1) Understanding the modus operandi of the business 2) Understanding the inter-play between various departments of the client 3) Understanding the reporting and organisational structure 4) Interpretation of the tax law and position in law 5) Review of underlying documents/ agreements

1) Agreement, underlying documents 2) Reporting and organisational hierarchy 3) Operation model of the business activity with value addition at each stage of the process 4) Tax status 5) Litigation history 5) Financial statements 6) Transfer pricing policy, if any