Court : Income Tax Appellate Tribunal ITAT Madras
Decided on : Apr-30-1991
Reported in : (1991)38ITD409(Mad.)
..... 88 itr 192 (sc), would arise, according to which when there are two constructions possible, the one in favour of the assessee should be preferred and adopted.however, in our opinion in the wording of section 161(1a) there is no ambiguity whatsoever present and ..... recipient of lease amount and that it was not carrying on any activity or trade which involved various acts like placing order on kumudam, take charge of copies, arrange for distribution and the other connected activities. the income-tax officer held that ..... beneficiary under the assessee-trust, represented by sri sap annamalai, who holds 90% share both as individual as well as hindu undivided family in the equity capital of a closely held private limited company called kumudam publications pvt. ltd. the learned departmental ..... and the buildings were lying idle. the powerlooms were commissioned again to work by r with effect from 1-11-1956 under an agreement dated 13-6-1957 and which was renewed on 16-4-1958. under the agreement, though r ..... and shall be utilised for the general welfare, education, marriage and maintenance expenses of the second, third, fourth, fifth and sixth beneficiaries and for purposes of making payments for the maintenance expenses of and for carrying out of the objects of the ..... ratio among the beneficiaries under the trust. it had shown the break-up of the total income of rs. 1,27,480 as follows : the assessee trust claimed that the consideration derived by it for appointing varalakshmi agencies as its sub .....Tag this Judgment!