Income inclusion for family transfers: transfers and relatives' receipts can be taxed to the transferor under attribution rules. Section 64 attributes to an individual income that arises directly or indirectly to specified relatives where the income benefits the individual ... Summary
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Income inclusion for family transfers: transfers and relatives' receipts can be taxed to the transferor under attribution rules.
Section 64 attributes to an individual income that arises directly or indirectly to specified relatives where the income benefits the individual immediately or deferredly: remuneration to a spouse from a concern in which the individual has a substantial interest (with an exception for income solely from the spouse's technical/professional qualifications), income of a minor child subject to exclusions for manual work or skilled activity, and income from assets transferred otherwise than for adequate consideration to spouses, son's wife, or other persons to the extent the income benefits those relatives. Explanations pro-rate income when transferees invest in business or contribute capital, prescribe substantial-interest tests, permit Assessing Officer re-attribution after hearing, and deem converted separate property in an HUF to have been transferred through the family; "income" includes loss.
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