https://www.taxtmi.com/caselaws?id=25957 The Tribunal upheld the Commissioner of Income-tax's action under section 263, setting aside the Income-tax Officer's assessment orders for the years 1976-77 and 1977-78 regarding Moti Trust. The Tribunal agreed that the trust was discretionary, with indeterminate beneficiary shares, leading to the applicability of section 164. The Tribunal rejected arguments against the discretionary nature of the trust and affirmed the Commissioner's jurisdiction under section 263. All legal questions were decided against the assessee, with no costs awarded. en-us Thu, 03 Jan 1985 00:00:00 +0530 Tue, 02 Feb 2010 10:06:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=25957 The Tribunal upheld the Commissioner of Income-tax's action under section 263, setting aside the Income-tax Officer's assessment orders for the years 1976-77 and 1977-78 regarding Moti Trust. The Tribunal agreed that the trust was discretionary, with indeterminate beneficiary shares, leading to the applicability of section 164. The Tribunal rejected arguments against the discretionary nature of the trust and affirmed the Commissioner's jurisdiction under section 263. All legal questions were decided against the assessee, with no costs awarded. Case-Laws Income Tax Thu, 03 Jan 1985 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=25957