Trust property and joint interest under agricultural income-tax law require an agency-like holding, not mere beneficial ownership.

Section 11(1) of the U.P. Agricultural Income-tax Act, 1948 applies only where land is held by a common manager, receiver, administrator or similar person on behalf of persons jointly interested in the land or the agricultural income. A trustee, though the legal owner of trust property, holds it for the benefit of beneficiaries and not on their behalf, so the necessary agency or representative relationship is absent. The phrase "jointly interested" requires an undivided legal interest, not merely separate beneficial interests under a trust deed. The trustees therefore fell outside section 11(1), and the beneficiaries were not jointly interested in the land or its income.

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Issues: Whether trustees holding an estate under a trust can be said to hold land on behalf of beneficiaries, and whether the beneficiaries can be said to be jointly interested in the land or in the agricultural income derived therefrom so as to attract section 11(1) of the U.P. Agricultural Income-tax Act, 1948.

Analysis: Section 11(1) applies only when land is held by a common manager, receiver, administrator or the like on behalf of persons jointly interested in the land or in the agricultural income derived therefrom, so that tax is computed with reference to the aggregate of the sums payable by each such person. The expression "on behalf of" imports an agency or representative relationship, not the position of a legal owner holding property for the benefit of another. Under trust law, the trustee is the legal owner of the trust property and holds it for the benefit of the beneficiaries, but not on their behalf. The words "jointly interested" denote an undivided legal interest, not merely a common or separate beneficial interest under different annuities. On the deed of trust, each annuitant had a separate and individual interest in the income to the extent of the annuity payable to him or her.

Conclusion: Section 11(1) did not apply. The trustees did not hold the land on behalf of the beneficiaries, and the beneficiaries were not jointly interested in the land or in the agricultural income derived therefrom.

Ratio Decidendi: A trustee, as legal owner of trust property, holds it for the benefit of the beneficiaries but not on their behalf; section 11(1) of the U.P. Agricultural Income-tax Act, 1948 applies only where the holder acts as an agent or representative of persons jointly interested in the land or its income.

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