https://www.taxtmi.com/caselaws?id=9502 The High Court held that the provisions of section 164(1), proviso (ii), were not applicable in a case involving a trust with an indeterminate share of beneficiaries. The Court ruled in favor of the assessee-trust, stating that since the trust was created solely for the benefit of one individual, the aggregation of interest income for the purpose of section 164(1) was unnecessary. The Court disagreed with the Revenue's argument regarding multiple trusts, emphasizing that section 164(1) is triggered only when the shares of different beneficiaries in a trust are indeterminate or unknown. The decision favored the assessee-trust, and the reference was disposed of with no order as to costs. en-us Tue, 29 Mar 2005 00:00:00 +0530 Tue, 23 Jun 2009 15:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=9502 The High Court held that the provisions of section 164(1), proviso (ii), were not applicable in a case involving a trust with an indeterminate share of beneficiaries. The Court ruled in favor of the assessee-trust, stating that since the trust was created solely for the benefit of one individual, the aggregation of interest income for the purpose of section 164(1) was unnecessary. The Court disagreed with the Revenue's argument regarding multiple trusts, emphasizing that section 164(1) is triggered only when the shares of different beneficiaries in a trust are indeterminate or unknown. The decision favored the assessee-trust, and the reference was disposed of with no order as to costs. Case-Laws Income Tax Tue, 29 Mar 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=9502