Liability on transfer of business: transferor and transferee bear joint and several responsibility for pre transfer tax liabilities. When a taxable person transfers a business in whole or part by any mode, the transferor and transferee are jointly and severally liable for tax, interest and penalties attributable to the transferor up to the date of transfer, whether determined before or after transfer. On transfer by death of a sole proprietor, the transferee is liable for supplies made from the date of transfer and must amend registration where applicable.