Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Oppression and mismanagement claim seeking rectification of the register of members was dismissed as time-barred where limitation began once appellants had knowledge of antecedent facts; the discovery rule delaying commencement of limitation does not apply when fraudulent conduct or concealment no longer suppresses knowledge. The tribunal relied on precedent that Section 17s postponement covers only concealment that prevents discovery of the cause of action, and found appellants had sufficient knowledge from events in 20062011 and prior complaints to have pursued rectification earlier, resulting in dismissal of the petition on limitation grounds.
Oppression and mismanagement claim seeking rectification of the register of members was dismissed as time-barred where limitation began once appellants had knowledge of antecedent facts; the discovery rule delaying commencement of limitation does not apply when fraudulent conduct or concealment no longer suppresses knowledge. The tribunal relied on precedent that Section 17s postponement covers only concealment that prevents discovery of the cause of action, and found appellants had sufficient knowledge from events in 20062011 and prior complaints to have pursued rectification earlier, resulting in dismissal of the petition on limitation grounds.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
