Assessee deriving income from assets reconstruction activity and handling of  non-performing assets of banks and financial institutions.  Assessing Officer holding that assessee-trust is  not a valid trust. CIT(A) affirmed the order of the AO. On appeal the Tribunal held that   while deciding the case of a similar trust set up by the ARCIL, the Tribunal had held that there was no prohibition on the settlor becoming a beneficiary of the trust in terms of sections 7 and 9 of the Indian Trusts Act, 1882, that the Assessing Officer was wrong in holding that the assessee-trust was not a valid trust, for the reason that its contributors and beneficiaries were the same, that the assessee-trust was a revocable trust, and therefore, the provisions of sections 61 to 63 of the Act would be applicable to it, that there was nothing on record to suggest that the beneficiary had agreed to associate for any common objective and the beneficiaries who did not have any control over the activities carried on by the trustee in managing the trust, had made their respective investments based on the offer documents, and on the basis of their investments made in the trust were allotted the security receipt which represented their undivided and proportionate interest in the corpus of the trust, that the Assessing Officer had failed to place on record any material to suggest that there was a concerted effort by the beneficiaries to earn income jointly, and that therefore, the assessee could not be treated as an association of persons. The Tribunal held that the assessee-trust was a determinate trust and no discretion had been given to the trustee to decide the allocation of the income every year, nor was any right given to the beneficiary to exercise an option to receive the income or not each year. Therefore, similarly in the case of the assessee also, the trust was a revocable trust and was not an association of persons. The income is  liable to be assessed in the hands of the beneficiaries in terms of the provisions of sections 61 to 63 of the Act. Further, since the respective shares were known since inception, the assessee could not be considered as an indeterminate trust.(AY.2016-17)