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Case lawCBDT Circulars & Instructions › Statutory position — s.161(1) and (2): the representative assessee is taxed 'in like manner and to the same extent' as the person represented, and cannot be assessed under any other provision
CBDT Circulars & InstructionsCuts both wayss.161s.161(1)s.161(1A)s.161(2)s.160s.160(1)(iv)s.162s.164s.166

Statutory position — s.161(1) and (2): the representative assessee is taxed 'in like manner and to the same extent' as the person represented, and cannot be assessed under any other provision

The Assessing Officer has assessed our trust in one order on the whole of the trust income at slab rates of its own. The shares of the beneficiaries are fixed and known. Is that how section 161 works?

The Assessing Officer has assessed our trust in one order on the whole of the trust income at slab rates of its own. The shares of the beneficiaries are fixed and known. Is that how section 161 works?

No. Section 161(1) makes the representative assessee liable to assessment in his own name, but it deems that assessment to be made upon him in his representative capacity only, and it caps the charge: the tax 'shall, subject to the other provisions contained in this Chapter, be levied upon and recovered from him in like manner and to the same extent as it would be leviable upon and recoverable from the person represented by him'. Where the shares are determinate the measure of the trustee's liability is therefore the liability of each beneficiary separately, not a single composite charge on the trust. Section 161(2) is the other half of the protection: where a person is assessable under Chapter XV in the capacity of a representative assessee, he shall not, in respect of that income, be assessed under any other provision of the Act.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2000-04-01, reported as Income-tax Act, 1961, s.161(1) and (2), as printed identically on departmental pages stamped Year 2000, 2018, 2019 (No. 1), 2022, 2023, 2024 (No. 1), 2024 (No. 2) and 2025. It bears on section 161, section 161(1), section 161(1A), section 161(2), section 160, section 160(1)(iv), section 162, section 164, section 166 of the Income Tax Act 1961, in Charitable Trusts & Exemption, Assessment & Scrutiny and How Tax Law Is Read matters.

Still good law. Eight departmental pages spanning Year 2000 to Year 2025 print sub-sections (1) and (2) word for word identically, which is the best evidence obtainable this pass that they stand unamended over that span. No page stamped Year 2026 was located for this section, no Finance Act text was read, and no later treatment was checked, so nothing later than the Year 2025 page is certified.

Why it matters

Two practical consequences follow from the words 'in like manner and to the same extent', and Assessing Officers routinely get one of them wrong in the taxpayer's favour and the other against him. In like manner means the assessment on the trustee is made in the same status and under the same computation provisions as would apply to the beneficiary, so a deduction or an exemption the beneficiary would have got is not lost merely because the trust is the assessee. To the same extent means the trustee's exposure is the beneficiary's exposure — which cuts both ways, because the rate is the rate applicable to that beneficiary's TOTAL income, including his income from outside the trust, and not merely the rate that his share of the trust income would attract standing alone. That second consequence is what the Gujarat High Court applied in Ganesh Chhababhai Vallabhai Patel v. CIT, and it is the reason a trust assessment that looks favourable on its face can be rectified upwards years later. Section 161(1) is also expressly made 'subject to the other provisions contained in this Chapter', and those other provisions are where the damage is done: section 161(1A) overrides sub-section (1) altogether where there are business profits, and section 164 charges the maximum marginal rate where shares are indeterminate. Finally, section 161(2) is a real bar and is under-used — it is the answer to an Assessing Officer who, having assessed the trustee under Chapter XV, then seeks to assess the same income in the trustee's own hands under some other head.

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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