The Madras High Court recently ruled that a private discretionary trust, being a representative assessee of identified beneficiaries, is liable to be treated as an individual for the purpose of taxation (The Commissioner of Income tax v. Shriram Ownership Trust).
Among other findings, the Court also emphasised that when the assessee does not challenge a tribunal ruling in appeal, he is not entitled to call on the High Court to frame additional questions of law by invoking Section 260A (4) of the Income Tax Act.