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Issues: Whether the assessees, having inherited property and later retained and managed it together for income, constituted an association of individuals and were rightly assessed as owners of the property under the Income-tax Act.
Analysis: The properties came to the assessees under a will, so their initial receipt was not the result of a voluntary combination. However, once they elected to retain the properties and manage them jointly for the purpose of earning income, their conduct amounted to an association of individuals within the meaning of the Act. On that basis, the income from the properties was assessable in their hands as owners.
Conclusion: The question was answered in the affirmative, against the assessees and in favour of the Revenue.
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