Income Transfer Without Asset Transfer: Section 60 Includes Income in Transferor's Total Income for Tax Purposes.
Section 60 of the Income Tax Act addresses the transfer of income without transferring the associated assets. In such cases, the income is included in the transferor's total income, regardless of whether the transfer is revocable or when it was effected. This rule applies unless the asset itself is transferred. The transfer of income alone is considered merely an application of income, not a transfer of the income source. The transferor remains the taxable person for such income.