https://www.taxtmi.com/caselaws?id=791394 A securitisation trust formed under the regulatory framework was not assessable as an Association of Persons because the beneficiaries were identifiable, their shares were determinable, and the arrangement lacked common volition and joint management. It was treated as a revocable trust under sections 61 to 63 because the trust deed and governing structure provided for re-transfer of income or assets, or a right to re-assume control, so the trust's income was not taxable in its own hands. Once that position applied, section 164 had no independent operation, and the additions and disallowances based on AOP taxation and alternate assessment of receipts could not stand. en-us Thu, 26 Mar 2026 00:00:00 +0530 Mon, 11 May 2026 09:50:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791394 A securitisation trust formed under the regulatory framework was not assessable as an Association of Persons because the beneficiaries were identifiable, their shares were determinable, and the arrangement lacked common volition and joint management. It was treated as a revocable trust under sections 61 to 63 because the trust deed and governing structure provided for re-transfer of income or assets, or a right to re-assume control, so the trust's income was not taxable in its own hands. Once that position applied, section 164 had no independent operation, and the additions and disallowances based on AOP taxation and alternate assessment of receipts could not stand. Case-Laws Income Tax Thu, 26 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791394