Clubbed income liability attaches to the transferee after notice of demand, with joint and several recovery for jointly held assets.

Liability in respect of clubbed income attaches to the person in whose hands the income is included, even where the income belongs to another person as the real owner of the asset or firm interest. Under the new section 100, the transferee becomes liable, after service of a notice of demand by the Assessing Officer, to pay the portion of tax attributable to the clubbed income. Where the asset is jointly held, all co-owners are jointly and severally liable, and the recovery machinery under Chapter XIX-D applies.

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