Author- Bhavika khetrapal, 4th Year, (S.S Khanna Girls' Degree College University of Allahabad)
Clubbing of Income
ABSTRACT
Albert Einstein has rightly said, “The hardest thing in the world to understand is the income tax.”
A taxpayer frequently feels compelled to combine another person's income
with their own.
This occurs when he intends to transfer any of his income or assets to a
different person in order to minimize taxation on the income while it remains
in his possession. The Income Tax Act of 1961's clubbing rules are the result
of these transactions. The Income Tax Act of 1961, including sections 60 to 64,
outlines the circumstances in which an individual is subject to taxation for
income that is earned by others. Of the several scenarios listed in these
sections, the case of an individual transferring an asset to his spouse without
giving it any thought has been thoroughly examined. Analysis has been done on
the impact of taxability on both the transferor and the transferee of such an
asset. It has been noted that the transfer of income to a spouse can serve as a
useful tax planning tool even in the face of clubbing provisions.
Clubbing of income is a critical anti-avoidance provision under tax laws
designed to prevent individuals from transferring their income to others to
reduce their overall tax liability. By analyzing legal provisions, case laws,
and tax avoidance tactics, the paper underscores the importance of these laws
in maintaining the integrity of the tax system
Keywords:
Income tax, Provisions, Spouse, Transfer, Taxpayer, Clubbing
INTRODUCTION
Clubbing of income means adding another person's
income to the taxpayer's total income under some circumstances. The main goal
of these laws is to stop tax avoidance, which is the transfer of money to
relatives or other close relatives in order to take advantage of tax breaks or
reduced rates. Clubbing requirements are defined under sections 60 to 64 of the
Income Tax Act, 1961 in various countries, including India. With the use of
pertinent case laws and judicial interpretations, this study seeks to present a
thorough analysis of clubbing provisions, including their legislative origins,
practical ramifications, and critical assessment.These
provisions address specific scenarios in which an individual transfers his
assets to another party in a way that shifts the tax liability to the recipient
while maintaining a direct or indirect benefit to the transferor from the
transferred assets. Therefore, it may be claimed that these parts have been
included in a way that prevents someone from doing such an act to avoid paying
taxes.
A
taxpayer is continually searching for methods to reduce their tax liability or
avoid paying taxes altogether. Clubbing income can also protect a taxpayer from
tax consequences if he plans to make gifts to his loved ones. Therefore,
learning strategies for reducing taxes is essential for all taxpayers.
Transferring
assets to family members is one such attempt, as is dividing income among
several identities under the guise of non-taxable income. Some of the examples
of this include giving the wife's salary from an entity in which her husband is
the owner, transferring the house's property to family members, and making
investments in the name of the wife or children.However, these attempts by the
average person to save taxes fail because they are unaware of the regulations
pertaining to "clubbing of income" that are provided in the Income
Tax Act, 1961. For instance, Rohan's tax return would contain the revenue from
salaries category if his wife, Nisha, received a salary from Rohan's company.
Should Rohan give his shares to Nisha for less money, the dividends from those
shares would fall under the category of "Income from other sources."
The main
goal of clubbing laws is to stop taxpayers from shifting income to individuals
who are either free from taxation or subject to lower tax rates in order to
artificially reduce their tax liability. By guaranteeing that income is taxed
in the hands of the person who economically benefits from it, these regulations
contribute to the integrity of the tax system.
CLUBBING
OF INCOME UNDER INCOME TAX ACT
Clubbing of Income is the term used to describe the situation where
another person's income is taxable in our jurisdiction and included in our own.
We refer to the income that is included in our income as considered income. The
income clubbing rules only applied to individuals; assessments of other
categories, such as businesses, Hindu undivided families, and companies, were
not covered.
Let’s
take an illustration to understand this situation:
Income
transferred to another person without transfer of the asset is not charged in
hand of transferee but it would be taxed in hand of Transferor. Listen up, if
Harsh transfers his rental income of a rented out house to Bhoomi without
transferring the title over then this rental income would be clubbed in hands
of Harsh and not with that of Bhoomi since he is transferor.
Let
us understand the consequences of each transaction
entered into by the tax payer:
(A)Transfer
of Income: Under a settlement, trust, or
agreement, if an individual transfers income from any asset to their wife,
kids, or relatives without actually transferring the asset, that income will be
added to the transferor's total income. Even in cases where an agreement to
transfer income was made before the Income Tax Act, this provision still holds
true.
