https://www.taxtmi.com/caselaws?id=49374 Section 16(1)(c) of the Indian Income-tax Act, 1922 fastened settlor liability on income arising under a settlement or revocable transfer, but the third proviso excluded income payable to another person where the settlement was not revocable for more than six years or during the beneficiary's lifetime and the settlor derived no direct or indirect benefit. On the amended trust deed, revocation could not be exercised until specified debts were discharged and the leases continued, so the power of revocation was not exercisable within six years. The proviso applied even though the settlement was otherwise treated as revocable and the assessee had a separate beneficial interest; income of the other beneficiaries was not treated as the assessee's income until the revocation power arose. en-us Tue, 28 Apr 1964 00:00:00 +0530 Sat, 23 Aug 2014 11:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49374 Section 16(1)(c) of the Indian Income-tax Act, 1922 fastened settlor liability on income arising under a settlement or revocable transfer, but the third proviso excluded income payable to another person where the settlement was not revocable for more than six years or during the beneficiary's lifetime and the settlor derived no direct or indirect benefit. On the amended trust deed, revocation could not be exercised until specified debts were discharged and the leases continued, so the power of revocation was not exercisable within six years. The proviso applied even though the settlement was otherwise treated as revocable and the assessee had a separate beneficial interest; income of the other beneficiaries was not treated as the assessee's income until the revocation power arose. Case-Laws Income Tax Tue, 28 Apr 1964 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49374