<h1>Tribunal Rules Trustees of Trust with Determinate Beneficiaries Exempt from Tax Assessment u/s 164 of Income Tax Act.</h1> The Income Tax Appellate Tribunal ruled that the trustees of a trust with determinate beneficiaries and shares are not subject to tax assessment under Section 164 of the Income Tax Act. The trust, established in 1986, had clearly defined beneficiaries and sharing ratios. The Department argued that the beneficiaries' shares were fluctuating due to life events, making them indeterminate. However, the Tribunal found that since the beneficiaries' identities and shares were known, the trustees could not be taxed on income not distributed to beneficiaries. The trustees' liability was limited to representing the beneficiaries, who themselves were not liable for tax on the trust's income.