Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liability.

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....Income-tax prosecution for false verification or wilful non-production of accounts cannot continue where a merits-based appellate remand removes the factual foundation of concealment, falsity or wilful default underlying the original assessment. Complaints founded on that original assessment are consequently unsustainable and liable to be quashed. Directors may be prosecuted under a vicarious-liability provision only when the company is arraigned as an accused. A complaint against the company and directors may be maintainable where their respective roles are alleged, but separate complaints against directors alone for the company's offence are unsustainable and liable to be quashed.....