2001 (2) TMI 19

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.... on which an assessment was made for the year 1962-63 the year preceding the dissolution of the firm. The property of the father in the hands of the sons is sought to be attached for the recovery of the tax arrears for that year. There is no dispute about the fact that the father died in the year 1958 and he could not be, and was not a partner in the firm in the year for which the assessment wa....

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...., so far as may be, shall apply to any such assessment or imposition of penalty or other sum." This sub-section, instead of supporting the Revenue, supports the stand of the assessee. It is clearly provided that the persons to be held liable are the persons who were partners at the time of such discontinuance or dissolution. In this case, the firm against which the assessment was made was disso....