https://www.taxtmi.com/caselaws?id=802549 Section 164(2) applies to non-exempt income derived from property held wholly for charitable or religious purposes, irrespective of the trust's registration. Its association-of-persons fiction determines the ordinary rate structure and basic exemption, while its proviso specifies when the maximum marginal rate applies. Section 167B concerns associations whose members have shares in their income. Where there is no finding that members have such shares or income above the exemption limit, the specific provision prevails. The trust's net income is therefore taxable at ordinary association-of-persons rates with the basic exemption, rather than at the maximum marginal rate. en-us Tue, 03 Nov 2026 00:00:00 +0530 Sat, 07 Nov 2026 08:22:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=802549 Section 164(2) applies to non-exempt income derived from property held wholly for charitable or religious purposes, irrespective of the trust's registration. Its association-of-persons fiction determines the ordinary rate structure and basic exemption, while its proviso specifies when the maximum marginal rate applies. Section 167B concerns associations whose members have shares in their income. Where there is no finding that members have such shares or income above the exemption limit, the specific provision prevails. The trust's net income is therefore taxable at ordinary association-of-persons rates with the basic exemption, rather than at the maximum marginal rate. Case-Laws Income Tax Tue, 03 Nov 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=802549