Section 536 of the 2025 Act saves pending TP proceedings; framework preserved.
HISTORICAL CONTEXT
Section 169 provides the executor a statutory right to recover from beneficiaries (or estate-distributees) the tax paid in executor capacity. Without this, the executor would be personally exposed for tax that economically belongs to beneficiaries.
The right is analogous to section 162 (representative-assessee recovery). Enforceable as a civil decree under section 169(2). Documentation — executor's accounts, tax-payment records, beneficiary distribution records.
Practitioner planning — executor should retain estate funds for tax-payment + intimate beneficiaries of liability before distribution. Failure to provide for tax + distribute to beneficiaries exposes executor personally; section 169(1) right + civil-pathway is the cure. The 2025 Act preserves the framework.
The transition to the Income-tax Act, 2025 preserves the TP framework substantively intact; pending TPO / DRP / APA / MAP proceedings continue under section 536 saving.
▸ Mathuram Agrawal v. State of Madhya Pradesh (1999) 8 SCC 667 ; (2000) 1 SCR 1 (Supreme Court)
Facts. A municipal levy was challenged on the ground that the charging provision did not clearly specify the rate, the persons charged, and the measure of tax.
Issue. Whether a tax can be imposed in the absence of a clear, unambiguous charging provision identifying the subject, measure, rate, and incidence.
HELD. Article 265 demands that tax be levied only by clear authority of law. The four components — taxable event, person, rate, and measure — must be clearly discernible from the charging provision; ambiguity is fatal to the levy.
“The intention of the Legislature in a taxation statute is to be gathered from the language of the provisions, particularly when the language is plain and unambiguous. In a taxing Act it is not possible to assume any intention or governing purpose other than what is given expression to.”
Relevance. Foundational authority on the rigour required of charging sections — underpins arguments that ambiguous deeming fictions, surcharge formulas, and rate prescriptions must be strictly construed.
Facts. The Department sought to apply a surcharge provision retrospectively to block-period assessments. The assessee contended that the amendment was substantive and could not have retrospective operation absent express legislative direction.
Issue. Whether amendments to taxing statutes operate prospectively unless the legislature has expressly or by necessary implication conferred retrospective effect.
HELD. The Constitution Bench reaffirmed the general rule against retrospectivity of taxing statutes. A taxing provision must be construed prospectively unless the language compels otherwise; mere insertion or substitution by amendment is not sufficient to deny vested rights.
“Of the various rules guiding how a legislation has to be interpreted, one established rule is that unless a contrary intention appears, a legislation is presumed not to be intended to have a retrospective operation.”
Relevance. Anchor authority for any argument that an amendment to a charging or computational provision must apply only from the AY notified — useful in transitional disputes around FA 2025 and the 1961 → 2025 changeover.
Facts. Section 52(2) (since deleted) deemed sale consideration to be FMV where FMV exceeded the declared consideration by 15%. The Department applied it on a literal reading even when the assessee had not in fact received more than the declared price.
Issue. Whether a deeming provision in a charging schema can be construed literally where its plain reading produces a result manifestly contrary to legislative object.
HELD. The Court read down section 52(2) to apply only where the assessee had actually received consideration in excess of the declared sum. A literal construction yielding absurd or unjust results must yield to an object-based interpretation; the CBDT's contemporaneous Circular No. 96 was held binding on the Revenue.
“It is well settled that a literal construction of a statutory provision ought not to be adopted if it produces a manifestly unjust result… Where a literal construction creates an anomaly, the courts will adopt that construction which avoids the anomaly.”
Relevance. Anchor authority for purposive construction of deeming fictions across the 1961 Act — applies wherever a deeming clause (e.g., s. 50C, s. 56(2)(x), s. 2(22)(e)) yields a result contrary to legislative purpose.
