Bombay High Court
Pr. Commissioner Of Income Tax 19 Mumbai vs Indian Corporate Loan Securitisation ... on 16 July, 2024
Author: G. S. Kulkarni
Bench: G. S. Kulkarni
4-ITXA-1525-18GRP.DOC
pvr
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
ORDINARY ORIGINAL CIVIL JURISDICTION
INCOME TAX APPEAL NO. 1525 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Indian Corporate Loan Securitization
Trust - 2008, Series 14 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 825 OF 2018
The Pr. Commissioner Of Income Tax -23 ...Appellant
Versus
India Commercial Loan Trust Series Ii 2009 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 240 OF 2022
Pr. Commissioner Of Income Tax 19 Mumbai ...Appellant
Versus
India Commercial Loan Trust Series Iii 2009 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 179 OF 2022
Pr. Commissioner Of Income Tax 19 Mumbai ...Appellant
Versus
Indian Corporate Loan Securitisation
Trust 2008 Series 14 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1910 OF 2017
The Principal Commissioner Of Income Tax - 23 Mumbai ...Appellant
Versus
Ge Capital Services India ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 145 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Ge Capital Services India ...Respondent
Page 1 of 20
16 July 2024
4-ITXA-1525-18GRP.DOC
WITH
INCOME TAX APPEAL(IT) NO. 151 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Ge Capital Services India ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 146 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Ge Capital Services India ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 148 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Ge Capital Services India ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 2026 OF 2017
The Principal Commissioner Of Income Tax -23 ...Appellant
Versus
Ge Capital Services India ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 257 OF 2018
The Principal Commissioner Of Income Tax-23,mumbai ...Appellant
Versus
Ge Capital Services India ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 53 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Ge Capital Services India ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1946 OF 2017
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Page 2 of 20
16 July 2024
4-ITXA-1525-18GRP.DOC
Ge Captial Services India ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1853 OF 2017
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Ge Capital Services India ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1862 OF 2017
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Ge Capital Services India ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1968 OF 2017
The Principal Commissioner Of Income Tax -23 ...Appellant
Versus
Ge Capital Services India ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 25 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Ge Capital Services India ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 271 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Ge Capital Services India ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 251 OF 2018
The Principal Commissioner Of Income Tax 23, Mumbai ...Appellant
Versus
Ge Capital Services India ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 172 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Page 3 of 20
16 July 2024
4-ITXA-1525-18GRP.DOC
Versus
Ge Capital Services India ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 278 OF 2018
The Principal Commissioner Of Income Tax-23 Mumbai ...Appellant
Versus
Ge Capital Services India ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 314 OF 2018
The Principal Commissioner Of Income Tax-23 ...Appellant
Versus
Ge Capital Services India ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 275 OF 2018
The Principal Commissioner Of Income Tax-23,mumbai ...Appellant
Versus
Ge Capital Services Inida ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 173 OF 2018
The Principal Commissioner Of Income Tax-23 Mumbai ...Appellant
Versus
Ge Capital Services India ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1752 OF 2017
The Prinicipal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Ge Capital Services India ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1908 OF 2017
The Principal Commissioner Of Income Tax-23,mumbai ...Appellant
Versus
Ge Capital Services India ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 654 OF 2018
The Principal Commissioner Of Income Tax -23 ...Appellant
Page 4 of 20
16 July 2024
4-ITXA-1525-18GRP.DOC
Versus
Ge Capital Services India ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 2212 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008, Series-24
...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 926 OF 2018
The Principal Commissioner Of Income Tax-23 Mumbai ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008 Series 28 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1819 OF 2019
The Principal Commissioner Of Income Tax-23 Mumbai ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1935 OF 2019
The Principal Commissioner Of Income Tax -23 ...Appellant
Versus
Indian Corporate Loan Securitization Trust - 2008 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1839 OF 2019
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
India Structured Asset Trust Series Vii ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1851 OF 2019
The Principal Commissioner Of Income Tax -23 ...Appellant
Versus
Indian Corporate Loan Securitization Trust - 2008 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1837 OF 2019
Page 5 of 20
16 July 2024
4-ITXA-1525-18GRP.DOC
The Principal Commissioner Of Income Tax-23 ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008,series Lxi ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 2240 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008, Series 24
...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1781 OF 2019
The Principal Commissioner Of Inicome Tax-23, Mumbai ...Appellant
Versus
Indian Corporate Loan Securitization ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1867 OF 2019
The Principal Commissioner Of Income Tax-23 Mumbai ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1869 OF 2019
The Principle Commissioner Of Income Tax-23 ...Appellant
Versus
India Structured Asset Trust Series Iii ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 2613 OF 2019
The Principal Commissioner Of Income Tax 23 ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1816 OF 2019
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Ibh Loan Trust The Il And Fs Financial Centre ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1984 OF 2018
Page 6 of 20
16 July 2024
4-ITXA-1525-18GRP.DOC
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Iml Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1842 OF 2019
The Principal Commissioner Of Income Tax-23 ...Appellant
Versus
India Commercial Loan Trust Series Ix-2008 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 753 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Iel Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 921 OF 2018
