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<h1>Diversion of income by overriding title shifts taxability to the recipient when payment is compelled by legal obligation.</h1> Diversion of income by overriding title occurs where income is redirected because of a legal obligation before reaching the assessee; such diverted income is taxable in the hands of the recipient and not the person from whom it is diverted. Section 4 recognises diversion at source. Where income is received by an assessee and only later passed to a third person, that is an application of income and remains income of the original recipient.