https://www.taxtmi.com/caselaws?id=300494 A trust formed under the SARFAESI asset reconstruction framework was treated as a valid revocable trust because the security receipt holders retained a revocable interest in their contributions. On that basis, the income from the trust fund was taxable in the hands of the transferors under the revocable transfer provisions, not in the hands of the trust. The structure also did not create an association of persons, since there was no inter se arrangement among beneficiaries and their shares were known from inception. The trust was therefore not regarded as indeterminate, and the Revenue's challenge failed. en-us Wed, 15 Sep 2021 00:00:00 +0530 Sun, 06 Feb 2022 14:41:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=300494 A trust formed under the SARFAESI asset reconstruction framework was treated as a valid revocable trust because the security receipt holders retained a revocable interest in their contributions. On that basis, the income from the trust fund was taxable in the hands of the transferors under the revocable transfer provisions, not in the hands of the trust. The structure also did not create an association of persons, since there was no inter se arrangement among beneficiaries and their shares were known from inception. The trust was therefore not regarded as indeterminate, and the Revenue's challenge failed. Case-Laws Income Tax Wed, 15 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=300494