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2001 (9) TMI 26

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....he assessment years are 1981-82 and 1982-83. This court in the case of CIT v. Sitalakshmi (Minor) [1996] 217 ITR 595, in circumstances were similar to those in this case, held in favour of the assessee and against the Revenue. That decision however would not apply to the facts of the case before us, as Explanation 2A to section 64 was incorporated in the statute with effect from April 1, 1980, ....

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....o arise indirectly to the minor from the admission of the trustee to the benefits of the partnership. The mere fact that the minor's right to receive the income is postponed till he attains the age of majority does not defeat this Explanation. The law deems the income to have arisen indirectly to the minor by virtue of the trustee having been admitted to the benefits of the partnership and the tim....