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Issues: Whether agricultural income-tax on income of land under a receiver's management could be assessed against the owner of the estate, or only against the receiver under the Act.
Analysis: Agricultural income-tax was chargeable under the charging provision on the total agricultural income of every person, and the income collected by the receiver remained the income of the owner. The provision dealing with land held by a receiver or similar person did not create the charge of tax but only provided a machinery for assessment and recovery by deeming such person to be an assessee in addition to the owner. The statutory definition of "person" also included a receiver, but that enlargement did not exempt the owner from assessment on the income received on his behalf.
Conclusion: The owner remained liable to be assessed to agricultural income-tax notwithstanding that the estate was in the hands of a receiver, and the question was answered against the assessee.
Final Conclusion: The appeal was rejected because the statutory scheme permitted assessment of the owner on agricultural income derived from the estate even during receivership.
Ratio Decidendi: A provision deeming a receiver or similar person to be an assessee operates as a recovery mechanism and does not displace the charging liability of the owner on whose behalf the agricultural income is received.