https://www.taxtmi.com/caselaws?id=55637 The judgment determined that the assessee-trusts should be taxed under section 21(1) rather than section 21(4) due to the indeterminate nature of beneficiaries' shares as per clauses 15 and 16 of the trust deed. It was held that trustees had discretionary powers to distribute corpus and make investments under clause 23, impacting tax assessment. The argument invoking the proviso to section 21(4) was rejected. The trustees' authority to distribute corpus, not limited to loans, was affirmed, with subsequent loan recovery not affecting beneficiaries' shares. The decision emphasized trust clause interpretation's significance in tax assessments, leading to assessment under section 21(1) and allowing all appeals. en-us Wed, 15 Mar 1989 00:00:00 +0530 Mon, 29 Nov 2010 11:26:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=55637 The judgment determined that the assessee-trusts should be taxed under section 21(1) rather than section 21(4) due to the indeterminate nature of beneficiaries' shares as per clauses 15 and 16 of the trust deed. It was held that trustees had discretionary powers to distribute corpus and make investments under clause 23, impacting tax assessment. The argument invoking the proviso to section 21(4) was rejected. The trustees' authority to distribute corpus, not limited to loans, was affirmed, with subsequent loan recovery not affecting beneficiaries' shares. The decision emphasized trust clause interpretation's significance in tax assessments, leading to assessment under section 21(1) and allowing all appeals. Case-Laws Income Tax Wed, 15 Mar 1989 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=55637