1991 (3) TMI 111

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....interpretation of the trust deed dated June 30, 1962, the assessees were liable to pay tax on 75 per cent. of its total income at the maximum rate of 65 per cent. as provided by section 164 of the Income-tax Act, 1961 ?" One Shri Chiranjilal Shrilal Goenka settled some of his properties on trust by an indenture dated June 30, 1962. The indenture, inter alia, provided that the trust income shall be accumulated for 18 years. Thereafter, 25% of the trust fund along with its accumulations will be spent on charity as mentioned in clause 4 of the indenture and the remaining 75% will be handed over to the wife or widow of the settlor's son, Shri Radheshyam Chiranjilal Goenka, who may be then living and if, at the relevant time, there is no such....

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....: "164. (1) Subject to the provisions of sub-sections (2) and (3), where any income in respect of which the persons mentioned in clauses (iii) and (iv) of sub-section (1) of section 160 are liable as representative assessees or any part thereof is not specifically receivable on behalf or for the benefit of any one person or where the individual shares of the persons on whose behalf or for whose benefit such income or such part thereof is receivable are indeterminate or unknown (such income, such part of the income and such persons being hereafter in this section referred to as 'relevant income', 'part of relevant income' and 'beneficiaries', respectively), tax shall be charged (i) as if the relevant income or part of relevant income were....