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
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
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
authentic material before him relating to the trust, trustee, settlor,
beneficiaries, whether the trust is specific or discretionary and dates of deposit
in the bank ... beneficiaries, so that
secrecy is maintained.
The ATO-understands that In practice the foundation board members act on the
wishes or instructions of the settlor
benefit of the
settlor/ contributor and the trust has three constituents i.e. settlor, contributor and
beneficiaries. It was claimed all the constituents are independent ... benefit
of a single beneficiary or where the beneficiaries are more than one, the individual
shares of the beneficiaries are indeterminate or unknown, the last
master trust' are beneficiaries in the subsidiary trusts, (2) none of the beneficiaries are related to the settlor of the 'master trust ... have taken 10 cases of the beneficiary trusts and have given the names of trustees, beneficiaries, settlor, the amount settled, etc., respectively.
The assessee
