Our discretionary trust has been charged at the maximum marginal rate under section 164 because the beneficiaries' shares are not fixed. What exactly takes a trust out of that rate, and does it help that the trust was created by my father's will?
Section 164(1) charges the relevant income at the maximum marginal rate where income for which a section 160(1)(iii) or (iv) representative is liable is not specifically receivable on behalf of any one person, or where the individual shares of the persons for whose benefit it is receivable are indeterminate or unknown. The FIRST PROVISO takes a case out of that rate — not into exemption, but into tax 'as if it were the total income of an association of persons' — in four situations, and only four: (i) none of the beneficiaries has any other income chargeable under the Act exceeding the maximum amount not chargeable to tax in the case of an association of persons, and none is a beneficiary under any other trust; (ii) the relevant income is receivable under a trust declared by any person by will and such trust is the only trust so declared by him; (iii) the relevant income is receivable under a trust created before 1 March 1970 by a non-testamentary instrument which the Assessing Officer is satisfied was created bona fide exclusively for the benefit of the settlor's relatives, or, where the settlor is a Hindu undivided family, of the members of that family, in circumstances where they were mainly dependent on the settlor for support and maintenance; or (iv) the relevant income is receivable by trustees on behalf of a provident fund, superannuation fund, gratuity fund, pension fund or any other fund created bona fide by a person carrying on a business or profession exclusively for the benefit of persons employed in that business or profession. The SECOND PROVISO then cuts all four down where there is business income: where the income of a section 160(1)(iv) trustee consists of, or includes, profits and gains of business, the first proviso applies only if those profits and gains are receivable under a trust declared by a person by will exclusively for the benefit of a relative dependent on him for support and maintenance, and that trust is the only trust so declared by him.
Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 1989-04-01, reported as Income-tax Act, 1961, s.164, as printed word for word identically on departmental pages stamped Year 2023 and Year 2025. It bears on section 164, section 164(1), section 164(2), section 164(3), section 160(1)(iii), section 160(1)(iv), section 161(1A), section 11, section 12, section 13(1)(c), section 13(1)(d), section 2(24)(iia), section 11(4A), section 2(29C) of the Income Tax Act 1961, in Charitable Trusts & Exemption, Assessment & Scrutiny, How Tax Law Is Read and Capital Gains Exemptions matters.
Three corrections to the way this section is usually described. First, the escape in the first proviso is not an exemption and it is not the beneficiary's own rate — it is tax computed as if the relevant income were the total income of an association of persons, which is slab treatment and nothing more. Second, limb (i) is about the BENEFICIARIES and not about the settlor: what has to be shown is that none of the beneficiaries has other income above the maximum amount not chargeable to tax for an association of persons AND that none of them is a beneficiary under any other trust. A settlor with no taxable income does not help; a beneficiary who is also a beneficiary of a second family trust destroys the limb outright. Third, the second proviso is what actually decides most private-trust cases, because it makes limbs (i), (iii) and (iv) unavailable wherever the trust has business profits and leaves only the sole will trust for a dependent relative — the same escape route as in section 161(1A). Beyond sub-section (1), the section carries two more machineries that are constantly confused with it. Sub-section (2) deals with income from property held under trust wholly for charitable or religious purposes, and taxes so much of it as is not exempt under section 11 or 12 as if it were the income of an association of persons — but its proviso charges the maximum marginal rate on the relevant income or the part of it that loses exemption by virtue of section 13(1)(c) or 13(1)(d). That proviso is where a charitable trust that has benefited a specified person, or has invested outside section 11(5), gets hit. Sub-section (3) deals with a trust held in part only for charitable or religious purposes and splits the tax into a charitable part taxed as an association of persons and a non-charitable, indeterminate part taxed at the maximum marginal rate, with its own three provisos mirroring the structure of sub-section (1). Finally, Explanation 1 is where most 'indeterminate' findings are made: shares are deemed indeterminate unless they are expressly stated in the order of the court, the instrument of trust or the wakf deed and are ascertainable as such ON THE DATE of that order, instrument or deed — a share that becomes ascertainable only later is an indeterminate share.
Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.