(B)
Transfer of assets for inadequate consideration:
The clubbing clause will take effect when a person transfers an asset in his
wife's name for an inadequate consideration. In these situations, the
transferor's income is combined with the income from the asset.
Example:
If Rishu invests Rs. 3 lakhs in Fixed Deposits in the name of his spouse Beena,
the interest earned from such FD shall be clubbed with the income of Rishu.
If
an owner transfers their home to their spouse without providing sufficient
consideration, the transferor will still be regarded as the owner. As a result,
the transferor gets taxed on the income from such residential property. The
rules of clubbing of income do not apply when any asset is
transferred
to the wife for consideration, no matter how small.[1] As
a result, the transferee's income from the transferred asset is considered to
be theirs and is taxable.
(C)Pay
or benefits from a company in which the spouse owns a sizable stake:
A person's earnings are combined with their spouse's income when they get
compensation in the form of a salary, fees, commissions, or any other type of
payment from a business in which their spouse owns a significant stake. If
money is received without any kind of qualification, then this clubbing
provision is applicable (professional or technical).[2] If
an individual is qualified for the position due to his technical and
professional experience, income cannot be combined with a spouse's salary.
Income
tax provisions on Clubbing of Income:
|
INCOME
TAX PROVISION |
TRANSACTIONS |
|
S.60 |
Transfer
of Income without Transfer of Asset |
|
S.61 |
Revocable
Transfer of Asset |
|
S.
64(1)(ii), 64(1)(iv), 64(1)(vii) |
Clubbing
of Income of Spouse |
|
S.64(1)(vi),
64(1)(viii) |
Clubbing
of Income in case of Son’s Wife |
|
S.64(1A) |
Clubbing
of Income of Minor Child |
|
S.64(2) |
Clubbing
of Income & Hindu UndividedFamily |
APPLICABILITY
OF CLUBBING OF INCOME
There
are different situations which attract the provisions of Clubbing of Income.
Let us glance through them:
A. Transfer
of Income without Transfer of Asset [Section 60]
A.When
an assessee transfers income without transferring ownership of the assets that
generate it, that income (such as rental income when the property owner
requests that his tenant pay the rent in the names of his spouse, children, or
parents) will be added to taxation in the hands of the transferor assessee.Thereby
preventing tax evasion i.e., taxpayers from assigning the income and keeping
ownership of the asset. This section is especially relevant when people try to
pass on their income to family members or any other person.
All income which
arises to any person by virtue of a transfer without a transfer or in the
applying his property when he looses by way of such application u/s 61would be
chargeable with tax merely as if it is an item that will always have been
specifically formed but because all total taxable incomes.[3]‘Transfer’ includes any settlement,
trust, covenant, agreement, arrangement.[4]
ILLUSTRATION: Harsh receives Rs 50,000 a month in rental
income from his Gorakhpur home. He encouraged his tenant to pay the rent by
writing a check payable to his wife in an effort to avoid paying taxes. Even
though the money in this instance is in Harsh's wife's account, Harsh would
still be taxed on it because he only transferred the source of income and not
the house's legal ownership.
B.
Revocable Transfer of
Asset [Section 61]
When an assessee
gives another party ownership of an asset with a provision in the agreement
allowing the transferor to reclaim ownership at a later date. We refer to this
circumstance as revocable transfer.In the hands of the transferor, any income
from an asset that is transferred in a "revocable manner" will be
subject to taxes. This stops people from temporarily moving assets to lower
their tax obligations.If (i) a transfer includes a clause allowing for the
direct or indirect retransfer of all or a portion of the income or assets to
the transferor, or (ii) the transferor receives the income or assets in any
manner, the transfer is considered revocable.
ILLUSTRATION: Rajesh
gave Shreya ownership of his house. The deal stipulates that after two years, Rajesh
will receive back ownership of the asset. According to the clubbing of income,
any income that Shreya receives from this house during the two years will only
be included in Rajesh's income.
C. Clubbing
of Income ofSpouse[Section64(1)(ii),64(1)(iv),64(1)(vii)]
Transferring
income onto our spouse's name is a widely used strategy to reduce taxes.
