Under section 3(42) of the General Clauses Act, person includes any company

or association or body of individuals, whether incorporated or not.

An association of persons (AOP) may have as its members, companies, firms, joint
families and associations (MMIpoh vCIT (67 ITR 106)).

Evidently, the companies entering into a joint venture can also be an assessable unit as
an AOP, as held in Ganga Metal Refining CoPte Ltd vCIT (67 ITR 771).

Analysing its plain ordinary meaning, the Supreme Court observed in the case of CIT
vIndiraBalkrishna (39 ITR 546) that the word 'associate' means according to the
'Oxford Dictionary', to join in common purpose, or to join in an action'. Therefore, an
'association of persons', must be one in which two or more persons join in a common
purpose or common action, and as the words occur in a section, which imposes a tax on
income, the association must be one the object of which is to produce income, profits or
gains.
Person [Section 2(31)] : Definition under I.Tax
Person includes :

1. an Individual;
2. a Hindu Undivided Family (HUF) ;

3. a Company;

4. a Firm

5. an association of persons or a body of individuals, whether incorporated or not;

6. a local authority; and

7. Every artificial juridical person not falling within any of the preceding sub-clauses.

8. Association of Persons or Body of Individuals or a Local authority or Artificial

Juridical Persons shall be deemed to be a person whether or not, such persons
are formed or established or incorporated with the object of deriving profits or
gains or income.
The Andhra Pradesh High Court, after considering previous decisions has, in the case
of Deccan Wine and General Stores vCIT (106 ITR 111), laid down the principles
governing an AOP by stating that it is clear that an association of persons does not mean
any and every combination of persons; it is only when they associate themselves in
income-producing activity that they become an association of persons.