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Section 164(1), printed identically on the Year 2023 and Year 2025 pages: 'Subject to the provisions of sub-sections (2) and (3), where any income in respect of which the persons mentioned in clauses (iii) and (iv) of sub-section (1) of section 160 are liable as representative assessees or any part thereof is not specifically receivable on behalf or for the benefit of any one person or where the individual shares of the persons on whose behalf or for whose benefit such income or such part thereof is receivable are indeterminate or unknown (such income, such part of the income and such persons being hereafter in this section referred to as "relevant income", "part of relevant income" and "beneficiaries", respectively), tax shall be charged on the relevant income or part of relevant income at the maximum marginal rate'. The first proviso opens 'Provided that in a case where—' and sets out limbs (i) to (iv) as summarised above, closing 'tax shall be charged on the relevant income or part of relevant income as if it were the total income of an association of persons'. The second proviso reads: 'Provided further that where any income in respect of which the person mentioned in clause (iv) of sub-section (1) of section 160 is liable as representative assessee consists of, or includes, profits and gains of business, the preceding proviso shall apply only if such profits and gains are receivable under a trust declared by any person by will exclusively for the benefit of any relative dependent on him for support and maintenance, and such trust is the only trust so declared by him.' Sub-section (2) charges so much of the relevant income of a wholly charitable or religious trust as is not exempt under section 11 or 12 as if it were the income of an association of persons, with a proviso charging the maximum marginal rate where the whole or part of the relevant income is not exempt by virtue of section 13(1)(c) or 13(1)(d). Sub-section (3) deals with a part-charitable trust and taxes the charitable part as an association of persons and the indeterminate non-charitable part at the maximum marginal rate, subject to three provisos which mirror sub-section (1)'s structure. Explanation 1 deems income not specifically receivable, and shares indeterminate or unknown, unless the person or the shares are expressly stated in the order of the court or the instrument of trust or wakf deed and are identifiable or ascertainable as such on the date of that order, instrument or deed. Explanation 2 is printed as '[Omitted by the Direct Tax Laws (Amendment) Act, 1987, w.e.f. 1-4-1989.]'
Where the relevant income of a section 160(1)(iii) or (iv) representative assessee is not specifically receivable for any one person, or the beneficiaries' individual shares are indeterminate or unknown, tax is charged on it at the maximum marginal rate. The first proviso substitutes taxation as if the income were the total income of an association of persons in four cases only — beneficiaries with no other income above the association-of-persons exemption limit and no interest under any other trust; a sole trust declared by will; a pre-1 March 1970 non-testamentary trust bona fide for dependent relatives of the settlor or members of a settlor Hindu undivided family; and an employees' provident, superannuation, gratuity, pension or similar fund. The second proviso restricts all of those, where the income of a section 160(1)(iv) trustee includes profits and gains of business, to the sole will trust for a dependent relative. Sub-section (2) taxes the non-exempt income of a wholly charitable or religious trust as an association of persons but charges the maximum marginal rate on income losing exemption under section 13(1)(c) or 13(1)(d); sub-section (3) splits the tax for a part-charitable trust. Explanation 1 fixes the date of the instrument as the date on which shares must be ascertainable.
Not applicable — this is a statement of statutory text taken from year-stamped departmental pages. No judicial reasoning is involved.
Provided further that where any income in respect of which the person mentioned in clause (iv) of sub-section (1) of section 160 is liable as representative assessee consists of, or includes, profits and gains of business, the preceding proviso shall apply only if such profits and gains are receivable under a trust declared by any person by will exclusively for the benefit of any relative dependent on him for support and maintenance, and such trust is the only trust so declared by him.
