https://www.taxtmi.com/caselaws?id=418077 A trust constituted under the SARFAESI framework for acquisition and reconstruction of non-performing assets was found to have identifiable Security Receipt holders with known shares from inception. Because the beneficiaries contributed separately, had no inter se arrangement, and the arrangement was treated as revocable, the statutory rules on revocable transfers and beneficiary taxation applied. The Tribunal rejected assessment of the trust as an Association of Persons and held that the income from realised assets could not be taxed in the trust's own hands merely because it carried on asset reconstruction activity. Income was therefore taxable in the hands of the Security Receipt holders. en-us Fri, 28 Jan 2022 00:00:00 +0530 Mon, 07 Feb 2022 09:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=418077 A trust constituted under the SARFAESI framework for acquisition and reconstruction of non-performing assets was found to have identifiable Security Receipt holders with known shares from inception. Because the beneficiaries contributed separately, had no inter se arrangement, and the arrangement was treated as revocable, the statutory rules on revocable transfers and beneficiary taxation applied. The Tribunal rejected assessment of the trust as an Association of Persons and held that the income from realised assets could not be taxed in the trust's own hands merely because it carried on asset reconstruction activity. Income was therefore taxable in the hands of the Security Receipt holders. Case-Laws Income Tax Fri, 28 Jan 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=418077