Report No. 12
65. Irrevocable transfers.-
(1) The provisions of section 64 [section 16(1)(c), main para., latter half] shall not apply to any income-
(a) arising to any person by virtue of a transfer which is not revocable for a period exceeding six years or during the lifetime of the transferee, or, in the case of a transfer by way of trust, during the life time of the beneficiary, and
(b) from which income the transferor derives no direct or indirect benefit.
[Section 16(1)(c), 3rd proviso earlier half]
(2) Notwithstanding anything contained in sub-section (1), all income arising to any person by virtue of a transfer shall be chargeable to income-tax as the income of the transferor as and when the power to revoke the transfer arises, and shall then be included in his total income.
[Section 16(1)(c), 3rd proviso, latter half]