only the coordinate
bench has upheld that there is no such mutuality concept applicable to the
income received by the assessee. He therefore submitted that ... assesse
claimed that it operates as a mutual concern on a no profit
basis. It was also claimed that the assesse company does not
fall
conditions
must exist before an activity could be brought under the concept of
mutuality;
It is noticed that the fund invested with bank which ... such the AOP body by the society is not covered by concept
of mutuality at all'..."
7.5 The appellant pleaded that the Supreme
conditions must exist
before an activity could be brought under the concept of mutuality:
(i) that no person can earn from him;
(ii) that there ... such the AOP body by the Society is not covered by
concept of mutuality at all."
26. These are the findings of fact which
conditions must
exist before an activity could be brought under the concept of mutuality;
7 I.T.A. No.2338/M/17
that no person ... such the AOP body by the society is not
covered by concept of mutuality at all."
27) These are the findings of fact which
members alone any income
derived from the activities are exempt under mutuality concept
and the deduction u/s 80P is not required for such income
conditions must exist before an activity could
be brought under the concept of mutuality;
that no person can earn from him;
that there a profit ... such the AOP body by the
society is not covered by concept of mutuality at all."
27) These are the findings of fact which
taxing the oilier
income from ton-members on the basis of mutuality concept
the Revenue has filed SLPs in the case of Otters Club,
Goregaon ... tile Income Tax Act,
1961 and not covered by the principle Of mutuality though
the assessee trust was violating Provisions of Section
conditions must
exist before an activity could be brought under the concept of mutuality;
ITA No.2703/Chny/2018
:- 8 -:
that no person can earn ... such the AOP body by
the society is not covered by concept of mutuality at all."
27) These are the findings of fact which
taxability of any amount
received as transfer fees on the concept of Mutuality and has set to
rest the controversy regarding its payment ... held that transfer fees received from members is exempt on the
concept of mutuality.
8.1 Further in the case of Sind
income tax, based on the doctrine of mutuality. After appreciating the
general understanding of the doctrine of mutuality in the context of the
provision ... turn
result in earning interest cannot be held to satisfy the mutuality
concept.
Submissions:
6. In the above backdrop of decisions of this Court
