SEC Comment Letter for SIFY TECHNOLOGIES LTD (SIFY) (CIK 0001094324) (SIFY) — Apr 1, 2009
SIFY TECHNOLOGIES LTD (SIFY) (CIK 0001094324)
Date: April 1, 2009 · CIK: 0001094324 · Accession: 0000000000-09-016692
AI Filing Summary & Sentiment
File numbers found in text: 000-27663
Referenced dates: February 9, 2009, March 16, 2009
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Mail Stop 4561 A p r i l 1 , 2 0 0 9 M P Vijay Kumar Chief Financial Officer Tidel Park, 2nd Floor No. 4, Rajiv Gandhi Salai Taramani, Chennai 600 113 Republic of India
Re: Sify Technologies Limited
Form 20-F for Fiscal Year Ended March 31, 2008
Filed October 14, 2008
File No. 000-27663
Dear Mr. Kumar:
We have reviewed your response letter dated March 16, 2009 in connection with
the above-referenced filing and have the followi ng comments. If indicated, we think you
should revise your document in response to these comments. If you disagree, we will
consider your explanation as to why our comment is inapplicable or a revision is
unnecessary. Please be as deta iled as necessary in your expl anation. In some of our
comments, we may ask you to provide us w ith supplemental information so we may
better understand your disclosure. After re viewing this information, we may raise
additional comments. Unless otherwise noted, where prior comments are referred to they
refer to our letter dated February 9, 2009.
Form 20-F for Fiscal Year Ended March 31, 2008
Item 5. Operating and Financial Review and Prospects
Liquidity and Capital Resources, page 40
1. We note your response to prior comment 3 indicates your DSOs increased from
79 days at March 31, 2007 to 103 days at March 31, 2008 because the economic
environment curtailed your ability to stri ctly enforce your credit policies. Please
expand upon your position that the elongation of your credit cycl e did not create
significant uncertainty with respect to your allowance for doubtful accounts or
impact your revenue recognition given your statements that your allowance is based in part on your assessment of the current economic environment and that your revenue recognition policy considers whether any uncertainty with respect to
M P Vijay Kumar
Sify Technologies Limited April 1, 2009 Page 2
collectability existed at the date of initi al recognition or whether the uncertainty
arose after that time. As part of your response, please provide us with your DSO
calculations at June 30, 2008, Sept ember 30, 2008 and December 31, 2008.
Item 18. Financial Statements
Note 4. Significant Accounting Policies
n. Export Benefits, page 97
1. Your response to prior comment 13 indi cates your credit duty entitlement from
the “Served from India” scheme will be used for the import of capital goods.
Please clarify for us whether or not the dut y entitlements represent “grants related
to assets” as defined in paragraph 3 of IAS 20 and, if so, tell us how you have
considered paragraphs 24 through 27 of that standard.
Note 12. Lease Prepayments, page 104
2. Please confirm that you will include in futu re filings the information provided in
your response to prior comment 18.
* * * * * * *
Please respond to these comments within 10 business days or tell us when you
will provide us with a response. Please submit all correspondence and supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T. If you amend your
filing(s), you may wish to provide us with marked copies of any amendment to expedite our review. Please furnish a cover letter that keys your response to our comments and provides any requested information. Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing any
amendment and your response to our comments.
You may contact Mark Sh annon, Staff Accountant, at (202) 551-3299 or me at
(202) 551-3451 if you have any questions regarding the above comments.
S i n c e r e l y , Mark Kronforst
Accounting Branch Chief