Section 179 director liability requires foundational facts and a reasonable opportunity before corporate veil can be lifted.

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....Section 179 proceedings against directors require both a reasonable opportunity to reply and foundational allegations in the notice itself. The text explains that where the notice allowed only about two days to respond, the proceedings failed for breach of natural justice and the resulting order and demand were quashed. It also states that if the company is asserted to be a public limited company, the notice must set out facts showing why it should nevertheless be treated as closely held or why the corporate veil should be lifted, including any allegation of an oblique motive to defraud the revenue. Fresh notice and reconsideration were permitted.....