Just a moment...

Top
Help
×

By creating an account you can:

Logo TaxTMI
Call Us / Help / Feedback

Contact Us At :

E-mail: [email protected]

Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters0/2000
Make Most of Text Search
  1. Checkout this video tutorial: How to search effectively on TaxTMI.
  2. Put words in double quotes for exact word search, eg: "income tax"
  3. Avoid noise words such as : 'and, of, the, a'
  4. Sort by Relevance to get the most relevant document.
  5. Press Enter to add multiple terms/multiple phrases, and then click on Search to Search.
  6. Text Search
  7. The system will try to fetch results that contains ALL your words.
  8. Once you add keywords, you'll see a new 'Search In' filter that makes your results even more precise.
  9. Text Search
Add to...
You have not created any category. Kindly create one to bookmark this item!
Create New Category
Hide
Title :
Description :
❮❮ Hide
Default View
Expand ❯❯
Close ✕
🔎 News - Adv. Search
TEXT SEARCH:

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In:
Main Text + AI Text
  • Main Text
  • Main Text + AI Text
  • AI Text
Category: ?
Categorized by AI
---- All Categories ----
  • ---- All Categories ----
  • Income Tax
  • GST
  • Customs, DGFT & SEZ
  • FEMA & RBI
  • Corp. Laws, SEBI & IBC
  • PMLA, Black Money & ED
  • Budget
  • News and Press Release
  • PTI News
Month:
---- All Months ----
  • ---- All Months ----
  • January
  • February
  • March
  • April
  • May
  • June
  • July
  • August
  • September
  • October
  • November
  • December
Year:
---- All Years ----
  • ---- All Years ----
  • 2026
  • 2025
  • 2024
  • 2023
  • 2022
  • 2021
  • 2020
  • 2019
  • 2018
  • 2017
  • 2016
  • 2015
  • 2014
  • 2013
  • 2012
  • 2011
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
RelevanceDefaultDate
    Govt allows FDI in inventory-based model of e-commerce only for export purposes
    CRIF India Launches Chennai Chapter of 'Credit Goes to HER' to Strengthen Women's Leadership in the Credit Ecosystem
    Loan Fest 2026: Apply for a Bajaj Finance Personal Loan Online with Attractive Offers
    Rupee slips 4 paise to settle at 96.57 against US dollar
    Supertech twin towers: SC defers hearing on plea seeking refund for homebuyers
    Invest Manchester: UK-India Free Trade Agreement Opens New Doors for APAC Manufacturers
    4 Chandigarh University Law Graduates Become Judicial Officers, 244 Secure Jobs at Corporate Law Firms
    ISTITUTO MARANGONI MUMBAI PRESENTS ITS 2026 STUDENT SHOWCASE — ‘ASTITVA’
    Rupee rises 5 paise to 96.48 against US dollar in early trade
    Ministry of Statistics and Programme Implementation has put in place well-defined mechanisms to ensure timely collection and publication of official s...
    Ministry of Statistics and Programme Implementation undertakes periodic methodological reviews of statistical framework to ensure official statis...
    ENERGY STATISTICS INDIA
    CCI approves acquisition of 100% of the equity share capital of NCR Atleos Corporation (Target) by The Brink's Company (Acquirer)
    US to unveil final action on Sec 301 investigation on Thursday: USTR Greer
    Lokayukta police unearth Rs 17 crore assets of power firm official, relatives
    Maharashtra govt releases 'representative' list of 533 beneficiaries of farm loan waiver scheme
    India exports 12.5 tons of Dashehari, Langra mangoes from UP to Dubai via sea route
    Finacle 10.2.25 software will make banking services faster and more transparent: Himachal CM
    Return of foreign investments shows revival of confidence in economy: RBI Bulletin
    India-US trade deal is almost complete: US State Department after Jaishankar-Rubio talks in Manila
❯❯
MaximizeMaximizeMaximize
0 / 200
Expand Note
Add to Folder

No Folders have been created

    +

    Are you sure you want to delete "My most important" ?

