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    <title>1977 (12) TMI 3 - DELHI High Court</title>
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    <description>Registration as a firm was refused where the alleged partnership was found not genuine on the facts; discrepancies between the partnership deed and the bank record, lack of partner familiarity with the business, and the withdrawal pattern supported that finding. The genuineness finding was treated as factual and no fresh material justified a different view for later years. The concern could also be assessed as an association of persons under the Income-tax Act, 1961, because that Act taxes each person as a separate taxable unit; separate assessment of members did not bar assessment of the group, and any double-taxation relief had to be pursued through rectification provisions.</description>
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    <pubDate>Fri, 09 Dec 1977 00:00:00 +0530</pubDate>
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      <title>1977 (12) TMI 3 - DELHI High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=37176</link>
      <description>Registration as a firm was refused where the alleged partnership was found not genuine on the facts; discrepancies between the partnership deed and the bank record, lack of partner familiarity with the business, and the withdrawal pattern supported that finding. The genuineness finding was treated as factual and no fresh material justified a different view for later years. The concern could also be assessed as an association of persons under the Income-tax Act, 1961, because that Act taxes each person as a separate taxable unit; separate assessment of members did not bar assessment of the group, and any double-taxation relief had to be pursued through rectification provisions.</description>
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      <pubDate>Fri, 09 Dec 1977 00:00:00 +0530</pubDate>
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