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    <title>2025 (4) TMI 1620 - ITAT AHMEDABAD</title>
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    <description>Where a discretionary &quot;trust at will&quot; had only three identifiable beneficiaries and its sole income comprised interest distributed to those beneficiaries, the ITAT held that the trust&#039;s income was not liable to be taxed at the maximum marginal rate under s. 164, since the beneficiaries were determinate and the income was actually allocated among them. The AO was directed to assess the trust at the rate ordinarily applicable to an AOP rather than at the maximum marginal rate, and the appeal was allowed.</description>
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      <description>Where a discretionary &quot;trust at will&quot; had only three identifiable beneficiaries and its sole income comprised interest distributed to those beneficiaries, the ITAT held that the trust&#039;s income was not liable to be taxed at the maximum marginal rate under s. 164, since the beneficiaries were determinate and the income was actually allocated among them. The AO was directed to assess the trust at the rate ordinarily applicable to an AOP rather than at the maximum marginal rate, and the appeal was allowed.</description>
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      <pubDate>Mon, 28 Apr 2025 00:00:00 +0530</pubDate>
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