https://www.taxtmi.com/caselaws?id=469414 Excess Interest Spread paid by a securitisation trust to the originator was not subject to tax deduction under section 194LBC because the originator had not subscribed to pass through certificates and had made no investment in the trust; it had only provided cash collateral to meet the minimum retention requirement. The payment was treated as a residual amount, not as income payable to an investor in respect of an investment in the securitisation trust. Following the Tribunal's earlier identical ruling, section 194LBC was held inapplicable, and the consequential demand under section 201(1) and interest under section 201(1A) were deleted. en-us Thu, 06 Mar 2025 00:00:00 +0530 Tue, 16 Jun 2026 21:37:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469414 Excess Interest Spread paid by a securitisation trust to the originator was not subject to tax deduction under section 194LBC because the originator had not subscribed to pass through certificates and had made no investment in the trust; it had only provided cash collateral to meet the minimum retention requirement. The payment was treated as a residual amount, not as income payable to an investor in respect of an investment in the securitisation trust. Following the Tribunal's earlier identical ruling, section 194LBC was held inapplicable, and the consequential demand under section 201(1) and interest under section 201(1A) were deleted. Case-Laws Income Tax Thu, 06 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469414