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1. M/s. Logitech Engineering & Designs India P. Ltd is the successor of the erstwhile Lifesize Communications P. Ltd which is a 100 % subsidiary of Lifesize Communications Inc. The assessee is a captive service provider and has been set up as a captive off shore software development centre for catering to the needs of the Lifesize group. Lifesize India is responsible for the research, software development and support services for Lifesize Inc’s products and services.

2. The assessee bench marked the software development

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