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21. The other submission made by Mr. Wazir Singh was that section 11 was subject to sections 60 to 63. It was submitted that section 62 and 63 would directly apply to the facts of the present case. Section 62 reads as follows :

"62. (1) The provisions of section 61 shall not apply to any income arising to any person by virtue of a transfer -
(i) by way of trust which is not revocable during the lifetime of the beneficiary, and, in the case of any other transfer, which is not revocable during the lifetime of the transferee; or