Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
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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