Allowing the appeal of the revenue the court held that the AO found on the basis of the materials recovered on search that there were multiple entities but no unity of control, inter-locking and inter-lacing of funds. There was no partnership deed. The assessee had not refuted the findings of the Assessing Officer at any point. The registration as a firm, inclusive of all the entities carrying on business in common, being not established by the assessee, the compelling evidence as recovered under the search and seizure supported the finding that the status of the assessee was one of association of persons.  Accordingly assessment as Association of persons  is justified. (AY. 1995 -96, 1996-97)