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    <title>1984 (9) TMI 20 - ALLAHABAD High Court</title>
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    <description>The Tribunal&#039;s finding that co-owners acting through a receiver were not taxable as an association of persons or body of individuals was treated as a finding of fact. Applying the settled test that an association of persons requires a common purpose or common action to earn income, the court held that the record showed no unity or common tie sufficient to constitute such an association. As the issue did not raise a referable question of law under section 256 of the Income-tax Act, 1961, the reference applications were dismissed.</description>
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    <pubDate>Wed, 05 Sep 1984 00:00:00 +0530</pubDate>
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      <title>1984 (9) TMI 20 - ALLAHABAD High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=27134</link>
      <description>The Tribunal&#039;s finding that co-owners acting through a receiver were not taxable as an association of persons or body of individuals was treated as a finding of fact. Applying the settled test that an association of persons requires a common purpose or common action to earn income, the court held that the record showed no unity or common tie sufficient to constitute such an association. As the issue did not raise a referable question of law under section 256 of the Income-tax Act, 1961, the reference applications were dismissed.</description>
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      <pubDate>Wed, 05 Sep 1984 00:00:00 +0530</pubDate>
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