https://www.taxtmi.com/caselaws?id=8406 Section 16(3) deeming provisions require strict construction and a proximate, interlinked nexus between the assessee's transfer and the income sought to be taxed. On the facts, a genuine gift by the assessee to his wife, followed years later by a separate gift by the wife to the minor sons, was not an indirect transfer by the assessee to the children, because there was no evidence of a prearranged scheme or common intention from the outset. The wife and minor-child limbs of the provision operate separately, so the wife-transfer clause could not be applied to a transfer to minor children. The income was therefore not includible in the assessee's total income on these facts. en-us Mon, 01 Mar 1971 00:00:00 +0530 Sat, 11 Apr 2009 12:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8406 Section 16(3) deeming provisions require strict construction and a proximate, interlinked nexus between the assessee's transfer and the income sought to be taxed. On the facts, a genuine gift by the assessee to his wife, followed years later by a separate gift by the wife to the minor sons, was not an indirect transfer by the assessee to the children, because there was no evidence of a prearranged scheme or common intention from the outset. The wife and minor-child limbs of the provision operate separately, so the wife-transfer clause could not be applied to a transfer to minor children. The income was therefore not includible in the assessee's total income on these facts. Case-Laws Income Tax Mon, 01 Mar 1971 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8406