1983 (1) TMI 58

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....Bhimjee & Company Pvt. Ltd. For the years 1964-65 and 1965-66, the company was assessed upon a best judgment basis under the provisions of s. 144 of the I.T. Act, 1961. For the years 1964-65 the tax was determined to be Rs. 2,300 and interest in the sum of Rs. 1,169 was made payable. For the year 1965-66 Rs. 4,200 was determined to be the tax and interest in the sum of Rs. 2,045 was made payable. ....

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....anything contained in the Companies Act, 1956 (1 of 1956), where any tax due from a private company in respect of any income of any previous year or from any other company in respect of any income of any previous year during which such other company was a private company cannot be recovered, then, every person who was a director of the private company at any time during the relevant previous year ....

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....to the commencement of the Act on April 1, 1962. It was contended by Mr. Naik, learned counsel for the respondents, that the phraseology employed in s. 179 enabled the tax authorities to recover from a director the tax which was determined to be due from his company prior to the coming into force of the amended s. 179. This does not appear to me to be correct. There is nothing in the section....