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Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
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Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
A securitisation trust constituted under the SARFAESI Act and governed by RBI guidelines was treated as a revocable trust, so its income was held taxable in the hands of the Security Receipt holders rather than in the hands of the trust. The trust was also held not assessable as an association of persons, and the rule relating to indeterminate shares was found inapplicable. In the absence of any distinguishing feature or contrary higher precedent, the appellate order was upheld and the Revenue's attempt to tax the trust was rejected.
A securitisation trust constituted under the SARFAESI Act and governed by RBI guidelines was treated as a revocable trust, so its income was held taxable in the hands of the Security Receipt holders rather than in the hands of the trust. The trust was also held not assessable as an association of persons, and the rule relating to indeterminate shares was found inapplicable. In the absence of any distinguishing feature or contrary higher precedent, the appellate order was upheld and the Revenue's attempt to tax the trust was rejected.
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