Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
An ECIR under the PMLA is an internal departmental document with no statutory status, so its quashing is not ordinarily maintainable unless the predicate offence itself is quashed; the challenge here was also premature because the alleged overlap with an earlier ECIR was not established. A subsequent ECIR or parallel investigation is permissible where it concerns a larger conspiracy, additional offences, or different accused, and is not barred as a second FIR. Statements recorded under Section 50 of the PMLA were not invalidated because Article 20(3), Section 164 CrPC safeguards, and Miranda-type protections apply only once a person is an accused or formally arrested. Section 50 summons and Section 66(2) information-sharing were upheld as part of lawful investigation, and a private person can be proceeded against for corruption-linked offences.
An ECIR under the PMLA is an internal departmental document with no statutory status, so its quashing is not ordinarily maintainable unless the predicate offence itself is quashed; the challenge here was also premature because the alleged overlap with an earlier ECIR was not established. A subsequent ECIR or parallel investigation is permissible where it concerns a larger conspiracy, additional offences, or different accused, and is not barred as a second FIR. Statements recorded under Section 50 of the PMLA were not invalidated because Article 20(3), Section 164 CrPC safeguards, and Miranda-type protections apply only once a person is an accused or formally arrested. Section 50 summons and Section 66(2) information-sharing were upheld as part of lawful investigation, and a private person can be proceeded against for corruption-linked offences.
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