having sole beneficiary but the
issue is having settlor as sole beneficiary."
10.5.3.1 "This provision requires that the creation of Trust is
reposing ... holding that:
i. That M/s EL by becoming the settlor and the sole
beneficiary had reserved all the rights with itself to deal
with
Beneficiaries are the same and
identical, as against the Settlor and Beneficiaries are different in an ideal
Trust."
3. "On the facts ... also the beneficiaries. Thus, in
the instant case, the settlor and beneficiaries are the same and identical. The
AO further held that the trust
Beneficiaries are the same and
identical, as against the Settlor and Beneficiaries are different in an ideal
Trust."
3. "On the facts ... also the beneficiaries. Thus, in
the instant case, the settlor and beneficiaries are the same and identical. The
AO further held that the trust
Beneficiaries are the same and
identical, as against the Settlor and Beneficiaries are different in an ideal
Trust."
3. "On the facts ... also the beneficiaries. Thus, in
the instant case, the settlor and beneficiaries are the same and identical. The
AO further held that the trust
laws of a country outside India, in which one is
trustee, beneficiary or settlor. There are similar requirements in Form ... must be granted.
33. As there is no bar to the settlor and beneficiary being the same person
and in view of the judgment
Financial Services Ltd. is the sole contributor and beneficiary, therefore, when
the beneficiary, trustee and Settlor are distinct persons/entities and the share ... Trust Co. Ltd.
III Beneficiary - As per schedule A as under :-
SCHEDULE A
THE BENEFICIARIES
Contributors / Beneficiaries
Class A Beneficiaries
Name Percentage
beneficiary, the income to which that beneficiary was entitled would be distributed equally amongst the legal heirs of that beneficiary (settlor excluded). The trust deed ... trust deed, the real beneficiary is the AOP/BOI, consisting of the various beneficiaries. Actually, the beneficiaries are not carrying on any business
being disposed of by this common order.
2. The assessee was a beneficiary in a private trust, known as "Lokhandwala Developers", created ... trust, examining the balance-sheets, the relation between the settlor, beneficiaries and the trustees, the Assessing Officer concluded that it was a well planned
determination of trust if the beneficiary dies then the heirs of the beneficiary or beneficiaries other than the settlor shall be treated as equal beneficiary ... trust any beneficiary dies, the interest of other beneficiaries get enhanced to the extent of the share of the deceased beneficiary. The settled amount
under:
"1. Whereas in the case of the trust, settlor, contributor and beneficiaries,
all have to be independent and distinct. In the case ... defines beneficiary as
"9. Who may be beneficiary
Every person capable of holding property may be a beneficiary.
Section 7 of the Indian Trust
