22. In Commissioner of Income Tax, Madras v. Kumbakonam Mutual Benefit Fund Ltd.12

Genpact India Private Limited vs. Deputy Commissioner of Income Tax

Bench: HON'BLE THE CHIEF JUSTICE

…SRTC v. Krishna Kant15, Kerala SEB v. Kurien E. Kalathil16, A. 3 AIR 1958 SC 86 4 (1983) 2 SCC 433 : 1983 SCC (Tax) 131 5 (2003) 2 SCC 107 6 (2005) 6 SCC 499 7 AIR 1954 SC 207 8 AIR 1955 SC 425 9 AIR 1957 SC 882 10AIR 1966 SC 1089 11 AIR 1959 SC 422 12 AIR 1965 SC 1321 : (1965) 2 SCR 653 13 (1984) 2 SCC 436 : 1984 SCC (Tax) 133 14 (1988) 1 SCC 572 15 (1995) 5 SCC 75 : 1995 SCC (L&S) 1207 : (1955) 31 ATC 110 16 (2000) 6 SCC 293 Civil Appeal No. 8945 of 2019 @ SLP(C) No.20728 of 2019 Genpact India Private Limited v. Deputy Commissioner of Income Tax & Anr. 25 Venkatasubbiah Naidu v. S. Chellappan17…

M/S. Bangalore Club vs. Commissioner of Income Tax

…s I understand it, is the effect of the decision in the New York case." (Emphasis supplied) 22. In Commissioner of Income Tax, Madras Vs. Kumbakonam Mutual Benefit Fund Ltd.12, this Court 12 AIR 1965 SC 96 23 Page 24 JUDGMENT differentiated the facts of the case before it from those of Styles case (supra) and denied the exemption of mutuality because of the taint of commerciality. It was observed thus: “It seems to us that it is difficult to hold that Style's case applies to the facts of the case. A shareholder in the assessee com…

M/S. Bangalore Club vs. Commissioner of Income Tax

…s I understand it, is the effect of the decision in the New York case." (Emphasis supplied) 22. In Commissioner of Income Tax, Madras Vs. Kumbakonam Mutual Benefit Fund Ltd.12, this Court 12 AIR 1965 SC 96 23 Page 24 JUDGMENT differentiated the facts of the case before it from those of Styles case (supra) and denied the exemption of mutuality because of the taint of commerciality. It was observed thus: “It seems to us that it is difficult to hold that Style's case applies to the facts of the case. A shareholder in the assessee com…