Personal settlement under tax investigation law does not release other heirs from separate statutory liability for unpaid dues.

A settlement under section 8A(1) of the Taxation on Income (Investigation Commission) Act, 1947 is personal to the applicant and operates only for the matters covered by that composition. Where one branch of a deceased assessee's legal representatives accepted such a composition, it did not extinguish the separate statutory liability of the other legal representative for the deceased's tax dues. The unpaid balance attributable to concealed income could still be recovered from the remaining legal representative to the extent of the deceased's assets in his possession or later received by him.

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Issues: Whether a composition accepted under section 8A(1) of the Taxation on Income (Investigation Commission) Act, 1947, by one branch of the deceased assessee's legal representatives discharged the liability of the other legal representative, and whether the remaining legal representative could still be proceeded against for the unpaid balance of tax attributable to the concealed income.

Analysis: The liability arose not from any contractual obligation but from the statutory scheme governing proceedings before the Investigation Commission and subsequent assessment. Section 8(2) empowered the Central Government to direct proceedings against the person to whose case the report related, which in this case meant the deceased assessee and, after his death, his legal representatives. Section 8A(1) specifically limited a settlement to the person who applied for it and provided that the investigation would be deemed closed only so far as it related to matters covered by that settlement. The composition entered into by one branch of the heirs therefore operated only for that branch. It did not extinguish the entire tax liability already accepted by all the legal representatives, nor did it prevent recovery of the unpaid balance from the appellant to the extent he held, or later came into possession of, assets of the deceased.

Conclusion: The composition did not discharge the appellant's statutory liability, and he remained liable for the balance of the tax.

Ratio Decidendi: A settlement under section 8A(1) of the Act is personal to the applicant and does not release other legal representatives from their separate statutory liability for the deceased's tax dues.

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