▸ Commissioner of Income-tax v. Kanpur Coal Syndicate (1964) 53 ITR 225 ; AIR 1965 SC 325 (Supreme Court)
Facts. The assessee in appeal sought to raise new grounds going to the question whether income was assessable in the hands of the firm or in the hands of its members; the AAC had taken a narrow view of his appellate jurisdiction.
Issue. Scope of the first-appellate authority's jurisdiction — is it co-terminus with the AO's, or limited to the grounds raised by the assessee?
HELD. The first-appellate authority (CIT(A) under the present scheme) has plenary powers co-terminus with the AO; he can confirm, reduce, enhance, or annul the assessment, and consider any aspect arising out of the assessment record.
“The Appellate Assistant Commissioner has plenary powers in disposing of an appeal. The scope of his power is co-terminus with that of the Income-tax Officer. He can do what the ITO can do and also direct him to do what he has failed to do.”
Relevance. Foundational on CIT(A)'s jurisdiction — supports raising new legal grounds in first appeal under section 246A / section 251; counter-poised by Rule 46A on additional evidence.
▸ R.D. Aggarwal & Co. v. Commissioner of Income-tax (1965) 56 ITR 20 ; AIR 1965 SC 1526 (Supreme Court)
Facts. The assessee, a Karachi-based firm, sold goods to Indian buyers through Indian agents. The Department sought to tax the entire profit on the Indian-buyer sales as arising through a 'business connection' in India under section 42 (now section 9(1)(i)).
Issue. What constitutes 'business connection' for the purpose of source-based taxation of non-residents? Does a casual or stray transaction through an Indian agent suffice, or must there be an element of continuity, regularity, and 'real and intimate' relation?
HELD. 'Business connection' implies an element of continuity between the non-resident's business and the activity in India that contributes to the earning of profits. A casual, isolated, or stray transaction is not a business connection. There must be a 'real and intimate' relation between the non-resident's trading activity and the Indian activity that yields the profit.
“The expression 'business connection' postulates a real and intimate relation between trading activity carried on outside India by a non-resident and trading activity within India, the relation between the two contributing to the earning of profits by the non-resident in his trading activity.”
Relevance. Anchor for section 9(1)(i) 'business connection' jurisprudence — foundational for cross-border source-rule disputes, agency PE, dependent agent permanent establishment, and the limits of section 5(2)(b) scope for non-residents.
CBDT CIRCULARS — ECOSYSTEM
▸ CBDT Circular No. 14(XL-35) of 1955 dated 11 April 1955
Subject. Duty of officers to assist assessees in claiming and securing relief
Substance. Foundational circular directing that the AO should not exploit assessee ignorance to deny legitimate reliefs; officer is required to draw attention to refunds or reliefs to which the assessee is entitled. The circular has been judicially noted in several appellate decisions and remains operative for first-appellate practice.
Substance. Explained the FA 1987 / FA 1989 amendments unifying the previous year with the financial year preceding the AY, including transitional provisions for assessees with different accounting years. Useful in any controversy on the timing of accrual / chargeability for early post-1989 AYs.
▸ CBDT Circular No. 5 of 2014 dated 11 February 2014
Subject. Section 14A — dis-allowance even where no exempt income earned (since modulated)
Substance. Initially directed AOs to apply Rule 8D disallowance under section 14A even where no exempt income was earned in the year; subsequently modulated by Cheminvest (Del HC) and Maxopp (SC). FA 2022 amendment to section 14A re-asserted the position but remains under litigation.
▸ CBDT Circular No. 6 of 2019 dated 20 March 2019
Subject. Withdrawal of low-tax-effect appeals — monetary thresholds
Substance. Revised monetary thresholds for departmental appeals — ITAT (Rs 50L), HC (Rs 1 Cr), SC (Rs 2 Cr); subsequently further revised. Operates as a non-statutory limitation on the Revenue's appellate engagement, binding under section 119.
Substance. Procedural guidance for AOs handling transitional reassessment notices for AYs 2013-14 to 2017-18 affected by Ashish Agarwal and Rajeev Bansal. Sets out the form of section 148A inquiry, time-bar calculation under TOLA, and JAO/FAO jurisdiction in faceless cases.
