Sec. 62 read with section 164 of the Income Tax Act, 1961 — Revocable/Irrevocable Transfer — Where funds were transferred by beneficiaries to a trust created by State Government were revocable after 3 years, provisions of Section 62 (2) clearly attracted to assessee's case and thus income arising by virtue of a revocable transfer of assets would be chargeable to tax as income of transferors and would be included in the total income. SLP of the revenue dismissed. - CIT V/s TAMILNADU URBAN DEVELOPMENT FUND - [2020] 269 TAXMAN 005 (SC)