https://www.taxtmi.com/caselaws?id=788435 Whether payments from a trust to related concerns attract the embargo in Section 13(1)(c) turns on material showing diversion of trust income for the direct or indirect benefit of persons specified in Section 13(3); mere higher profit margins or higher director remuneration in related entities, without comparative material demonstrating diversion, do not attract the embargo, and earlier acceptance by the tax authority in identical factual matrices must be maintained under the rule of consistency. The appeals were dismissed in favour of the assessee. en-us Sat, 21 Feb 2026 00:00:00 +0530 Sat, 21 Mar 2026 08:29:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788435 Whether payments from a trust to related concerns attract the embargo in Section 13(1)(c) turns on material showing diversion of trust income for the direct or indirect benefit of persons specified in Section 13(3); mere higher profit margins or higher director remuneration in related entities, without comparative material demonstrating diversion, do not attract the embargo, and earlier acceptance by the tax authority in identical factual matrices must be maintained under the rule of consistency. The appeals were dismissed in favour of the assessee. Case-Laws Income Tax Sat, 21 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788435