2007 (1) TMI 111

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....tions of law under section 256(1) of the Income-tax Act, 1961, for the opinion of this court: "1. Whether, on the facts and circumstances of the case, the Income-tax Appellate Tribunal was justified in holding that the assessee's-trusts were validly created trusts, when the sale beneficiaries of these trusts were neither in existence nor were identifiable at the time of creation of the trusts? ....

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....ot validly created as the sole beneficiary of each of the two trusts was neither in existence nor identifiable at the time of the creation of these trusts. Due to creation of these trusts the assessee did not show the dividend income on the above shares in her returns of income. Hence, the Department took action under section 147(a)/148 and added the dividend income on these shares in the hands of....