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State Of West Bengal vs Calcutta Club Limited on 3 October, 2019

8. More apposite would be the judgment of the Hon'ble Supreme Court in Calcutta Club Ltd. (supra), wherein the 'doctrine of mutuality' was applied when persons carrying on a certain activity, in a manner, indicating absolute identity between contributors and participators. This identity according to the learned Judges would not be snapped because the surplus that arises from the common fund is not distributed among members. What was emphasized was that, while applying the doctrine there is no sale transaction between an incorporated legal entity in the nature of a club and its own members.
Supreme Court of India Cites 86 - Cited by 99 - R F Nariman - Full Document

Secundrabad Club Etc. vs C.I.T-V Etc. on 17 August, 2023

7. We cannot but notice that Secunderabad Club (supra) was a decision in the context of the Income Tax Act, the principles of which cannot be applied to an indirect tax like sales tax. The specific reference was also to paragraph 93 of the decision, wherein, the Hon'ble Supreme Court found that the 'principles of mutuality' applies only when a number of people who contribute to a fund are ultimately paid the surplus, from the fund, which alone makes it a repayment of the contributor's own money. Therein, the surplus fund was not applied for the common purpose of the club or towards the benefit of the members of the club directly. It was invested with a third party, Patna High Court MA No. 210 of 2008 dt.19-12-2024 6/8 a bank, for the purpose of using it later. The interest generated on the fixed deposits or the investments made hence, becomes a commercial activity, thus permitting the bank to utilize the fixed deposit amount for its banking business and derive profit thereof. Thus, the identicality between the contributors to the common fund and the participation in it, which is a sine qua non for the application of 'principles of mutuality' would get ruptured. At the risk of the repetition, we have to reiterate that this is in the context of levy of income tax.
Supreme Court of India Cites 36 - Cited by 1 - B V Nagarathna - Full Document
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