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1966 (5) TMI 14 - SC - Wealth-taxWhether the shares in question held by the trustees under the Second Trust are held for the benefit of the three minor children mentioned in the Second Trust deed? Held that:- The word " benefit " in the context means for the immediate benefit of the individual or his wife or minor child. If a property is transferred to trustees to hold in trust for the life of A and then for B, we cannot hold that the property is held for the benefit of B during the lifetime of A. As will appear later, under the Second Trust, the trustees hold the trust property for the benefit of the charitable trust for a number of years before they start holding it for the benefit of the minor children. It is difficult to say that while the property is being held for the benefit of the charitable trust, it is also being held for the benefit of the minor children. Thus considering the document as a whole the shares were not held for the benefit of the three minor children as on March 31, 1958, and March 31, 1959. Accordingly the answer to the question referred by the Appellate Tribunal and set out above must be against the revenue
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