Report No. 265

6. Transfer of Assets

6.1 In case of transfer of assets, whatever may be its nature and whatever may be its mode of transfer, the transfer is generally intentional and by free will.

6.2 The indirect transfer, by its very nature, would involve more than one transaction with an ultimate object being, to give effect to original intention of transferring assets by an individual to his or her spouse or minor child.8

8. D M Naielwala v. CIT, (1979) 120 ITR 848 (Bombay).