1998 (1) TMI 5

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....for its opinion. The main controversy before the High Court was with regard to the applicability of section 161 or 164 of the Income-tax Act, 1961, with regard to the assessment of the profits. The question was whether on the distribution of the profits amongst the beneficiaries the assessment was to be made under section 161 or whether the trust was to be assessed under section 164 as an associat....