Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Nominee director protection shields independent financial-institution appointees from criminal liability where they lack involvement in deposit defaul...
The ITAT Mumbai held that u/s 194LBC, TDS is not applicable to payments made by a securitization trust to the Originator as Excess Interest Spread (EIS). The tribunal found that the Originator does not qualify as an investor of the trust nor does the payment constitute income from the trust investment. The FAA determined that the Originator is not a holder of securitized debt instruments, thus not an investor. The tribunal rejected the AO's argument that the Assignment Deed is a securitized debt instrument. It clarified the distinction between the Originator, the trust, and the PTC holders. The decision was supported by precedent cases. The appeal was dismissed.
The ITAT Mumbai held that u/s 194LBC, TDS is not applicable to payments made by a securitization trust to the Originator as Excess Interest Spread (EIS). The tribunal found that the Originator does not qualify as an investor of the trust nor does the payment constitute income from the trust investment. The FAA determined that the Originator is not a holder of securitized debt instruments, thus not an investor. The tribunal rejected the AO's argument that the Assignment Deed is a securitized debt instrument. It clarified the distinction between the Originator, the trust, and the PTC holders. The decision was supported by precedent cases. The appeal was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
