THE COMMISSIONER OF INCOME-TAX BOMBAY vs MANILAL DHANJI, BOMBAY

The Supreme Court ruled that under Section 16(3)(b) of the Indian Income-tax Act, 1922, income from a trust for a minor child cannot be taxed as the income of the assessee unless the minor either received the income or had a beneficial interest in it during the accounting year. The Court held that since the minor child did not benefit from the income in the relevant year, the amounts of Rs. 410 and Rs. 14,170 could not be included in the total income of the assessee. The decision clarified the interpretation of trust income and the tax implications for trustees under Section 41(1) of the Act.