Representative assessee liability: tax and assessment obligations treat representative as if beneficial owner, with direct recovery possible. A representative assessee is subject to the same duties and liabilities as if the income were beneficially theirs, is liable to assessment and proceedings in their own name in a representative capacity, and tax on such income shall be levied and recovered from them 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, and has the same remedies against property of the representative assessee as against property of any person liable to pay tax. Where only part of a trust's income is chargeable, the beneficiary's chargeable share is apportioned by the ratio of the chargeable part to the whole trust income multiplied by the beneficiary's receivable income.
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Provisions expressly mentioned in the judgment/order text.
Representative assessee liability: tax and assessment obligations treat representative as if beneficial owner, with direct recovery possible.
A representative assessee is subject to the same duties and liabilities as if the income were beneficially theirs, is liable to assessment and proceedings in their own name in a representative capacity, and tax on such income shall be levied and recovered from them 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, and has the same remedies against property of the representative assessee as against property of any person liable to pay tax. Where only part of a trust's income is chargeable, the beneficiary's chargeable share is apportioned by the ratio of the chargeable part to the whole trust income multiplied by the beneficiary's receivable income.
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