Special measures are in place to keep an eye on these transfers. The following
is a discussion of all the various scenarios:
1. My
spouse works for a company that I own a significant stake in: A person is said
to have substantial interest when they are entitled to 20% or more of earnings
(if the company has any) or at least 20% of the vote. This example has two
components, which are explained as follows:
|
Spouse is employed because of
his/her professional/ technical qualifications. |
Provision of Clubbing of Income
will not apply. In other words, only the spouse will be subject to taxes on
that compensation. For instance, if you are a partner in a business, you are
entitled to 40% of the company's income. Since your wife works as a general
manager for the same company and receives Rs 20,000 per month for her
expertise, you will not be able to keep this money. |
|
No such professional/ technical
qualification. |
Any compensation that my spouse
receives from such a company or entity will be combined and subject to my
personal taxes alone. |
2. When
a person and his spouse receive remuneration from a concern, and both have
substantial interest in that concern:
In the event
that both person and his spouse get remunerationfrom
a company and have a significant stake in that company, there combined remuneration
will be clubbed becomes the possession of the spouse with a higher income
(without such compensation).However, the general consensus is that the clubbing
provisions do not apply if both spouses are being paid for their professional
skills.[5]
Note:
Substantial interest is defined as having the right, at any point in the year,
to not less than 20% of a company's voting power (in the case of a company) or
20% or more of the firm's profits.
3. If
you have given any asset to your wife without giving adequate consideration:Transferring
an income-generating item into the name of one's spouse in order to avoid
paying taxes is a relatively prevalent practice. These new regulations aim to
stop these kinds of tax evasion schemes. Income from these assets will
thereafter be subject to taxation. This income clubbing clause will not apply
if an asset is transferred:
a) in exchange
for adequate consideration;
b) as a
requirement of a divorce;
c) prior to
marriage.
4. The
transferee modifies the character of the transferred gift.:
Sometimes a
transferred gift that wasn't taxable at first is invested further so that it
begins to generate income. The rules of section 64(1)(iv) apply in all such
circumstances where the transferee spouse modifies the character of the asset,
and clubbing of incomeshould take place.
ILLUSTRATION: Mr.
Narayan gave his wife Sonam a present of Rs. 6,00,000. Sonam places this sum of
money into a savings account and begins to receive interest on it. Does Mr. Narayan
have to pay taxes on this interest?
Since Sonam, the
wife, has received the gift of Rs 6,00,000, it is not taxable. However, in
compliance with section 64(1)(iv), Mr. Narayan will be liable for the interest
earned on FD.
5. Any
asset transferred made to a third person[6]:
Such
a transfer must have been made without consideration or with insufficient
consideration in order to eventually benefit your spouse, either now or in the
future. This type of asset route will also be subject to the clubbing
provisions, which postpone your spouse's benefit from the assets.
D. Clubbing
in case of Son’s Wife Income [Section 64(1)(vi),64(1)(viii)]
The clubbing of
income provisions also apply if you give your daughter-in-law any money
transfers. We discuss the circumstances below. Your daughter-in-law received
the asset without proper consideration. If this is the case, any income you
obtain from that asset will be subject to taxation.
ILLUSTRATION: Rahul
gave his daughter-in-law 10,000 and 10% Debentures, each valued Rs 100, without
asking anything in return. His taxes will now include the Rs. 1,00,000 interest
income.
E. Clubbing
of Minor Child’s Income [Section 64(1A)]
In the case of a
minor child below 18 years, its income shall be clubbed in the hands of either
of its parents, whose income (exclusive minor’s income) is greater.[7]
There are specific
circumstances stated in the income tax provisions, but there is no such need in
other provisions. These are the following:
i.
When a minor kid is
classified as disabled under Section 80U, or
ii.
When a minor earns
money by physically demanding labour or
iii.
Money a young youngster
makes from his talents, etc. For instance, a young child wins money on
television programmes such as Voice India Kids and Indian Idol Junior.
F. Clubbing
of the Major Child's Income
People often ask
how much money their major child makes. In situations like this, a particular
sentence is not necessary. The same guidelines that apply to adults up to the
age of sixty also apply to major children. As a result, if your significant
child's income surpasses Rs 2.5 lakhs (before any deductions), he needs to file
an income tax return. It is forbidden to combine income provisions. The child
may have been a minor throughout the fiscal year in which they became a major.
In this scenario, income would not be merged until the child turned become a
minor, but rather for the remainder of the year.
Clubbing of
Income & Hindu Undivided Family [Section 64(2)]
The Hindu
Undivided Family has been around for a very long time. Rules pertaining to
income taxes also acknowledge HUF as an assesses. To put it plainly, A HUF is
required to submit an income tax return. Consequently, clubbing of income
provision is also attracted in the case of HUF.
Any income
derived from personal assets that were transferred to the HUF without adequate
consideration will be subject to personal taxation.
The dispersed
property in your spouse's possession will be combined with your income in the
event of a future HUF split.
