Securitisation trust income taxed in Security Receipt holders' hands, with AOP status rejected under revocable trust principles.

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....A securitisation trust constituted under the SARFAESI Act and governed by RBI guidelines was treated as a revocable trust, so its income was held taxable in the hands of the Security Receipt holders rather than in the hands of the trust. The trust was also held not assessable as an association of persons, and the rule relating to indeterminate shares was found inapplicable. In the absence of any distinguishing feature or contrary higher precedent, the appellate order was upheld and the Revenue's attempt to tax the trust was rejected.....