VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — s.166 and s.167: the Department may assess the beneficiary direct, and s.167 is about remedies against property, NOT a bar on double taxation
CBDT Circulars & InstructionsCuts both wayss.166s.167s.161s.161(2)s.160s.162s.164

Statutory position — s.166 and s.167: the Department may assess the beneficiary direct, and s.167 is about remedies against property, NOT a bar on double taxation

The Department has assessed our trustee under section 161 and has now issued a notice to me as beneficiary on the same income. Which section stops it doing both, and is it section 167?

The Department has assessed our trustee under section 161 and has now issued a notice to me as beneficiary on the same income. Which section stops it doing both, and is it section 167?

It is not section 167. Section 166 is the enabling provision: 'Nothing in the foregoing sections in this Chapter shall prevent either the direct assessment of the person on whose behalf or for whose benefit income therein referred to is receivable, or the recovery from such person of the tax payable in respect of such income.' Section 167 is headed 'Remedies against property in cases of representative assessees' and does something quite different: it gives the Assessing Officer the same remedies against all property of any kind vested in or under the control or management of a representative assessee as he would have against the property of any person liable to pay tax, and in as full and ample a manner, 'whether the demand is raised against the representative assessee or against the beneficiary direct'. It is a recovery-reach provision in the Revenue's favour, not a taxpayer protection. The bar on taxing the same income twice comes from elsewhere: from section 161(2), from the Central Board of Direct Taxes' own instruction of 24 February 1967, and from the case law on the exercise of the option.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 1988-04-01, reported as Income-tax Act, 1961, ss.166 and 167, as printed identically on departmental pages stamped Year 2000 and Year 2023. It bears on section 166, section 167, section 161, section 161(2), section 160, section 162, section 164 of the Income Tax Act 1961, in Charitable Trusts & Exemption, Assessment & Scrutiny, Demand, Recovery & Stay and How Tax Law Is Read matters.

Still good law. Both sections are printed word for word identically on departmental pages stamped Year 2000, Year 2023 and Year 2025, which is the best evidence obtainable on this pass that they stand unamended over that span. No page stamped Year 2026 was located for either section, no Finance Act text was read, and no judicial treatment was checked.

Why it matters

This distinction has to be got right because an argument built on the wrong section fails on the first reading of it. Section 166 gives the Department the option — it is the express provision that lets the Revenue go to the beneficiary instead of the trustee, and the Supreme Court in ITO v. Ch. Atchaiah made the general point that under the 1961 Act an option exists only where Parliament has provided one expressly, which is precisely what section 166 does. Once the option has been exercised, three things restrain the Department. Section 161(2) says that a person assessable under Chapter XV in a representative capacity 'shall not, in respect of that income, be assessed under any other provision of this Act'. The Central Board's letter of 24 February 1967 — which the Gujarat High Court reproduced in Ganesh Chhababhai Vallabhai Patel v. CIT and which the departmental section 166 page itself points to as 'Letter F. No. 45/78/66-ITJ (5), dated 24-2-1967' — directs that once the choice is made to tax either the trustee or the beneficiary, it is not open to the Department to go behind it and assess the other at the same time. How far that instruction can be pressed was not established on this pass: no decision on the binding force of a Board circular was read for this entry, and the Gujarat High Court in Ganesh Chhababhai Vallabhai Patel, applying Hindustan Aeronautics Ltd. v. CIT, held that a circular cannot be enforced against the interpretation given by the Supreme Court or a High Court to a provision of law. Plead the instruction, but plead section 161(2) as the primary ground. Section 167, by contrast, works entirely for the Revenue at the recovery stage: it puts every asset vested in or controlled or managed by the representative assessee within reach, and its concluding words make clear that the reach exists whichever way the demand was raised. If you are a trustee whose beneficiary has been assessed direct, section 167 is the provision under which trust property can still be proceeded against, and it is a reason to take the section 162 retention and certificate seriously.

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

Other authorities on the same sections.