https://www.taxtmi.com/caselaws?id=794594 A public charitable trust whose income could not be distributed to members or trustees and was confined to charitable objects was not liable to tax at the Maximum Marginal Rate under section 164(1) merely because it was unregistered under sections 12AA/12AB and did not claim exemption under sections 11 to 13. Section 164(1) applies to discretionary trusts with indeterminate shares, and cannot be invoked mechanically where no beneficiary has a share in the income. Relying on CBDT Circular No. 320, the ITAT Bangalore held that such a trust is taxable at the normal rates applicable to an Association of Persons, and the Revenue's reliance on private discretionary trust cases was rejected. en-us Wed, 03 Jun 2026 00:00:00 +0530 Wed, 08 Jul 2026 09:08:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794594 A public charitable trust whose income could not be distributed to members or trustees and was confined to charitable objects was not liable to tax at the Maximum Marginal Rate under section 164(1) merely because it was unregistered under sections 12AA/12AB and did not claim exemption under sections 11 to 13. Section 164(1) applies to discretionary trusts with indeterminate shares, and cannot be invoked mechanically where no beneficiary has a share in the income. Relying on CBDT Circular No. 320, the ITAT Bangalore held that such a trust is taxable at the normal rates applicable to an Association of Persons, and the Revenue's reliance on private discretionary trust cases was rejected. Case-Laws Income Tax Wed, 03 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794594