The Pr. Commissioner Of Income Tax-23 Mumbai ...Appellant
Versus
Ighcc2 Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 812 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
India Commercial Loan Trust Series Ii 2008 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1838 OF 2019
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
India Structured Asset Trust Series Iv The Il And Fs Financial Centre
...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1312 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
India Commercial Loan Trust Series Vii 2008 ...Respondent
WITH
Page 7 of 20
16 July 2024
4-ITXA-1525-18GRP.DOC
INCOME TAX APPEAL(IT) NO. 1806 OF 2019
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Long Bond Receivable Trust 2006 Series Iii ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1853 OF 2019
The Pr. Commissioner Of Income Tax-23 Mumbai ...Appellant
Versus
India Commercial Loan Trust Series Iii 2008 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1952 OF 2019
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Long Bond Receivable Trust 2006 Series Iv ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1866 OF 2019
The Pr. Commissioner Of Income Tax-23 Mumbai ...Appellant
Versus
Ikr Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1974 OF 2019
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Ikr Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 2269 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Kba Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 762 OF 2019
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
India Structured Asset Trust Series Iii ...Respondent
WITH
Page 8 of 20
16 July 2024
4-ITXA-1525-18GRP.DOC
INCOME TAX APPEAL(IT) NO. 645 OF 2019
The Principal Commissioner Of Income Tax 23 ...Appellant
Versus
Indian Loan Receivable Trust April Ii 2009 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 813 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Pes Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 646 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Iop Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1099 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Long Bond Receivable Trust 2007 Series V ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 643 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Ipl Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 919 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
India Structured Asset Trust Series Viii ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 3069 OF 2018
The Principal Commissioner Of Income Tax-23 ...Appellant
Versus
Pfl Loan Trust ...Respondent
WITH
Page 9 of 20
16 July 2024
4-ITXA-1525-18GRP.DOC
INCOME TAX APPEAL(IT) NO. 2518 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Ibh Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 763 OF 2019
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Sme Loan Receivable Trust August 2007 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 653 OF 2019
The Principal Commissioner Of Income Tax -23, ...Appellant
Versus
Kse Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1213 OF 2019
The Pr. Commissioner Of Income Tax-23 Mumbai ...Appellant
Versus
India Commercial Loan Trust Series Iii 2010 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 2978 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Kba Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 2979 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Kse Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1091 OF 2018
The Principal Commissioner Of Income Tax -23, ...Appellant
Versus
Pfl Loan Trust ...Respondent
WITH
Page 10 of 20
16 July 2024
4-ITXA-1525-18GRP.DOC
INCOME TAX APPEAL(IT) NO. 1520 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Indian Loans Receivable Trust February 2008 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 922 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
K S E Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1969 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Pse Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 782 OF 2018
The Principal Commissioner Of Income Tax-23 ...Appellant
Versus
Long Bond Receivable Trust 2006 Series Iv ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1522 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
India Commercial Loan Trust Series Viii 2008 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1617 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Pes Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 2067 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Page 11 of 20
16 July 2024
4-ITXA-1525-18GRP.DOC
Versus
Kge Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 2134 OF 2018
The Pr. Commissioner Of Income Tax-23 Mumbai ...Appellant
Versus
Kag Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1476 OF 2019
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
India Structured Asset Trust Series Ii ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 647 OF 2019
The Pr. Commissioner Of Income Tax-23 Mumbai ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008 Series 38 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1216 OF 2019
The Principal Commissioner Of Income Tax -23, ...Appellant
Versus
India Commercial Loan Trust Series Iv 2009 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 704 OF 2019
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Pse Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 652 OF 2019
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Sme Retail Pool Ii Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1481 OF 2019
The Principal Commissioner Of Income Tax -23, ...Appellant
Page 12 of 20
16 July 2024
4-ITXA-1525-18GRP.DOC
Versus
Long Bond Receivable Trust 2006 Series Iv ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 709 OF 2019
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Ighcc 3 Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1519 OF 2018
The Principal Commissioner Of Income Tax-23 ...Appellant
Versus
Long Bond Receivable Trust 2006 Series Iii ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 923 OF 2018
The Pr. Commissioner Of Income Tax-23 Mumbai ...Appellant
Versus
Iwh Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1285 OF 2018
The Principal Commissioner Of Income Tax -23, ...Appellant
Versus
Sme Retail Pool Ii Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1212 OF 2019
The Principal Commissioner Of Income Tax-23 ...Appellant
Versus
India Commercial Loan Trust Series V ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1106 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008, Series Xli
...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 2016 OF 2018
Page 13 of 20
16 July 2024
4-ITXA-1525-18GRP.DOC
The Pr. Commissioner Of Income Tax-23 Mumbai ...Appellant
Versus
