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1981 (8) TMI 98 - ITAT BOMBAY-CExtract: .......nsideration, the beneficiaries and their respective shares are known and determinable. Therefore, the provisions of s 164(1) of the Act are not applicable to the facts and circumstances of the case and the CIT (Appeals) has acted accordingly in arriving at his conclusion. Hence we confirm his orders. 8. In the result both the appeals are dismissed.
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