1. Review of the transaction and its underlying documents. 2. Understanding the commercial expediency of the transaction. 3. Understanding the nature of business of the entity and its group entities which are parties to the transaction. 4. Interpretation of tax laws and Double tax avoidance agreement clauses. 5. Analysing the position in law with reference to judicial precedents, circulars, notifications issued by the relevant government authorities.

1. Understanding of the transaction and business rationale of the same 2. Understanding the nature of business of the entity and the group 3. Relationship between the parties to the transaction 4. Tax residency status in the other country and taxability of the transaction in the other country, this can be provided by way of tax computation, tax returns, tax memos prepared in the foreign jurisdiction 5. Transfer pricing document, if any 6. Reportings made relevant to the transaction to any government authority in India and foreign jurisdiction