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(b) Review, analyse and give recommendations on improvement of management and business activities ;
(c) Advice and assistance on financial matters including but not limited to budgeting and long-term financial planning ; and
(d) Assistance regarding seminars, customer training, employee relations and product application training.

2. Danfoss Singapore provides the aforementioned services to help the group companies in the region to effectively carry out their business and to ensure that all Danfoss Group companies follow the procedures relating to Human Resource, Accounting, Finance, etc., uniformly. The applicant says that to carry out business operation in a more economic and efficient manner and to maintain the global standards set by Danfoss Group it proposes to enter into an agreement with Danfoss Singapore to avail the said services. The consideration for availing those services is on the basis of allocation key which is determined on a proportional percentage of budget turnover weighted by growth rate and market maturity of the group company availing the services and any increase or shortfall in the actual turnover would proportionately increase or decrease the portion of cost to be absorbed by the group company which avails of services from Danfoss Singapore. The cost is reimbursable on a monthly basis. Though the applicant believes that no tax is required to be deducted at source while making payments of the service fee to Danfoss Singapore under Section 195 of the Income-tax Act, 1961 (for short "the Act"), in order to confirm its position advance ruling is sought on the following question :