Joint and Several Liability: partners remain responsible for firm tax, interest and penalties despite discontinuance or reconstitution.

Section 94 provides that when a firm, association of persons or HUF discontinues, tax, interest and penalty may be determined as if no discontinuance occurred, and every partner or member at the time remains jointly and severally liable for amounts determined or penalties imposed; similar joint and several liability attaches on change of constitution, dissolution or partition. A Limited Liability Partnership is treated as a firm and "court" is defined for these provisions.

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