The assessee was a recreational club. In each of the assessment years 2008-2009 to 2012-2013, the assessee received on account of rent sums of money from a company for occupation of a portion of the club premises. The Assessing Officer held that the amounts were taxable but the Commissioner (Appeals) reversed the order. However, the Tribunal affirmed the order of the Assessing Officer. On appeal to the High Court: Held, that in the orders of the Assessing Officer, Commissioner (Appeals) and the Tribunal there was no analysis of the facts, which would go to show whether the principle of mutuality was being maintained in the subject transaction between the club and the company. Only conclusions were made with regard to the status and the transaction between the parties. Matter remanded.