AI Insights
The case involved two petitioners, directors of private companies, who were disqualified and had their DINs deactivated by the 2nd respondent under Section 164(2)(a) of the Companies Act, 2013. This action was based on their failure to file financial statements or annual returns for three consecutive financial years. The petitioners challenged the disqualification and DIN deactivation, arguing that the action was taken retrospectively and violated principles of natural justice and their rights under the Constitution. The court examined the applicability of Section 164(2)(a) and the relevant rules, concluding that the provisions were applied retrospectively, which was impermissible.
Appeal Details
Counselvise Citation
[2020] 140 COUNSELVISE.COM (IT) 721736 (HC-TELANGANA)
Assessee PAN
Bench
Appeal Number
CRN Number
Appellant
Respondent
Appeal Type
Others
Pronouncement Date
01-09-2020
Assessment Year
misc
Judgement Text
"HIGH COURT FOR THE STATE OF TELANGANA (Special Original Jurisdiction) TUESDAY ,THE FIRST DAY OF SEPTEIVBER TWO THOUSAND AND TWENTY PRESENT THE HON'BLE SRI JUSTICE A.RAJASHEKER REDDY WRIT PETITION NO: 13264 OF 2020 Betwee n: AND '1 . l ,4 r. Ranganathan Sambanthan Babu, S/o. Sambanthan Aged About 50 Years, Occ. Business, Anusha Pats, 4th Floor, 406 Begumpet, Chikoti Garden Hyderabad, Telangana State-50001 6 2, Mr. Anuradha Babu, S/o. Krishna Murthy Kumar Aged About 41 Years, Occ. Business, R/o. 406, 4th Floor, Anusha Apts Begumpet, Chikoti Garden Hyderabad, Telangana State - 50001 6 . ..PETITIONERS 1 2 Union of lndia, The Ir/inistry of Corporate Affairs Represented by its Secretary 'A' Wing, ShastriBhawan, Rajendra Prasad Road, New Delhi - 110 011, The Registrar of Companies, Telangana State, 2nd Floor, Corporate Bhawan, GSI Post, Tattianaram, Nagole, Bandlaguda, Hyderabad -500 068 ...RESPONDENTS Petition under Adicle 226 of the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to pass an order or direction or any other proceeding one in the nature of Writ of N4andamus declaring the action of respondents in deactivating the DIN Numbers 02823432 and 02826984 for the disqualification period from 111112016 to 3011012022 of the Petitioner and restricting the petitioners from filing statutory relurns, i.e., the annual returns of the companies in which the petitioner is director. as arbitrary, illegal, without jurisdiction, contrary of the provisions of the Companies Act, 2013 and Rule 1 1 of the Companies (Appointment of Directors) Rules, 2014, violation of the principle of natural Justice besides violating the petitroner rights guaranleed under Article 14 and Article 19 (1 ) (g) of the Constitution of lnd ia. lA NO: 1 OF 2020 Petition under Section 151 CPC praying that in the circumstances stated in the affidavit filed in support of the petition, the High Court may be pleased to direct the 1s, respondent to restore the DIN number 02823432 and 02826984 for the d isq ua lification period from 111112016 to 3011012022 of the Petitioner. So as to enable him to submit the annual returns and Financial Statements of the companies in which the petitioner is acting as director. Counsel for the Petitioner : SRI MANDADAPU AJAY BABU Counsel for the Respondents; SRI NAMAVARAPU RAJESHWAR RAO ASST SOLICITOR GENERAL The Court made the following: ORDER HON'BLE SRI JUSTICE A.RAJASHEKER REDDY Writ Petition No.13264 OF 2O2O ORDER: Learned counsel for the petitioners as well as Sri Namavarapu Rajeshr,r'ar Rao, Iearned Assistant Solicitor General of India, appearing for the respondents submits that the lis in this Writ Petition is squarely covered by the Common Orders of this Court in WP No.5422 of 2018 & batch, dated 18.07.2019. In view of the same and for the reasons alike in the Common Order in WP No.5422 ol 2Ola & batch, dated 18.07.2019, this Writ Petition is also a llor','ed. There shall be no order as to costs. As a sequel thereto, miscellancous applications, if anr', pending in this Writ Petition, shall st:rnd disposed ol. SD/-M.MANJ LA ASSISTANT REG RAR ,TRUE COPY// SECTI OFFICER 1. The Secretary, Union of lndia, The Ministry of Corporate Affairs 'A' Wing' SnistriSfraw6n, Rajendra Prasad Road, New Delhi - 110 01 1' 2. The Registrar of Companies, Telangana State,.2nd Floor, C-o-rp-orate Bhawan' - osr p\"ii, iittiinarrm, Nagole' Banllaguda, Hyderabad -500 068 3. One CC to Sri Mandadapu Ajay Babu, Advocate [OPUC] 4. One CC to Sri Namavarapu Rajeshwar Rao, Asst Solicitor General' Advocate tOPUCI 5. Two CD CoPies (Alongwithacopyoforderdl.lslOTt20'19inWPNo5422of2018andBatch) To, SM ASk HIGH COURT DATED:01/09/2020 ORDER WP.No.13264 of 2020 ALLOWING THE WP WITHOUT COSTS J o 0 7 SEP 202{] HE SI4 1 o 6', '( q o /:- ((., ) -/ r^ tl AXo (,/, l THE HON'BLE SRI JUSTI E A,RA] ASHEKER REDDY W.P. NOs.5 22. I 2La4 1352o. 137a3_ 13455- 1 4L66 24 s1. ?oqq3. 