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    <title>1997 (12) TMI 93 - GUJARAT High Court</title>
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    <description>An irrevocable assignment of a retired partner&#039;s yet-unaccrued right to receive partnership receipts to a trust was treated as a valid diversion of income by overriding title, because the assessee retained no asset or interest in the source of income when the right arose. On that basis, section 60 did not apply, since it concerns cases where the transferor retains the underlying asset. Section 176(4) also had no application because the facts did not show discontinuance of the profession, but only assignment of the right to receive amounts after retirement. The amounts were therefore not assessable as the assessee&#039;s income.</description>
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    <pubDate>Fri, 12 Dec 1997 00:00:00 +0530</pubDate>
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      <title>1997 (12) TMI 93 - GUJARAT High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=17107</link>
      <description>An irrevocable assignment of a retired partner&#039;s yet-unaccrued right to receive partnership receipts to a trust was treated as a valid diversion of income by overriding title, because the assessee retained no asset or interest in the source of income when the right arose. On that basis, section 60 did not apply, since it concerns cases where the transferor retains the underlying asset. Section 176(4) also had no application because the facts did not show discontinuance of the profession, but only assignment of the right to receive amounts after retirement. The amounts were therefore not assessable as the assessee&#039;s income.</description>
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      <pubDate>Fri, 12 Dec 1997 00:00:00 +0530</pubDate>
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