Interest-Free Loan Between Trusts: No Substantial Interest or Benefit, Section 13(1)(c) Not Applicable.

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....The interest free loan was given to another trust and the common trustee have no substantial interest in any of the trust. Therefore in the absence of any direct or indirect benefit to the trustees or author of assessee trust or to the trustees of the resident trust the provisions of section 13(1)(c) cannot be attracted. - AT....