ILLUSTRATION:Ashish
have a residence that generates Rs 5,00,000 in rental income annually. The
entire Rs 5,00,000 in income is going to be taxed in Ashish’s name alone if Ashish
transfer this house to the HUF without giving it proper or sufficient
consideration.
Self-acquired
Property converted to Joint Ownership
The
revenue that a joint family receives from self-acquired property that is
converted is added to the total amount of money that the joint family is
responsible for, without giving it enough thought. If a person is a member of
the HUF, the income from such property will be included in their overall
income.:
a) transforms
their individual property into the HUF.
b) Integrates
the property into the family's common stock
c) gives
their own belongings to the family without receiving sufficient consideration
This
clause guarantees the inclusion of any income recognized in the applicable tax
assessments as a result of the conversion or transfer of independently acquired
property into joint family property.
Non-Applicability
of Clubbing of Income
Income
transferred before marriage:Any gift or asset given to the prospective wife
before the marriage is exempt from the clubbing limitations. Considering that
the spouses ought to be related at the time of both the asset transfer and the
income accrual.
Income
from clubbed income: Any additional income from the revenue earned will not be
included in the club if the asset is passed to a spouse or, in the case of a
minor, to a daughter-in-law (the son's wife).
Savings
are not regarded as transferred assets.:The wife's savings from donations made
to help with daily or household expenses are not considered an asset transfer
and are not subject to the clubbing restrictions.
If
the clubbed income consists of interest or prizes from games, puzzles,
lotteries, or other similar sources, it will be classified as income from other
sources; otherwise, it will be taxed as income from house property. Similarly,
to put it succinctly, its generation source will always be the head of bundled
revenue. Clubbing rules, however, will have an impact on how you calculate your
income and file your return.
For
instance, Mr. Kian's salary is Rs 6,00,000. Kian likes to play lotto games with
his youngster lavya. Superb lavyamade Rs 2,00,000 one day. Lavya's income will
be pooled with Mr. Kian as he is a minor. Now, Mr. Kian needs to file his
return using form ITR 2. He would have submitted an ITR 1 Form in the event
that his minor child had not received any "lottery income." The
primary concept is that the sort of revenue to be merged will determine how the
ITR Form is filled out.
Regulatory
Measures and Anti-Avoidance Rules[8]
Governments
have introduced various anti-avoidance rules, such as General Anti-Avoidance
Rules (GAAR), which empower tax authorities to look beyond the legal form of
transactions to their actual substance. GAAR can invalidate any arrangement
with the primary purpose of obtaining a tax benefit, thus supporting the
broader application of clubbing provisions.
CRITICAL
ANALYSISOF CLUBBING PROVISIONS
Strengths
of Clubbing Provisions
Clubbing
provisions effectively curb tax evasion, ensuring that income is taxed according
to the real economic ownership rather than manipulated transfers. By targeting
transactions between closely connected individuals, the law preserves the
integrity of progressive tax systems.
Stopping
Tax Evasion: The purpose of clubbing regulations is to stop people from evading
taxes and from misusing their relatives or connected companies to avoid paying
their fair share of taxes.
Effect
on Tax Planning: When structuring their financial affairs, taxpayers should
exercise caution, particularly if family members are involved. In order to
prevent unfavourable tax outcomes, careful tax planning and adherence to
clubbing regulations are important.
Weaknesses
and Challenges
Despite
their strengths, clubbing provisions face some challenges:
·
Complexity: The
detailed rules can be complex, leading to misunderstandings or misapplications.
·
Enforcement:
Identifying and proving the beneficial ownership or control of
income-generating assets can be challenging for tax authorities.
·
Loopholes: Taxpayers
continue to explore new avoidance schemes, requiring constant updates and
amendments to the law.
Suggestions
for Improvement
To
strengthen the clubbing provisions:
·
Clearer Guidelines:
Simplified and clearer guidelines for both taxpayers and authorities could improve
compliance.
·
Enhanced Enforcement
Mechanisms: Better data analytics and cooperation between tax authorities can
help in identifying evasion tactics.
·
Regular Legislative
Updates: Regularly updating laws to close identified loopholes and respond to
evolving avoidance strategies.
