Forged Form F cannot sustain tax liability when signatures and execution are unreliable.

Liability for arrears of tax could not be fastened on the petitioner or the legal heirs where the foundational Form F was found to bear forged signatures and lacked reliable execution. The court compared the form with contemporaneous records, including a power of attorney and a sale deed, and found material inconsistencies in dates, notarial endorsement, and signature style. As the document was treated as a clear imitation rather than a genuine instrument, it could not support recovery of tax demand against the petitioner or the wife's estate.

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Issues: Whether the petitioner and the legal heirs could be fastened with liability for the arrears of tax on the basis of Form F, when the execution and signatures on that form were found to be forged.

Analysis: Form F was compared with other contemporaneous documents such as the power of attorney and the sale deed. The dates on the form and the notarial endorsement did not tally, and the signatures of the deceased petitioner and his wife varied materially from their signatures on other registered documents. On that comparison, the signatures in Form F were found to be clear imitations. In the absence of a genuine execution, the document could not be used to impose liability on the petitioner or his wife.

Conclusion: The petitioner and the legal heirs were not liable to be fastened with the tax demand on the basis of the forged Form F.

Ratio Decidendi: A tax demand cannot be sustained against a person when the foundational document relied upon for fastening liability is found to bear forged signatures and lacks reliable execution.

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