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10. Section 60 provides :

"All income arising to any person by virtue of a transfer whether revocable or not and whether effected before or after the commencement of this Act shall, where there is no transfer of the assets from which the income arises, be chargeable to income-tax as the income of the transferor and shall be included in his total income."

11. Section 61 makes all income arising to any person by virtue of a revocable transfer of assets chargeable to income-tax as the income of the transferor. Section 62 stipulates that the provisions of Section 61, that is to say, addition of income by virtue of a revocable transfer of assets to the income of the transferor, should not apply to income arising to any person by virtue of a transfer by way of, inter alia, a transfer which is not revocable during the life time of the beneficiary or made before April 1, 1961, which is not revocable for a period exceeding 6 years. But Sub-s. (1) of s. 62 is hedged by a proviso, which is applicable, provided that the transferor does not derive any direct or indirect benefit from such income in either case. If the transferor does derive, in fact, direct or indirect benefit from a transfer and even if the conditions of the sub-clause(i) or(ii) or sub-s. (1) of s. 62 are fulfilled, it would be treated as revocable trust.