Assessee is carrying out business of advertisement, marketing and publicity for franchisees from whom it received money and against said receipts, expenses were made. Assessee also received contributions from various franchisees. Tribunal held that from franchise agreement submitted by assessee that contribution made by holding company was tinged with commercial considerations.  Similarly advertisement made by assessee wherein Pepsi was advertised would also improve sales of Pepsi Foods Ltd., thus, tinged with commercial transactions. Tribunal held that  the assessee is  not a mutual concern and income of assessee was not tainted with mutuality and therefore chargeable to tax as business income. (AY. 2001-02 to 2003-04, 2006-07, 2008-09 to 2010-11 and 2013-14)