Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
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Revision u/s 263 - loss incurred by the Directors - trading activity in F & O undertaken on behalf of the company - The trading of sale and purchase of shares done by the directors of the company in their individual capacity cannot be said to be in pursuance to the Board's resolution passed by the assessee company. In the board resolution, there is no whisper of making any "investment" on behalf of the company by these directors as provided u/s. 179(3)(e) of the Companies Act, 2013. In view of the above, we do not find any justification for the Assessing Officer to allow the deduction of the losses suffered by these directors in the hands of the assessee company. - AT
Revision u/s 263 - loss incurred by the Directors - trading activity in F & O undertaken on behalf of the company - The trading of sale and purchase of shares done by the directors of the company in their individual capacity cannot be said to be in pursuance to the Board's resolution passed by the assessee company. In the board resolution, there is no whisper of making any "investment" on behalf of the company by these directors as provided u/s. 179(3)(e) of the Companies Act, 2013. In view of the above, we do not find any justification for the Assessing Officer to allow the deduction of the losses suffered by these directors in the hands of the assessee company. - AT
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