7073. 7tO5,7432, 7454,7572, 7595, 7732. 7765.776a. 7A24. 7974, 4 669 5687 78 6L40,64A4,6753, 6858, 5958, 6981, 7001, 700a, 7014,7046,7069, 8111, 8223, 8s86. 8s90. 9333. 9340. 9381. 9468. 9563. 9584, 9623, 9726, 9737. LOOsA. LOO99, L1208, 11223. 1t239. t1263, L1889. 11991, 12018, 12036, L2040, L2069 12108 t2t44 1 2 146. 12194. 12200. t2209. L221s. 122L7.12243. 1-2260. 12262. t22Aa. t2342. L2350, 124L7, L2432, t2472, 12498, 12506, 12574, 12598, L262t, t2702. L2735. L2740, t2a45, 12850. t2865, 12866. L3013. r36LA. 8 13855 1 7 13 139t7 t3945, L4LOL, L4L74, 14207, L4350, 1436t. 14390. L4392, 14397, t4409, 14582 AND L4597 0F 20L9 Since, the issue involved in all the writ petitions is one and the same, they are heard together and are being disposed of by this common order. 2. The petitioners are the directors of the private companies, registered under the Companies Act, 2013 (18 of 2013) (for short 'the Act'). Some of the such companies are active, and some of them have been struck off from the register oF companies under Section 24e(l)( c ) of the Act, for not carrying on any business operation for the specified period mentioned in the said provision, and for not making any application within the specified period, for obtaining the status of a dormant company under Section 455 of the Act. 3. The petitioners, who were directors of the struck off companies, and who are presently directors of active companies, period in questioni failed to file financial statements or durlng annual the re eva nt returns for a continuous period of three years. Therefore, the 2\"d respondent passed the impugned order under Section L64(2) of the Act, disqualifying them as directors, and further making them ineligible to be re-appointed as directors of that company, or any other company, for a period of five years from the date on which the respective companies failed to do so. The Director Identification Numbers (DINs) of the petitioners were also deactivated. Aggrieved by the same, the present writ petitions have been filed. , I COMMON ORDER : 4. This court granted interim orders in the writ petitions directing the 2nd respondent to activate DINs of the petitioners, to enable them to function other than in strike off companies. 5. Heard the learned counsel appearing for the petitioners in all the writ petitions, Sri K.Lakshman, learned Assistant Solicitor General appearing for the respondents - Union of India. 6. Learned counsel for the petitioners, contend that before passing the impugned order, notices have not been issued, giving them opportunity, and this amounts to violation of principles of natural justice, and on this ground alone, the impugned orders are Iiable to be set aside. '7. Learned counsel submits that Section 16+(2)(a) of the Act empowers the authority to disqualify a person to be a director, provided he has not filed financial statements or annual returns of the company to whlch he is director, for any continuous period of three financial years. Learned counsel further submits that this provision came into force with effect from 7.4.2014, and prior thereto i.e., under Section 2l+(t)(9) of the Companies Act, 1956 (1 of 1956), which is the analogous provision, there was no such requirement for the directors of the private companies. They contend that this provision under Act 18 of 2013, will have prospective operation and hence, if the directors of company fail to comply with the requirements mentioned in the said provision subsequent to the said date, the authority under the Act, is within its jurisdiction to disqualify them. But in the present cases, the 2\"d respondent, taking the period prior to 1.4.2014, i.e., giving the provision retrospective effect, disqualified the petitioners as directors, which is illega I and arbitrary. B. With