https://www.taxtmi.com/caselaws?id=22098 Section 4 of the Income-tax Act, 1961 was construed as taxing an association of persons in its own hands where it is the recipient of income, because the Act does not contain the 1922 Act's express basis for splitting income and assessing members individually. Applying strict construction of taxing statutes, the Court held that no charge or alternative incidence of tax can be implied from general charging language. Section 86 did not change that position on these facts. The Tribunal therefore lacked authority to direct division of capital gains among the members of the association of persons, and the reference was answered against the Revenue. en-us Wed, 26 Jun 1991 00:00:00 +0530 Mon, 07 Dec 2009 11:02:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=22098 Section 4 of the Income-tax Act, 1961 was construed as taxing an association of persons in its own hands where it is the recipient of income, because the Act does not contain the 1922 Act's express basis for splitting income and assessing members individually. Applying strict construction of taxing statutes, the Court held that no charge or alternative incidence of tax can be implied from general charging language. Section 86 did not change that position on these facts. The Tribunal therefore lacked authority to direct division of capital gains among the members of the association of persons, and the reference was answered against the Revenue. Case-Laws Income Tax Wed, 26 Jun 1991 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=22098