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    <title>2020 (9) TMI 465 - ITAT MUMBAI</title>
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    <description>A trust deed permitting contributors to be beneficiaries was treated as valid, because no legal bar existed and there was no common scheme to treat the arrangement as an association of persons. The deed also provided for re-transfer of trust assets to security receipt holders, so the contribution was a revocable transfer and the corresponding tax provisions applied even though revocation required collective consent. The trust&#039;s beneficiaries and shares were fixed from inception, making it determinate rather than discretionary or indeterminate. A write-back of impairment provision was not taxable as income, as it was only a reversal of an accounting entry and no real receipt or prior allowance of deduction was shown.</description>
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