https://www.taxtmi.com/caselaws?id=33214 Section 164 of the Income-tax Act applies only where beneficiaries or their shares are indeterminate or unknown. On the trust deed, the beneficiaries were specifically identified and their shares were ascertainable, and later contingencies such as marriage or birth of children did not make those shares uncertain because the deed provided a mechanism for substitution and adjustment. The trustees therefore could not be assessed under section 164. The separate issue on the advance ruling did not survive independently because the Tribunal had relied on binding judicial precedent, not on the ruling as a standalone basis. en-us Wed, 15 Apr 2009 00:00:00 +0530 Mon, 03 May 2010 12:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=33214 Section 164 of the Income-tax Act applies only where beneficiaries or their shares are indeterminate or unknown. On the trust deed, the beneficiaries were specifically identified and their shares were ascertainable, and later contingencies such as marriage or birth of children did not make those shares uncertain because the deed provided a mechanism for substitution and adjustment. The trustees therefore could not be assessed under section 164. The separate issue on the advance ruling did not survive independently because the Tribunal had relied on binding judicial precedent, not on the ruling as a standalone basis. Case-Laws Income Tax Wed, 15 Apr 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=33214