regard to deactivation of DINs, learned petitioners submit that the DINs, as contemplated under Companies (Appointment and Qualification of Directors), counsel for the Ru le 2(d) of the Rules,2014 (fo r / ( short'the Rules), are granted for life time to the appiicants under Rule 10(6) of the sa id Rules, grounds mentioned sa id grounds does and cancellation of the DIN can be made only for the in clauses (a) to (f) under Rule 11 of the Rules, and the not provide for deactivation for having become ineligible for appointment Learned cou nsel is provided under the Rules, the Act is provided only Section 248 of the Act. as Directors of the company under Section 164 of the Act. further subm its that as against the deactivation, no appeal appeal to the Tribunal under Section 252 of and against the dissolution of the company under 9. Learned counsel further submits that 1't respondent - Government of Indla represented by the Ministry of Corporate Affairs, has floated a scheme daled 29.12.2017 viz., Condonation of Delay Scheme - 2018, wherein the directors, whose DINs have been deactivated by the 2\"i respondent, allows the DINs of the Directors to be activated. However, such scheme is not applicable to the companies which are struck off under Section 248(5) of the Act. In case of active companies, they can make application to National Company Law Tribunal under Section 252 of the Act, seeking for restoration, and the Tribunal can order for reactivation of DIN of such directors, whose DIN are deactivated. However, under Section 252 only the companies, which are carrying on the business, can approach the Tribunal and the companies, which have no business, cannot approach the Tribunal for restoration. They submit that since the penal provision is given retrospective operation, de hors the above scheme, they are entitled to invoke the jurisdiction of this court under Article 226 of the Constitution of India. 10. With the above contentions, learned counsel sought to set aside the impugned orders and to allow the writ petitions. 11. On the other hand learned Assistant Solicitor General submits that failure to file financial statements or annual returns For any continuous period of three financial years, automatically entail their disqualification und Section 164(2)(a) of the Act and the statute does not provide for issuance of any notice, Hence, the petitioners, who have failed to comply wlth the statutory requirement under Section 164 of the Act, cannot complain of violatlon of principles of natural justice, as it is a deeming provision. Learned counsel further submits that the petitioners have alternative remedy of appeal under Section 252 of ll',e Act, and hence writ petitions may not be en te rta in ed. -+ L2. To consider the contention of the learned Assistant Solicitor General with regard to alternative remedy Act, the said provision is required to extracted as under for better appreciation: of appeal under Sectron 252 of the be considered, and the same is 252. Appeal to Tribunal: (1) Any person aggrieved by an order of the Registrar, notifying a company as dissolved under Section 248, may file an appeal to the Tribunal within a period of three years from the date of the order of the Reqistrar and if the Tribunal is of the opinion that the removal of the name of the company from the register of companies is not justified in view of the absence of any of the grounds on which the order was passed by the Registrar, it may order restoration of the name of the company rn the register of com pa nies; Provided that before passing an order under this section, the Tribunal shall give a reasonable opportunity of making representations and of being heard to the Registrar, the company and all the persons concerned: Provided further that if the Registrar is satisfed, that the name of the company has been struck off from the register of companres either inadvertently or on basis of incorrect information furnished by the company or its directors, which requires restoratron in the register of companies, he may within a period of three years from the date of passing of the order dissolving the company under Section 248, file an applrcation before the Tribunal seeking restoration of name of such com pany. (2) A copy of the order passed by the Trlbunal shall be f