Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
Clarifies that securitisation trusts constituted under regulatory framework qualify as revocable trusts because the trust deed grants contributors a structured right of revocation and re-transfer of assets, thereby satisfying the re-transfer and re-assumption limbs of revocability; consequence: income is taxable in the hands of Security Receipt Holders, not the trust. Rejects characterization of such trusts as an Association of Persons: the trustee acts under the deed without joint management or common volition, beneficiaries are determinable from records, and therefore AOP assessment and applying general aggregation provisions is inapplicable. Concludes that earlier Tribunal and legislative developments support pass-through taxation of securitisation trusts.
Clarifies that securitisation trusts constituted under regulatory framework qualify as revocable trusts because the trust deed grants contributors a structured right of revocation and re-transfer of assets, thereby satisfying the re-transfer and re-assumption limbs of revocability; consequence: income is taxable in the hands of Security Receipt Holders, not the trust. Rejects characterization of such trusts as an Association of Persons: the trustee acts under the deed without joint management or common volition, beneficiaries are determinable from records, and therefore AOP assessment and applying general aggregation provisions is inapplicable. Concludes that earlier Tribunal and legislative developments support pass-through taxation of securitisation trusts.
Note: It is a system-generated summary and is for quick reference only.