Trustees cannot be assessed in personal capacity if Beneficiary share is determinable

Examining the matter in the present case it appears that it is not the case of the Revenue that the findings so recorded is such, which no man with reasonable prudence would arrive at such finding. But the contention sought to be canvassed is that on the date of execution of the Trust Deed, the shares should specifically come in existence with the quantification and it need not depend upon the future share of the benefits or upon any future contingency.

10. In our view, the contention is wholly misconceived for three reasons.

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