COMMISSIONER OF INCOME-TAX, CULCUTTA vs KESHAVLAL LALLUBHAI PATEL

The Supreme Court held that the transfer of self-acquired property into a Hindu Undivided Family (HUF) hotchpotch and subsequent partition does not constitute an indirect transfer under Section 16(3)(a)(iii) and (iv) of the Income Tax Act, 1922. The Court clarified that for these provisions to apply, there must be a direct or indirect transfer of assets from the husband to the wife or minor child, which was not satisfied in this case. The High Court's ruling that the transactions did not amount to a transfer was upheld, confirming the assessee's claim for assessment was valid.