https://www.taxtmi.com/caselaws?id=291588 Section 69(2) of the Rangoon Development Trust Act placed liability to collect and pay terminal tax on the owner of the vessel, while section 69(3) referred to owner and agent only for returns. Rules made under section 95 could not enlarge that statutory liability, so the provisions purporting to impose tax liability on agents were ultra vires. Because the respondents were only agents and not persons liable for the tax, the statutory preconditions for demand and attachment under the Lower Burma Land and Revenue Act were not met. The demand and recovery proceedings were therefore without jurisdiction and void, and the affected property was entitled to be released from attachment. en-us Tue, 14 Jun 1932 00:00:00 +0530 Wed, 18 Nov 2020 13:53:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=291588 Section 69(2) of the Rangoon Development Trust Act placed liability to collect and pay terminal tax on the owner of the vessel, while section 69(3) referred to owner and agent only for returns. Rules made under section 95 could not enlarge that statutory liability, so the provisions purporting to impose tax liability on agents were ultra vires. Because the respondents were only agents and not persons liable for the tax, the statutory preconditions for demand and attachment under the Lower Burma Land and Revenue Act were not met. The demand and recovery proceedings were therefore without jurisdiction and void, and the affected property was entitled to be released from attachment. Case-Laws Income Tax Tue, 14 Jun 1932 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=291588