Clubbing of income under section 64(1)(vi) fails where Explanation 3 cannot be stretched beyond its express scope.

Explanation 3 to section 64(1) applies only to clauses (iv) and (v) and cannot be extended by interpretation to clause (vi); taxing provisions cannot be enlarged beyond their express language, so the daughter's-in-law share of profit was not includible in the assessee's income under section 64(1)(vi). The deposit of the gifted amount with the firm also lacked the direct nexus needed to treat it as part of the partner-inclusion rule, reinforcing that the income could not be clubbed in the assessee's hands.

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Issues: Whether the share of profit earned by the assessee's daughter-in-law from the firm could be included in the assessee's income under section 64(1)(vi) of the Income-tax Act, 1961, and whether Explanation 3 to section 64(1) extended to such inclusion.

Analysis: Explanation 3 expressly applied only to clauses (iv) and (v) of section 64(1), and could not be extended by intendment to clause (vi). In taxing provisions, no scope exists for enlarging the statutory language beyond what the Legislature has enacted. The deposit of the gifted amount with the firm was also found not to have an intimate or direct nexus with the daughter-in-law becoming a partner in the firm.

Conclusion: The share income of the daughter-in-law from the firm was not includible in the assessee's hands under section 64(1)(vi).

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