https://www.taxtmi.com/caselaws?id=49225 Section 44D was interpreted as an anti-avoidance deeming provision focused on the effect of a transfer, not on whether the assessee personally executed it. The provision applied where assets were transferred by a firm if the arrangement enabled the assessees to enjoy or control the income in the relevant assessment year. The section was also held to operate even if the income was not chargeable at the time of transfer. On the facts, the assessees were found to have power to enjoy the income through family control of the company, and the bona fide transaction exemption was unavailable because the transfer was found to have been made to avoid tax. en-us Mon, 29 Nov 1965 00:00:00 +0530 Mon, 18 Aug 2014 22:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49225 Section 44D was interpreted as an anti-avoidance deeming provision focused on the effect of a transfer, not on whether the assessee personally executed it. The provision applied where assets were transferred by a firm if the arrangement enabled the assessees to enjoy or control the income in the relevant assessment year. The section was also held to operate even if the income was not chargeable at the time of transfer. On the facts, the assessees were found to have power to enjoy the income through family control of the company, and the bona fide transaction exemption was unavailable because the transfer was found to have been made to avoid tax. Case-Laws Income Tax Mon, 29 Nov 1965 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49225