https://www.taxtmi.com/caselaws?id=751480 ITAT Jodhpur held that a trust denied exemption under sections 11-12 should be taxed under section 164(2) at individual/AOP rates rather than section 164(1) at maximum marginal rate, as beneficiaries are general public with no specific shares. The tribunal noted the trust obtained section 12A registration on 22.03.2022, distinguishing it from provisions under sections 13(1)(c) and (d). CIT(A)'s decision to apply section 164(1) was incorrect. The tribunal also directed the AO to allow deduction of expenditure claimed for trust purposes, considering the subsequent registration. Both grounds raised by the assessee were allowed. en-us Mon, 15 Apr 2024 00:00:00 +0530 Wed, 17 Apr 2024 13:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751480 ITAT Jodhpur held that a trust denied exemption under sections 11-12 should be taxed under section 164(2) at individual/AOP rates rather than section 164(1) at maximum marginal rate, as beneficiaries are general public with no specific shares. The tribunal noted the trust obtained section 12A registration on 22.03.2022, distinguishing it from provisions under sections 13(1)(c) and (d). CIT(A)'s decision to apply section 164(1) was incorrect. The tribunal also directed the AO to allow deduction of expenditure claimed for trust purposes, considering the subsequent registration. Both grounds raised by the assessee were allowed. Case-Laws Income Tax Mon, 15 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751480