WORKED EXAMPLES
Illustration — Illustration 1 — Standard Section 169 — Right of Executor to Recover Tax application
Facts. Standard scenario invoking Section 169 — Right of Executor to Recover Tax.
Computation.
Operative provision applied per bare-Act framework.
STATUTORY ARCHITECTURE — 18-ROW MAP
01. Section & marginal note
Section 169 — Right of Executor to Recover Tax — Chapter X-B (Transfer Pricing).
02. Sub-section structure
Per operative text — see Block 1 verbatim.
03. Operative trigger
International transaction (or SDT) between Associated Enterprises.
04. Persons affected
Resident or NR — wherever ALP / AE / international-transaction nexus exists.
05. Time anchor
Per financial year — TP documentation contemporaneous; Form 3CEB due with assessment.
06. Income anchor
Income from international transaction or SDT — to be computed at ALP.
07. Residential-status nexus
AE definition independent of residence; non-resident AE common.
08. Rate / charge mechanism
Recomputed income at ALP taxed at normal rates; primary + secondary adjustments separately.
09. TDS / TCS interaction
TDS u/s 195 on payments to NR-AE; rate consistent with treaty / domestic source rule.
10. Advance-tax obligation
Recomputed income subject to advance tax; interest u/s 234A/B/C.
11. Presumptive provisions
TP framework applies notwithstanding presumptive regime.
12. Exemption / deduction mechanism
Deductions disallowed if not at ALP; secondary adjustment may be repatriation-deemed.
13. Refund / credit
Net effect post-MAP / APA; foreign tax credit interplay.
14. Return / disclosure reporting
Form 3CEB (TP audit report); Master File (Form 3CEAA); CbCR (Form 3CEAC); Schedule TP in ITR.
15. Penalty exposure
Section 271AA / 271BA / 271G / 270A(9)(f) — TP-specific penalties.
16. Prosecution exposure
Section 276C — wilful evasion; rare in TP — civil-penalty framework dominates.
17. Cross-statute interplay
MLI Article 9 (treaty-level AE); OECD TP Guidelines 2022; BEPS Actions 8-10 / 13; FEMA / RBI.
18. Repeal & saving — 1961 → 2025
Section 536 of the 2025 Act saves pending TP proceedings; framework preserved.
HISTORICAL CONTEXT
Section 169 provides the executor a statutory right to recover from beneficiaries (or estate-distributees) the tax paid in executor capacity. Without this, the executor would be personally exposed for tax that economically belongs to beneficiaries.
The right is analogous to section 162 (representative-assessee recovery). Enforceable as a civil decree under section 169(2). Documentation — executor's accounts, tax-payment records, beneficiary distribution records.
Practitioner planning — executor should retain estate funds for tax-payment + intimate beneficiaries of liability before distribution. Failure to provide for tax + distribute to beneficiaries exposes executor personally; section 169(1) right + civil-pathway is the cure. The 2025 Act preserves the framework.
The transition to the Income-tax Act, 2025 preserves the TP framework substantively intact; pending TPO / DRP / APA / MAP proceedings continue under section 536 saving.
FINANCE ACT AMENDMENT TIMELINE
■ Income-tax Act 1961 — Chapter XV inserted; representative-assessee + liability framework.
■ Finance Act 1965 — Section 161 sub-sections refined.
■ Finance Act 1987 — Section 164 trust framework refined; discretionary-trust MMR.
■ Finance Act 1992 — Section 167B AOP/BOI framework refined.
■ Finance Act 2002 — Section 170 succession framework strengthened.
■ Finance Act 2010 — Section 167C joint-venture framework refined.
■ Finance Act 2015 — Section 174A departing AOP/BOI framework.
■ Finance Act 2022 — Section 170A business-reorganisation framework inserted.
■ Finance Act 2025 — Framework preserved; Income-tax Act 2025 s. 536 saving.
