1999 (4) TMI 628

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..... ferred the following two questions of law for the opinion of this Court: 1. whether, on the facts and in the circumstances of the case, the Tribunal was right in law in coming to the conclusion that the provisions of Section 60 of the Income-tax Act, 1961 were not applicable to the facts of the case? 2.Whether in the facts and in the circumstances of the case, the Tribunal was righ .....

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..... ew therefore, the Tribunal rightly held that the principle of constructive receipt could not be invoked by the revenue authority for justifying its stand to include the interest income earned by the beneficiaries in the hands of the trustees. The court further held that the interest income did not accrue to beneficiaries by virtue of the transaction of the loan, but it accrued to them by virt .....

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