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...
Tribunal jurisdiction to convene a requisitioned extraordinary general meeting is not conditional on the requisitioning member first using its statutory power to call the meeting after Board default; those remedies operate independently. However, intervention in corporate internal management remains exceptional and requires a reasonable factual basis showing that convening the meeting through ordinary statutory or articles-based mechanisms is impracticable. Board division or rejection of a requisition alone does not establish impracticability. Where the requisitioning member neither demonstrates difficulty in convening shareholders nor uses the available statutory mechanism, a direction to convene the meeting lacks the required factual basis and should be set aside.
Tribunal jurisdiction to convene a requisitioned extraordinary general meeting is not conditional on the requisitioning member first using its statutory power to call the meeting after Board default; those remedies operate independently. However, intervention in corporate internal management remains exceptional and requires a reasonable factual basis showing that convening the meeting through ordinary statutory or articles-based mechanisms is impracticable. Board division or rejection of a requisition alone does not establish impracticability. Where the requisitioning member neither demonstrates difficulty in convening shareholders nor uses the available statutory mechanism, a direction to convene the meeting lacks the required factual basis and should be set aside.
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