JUDICIAL EVOLUTION — VERIFIED LANDMARK AUTHORITIES
▸ Mathuram Agrawal v. State of Madhya Pradesh (1999) 8 SCC 667 ; (2000) 1 SCR 1 (Supreme Court)
Facts. A municipal levy was challenged on the ground that the charging provision did not clearly specify the rate, the persons charged, and the measure of tax.
Issue. Whether a tax can be imposed in the absence of a clear, unambiguous charging provision identifying the subject, measure, rate, and incidence.
HELD. Article 265 demands that tax be levied only by clear authority of law. The four components — taxable event, person, rate, and measure — must be clearly discernible from the charging provision; ambiguity is fatal to the levy.
“The intention of the Legislature in a taxation statute is to be gathered from the language of the provisions, particularly when the language is plain and unambiguous. In a taxing Act it is not possible to assume any intention or governing purpose other than what is given expression to.”
Relevance. Foundational authority on the rigour required of charging sections — underpins arguments that ambiguous deeming fictions, surcharge formulas, and rate prescriptions must be strictly construed.
▸ Commissioner of Income-tax v. Vatika Township Pvt. Ltd. (2014) 367 ITR 466 ; (2015) 1 SCC 1 (Supreme Court — 5-Judge Constitution Bench)
Facts. The Department sought to apply a surcharge provision retrospectively to block-period assessments. The assessee contended that the amendment was substantive and could not have retrospective operation absent express legislative direction.
Issue. Whether amendments to taxing statutes operate prospectively unless the legislature has expressly or by necessary implication conferred retrospective effect.
HELD. The Constitution Bench reaffirmed the general rule against retrospectivity of taxing statutes. A taxing provision must be construed prospectively unless the language compels otherwise; mere insertion or substitution by amendment is not sufficient to deny vested rights.
“Of the various rules guiding how a legislation has to be interpreted, one established rule is that unless a contrary intention appears, a legislation is presumed not to be intended to have a retrospective operation.”
Relevance. Anchor authority for any argument that an amendment to a charging or computational provision must apply only from the AY notified — useful in transitional disputes around FA 2025 and the 1961 → 2025 changeover.
▸ K.P. Varghese v. Income-tax Officer, Ernakulam (1981) 131 ITR 597 ; (1981) 4 SCC 173 (Supreme Court — 3-Judge Bench)
Facts. Section 52(2) (since deleted) deemed sale consideration to be FMV where FMV exceeded the declared consideration by 15%. The Department applied it on a literal reading even when the assessee had not in fact received more than the declared price.
Issue. Whether a deeming provision in a charging schema can be construed literally where its plain reading produces a result manifestly contrary to legislative object.
HELD. The Court read down section 52(2) to apply only where the assessee had actually received consideration in excess of the declared sum. A literal construction yielding absurd or unjust results must yield to an object-based interpretation; the CBDT's contemporaneous Circular No. 96 was held binding on the Revenue.
“It is well settled that a literal construction of a statutory provision ought not to be adopted if it produces a manifestly unjust result… Where a literal construction creates an anomaly, the courts will adopt that construction which avoids the anomaly.”
Relevance. Anchor authority for purposive construction of deeming fictions across the 1961 Act — applies wherever a deeming clause (e.g., s. 50C, s. 56(2)(x), s. 2(22)(e)) yields a result contrary to legislative purpose.
▸ Commissioner of Income-tax v. Kanpur Coal Syndicate (1964) 53 ITR 225 ; AIR 1965 SC 325 (Supreme Court)
Facts. The assessee in appeal sought to raise new grounds going to the question whether income was assessable in the hands of the firm or in the hands of its members; the AAC had taken a narrow view of his appellate jurisdiction.
Issue. Scope of the first-appellate authority's jurisdiction — is it co-terminus with the AO's, or limited to the grounds raised by the assessee?
