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Case lawCBDT Circulars & Instructions › Statutory position — s.64(2): converting self-acquired property into HUF property does not move the income, and on a partition the spouse's share is clubbed too
CBDT Circulars & InstructionsCuts both wayss.64(2)s.64(1)s.64s.10(2)s.171

Statutory position — s.64(2): converting self-acquired property into HUF property does not move the income, and on a partition the spouse's share is clubbed too

A client wants to transfer a rental property he owns personally into his family HUF so that the rent is taxed in the HUF's lower slab. He says the HUF will be a separate assessee with its own basic exemption. Does that work?

A client wants to transfer a rental property he owns personally into his family HUF so that the rent is taxed in the HUF's lower slab. He says the HUF will be a separate assessee with its own basic exemption. Does that work?

No. Section 64(2) applies where an individual who is a member of a Hindu undivided family converts property that was his separate property into property belonging to the family — by impressing it with the character of family property, or by throwing it into the common stock, or by transferring it to the family otherwise than for adequate consideration. From the assessment year beginning 1 April 1971, and notwithstanding anything in any other provision of the Act or in any other law, the income derived from the converted property is deemed to arise to the INDIVIDUAL and not to the family. And the clubbing survives a partition: where the converted property has been the subject-matter of a partition, whether partial or total, the income from so much of it as is received by the SPOUSE on partition is deemed to arise to the spouse from assets transferred indirectly by the individual to the spouse, and s.64(1) then applies so as to bring it back into the individual's hands.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 1971-04-01, reported as Income-tax Act, 1961, s.64(2), as printed on the departmental Year 2025, Year 2024 (No. 1), Year 2019 (No. 1), Year 2012, Year 2009 and Year 2000 pages. It bears on section 64(2), section 64(1), section 64, section 10(2), section 171 of the Income Tax Act 1961, in Assessment & Scrutiny, Gifts, Shares & Angel Tax and How Tax Law Is Read matters.

Still good law. Six departmental editions spanning Year 2000 to Year 2025 print sub-section (2) in identical words, and this entry's text was transcribed from editions stamped Year 2025 and Year 2019 (No. 1), so this is a reading of a current edition. I could not read a footnote tying a specific amending Act to any particular words of sub-section (2), and none is asserted. The link to s.10(2) stated in this entry was verified independently on two departmental s.10 pages (Year 2007 and Year 2024 (No. 2)), both of which print clause (2) as opening "subject to the provisions of sub-section (2) of section 64". I did not carry out any check of judicial treatment of s.64(2).

Why it matters

This is the provision that defeats the most common piece of family tax planning in Indian practice. Six features decide the outcome. First, the trigger is deliberately wide: it catches the unilateral act of blending as well as an outright transfer to the family for less than adequate consideration, which matters because blending is not a transfer at all as a matter of Hindu law. Second, the cut-off is 31 December 1969 for the conversion and assessment year 1971-72 for the computation, so a conversion made before those dates is outside the sub-section — a point worth checking before conceding an old family arrangement. Third, clause (a) deems the individual to have transferred the converted property, through the family, to the members of the family for being held by them jointly; that deemed transfer is the hinge on which clauses (b) and (c) hang. Fourth, clause (c) is the part practitioners forget: a partition does not break the clubbing, it merely redirects it — the income from the share received by the SPOUSE on partition is treated as income from assets transferred indirectly to the spouse and comes back through s.64(1). Note the asymmetry: clause (c) names the spouse and no one else, so a share taken on partition by a son does not fall within clause (c). Fifth, the proviso prevents double taxation: income included in the individual's total income under clause (b) or clause (c) is excluded from the total income of the family or of the spouse, as the case may be. Sixth, the definition in Explanation 1 is expansive — "property" includes any interest in property, movable or immovable, the proceeds of sale of it, any money or investment for the time being representing those proceeds, and where the property is converted into any other property by any method, that other property. So selling the converted asset and reinvesting does not shake the clubbing off. Explanation 2 adds that "income" includes loss. Read this alongside s.10(2), which exempts a sum received by a member out of family income but opens with the words "subject to the provisions of sub-section (2) of section 64".

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

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