https://www.taxtmi.com/caselaws?id=768997 In a SARFAESI-based security receipt structure, a consistent book write-off of security receipts made in accordance with the RBI framework was allowable as a deduction, and the mere possibility of later recovery did not justify disallowance. Recoveries made by the trusts were not taxable in the asset reconstruction company's hands at the stage of recovery, because income arose only on actual distribution to security receipt holders; the trusts operated as separate accounting entities for scheme purposes. The same reasoning defeated the protective addition, since income attributable to other receipt holders could not be assessed in the assessee's hands before distribution. The Revenue's appeal failed and the disputed additions were deleted. en-us Tue, 25 Mar 2025 00:00:00 +0530 Thu, 17 Apr 2025 08:37:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768997 In a SARFAESI-based security receipt structure, a consistent book write-off of security receipts made in accordance with the RBI framework was allowable as a deduction, and the mere possibility of later recovery did not justify disallowance. Recoveries made by the trusts were not taxable in the asset reconstruction company's hands at the stage of recovery, because income arose only on actual distribution to security receipt holders; the trusts operated as separate accounting entities for scheme purposes. The same reasoning defeated the protective addition, since income attributable to other receipt holders could not be assessed in the assessee's hands before distribution. The Revenue's appeal failed and the disputed additions were deleted. Case-Laws Income Tax Tue, 25 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768997