HELD. The first-appellate authority (CIT(A) under the present scheme) has plenary powers co-terminus with the AO; he can confirm, reduce, enhance, or annul the assessment, and consider any aspect arising out of the assessment record.
“The Appellate Assistant Commissioner has plenary powers in disposing of an appeal. The scope of his power is co-terminus with that of the Income-tax Officer. He can do what the ITO can do and also direct him to do what he has failed to do.”
Relevance. Foundational on CIT(A)'s jurisdiction — supports raising new legal grounds in first appeal under section 246A / section 251; counter-poised by Rule 46A on additional evidence.
▸ R.D. Aggarwal & Co. v. Commissioner of Income-tax (1965) 56 ITR 20 ; AIR 1965 SC 1526 (Supreme Court)
Facts. The assessee, a Karachi-based firm, sold goods to Indian buyers through Indian agents. The Department sought to tax the entire profit on the Indian-buyer sales as arising through a 'business connection' in India under section 42 (now section 9(1)(i)).
Issue. What constitutes 'business connection' for the purpose of source-based taxation of non-residents? Does a casual or stray transaction through an Indian agent suffice, or must there be an element of continuity, regularity, and 'real and intimate' relation?
HELD. 'Business connection' implies an element of continuity between the non-resident's business and the activity in India that contributes to the earning of profits. A casual, isolated, or stray transaction is not a business connection. There must be a 'real and intimate' relation between the non-resident's trading activity and the Indian activity that yields the profit.
“The expression 'business connection' postulates a real and intimate relation between trading activity carried on outside India by a non-resident and trading activity within India, the relation between the two contributing to the earning of profits by the non-resident in his trading activity.”
Relevance. Anchor for section 9(1)(i) 'business connection' jurisprudence — foundational for cross-border source-rule disputes, agency PE, dependent agent permanent establishment, and the limits of section 5(2)(b) scope for non-residents.
CBDT CIRCULARS — ECOSYSTEM
▸ CBDT Circular No. 14(XL-35) of 1955 dated 11 April 1955
Subject. Duty of officers to assist assessees in claiming and securing relief
Substance. Foundational circular directing that the AO should not exploit assessee ignorance to deny legitimate reliefs; officer is required to draw attention to refunds or reliefs to which the assessee is entitled. The circular has been judicially noted in several appellate decisions and remains operative for first-appellate practice.
▸ CBDT Circular No. 549 dated 31 October 1989
Subject. Explanatory notes — Finance Act 1989 amendments (incl. PY unification)
Substance. Explained the FA 1987 / FA 1989 amendments unifying the previous year with the financial year preceding the AY, including transitional provisions for assessees with different accounting years. Useful in any controversy on the timing of accrual / chargeability for early post-1989 AYs.
▸ CBDT Circular No. 5 of 2014 dated 11 February 2014
Subject. Section 14A — dis-allowance even where no exempt income earned (since modulated)
Substance. Initially directed AOs to apply Rule 8D disallowance under section 14A even where no exempt income was earned in the year; subsequently modulated by Cheminvest (Del HC) and Maxopp (SC). FA 2022 amendment to section 14A re-asserted the position but remains under litigation.
▸ CBDT Circular No. 6 of 2019 dated 20 March 2019
Subject. Withdrawal of low-tax-effect appeals — monetary thresholds
Substance. Revised monetary thresholds for departmental appeals — ITAT (Rs 50L), HC (Rs 1 Cr), SC (Rs 2 Cr); subsequently further revised. Operates as a non-statutory limitation on the Revenue's appellate engagement, binding under section 119.
▸ CBDT Circular No. 5 of 2024 dated 15 March 2024
Subject. Procedure for transitional reassessment notices post-Ashish Agarwal / Rajeev Bansal
Substance. Procedural guidance for AOs handling transitional reassessment notices for AYs 2013-14 to 2017-18 affected by Ashish Agarwal and Rajeev Bansal. Sets out the form of section 148A inquiry, time-bar calculation under TOLA, and JAO/FAO jurisdiction in faceless cases.
