Corporate separateness bars tax recovery from shareholders' personal assets when liability is assessed against the company.

A limited company is a separate legal entity from its shareholders, and its assets do not belong to them personally. Where sales tax is assessed against the company, recovery may be enforced only against the company's assets and not against the personal assets of shareholders. Coercive recovery from shareholders for the company's tax liability was unlawful, and mandamus was granted restraining such recovery.

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Issues: Whether sales tax assessed on a limited company could be realised by the Collector from the personal assets of its shareholders.

Analysis: A limited company is a distinct legal entity separate from its shareholders. The shareholders have no proprietary interest in the company's assets and are not personally liable for the company's debts or liabilities. Where the tax liability is assessed against the company and not against the shareholders, coercive recovery can be made only against the company's assets and not against the personal assets of the shareholders.

Conclusion: Recovery from the personal assets of the shareholders was held to be unlawful, and relief by mandamus was granted restraining such recovery.

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