https://www.taxtmi.com/caselaws?id=797454 Tax deduction under section 194LBC applies only to income payable to an investor in respect of that investor's investment in a securitisation trust. Excess Interest Spread paid to an originator that neither subscribed to pass-through certificates nor otherwise invested in the trust does not meet those conditions. Maintaining the minimum retention requirement through cash collateral does not make the originator an investor for this purpose. As the payment represents residual surplus under the transaction waterfall rather than income from an investment, no tax is deductible under section 194LBC, and default consequences under sections 201(1) and 201(1A) do not arise. en-us Mon, 09 Feb 2026 00:00:00 +0530 Sat, 22 Aug 2026 10:33:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797454 Tax deduction under section 194LBC applies only to income payable to an investor in respect of that investor's investment in a securitisation trust. Excess Interest Spread paid to an originator that neither subscribed to pass-through certificates nor otherwise invested in the trust does not meet those conditions. Maintaining the minimum retention requirement through cash collateral does not make the originator an investor for this purpose. As the payment represents residual surplus under the transaction waterfall rather than income from an investment, no tax is deductible under section 194LBC, and default consequences under sections 201(1) and 201(1A) do not arise. Case-Laws Income Tax Mon, 09 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797454