led by the company with the Registrar within thirty days from the date of the order and on receipt of the order, the Registrar shall cause the name of the company to be restored in the register of companies and shall issue a fresh certifrcate of incorporation. (3) if a company, or any member or creditor or workcT thereoF feels aggfleved by the company having rts name struck off from the registcr of companies, the Tribunal or an applicaton made by the compafy, member, crcditor or workman before the expiry of twenty years from the publrcation in the Officia Gazette of the notice under sub-section (5) of Section 248, if satisfied that the company was, at the time of its name being struck off, carrying on business or in operation or otherwise it is just that the name of the company be restored to the register of companies, order the name of the company to be restored to the register of companies, and the Tribunal may, by the order, give such other directions and make such provisions as deemed just for placing the company and all other persons in the same position as nearly as may be as if the name of the company has not been struck off from the register of companies. 5 A reading of above provision goes to show that if the company is dissolved under Section 248 of the Act, any person aggrieved by the same, can file an appeal. Thus the said provision provides the forum for redressal against the dissolution and striking off the company from the register of companies. It does not deal with the disqualiFication of the directors, and deactivation of their DINs. In the present case, the petitioners are only aggrieved by their disqualification as directors and deactivation of DINs, but not about striking off companies as such. Hence, Section 252 of the Act, cannot be an alternative remedy for seeking that relief, and the contention of the learned Assistant Solicitor General, in this regard, merits for rejection. 13. Under Section rca(2)(a) of the Act, if the Director of a company fails to file financial statements or annual returns for any continuous period of three financial years, he shall not be eligible to be re-appointed as a director of that company or appointed in other company for a period of five years from the date on which the said company fails to do so. The sald provision under the Act 18 of 2013, came into force with effect from 01.O4.2074, and the petitioners are disquallfied as directors under the said provision. At this stage, the issue that arises for consideration is - whether the disqualification envisaged under Section 164(2)(a) of the Act, which provision came into force with effect from 07.04.2014, can be made applicable with prospective effect, or has to be given retrospective operation? In other words, the issue would be, from which financial year, the default envisaged under Section 76a(2)(a) of the Act, has to be calculated, to hold the director of the company liable? In this regard, the learned counsel brought to the notice of this Court, the General Circular No.08/14 dated 4.4.2074 issued by the Ministry of Corporation affalrs, which clarifies the applicability of the relevant financial years. The relevant portion of the said circular is as under: \"A number of provisrons of the Companies Act, 2013 including those relatrng to marntenance of books of account, preparation, adoption and filrng of flnancial statements (and documents requared to be attached thereto), Auditors reports and the Board of Directors report (Board's report) have been brouqht tnto force wtth 6 effect from 1'!t April, 2014. Provisions of Schedule II (useful lives to cornpute depreciation) and Schedule III (format of financial statements) have also been brought into force from that date. The relevant Rules pertaining to these provisions have also been notified, placed on the website of the Ministry and have come into force from the same date. The Ivlinistry has received requests for clarifcation with regard to the relevant financial years wrth effect from which such provrsro s of the new Act retating to maintenance of books of account, preparation, adoption and filing of frnancial statements (and attachments thereto), audttors report and Board,s reOort ,!ill be applicable. Although the posltion in this behaif rs qurte clear, to make th ngs absolutely