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    <title>2004 (12) TMI 638 - ITAT BANGALORE</title>
    <link>https://www.taxtmi.com/caselaws?id=119150</link>
    <description>The Tribunal upheld the addition of income under section 64(1)(a) due to the clubbing of income from a Trust for minor children of the assessee. It found that the arrangement where the assessee claimed interest expenses payable to a Trust where she was also a trustee, leading to a circular flow of funds, lacked legitimate tax planning. The Tribunal applied principles from the McDowell case, holding that the interest expenses should be treated as paid to the Trustee (the assessee) herself, resulting in the clubbing of income for the minor children under section 64(1A). Both appeals were dismissed, with consequential interest charges applied.</description>
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    <pubDate>Tue, 21 Dec 2004 00:00:00 +0530</pubDate>
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      <title>2004 (12) TMI 638 - ITAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=119150</link>
      <description>The Tribunal upheld the addition of income under section 64(1)(a) due to the clubbing of income from a Trust for minor children of the assessee. It found that the arrangement where the assessee claimed interest expenses payable to a Trust where she was also a trustee, leading to a circular flow of funds, lacked legitimate tax planning. The Tribunal applied principles from the McDowell case, holding that the interest expenses should be treated as paid to the Trustee (the assessee) herself, resulting in the clubbing of income for the minor children under section 64(1A). Both appeals were dismissed, with consequential interest charges applied.</description>
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      <pubDate>Tue, 21 Dec 2004 00:00:00 +0530</pubDate>
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