Section 24B limits tax liability after death to income tied to the relevant previous year, excluding later receipts by heirs.

Section 24B of the Income-tax Act, 1922 extends a deceased assessee's legal personality only to tax income received before death or income received by legal representatives during the previous year in which death occurred. The fiction is confined to that statutory purpose and cannot be enlarged to cover post-death receipts in later assessment years. On that construction, receipts obtained by the legal heirs after the assessee's death were not assessable to income-tax for the assessment years in issue.

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Issues: Whether section 24B of the Income-tax Act, 1922 authorises assessment of receipts obtained by the legal heirs of a deceased assessee in assessment years subsequent to the previous year in which the assessee died.

Analysis: Section 24B extends the legal personality of a deceased assessee only for the purpose of bringing to tax income received by him before death or income received by his legal representatives during the previous year in which death occurred. The provision does not create a general liability to tax all post-death receipts in later assessment years. The fiction created by the section is confined to the object for which it was enacted and cannot be enlarged beyond the statutory scheme of assessment of total income for the relevant previous year.

Conclusion: Section 24B did not apply to the receipts in question, as they were not income received in the relevant previous year. The amounts were not assessable to income-tax in the hands of the legal heirs for the assessment years in issue.

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