Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
Effect of amalgamation on corporate identity and liabilities was determinative: because the assessment related to a transferor company that had been amalgamated, its liabilities could not be attributed to that non-existing entity and the banking attachment enforced against the petitioner could not be sustained. Liability of a former director was rejected as the petitioner had resigned before the assessment periods and thus could not be held personally responsible for the companys tax debt. Reliance on a provision purporting to fasten director liability was held inapplicable where the transferor company stood amalgamated and the tax authorities could proceed against the amalgamated entity instead.
Effect of amalgamation on corporate identity and liabilities was determinative: because the assessment related to a transferor company that had been amalgamated, its liabilities could not be attributed to that non-existing entity and the banking attachment enforced against the petitioner could not be sustained. Liability of a former director was rejected as the petitioner had resigned before the assessment periods and thus could not be held personally responsible for the companys tax debt. Reliance on a provision purporting to fasten director liability was held inapplicable where the transferor company stood amalgamated and the tax authorities could proceed against the amalgamated entity instead.
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