https://www.taxtmi.com/caselaws?id=199763 Co-heirs may be assessed as an association of persons when they voluntarily combine and cooperate in carrying on a business with a common income-earning purpose; mere inheritance of defined shares is not enough. Residence under section 4A(b) of the Income-tax Act, 1922 depends on the real seat of control and management, not formal title alone. On the stated facts, the Penang business was treated as carried on by the Indian heirs as an association of persons. For 1945 and 1946 the business was in exclusive management at Penang, so the association was non-resident; for 1947 and 1948, the material supported residence and ordinary residence in the taxable territories. en-us Fri, 02 Mar 1962 00:00:00 +0530 Mon, 12 Mar 2018 13:20:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=199763 Co-heirs may be assessed as an association of persons when they voluntarily combine and cooperate in carrying on a business with a common income-earning purpose; mere inheritance of defined shares is not enough. Residence under section 4A(b) of the Income-tax Act, 1922 depends on the real seat of control and management, not formal title alone. On the stated facts, the Penang business was treated as carried on by the Indian heirs as an association of persons. For 1945 and 1946 the business was in exclusive management at Penang, so the association was non-resident; for 1947 and 1948, the material supported residence and ordinary residence in the taxable territories. Case-Laws Income Tax Fri, 02 Mar 1962 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=199763