2001 (6) TMI 20 - HC - Income Tax

Summary

The High Court of Madras ruled that an assessee-trust cannot claim the benefit of section 164(1) of the Income-tax Act, 1961 if it fails to satisfy the requirements of the Act. The court emphasized that even if beneficiaries and trustees transfer assets between trusts, it does not change the fact that multiple trusts were created by the settlor. The judgment favored the Revenue over the assessee.