Opportunity to respond to jurisdictional reports is mandatory before customs settlement duty enhancement; connected applications require consistent ad...
Specific customs headings for scaffolding components prevail over general classification, invalidating misclassification proceedings and enabling with...
Liquidator appointment under Section 34 requires consideration of creditor recommendations, valid professional authorisation, and preservation of vali...
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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.
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