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The High Court of Bombay ruled in favor of the assessee-trust for the assessment year 1978-79, stating that section 164(1) of the Income-tax Act, 1961 was not applicable. The beneficiaries were specified individuals with determined shares, and their income had been properly distributed and taxed. The court found no evidence to support the Department's claim. The judgment was delivered by Judge S. H. Kapadia.
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