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Handle my notice → Ask a CA on WhatsAppSection 164(1) charges the relevant income at the maximum marginal rate where income for which a section 160(1)(iii) or (iv) representative is liable is not specifically receivable on behalf of any one person, or where the individual shares of the persons for whose benefit it is receivable are indeterminate or unknown. The FIRST PROVISO takes a case out of that rate — not into exemption, but into tax 'as if it were the total income of an association of persons' — in four situations, and only four: (i) none of the beneficiaries has any other income chargeable under the Act exceeding the maximum amount not chargeable to tax in the case of an association of persons, and none is a beneficiary under any other trust; (ii) the relevant income is receivable under a trust declared by any person by will and such trust is the only trust so declared by him; (iii) the relevant income is receivable under a trust created before 1 March 1970 by a non-testamentary instrument which the Assessing Officer is satisfied was created bona fide exclusively for the benefit of the settlor's relatives, or, where the settlor is a Hindu undivided family, of the members of that family, in circumstances where they were mainly dependent on the settlor for support and maintenance; or (iv) the relevant income is receivable by trustees on behalf of a provident fund, superannuation fund, gratuity fund, pension fund or any other fund created bona fide by a person carrying on a business or profession exclusively for the benefit of persons employed in that business or profession. The SECOND PROVISO then cuts all four down where there is business income: where the income of a section 160(1)(iv) trustee consists of, or includes, profits and gains of business, the first proviso applies only if those profits and gains are receivable under a trust declared by a person by will exclusively for the benefit of a relative dependent on him for support and maintenance, and that trust is the only trust so declared by him. This was decided by the CBDT Circulars & Instructions (Not applicable — statutory text) and bears on section 164, section 164(1), section 164(2), section 164(3), section 160(1)(iii), section 160(1)(iv), section 161(1A), section 11, section 12, section 13(1)(c), section 13(1)(d), section 2(24)(iia), section 11(4A), section 2(29C) of the Income Tax Act 1961. It is reported as Income-tax Act, 1961, s.164, as printed word for word identically on departmental pages stamped Year 2023 and Year 2025. Three corrections to the way this section is usually described. First, the escape in the first proviso is not an exemption and it is not the beneficiary's own rate — it is tax computed as if the relevant income were the total income of an association of persons, which is slab treatment and nothing more. Second, limb (i) is about the BENEFICIARIES and not about the settlor: what has to be shown is that none of the beneficiaries has other income above the maximum amount not chargeable to tax for an association of persons AND that none of them is a beneficiary under any other trust. A settlor with no taxable income does not help; a beneficiary who is also a beneficiary of a second family trust destroys the limb outright. Third, the second proviso is what actually decides most private-trust cases, because it makes limbs (i), (iii) and (iv) unavailable wherever the trust has business profits and leaves only the sole will trust for a dependent relative — the same escape route as in section 161(1A). Beyond sub-section (1), the section carries two more machineries that are constantly confused with it. Sub-section (2) deals with income from property held under trust wholly for charitable or religious purposes, and taxes so much of it as is not exempt under section 11 or 12 as if it were the income of an association of persons — but its proviso charges the maximum marginal rate on the relevant income or the part of it that loses exemption by virtue of section 13(1)(c) or 13(1)(d). That proviso is where a charitable trust that has benefited a specified person, or has invested outside section 11(5), gets hit. Sub-section (3) deals with a trust held in part only for charitable or religious purposes and splits the tax into a charitable part taxed as an association of persons and a non-charitable, indeterminate part taxed at the maximum marginal rate, with its own three provisos mirroring the structure of sub-section (1). Finally, Explanation 1 is where most 'indeterminate' findings are made: shares are deemed indeterminate unless they are expressly stated in the order of the court, the instrument of trust or the wakf deed and are ascertainable as such ON THE DATE of that order, instrument or deed — a share that becomes ascertainable only later is an indeterminate share. If it applies to you, the first step is this: Go to Explanation 1 before you argue rate. If the beneficiaries and their shares are expressly stated in the trust deed and ascertainable on the date of the deed, the trust is not within section 164 at all and section 161 governs.
