https://www.taxtmi.com/caselaws?id=69266 The Tribunal upheld the AAC's decision, dismissing the Revenue's appeals. It concluded that uncertainty of beneficiaries does not justify invoking s. 164 to tax trust income at the maximum rate. The decision was based on the principle that the trust had clearly allocated assets to specific beneficiaries without reversion during the relevant accounting years, making the ITO's inclusion of trust income at the maximum rate incorrect. The appeals were ultimately dismissed, affirming the AAC's decision and rejecting the Revenue's argument to apply s. 164 due to uncertainty of beneficiaries. en-us Wed, 07 Mar 1979 00:00:00 +0530 Wed, 06 Apr 2011 10:29:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=69266 The Tribunal upheld the AAC's decision, dismissing the Revenue's appeals. It concluded that uncertainty of beneficiaries does not justify invoking s. 164 to tax trust income at the maximum rate. The decision was based on the principle that the trust had clearly allocated assets to specific beneficiaries without reversion during the relevant accounting years, making the ITO's inclusion of trust income at the maximum rate incorrect. The appeals were ultimately dismissed, affirming the AAC's decision and rejecting the Revenue's argument to apply s. 164 due to uncertainty of beneficiaries. Case-Laws Income Tax Wed, 07 Mar 1979 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=69266