Court Examines If Trust Beneficiaries Are an Association of Persons u/s 177(3) of Income Tax Act.

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....Outstanding demand u/s 177(3) - beneficiaries who are named in the trust as recipients of the income of the trust cannot be considered as an association of persons. - If that be the position, prima facie, the question as to whether Section 177(3) would apply to the Petitioner raises a serious issue for consideration. - HC....