https://www.taxtmi.com/caselaws?id=795339 A securitisation trust with identifiable security receipt holders and determinate interests may be treated as a revocable pass-through trust under sections 61 to 63 of the Income-tax Act. Multiple beneficiaries alone do not create an Association of Persons; that classification requires a voluntary combination pursuing income through common design, joint management or concerted action. Where the trust deed permits revocation of contributions and recovery of assets, the transfer may satisfy the requirements for revocable-transfer treatment. The stated analysis supports assessment of such a trust on a pass-through basis rather than as an Association of Persons. en-us Mon, 22 Jun 2026 00:00:00 +0530 Tue, 21 Jul 2026 08:32:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795339 A securitisation trust with identifiable security receipt holders and determinate interests may be treated as a revocable pass-through trust under sections 61 to 63 of the Income-tax Act. Multiple beneficiaries alone do not create an Association of Persons; that classification requires a voluntary combination pursuing income through common design, joint management or concerted action. Where the trust deed permits revocation of contributions and recovery of assets, the transfer may satisfy the requirements for revocable-transfer treatment. The stated analysis supports assessment of such a trust on a pass-through basis rather than as an Association of Persons. Case-Laws Income Tax Mon, 22 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795339