Section 98
Section 98: meaning of "transfer" and "revocable transfer"
Section 98 defines two terms that are central to the clubbing rules in Sections 96 and 97: what counts as a "transfer", and when a transfer is treated as "revocable."
This explanation is AI-assisted and pending review by our CA/CS team. It is general information, not professional advice - always cross-check against the bare law text above or talk to our tax team for guidance specific to your situation.
What Section 98 says
For the purposes of Sections 96 and 97 (and this section itself), "transfer" includes any settlement, trust, covenant, agreement or arrangement.
A transfer is deemed to be revocable if it contains any provision for the direct or indirect re-transfer of the whole or any part of the income or assets to the transferor, or if it in any way gives the transferor a right to re-assume power, directly or indirectly, over the whole or any part of the income or assets.
Frequently asked questions
Does "transfer" under this section only mean a sale?
No - it is defined broadly to include any settlement, trust, covenant, agreement or arrangement, not just a sale or conveyance.
What makes a transfer "revocable" under Section 98?
A transfer is revocable if it lets the transferor get back, directly or indirectly, the whole or part of the income or assets, or gives the transferor a right to reassume power over the whole or part of the income or assets.
Related sections
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Get clarity on clubbing of income rules from our tax teamLast updated 9 September 2026