If the assessee parts with his income producing asset, so that the right to (1) (2) (3) (4) 823 receive income arising from the asset which theretofore belonged to the assessee is transferred to and vested in some other person, there is no avoidance of tax liability: no part of the income from the asset goes into the hands of the assessee in the shape of income or under any guise. ' This decision has been affirmed by this Court in Commissioner of Income tax vs Sakarlal Balabhai.(1) We may also recall the observations of Viscount Simon in Latilla vs I. R. (2) "Of recent years much ingenuity has been expended in certain quarters in attempting to device methods of deposition of income by which those who were prepared to adopt them might enjoy the benefits of residence in this country while receiving the equivalent of such incomes, without sharing in the appropriate burden of British taxation.