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Reopening of Trust Assessment u/s 147 Invalid Due to No Income Escapement Linked to Beneficiaries' Returns.

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....Reopening of assessment u/s 147 - Assessment of trust - There is a direct live link between the rental income received by the trust and the income shown by the beneficiaries in the respective returns as per their respective share of rental income as specified in the trust deed and, therefore, there is no escapement of income at all. We hold that the reopening of the assessment is bad in law. - AT....

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