Association of individuals for agricultural income-tax requires conscious common venture; mere family land management cannot justify clubbing holdings.

Liability to agricultural income-tax as an association of individuals arises only where family members have consciously associated in a common venture to exploit the lands for their mutual benefit, supported by authority to act as a unit. Mere common management or convenience-based administration is insufficient. On the facts, a prior partition, separate allotments, separate later acquisitions, and individual assessment of one son negatived a taxable association, so clubbing the lands standing in the names of the wife and sons with the petitioner's holdings was unsustainable and was set aside.

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Issues: Whether the petitioner and other family members could be treated as an association of individuals for agricultural income-tax purposes and the lands standing in the names of the wife and sons could be clubbed with the petitioner's holdings.

Analysis: Liability as an association of individuals arises only where the persons have associated together and decided upon the common exploitation of the lands for their common benefit. Mere common management, or the fact that one person manages the lands for convenience, is not enough. An element of investiture or express authority to manage the affairs of the association is essential. On the facts, there had been a prior partition, separate extents had been allotted, further acquisitions were also separate, and one son had already been assessed individually. These circumstances negatived the existence of a taxable association of individuals.

Conclusion: The revised assessment clubbing the properties and treating the petitioner as an association of individuals was unsustainable and was set aside in favour of the assessee.

Ratio Decidendi: For agricultural income-tax, family properties cannot be assessed as an association of individuals unless there is a conscious common venture for mutual benefit supported by authority to act as a unit; mere common management or convenience-based administration does not suffice.

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