Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Article 32 may be invoked to quash criminal proceedings to prevent abuse of process, and the availability of an alternative remedy does not itself bar jurisdiction. However, direct recourse is ordinarily inappropriate where remedies under Article 226 or Section 482 CrPC are available, unless fundamental-right infringement or exceptional circumstances are shown. On the same-transaction test, multiple FIRs cannot continue for one incident or connected offences forming a single transaction, but may proceed for distinct occurrences. Cyber-fraud complaints involving separate inducements, victims, transactions and consequences were treated as prima facie distinct; a common modus operandi or fund transfers alone did not justify clubbing or a composite investigation.
Article 32 may be invoked to quash criminal proceedings to prevent abuse of process, and the availability of an alternative remedy does not itself bar jurisdiction. However, direct recourse is ordinarily inappropriate where remedies under Article 226 or Section 482 CrPC are available, unless fundamental-right infringement or exceptional circumstances are shown. On the same-transaction test, multiple FIRs cannot continue for one incident or connected offences forming a single transaction, but may proceed for distinct occurrences. Cyber-fraud complaints involving separate inducements, victims, transactions and consequences were treated as prima facie distinct; a common modus operandi or fund transfers alone did not justify clubbing or a composite investigation.
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