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Determining legal representation for tax liability of deceased individual. Analysis: The judgment revolves around the issue of whether the petitioner can be considered the legal representative of his deceased mother for the purpose of bearing her income tax liability. The Income Tax Officer assessed the petitioner as the legal representative under section 24B of the Indian Income Tax Act. The petitioner's mother, Mahalakshmamma, had properties bequeathed to the petitioner's brother, and the petitioner had no right or interest in those properties. The Income Tax Officer demanded payment of half the assessed tax from the petitioner, claiming he was the legal representative. The petitioner contested the demand, arguing that he did not inherit any property from his mother and thus could not be considered her legal representative. The Commissioner of Income Tax erroneously dismissed the revision, stating that the assessment was based on the income from the properties of the petitioner's father, not the mother. However, the court clarified that under section 24B, a legal representative is liable to pay the deceased's tax out of the estate, and in this case, the petitioner did not inherit anything from his mother's estate. The court concluded that since the petitioner did not receive any assets from his mother's estate and the assessments pertained to her income, he could not be deemed the legal representative. Therefore, the court allowed the writ petitions, issuing a writ of mandamus in favor of the petitioner. The petitioner was granted costs in one writ petition, and the costs were to be paid by the second respondent, the Income Tax Officer. In summary, the judgment clarifies the legal representation for tax liability of a deceased individual under the Income Tax Act, emphasizing the requirement of inheriting assets from the deceased's estate to be considered a legal representative liable for tax payments.
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