https://www.taxtmi.com/caselaws?id=461798 ITAT Mumbai held that appellant was not liable to deduct TDS under Section 194LBC on excess interest spread (EIS) paid to originator. The tribunal ruled that while originator qualified as investor, EIS represented residual amount flowing to originator as reward for creating assignable loan pool, not income from investment in securitization trust. Since twin conditions of Section 194LBC - payment to investor AND income from investment in securitization trust - were not satisfied, TDS liability did not arise. Appeal allowed. en-us Mon, 09 Sep 2024 00:00:00 +0530 Tue, 29 Apr 2025 18:59:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461798 ITAT Mumbai held that appellant was not liable to deduct TDS under Section 194LBC on excess interest spread (EIS) paid to originator. The tribunal ruled that while originator qualified as investor, EIS represented residual amount flowing to originator as reward for creating assignable loan pool, not income from investment in securitization trust. Since twin conditions of Section 194LBC - payment to investor AND income from investment in securitization trust - were not satisfied, TDS liability did not arise. Appeal allowed. Case-Laws Income Tax Mon, 09 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461798