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    <title>2011 (2) TMI 1327 - ALLAHABAD HIGH COURT</title>
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    <description>Liabilities arising before the rehabilitation scheme cut-off date remain outstanding dues under section 22 of the Sick Industrial Companies (Special Provisions) Act, 1985, even where a later reassessment order quantifies them after remand. The operative distinction is between pre-cut-off liabilities and current dues: only amounts arising after the cut-off date fall outside the scheme as current dues. On that basis, tax and penalty demands relating to earlier assessment years were treated as covered by the rehabilitation framework, and recovery action based on the later reassessment orders was not permitted to proceed outside that framework.</description>
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    <pubDate>Fri, 11 Feb 2011 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=166485</link>
      <description>Liabilities arising before the rehabilitation scheme cut-off date remain outstanding dues under section 22 of the Sick Industrial Companies (Special Provisions) Act, 1985, even where a later reassessment order quantifies them after remand. The operative distinction is between pre-cut-off liabilities and current dues: only amounts arising after the cut-off date fall outside the scheme as current dues. On that basis, tax and penalty demands relating to earlier assessment years were treated as covered by the rehabilitation framework, and recovery action based on the later reassessment orders was not permitted to proceed outside that framework.</description>
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