§ 96
Chapter V — Income Of Other Persons Included In Total Income Of Assessee

Transfer of income without transfer of assets

Income-tax Act, 2025

Business owners should be aware that income from a transfer, whether revocable or not, is taxable. This applies even if there's no transfer of assets. The income is chargeable to the transferor and included in their total income. Key points to note include:

  • the transfer can be made before or after the commencement of the Act
  • no actual asset transfer is required for the income to be taxable

📜 Official text of the section +
96. All income arising to any person by virtue of a transfer,— ( a) whether revocable or not, and whether effected before or after the com- mencement of this Act; and ( b) where there is no transfer of assets from which such income arises, shall be chargeable to income-tax as the income of the transferor and shall be included in his total income. Chargeability of income in transfer of assets.

Plain-language summary — not the official text. Refer to the bare Act and confirm with a professional for your specific case.