Income from revocable trust was taxable in settlor’s hands and not in hands of Trust

Green Maiden A 2013 Trust Vs ACIT (ITAT Mumbai) Conclusion: Addition made by AO in the hands of the trust was not justified as income from investments was taxable in the settlor’s hands and exempt under the India-UAE Double Taxation Avoidance Agreement (DTAA). Held: Assessee earned income of Rs. 5,58,71,311 from investments in India, which AO taxed in the trust’s hands under Section 147, read with Section 144C (13). Assessee contended that the trust was revocable under Sections 61 and 63, as ADIA was both settlor and sole beneficiary with rights to reassume power over the assets. Thus, the...