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...
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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