https://www.taxtmi.com/caselaws?id=60319 A film distribution arrangement was treated as an Association of Persons because the agreements showed a joint enterprise with shared profits and losses, mutual restrictions on surrender of rights, and common business terms. Even so, the statutory set-off bar invoked by the revenue was held inapplicable on these facts, so the assessee could adjust his share of loss against other income and the enhancement failed. An estimated disallowance from picture expenditure was also rejected because the record showed complete details and no specific defect, inflation, or unvouched item; the disallowance was deleted. en-us Thu, 27 Oct 1994 00:00:00 +0530 Sat, 18 Apr 2026 11:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=60319 A film distribution arrangement was treated as an Association of Persons because the agreements showed a joint enterprise with shared profits and losses, mutual restrictions on surrender of rights, and common business terms. Even so, the statutory set-off bar invoked by the revenue was held inapplicable on these facts, so the assessee could adjust his share of loss against other income and the enhancement failed. An estimated disallowance from picture expenditure was also rejected because the record showed complete details and no specific defect, inflation, or unvouched item; the disallowance was deleted. Case-Laws Income Tax Thu, 27 Oct 1994 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=60319