Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
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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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