Classification of knocked down motor vehicle component imports: Notification benefit denied because items are standalone non kit parts requiring subst...
Reassessment against a deceased assessee: procedural defect mandates fresh reassessment; nonresponsive petitioner may be treated as legal representati...
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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