The term loop hole is based on how they described it. They want any payment to be taxed at least at one place (otherwise, it will itch the Babus in Fin min !! somewhere, they have to milk it). since, it was a pass through, it itched them and they said ‘you unit holder, get slaughtered’… 
that is that !! I have pasted the exact Fin bill above in post 149 above…and you can infer this !
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