Association of persons Income Tax Act, 1922,Section 3 As to what constitutes an association of persons was laid down by the Supreme Court in Commr. of Income-tax, Bombay North v. Indira Balkrishna, AIR 1960 SC 1172 and the Mohammad Noorulla v. Commissioner of Income-tax, ,AIR 1961 SC 1043, where the business was carried on as one unit and by the consent of all the parties who were heirs of deceased Mohammad Omer Sahib and during the period when an administration suit between them was being fought in Courts of law. In the present case the Tribunal has found that the import and distribution by the respondent was done on a joint basis. The purchases were joint, so were the sales and the profits were ascertained on a joint basis and then distributed according to the capital contributed by each member of the group. This finding which is one of fact makes the respondent an "association of persons" and it makes no difference that the business was carried on because the Deputy Commissioner of the district had appointed the members constituting the group to import and distribute the cloth in the district. (I.T. Commr. v. Buldana D.M.C.I. Group, AIR 1961 SC 1261 (1262,1263)