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Revenue Fails to Prove Trust as "Association of Persons" Due to Lack of Evidence in Securitization Process.

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....Treating the status of the assessee Trust as "AOP" - there has been some concerted and coordinated action on the part of the beneficiaries in completing the securitization process, has not travelled beyond the stage of suspicion and surmise and therefore in our view Revenue has not discharged the onus of establishing the existence of an AOP in the case on hand.....

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Revenue Fails to Prove Trust as "Association of Persons" Due to Lack of Evidence in Securitization Process.