https://www.taxtmi.com/caselaws?id=308947 Orders purporting to treat a person as a representative/agent under section 163 must be made by an authority competent under the tax statute; a Commissioner lacks power to issue such an order in the circumstances described, and an order by the Commissioner is quashed. Where the principal has already been validly assessed for the relevant income, no separate assessment can be sustained against an alleged representative for the same income. If the principal has been liquidated or extinguished prior to proceedings, the statutory scheme contains no mechanism to treat another person as representative; consequently subsequent orders dependent on such treatment fall and appeals are allowed. en-us Mon, 19 Dec 2022 00:00:00 +0530 Wed, 02 Aug 2023 21:18:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=308947 Orders purporting to treat a person as a representative/agent under section 163 must be made by an authority competent under the tax statute; a Commissioner lacks power to issue such an order in the circumstances described, and an order by the Commissioner is quashed. Where the principal has already been validly assessed for the relevant income, no separate assessment can be sustained against an alleged representative for the same income. If the principal has been liquidated or extinguished prior to proceedings, the statutory scheme contains no mechanism to treat another person as representative; consequently subsequent orders dependent on such treatment fall and appeals are allowed. Case-Laws Income Tax Mon, 19 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=308947