Where a non-resident investor company is a beneficiary in an Indian trust, the assessment of income of the trust on the trustees is merely in their representative character. In such a case, really speaking, it is the non-resident beneficiary who is vitally and directly affected by the nature and mode of such assessment. Hence, it is such non-resident beneficiary, who is to be considered as the applicant and who, therefore, qualifies to seek a ruling from the (Advance Ruling P. No. 10 of 1996, In re (1997) 224 ITR 473 (AAR), (1996) 89 Taxman 125 (AAR)