https://www.taxtmi.com/caselaws?id=59762 The Tribunal dismissed the revenue's appeal, ruling that the assessee-trust is not subject to taxation at the maximum rate under Section 164 of the Income-tax Act, 1961. The decision emphasized that the beneficiaries were known and determinate as of the relevant date, and the trust provisions were clear and irrevocable. The Tribunal also noted that the legislative amendment to Section 164, introduced later, aimed to prevent manipulation and did not apply to the assessment year in question. en-us Mon, 07 Dec 1981 00:00:00 +0530 Sat, 01 Jan 2011 10:57:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59762 The Tribunal dismissed the revenue's appeal, ruling that the assessee-trust is not subject to taxation at the maximum rate under Section 164 of the Income-tax Act, 1961. The decision emphasized that the beneficiaries were known and determinate as of the relevant date, and the trust provisions were clear and irrevocable. The Tribunal also noted that the legislative amendment to Section 164, introduced later, aimed to prevent manipulation and did not apply to the assessment year in question. Case-Laws Income Tax Mon, 07 Dec 1981 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59762