Section 164(1), printed identically on the Year 2023 and Year 2025 pages: 'Subject to the provisions of sub-sections (2) and (3), where any income in respect of which the persons mentioned in clauses (iii) and (iv) of sub-section (1) of section 160 are liable as representative assessees or any part thereof is not specifically receivable on behalf or for the benefit of any one person or where the individual shares of the persons on whose behalf or for whose benefit such income or such part thereof is receivable are indeterminate or unknown (such income, such part of the income and such persons being hereafter in this section referred to as "relevant income", "part of relevant income" and "beneficiaries", respectively), tax shall be charged on the relevant income or part of relevant income at the maximum marginal rate'. The first proviso opens 'Provided that in a case where—' and sets out limbs (i) to (iv) as summarised above, closing 'tax shall be charged on the relevant income or part of relevant income as if it were the total income of an association of persons'. The second proviso reads: 'Provided further that where any income in respect of which the person mentioned in clause (iv) of sub-section (1) of section 160 is liable as representative assessee consists of, or includes, profits and gains of business, the preceding proviso shall apply only if such profits and gains are receivable under a trust declared by any person by will exclusively for the benefit of any relative dependent on him for support and maintenance, and such trust is the only trust so declared by him.' Sub-section (2) charges so much of the relevant income of a wholly charitable or religious trust as is not exempt under section 11 or 12 as if it were the income of an association of persons, with a proviso charging the maximum marginal rate where the whole or part of the relevant income is not exempt by virtue of section 13(1)(c) or 13(1)(d). Sub-section (3) deals with a part-charitable trust and taxes the charitable part as an association of persons and the indeterminate non-charitable part at the maximum marginal rate, subject to three provisos which mirror sub-section (1)'s structure. Explanation 1 deems income not specifically receivable, and shares indeterminate or unknown, unless the person or the shares are expressly stated in the order of the court or the instrument of trust or wakf deed and are identifiable or ascertainable as such on the date of that order, instrument or deed. Explanation 2 is printed as '[Omitted by the Direct Tax Laws (Amendment) Act, 1987, w.e.f. 1-4-1989.]' The matter was decided on 1989-04-01 by the CBDT Circulars & Instructions (Not applicable — statutory text). On those facts the CBDT Circulars & Instructions held as follows. Where the relevant income of a section 160(1)(iii) or (iv) representative assessee is not specifically receivable for any one person, or the beneficiaries' individual shares are indeterminate or unknown, tax is charged on it at the maximum marginal rate. The first proviso substitutes taxation as if the income were the total income of an association of persons in four cases only — beneficiaries with no other income above the association-of-persons exemption limit and no interest under any other trust; a sole trust declared by will; a pre-1 March 1970 non-testamentary trust bona fide for dependent relatives of the settlor or members of a settlor Hindu undivided family; and an employees' provident, superannuation, gratuity, pension or similar fund. The second proviso restricts all of those, where the income of a section 160(1)(iv) trustee includes profits and gains of business, to the sole will trust for a dependent relative. Sub-section (2) taxes the non-exempt income of a wholly charitable or religious trust as an association of persons but charges the maximum marginal rate on income losing exemption under section 13(1)(c) or 13(1)(d); sub-section (3) splits the tax for a part-charitable trust. Explanation 1 fixes the date of the instrument as the date on which shares must be ascertainable.
Not applicable — this is a statement of statutory text taken from year-stamped departmental pages. No judicial reasoning is involved. In the words reproduced by the source cited on this page: "Provided further that where any income in respect of which the person mentioned in clause (iv) of sub-section (1) of section 160 is liable as representative assessee consists of, or includes, profits and gains of business, the preceding proviso shall apply only if such profits and gains are receivable under a trust declared by any person by will exclusively for the benefit of any relative dependent on him for support and maintenance, and such trust is the only trust so declared by him."
It was decided by the CBDT Circulars & Instructions on 1989-04-01 and is reported as Income-tax Act, 1961, s.164, as printed word for word identically on departmental pages stamped Year 2023 and Year 2025. Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them. A CBDT circular or instruction binds officers of the department but not the assessee and not the courts. Where a circular helps you, you may hold the department to it. Where it hurts you, it cannot override the Act or a judgment. On section 164, section 164(1), section 164(2), section 164(3), section 160(1)(iii), section 160(1)(iv), section 161(1A), section 11, section 12, section 13(1)(c), section 13(1)(d), section 2(24)(iia), section 11(4A), section 2(29C), the practical question is whether the facts of your own notice match the facts of this case closely enough for the same rule to apply.