clear it is hereby notified that the financial statements (and documents required to be attached thereto), auditors report and Board's report in respect of frr.tancral years that commenced earlier than 1't April shall be governed by the relevant provisrons/scheduies/rules of the Companies Act, 1956 and that tn respect of Financial years commencing on or after lstApril, 2014, the provlsions oF the new Act shall apply. \" A reading of the above circular makes it clear the financial statements and the documents required to be attached thereto, auditors report and Board,s report in respect of financial years that commenced earller than OI.04.2074, shall be governed by the provisions under the Companies Act, 1956 and in respect of financial years commencing on or after O1.04.2074, the provisions of the new Act shall apply. 14. At this stage it is required to be noticed that the analogous provision to Section t6 Q)@) of rhe Act 18 of 2013, is Section 27ae)@) of Act 1 of 1956. The said provision under Act 1 of 1956 is extracted as under for ready reference: Section 274(1) A person shall not be capable of bernq appornted dlrector of a company, if - (g) such person is already a director of a publtc company which, - (A) has not filed the annual accounts and annual Teturns For any continuous three financial years commencing on and after the first day of Aprit, 1999; or (B) Provided that such person shall not be eligibte to be appointed as a director of any other public company for a period of five years from the date on which such public company, in which he is a director, failed to file annual accounts and annual returns under sub-clause (A) or has failed to repay its deposits or interest or redeem its debentures on due date or pay dividend referred to jn clause (B). A reading of the above provision under Act 1 of 1956, makes it clear that if a person capable of being appointed director of a company and such person is already a director of a public company, which has not filed annual accounts and annual returns for any continuous three financial years commencing on ,7 and after the first day of April 1999, shall not be eligible to be appointed as a director of any other public company for a period of five years from the date on which such public company, in which he is a director, falled to file annual accounts and annual returns. So the statutory requirement of filing annual accounts and annual returns, is placed on the directors of a 'public company'. There is no provislon under the Act 1of 1956, which places similar obligations on the directors of a 'private company'. Therefore, non- filing of annual accounts and annual returns by the directors of the private company, will not disqualify them as directors under the provisions of Act 1 of 1956. 15. Under Section 164(2) of the new legislation i.e., Act 18 of 2013, no such distinction between a 'private company' or a 'public company' is made and as per the said provision goes to show that no person who is or has been a director of a 'company', fails to file financial statements or annual returns for any continuous period of three financial years, will not be eligible for appointment as a director of a company. As already noted above, the said provision, came into force with effect from O1.04.2014. 16. Coming to the facts on hand, the 2\" respondent has disqualified the petitioners under Section l6a(2)(a) of the Act 18 of 2013, for not filing financial statements or annual returns, for period prior to 01.04.2014. The action of the 2'd respondent runs contrary to the circular issued by the tvlinistry of the Corporate Affairs, and he has given the provisions of Act 1B of 2013, retrospective effect, which is impermissible. 1.7. The Apex Court in COMMISSIONER OF INCOME TAX (CENTRAL)-L NEW DELHI v. VATTKA TOWNSHIP PRIVATE LIMITED! has dealt with the general principles concerning retrospectiv ity. The relevant portion of the judgment is thus: 27. A legislation, be it a statutory Act or a statutory Rule or a statutory Notlfication, may physically consists of words printed on papers. However, (1015)l S( C'l s conceptually Jt rS a great deal more (naa an orornarv , i,\",:,j,il:Ll\",i:,I:1\"\":1\"\"-?, .o\",;;\";;\";;,;; ;i\",, i,!\",il\" lr;!:,i:,\"\",,,,,\"ffJ rn a JUdgmenr or a courr ;i ;';^ \"tt^:T l',,-ts^rn a work tf frctronrnon i'.,,on\"o.'