    NOTE:

    News
    Showing Results for :
    Reset Filters
    Results Found:
    Show All SummariesHide All Summaries
    July 23, 2026
    Show AI Summary
    Foreign investment in inventory-based e-commerce is permitted exclusively for exports of Indian-manufactured or produced goods under export compliance rules.
    Foreign direct investment in inventory-based e-commerce is permitted exclusively for exports of goods or products manufactured or produced in India. Foreign direct investment remains permitted in business-to-business e-commerce and the marketplace model, while business-to-consumer and inventory-based direct sales to consumers remain prohibited except for the specified export activity. Export-oriented inventory-based operations must comply with the applicable Foreign Trade Policy and foreign exchange regulations governing exports.
    July 23, 2026
    Show AI Summary
    Women's leadership in credit expands through a Chennai community platform supporting mentorship, inclusive lending practices, and financial ecosystem collaboration.
    The Chennai chapter of the 'Credit Goes to HER' initiative provides a platform for women professionals in banking, NBFCs, fintech, housing finance, academia and policy to share knowledge, obtain mentorship and collaborate on inclusive credit practices. It seeks to strengthen women's leadership and participation in the credit ecosystem while supporting responsible lending, financial inclusion, transparency and data-driven decision-making.
    July 23, 2026
    Show AI Summary
    Digital personal-loan campaign combines online collateral-free borrowing, eligibility-based assessment, flexible repayment options and conditional lifestyle rewards for successful disbursals.
    Digital personal-loan campaign permits eligible customers to apply online for collateral-free borrowing and receive specified lifestyle rewards upon successful disbursal, subject to campaign terms. Applicants may check an offer, provide personal, financial and employment information, review loan terms, complete know-your-customer and bank-account verification, and undergo assessment. Interest rates, loan amounts and repayment tenures depend on eligibility, credit profile, income and internal assessment. An EMI calculator supports comparison of repayment options and estimation of monthly instalments before application.
    July 23, 2026
    Show AI Summary
    Foreign-exchange market pressure weakened the rupee as elevated crude prices and risk sentiment drove trading conditions.
    Foreign-exchange market movement saw the rupee depreciate against the US dollar amid elevated crude oil prices linked to heightened West Asia hostilities. Weak domestic equity markets and foreign investor equity outflows contributed to negative sentiment. Market commentary indicated that prospective Reserve Bank of India intervention supported the rupee and could limit sharper depreciation, while shipping-security concerns contributed to elevated oil prices.
    July 23, 2026
    Show AI Summary
    Homebuyer refund claims in developer insolvency proceed through pro-rata distribution of funds deposited for eligible buyers.
    Homebuyer refund claims connected with demolished residential towers are being considered within the developer's insolvency proceedings. Buyers who have not opted for alternative allotment seek repayment. Eligible refunds are contemplated on a pro-rata basis from funds deposited by the Interim Resolution Professional, subject to the claims process and the availability of deposited funds.
    July 23, 2026
    Show AI Summary
    Free trade agreement tariff reductions create investment opportunities for Asia-Pacific manufacturers seeking UK and European market access.
    The UK-India Free Trade Agreement is presented as reducing tariffs on advanced machinery and manufacturing-related goods and creating trade and investment opportunities for Asia-Pacific manufacturers seeking UK and European market access. Manchester is promoted as an investment location through its advanced manufacturing cluster, skilled workforce, innovation infrastructure, international links, and available manufacturing and research space. Invest Manchester provides investor support and undertakes international engagement to develop trade, investment and innovation partnerships.
    July 23, 2026
    Show AI Summary
    Practical legal training and structured internships strengthen judicial examination preparation, professional skills, and career exposure for law students.
    Legal education employability initiatives combine curriculum alignment for judicial and competitive examinations with mentoring, legal drafting practice, research training, and professional interaction. Internships provide practical exposure to courts, judicial institutions, government bodies, law firms, advocates' chambers, corporate legal departments, and non-governmental organisations. Students in integrated and three-year law programmes complete prescribed minimum internship periods, with summer and winter placements commencing after the first year. Specialisation-based internships cover civil, criminal, corporate, cyber, intellectual property, arbitration, taxation, and government or non-governmental legal work.
    July 23, 2026
    Show AI Summary
    Student fashion showcase celebrates identity, personal storytelling, craft preservation and conscious creation through nine contemporary design collections.
    Student fashion showcase 'Astitva' presented nine contemporary collections exploring identity, belonging, transformation, memory, resilience, grief and cultural heritage through personal design narratives. The collections included a contemporary reinterpretation of Bhujodi weaving, Ajrakh block printing and Kumaoni hand-knitting, emphasising preservation of Indian craft traditions. Recognition included a designer award for the craft-revival collection and a sustainability award for a collection focused on craftsmanship, conscious creation, heirloom design and mindful luxury.
    July 23, 2026
    Show AI Summary
    Rupee exchange-rate movements face pressure from elevated crude prices and equity outflows, moderated by possible central-bank intervention.
    Rupee exchange-rate movement in early foreign-exchange trading reflected a modest appreciation against the US dollar after depreciation in the preceding session. Possible dollar sales by state-owned banks, widely viewed as central-bank intervention, and a weaker US dollar supported the currency. Elevated crude-oil prices, foreign institutional equity outflows, and negative domestic equity-market sentiment continued to create downside pressure, although expected central-bank support was considered likely to limit losses.
    July 23, 2026
    Show AI Summary
    Official statistics dissemination uses digital validation, release calendars, anonymised microdata and accessible platforms to strengthen timeliness and transparency.
    Official statistics collection and dissemination are supported through digital survey platforms with built-in validation, real-time monitoring and supervisory quality controls. Consumer Price Index, National Accounts Statistics and Index of Industrial Production data are collected, compiled or validated through specified quality and timeliness mechanisms. An Advance Release Calendar supports accountable publication, while anonymised survey microdata, stakeholder engagement and digital portals improve transparency, accessibility and use of official statistics.