It cuts both ways and is cited by both sides. Where the relevant income of a section 160(1)(iii) or (iv) representative assessee is not specifically receivable for any one person, or the beneficiaries' individual shares are indeterminate or unknown, tax is charged on it at the maximum marginal rate. The first proviso substitutes taxation as if the income were the total income of an association of persons in four cases only — beneficiaries with no other income above the association-of-persons exemption limit and no interest under any other trust; a sole trust declared by will; a pre-1 March 1970 non-testamentary trust bona fide for dependent relatives of the settlor or members of a settlor Hindu undivided family; and an employees' provident, superannuation, gratuity, pension or similar fund. The second proviso restricts all of those, where the income of a section 160(1)(iv) trustee includes profits and gains of business, to the sole will trust for a dependent relative. Sub-section (2) taxes the non-exempt income of a wholly charitable or religious trust as an association of persons but charges the maximum marginal rate on income losing exemption under section 13(1)(c) or 13(1)(d); sub-section (3) splits the tax for a part-charitable trust. Explanation 1 fixes the date of the instrument as the date on which shares must be ascertainable. It arises in Charitable Trusts & Exemption, Assessment & Scrutiny, How Tax Law Is Read and Capital Gains Exemptions matters, on section 164, section 164(1), section 164(2), section 164(3), section 160(1)(iii), section 160(1)(iv), section 161(1A), section 11, section 12, section 13(1)(c), section 13(1)(d), section 2(24)(iia), section 11(4A), section 2(29C) of the Income Tax Act 1961, and was decided by Not applicable — statutory text. Before relying on it, read the source linked on this page and check whether it has since been distinguished, overruled or overtaken by an amendment to the Income Tax Act. In practice the steps that follow from it are these. If business income is present, go straight to the second proviso. Limbs (i), (iii) and (iv) of the first proviso are unavailable to you, and unless you can prove a sole will trust exclusively for a dependent relative the maximum marginal rate stands. If you rely on limb (i), obtain and file a declaration and supporting returns for EVERY beneficiary showing that none has other income above the maximum amount not chargeable to tax for an association of persons and that none is a beneficiary under any other trust. One failure defeats the limb. If you rely on limb (ii), produce the will, the probate, and evidence that this is the only trust declared by will by that person. For limb (iii), check the date of creation first — the instrument must be non-testamentary and pre-1 March 1970 — and then build the bona fide and dependency material the Assessing Officer must be 'satisfied' about. For limb (iv), identify the fund by its statutory description (provident, superannuation, gratuity, pension, or another fund created bona fide by a person carrying on a business or profession exclusively for employees in it) and show the exclusivity. For a charitable trust, separate the section 164(2) question from the section 164(1) question. The exposure there is the proviso to sub-section (2), which charges the maximum marginal rate on the income that loses exemption by reason of section 13(1)(c) or 13(1)(d) — so pin down exactly how much income is affected before conceding a rate. For a part-charitable trust, work sub-section (3) in its own terms: the charitable part is taxed as an association of persons and only the indeterminate non-charitable part goes to the maximum marginal rate. Do not state a figure for the maximum marginal rate from memory. It is defined in section 2(29C) by reference to the Finance Act of the relevant year and has to be computed for the year in issue.
Still good law. Sub-section (1) with both provisos is corroborated on two independently fetched year-stamped departmental pages, Year 2023 and Year 2025, which print it word for word identically. Sub-sections (2) and (3) and Explanation 1 are likewise printed word for word identically on both the Year 2023 and the Year 2025 pages; no part of this entry rests on a single page. No page stamped Year 2026 was located for this section, no Finance Act text was read, no amendment footnote list is printed on either page, and no judicial treatment was checked. Any authority stating that section 164(1) offers a choice between association-of-persons rates and a flat sixty-five per cent is superseded by amendment: neither the Year 2023 nor the Year 2025 page contains any such alternative, and the charge is the maximum marginal rate. No source could be cited for that finding. Checking whether an authority still stands matters as much as knowing what it held: a decision may be overruled on one point and survive on another, or the provision it interprets may have been amended since. Read the source and the editor's note on this page before relying on it in a reply to an Assessing Officer or in an appeal.
