S. 4 : Charge of income-tax – Mutuality – Contributions both from members and non-members and one member was vested with powers to control functioning and interests of other members, such an assimilation could not be termed as a social intercourse devoid of commerciality- Assessee, being not a mutual concern, could not be entitled to tax exemption- Exemptions are to be put to strict interpretation- Principle of mutuality is held to be not applicable -Order of AO is affirmed .[ S .2 (24 ) ]
Yum! Restaurants (Marketing ) Pvt Ltd v CIT ( 2020) 424 ITR 630 / 189 DTR 1/ 313 CTR 37 / 271 Taxman 217 / 116 taxmann.com 374 (SC ) www.itatonline .org 116 taxmann.com 374 (SC ) www.itatonline .org