https://www.taxtmi.com/caselaws?id=6893 Where a genuine sub-partnership or similar arrangement makes others co-owners of a registered firm's share, the income from that share is taxed only to the extent it is the assessee's real income. On the assumed validity of the later deed, the named persons owned the 47.25 pies share itself, so the income was first earned by them in the proportions stated in the deed. The matter was treated as diversion of income at source, not a mere application of the assessee's own income. Accordingly, only the assessee's proportionate share was assessable, and the full amount was not includible in his total income. en-us Thu, 02 Sep 1965 00:00:00 +0530 Fri, 06 Feb 2009 19:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6893 Where a genuine sub-partnership or similar arrangement makes others co-owners of a registered firm's share, the income from that share is taxed only to the extent it is the assessee's real income. On the assumed validity of the later deed, the named persons owned the 47.25 pies share itself, so the income was first earned by them in the proportions stated in the deed. The matter was treated as diversion of income at source, not a mere application of the assessee's own income. Accordingly, only the assessee's proportionate share was assessable, and the full amount was not includible in his total income. Case-Laws Income Tax Thu, 02 Sep 1965 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6893