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3. The appellant craves leave to add, alter, amend and/or withdraw any ground or grounds of appeal either before or during the course of hearing of the appeal."

3. The brief facts of the case are that the assessee, Rajpath Club Ltd. is a Club and primarily involved in various activities which are covered under the concept of mutuality.For A.Y. 2015-16, the assessee filed it's return of income declaring total income of Rs. 5,89,15,000/-.

4. During the course of assessment proceedings the Assessing Officer observed that assessee has received income from lawn and marriage hall bookings amounting to Rs. 2,25,65,490/- and the Assessing Officer asked the assessee to provide the break-up of the same. On analysis of the details provided by the assessee, the Assessing Officer observed that out of the above receipts, a sum of Rs. 60,38,990/- pertains to the use of above facilities by the guests of the members (and not by the members themselves) and therefore, the assessee was asked to explain as to why the above income should not be taxed in the hands of assessee as the same is not governed by the concept of mutuality. Accordingly, the Assessing Officer held that such receipts from Lawn ITA Nos. 111&112/Ahd/2021 Rajpath Club Ltd. vs.PCIT Asst. Years -2015-16 & 2016-17 booking and Hall booking facilities by non-members are not covered under the concept of mutuality and therefore, the same cannot be treated as exempt for purposes of taxation. Accordingly, Ld. Assessing Officer made addition of Rs. 60,38,990/- to the income of the assessee.