https://www.taxtmi.com/caselaws?id=276850 Section 44D was construed broadly to cover transfers of assets by a firm even where the assessees were not the direct transferors, because the statutory language did not require personal transfer by the taxpayer. The phrase referring to income chargeable to tax was read by reference to the assessment year and the applicable law and facts, not as limiting the provision to income chargeable in the year of transfer. Substantial shareholding in a closely held corporation was treated as sufficient practical power to enjoy the income. Relief under section 44D(3)(a) was unavailable where surrounding circumstances showed that avoidance of tax was one of the purposes of the transfer or associated operations. en-us Fri, 16 Oct 1959 00:00:00 +0530 Mon, 19 Nov 2018 14:50:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276850 Section 44D was construed broadly to cover transfers of assets by a firm even where the assessees were not the direct transferors, because the statutory language did not require personal transfer by the taxpayer. The phrase referring to income chargeable to tax was read by reference to the assessment year and the applicable law and facts, not as limiting the provision to income chargeable in the year of transfer. Substantial shareholding in a closely held corporation was treated as sufficient practical power to enjoy the income. Relief under section 44D(3)(a) was unavailable where surrounding circumstances showed that avoidance of tax was one of the purposes of the transfer or associated operations. Case-Laws Income Tax Fri, 16 Oct 1959 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276850