Residence - availed - Ad-space 100,022,760
Hong Kong) purchased on Star Plus
Channel
Asian Services provided -
Broadcasting FZ- Television Content ... assessee
was willing to spend a target amount over period of time. Accordingly
the assessee selected STAR PLUS channel for its promotional activity
and entered
target interest rate that is fixed by the Federal
Open Market Committee ('FOMC') for implementing the USA's
monetary policies, plus
Under the agreement, the AEs are to be
compensated on a cost plus a mark-up in accordance with the group
standard policy and procedures ... business targeting
and strategic planning and research.
under MSF)
Pricing policy Charged by Associated Enterprise Charged by AE at cost plus
target interest rate that is fixed by the Federal
Open Market Committee ('FOMC') for implementing the USA's
monetary policies, plus
target interest rate that is fixed by the Federal
Open Market Committee ('FOMC') for implementing the USA's
monetary policies, plus
target interest rate that is fixed by the Federal
Open Market Committee ('FOMC') for implementing the USA's
monetary policies, plus
target interest rate that is fixed by the Federal
Open Market Committee ('FOMC') for implementing the USA's
monetary policies, plus
target interest rate that is fixed by the Federal
Open Market Committee ('FOMC') for implementing the USA's
monetary policies, plus
were in the nature of assistance in fostering and developing new
business targeting, public relations, strategic planning, media
support, financial administration, human resources management ... assistance in managing
and planning local account and targeting, winning new business, in
assessee's target market. The details such as the nature
taking a product and
making it linguistically and culturally appropriate to the target locale.
Content development includes updating and management of clients'
localized software ... customer's requirements. It was
remunerated for its services at cost plus mark-up of 16.37%.
3. For the impugned year, the applicant selected
