Ground raised by the assessee is that the learned CIT(Appeals) erred both in law and on facts of thecasein upholding the action of the Assessing Officer in treating the Appellant as an invalid trust under the provisions of Indian Trust Act, 1882 and in consequence thereto in bringing to tax dividend income of Rs. 4,47,60,037/- as income from other sources and denying the benefit of exemption u/s 10(34) of Income-tax Act, 1961 (being dividend referred to in section 115-O of the Income-tax Act).