(1.) 1. The applicant is a wholly owned subsidiary Indian company of A.P. Asia, a foreign company. It is stated that it would be providing among others, investment research and other advisory services. For this purpose, it has entered into an agreement with the holding company for providing services on payment of fees which are claimed to be an arm's length return on total costs over a financial period.
(2.) On the aforementioned facts, the applicant has sought an advance ruling of the Authority on the following question:
(3.) ON 10-4-2007, none appeared on behalf of the applicant. Shri Deepak Garg, Senior Departmental Representative appeared on behalf of the Commissioner and made his submissions.