Diversion of income by overriding title - merely because the...

Diversion of income by overriding title - merely because the moneys flow through the assessee, it cannot be automatically inferred that it is income in the hands of the assessee. The money was always intended to be passed on to the PTC holders and therefore, it can be said that only the PTC holders had a claim on the money, if not an absolute charge - principle of diversion of income at the source by overriding title is attracted - AT