TMI Blog2019 (1) TMI 1761X X X X Extracts X X X X X X X X Extracts X X X X ..... ing repayments - HELD THAT:- It is well settled through series of judgments that merely because a debt has not been repaid for over three years, would not automatically imply cessation of liability. Exhaustion of period of limitation may prevent filing of recovery proceedings in a Court of law, nevertheless it cannot be stated by itself that the liability to repay the amount had ceased. Going b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nces of the case and in Law, the Hon. ITAT was justified in upholding the decision of the Ld. CIT(A) by completely ignoring the contention of the revenue in respect of violation of Rule 46A of the I T Rules, 1962 ? 2. Whether on the facts and circumstances of the case and in Law, the Hon. ITAT was justified in upholding the decision of the Ld. CIT(A) wherein the addition by the A.O., by invokin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... roduced before the Commissioner (Appeals). The Commissioner (Appeals) allowed the Appeal upon which the Revenue approached the Tribunal. The Tribunal by the impugned judgment dismissed the Revenue's Appeal. The Tribunal noted that the assessee was unable to repay the creditors because of weak financial position and further that the assessee had never completely stopped making repayments. The T ..... X X X X Extracts X X X X X X X X Extracts X X X X
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