Section 105: If–

(a) a partnership or other unincorporated association or body is dissolved or otherwise ceases to exist because of the retirement or withdrawal of one or more, but not all, of its partners or members or because of the admission of a new partner or member; (b) apart from this Act a new partnership, association or body, consisting of the remaining members or of the existing or remaining members and one or more new members, thereby comes into existence; and (c) the new partnership, association or body continues to carry on the taxable activity that was carried on by the dissolved partnership, association or body, 108 109 Directors of companies. Officers of unicorporated bodies. Continuity of partnerships or unincorporated associations. the dissolved partnership, association or body and the new partnership, association or body are, for the purposes of this Act, deemed to be one and the same, unless the Commissioner-General, having regard to the circumstances of the case, otherwise directs.