Held that characterization of consortium as an AOP,  has to be determined in terms of the agreement between parties. Circular No 7/2016 dt. 7-3-2016 (2016) 382 ITR 27 (St.). Accordingly the Tribunal held that Consortium  failed to fulfil the relevant requirement of the circular. Thus  up held the taxability of Consortium as  an  AOP and not as individual members.    (AY. 2011-12)(ITA No. 518 / Del/2022 dt. 22-12-2023)