Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
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.
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