1993 (9) TMI 73

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..... ppellate Tribunal (hereinafter referred to as "the Tribunal") to this court for decision : "Whether, on the facts and in the circumstances of the case, the Tribunal was justified in rejecting the claim of the assessee for the income-tax and wealth-tax liabilities as claimed by the assessee ?" The assessee claimed the deduction of the following liabilities for the assessment year 1971-72: Rs. .....

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..... al, the Commissioner of Income-tax (Appeals) observed for the assessment year 1971-72 as under: " It was admitted by Shri Verma, learned counsel for the appellant, that these liabilities were more than 12 months old and some of them were continuing for the last several years. Moreover, no evidence was produced before me showing that the appellant was liable to pay liabilities in respect of Bharat .....

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..... nce to establish the claim. As to what was the liability discharged in the instant case was on the assessee. It was his burden to have brought evidence to the satisfaction of the authorities establishing the same. The assessee did not discharge the same. The argument of learned counsel for the petitioner was that, since the dispute was between the Income-tax Department and the assessee the burden .....

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