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1976 (11) TMI 79 - ITAT COCHINExtract: .......d liabilities of the firm itself. It may be true that S. 40A(2) might have applied in this case read with S. 37. But neither the Income-tax Officer nor the Appellate Assistant Commissioner had directed their attention to that question. It will not be fair to take up that line at the final stage of appeal. 18. For these reasons we allow the appeals.
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