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    <title>1997 (12) TMI 147 - ITAT DELHI</title>
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    <description>The court ruled in favor of the revenue assessees, determining that the Trust could not be classified as an Artificial Juridical Person and should be assessed as an Association of Persons. The Trust was found to have not allocated funds appropriately for its objectives, leading to the imposition of tax at the maximum marginal rate. Additionally, the court concluded that the Trust was not genuine and operated for tax evasion purposes, resulting in the inclusion of alleged donations as income of the assessee.</description>
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      <description>The court ruled in favor of the revenue assessees, determining that the Trust could not be classified as an Artificial Juridical Person and should be assessed as an Association of Persons. The Trust was found to have not allocated funds appropriately for its objectives, leading to the imposition of tax at the maximum marginal rate. Additionally, the court concluded that the Trust was not genuine and operated for tax evasion purposes, resulting in the inclusion of alleged donations as income of the assessee.</description>
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