Though several contentions have been raised before the High Court and the Appellate Tribunal, Mr. K. C. Puri, learned counsel for the appellant, has raised before us only two contentions, namely, (1) the assets of pound 1,80,000 covered by the trust deed not having been transferred to the wife or minor daughter in question, but to the Grindlays Bank, as trustee, section 16(3) (b) of the Act has no application; and (2) even if section 16(3) (b) of the Act applies, what is to be included in computing the total income of the assessee is not the income that has been received by the minor 9 daughter under the trust deed, but only so much of the income of any person or association of persons (in this case the trustee) to whom the assets have been transferred for the benefit of the wife or the minor child.