'decided_on' is 1 April 1989, the only dated legislative change printed on either page read for this section — Explanation 2 stands '[Omitted by the Direct Tax Laws (Amendment) Act, 1987, w.e.f. 1-4-1989]'. It is not the commencement of the section as a whole, which neither page dates, and it is not a decision date. 'bench' is 'Not applicable — statutory text' and 'favours' is null. THE BRIEF THAT COMMISSIONED THIS ENTRY IS WRONG ON ONE POINT AND I FLAG IT HERE BECAUSE IT WOULD PRODUCE BAD ADVICE: it describes the first proviso's fourth escape as 'the case where the settlor has no other taxable income'. The section says nothing of the kind. Limb (i) of the first proviso turns on the BENEFICIARIES — 'none of the beneficiaries has any other income chargeable under this Act exceeding the maximum amount not chargeable to tax in the case of an association of persons or is a beneficiary under any other trust'. The settlor's own income is irrelevant to it. The brief also warns, correctly, that https://incometaxindia.gov.in/w/section-164-46 is an archived 1979 page printing a sixty-five per cent rate; I did not use it and I did not open it. Full text of the section was transcribed from https://incometaxindia.gov.in/w/section-164-61 (Year: 2023) — heading 'Charge of tax where share of beneficiaries unknown', Income-tax Act, 1961 — and sub-section (1) with both its provisos was transcribed a second time, independently, from https://incometaxindia.gov.in/w/section-164-64 (Year: 2025), which printed it word for word identically. The whole section — sub-section (1) with both provisos, sub-section (2) with its proviso, sub-section (3) with clauses (a) and (b) and all three of its provisos, Explanation 1 clauses (i) and (ii), and Explanation 2 as omitted — is printed word for word identically on BOTH the Year 2023 page and the Year 2025 page. Nothing in this entry is single-sourced. Neither page printed a numbered amendment footnote list, so no commencement date is asserted for any part of the section; the only dated note printed is that Explanation 2 stands '[Omitted by the Direct Tax Laws (Amendment) Act, 1987, w.e.f. 1-4-1989.]'. I state NO figure for the maximum marginal rate — it is defined in section 2(29C) by reference to the Finance Act of the relevant year, and I did not retrieve section 2(29C) this pass. The definition itself IS retrievable and was transcribed on verification from two year-stamped departmental pages of section 2 — https://incometaxindia.gov.in/w/section-2-64 (Year: 2024 (No. 1)) and https://incometaxindia.gov.in/w/section-2-65 (Year: 2024 (No. 2)) — which print it word for word identically: '(29C) "maximum marginal rate" means the rate of income-tax (including surcharge on income-tax, if any) applicable in relation to the highest slab of income in the case of an individual, association of persons or, as the case may be, body of individuals as specified in the Finance Act of the relevant year;'. Two things follow that a reader needs: the rate INCLUDES surcharge, and it is the rate on the highest slab for an individual, association of persons or body of individuals, not a company rate. It still fixes no percentage — the percentage comes from the Finance Act of the relevant year, which is why no figure is stated here. (The URL /w/section-2-29c does 404; the definition lives inside the section 2 pages, whose suffixes follow the same -6x pattern as the rest of this Chapter.) Every word of the statutory text quoted in this entry was transcribed this pass from incometaxindia.gov.in section pages, each of which was made to print its section HEADING and its "Year:" stamp alongside the text, and each of which named the Act as the Income-tax Act, 1961. No text in this entry comes from an indiankanoon bare-act page, from a commentary, or from memory. This library shows the verification state of every entry openly. This entry has not yet been read in full by a chartered accountant. The summary reflects the sources listed on this page. Read the source before you rely on it in a reply to an Assessing Officer or in an appeal before the Commissioner (Appeals) or the Income Tax Appellate Tribunal.
Where the relevant income of a section 160(1)(iii) or (iv) representative assessee is not specifically receivable for any one person, or the beneficiaries' individual shares are indeterminate or unknown, tax is charged on it at the maximum marginal rate. The first proviso substitutes taxation as if the income were the total income of an association of persons in four cases only — beneficiaries with no other income above the association-of-persons exemption limit and no interest under any other trust; a sole trust declared by will; a pre-1 March 1970 non-testamentary trust bona fide for dependent relatives of the settlor or members of a settlor Hindu undivided family; and an employees' provident, superannuation, gratuity, pension or similar fund. The second proviso restricts all of those, where the income of a section 160(1)(iv) trustee includes profits and gains of business, to the sole will trust for a dependent relative. Sub-section (2) taxes the non-exempt income of a wholly charitable or religious trust as an association of persons but charges the maximum marginal rate on income losing exemption under section 13(1)(c) or 13(1)(d); sub-section (3) splits the tax for a part-charitable trust. Explanation 1 fixes the date of the instrument as the date on which shares must be ascertainable.
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