paper Book from the website of the company to establish .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

on to the submission made on behalf of the Assessee. We find that the TPO has drawn conclusions on the basis of information obtained by issue of notice u/s.133(6) of the Act. This information which was not available in public domain could not have been used by the TPO, when the same is contrary to the annual report of this company as highlighted by the Assessee in its letter dated 21.6.2010 to the TPO. We also find that in the decision referred to by the learned counsel for the Assessee, the Mum .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ich the aforesaid company was considered by the TPO as comparable with a software development service provider such as the Assessee for identical reasons, we direct the TPO to exclude the aforesaid company from the list of comparable companies for the purpose of computation of ALP. 9.2 Following the decision of the co-ordinate bench of this Tribunal in the case of Airbus India Operations Pvt. Ltd. (supra) and after taking note that the facts and circumstances under which the aforesaid company wa .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

turnover filter, they are also additionally functionally different and not comparable to a company such as the assessee as has been held by different co-ordinate benches of this Tribunal in the case of Genisys Integrating Systems (India) Ltd. (supra), Cisco Systems (India) Pvt, Ltd. and the case of Airbus India Operations Pvt. Ltd. (supra) for Assessment Year 2009- 10. The learned Authorised Representative submits that in the factual matrix of the case and in view of the aforesaid decisions of t .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ompanies as comparable to an assessee who is purely a software development service provider, holding as under at paras 19 & 20 thereof :- 19. The next submission of the learned Counsel for the Assessee was that though, Infosys Technologies Ltd., & Tata Elxsi Ltd. (seg.) have to be excluded by applying the Turnover filter, they are also additionally functionally not comparable as held by this Tribunal in the case of Genisys Integrating Systems (India) Ltd. (supra) and Cisco Systems (India .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

rent from a company providing simple software development services, as this company owns significant intangibles and has huge revenues from software products. In this regard, we find that the Bangalore Bench of the Tribunal in the case of M/s. TDPLM Software Solutions Ltd. v. DCIT, ITA No.1303/Bang/2012, by order dated 28.11.2013 with regard to this comparable has held as follows:- 11.0 Infosys Technologies Ltd. 11.1 This was a comparable selected by the TPO. Before the TPO, the assessee objecte .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ur attention to various parts of the Annual Report of this company to submit that this company commands substantial brand value, owns intellectual property rights and is a market leader in software development activities, whereas the assessee is merely a software service provider operating its business in India and does not possess either any brand value or own any intangible or intellectual property rights (IPRs). It was also submitted by the learned Authorised Representative that :- (i) the co .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

e observation of the ITAT, Delhi Bench in the case of Agnity India Technologies Pvt. Ltd. in ITA No.3856 (Del)/2010 at para 5.2 thereof, that Infosys Technologies Ltd. being a giant company and market leader assuming all risks leading to higher profits cannot be considered as comparable to captive service providers assuming limited risk ; (iii) the company has generated several inventions and filed for many patents in India and USA ; (iv) the company has substantial revenues from software produc .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ing the contentions of the assessee, the learned Departmental Representative submitted that comparability cannot be decided merely on the basis of scale of operations and the brand attributable profit margins of this company have not been extraordinary. In view of this, the learned Departmental Representative supported the decision of the TPO to include this company in the list of comparable companies. 11.4 We have heard the rival submissions and perused and carefully considered the material on .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

cant intangible and has huge revenues from software products. It is also seen that the break up of revenue from software services and software products is not available. In this view of the matter, we hold that this company ought to be omitted from the set of comparable companies. It is ordered accordingly. The decision rendered as aforesaid pertains to A.Y. 2008-09. It was affirmed by the learned counsel for the Assessee that the facts and circumstances in the present year also remains identica .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ices segment in ITA No.1076/Bang/2011, order dated 29.3.2013. Following were the relevant observations of the Tribunal:- II. UNREASONABLE COMPARABILITY CRITERIA : 19. The learned Chartered Accountant pleaded that out of the six comparables shortlisted above as comparables based on the turnover filter, the following two companies, namely (i) Tata Elxsi Ltd; and (ii) M/s. Flextronics Software Systems Ltd., deserve to be eliminated for the following reasons : (i) Tata Elxsi Ltd., : The company oper .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ble to any other software services company because of its complex nature. Hence, Tata Elxsi Ltd., is to be excluded from the list of comparables. (ii) Flextronics Software Systems Ltd. : The learned TPO has considered this company as a comparable based on 133(6) reply wherein this company reflected its software development services revenues to be more than 75% of the "software products and services" segment revenues. Flextronics has a hybrid revenue model and hence should be rejected a .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

tware/product development services depends on the success of the products sold by its clients in the marketplace. Hence, it would be inappropriate to compare the business operations of the assessee with that of a company following hybrid business model comprising of royalty income as well as regular software services income, for which revenue break-up is not available. He finally submitted that this was a good reason to exclude this company also from the list of comparables. 20. On the other han .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ngineering design services and iii) visual computing labs. 2. The product design services sub-segment is into embedded software development. Thus this segment is into software development services. 3. The contribution of the embedded services segment is to the tune of ₹ 230 crores in the total segment revenue of ₹ 263 crores. Even if we consider the other two sub-segments pertain to IT enabled services, the 87.45% (›75%) of the segment's revenues is from software developme .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ed by the taxpayer are the same and these were there in the earlier FY 2005-06, there is no reason why the taxpayer is objecting to it. How the company is functionally similar in the earlier FY 2005-06 but the same is not functionally similar for the subsequent FY 2006-07 even when no facts have been changed from the preceding year. Thus the taxpayer is arguing against this comparable as the company was not considered as a comparable by the taxpayer for the present FY 2006-07." 21. We have .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

ollowing the decision of the Tribunal referred to above and taking note of the fact that the facts and circumstances under which the aforesaid company was considered by the TPO as comparable with a software development service provider such as the Assessee for identical reasons, we direct the TPO to exclude the aforesaid two companies from the list of comparable companies for the purpose of computation of ALP. 10.2.2 Following the decision of the co-ordinate bench of this Tribunal in the case of .....

X X X X X X X

Extract - Part text only
Click here to Access Full Contents

X X X X X X X

 

 

 

 

 

what is new what is new
  ↓     bird's eye view     ↓  


|| Home || Acts and Rules || Notifications || Circulars || Schedules || Tariff || Forms || Case Laws || Manuals ||

|| About us || Contact us || Disclaimer || Terms of Use || Privacy Policy || TMI Database || Members || Site Map ||

© Taxmanagementindia.com [A unit of MS Knowledge Processing Pvt. Ltd.] All rights reserved.

Go to Mobile Version