Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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HC held that the director cannot be personally liable for company's export obligation defaults without specific allegations demonstrating direct responsibility. The court found procedural irregularities, including failure to issue proper show cause notices after company's liquidation in 1998 and lack of evidence establishing director's direct culpability. Fundamental principles of natural justice were violated, and the respondent's orders imposing personal liability were consequently set aside. The court emphasized that mere directorship does not automatically create personal liability, requiring clear proof of direct involvement in the company's non-compliant conduct.
HC held that the director cannot be personally liable for company's export obligation defaults without specific allegations demonstrating direct responsibility. The court found procedural irregularities, including failure to issue proper show cause notices after company's liquidation in 1998 and lack of evidence establishing director's direct culpability. Fundamental principles of natural justice were violated, and the respondent's orders imposing personal liability were consequently set aside. The court emphasized that mere directorship does not automatically create personal liability, requiring clear proof of direct involvement in the company's non-compliant conduct.
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