Association of individuals taxability turns on ownership or holding of property, not merely common management and profit sharing.

An association of individuals is assessable to agricultural income tax only where it owns or holds the property from which the income arises. Common management of jointly cultivated land, maintenance of common accounts, and division of net profits do not by themselves establish that the lessees held the land as an association within the statutory definition of "person". On the stated facts, the income from the lands could not be assessed as the income of an association of individuals.

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Issues: Whether the income from lands jointly cultivated by two lessees could be assessed as the income of an association of individuals under section 3 read with section 2(11) of the U.P. Agricultural Income-tax Act.

Analysis: The tax could be levied on an association of individuals only if the income accrued to such association as one owning or holding property. The facts found showed only that the lessees appointed a common manager, maintained common accounts, and divided net profits. Those findings did not justify the inference that the lessees, even assuming they formed an association of individuals, held the land as an association in any capacity covered by the statutory definition of "person".

Conclusion: The two lessees could not be assessed as an association of individuals on the agricultural income from the lands.

Ratio Decidendi: An association of individuals is assessable only where it owns or holds the property from which the income arises, and common management with division of profits, without more, does not establish such holding.

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