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    <title>1955 (7) TMI 33 - MADRAS HIGH COURT</title>
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    <description>Settlement deeds that merely directed partnership profits to a wife and daughters, without transferring the underlying asset or source of income, were analysed as an assignment of income rather than a diversion by overriding title. The text explains that section 16(1)(c) of the Income-tax Act, 1922, distinguishes a true transfer of the source from a voluntary disposition of income, so taxability depends on the general charging provisions and the nature of the arrangement. It also notes that section 16(3) supports aggregation where a transfer of assets is involved. On the stated facts, the settled profits remained includible in the assessee&#039;s total income.</description>
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    <pubDate>Thu, 21 Jul 1955 00:00:00 +0530</pubDate>
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      <title>1955 (7) TMI 33 - MADRAS HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=276865</link>
      <description>Settlement deeds that merely directed partnership profits to a wife and daughters, without transferring the underlying asset or source of income, were analysed as an assignment of income rather than a diversion by overriding title. The text explains that section 16(1)(c) of the Income-tax Act, 1922, distinguishes a true transfer of the source from a voluntary disposition of income, so taxability depends on the general charging provisions and the nature of the arrangement. It also notes that section 16(3) supports aggregation where a transfer of assets is involved. On the stated facts, the settled profits remained includible in the assessee&#039;s total income.</description>
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      <pubDate>Thu, 21 Jul 1955 00:00:00 +0530</pubDate>
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