Legal representative liability for deceased taxpayer's income is limited to estate available for tax recovery.

Liability for income-tax assessed on a deceased person's income under section 24B(1) attaches only to an executor, administrator, or other legal representative, and only to the extent of the estate available to satisfy the tax. On the stated facts, the petitioner had not derived any property or benefit from his mother's estate under her will or codicil, and his status as her son or as a legatee under his father's will did not make him her legal representative for this purpose. The demand raised against him was therefore unsustainable.

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Issues: Whether the petitioner could be treated as the legal representative of his deceased mother for the purpose of fastening liability for the income-tax assessed on her income.

Analysis: Liability under section 24B(1) arises only against the executor, administrator or other legal representative of the deceased and is limited to the extent of the estate capable of meeting the tax. On the facts found, the petitioner did not derive any property or benefit from his mother's estate under her will or codicil, and the assessments related to his mother's own income for the relevant years. Mere status as a son or as a legatee under his father's will did not make him the legal representative of his mother for purposes of the section.

Conclusion: The petitioner was not liable under section 24B(1) as the legal representative of his mother, and the demand raised against him was unsustainable.

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