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13. Mr. Meyer next contended that even assuming that the case is governed by the substantive part of Section 41(1) the entire income is receivable on behalf of Birendra alone as Clause 1 of the trust deed requires payment of the whole income to Birendra and therefore the tax on the income must be levied in a single sum. In my opinion there are at least two answers to this contention. Firstly Clause 1 of the trust deed properly read means that the beneficiaries under the trust are Sudhamukhi, Birendra Suprovat, Jyotsna and Indrajit and that instead of both trustees making the payments to those beneficiaries the duty of making those payments is delegated to one trustee namely Birendra In other words Birendra is not the sole beneficiary on whose behalf the rents are receivable. The persons on whose behalf the income is receivable are Sudhamukhi, Birendra, Suprovat, Jyotsna and Indrajit. Secondly assuming for a moment that the entire income is receivable by the two trustees on behalf of Birendra alone the tax must be levied on the two trustees in the same manner and to the same amount as it would be leviable upon Birendra. Now by the very same trust deed the entire income in the hands of Birendra is impressed with a trust in favour of the beneficiaries, Sudhamukhi, Birendra, Suprovat, Jyotsna and Indrajit and definite portions of the income are specifically receivable by Birendra as a trustee on behalf of those beneficiaries. In view of Section 41 the tax would then be leviable upon Birendra in separate sums. It follows that the tax must be levied on the two trustees in the same manner and in separate sums.