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    <title>1961 (11) TMI 81 - ALLAHABAD HIGH COURT</title>
    <link>https://www.taxtmi.com/caselaws?id=285072</link>
    <description>A legal representative assessed under section 24B of the Income-tax Act, 1922 was treated as an assessee for liability and enforcement purposes, so the statutory fiction was not limited to assessment alone. The court held that the distinction between the expressions &quot;assessee&quot; and &quot;every person liable to pay&quot; did not prevent enforcement action, because section 24B created vicarious liability carrying full legal consequences. Accordingly, where the legal representative defaulted in paying the tax due, penalty under section 46(1) was validly attracted. The objection that the orders were made against a dead person was rejected because they were passed against the legal representative himself.</description>
    <language>en-us</language>
    <pubDate>Fri, 24 Nov 1961 00:00:00 +0530</pubDate>
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      <title>1961 (11) TMI 81 - ALLAHABAD HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=285072</link>
      <description>A legal representative assessed under section 24B of the Income-tax Act, 1922 was treated as an assessee for liability and enforcement purposes, so the statutory fiction was not limited to assessment alone. The court held that the distinction between the expressions &quot;assessee&quot; and &quot;every person liable to pay&quot; did not prevent enforcement action, because section 24B created vicarious liability carrying full legal consequences. Accordingly, where the legal representative defaulted in paying the tax due, penalty under section 46(1) was validly attracted. The objection that the orders were made against a dead person was rejected because they were passed against the legal representative himself.</description>
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      <pubDate>Fri, 24 Nov 1961 00:00:00 +0530</pubDate>
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