Shri Om Parkash Legal Heiar Smt Pushpa ... vs Income Tax Officer Ward-1(3), ... on 31 October, 2018
Again, the
period for which the liability had remained unpaid, i.e., as at the end of the relevant
year, etc., are all matters of fact, again, emphasizing, if one was still necessary, that
the matter as to whether a liability subsists as at the year-end or not is essentially
factual, even as clarified in several decisions that have travelled to the Hon'ble
higher courts of law (refer, inter alia, CIT v. Autopins India [1991] 191 ITR 161
(Del); CIT v. Jaipur Oil Products Pvt. Ltd. [1994] 206 ITR 90 (Raj); CIT v. Sea
Pearl Industries [1995] 211 ITR 508 (Ker)).