https://www.taxtmi.com/caselaws?id=19480 Where a trust is only partly for charitable or religious purposes, the portion of income not specifically receivable by any identified beneficiary is taxed under section 164(1) if the beneficiaries' shares are indeterminate or unknown. The trust deed gave definite shares to the named beneficiaries for 85% of the income, so section 164(3) did not apply to that portion. The remaining 15% credited to the charity account was not earmarked for any specific beneficiary and had indeterminate shares, so it fell within section 164(1). The income attributable to the charity account was therefore chargeable at the rate applicable under section 164(1). en-us Tue, 03 Jan 1995 00:00:00 +0530 Fri, 06 Nov 2009 14:14:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=19480 Where a trust is only partly for charitable or religious purposes, the portion of income not specifically receivable by any identified beneficiary is taxed under section 164(1) if the beneficiaries' shares are indeterminate or unknown. The trust deed gave definite shares to the named beneficiaries for 85% of the income, so section 164(3) did not apply to that portion. The remaining 15% credited to the charity account was not earmarked for any specific beneficiary and had indeterminate shares, so it fell within section 164(1). The income attributable to the charity account was therefore chargeable at the rate applicable under section 164(1). Case-Laws Income Tax Tue, 03 Jan 1995 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=19480