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    <title>1999 (4) TMI 628 - GUJARAT HIGH COURT</title>
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    <description>Income earned by beneficiaries from investments made in their own right could not be assessed in the hands of the trust under Section 60 of the Income-tax Act, 1961, because the beneficiaries were not acting as agents of the trust and the income arose from their own subsequent investments. The doctrine of constructive receipt also failed on the same factual basis, as the interest was not income received by or on behalf of the trustees. Both issues were answered in favour of the assessee, and the reference was disposed of accordingly.</description>
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    <pubDate>Tue, 06 Apr 1999 00:00:00 +0530</pubDate>
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      <title>1999 (4) TMI 628 - GUJARAT HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=190004</link>
      <description>Income earned by beneficiaries from investments made in their own right could not be assessed in the hands of the trust under Section 60 of the Income-tax Act, 1961, because the beneficiaries were not acting as agents of the trust and the income arose from their own subsequent investments. The doctrine of constructive receipt also failed on the same factual basis, as the interest was not income received by or on behalf of the trustees. Both issues were answered in favour of the assessee, and the reference was disposed of accordingly.</description>
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      <pubDate>Tue, 06 Apr 1999 00:00:00 +0530</pubDate>
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