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3. In this background, For AY 2016-17 the appellant filed its return in the status of an Association of Persons [ AOP] declaring income of Rs. Nil by claiming the dividend of Rs. 4,47,60,037/- as exempt u/s 10(34) of the Income Tax Act, 1961("the Act"). In the assessment proceedings the assessing officer ("the Ld AO") sought information more specifically on the purpose of the formation of various trusts, their dissolution and the legal status and validity of the appellant trust namely EBWT. The ld AO also issued notices u/s 131 of the Act to the current and former trustees and recorded their statements. Namely, (1) Shri S.A. Dave (trustee up to 27October 2016), (2) Shri G. B. Mathur (appointed trustee w.e.f. 2September 2014) and (3) Shri Ajay Sharma (appointed w.e.f. 30January 2016). Pursuant to the recording of the statements, the ld AO concluded as under: