Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
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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