Justice P.V. Reddi, Chairman. - The applicant (BAGI) is a company incorporated in India on 13-7-2007 to undertake the business of general insurance. AXA Asia Regional Centre Pvt. Ltd., (AXA ARC) is a company incorporated in Singapore and it is a part of the AXA group of companies. It acts as a Central service organization which caters to the requirements of AXA group companies in the region. The applicant entered into a Service Agreement with AXA ARC for receiving assistance such as business support, marketing information technology support services and strategy support etc., from AXA ARC. The applicant states that these services are merely advisory in nature and are procured with the intention of carrying on business in line with the best practices followed by other AXA group entities globally.

2. The applicant submits that the ‘services provided by AXA ARC are not “a one off transaction” but they are meant to support the applicant’s functioning on a continuous basis’. For providing these services no employee of AXA ARC will physically visit India. AXA ARC has no business establishment in India. The applicant has stated that for the services rendered by it, AXA ARC charges a