Securitization company not liable to deduct TDS on Excess Interest Spread paid to Originator.

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....The assessee was in default u/s 201(1) for non-deduction of TDS u/s 194LBC on the Excess Interest Spread (EIS) paid to the Originator. The CIT(A) held that since the Originator did not subscribe to any Pass-Through Certificates (PTCs), it cannot be termed as an 'investor' u/s 194LBC read with Section 115TCA, and no investment was made by the Originator. Therefore, the provisions of Section 194LBC were not attracted. The ITAT, relying on previous decisions, observed that the issue had been extensively dealt with by the jurisdictional coordinate bench, which had taken a view in support of the assessee. Finding no infirmity in the CIT(A)'s order, the ITAT dismissed the grounds of appeal.....