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    <title>1966 (4) TMI 91 - PATNA HIGH COURT</title>
    <link>https://www.taxtmi.com/caselaws?id=310953</link>
    <description>A trustee holding trust property under a duly executed trust deed was considered outside the representative assessment machinery of Section 21 of the Wealth-tax Act for the relevant valuation dates. Section 21 applies where assets are held on behalf of another person, and the liability is co-extensive with that person&#039;s liability. A trustee, however, is the legal owner of the trust property and holds it for the benefit of the beneficiaries, not on their behalf; the two expressions are not synonymous. The later amendment adding &quot;for the benefit of&quot; did not apply to the assessment years in question. The trustee was therefore not assessable to wealth-tax under Section 21.</description>
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    <pubDate>Wed, 13 Apr 1966 00:00:00 +0530</pubDate>
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      <title>1966 (4) TMI 91 - PATNA HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=310953</link>
      <description>A trustee holding trust property under a duly executed trust deed was considered outside the representative assessment machinery of Section 21 of the Wealth-tax Act for the relevant valuation dates. Section 21 applies where assets are held on behalf of another person, and the liability is co-extensive with that person&#039;s liability. A trustee, however, is the legal owner of the trust property and holds it for the benefit of the beneficiaries, not on their behalf; the two expressions are not synonymous. The later amendment adding &quot;for the benefit of&quot; did not apply to the assessment years in question. The trustee was therefore not assessable to wealth-tax under Section 21.</description>
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      <pubDate>Wed, 13 Apr 1966 00:00:00 +0530</pubDate>
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