Trustee's Income in India Taxable; Beneficiaries in Netherlands Eligible for Treaty Protection Against Double Taxation.

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....Income accrued in India - turstee of a trust - representative assessee - The beneficiaries are thus clearly taxable entities in Netherlands. What essentially follows is like this. If the assessee is to be taxed in its own right, which is not even the case of the revenue, there cannot be any dispute that the assessee is a taxable entity in the Netherlands, and, for this reason, the assessee is liable for treaty protection....