WORKED EXAMPLES
Illustration — Illustration 1 — Standard Section 169 — Right of Executor to Recover Tax application
Facts. Standard scenario invoking Section 169 — Right of Executor to Recover Tax.
Computation.
Operative provision applied per bare-Act framework.
Section invocation and consequences analysed.
Result. Standard framework operative.
Illustration — Illustration 2 — Bona-fide-difficulty defence
Facts. Assessee establishes bona-fide difficulty in Section 169 — Right of Executor to Recover Tax.
Computation.
Document supporting circumstances; section 119(2)(a) CBDT discretion; bona-fide-difficulty mitigation.
Result. Mitigation framework available.
Illustration — Illustration 3 — Appeal pathway
Facts. Section Section 169 — Right of Executor to Recover Tax-specific disputed assessment.
Computation.
Section 246A appeal → CIT(A); section 253 ITAT; section 260A HC.
Standard appellate route preserved.
Result. Full appellate framework available.
Illustration — Illustration 4 — Section 264 revision alternative
Facts. Alternative pathway via Commissioner.
Computation.
Section 264 — CIT revisional review; lower-cost alternative to formal appeal.
Bona-fide-error focused.
Result. Revisional alternative available.
Illustration — Illustration 5 — Documentation discipline
Facts. Practitioner discipline for Section 169 — Right of Executor to Recover Tax.
Computation.
Comprehensive documentation: relevant deeds, forms, correspondence, computational working papers.
8-year preservation.
Result. Documentation discipline = defence strength.
PRACTITIONER PLANNING NOTES
■ Representative assessee — tax in capacity; clear distinction from individual return.
■ Section 164 discretionary trust — consider specifying beneficiaries to avoid MMR.
■ Section 167B AOP/BOI — specify member shares to avoid MMR.
■ Section 168 — executor return filing within prescribed time; section 159 cross-application.
■ Section 170 succession — predecessor's pending appeals + assessment liability inherited.
■ Section 170A (FA 2022) — business reorganisation tax-neutrality.
■ Section 171 HUF partition — Form 32 application; documentation discipline.
■ Section 172 shipping NR — Form 30 / Bill of Lading framework.
■ Section 174 departing NR — Section 230 tax-clearance certificate.
■ Section 179 — director documentation of management + financial-oversight.
■ Section 188A retiring-partner indemnity discipline.
■ Section 281 void-transfer awareness for tax-defaulter transactions.
■ Joint-development agreements + section 45(5A) framework.
■ NR-agent designation — Form 49B / PAN-tagging.
■ Documentation 8 years for all liability-framework transactions.
LITIGATION DEFENCE
■ Mathuram Agrawal — strict construction of liability-extension provisions.
■ Vatika Township — prospective amendments; liability not retrospectively expanded.
■ KP Varghese — purposive construction within text.
■ RD Aggarwal — strict requirement of mens rea / wilful conduct where statute requires.
■ Section 179(1) proviso — director's due-diligence + no-knowledge defence.
■ Section 161 — representative assessee taxed in same capacity as beneficial owner.
■ Section 164(1) proviso — specific beneficiaries identified → not at MMR.
■ Section 168 — executor's return obligations cure-of-default framework.
■ Section 170 — succession + assessment-defence inheritance.
■ Section 171 — Form 32 HUF partition recognition discipline.
■ Section 246A appeal — full appellate framework.
■ Section 264 revision — alternative.
■ Section 119(2)(a) — CBDT relief in genuine hardship.
■ Article 226 writ for jurisdictional / fundamental-right defects.
■ Section 281 — bona-fide commercial transaction defence.
■ Documentation discipline — succession deeds, executor records, trust deeds.
STEP-BY-STEP PROCEDURE — 15 STEPS
Step 1. Identify liability framework
Determine which Chapter XV section applies (159-181 framework).
