Eligible assessee for safe harbour rules for international transactions

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....nce with rule 90, and- (a) is engaged in providing information technology services consisting of any one or more of the following:- (i) software development services; or (ii) information technology enabled services; or (iii) knowledge process outsourcing services; or (iv) contract research and development services wholly or partly relating to software develop....

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....reign company. (2) For the purposes of identifying an eligible assessee, with insignificant risk, referred to in sub-rule (1)(a), the Director General of Income-tax (Systems) shall have regard to the following factors:- (a) the foreign principal performs most of the economically significant functions involved, including the critical functions, such as, - (i) conceptualisation;....

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....uct development or the activities carried out through its strategic decisions to perform core functions as well as by monitoring activities on a regular basis; (d) the eligible assessee does not assume or has no economically significant realised risks, and if a contract shows that the foreign principal is obligated to control the risk but the conduct shows that the eligible assessee is do....

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....rch or product development cycle, including the critical functions such as; (i) conceptualisation; (ii) design of the product; and (iii) providing the strategic direction and framework, either through its own employees or through its other associated enterprises while the eligible assessee carries out the work assigned to it by the foreign principal; (b....