capital asset under a gift or will
or an irrevocable trust:
Provided that this clause shall not apply to transfer
under a gift ... irrevocable trust of a capital asset
being shares, debentures or warrants allotted by a
company directly or indirectly to its employees under
any Employees
create
thereby a trust, (b) the purpose of the trust, (c) the
beneficiary, and (d) the trust property and (unless the
trust is declared ... trust property which was specified in Schedule "A" to
the Deed of Trust dated 11-4-1961. Though the trust was
irrevocable
create thereby a trust, (b) the purpose of the trust, (c) the beneficiary, and (d) the trust property and (unless the trust is declared ... trust property which was specified in Schedule "A" to the deed of trust dt. 11th April, 1961. Though the trust was irrevocable
association of persons, or bequest under a gift, will or an irrevocable trust; or transfer of a capital asset by a company to its subsidiary ... company, or
(d) under a transfer to a revocable or an irrevocable trust, or
(e) under any such transfer as is referred to in clause
exclusive benefit of his employees under an irrevocable trust."
21. The above clause shall be read in respect of matters spelt out therein ... exclusive benefit of his employees under an irrevocable trust.
22. On a plain reading of these provisions it is apparent that any sum paid
were subsequently fulfilled, inasmuch as an irrevocable trust fund had been created before January 1, 1979, and a sum equal to 50 per cent ... April, 1979. However, it was noticed that the irrevocable trust fund created by the assessee was not approved by the Commissioner of Income-tax under
benefit of the employees of the company, an irrevocable deed of trust was executed to promote contentment and to ensure continuance of cordial relations between ... capital asset and not an expenditure of a revenue character". Irrevocable trust is executed by the company in favour of the trustees
belonged to the assessee and not to the K. T. Doctor Family Trust ?
(2) If the answer to the above question ... October 1, 1971, to March 31, 1972. By a deed of irrevocable trust dated September 30, 1971, Savitaben Tapidas, the mother of the assessee, settled
value of Rs. 52,744 given to the Bhavana Nalinkant Trust ?"
2. The applicant-assessee is an individual. The assessment year ... March 31, 1980. On February 19, 1979, the assessee created an irrevocable trust with initial sum of Rs. 1,000 by executing a deed
exclusive benefit of his employees under an irrevocable trust, was rejected in the following words at p. 67 :
"This argument is plainly incorrect because
