Section 96 of the Income-tax Act, 2025 includes income in the total income of the transferor where

Section 96 of the Income-tax Act, 2025 applies where income arises to a person by virtue of a transfer, whether revocable or not, and there is no transfer of the assets from which the income arises; such income is taxed as the transferor's. It therefore covers the case where "income is transferred without transferring the asset from which it arises", while a revocable transfer of the asset itself is dealt with by section 97. This corresponds to section 60 of the repealed Income-tax Act, 1961.