https://www.taxtmi.com/caselaws?id=314216 Section 194LBC applies only to income payable to an investor in respect of investment in a securitisation trust, and the term "investor" is tied to a holder of a securitised debt instrument or security receipt. On the stated facts, the originator had not subscribed to PTCs or any investment in the trust; its retention was through cash collateral and collateralisation of excess receivables, and the assignment deed did not create an investment instrument. Excess Interest Spread was treated as a residual amount for creating the receivables pool, not income from investment in the trust, so TDS was held not deductible under section 194LBC and liability under sections 201(1) and 201(1A) did not arise. 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 Section 194LBC applies only to income payable to an investor in respect of investment in a securitisation trust, and the term "investor" is tied to a holder of a securitised debt instrument or security receipt. On the stated facts, the originator had not subscribed to PTCs or any investment in the trust; its retention was through cash collateral and collateralisation of excess receivables, and the assignment deed did not create an investment instrument. Excess Interest Spread was treated as a residual amount for creating the receivables pool, not income from investment in the trust, so TDS was held not deductible under section 194LBC and liability under sections 201(1) and 201(1A) did not arise. Case-Laws Income Tax Wed, 21 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=314216