Contract R&D insignificant risk: criteria defined for Indian development centres; conduct, control, assets and ownership determine transfer pricing treatment. An Indian development centre may be treated as a contract R&D service provider with insignificant risk only if all five cumulative conditions are met: the foreign principal performs economically significant R&D functions while the Indian centre performs economically insignificant functions; the principal provides funds and economically significant assets including intangibles and the Indian centre does not use such assets; the principal actually supervises and controls core activities; the Indian centre bears no economically significant realised risks; and the Indian centre has no legal or economic ownership of research outcomes, with conduct prevailing over contractual terms.