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    <title>2024 (6) TMI 568 - ITAT MUMBAI</title>
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    <description>A trust arrangement was analysed as a valid revocable trust where the deed allowed revocation of contributions and the contributors and beneficiaries could overlap without invalidating the structure. The trust was not treated as an association of persons because the investments were made separately and there was no common concerted purpose among the security receipt holders. As the beneficial shares were identifiable from inception, the trust was also not indeterminate. Income was therefore governed by the revocable transfer provisions and assessable in the hands of the beneficiaries under sections 61 to 63 of the Income-tax Act, 1961, rather than in the hands of the trust.</description>
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      <description>A trust arrangement was analysed as a valid revocable trust where the deed allowed revocation of contributions and the contributors and beneficiaries could overlap without invalidating the structure. The trust was not treated as an association of persons because the investments were made separately and there was no common concerted purpose among the security receipt holders. As the beneficial shares were identifiable from inception, the trust was also not indeterminate. Income was therefore governed by the revocable transfer provisions and assessable in the hands of the beneficiaries under sections 61 to 63 of the Income-tax Act, 1961, rather than in the hands of the trust.</description>
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