CASE
LAWS AND JUDICIAL INTERPRETATIONS
Abhay
Kumar Mittal v. Dy. CIT ITA[9]
Facts
of the case: For the assessment year 2013–14, Abhay
Kumar Mittal had asked for his wife Shivani Mittal's housing rent to be
deducted from his income. His wife bought the property in her name, and she
reported the rent as income from home property on her income tax filings. The
AO also raised doubts about the assessee's wife's ability to buy the property
because the assessee provided funding for Rs. 87.50 lakh of the Rs. 1.15 crores
utilized to purchase it. The AO appealed, arguing that the rental income had to
be clubbed with the assessee's substantial contributionunder Section 64 of the
Income Tax Act 1961because the wife's has no independent income sources.
Submission
by the Assessee:
1.
Validity of the Transaction: The assessee stated that the rent he paid his wife
for the house was legal and that she had reported the rental income on her
taxes under income from house property.
2.Provide the wife an advance: The assessee clarified that his wife had
borrowed money from him to cover the cost of the property acquisition and that
she had used her own money to repay him, including by liquidating fixed
deposits and redeeming mutual funds.
3.No
Prohibition of Rent to Spouse: The assessee asserts that the Income Tax Act
does not prohibit claiming a home rent allowance or paying any rent to one's
spouse, provided that the transaction is sincere and open.
Observation
of the Commissioner of Income Tax:
1.
Income Clubbing: In accordance with Section 64 of the Income Tax Act, the CIT
upheld the AO's order on the clubbing of rental income. In addition to
rejecting the claim, the CIT invalidated this independent and declared that the
assessee provided the majority of the cash and that the wife did not have
enough income on her own to buy the home.
2.The
Wife's inadequate resources: The CIT properly determined that the wife could
not have invested in the subject property on her own without taking the
assessee's financial support into account, as she had only a meager salary in
prior years.
3.Property
as Joint Investment:The assessee was recognized as the second holder in a
series of investments made in the wife's property, according to the CIT.
ITAT
Decision:
1.
No Prohibition on Rent Paid to Spouse: It was decided that the Income Tax Act
does not contain any legislative restrictions that would forbid paying rent to
a spouse. The revenue authorities have acknowledged the rental receipts that
the wife included in her income tax return.
2.
Lawful Loan Repayment: The wife had obtained a loan from the assessee to
purchase the aforementioned property, and it had been accepted since it had
been paid back through legitimate channels including the redemption of mutual
funds and the liquidation of fixed deposits.
3.
Property Listed in Wife's Name: The Tribunal found that the property was
registered in the wife's name and that she had reported rental revenue on her
tax forms.
4.
No legal foundation for clubbing the Income: The Tribunal determined that the
AO's clubbing of rental income under Section 64 was unjustified and without a
basis in law. It was proved that the wife owned the property on her own.
Secunderabad
Club Etc. vs C.I.T-V Etc[10]
Facts
of the case:
The
case involved the Secunderabad Club, a prominent social club, and its taxation
under the Income Tax Act.The primary issue revolved around whether the amount
of money made by the club from its members, such as fees and charges for
various services, should be subjected to income tax.The club argued that the
income generated from its members was not taxable due to the doctrine of
mutuality, which means that there is no commercial transaction between the club
and its members.
Issues:
1.
Whether the income of the club derived from transactions with its members is
exempt under the doctrine of mutuality.
2.
Whether the principles of mutuality apply in the case of income from
non-members and other commercial activities.
Judgment:
1.
The Court held that the doctrine of mutuality does not apply to income
generated by the club from non-members or commercial activities.
2.
However, the income derived exclusively from members could still be covered
under the doctrine of mutuality, and therefore, not subject to tax.
3. The court emphasized that for the mutuality principle to apply, the relationship between the club and its members should not involve any commercial profit-making intent.
CONCLUSION
The
Income Tax Act, 1961's clubbing provisions are a vital component of India's tax
structure. These rules are designed to stop taxpayers from moving assets or
income to relatives or other connected businesses in an attempt to artificially
lower their tax obligation. To maintain compliance and prevent unforeseen tax
repercussions, it is imperative that taxpayers and tax professionals comprehend
the major portions and their ramifications. Although the purpose of these laws
is to stop tax evasion, they nevertheless provide limitations and exclusions
that let lawful income-earning endeavours continue without facing unfavourable
tax consequences.
There
are numerous strategies and techniques to keep taxes from grabbing hold of our
hard-earned money. Tax planning is essential. Giving money as a premarital gift
to one's wife or daughter-in-law helps prevent income clubbing. After marriage,
the clubbing provisions will come into play if one provides any money.
Additionally, if the home is owned by one's parents and they live with him.
