Authentication of paper assessment orders upheld, while qualifying repairs, consumables and vendor advance write-offs remain deductible business claim...
Transaction value cannot be rejected solely on non-statutory valuation guidelines without corroborative evidence supporting reassessment of final cust...
Cross-examination rights and corroborated evidence limit customs penalties for misdeclaration in genuine import transactions involving documented clea...
Tariff classification of vehicle gear components follows the specific gearing entry, displacing motor-vehicle parts classification and related liabili...
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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