https://www.taxtmi.com/caselaws?id=37685 An association of persons arises only where persons voluntarily combine for a common enterprise to earn income; mere joint purchase, joint ownership, or receipt of sale proceeds is insufficient. On the facts stated, separate funding, distinct shares, and absence of any agreement, common management, or joint enterprise meant the five ladies were not an association of persons, and assessment on that basis was unjustified. A reassessment notice must clearly identify the assessee and the capacity in which it is issued; a vague notice that does not show whether it is against the association or the individuals is jurisdictionally defective. The notice and the assessment made under it were therefore invalid. en-us Wed, 18 Jun 1975 00:00:00 +0530 Tue, 27 Jan 2026 15:48:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=37685 An association of persons arises only where persons voluntarily combine for a common enterprise to earn income; mere joint purchase, joint ownership, or receipt of sale proceeds is insufficient. On the facts stated, separate funding, distinct shares, and absence of any agreement, common management, or joint enterprise meant the five ladies were not an association of persons, and assessment on that basis was unjustified. A reassessment notice must clearly identify the assessee and the capacity in which it is issued; a vague notice that does not show whether it is against the association or the individuals is jurisdictionally defective. The notice and the assessment made under it were therefore invalid. Case-Laws Income Tax Wed, 18 Jun 1975 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=37685