Income arising from revocable transfer of assets [Section 61] :

(i) All income arising to any person by virtue of a revocable transfer of assets is to be included in the total income of the transferor.

(ii) As per section 63, the transfer is deemed to be revocable if—

(a) it contains any provision for the retransfer, directly or indirectly, of the whole or any part of the income or assets to the transferor, or

(b) it gives, in any way to the transferor, a right to reassume power, directly or indirectly, over the whole or any part of the income or the assets.

(iii) This clubbing provision will operate even if only part of income of the transferred asset had been applied for the benefit of the transferor. Once the transfer is revocable, the entire income from the transferred asset is includible in the total income of the transferor.