    July 23, 2026
    Show AI Summary
    Official statistical modernization strengthens macroeconomic measurement through revised bases, digital surveys, validated data collection and district-level estimates.
    Official statistical methodology and National Sample Surveys are periodically reviewed to reflect changing economic conditions, emerging data needs and international standards. Base revisions for key macroeconomic indicators incorporate updated data, expanded coverage, revised weights, administrative sources and improved estimation of the unincorporated sector. Survey methods are updated through expert consultation, pilot studies and field testing. Digital collection platforms, validation checks, real-time monitoring, AI-enabled tools and multilingual interfaces support improved data quality, quicker releases, high-frequency surveys and district-level estimates.
    July 23, 2026
    Show AI Summary
    Energy statistics reporting expands with internationally aligned consumption data, energy-sector credit flows, and improved coal and electricity coverage.
    Energy Statistics India 2026 reports Total Primary Energy Supply and renewable energy potential, supporting energy policy and infrastructure planning. Its 33rd edition adds data on credit flow to the energy sector, the international energy scenario, and international marine and aviation bunker use. It aligns end-use consuming sectors for energy commodities with international standards and addresses data gaps in industry-wise coal and electricity consumption.
    July 23, 2026
    Show AI Summary
    Competition approval for full acquisition integrates cash replenishment, ATM hardware, software, managed services and maintenance operations.
    Competition approval has been granted for The Brink's Company's acquisition of the entire equity share capital of NCR Atleos Corporation, which will become wholly owned and controlled by the acquirer. The acquirer provides cash replenishment and ancillary first-line maintenance in India. The target's Indian activities include ATM hardware manufacture and supply, ATM software development and licensing, ATM managed services, and first-line and second-line ATM maintenance.
    July 22, 2026
    Show AI Summary
    Forced-labour import controls face proposed Section 301 tariff action, while India contests the investigations through bilateral trade discussions.
    Section 301 investigations concerning forced-labour imports examine whether 60 major trading partners, including India, have adopted and effectively enforced import prohibitions on goods produced with forced labour. Proposed additional tariffs would vary according to the strength of existing forced-labour import controls. India has contested the investigations and indicated that these issues may be addressed through the bilateral trade agreement under discussion. India has also initiated an anti-dumping investigation into global soda ash imports to assess potential injury or threat of injury to domestic industry.
    July 22, 2026
    Show AI Summary
    Disproportionate-assets investigation examines property, bank accounts, tax returns and investments linked to a power company official and relatives.
    Disproportionate-assets investigation concerns allegations that a power distribution company official and close relatives acquired movable and immovable assets beyond known sources of income. Lokayukta Police conducted searches, identified assets and bank deposits linked to the official, family members and associated business entities, and sought freezing of account transactions. The inquiry includes verification of property acquisitions, income-tax returns, and stock-market and mutual-fund investments, with further investigation pending.
    July 22, 2026
    Show AI Summary
    Farm loan waiver eligibility requires verified data, Agristack registration and Aadhaar authentication before direct transfer to loan accounts.
    The farm-loan waiver and one-time settlement mechanism applies to eligible beneficiaries whose loan data is uploaded by participating banks and verified through the scheme portal. Excluded categories include legislators, local-body office-bearers, government employees, certain income-tax payers, and specified cooperative-sector personnel. Eligible farmers must register on Agristack and complete Aadhaar authentication using their Aadhaar number or unique ID. After successful authentication, the eligible benefit is transferred directly to the loan account through the Direct Benefit Transfer system.
    July 22, 2026
    Show AI Summary
    Sea-route mango export protocol validates cold-chain shipping that can reduce logistics costs and expand overseas market access.
    A sea-route export protocol for Dashehari and Langra mangoes was commercially validated for shipment from Uttar Pradesh to Dubai under an extended harvest-to-market transit period. The process used scientific post-harvest management, shelf-life treatment, grading, packing, refrigerated-container transport and a continuous cold chain. The reported marketable condition on arrival supports wider use of cost-effective sea freight, potentially reducing logistics costs, improving grower procurement prices and expanding access to overseas markets.
    July 22, 2026
    Show AI Summary
    Core banking migration supports faster transactions, stronger cyber security, transparent services and more convenient digital banking for customers.
    Migration of the cooperative bank's core banking system to the Finacle 10.2.25 platform is intended to enable faster, more transparent and secure banking services. The platform is expected to support customer-friendly transactions, stronger cyber security, convenient digital banking and improved operational efficiency. It may also strengthen the bank's delivery of financial benefits under government welfare schemes.
    July 22, 2026
    Show AI Summary
    Foreign investment recovery signals improved economic confidence amid sustained trade momentum and renewed food- and fuel-led inflation pressures.
    Foreign investment recovery, external trade momentum and inflation developments are examined amid geopolitical and supply-chain uncertainty. Strong export and import growth, the operationalisation of the India-UK Comprehensive Economic and Trade Agreement, renewed portfolio inflows and higher foreign direct investment were identified as supporting external-sector confidence. Consumer price inflation increased, led by food and fuel, while core inflation remained unchanged. Food-price pressures continued across staples, edible oils and vegetables, although comfortable foodgrain stocks could mitigate food-inflation effects.
    July 22, 2026
    Show AI Summary
    Interim trade deal negotiations near completion as bilateral discussions advance tariffs, defence agreements, strategic cooperation, and regional security.
    India-US bilateral engagement focused on advancing an interim trade arrangement reported to be nearing completion, alongside discussions on tariffs, energy, defence and security, critical minerals, and artificial intelligence. The talks included a shared interest in finalising the interim trade deal and completing unspecified defence agreements connected with prior bilateral commitments. Regional security, West Asia, the Indo-Pacific, and Quad cooperation were also discussed amid efforts to restore bilateral relations following trade, immigration, and security-related strains.

