A trust couldn't be deemed as discretionary even if it allocated its income to a special fund held b

IT: Where as per trust deed 50 per cent income was to be received by one set of beneficiaries and balance 50 per cent of income was to be received by trustees on behalf of second set of beneficiaries and were to be accumulated as a special fund in hands of trustees for 19 years and same were to be paid after a period of 19 years to respective beneficiaries, it cannot be said that Trust was discretionary Trust and/or was not a specific Trust