https://www.taxtmi.com/caselaws?id=785659 A securitisation trust was treated as a revocable transfer under sections 61 to 63 because its deed allowed revocation by the Security Receipt Holders with re-transfer of the trust fund, and a collective or conditional mechanism was sufficient for section 63. As a result, the trust could not be assessed as an Association of Persons, section 164 did not apply, and the special charging scheme displaced that approach. The structure was also held to operate as a pass-through arrangement, so the income was not taxable in the hands of the trust but in the hands of the Security Receipt Holders. en-us Thu, 22 Jan 2026 00:00:00 +0530 Mon, 20 Jul 2026 16:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785659 A securitisation trust was treated as a revocable transfer under sections 61 to 63 because its deed allowed revocation by the Security Receipt Holders with re-transfer of the trust fund, and a collective or conditional mechanism was sufficient for section 63. As a result, the trust could not be assessed as an Association of Persons, section 164 did not apply, and the special charging scheme displaced that approach. The structure was also held to operate as a pass-through arrangement, so the income was not taxable in the hands of the trust but in the hands of the Security Receipt Holders. Case-Laws Income Tax Thu, 22 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785659