Taxability - services rendered by ICICI Econet Internet and...

Taxability - services rendered by ICICI Econet Internet and Technology Fund floated by the Settlor - The impugned trusts have violated the principles of mutuality by concerning themselves in commercial activities and by using the discretionary powers to benefit a certain class of investors or nominees or employees or subsidiaries. They can no longer be treated as trusts for the purposes of taxation statutes at least - the learned special counsel has rightly submitted that VCFs bear no comparison to members of club, which, by its very incorporation, is a grouping of individuals who have chosen to be members of a particular institution or club for fulfilment of certain human needs social, sporting, recreational etc that cannot be fulfilled except in such oragnised collectives. - the Department was in its right to invoke the extended period for the issue of SCN. - AT