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    <title>2004 (2) TMI 277 - ITAT BANGALORE-C</title>
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    <description>Section 164(1) of the Income-tax Act did not apply to the trust income because the beneficiary was alive, identifiable, and entitled under the trust deed during the relevant previous year. The deed required accumulation of income until the beneficiary attained majority and directed transfer of corpus and accumulated income only on that event; the possibility of a later contingency, including death before determination of the trust, did not make the income indeterminate for the year under assessment. The majority held that entitlement must be examined on the relevant accounting date, and the trust income was therefore not assessable at the maximum marginal rate under section 164(1).</description>
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    <pubDate>Fri, 27 Feb 2004 00:00:00 +0530</pubDate>
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      <title>2004 (2) TMI 277 - ITAT BANGALORE-C</title>
      <link>https://www.taxtmi.com/caselaws?id=57839</link>
      <description>Section 164(1) of the Income-tax Act did not apply to the trust income because the beneficiary was alive, identifiable, and entitled under the trust deed during the relevant previous year. The deed required accumulation of income until the beneficiary attained majority and directed transfer of corpus and accumulated income only on that event; the possibility of a later contingency, including death before determination of the trust, did not make the income indeterminate for the year under assessment. The majority held that entitlement must be examined on the relevant accounting date, and the trust income was therefore not assessable at the maximum marginal rate under section 164(1).</description>
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      <pubDate>Fri, 27 Feb 2004 00:00:00 +0530</pubDate>
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