Clubbing of income from transferred assets excludes later accretion income earned by the transferee.

Income arising directly to the transferee from property transferred without consideration may be included in the transferor's taxable income under the clubbing rules. The relevant principle is that income derived from the transferred asset itself is treated as income of the transferor when the transfer falls within the statutory clubbing framework. Income arising from accretion to the transferred property, however, is treated differently and is not includible in the transferor's total income.

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