In the result, all the three appeals of the assessee are allowed
Bench: Dr.Manish Boradआयकर अपील सं. / Ita Nos.2816, 2817 & 2560/Pun/2024 Assessment Years : 2010-11, 2014-15 & 2016-17
charitable trust, where the shares of the beneficiaries are in determinate are not known, unlike an AOP, where the beneficiaries have a defined share in the income. It is noted that Section 164 is a special provision that prevails over the general provision of Section 167B