https://www.taxtmi.com/caselaws?id=168545 Dividend income was treated as arising from a revocable transfer where the share transfer arrangements allowed retransfer on default or bankruptcy and enabled the transferor to reassume control over the income or management, even if those rights were contingent. On that construction of section 16(1)(c) of the Indian Income-tax Act, 1922, the dividend was deemed to be the transferors' income. The assessees were therefore not entitled to refund under section 48, because refund was available only to the person whose total income included the relevant income; grossing-up and deemed payment did not alter that statutory restriction. en-us Tue, 03 Sep 1957 00:00:00 +0530 Wed, 11 Mar 2015 16:51:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=168545 Dividend income was treated as arising from a revocable transfer where the share transfer arrangements allowed retransfer on default or bankruptcy and enabled the transferor to reassume control over the income or management, even if those rights were contingent. On that construction of section 16(1)(c) of the Indian Income-tax Act, 1922, the dividend was deemed to be the transferors' income. The assessees were therefore not entitled to refund under section 48, because refund was available only to the person whose total income included the relevant income; grossing-up and deemed payment did not alter that statutory restriction. Case-Laws Income Tax Tue, 03 Sep 1957 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=168545