The reason the tax is out of whack is because technically the structure is a trust, which means the fund can notionally allocate some money to all trust beneficiaries (ie shareholders) even if they don't pay it out. I presume the rationale for this is that they can then hold the money for leaner years and distribute it later (at which point you won't pay tax on it, if you are still holding it).
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AMIT fund and tax, page-11
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