Circular on conditions relevant to identify development centres engaged in contract R&D services with insignificant risk

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..... rcular on conditions relevant to identify development centres engaged in contract R&D services with insignificant risk It has been brought to the notice of CBDT that there is divergence of views amongst the field officers and taxpayers regarding the functional profile of development centres engaged in contract R&D services for the purposes of transfer pricing audit. Moreover, while at times taxpa .....

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..... product development and Indian development centre would not use any other economically significant assets including intangibles in research or product development; 3. Indian development centre works under direct supervision of foreign principal who not only has capability to control or supervise but also actually controls or supervises research or product development through its strategic decisi .....

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..... ith foreign principal, and that it shall be evident from conduct of the parties. The satisfaction of all the above mentioned conditions should be borne out by the conduct of the parties and not merely by the contractual terms. The above may be brought to the notice of all concerned. (Batsala Jha Yadav) Director APA Central Board of Direct Taxes Copy to: 1. The Chairperson, Members and all .....

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