Association set up for non-commercial objective. Members make contributions to meet operating and management expenses, proportionate to their revenues. Subscription fee, Technical subscription fee and other recoveries from its member firms located in India. Principle of mutuality is applicable. Payments were reimbursement and exempt from taxation and covered by principle of mutuality. (AY.2008-09 to 2011-12)
Dy. CIT (IT) v. Deloitte Touche Tohmastu (2023)108 ITR 577 (Delhi) (Trib)
S. 4 : Charge of income-tax-Principle of mutuality — Payments were reimbursement and exempt from taxation and covered by principle of mutuality.