Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
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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