During the period in which the tax liability arose, disputes existed among the partners of the firm. One of the partners contended that he was a sleeping partner and had been excluded from the affairs of the partnership, allegedly taking advantage of his advanced age. It was also contended that the partnership firm had subsequently been dissolved pursuant to a judgment and decree of the Court; accordingly, it was not liable for the taxes. The Court held that, notwithstanding internal disputes among partners or the dissolution of the firm, all partners remain jointly and severally liable under section 188A for the tax liabilities incurred by the partnership firm during the relevant period. The plea that the partner was a sleeping partner or was not actively involved in the business was held to be irrelevant for the purpose of statutory liability. However, having regard to the peculiar facts of the case, including the advanced age of the partner, the Court directed that the impugned demand order shall remain stayed insofar as it related to the said partner, for a period of two months. (AY.  2017-18)