https://www.taxtmi.com/caselaws?id=19319 Refund arising after vesting of an undertaking could not be adjusted against liabilities attributable to periods before the appointed day, because the acquisition statute preserved a specific liability scheme and liabilities outside section 5(2) could not be enforced against the Central Government, State Government, or the Government company. The High Court also held that refusing to examine the revision on delay alone was unjustified where the statutory vesting and liability framework required merits-based consideration. The adjustment order was quashed and the Commissioner was directed to decide the matter on merits. en-us Thu, 27 Oct 1994 00:00:00 +0530 Thu, 05 Nov 2009 13:34:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=19319 Refund arising after vesting of an undertaking could not be adjusted against liabilities attributable to periods before the appointed day, because the acquisition statute preserved a specific liability scheme and liabilities outside section 5(2) could not be enforced against the Central Government, State Government, or the Government company. The High Court also held that refusing to examine the revision on delay alone was unjustified where the statutory vesting and liability framework required merits-based consideration. The adjustment order was quashed and the Commissioner was directed to decide the matter on merits. Case-Laws Income Tax Thu, 27 Oct 1994 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=19319