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...
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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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