Trust Taxed at 30% Marginal Rate, Not Eligible as AOP u/s 164(2) Due to Section 11 Ineligibility.

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....Assessment of trust - Application of Maximum Marginal rate @ 30% - To be treated as AOP u/s 164 or not - As such subsection (2) of section 164 of the Act provides to charge the tax on the part of income which is not exempt treating the same as income of the Association of persons. However, in the case on hand, the trust before us is not eligible for exemption under section 11 of the Act for the year under consideration. Therefore, the same cannot be treated as Association of persons in the manner as provided under subsection (2) of section 164 of the Act. - AT....