Assessee-firm is  running a hotel business.  It consisted of two partners who were related to each other (brothers) and belonged to Khasi tribe which was enlisted as Scheduled Tribe in State of Meghalaya and was covered under article 366(25) of Constitution of India.  They were residents of Khasi Hills Autonomous District and thus were entitled to exemption under section 10(26) in their individual capacity. Assessee  firm claimed exemption under section 10(26) on plea that since a partnership firm in itself was not a separate juridical person and it was only a collective or compendious name for all of its partners having no independent existence without them, and since partners of assessee-firm were entitled to exemption under section 10(26), therefore, same exemption under section 10(26) is  available to firm. AO rejected the claim. CIT(A) up held thee order of the AO. On appeal the Tribunal held that  a partnership firm being a separate assessable person under Income-tax Act, would not be entitled to same exemption under section 10(26) as any or all of individual partners would be in their individual capacity. Advantages and disadvantages conferred under Income-tax Act on separate class of persons were neither transferable nor inter changeable and, thus, scope of beneficial provisions could not be extended to a different person under Income-tax Act as it might defeat mechanism and process provided for assessment of different class/category of persons. Ratio decidendi in judgment of Gauhati High Court in CIT v. Mahari & Sons (1993) 67 Taxman 449 ( Gauhati)( HC)   in context of a Khasi family would not be applicable in case of a partnership firm, though consisting solely of partners, who in their individual capacity are entitled to exemption under section 10(26). (AY. 2013-14 to 2015-16)