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1980 (6) TMI 15 - HC - Income TaxExtract: .......ssessees do not form income in the hands of the two assessee-trusts and do not, therefore, attract the applicability of the provisions of sub-s. (2) of s. 12. The question referred in these two cases is accordingly answered in the negative, that is, in favour of the assessees and against the department. The parties will bear their respective costs.
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