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. Andhra Pradesh High Court established the principles of a PDO in one of its cases. It is made clear that an association of people does not necessarily mean any combination of people and people. It only applies when participants align themselves with an income-creating activity. People must come together to carry out such an activity and the commitment must be done under the common voluntary will of the people who make up the association. Therefore, there are obvious differences between the union of people and a body of individuals. Therefore, the only difference between the PDO and BOI is the composition of its members. AOP/BOI can be constituted by simple entry into an act that aims, the names of the members, the members` share, the date of constitution, statutes, statutes, the frequency of meetings of members or executives, management powers, the amount of capital set up by the members, if any, the deed can be registered with the Registrar of the Company by paying the fees. The AAR also stated that the joint venture agreement had been preceded by a recital in which „the three parties agreed to cooperate on all work related to advisory services.“ Thus, the applicant, who received most of the consideration/revenue from the contract, led the joint venture and coordinated with all parties involved a successful execution of the contract within the allotted time. The formation of the PDO with a common purpose and unique management was therefore obvious. Thus, the essential characteristics and provisions of the two agreements, in conjunction with the context in which the joint venture was formed, indicated the existence of a PDO, as understood in the law and in the usual language. The contract was concluded between the partners of the joint venture and the customer, so that all the revenues of the joint venture would be taxed as income from the joint venture (AOP) and not as income between the different hands of the partners of the joint venture.