“Section 2(1)(r)”

SME POOL SERIES V AUG 2016,MUMBAI vs. INCOME- TAX OFFICER (TDS) 2(2)(1), MUMBAI

In the result, both the appeals are allowed

Bench: SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

Assignment Deed cannot be regarded as instrument issued by the special purpose distinct entity. A perusal of definition of ‘securitization’ as contained in Section 2(1)(r) of the 2008 Regulation shows that securitization has been defined to mean acquisition of debt or receivables by any special purpose distinct entity