Comparison of section 304 'Liability of representative assessee.' between the Income-Tax Act, 2025 (as passed) and the Income-Tax Bill, 2025 (as originally introduced)

Representative assessee treated as beneficial owner for assessment; exclusivity, recovery from beneficial owner, limited deeming to assessment

The provision treats a representative assessee as liable for income as if beneficially owned, permitting assessment in the representative's name, imposing exclusivity against other assessments, and authorizing recovery or direct assessment from the underlying beneficial owner; it prescribes a pro rata formula where only part of a trust's income is chargeable and grants the tax authority equivalent remedies against property under the representative's control. The enacted text narrows earlier bill language by limiting the deeming clause to 'assessment' (omitting 'any other proceedings'), creating potential procedural uncertainty over whether non-assessment actions must be brought in the representative's name.