Under section 97(1) of the Income-tax Act, 2025, income arising to a transferee from an asset…

Section 97(1) of the Income-tax Act, 2025 provides that all income arising to any person by virtue of a revocable transfer of assets is chargeable as income of "the transferor" and is included in his total income. Under section 98(b), a transfer is revocable if it provides for re-transfer of the income or assets to the transferor or gives him a right to re-assume power over them. This corresponds to section 61 of the repealed Income-tax Act, 1961.