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SEC Comment Letter 0000000000-25-002804 to WNS (HOLDINGS) LTD (WNS) (CIK 0001356570) (WNS)

WNS (HOLDINGS) LTD (WNS) (CIK 0001356570)
Date: March 14, 2025 · CIK: 0001356570 · Accession: 0000000000-25-002804

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

File numbers found in text: 001-32945

Date
March 14, 2025
Author
Division of
Form
UPLOAD
Company
WNS (HOLDINGS) LTD (WNS) (CIK 0001356570)

Letter

Re: WNS (Holdings) Limited Form 20-F for Fiscal Year Ended March 31, 2024 Form 10-Q for Fiscal Quarter Ended December 31, 2024 File No. 001-32945 Dear Arijit Sen:

March 14, 2025

Arijit Sen Group Chief Financial Officer WNS (Holdings) Limited 515 Madison Avenue, 8th Floor New York, NY 10022

We have reviewed your filings and have the following comment(s).

Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this letter, we may have additional comments.

Form 10-Q for Fiscal Quarter Ended December 31, 2024 Item 2. Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 15

1. Please expand your disclosure to provide a discussion of results of operations on the reportable segment basis. Please also explain the material changes in the reconciling items of the segment reconciliation in Note 20. In circumstances where there are more than one business reason for the change, please quantify the incremental impact of each individual business reason discussed on the overall change. Refer to Item 303 of Regulation S-K and SEC Release No. 33-8350. Notes to Unaudited Consolidated Financial Statements 20. Segment Reporting, page F-60

2. You state that you use revenue less repair payments as a primary measure to allocate resources and measure segment performance. We note you also disclose a segment gross profit measure in your reconciliation on page F-61. Please tell us if the segment March 14, 2025 Page 2

gross profit is a measure of a segment s profit or loss regularly provided and used by your CODM in assessing segment performance and deciding how to allocate resources. If your CODM uses both revenue less repair payments and segment gross profit as segment profit or loss measures, the reported measure shall be the one determined in accordance with the measurement principles most consistent with those used in the corresponding amounts in your consolidated financial statements. Please revise your disclosure to clarify the segment profit or loss measures required to be disclosed by ASC 280. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Please contact Suying Li at 202-551-3335 or Angela Lumley at 202-551-3398 if you have any questions.

Sincerely,
Division of
Corporation Finance
Office of Trade &
Services

Show Raw Text
<DOCUMENT>
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<TEXT>
 March 14, 2025

Arijit Sen
Group Chief Financial Officer
WNS (Holdings) Limited
515 Madison Avenue, 8th Floor
New York, NY 10022

 Re: WNS (Holdings) Limited
 Form 20-F for Fiscal Year Ended March 31, 2024
 Form 10-Q for Fiscal Quarter Ended December 31, 2024
 File No. 001-32945
Dear Arijit Sen:

 We have reviewed your filings and have the following comment(s).

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-Q for Fiscal Quarter Ended December 31, 2024
Item 2. Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Results of Operations, page 15

1. Please expand your disclosure to provide a discussion of results of
operations on the
 reportable segment basis. Please also explain the material changes in
the reconciling
 items of the segment reconciliation in Note 20. In circumstances where
there are more
 than one business reason for the change, please quantify the incremental
impact of
 each individual business reason discussed on the overall change. Refer
to Item 303 of
 Regulation S-K and SEC Release No. 33-8350.
Notes to Unaudited Consolidated Financial Statements
20. Segment Reporting, page F-60

2. You state that you use revenue less repair payments as a primary measure
to allocate
 resources and measure segment performance. We note you also disclose a
 segment
 gross profit measure in your reconciliation on page F-61. Please tell
us if the segment
 March 14, 2025
Page 2

 gross profit is a measure of a segment s profit or loss regularly
provided and used by
 your CODM in assessing segment performance and deciding how to allocate
 resources. If your CODM uses both revenue less repair payments and
segment gross
 profit as segment profit or loss measures, the reported measure shall be
the one
 determined in accordance with the measurement principles most consistent
with those
 used in the corresponding amounts in your consolidated financial
statements. Please
 revise your disclosure to clarify the segment profit or loss measures
required to be
 disclosed by ASC 280.
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 Please contact Suying Li at 202-551-3335 or Angela Lumley at
202-551-3398 if you
have any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
</TEXT>
</DOCUMENT>