Registration relates back to execution date for tax purposes, defeating spousal clubbing and wealth inclusion.

A registered transfer deed intended to operate from the date of execution takes effect for tax purposes from that execution date, even if registration occurs later. Applying section 47 of the Registration Act, 1908, the transferee was treated as owner from the execution date. Because the transferee was not the assessee's spouse on that date, the clubbing condition in section 64(1)(iv) of the Income-tax Act, 1961 was not met. For the same reason, the property value was not includible in the assessee's net wealth under the Wealth-tax Act, 1957.

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Issues: Whether the settlement of immovable property became effective from the date of execution or only from the date of registration for the purpose of section 64(1)(iv) of the Income-tax Act, 1961 and the inclusion of the property's value in net wealth under the Wealth-tax Act, 1957.

Analysis: The transfer was executed before the marriage but registered later. The controlling question was whether, on registration, the deed related back to the date of execution under section 47 of the Registration Act, 1908. On the facts, the Court accepted that the registered document took effect from the date of execution, so the transferee became the owner from that date. Since the transferee was not the spouse on the execution date, the statutory condition for clubbing income under section 64(1)(iv) was not satisfied. For the same reason, the asset could not be treated as the assessee's wealth on the relevant valuation date.

Conclusion: The income from the property was not assessable in the assessee's hands under section 64(1)(iv) of the Income-tax Act, 1961, and the property's value was not includible in the assessee's net wealth under the Wealth-tax Act, 1957.

Ratio Decidendi: Where a registered transfer deed is intended to operate from the date of execution, the operative date of transfer is the execution date for tax consequences, and a spousal-clubbing provision cannot apply unless the transferee is the spouse on that date.

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