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    <title>1998 (2) TMI 113 - GUJARAT High Court</title>
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      <link>https://www.taxtmi.com/caselaws?id=17141</link>
      <description>The court held that the character of a discretionary trust cannot be changed by a resolution passed by the trustees. The Tribunal&#039;s decision was overturned as it erred in holding that the Income-tax Officer was not justified in applying the 65% tax rate under section 164. The court found that the shares of the beneficiaries remained indeterminate, leading to the application of the 65% rate. The decision favored the Revenue and ruled against the assessee, resulting in no order as to costs.</description>
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      <pubDate>Thu, 26 Feb 1998 00:00:00 +0530</pubDate>
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