Life tenant tax liability cannot pass to a remainderman absent devolution of the deceased's estate.

Liability for agricultural income-tax under the Agricultural Income-tax Act, 1950 attaches to the person who received the income, and on death it can pass only to the deceased's executor, administrator or legal representatives under section 24, and only out of the deceased's estate. A life interest that ends on death does not survive as property capable of devolution. On that basis, a remainderman taking under an independent title under the will and family law was not the deceased life tenant's legal representative, because no part of the deceased's estate in the properties devolved on her. The remainderman was therefore not liable for the deceased's agricultural income-tax arrears.

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Issues: Whether a remainderman can be treated as the legal representative of a deceased life-estate holder and made liable for agricultural income-tax arrears under the Agricultural Income-tax Act, 1950.

Analysis: The tax scheme under sections 3(1), 4(1), 17 and 18 of the Act fastens liability on the person who receives the agricultural income and requires assessment of the income received by him. Section 24 extends liability after death only to the deceased person's executor, administrator or legal representatives, and only out of the estate of the deceased. A life interest that is extinguished on death does not survive as an estate capable of devolution. The remainderman did not take through the deceased life tenant, but by an independent title under the will and the governing family law. Since no part of the deceased's estate in the properties survived and devolved on the remainderman, she could not be treated as the legal representative for purposes of section 24.

Conclusion: A remainderman is not liable as the legal representative of a deceased life-estate holder for agricultural income-tax due from the deceased.

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