closely linked', if they emanate
from a common source, being an order or contract or an agreement or
an arrangement, and the nature, characteristic ... terms of such
transactions substantially flow from the said common source. The
following extract from the said Guidance Notes is worthy of notice
accepted
by Shivaji Chumble. Moreover, there appears to be a common
source of fund. Thus, according to the AO the assessee is solely
and completely ... where the AO has observed that there appears to be a
common source of funds and that the assessee himself has
admitted that this business
closely linked', if they emanate from a common source, being
an order or contract or an agreement or an arrangement, and the
nature, characteristic ... terms of such transactions
substantially flow from the said common source. The following
extract from the said Guidance Notes is worthy of notice
expansion of business and not for starting a new business;
iv) that common Bond register for the purposes of custom duty has
been maintained ... assets of Unit A;
vii) that the new Unit has a common source of power as there is a
common electricity meter;
viii) that Unit
constitute an AOP persons must have joint for a common purpose or common action. The object of the association must be to produce income ... merely because all of them receive income from a common source. In the present case the only facts on record are that settlor created
taken in earlier years too from MGG. Agricultural
income is the common source of income for the M/s.Mahaveer Green Gold to
give
Kumar Housing Corporation Ltd.,, Pune vs Assistant Commissioner Of ... on 10 March, 2017
आयकर अपील
alleged nexus with the common income does not have the common bond required for AOP. Unlike N.V. Shanmugham & Co. 's case (supra ... beneficiaries should be linked together by a common nexus with the source of income. In our opinion, this test is not satisfied in this case
G.C. Bafna vs Deputy Commissioner Of Income Tax on 25 February, 2003
Equivalent citations
noted that the
companies selected were in group trading activity where the source of such
vehicles was from India only, whereas in the case ... sale of spares as the source of products
and intermediary i.e. dealers of assessee, remained common; the functions
performed, risk assumed were also identical
