https://www.taxtmi.com/caselaws?id=470228 Income of a securitisation trust funded through Security Receipts is assessable in the hands of Security Receipt holders where contributors retain contractual revocation rights. Applying the revocable-transfer provisions, income from transferred assets is attributed to contributors rather than the trust. The absence of an inter se agreement among Security Receipt holders to pursue a common purpose also prevents classification of the trust as an Association of Persons, rendering the AOP taxation provision inapplicable. The analysis states that additions in the trust's assessment were deleted. en-us Tue, 28 Apr 2026 00:00:00 +0530 Mon, 20 Jul 2026 20:32:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470228 Income of a securitisation trust funded through Security Receipts is assessable in the hands of Security Receipt holders where contributors retain contractual revocation rights. Applying the revocable-transfer provisions, income from transferred assets is attributed to contributors rather than the trust. The absence of an inter se agreement among Security Receipt holders to pursue a common purpose also prevents classification of the trust as an Association of Persons, rendering the AOP taxation provision inapplicable. The analysis states that additions in the trust's assessment were deleted. Case-Laws Income Tax Tue, 28 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470228