Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
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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