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of <h1>Section 171 of Income Tax Act: Partition Requires Physical Division of Property, Not Just Income Division for Tax Purposes.</h1> Under Section 171 of the Income Tax Act, 1961, 'partition' refers to the physical division of property, not merely the division of income. Legal interpretations clarify that partition requires actual physical division, and a mere change in status or agreements without such division does not suffice. Court rulings, such as those in Govind Das v. ITO and ITO v. N. K. Sarada Thampatty, emphasize that for tax purposes, a Hindu undivided family (HUF) remains as such unless there is a tangible division of property. The law imposes specific tax liabilities on HUF members post-partition, which differ from general Hindu law principles.
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