THE ADDITIONAL INCOME-TAX OFFICER,SALEM vs E. ALFRED

The Supreme Court held that under the Income-tax Act, 1922, a legal representative of a deceased person is deemed an assessee for the purpose of tax assessment, as per Section 24B(2). The Court ruled that this legal fiction does not end after the assessment, allowing the imposition of penalties under Section 46(1) for non-payment of tax. The High Court's decision to quash the penalty was overturned, affirming that the legal representative remains liable for penalties as an assessee even after the assessment is completed.