Court Invalidates Director Liability Order Due to Lack of Documentation and Subjective Satisfaction u/s 179.

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....Liability of directors of private company in liquidation - steps taken against the delinquent Company - The order does not record any of the material which formed the basis for the Assessing Officer to conclude that all steps have been taken to recover the tax dues from the Company. Further, the impugned order does not refer to the Assessing Officer's subjective satisfaction based upon material before it, to conclude that all steps had been taken to proceed against the delinquent Company and such steps had failed. - The order issued u/s 179 are unsustainable - HC....