Association of Individuals requires common agreement to exploit property jointly, not mere common management of lands.

Common management of agricultural lands and the use of common agents did not, by themselves, create an association of individuals for agricultural income-tax purposes. The settlement deeds were genuine and acted upon, and the records showed separate accounts and statements for each beneficiary, with income and expenses maintained individually. Because there was no material showing that the beneficiaries had associated together or agreed to exploit the lands jointly for their common benefit, the essential element of an association of individuals was absent. The assessments made on that footing could not stand, and the Tribunal's view was upheld.

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Issues: Whether the beneficiaries under the several settlement deeds could be treated as an association of individuals for agricultural income-tax purposes on the basis of common management of the lands and pooled income.

Analysis: The settlement deeds were found to be genuine and acted upon. Separate account books and statements showed that the income and expenses relating to each beneficiary were kept separately, and the existence of common agents for cultivating the lands of absentee owners did not by itself establish any common enterprise. To constitute an association of individuals, there must be material showing that the persons had associated together and decided upon the common exploitation of the lands for their common benefit. That essential element was absent here.

Conclusion: The beneficiaries did not form an association of individuals, and the assessments made on that footing could not stand.

Final Conclusion: The Tribunal's view was upheld and the revenue revisions failed.

Ratio Decidendi: Common management or common agents for cultivation do not, evidence of a common agreement to exploit property jointly for mutual benefit, constitute an association of individuals.

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