The explanatory note in paragraph 31 of paragraph 2 of the Act, effective April 1, 2002, provides that an association of persons is considered a person, whether or not it is formed for the purpose of being derived from income. In other words, it is not absolutely necessary for a PDO to necessarily generate revenue. You can see that a PDO is formed and not created. A PDO can either register or not remain registered. The association of people usually means that two or a few people come together and form an association in which the goal is to achieve the same goal. It should be noted that the word « person » encompasses each person, be it a HUF, individuals, etc. The term association of people is not a notion of art (empty GMurugesanand Bros vCIT  88 ITR 432 (SC). It must be understood in its ordinary sense. The Supreme Court referred to Costello J.`s appropriate submissions in his separate but simultaneous opinion to BN Elias. In re (3 ITR 408). The Supreme Court noted that Costello J tested it in more forceful language.
The Court found that, although these four persons are not a partnership, it is, in many ways, similar to a partnership and close to a partnership, and that Parliament intends to make combinations of people who work together in a joint venture but do not legally constitute partnerships. The following passage of the decision of the Supreme Court of Shanmugham and Co v CIT (81 ITR 310) is also appropriate: 1 CONVENTION OF THE PERSONS ASSOCIATION This written statement of the association of persons is made to NAME until 26 January 2012 in CITY 1. Person -1 Address 2 person -2 Address 3 person -3 Address 4 Pesson -4 Address While on January 26, 2019, on behalf of BJS (Given name) City was founded during a meeting at CITY NAME with the recommendation of sponsorship by an association of people. While it was considered appropriate, for various reasons or for other reasons, to write orally the objectives/objects of the association and how the PDO should be managed and managed, and decided to write orally on January 18, 2019, writing in writing on January 26, when all PDO members authorized the President, 1 at the January 26, 2019 meeting in CITY. Person`s name to design and execute an appropriate agreement and have authorized it with the members of the top chapter mentioned in this document.