KAPURCHAND SHRIMAL vs TAX RECOVERY OFFICER, HYDERABAD & ORS.

The Supreme Court held that under the Income-tax Act, 1922, a Hindu undivided family is treated as a distinct taxable entity, and thus, the Karta cannot be detained for tax defaults of the family. The Court ruled that the Tax Recovery Officer's actions against the Karta were unlawful as there is no provision in the Act that deems the Karta as the assessee for tax recovery purposes. Consequently, the Court ordered the release of the Karta from custody, emphasizing that personal liability cannot be imposed on the Karta for the family's tax obligations under Section 222 of the Income-tax Act.