Eligible assessee

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..... information technology enabled services or knowledge process outsourcing services, with insignificant risk, to a non-resident associated enterprise (hereinafter referred as foreign principal) ; (ii) has made any intra-group loan; (iii) has provided a corporate guarantee; (iv) is engaged in providing contract research and development services wholly or partly relating to software developm .....

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..... l have regard to the following factors, namely:- (a) the foreign principal performs most of the economically significant functions involved, including the critical functions such as conceptualisation and design of the product and providing the strategic direction and framework, either through its own employees or through its other associated enterprises, while the eligible assessee carries out .....

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..... that the foreign principal is obligated to control the risk but the conduct shows that the eligible assessee is doing so, the contractual terms shall not be the final determinant; (e) the eligible assessee has no ownership right, legal or economic, on any intangible generated or on the outcome of any intangible generated or arising during the course of rendering of services, which vests with th .....

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..... oreign principal or its other associated enterprises provides the funds or capital and other economically significant assets including intangibles required for research or product development and also provides a remuneration to the eligible assessee for the work carried out by it; (c) the eligible assessee works under the direct supervision of the foreign principal or its other associated enter .....

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..... Notes :- 1. Inserted vide Notification No. 73/2013 September 18, 2013 2. Omitted vide Not. 46/2017 - Dated 7-6-2017 w.e.f. 1st day of April, 2017, before it was read as or 3. Inserted vide Not. 46/2017 - Dated 7-6-2017 w.e.f. 1st day of April, 2017 4. Inserted vide Not. 46/2017 - Dated 7-6-2017 w.e.f. 1st day of April, 2017 - - statute, statutory provi .....

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