gratuity fund for the exclusive benefit of his employees under an irrevocable trust, the application for the approval of the fund having been made before ... gratuity fund for the exclusive benefit of his employees under an irrevocable trust, the application for the approval of the fund having been made before
relied on case the amount was paid to an irrevocable trust and the applicability of Section 40A(9) has not been gone into. In appeal ... exclusive benefit of his employees under an irrevocable trust.
24. In the present case, the assessee has claimed deduction under clause (v) of Section
under a deed of gift, bequest, will or transfer on irrevocable trust shall not, for the purposes of this section, be treated as sale, exchange ... company or under a deed of gift, or transfer on irrevocable trust, its actual cost allowable to him for the purposes of this section shall
contribution to an approved gratuity fund created under an irrevocable trust or a sum paid as an employer by way of contribution towards a recognised ... deduction. Instances have come to notice where certain employers have created irrevocable trusts, ostensibly for the welfare of employees, and transferred to such trusts substantial
assessee created two trusts known as M. C. Shyamala Marriage Benefit Trust and M. S. Sowmiyaram Marriage Benefit Trust. The trusts were created under ... married. Clause 19 of the trust deeds states that the trusts are irrevocable. Clause 22 of the trust deeds states that if the said intended
exclusive benefit of his employees under an irrevocable trust. He was of the opinion that under mercantile system of accounting 'paid' includes payable ... payment made to an approved gratuity fund created under deed of irrevocable trust. The learned senior standing counsel also pointed out that
gratuity fund for the exclusive benefit of his employees under an irrevocable trust, the application for the approval of the fund having been made before ... gratuity fund for the exclusive benefit of his employees under an irrevocable trust, the application for the approval of the fund having been made before
trusts. The ITO held that in view of cl. 22 of the trust deeds, the trusts could not be treated as irrevocable trusts. Since ... trust deed was with reference to the trust property and such reinvesture of the trust estate was only in the settlor of the trusts
Trust. The Wealth-tax Officer in the assessment proceedings for the assessment years 1980-81 and 1981-82 held that the trusts were revocable trusts ... trusts both of the M. C. Shyamala Marriage Benefit Trust and M. C. Sowmyaram Marriage Benefit Trust and held that the trusts are irrevocable trusts
capital asset under a gift or will or an irrevocable trust; ......... "
30. This section would apply only if there was a transfer of capital
