Limitation of time is not a determining factor in matters relating to remission or cessation of liabilities

RELEVANT PARAGRAPH 9. From the rival positions of both the parties as well as the provisions of section 41(1) and the legal propositions of various judicial fora, the following issues have emerged. They are: (a) the issue of limitation of period of three years; (b) the issue of discharge of onus, when the assessee has not unilaterally written them off; (c) the issue of unilateral write off for the assessments of the post amendment period i.e. 1.4.1997. We shall proceed to analyze one by one in the succeeding paragraphs. (a). Regarding the issue of limitation of three years; it is noticed that ...