    News

    Back

    All News

    Showing Results for :
    Reset Filters
      No Records Found

      News

      Back

      All News

      whatsappJoin Channel
      Showing Results for : Reset Filters

      Assessment of Trust - Applicability of Section 164 where the beneficiaries and their shares are determinate

      May 3, 2009

      Contents
      Acts
      Summary
      Note

      Note

      -

      Bookmark

      Print

      Print

      The Question:

      "Whether on the facts and in the circumstances of the case, the Income Tax Appellate Tribunal was right in holding that in the case of the assessee Trust, the beneficiaries and their shares are determinate and, therefore, the trustees could not be assessed for tax and the provisions of section 164 of the Income Tax Act are not attracted?"

      Facts of the Case:

      4. The assessee was a Trust created by a Trust Deed dated 01.04.1986. The author of the Trust was one Smt. A. Lalitha. The Trustees were Sri P.Sekar, Smt. S.Gowri and Sri P.Badri. The Trust was created for the benefit of seven beneficiaries. The beneficiaries and their beneficial interest in the income of the Trust other than the income which forms part of the corpus or capital fund of the Trust were as under :

      From 01.04.1986 to 31.03.1989 the following were the beneficiaries with the following sharing ratios :

      1. Smt. P.Girija in the status of individual           -           15%

      2. Sri P.Sekar in the status of individual            -            20%

      3. Smt.S.Gowri in the status of individual           -           15%

      4. Sri P.Badri in the status of individual              -           25%

      5. Sri P.Prabhakar in the status of individual      -           25%

      From 01.04.1989 to the determination period of 25 years from 01.04.1986 the following were the beneficiaries with equal sharing ratios:

      1. Sri D.Parthasarathy in the status of individual

      2. Smt. P.Girija in the status of individual

      3. Sri P.Sekar as karta of Hindu Undivided Family

      4. Sri P.Sekar in the status of individual

      5. Smt.S.Gowri in the status of individual

      6. Sri P.Badri in the status of individual till the date of his marriage and separately in the status of the individual and Hindu Undivided Family consisting of himself and his wife from the date of marriage.