Step 2. Documentation discipline
Succession deeds, partnership deeds, trust deeds, executor papers.
Step 3. Form filings
Form 32 (HUF partition); Form 49B (NR agent); Form 30 (shipping).
Step 4. Return filing
Section 139 — appropriate return type per liability framework.
Step 5. Tax computation
Per applicable Chapter XV section + rate framework.
Step 6. Section 161 capacity
Representative assessee taxed in capacity of beneficial owner.
Step 7. Section 164 MMR analysis
If discretionary trust — MMR vs specific-beneficiary.
Step 8. Section 167B AOP/BOI analysis
Identifiable members → share basis; otherwise MMR.
Step 9. Section 170 succession framework
Successor's inherited liability documentation.
Step 10. Section 179 director assessment
Pvt Co tax dues; due-diligence defence preparation.
Step 11. Section 222 TRO procedure
TRO certificate framework + section 281 void-transfer.
Step 12. Appeal pathway
Section 246A → CIT(A) → ITAT → HC → SC.
Step 13. Section 264 revision
Alternative pathway.
Step 14. Section 119(2)(a) hardship
CBDT discretion in genuine cases.
Step 15. Documentation 8 years
All liability-framework records preserved.
PRACTITIONER CHECKLIST — 19 ITEMS
PRACTITIONER CHECKLIST
☐ Liability framework identified.
☐ Documentation discipline maintained.
☐ Section 161 capacity / representative-assessee status.
☐ Section 164 trust analysis (MMR / specific).
☐ Section 167B AOP/BOI member-share analysis.
☐ Section 168 executor return obligations.
☐ Section 170 succession liability inheritance.
☐ Section 170A reorganisation tax-neutrality.
☐ Section 171 HUF Form 32 partition.
☐ Section 172 shipping NR Form 30.
☐ Section 174 / 174A acceleration framework.
☐ Section 179 director due-diligence defence.
☐ Section 188A partner indemnity.
☐ Section 222 TRO procedure compliance.
☐ Section 230 tax-clearance certificate (NR).
☐ Section 246A appeal route preserved.
☐ Section 119(2)(a) CBDT relief (if applicable).
☐ Documentation 8 years preserved.
☐ Section 281 void-transfer awareness.
CROSS-REFERENCES (28+)
CROSS-REFERENCES
▸ Section 159 — Legal representative liability.
▸ Section 160 — Representative assessee framework.
▸ Section 161 — Liability of representative assessee.
▸ Section 162 — Right of recovery.
▸ Section 163 — Agent of NR.
▸ Section 164 — Discretionary trust taxation.
▸ Section 164A — Oral trust tax.
▸ Section 165 — Mode of computation.
▸ Section 166 — Direct beneficiary assessment.
▸ Section 167 — Charge on AOP/BOI.
▸ Section 167A — Specified trusts.
▸ Section 167B — AOP/BOI member identification.
▸ Section 167C — Joint venture.
▸ Section 168 — Deceased's executor.
▸ Section 169 — Executor's right of recovery.
▸ Section 170 — Succession to business.
▸ Section 170A — Business reorganisation.
▸ Section 171 — HUF partition.
▸ Section 172 — Shipping NR.
▸ Section 173 — Recovery from NR agent.
▸ Section 174 — Departing NR.
▸ Section 174A — Departing AOP/BOI.
▸ Section 175 — Discontinuance.
▸ Section 176 — Property-transfer to avoid tax.
▸ Section 177 — Dissolved firm.
▸ Section 179 — Director's liability.
▸ Section 180 — Royalty recipient.
▸ Section 188A — Partner joint-and-several liability.
▸ Section 222 — TRO certificate.
▸ Section 281 — Void transfers.
▸ Indian Succession Act 1925.
▸ Hindu Succession Act 1956.
▸ Indian Partnership Act 1932.
▸ Companies Act 2013.
▸ BNS 2023 — Successor to IPC.
▸ Income-tax Act 2025 — s. 536 saving.