Tax implications to be considered while converting NRE account

Hello, Husband and wife both have been working abroad but only Husband had NRE Accounts. Wife Income also transferred to Husband's NRE Account. 1. Now upon return to India (after 8-9 years, for good) and when Husband converts NRE Account to Domestic Account and opens separate Domestic Account for wife and transfers money to her account, will Clubbing be applicable for Tax purpose or won't be applicable and Tax burden can be shared this way ? 2. Any other Tax-efficient advise ? Thanks in advance