      7. Sri P.Prabhakar in the status of individual till the date of his marriage and separately in the status of individual and Hindu Undivided Family consisting of himself and his wife from the date of marriage.

      Contention of the Department:

      Department assessed the income of trust under section 164 on the following grounds:

      Though the beneficiaries are known and the share of the beneficiaries are determinate apparently, but are fluctuating depending upon the contingencies, such as, getting married, begetting children. He further submitted that number of beneficiaries would be less in the beginning of the accounting year , but more at the end of the accounting year, if such contingencies happen. Hence, the beneficiaries cannot be regarded as known.

      Contention of the Assessee

      Whatever the beneficial interest, the beneficiaries had in the income of the Trust have been directly assessed under section 166 of the Act in the hands of the beneficiaries and so no liability arises in the hands of the Trustees under section 161, or under section 164 of the Act framed the assessment under section 164 of the Act treating the trustees as the representative assessee in respect of 90% of the accumulated income.

      Observations

      Section 5 of the Act deals with the scope of the total income of any previous year of residents and non residents. Section 4 of the Act deals with the charge of income tax in respect of total income of the previous year of every person "subject to the provisions of this Act".

      Chapter XV of the Act deals with the liability in special cases. Representative assessees are dealt in section 160 of the Act. Section 160(1)(iv) of the Act provides that in respect of income which a trustee appointed under a trust declared by a duly executed instrument in writing whether testamentary or otherwise (including any wakf deed, which is valid under the Musalman Wakf Validity Act, 1913 (6 of 1913) receives or is entitled to receive on behalf of or for the benefit of any person such trustee or trustees will be representative assessee.

      Section 161 provides for the extent of the liability of the representative assessee to the effect that every representative assessee as regards the income in respect of which he is a representative assessee, shall be subject to the same duties, responsibilities and liabilities as if the income received by or accruing to or in favour of him beneficially, and shall be liable to assessment in his own name in respect of that income; but any such assessment shall be deemed to be made upon him in his representative capacity only, and the tax shall, subject to the other provisions contained in Chapter XV, be levied upon and recovered from him in like manner and to the same extent as it would be leviable upon and recoverable from the person represented by him.

      Section 164 of the Act gets attracts only when the shares of the beneficiaries are unknown, which is manifest from the marginal heading of that section itself, viz., Charge of tax where the share of the beneficiaries unknown. That section comes into play only where any income or any part thereof is not specifically receivable on behalf of or for the benefit of any one person or where the individual shares of the persons on whose behalf or for whose benefit such income or such part thereof is receivable are indeterminate or unknown, and in such case, the relevant income, or part of the relevant income shall be charged at the maximum marginal rate.

      Final Decision

      "In the assessment year with which we are concerned, having regard to the terms of the trust, the beneficiaries had no right to receive any part of the corpus of the trust to which the income received by the trustees by way of prize money on the lottery ticket was required to be credited. The right to the beneficiary was only to share in the division of that corpus at the end of the fifteen year period or sooner, if all the beneficiaries unanimously agreed to terminate the trust. The beneficiaries could not have been assessed to tax in respect of any part of this prize money in the year in which that money was received by the trust. The prize money received by the trustees on the lottery tickets not being an amount in which the beneficiaries, whose identities are known and whose shares are determinate, could claim a share in the year of account and which amount could not have been assessed in their hands as their income in whole or in part, therefore, was not assessable in the hands of the trustees who only represented the beneficiaries for the purposes of assessment and who could only be assessed in the same manner and to the same extent as the beneficiaries could have been assessed. The trustees assumed no higher liability than the beneficiaries themselves were required to bear under the law. If the beneficiary was not to be taxed, that tax could not be levied on the trustee who only represented the beneficiary and no more, in cases where the identity of the beneficiary was known and the share of the beneficiary was determinate. (emphasis supplied)

       

      Topics

      ActsIncome Tax