Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
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Private-courier delivery of an insolvency demand notice to the corporate debtor's undisputed registered office constitutes effective service where dispatch and delivery establish knowledge and an opportunity to pay or dispute the claim; a technical objection to the service mode does not defeat the proceedings. Foreign-currency advances are converted at the exchange rate on the demand-notice date when testing the operational-debt threshold, while uncrystallised disputed damages may be excluded. Admitted advances for undelivered goods, with no repayment or genuine pre-existing dispute, establish operational debt and default; asserted solvency is not a separate bar. Corporate insolvency resolution proceedings were directed to be initiated, subject to payment before the initiation order.
Private-courier delivery of an insolvency demand notice to the corporate debtor's undisputed registered office constitutes effective service where dispatch and delivery establish knowledge and an opportunity to pay or dispute the claim; a technical objection to the service mode does not defeat the proceedings. Foreign-currency advances are converted at the exchange rate on the demand-notice date when testing the operational-debt threshold, while uncrystallised disputed damages may be excluded. Admitted advances for undelivered goods, with no repayment or genuine pre-existing dispute, establish operational debt and default; asserted solvency is not a separate bar. Corporate insolvency resolution proceedings were directed to be initiated, subject to payment before the initiation order.
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