After that, we may give them our rent and ask to have our housing rent
allowance waived. Obtaining health insurance for one's family allows one to
further claim the deduction under Section 80D.Remember that investments ought
to come through joint accounts, at the pain of interest income be taxable tothe
primary holder and can be done in a tax saving way. All such steps can
beundertaken to reduce tax liability because it is the wearer who knows where
the shoe pinches.
The aforementioned makes it clear that any income resulting from an asset that a person transfers to his spouse without payment will be combined and held by the transferor. He is not eligible to get any immediate tax benefits from the transfer. Given that the compounding effect is not combined, transferring the aforementioned income might be seen as a useful tax planning strategy. Long-term tax savings could be significant, even if there might not be any immediate tax benefits.
SUGGESTION
The
taxation concept known as "clubbing of income" states that some forms
of income received by various people are aggregated for taxable purposes. The
following are some suggestions for approaching income clubbing:
Recognize
the Provisions: Become acquainted with the
particular tax legislation pertaining to income clubbing in your jurisdiction.
This frequently involves making allowances for income from assets given to a
spouse or younger child.
Determine
revenue Sources: Find out which forms of revenue
are susceptible to clubbing. This can include gifts, investments, and income
from real estate.
Documentation:
Keep detailed records of every source of income and every transfer that takes
place. This can strengthen your position in the event of a tax assessment and
help to clarify ownership.
Consider
the importance of tax planning: Utilize
strategies to minimize clubbing implications within the bounds of the law. For
instance, arrange investments in a way that prevents easy attribution of income
to a spouse or minor.
Seek
professional guidance: Consult with a tax
professional or financial advisor who can offer tailored advice based on your
specific situation.
Splitting
Income:Explore legal methods of income
splitting with family members to leverage lower tax brackets, where applicable.
Gifts
and Transfers:Exercise caution when making gifts
or transfers that could unintentionally result in income clubbing. Gain a clear
understanding of the tax consequences of transferring assets to family members.
Review Annually: Review your income sources and structures on an annual basis to ensure compliance and optimize your tax positioning.
REFERENCES
Articles:
·
Ahuja G & Gupta R,
Simplified Approach to Income Tax and Sales Tax, Sahitya Bhawan Publishers andDistributors
Ltd.
·
Lal B.B.&Vashisht,
Direct Taxes, Pearson Education, 28e.
·
Pagare D, Law and
Practice ofIncome Tax, Sultan Chand. & Sons.
·
Singhania V.K. &
Singhania M, Students' Guide to Income Tax, Taxmann Publications Private Ltd.
Websites:
·
https://www.taxmann.com/post/blog/743/provisions-of-clubbing-of-income-under-income-tax-act-1961/
·
https://www.freedmaxick.com/services/tax/international-tax-services/expatriate-tax-planning/
·
https://cleartax.in/s/section-64-clubbing-income
[1]‘Income tax: Know the
rules of clubbing income’ (2021)https://news.cleartax.in/income-tax-know-the-rules-of-clubbing-of-income/7201/(Accessed:20 September
2024)
[2]‘Provisions of
clubbing of income under Income Tax Act’ (2023) https://www.taxmann.com/post/blog/743/provisions-of-clubbing-of-income-under-income-tax-act-1961/ (Accessed: 20
September 2024).
[3]ProvatKumar Mitter v.
C.I.T.(1961)
41 I.T.R. 624 (S.C.).
[4]The Income Tax Act1961,
s 63
[5] Reddy S,
‘Understanding “clubbing” of Income of Spouse & Child: A Complete Guide’
(ReLakhs, 4 August 2020) https://www.relakhs.com/clubbing-of-income-of-spouse-minor-child/ accessed 21 September
2024.
[6] Ayush, ‘Clubbing of
Income under Income Tax Act’ (CAclubindia, 27 February 2024) https://www.caclubindia.com/articles/clubbing-of-income-under-income-tax-act-49554.asp accessed 21 September
2024
[7]‘Tax Equalization
Policy Global Employees: Expatriate Tax Planning’ (Freed Maxick) https://www.freedmaxick.com/services/tax/international-tax-services/expatriate-tax-planning/ accessed 22 September
2024
[8] ‘Tax Avoidance and
Anti-Avoidance Measures’ [2003] Tax Avoidance and Anti-Avoidance Measures in
Major Developing Economies 77.
[9](Delhi Tribunal) No.
3385/Del/2019 2022 Tax Public (DT) 1854: (2022) 194 ITD 0224 Date of Judgement:
8 Feb 2022.
[10]Neutral Citation: 2023 INSC 736
Post a Comment