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    <title>1977 (12) TMI 27 - GUJARAT High Court</title>
    <link>https://www.taxtmi.com/caselaws?id=38436</link>
    <description>The case involved the taxability of income received by the assessee from discretionary trusts. The Appellate Tribunal held that such income should be taxed in the hands of the trustees under Section 164 of the Income-tax Act, 1961, as the shares of the beneficiaries were indeterminate and unknown. The majority opinion emphasized that Section 164 overrides general provisions and concluded that the income should be assessed in the hands of the trustees. The dissenting opinion argued for the option to tax the income in the hands of the beneficiaries. Ultimately, the majority ruled in favor of the assessee, directing the income to be assessed in the trustees&#039; hands under Section 164.</description>
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    <pubDate>Fri, 23 Dec 1977 00:00:00 +0530</pubDate>
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      <title>1977 (12) TMI 27 - GUJARAT High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=38436</link>
      <description>The case involved the taxability of income received by the assessee from discretionary trusts. The Appellate Tribunal held that such income should be taxed in the hands of the trustees under Section 164 of the Income-tax Act, 1961, as the shares of the beneficiaries were indeterminate and unknown. The majority opinion emphasized that Section 164 overrides general provisions and concluded that the income should be assessed in the hands of the trustees. The dissenting opinion argued for the option to tax the income in the hands of the beneficiaries. Ultimately, the majority ruled in favor of the assessee, directing the income to be assessed in the trustees&#039; hands under Section 164.</description>
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      <pubDate>Fri, 23 Dec 1977 00:00:00 +0530</pubDate>
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