Dr. A. S. ANAND, C.J.

This tax revision case is directed against the order of the Tamil Nadu Agrl. ITAT, dt. 3rd March, 1981, passed in ATA No. 258 of 1980.

2. The petitioners were assessed on a net agricultural income of Rs. 12, 010 for the asst. yr. 1978-79 in the status of an association of individuals. Before the Assistant Commissioner, the petitioner disputed the status of association of individuals as also the estimated income. The plea of the petitioners was that since the sale deed had been taken jointly in the name of ten persons, there was a presumption in law that where there is no indication in the sale deed that the buyers would take unequally, then, they shall take equally and they could not be assessed as association of individuals. It was argued before the appellate authority that the mere fact that the land had been purchased jointly and cultivated through one of them would not render them liable to be assessed in the status of association of individuals. The plea, however, did not find favour with the Assistant Commissioner. A further appeal before the Tamil Nadu Agrl. ITAT also failed. Before the Tribunal, no arguments, however, were advanced during the