Held  that the facts were that the booking was done in the name of the member clearly mentioning the fact of the usage of facility by an outsider or non-member, the liability for payment for the usage of the facility was raised in the account of the member, and the facility was utilised by non-members or guests, and payment also was made by the guests or non-members. The fact that the non-members paid for the usage of these facilities was a clear pointer to the fact that the facility was given to the non-members not on behalf of the members as their guests but for the benefit of the non-members alone. Clearly the member was only a name lender, a conduit. His role ended with the lending of his name, the facility was thereafter utilised by non-member on making payment. The mere fact that the club held the member liable for making the payment, did not take away the fact that in every such letting out to non-members, the payment invariably was made by the non-members. There was no doubt, therefore, that the letting out of these facilities to non-members was not for the contributors in the common fund of the assessee club. In other years, before the Tribunal, it was noted that the facilities had been extended to the non-members on the behest of the members as his guests and the fact that the payment was being made by non-members was not brought to the knowledge of the Tribunal ; and, therefore, it proceeded with the belief that the extension of the facility to non-members was for and on behalf of the members itself. Since the facility was not being given to the non-members for and on behalf of the member, but was being exclusively given to the non-members alone, the usage of the air-conditioned hall and lawns facility by non-members in the facts of the present case was not covered by the principle of mutuality. (AY.2008-09, 2012-13, 2013-14, 2015-16)