Held that the nature of activity and objects of the assessee-society were the same as had been considered in earlier years. For the assessment year 2012-13, the Tribunal had held that the income of the assessee-society was entitled to exemption under section 11. The Tribunal order was challenged by the Revenue before the High Court which had dismissed the appeal holding that the assessee-society was entitled to claim relief under sections 11, 12 and 13. Once the activities of the assessee-society were charitable, the principle of mutuality became superfluous. Relied on CIT(E) v. India Habitat Centre ((2020) 424 ITR 325 (Delhi)(HC) (AY. 2014-15).
ACIT(E) v. India Habitat Centre (2021) 86 ITR 290 (Delhi)(Trib.)
S. 11 : Property held for charitable purposes-No changes in the nature of activities-Principle of consistency should be followed-Mutuality-Once the activities of the assessee-society were charitable, the principle of mutuality became superfluous. [S. 2(15) 12, 12A, 13]