Dismissing the appeal of the revenue, the Court held that it was not the Department’s case that the net present value of the tax of Rs. 31.75 crores payable after twelve years was not Rs. 5.94 crores. Therefore, the assignment of liability for the value of Rs. 5.94 crores would not constitute a cessation of liability, as, upon such assignment at that value, the entire liability to pay the tax stood discharged. Therefore, the claim that section 41(1) of the Act was attracted was misconceived..(AY. 1999-2000, 2000-01)