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HC upheld the ITAT's decision classifying the Trust as an Association of Persons (AOP), thereby disallowing interest paid to beneficiaries u/s 40(b). The AO found beneficiaries voluntarily pooled funds with clear intent to undertake project work and generate profits. The trust's self-declaration as an AOP and failure to rectify this status substantiated the classification. The court determined the findings were not perverse and the lower authorities' orders were legally justified, maintaining the disallowance of interest payments to beneficiaries.
HC upheld the ITAT's decision classifying the Trust as an Association of Persons (AOP), thereby disallowing interest paid to beneficiaries u/s 40(b). The AO found beneficiaries voluntarily pooled funds with clear intent to undertake project work and generate profits. The trust's self-declaration as an AOP and failure to rectify this status substantiated the classification. The court determined the findings were not perverse and the lower authorities' orders were legally justified, maintaining the disallowance of interest payments to beneficiaries.
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