https://www.taxtmi.com/caselaws?id=21200 The Calcutta HC determined that trustees of a discretionary private trust should be assessed as "individual" rather than "association of persons" under income tax law. The court held that "individual" does not exclusively refer to a single natural person and can include groups when context requires. The court distinguished discretionary trusts from charitable/religious trusts, noting that trustees and beneficiaries lack the voluntary association element essential for "association of persons" status. Following the Finance Act 1980 amendments removing deeming provisions for private trusts under section 164(1), the court ruled in favor of the assessee, confirming individual status for tax assessment purposes. en-us Thu, 19 Mar 1992 00:00:00 +0530 Thu, 20 Feb 2025 17:38:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=21200 The Calcutta HC determined that trustees of a discretionary private trust should be assessed as "individual" rather than "association of persons" under income tax law. The court held that "individual" does not exclusively refer to a single natural person and can include groups when context requires. The court distinguished discretionary trusts from charitable/religious trusts, noting that trustees and beneficiaries lack the voluntary association element essential for "association of persons" status. Following the Finance Act 1980 amendments removing deeming provisions for private trusts under section 164(1), the court ruled in favor of the assessee, confirming individual status for tax assessment purposes. Case-Laws Income Tax Thu, 19 Mar 1992 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=21200