India Structured Asset Trust Series V ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 472 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Indian Loan Receivable Trust May 2008 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 774 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Indian Loan Receivable Trust May 2008 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 651 OF 2018
The Pr. Commissioner Of Income Tax-23 Mumbai ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008
Series Lvi ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1308 OF 2018
The Principal Commissioner Of Income Tax-23 Mumbai ...Appellant
Versus
Long Bond Receivable Trust 2007 Series V ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1474 OF 2019
The Pr. Commissioner Of Income Tax-23 Mumbai ...Appellant
Versus
India Structured Asset Trust Series Ii ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 2274 OF 2018
The Principal Commissioner Of Income Tax-23 Mumbai ...Appellant
Versus
Indian Corporation Loan Securitization Trust-2008 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 2138 OF 2018
Page 14 of 20
16 July 2024
4-ITXA-1525-18GRP.DOC
The Principal Commissioner Of Income Tax-23 ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008,
Series-lvi ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1475 OF 2019
The Principal Commissioner Of Income Tax -23, ...Appellant
Versus
Kul Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 644 OF 2019
The Principal Commissioner Of Income Tax-23 ...Appellant
Versus
Indian Corporate Loan Securitization Trust- 2008 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1618 OF 2018
The Principal Commissioner Of Income Tax-23 ...Appellant
Versus
Ighcc Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 648 OF 2019
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008, Series-9 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 3088 OF 2018
The Principal Commissioner Of Income Tax-23 ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008 Series 33 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 646 OF 2019
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008,
Series-xl Vii ...Respondent
Page 15 of 20
16 July 2024
4-ITXA-1525-18GRP.DOC
WITH
INCOME TAX APPEAL(IT) NO. 1079 OF 2018
The Principal Commissioner Of Income Tax-23 ...Appellant
Versus
Indian Corporate Loan Securitization Trust 2008,series-lxii ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 826 OF 2018
The Principal Commissioner Of Income Tax -23, ...Appellant
Versus
Indian Corporate Loan Securitization Trust - 2008,
Series -xli ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 779 OF 2018
The Principal Commissioner Of Income Tax-23. ...Appellant
Versus
Indian Corporate Loan Securitization Trust 2008,series-27 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 708 OF 2019
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008, Series-vi ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1218 OF 2019
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008, Series-39
...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1217 OF 2019
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Ire Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1214 OF 2019
The Pr. Commissioner Of Income Tax-23 Mumbai ...Appellant
Page 16 of 20
16 July 2024
4-ITXA-1525-18GRP.DOC
Versus
Indian Corporate Loan Securitization Trust-2008 Series-lxi ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1215 OF 2019
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008, Series 20
...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 2522 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008, Series-18
...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 2983 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008, Series-20
...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 2210 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008, Seres-40 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 2209 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008,
Series 22 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 2214 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008,
Page 17 of 20
16 July 2024
4-ITXA-1525-18GRP.DOC
Series-37 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 3095 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008, Series-xi ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 3067 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008, Series-ii ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 649 OF 2019
The Principal Commissioner Of Income Tax-23 Mumbai ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008,
Series - Vii ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1282 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
India Structured Asset Trust Series Iv ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 2652 OF 2018
The Principal Commissioner Of Income Tax-23 Mumbai ...Appellant
Versus
Loans Receivable Trust April 2008 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 920 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008,
Series-13 ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1677 OF 2018
Page 18 of 20
16 July 2024
4-ITXA-1525-18GRP.DOC
The Principal Commissioner Of Income Tax-23 ...Appellant
Versus
Ish Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 2977 OF 2018
The Principal Commissioner Of Income Tax -23, ...Appellant
Versus
Indian Corporate Loan Securitization Trust - 2008,
Series Iii ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1219 OF 2019
The Pr. Commissioner Of Income Tax-23 Mumbai ...Appellant
Versus
Itccl Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 924 OF 2018
The Principal Commissioner Of Income Tax-23 Mumbai ...Appellant
Versus
Itbl Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 2220 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Kes Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 2980 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Kag Loan Trust ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 2519 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Long Bond Receivable Trust 2007 Series V ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 1132 OF 2018
Page 19 of 20
16 July 2024
4-ITXA-1525-18GRP.DOC
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Indian Corporate Loan Securitization Trust-2008, Series Vi ...Respondent
WITH
INCOME TAX APPEAL(IT) NO. 2068 OF 2018
The Principal Commissioner Of Income Tax-23, Mumbai ...Appellant
Versus
Kjs Loan Trust ...Respondent
Mr. Prakash C. Chhotaray, for the Appellant.
Mr. P. J. Pardiwalla, Sr. Advocate with Mr. Madhur Agrawal i/b. Atul K.
Jasani, for Respondents.
Ms. Fereshte Sethna with Mr. Mrunal Parekh i/b. DMD, for
Respondents.
_______________________
CORAM: G. S. KULKARNI &
SOMASEKHAR SUNDARESAN, JJ.
DATE 16 JULY 2024 _______________________ P.C.
1. Heard learned Counsel for the appellants.
2. Stand over to 24 July 2024 at 3.30 p.m. (SOMASEKHAR SUNDARESAN, J.) (G. S. KULKARNI , J.) Page 20 of 20 Signed by: P.V.Rane 16 July 2024 Designation: PS To Honourable Judge Date: 23/07/2024 22:03:46