https://www.taxtmi.com/caselaws?id=314216 ITAT MUMBAI (AT) held that payments made to the originator as excess interest spread were not subject to TDS under section 194LBC because the originator did not hold any investment in the securitization trust/special purpose vehicle. The minimum retention requirement (MRR) was satisfied via cash collateral and collateralisation of excess receivables, not by the originator subscribing to PTCs or other instruments. Following a prior Tribunal view, the demand under section 201(1A) was deleted and the assessee's appeal was allowed. en-us Wed, 21 Feb 2024 00:00:00 +0530 Mon, 10 Nov 2025 11:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=314216 ITAT MUMBAI (AT) held that payments made to the originator as excess interest spread were not subject to TDS under section 194LBC because the originator did not hold any investment in the securitization trust/special purpose vehicle. The minimum retention requirement (MRR) was satisfied via cash collateral and collateralisation of excess receivables, not by the originator subscribing to PTCs or other instruments. Following a prior Tribunal view, the demand under section 201(1A) was deleted and the assessee's appeal was allowed. Case-Laws Income Tax Wed, 21 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=314216