Scope of Section 64(1) clarified; appellate decision recommended as guidance for interpreting its applicability in attribution assessments. Doubts have arisen concerning the scope and applicability of Section 64(1) of the Income-tax Act, 1961, specifically whether and how incomes are to be attributed for assessment under that provision. Administrative guidance directs Commissioners of Income-tax to refer to the reasoning in an appellate decision which discusses the applicability and scope of the provision and is recommended as a guide for consistent departmental application.