https://www.taxtmi.com/caselaws?id=16074 The High Court of Madras interpreted Section 164(1) of the Act in a case concerning the assessment of income for the years 1977-78 and 1978-79. The court held that the trust, with T. G. C. Raman as the sole beneficiary, was not subject to taxation at the highest marginal rate. The court emphasized that the key factor was the trustees' obligation to apply income for the known beneficiary's benefit, regardless of income vesting in the beneficiary. The court distinguished the case from discretionary trusts and ruled in favor of the assessee, upholding the Tribunal's decision and awarding costs against the Revenue. en-us Wed, 10 Jun 1998 00:00:00 +0530 Mon, 31 Aug 2009 18:07:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=16074 The High Court of Madras interpreted Section 164(1) of the Act in a case concerning the assessment of income for the years 1977-78 and 1978-79. The court held that the trust, with T. G. C. Raman as the sole beneficiary, was not subject to taxation at the highest marginal rate. The court emphasized that the key factor was the trustees' obligation to apply income for the known beneficiary's benefit, regardless of income vesting in the beneficiary. The court distinguished the case from discretionary trusts and ruled in favor of the assessee, upholding the Tribunal's decision and awarding costs against the Revenue. Case-Laws Income Tax Wed, 10 Jun 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=16074