\"ru-, ::\"[,il::.'i\"t[1\"i'\"'j11.: l\"-n,:'\";;;'';,';'JliiX:;i;:::\"\"J;\"1i':3[3i:[ff: st\"tut\"-r,. -v,sl]u .\" ;;d;::. b: rouno in rhe vdrious pnncrples oF 'tnterDreratror or :ll\"t;*:ii:*1tftiJlff :::.\".i\"iJ.]ijn j;1\"J1;:,::l;::;t[.#*l 29. Of the vaflous rul estabirshed;L;.\";;\";r\",i\"\"^r- ?uiding how a tegistation has to be interpreted, one not to be intended to t.,\"uitt- u--1o\".u'y rntentron appears, a legisldtion ; ;;;;;r;;; tnut u.*r\"\"i,fu,*\"rnluio\",.\"^. *,.ospectrve operatror.. rhe,dei O\",,,nO-tn\"-l]iull [*111;*,:ir:ffii{f[ii#$ilii;::r,n]r:l*; j*,,*ti ::.'\"',l!\"\"| y:,.,:I, ;J\",.\"Jt:t on rhe bed ';.k l;; \";\"'; ;uman be,ns ,s enrired ro have -been ,\",.\".0\".i r\"i,i .t-q. on the exrstrnq law and should \"\", rroin\", i,r ri\"rl resprcrt : law rooks ,o.r\"\"..'\"\"' Thrs princrple of law '|s kr l*B7o) LR 6 oB ,r e ..;i^1-ol Pu'ky;,.d -;;;\"'\"\";;;\")J:I:\"';li;J,''\"?\"#: ir,ii qj ,,t I\"\"o\", '\"J; l'ill\"lli.'.lliJ';.i:[* : i:Tf Z,L:i:: *\"**:*::jgi tor the fjrst trme to deal with Furure u.,. orgni-nJ,.io?ul transaclrons carried on upon the rr,,,.l Jir]\" ii\"\"i\"i;il ilf: the cha.acter or pasr o,ii;rrlni,i,?l'\"fltrrb,\"i: ?l!': principre aea,nst rerrospecrrvity is the principre or oec,sron reported ,\" a,on,.l\" ao#l?,.:t ,::.\"tr\",'^\"g :ute as was observed in the .liiilli i,\"qi; ill,\"i'\"'3:ll.l ii i'-;i. H,;' ;'\"';;;l:;\", \";,IiT::'i\";.':::ll:; i=*1,::iltffi ff r,.:.r,,r,\"\"tritir;l\"if lr1iiF;1,ri\"H\"Tt[i an obvrous Omrssron in \" fn._\".,,j^,.]li, ls ror purpose oF supplyinO need not \"rt\" ,t \", .\"r\"r?\"o\",'I^e\"'-l-ee istatio', or to exDlarn \" r\"in,,\"'. l\"q'irrt,\"il 'wI teqat posrtion-ctei;; ;;\"\"#: or case law available on lhe sub]e* 0\".*r\" ,i\"*r\",i ,:T,T.\"\"*.':i#i,i;uiJigl\",,i:.1,\"\".1:?.::';\"a::._f ':i#.:,i';1r:;1\"* 30. We woLrlo atso lrke to be_aeF,t rs .onr\".reJ L\"v';;\";; oo'nt out' for the sake oF comDlete.ess, r.ar where a drfisrgll rr a rej,srarioi :;:l'l'\"\",, the rule against a rcrrospecr,ve construc.ron .s corrcsp_ondrng o\"ir#\"\"i \"i\"rl\"'s a benefit on some Dersons or, *,,'or, ,t .,'\"\"9 J ro con,er such beneFrr ,.\"jI::tl\"ll:jt?i-\"1 ?l rne pubr,c sc,rerd y. and whe,e presumptron *orto o\"',rfr\"i\"r r ru Iidve oeen tl'e ieo'slators oolect, tr.cn tr,J wourd warranr ,i i;o;;;\";: \"'::l'.:]:.,J:j:t::i:-,e,,lls ,t a p.r.pos,vc LonsLru(tjon, trear proccdurar p.ou,,1*, ; ;;;;;!i::',1;\"'\"lll .\"lf.il\"\".jl, 's ttse jusr,r,car,on r; I nd ian Tobacco Assocratton I1 oc rerevanr ractor ro Lonsrrue zo-os; iiii'igoi] .;\";;l l;;T:,.%,f1t\",\", ,,1$i,. I; s ven d rctrospe.r,r\" or\"\"u,,inttutYL t::1\": lg^: bensf 1,-'' tnc' conre t of ,t ro bc iH::: #i :,;,;\".:,I 1,,.;. I ?;t :j \", ;',^; \"i ; ;, ;; :,; ?;\" \"J \".\"\" ;,-'\":; \" i il, 0,,,# \"1 ro. rne be.eri ;;'.;,;l;:;:l,'-:c.c 2:e1 lt was herd tn\"i *r.,\"r-\" a raw ,s ena*ed ::1tjre rnay o\"- n\",o ,\" \"0\" ,r\"\",t\":r::,\",,1? ,\"rr\"*,,,i.\",n\" ;:;\"\"1.\" \", \" p.o,,r,on -iii contronted wlth any such sttuatlon here. 'er, we are (src not) 31. In such cases, retr( ;:ll jx,',*'i:l;:ili-::.;si:]*.i;i:'i'j\"8,;\"\"\"'\"#1i:,:lt,\",LT::J',;: ;?\"?:j:i\"_ii1:j.};uiilJ:i j:i\"\",.,:':fl \".T\",::,[..,3J:.S;1JJ:#,\",:ff *'#: to proceed with the normal .,1:. u^ttu-tt\"u' Therefore, in a case trr
Other Referred Cases
WP No.5422 of 2018 & batch, COMMISSIONER OF INCOME TAX (CENTRAL)-L NEW DELHI v. VATTKA TOWNSHIP PRIVATE LIMITED, GAURANG BALVANTLAL SHAH S/O BALVANTLAL SHAH vs. UNION OF INDIA, BHAGAVAN DAS DHANANJAYA DAS vs. UNION OF INDIA
Laws Referred To
Companies Act, 2013, Companies (Appointment of Directors) Rules, 2014, Constitution of India
Tax Holiday Secrets for Startups
₹0
Tax Holiday Secrets for Startups
₹0
Consultation on Entity Formation
₹0
Assignment of Registered Trademark
Mehul₹500
Memorandum of Understanding - Relevant for Revenue Sharing between Companies
Mehul₹500
From Endless Revisions to Timely Compliance: The New Era of TDS/TCS Rectification
Team Counselvise - January 30, 2026
Residency Rules: Income Tax Act, 1961 vs Income Tax Bill, 2025 — A Subtle Yet Significant Shift!
Team Counselvise - February 18, 2026
Transfer Pricing and International Tax Reforms under Finance Bill, 2026: A Practical Overview
Team Counselvise - February 07, 2026