Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Section 223(1) BNSS requires a proposed accused to be heard before cognizance of a PMLA complaint where the BNSS governs the cognizance stage. Section 44(1)(b) PMLA permits direct cognizance without committal but does not displace incorporated complaint safeguards; Sections 46 and 65 preserve criminal procedure unless inconsistent with the PMLA. Section 71 operates only upon inconsistency. Registration or listing of a complaint before BNSS commencement is administrative, not a pending inquiry under the saving clause, absent judicial application of mind. Non-compliance with the hearing requirement renders cognizance invalid and requires reconsideration from that stage; the hearing addresses prima facie cognizance, not trial merits.
Section 223(1) BNSS requires a proposed accused to be heard before cognizance of a PMLA complaint where the BNSS governs the cognizance stage. Section 44(1)(b) PMLA permits direct cognizance without committal but does not displace incorporated complaint safeguards; Sections 46 and 65 preserve criminal procedure unless inconsistent with the PMLA. Section 71 operates only upon inconsistency. Registration or listing of a complaint before BNSS commencement is administrative, not a pending inquiry under the saving clause, absent judicial application of mind. Non-compliance with the hearing requirement renders cognizance invalid and requires reconsideration from that stage; the hearing addresses prima facie cognizance, not trial merits.
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TaxTMI 
TaxTMI 
of 4913 
