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    <title>1966 (4) TMI 10 - PATNA High Court</title>
    <link>https://www.taxtmi.com/caselaws?id=6849</link>
    <description>A trustee holding trust property for the benefit of beneficiaries is not assessable to wealth-tax under section 21 unless the assets are held on their behalf within the statutory meaning. The Court treated representative assessment as co-extensive with the liability of the person for whom the assets are held, but found that &quot;on behalf of&quot; is materially different from &quot;for the benefit of&quot;. As the trustee held the trust estate as legal owner for the beneficiaries and not on their behalf, section 21 was not attracted. Section 3 also did not sustain a representative assessment because the beneficiaries were not liable in the required manner.</description>
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    <pubDate>Wed, 13 Apr 1966 00:00:00 +0530</pubDate>
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      <title>1966 (4) TMI 10 - PATNA High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=6849</link>
      <description>A trustee holding trust property for the benefit of beneficiaries is not assessable to wealth-tax under section 21 unless the assets are held on their behalf within the statutory meaning. The Court treated representative assessment as co-extensive with the liability of the person for whom the assets are held, but found that &quot;on behalf of&quot; is materially different from &quot;for the benefit of&quot;. As the trustee held the trust estate as legal owner for the beneficiaries and not on their behalf, section 21 was not attracted. Section 3 also did not sustain a representative assessment because the beneficiaries were not liable in the required manner.</description>
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      <pubDate>Wed, 13 Apr 1966 00:00:00 +0530</pubDate>
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