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...
Liability of directors for company tax in liquidation was examined with emphasis on control by a liquidator and recovery from the companys credit ledger; the court found no justification to attach individual directors bank accounts where the company is under liquidator control, and the attachment was ordered vacated. The applicability of recoveries under GST enactments and operation of the credit ledger was recognized as satisfying tax recovery against the company, and directors were granted liberty to apply to respondents to be extricated from the impugned liability, with leave to file within 15 days.
Liability of directors for company tax in liquidation was examined with emphasis on control by a liquidator and recovery from the companys credit ledger; the court found no justification to attach individual directors bank accounts where the company is under liquidator control, and the attachment was ordered vacated. The applicability of recoveries under GST enactments and operation of the credit ledger was recognized as satisfying tax recovery against the company, and directors were granted liberty to apply to respondents to be extricated from the impugned liability, with leave to file within 15 days.
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