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Case lawCBDT Circulars & Instructions › Statutory position — s.160: the five, and only five, classes of representative assessee, and what Explanations 1 and 2 do to an unwritten trust
CBDT Circulars & InstructionsCuts both wayss.160s.160(1)(i)s.160(1)(ii)s.160(1)(iii)s.160(1)(iv)s.160(1)(v)s.160(2)s.163s.9(1)s.161s.164s.164A

Statutory position — s.160: the five, and only five, classes of representative assessee, and what Explanations 1 and 2 do to an unwritten trust

The Assessing Officer has issued a notice describing me as the 'representative assessee' of a family trust. Who can lawfully be made a representative assessee, and does being called one make me the assessee?

The Assessing Officer has issued a notice describing me as the 'representative assessee' of a family trust. Who can lawfully be made a representative assessee, and does being called one make me the assessee?

Section 160(1) is an exhaustive list of five classes and nobody outside it can be made a representative assessee: (i) the agent of a non-resident, in respect of income of the non-resident specified in section 9(1), including a person treated as an agent under section 163; (ii) the guardian or manager of a minor, lunatic or idiot who is entitled to receive or is in receipt of the income on that person's behalf; (iii) the Court of Wards, the Administrator-General, the Official Trustee or any receiver or manager (including any person, whatever his designation, who in fact manages property on behalf of another) appointed by or under an order of a court; (iv) a trustee appointed under a trust declared by a duly executed instrument in writing, whether testamentary or otherwise, including a wakf deed valid under the Mussalman Wakf Validating Act, 1913; and (v) a trustee appointed under an oral trust. Section 160(2) then says that every representative assessee shall be deemed to be an assessee for the purposes of the Act, so yes — you are an assessee, with an assessee's rights of appeal as well as an assessee's exposure.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2000-04-01, reported as Income-tax Act, 1961, s.160, as printed on departmental pages stamped Year 2000, Year 2022 and Year 2025. It bears on section 160, section 160(1)(i), section 160(1)(ii), section 160(1)(iii), section 160(1)(iv), section 160(1)(v), section 160(2), section 163, section 9(1), section 161, section 164, section 164A of the Income Tax Act 1961, in Charitable Trusts & Exemption, Assessment & Scrutiny and How Tax Law Is Read matters.

Still good law. Three departmental pages stamped Year 2000, Year 2022 and Year 2025 print word-for-word identical text for section 160, which is the best evidence obtainable on this pass that the section stands unamended over that span. That is not the same as reading the current Finance Act: no Finance Act text was retrieved this pass, no page stamped Year 2026 was located for this section, and no amendment footnote is printed on any of the three pages, so no commencement date is asserted and no post-2025 change is excluded.

Why it matters

Which clause you fall in decides the rate you pay, which is why the classification and not the label is what to fight about. A trustee under clause (iv) — a written or testamentary trust — is exposed to section 161(1A), which charges the WHOLE income at the maximum marginal rate if any part of it is profits and gains of business, and to section 164 if the beneficiaries' shares are indeterminate. A trustee under clause (v) — an oral trust — is in a worse place still: section 164A charges the whole of the income at the maximum marginal rate with no proviso at all. That is the practical work done by Explanation 1, which is a rescue provision that practitioners forget exists. A trust not declared by a duly executed instrument in writing is DEEMED, for the purposes of clause (iv), to be a trust so declared if a statement in writing signed by the trustee or trustees, setting out the purposes of the trust, particulars of the trustees, the beneficiaries and the trust property, is forwarded to the Assessing Officer — within three months of the declaration of the trust, or, for a trust declared before 1 June 1981, within three months from that day. File that statement in time and the trust is a clause (iv) trust with all of section 164's provisos available to it; miss it and Explanation 2 makes it an 'oral trust' and section 164A applies. Note also two things about clause (iii): it is not confined to court-appointed officers with formal titles, because it expressly picks up 'any person, whatever his designation, who in fact manages property on behalf of another' appointed by or under an order of a court; and clause (i) is limited to income 'specified in sub-section (1) of section 9' — a point worth taking where the Department seeks to make an agent liable for income that does not arise under section 9(1).

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

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Related

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