Summarize the following court judgment. Appeal No.449 of 1958. Appeal by special leave from the judgment and decree dated August 7	 1956	 of the Patna High Court in Misc. Judicial Case No. 604 of 1953. 406 D. P. Singh	 for the appellant. section P. Varma	 for the respondent. January 11. The Judgment of the Court was delivered by SHAH	 J. The High Court of Judicature at Patna answered in the affirmative the following question which was submitted by the Board of Agricultural Income tax	 Bihar	 under section 28(3) of the Bihar Agricultural Income tax Act	 XXXII of 1948 hereinafter referred to as the Act: " Whether	 in the facts and circumstances of the case	 the petitioner could be legally assessed for the income of the Estate in 1355 Fasli when the Estate was in the hand of the Receiver ? " With special leave under article 136 of the Constitution	 this appeal is preferred against the order of the High Court. The appellant is the Mahant of the Asthal Estate	 Salauna	 in the District of Bhagalpur in Bihar. In a suit concerning that estate	 a Court Receiver was appointed by the First Class Subordinate Judge	 Monghyr	 to manage the estate. The Receiver functioned till sometime in December	 1949	 and under the order of the Subordinate Judge he handed over charge of the estate to the appellant on January 8	 1950. On January 15	 1950	 the appellant submitted a return of income of the estate to the Agricultural Income tax Officer	 Monghyr	 for the Fasli year 1355 corresponding to September 16	 1948	 to September 15	 1949. The Agricultural Income tax Officer assessed on August 7	 1950	 the agricultural income of the estate at Rs. 90	507 2 6 and ordered the appellant to pay Rs. 20	290 13 0 as agricultural income tax. Appeals against the order of assessment preferred to the Commissioner of Agricultural Income tax and the Board of Agricultural Income tax	 Bihar	 were unsuccessful. The Board however referred the question set out hereinbefore to the High Court under section 28(3) of the Act as arising out of its order. The only question which falls to be determined in this appeal is whether the appellant was liable to be assessed to pay agricultural income tax for the year 407 in which the estate was in the management of the Court Receiver. Section 3 of the Act which is the charging section provides: " Agricultural income tax shall be charged for each financial year in accordance with and subject to the provisions of this Act on the total agricultural income of the previous year of every person. " By section 4	it is provided: Save as hereinafter provided	 this Act shall apply to all agricultural income derived from land situated in the State of Bihar. " The income of the estate of the appellant was not exempt from payment of tax and by virtue of section 3	 agricultural income tax was charged upon the income for the assessment year in question	 and the appellant was prima facie liable as owner of the estate to pay tax on that income. The appellant however relied upon section 13 of the Act which provides: " Where any person holds land	 from which agricultural income is derived	 as a common manager appointed under any law for the time being in force	 or under any agreement or as receiver	 administrator or the like on behalf of persons jointly interested in such land or in the agricultural income derived therefrom	 the aggregate of the sums payable as agricultural income tax by each person on the agricultural income derived from such land and received by him shall be assessed on such common manager	 receiver	 administrator or the like	 and he shall be deemed to be the assessee in respect of the agricultural income tax so payable by each such person and shall be liable to pay the same. " The appellant urged that if the land from which agricultural income is derived is held by a Receiver and the income is received by the Receiver	 the Receiver alone can	 by virtue of section 13	 be deemed to be the assessee and the Receiver alone is liable to pay the tax in respect of that income. In support of his contention	 the appellant relies upon the definition of the word. 	 " person " in s	 2	 cl. (m) which estates; 408 Person ' mean	% any individual or association of individuals	 owning or holding property for himself or for any other	 or partly for his own benefit and partly for another	 either as owner	 trustee	 receiver	 common manager	 administrator or executor or in any capacity recognised by law	 and includes an undivided Hindu family	 firm or company. " In our view	 there is no substance in the contention raised by the appellant. The liability to pay tax is charged on the agricultural income of every person. The income though collected by the Receiver was the income of the appellant. By section 13	 in addition to the owner	 the Receiver is to be deemed to be an assessee. But the fact that the Receiver may	 because he held the property from which income was derived in the year of account	 be deemed to be an assessee and liable to pay tax	 does not absolve the appellant on whose behalf the income was received from the obligation to pay agricultural income tax. Section 13 merely provides a machinery for recovery of tax	 and is not a charging section. When property is in the possession of the Receiver	 common manager or administrator	 the taxing authorities may	 but are not bound to	 treat such persons as assessees and recover tax. The taxing authorities may always proceed against the owner of the income and assess the tax against him. The definition in the connotation of" person " undoubtedly included a receiver	 trustee	 common manager	 administrator or executor	 and by such inclusion	 it is open to the taxing authorities to assess tax against any such persons; but on that account	 the income in the hand of the owner is not exempt from liability to assessment of tax. Counsel for the appellant urged that the income received by the appellant from the Receiver did not retain its character of agricultural income and therefore also the appellant was not liable to pay agricultural income tax. But this contention was never raised before the taxing authorities and no such question has been referred to this court. The character of the income was accepted to be agricultural 409 income in the hands of the appellant and the only question which was sought to be referred and raised before the Board of Agricultural Income tax was one as to the liability of the appellant to be assessed to agricultural income tax for the year in question. In that view of the case	 the appeal fails and is dismissed with costs. Appeal dismissed.

The appellant was the Mahant of the Asthal Estate in Bihar which was in the management of a Receiver appointed by the Civil Court in a suit relating to the estate. On appeal the question that arose for decision in this Court was whether the appellant Mahant was liable to be assessed under the Bihar Agricultural Income tax Act	 1948	 to pay agricultural income tax for the year in which the estate was in the management of the Court Receiver. Held	 that the income though collected by the Receiver was the income of the appellant. By virtue of the provisions of sections 2	 cl. (m) and 13 of the Bihar Agricultural Income tax Act it was open to the taxing authorities to treat the Receiver as the assessee because he held the property from which income was derived	 but on that account the income in the hand of the owner was not exempt from liability to assessment of tax. Section 3 of the Act provides for charging agricultural income of every person " as defined in section 2	 cl. (m) which includes a receiver and section E3 merely provides a machinery for recovery of tax from "Persons" including receivers and is not by itself a charging section.