K.R. PATEL(DEAD) THROUGH LRS. vs COMMNR. OF INCOME TAX

The Supreme Court addressed the interpretation of Section 161 of the Income-tax Act, 1961, concerning the liability of executors and trustees for income tax. The Court held that K.R. Patel and B.G. Amin were liable to be assessed as trustees under Section 161 from the time of the testator's death, clarifying that their capacity as trustees commenced immediately upon the testator's death, not from the date of probate. The Court affirmed the High Court's decision, thereby ruling in favor of the revenue.