Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
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Further investigation under the PMLA is a continuation of the original investigation, not a re-investigation, and may bring additional oral or documentary evidence on record. Explanation (ii) to section 44(1) recognises the authorised agency's continuing power to undertake such investigation. The proviso to section 193 of the BNSS requires prior permission of the Criminal Court only during trial, which commences upon framing of charge. Where charges have not been framed, further investigation may therefore proceed without prior leave of the Court, including through investigative notices.
Further investigation under the PMLA is a continuation of the original investigation, not a re-investigation, and may bring additional oral or documentary evidence on record. Explanation (ii) to section 44(1) recognises the authorised agency's continuing power to undertake such investigation. The proviso to section 193 of the BNSS requires prior permission of the Criminal Court only during trial, which commences upon framing of charge. Where charges have not been framed, further investigation may therefore proceed without prior leave of the Court, including through investigative notices.
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