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    <title>1954 (12) TMI 39 - ITAT NAGPUR</title>
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    <description>Semi-wholesalers engaged in Government-controlled cloth distribution were not assessable as an unregistered firm or as an association of persons. Partnership was absent because there was no agreement among the participants to carry on business and share profits in a mutual partnership arrangement; the profit share was fixed by Government, and each participant&#039;s return was in substance consideration for supplying working capital. Association of persons was also absent because there was no voluntary combination or common management devised by the semi-wholesalers for a shared business purpose. The reference was answered in the negative, and their status as neither a partnership firm nor an association of persons was upheld.</description>
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    <pubDate>Fri, 17 Dec 1954 00:00:00 +0530</pubDate>
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      <title>1954 (12) TMI 39 - ITAT NAGPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=290137</link>
      <description>Semi-wholesalers engaged in Government-controlled cloth distribution were not assessable as an unregistered firm or as an association of persons. Partnership was absent because there was no agreement among the participants to carry on business and share profits in a mutual partnership arrangement; the profit share was fixed by Government, and each participant&#039;s return was in substance consideration for supplying working capital. Association of persons was also absent because there was no voluntary combination or common management devised by the semi-wholesalers for a shared business purpose. The reference was answered in the negative, and their status as neither a partnership firm nor an association of persons was upheld.</description>
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      <pubDate>Fri, 17 Dec 1954 00:00:00 +0530</pubDate>
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