Representative assessee liability: representative assessed in own name and tax recoverable from representative or beneficiary directly.

Representative provisions render a person acting for another subject to the same duties and liabilities as if the income were beneficially his; he is liable to assessment in his own name and tax is leviable and recoverable from him as from the person represented. The Assessing Officer may nonetheless assess or recover tax directly from the person for whose benefit the income is receivable. Where only part of a trust's income is chargeable, a beneficiary's taxable share is determined by the proportion of chargeable income to total trust income multiplied by the beneficiary's receipt, and the Assessing Officer has equivalent remedies against property under the representative's control.

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