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Provisions expressly mentioned in the judgment/order text.
ITAT allowed the appeal regarding surcharge computation on private discretionary trust income. The tribunal held that CIT(A) erroneously determined the entire trust income should attract Maximum Marginal Rate with 37% surcharge under section 167B read with section 2(29C). Following precedent in Araadhya Jain Trust, ITAT ruled the assessee correctly claimed 15% surcharge rate in its return. The Assessing Officer appropriately allowed this claim through rectification order. The appellate authority's decision to impose 37% surcharge on trust income was overturned, with ITAT confirming the lower 15% surcharge rate applies to the trust's taxable income assessment.
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