Joint lottery ticket purchases can form an association of persons, making winnings assessable as income.

Lottery winnings from tickets jointly purchased by a group were treated as income assessable in the status of an association of persons because the contributors acted through a common venture with the object of earning income. The governing test for an association of persons was satisfied on these facts, and the principle had already been applied in similar cases. The question was answered in favour of the Revenue and against the assessee, so the winnings were assessable accordingly.

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Issues: Whether the lottery winnings of a group of persons who jointly purchased tickets were assessable to income-tax in the status of an association of persons or body of individuals.

Analysis: The persons had jointly contributed towards the purchase of lottery tickets, and the winning ticket arose from that common venture. The governing test for assessment as an association of persons was satisfied because there was a joint venture and the object of the venture was to earn income. The question was covered by the principle earlier applied to similar facts.

Conclusion: The winnings were assessable in the status of an association of persons, and the question was answered in favour of the Revenue and against the assessee.

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