Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
Section 179 cannot fasten unrecovered company tax on a director of an unlisted public company merely because shareholding is concentrated or shares were not publicly offered. Public or private status depends on the Memorandum and Articles of Association; lifting the corporate veil requires exceptional facts, which were absent. Liability also requires a finding that non-recovery was attributable to the director's gross neglect, misfeasance or breach of duty, assessed against the director's role in the non-recovery. Reliance on an undisclosed adverse statement while disregarding relevant material from the director breached natural justice. The order imposing the company's tax liability on the director was quashed.
Section 179 cannot fasten unrecovered company tax on a director of an unlisted public company merely because shareholding is concentrated or shares were not publicly offered. Public or private status depends on the Memorandum and Articles of Association; lifting the corporate veil requires exceptional facts, which were absent. Liability also requires a finding that non-recovery was attributable to the director's gross neglect, misfeasance or breach of duty, assessed against the director's role in the non-recovery. Reliance on an undisclosed adverse statement while disregarding relevant material from the director breached natural justice. The order imposing the company's tax liability on the director was quashed.
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TaxTMI 
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