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INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Shri Sandeep Singh Karhail, J.M, Shri Narendra Kumar Billaiya, A.M
ARCIL Retail Loan Portfolio001 J Trust – Appellant
Versus
The Income Tax Officer, Circle-21(1)(2) – Respondent
| Table of Content |
|---|
| 1. trusts must satisfy regulatory and legal definitions to be recognized for tax purposes. (Para 2 , 3) |
| 2. revocability of a trust must align with recognized statutes and definitions, influencing tax liabilities. (Para 8 , 9) |
ORDER
PER SANDEEP SINGH KARHAIL, J.M.
The present appeals have been filed by the Assessee and the Revenue challenging the separate orders passed u/s 250 of the Income Tax Act, 1961 ("the Act") by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, [“learned CIT(A)”], details of which are tabulated below: -
| Appeal No. | Impugned Order under challenged before Tribunal |
| ITA No.4199/Mum/2023 | Order dated 18/07/2023 passed by learned CIT(A) for the assessment year 2016-17 |
| ITA No.2909/Mum/2023 | Order dated 26/06/2023 passed by learned CIT(A) for the assessment year 2016-17 |
| ITA No.3050/Mum/2023 | Order dated 05/07/2023 passed by learned CIT(A) for the assessment year 2016-17 |
2. In the present appeals, the assessees are in the business of Asset Reconstruction – securitization of debts and processing of such debts of banks and institutional lenders. The assessees are created by Assets Reconstruction Company India Limited (“ARCIL”) f
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