https://www.taxtmi.com/caselaws?id=277194 Whether assessees formed an association of persons turned on the totality of joint conduct rather than mere inheritance of divisible shares. The article explains the court's reasoning that prolonged joint management - including leases and receipts in joint names, joint collection and accounting in a common zamindari cash book, appropriation from a common fund contrary to notional shares, and prior returns treating the parties as an association - supported treating them as an association of persons under section 3; contrasting authorities that deny association where only ownership or a common agent exists. It also notes that possession of definite shares or section 9(3) analysis is not conclusive; inference from cumulative facts is decisive. en-us Mon, 03 Aug 1953 00:00:00 +0530 Wed, 28 Nov 2018 15:07:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=277194 Whether assessees formed an association of persons turned on the totality of joint conduct rather than mere inheritance of divisible shares. The article explains the court's reasoning that prolonged joint management - including leases and receipts in joint names, joint collection and accounting in a common zamindari cash book, appropriation from a common fund contrary to notional shares, and prior returns treating the parties as an association - supported treating them as an association of persons under section 3; contrasting authorities that deny association where only ownership or a common agent exists. It also notes that possession of definite shares or section 9(3) analysis is not conclusive; inference from cumulative facts is decisive. Case-Laws Income Tax Mon, 03 Aug 1953 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=277194