Representative assessment of estate receivers must follow beneficiary status, not treat the receiver as a separate taxable unit.

Under the Madras Agricultural Income-tax Act, 1955, a receiver of an estate was not an independent unit of assessment for the entire agricultural income. Section 3 taxes the total agricultural income of every person, and Section 8(1) shows that a receiver is liable only in a representative capacity, with tax recoverable as if it were from the person on whose behalf the income is received. The assessment therefore had to follow the status of the beneficiaries or persons entitled to the income, rather than treat the receiver as a separate assessee. The revision orders were set aside and the petitions succeeded.

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Issues: Whether, under the Madras Agricultural Income-tax Act, 1955, a receiver of an estate could be assessed as a separate unit on the entire agricultural income, or whether the assessment had to follow the status of the persons entitled to the income.

Analysis: Section 3 charges tax on the total agricultural income of every person, and "person" includes an individual or association of individuals owning or holding property, including through an agent or receiver. Section 8(1) expressly provides that tax leviable on a receiver is recoverable from the receiver in the same manner and to the same extent as it would be from the person on whose behalf the income is received, showing that the receiver has no independent status for assessment purposes. The assessment must therefore reflect the status of the person or persons entitled to the property and income, while the receiver is assessed only as the representative through whom the income is received.

Conclusion: The receiver could not be treated as an independent unit of assessment for the entire income; the assessment had to accord with the status of the beneficiaries. The revision orders were set aside and the petitions succeeded.

Ratio Decidendi: A receiver is assessable only in a representative capacity and, for income-tax purposes, his assessment must follow the status of the persons on whose behalf the income is received.

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