Assessee is  a securitisation trust. Assessee had paid an amount under head of Excess Interest Spread (EIS) to originator for relevant year.  The AO held that the assessee is obliged to deduct tax from the said amount under S. 194LBC of the Act  and treated the assessee as defaulter under S. 2001(1), 201(IA) of the Act. On appeal the CIT (A) held that the assessee cannot be treated as an investor within the meaning  of clause (a) Explanation 115TCA as the organisor is neither  receipt. On appeal the Tribunal held that  there is  a clear distinction between originator, which was assignor of loan portfolio to assessee, and PTC holders, who were investors in securitisation trust and since originator was neither a holder of any securitized debt instrument, securities or security receipts, it could not be regarded as an investor. Therefore, assessee is  not obliged to deduct TDS under section 194LBC  of the Act. (AY. 2018-19)