Deemed accrual of income from securities prevents tax avoidance through temporary transfers of beneficial interest. Deemed accrual of income from securities applies where a person has had beneficial interest in securities during the tax year and, because of a transaction involving those securities, receives no income or less income than would have accrued day to day. The proportionate income is then deemed to be that person's income. The provision is directed against tax avoidance through temporary transfers of beneficial interest around the interest payment date, subject to exceptions where no avoidance is shown or the avoidance is exceptional and not systematic. The Assessing Officer may also require information relating to securities by written notice with at least twenty-eight days for compliance.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Deemed accrual of income from securities prevents tax avoidance through temporary transfers of beneficial interest.
Deemed accrual of income from securities applies where a person has had beneficial interest in securities during the tax year and, because of a transaction involving those securities, receives no income or less income than would have accrued day to day. The proportionate income is then deemed to be that person's income. The provision is directed against tax avoidance through temporary transfers of beneficial interest around the interest payment date, subject to exceptions where no avoidance is shown or the avoidance is exceptional and not systematic. The Assessing Officer may also require information relating to securities by written notice with at least twenty-eight days for compliance.
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