https://www.taxtmi.com/caselaws?id=793780 Under the SARFAESI framework and RBI guidelines, a securitisation trust operating as a revocable trust under sections 61 to 63 of the Income-tax Act is treated as a pass-through arrangement. Its income is therefore assessable in the hands of the contributors or Security Receipt holders, not in the hands of the trust itself. On the same reasoning, the trust is not assessable as an Association of Persons, and section 164 does not apply. No contrary binding precedent or distinguishing feature was identified in the material discussed. en-us Wed, 15 Apr 2026 00:00:00 +0530 Wed, 24 Jun 2026 07:08:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793780 Under the SARFAESI framework and RBI guidelines, a securitisation trust operating as a revocable trust under sections 61 to 63 of the Income-tax Act is treated as a pass-through arrangement. Its income is therefore assessable in the hands of the contributors or Security Receipt holders, not in the hands of the trust itself. On the same reasoning, the trust is not assessable as an Association of Persons, and section 164 does not apply. No contrary binding precedent or distinguishing feature was identified in the material discussed. Case-Laws Income Tax Wed, 15 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793780