https://www.taxtmi.com/caselaws?id=177830 Trust income administered by trustees is assessable in the trustee's representative capacity for the beneficiaries, not as income of an association of persons. An association of persons requires voluntary combination and common purpose for earning income, and that consent cannot be inferred merely because trustees carry on business under a trust deed. The distinction between property held for beneficiaries and property held on their behalf also supports the representative assessment model rather than an agency relationship. Section 161(1A) was not read as converting all business income of a trust into AOP income, and the earlier assessment position remained correct, leaving no basis for revision or further reference. en-us Mon, 15 Oct 1990 00:00:00 +0530 Fri, 19 Feb 2016 12:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=177830 Trust income administered by trustees is assessable in the trustee's representative capacity for the beneficiaries, not as income of an association of persons. An association of persons requires voluntary combination and common purpose for earning income, and that consent cannot be inferred merely because trustees carry on business under a trust deed. The distinction between property held for beneficiaries and property held on their behalf also supports the representative assessment model rather than an agency relationship. Section 161(1A) was not read as converting all business income of a trust into AOP income, and the earlier assessment position remained correct, leaving no basis for revision or further reference. Case-Laws Income Tax Mon, 15 Oct 1990 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=177830