ITA No. 4252/Mum/2025
Case No: 4252/Mum/2025
Court: Income Tax Appellate Tribunal, 'A' Bench Mumbai
Date: 1/22/2026
Parties Involved
ApplicantARCIL RETAIL LOAN PORTFOLIO- 001- A TRUST
RespondentRevenue
Facts Summary
The assessee, ARCIL RETAIL LOAN PORTFOLIO- 001- A TRUST, filed its return of income for A.Y. 2016–17 declaring total income at Rs. NIL and claimed exempt income of Rs. 27,63,75,223/- under section 61 read with section 63 of the Income-tax Act, 1961. The Assessing Officer (AO) rejected the assessee's contentions, holding that the assessee could not be regarded as a trust for the purposes of sections 61 to 63 of the Act and that it constituted an Association of Persons (AOP) within the meaning of …
Decision in favour of
Assessee
Legal Issues
- 1. Whether the assessee trust is liable to be assessed as an Association of Persons.
- 2. Whether the trust is revocable or irrevocable for the purposes of sections 61 to 63 of the Income-tax Act, 1961.
1 more legal issue analysed in this judgement.
Precedents Relied Upon
7 precedents cited in this judgement.