AO has held that the beneficiaries have come together voluntarily by pooling their money in the trust with clear knowledge that the funds will be utilized by the trust for the business of project work undertaken and would result in profits for the trust and consequently for the beneficiaries.  The AO has recorded a finding that the trust is an AOP and the interest claim of Rs. 5,38,100 to the beneficiaries has been disallowed under S. 40(ba) of the Act.  Findings recorded by the AO have been upheld by the Tribunal. On appeal High Court affirmed the order of the Tribunal. (AY.1995-96)