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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Oppression and mismanagement allegations concerning group-asset and intellectual-property transfers, debt conversion, discounted share allotment and minority dilution require specific findings on the entire material and their cumulative effect; commercial justification cannot replace that inquiry. The dismissal was set aside and the company petition remanded, with status quo over shareholding, assets and liabilities restored pending adjudication. A clean-hands finding denying equitable relief must rest on clear, cogent record-based findings where meeting-related material permits competing interpretations. Perjury directions require precise allegations, meaningful opportunity to respond, identified false statements, reasons, and findings on oath, intentional falsity and requirements for further action; unsupported directions against shareholders and a creditor were set aside.
Oppression and mismanagement allegations concerning group-asset and intellectual-property transfers, debt conversion, discounted share allotment and minority dilution require specific findings on the entire material and their cumulative effect; commercial justification cannot replace that inquiry. The dismissal was set aside and the company petition remanded, with status quo over shareholding, assets and liabilities restored pending adjudication. A clean-hands finding denying equitable relief must rest on clear, cogent record-based findings where meeting-related material permits competing interpretations. Perjury directions require precise allegations, meaningful opportunity to respond, identified false statements, reasons, and findings on oath, intentional falsity and requirements for further action; unsupported directions against shareholders and a creditor were set aside.
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