CIT v. Bankipur Club Ltd.

226 ITR 97Supreme Court of India1997#831 most cited

What is CIT v. Bankipur Club Ltd. authority for?

The doctrine of mutuality applies only when there is complete identity between the contributors to a common fund and the participants in its surplus. Income received from non-members or distinct classes of members who do not share this identity is not covered by mutuality and is taxable.

125

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2000 to 2026.

Also referred to as

CIT v. Bankipur Club Ltd. · 226 ITR 97 · doctrine of mutuality · mutuality principle · identity of contributors participants · associate members · non-members income · Section 80P · co-operative society tax · clubs taxation · surplus distribution

Also reported as

92 Taxmann 278

Sections most often in play

Section 143(3)Section 142(1)Section 80PSection 80P(2)(a)(i)Section 80P(2)(d)Section 143(2)Section 1961Section 57 of the Income Tax Act
Read the full judgment

Issues it is cited on

doctrine of mutualitysection 59(2)mutuality principlesection 2(n)section 80(p)section 10(20)section 38section 80(p)(2)section 59section 80(p)(2)(d)section 80p(2)(a)section 57

Judgments citing CIT v. Bankipur Club Ltd.

Cricket Club of India P.Ltd, Mumbai vs. CIT 1, Mumbai

In the result, the appeal of the assessee is allowed

ITA 3282/MUM/2015[2010-11]Status: DisposedITAT Mumbai15 Jul 2022AY 2010-11

Bench: Us:-

Section 143(3)Section 263Section 263(1)

…or an International Cricket Match and IPL Match. This is evident from para 6.3. of the order of ld. PCIT. 4.1. We find that the ld. AR before us submitted that the assessee was a party before the Hon'ble Supreme Court in CIT vs. Bankipur Club Ltd reported in 226 ITR 97 (SC). The facts of the assessee's case relating to the Asst Years 1977-78 and 1978-79 are discussed at pages 106 and 107 of the judgement. The Hon'ble Supreme Court upheld the findings of the Tribunal and the Hon'ble High Court that the assessee is a mutual association and that the income from property let out to members is exempt from tax on the…

M/S Madras Race Club, Chennai vs. DCIT Corpo Circle 4 (1), Chennai

In the result, the appeals filed by the assessee in ITA Nos

ITA 503/CHNY/2018[2014-15]Status: DisposedITAT Chennai13 Jul 2022AY 2014-15

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri G. Baskar & Shri I. DineshFor Respondent: Shri AR.V. Sreenivasan, Addl.CIT
Section 143(3)Section 194C

…ected from these non-voting right members. We noted that the Hon’ble Supreme Court in the Bankipur Club Ltd., supra held that “5. A similar issue came up for consideration before the Supreme Court in CIT vs. Bankipur Club Ltd. (1997) 140 CTR (SC) 102 : (1997) 226 ITR 97 (SC). The issue referred by the High Court therein was whether the profits arising from sales made to regular members of the club are entitled to exemption on the doctrine of mutuality. There also there were various kinds of members like permanent, temporary as also honorary members. The temporary and honorary members enjoyed all the privileges of…

M/S Madras Race Club, Chennai vs. DCIT Corpo Circle 4 (1), Chennai

In the result, the appeals filed by the assessee in ITA Nos

ITA 502/CHNY/2018[2013-14]Status: DisposedITAT Chennai13 Jul 2022AY 2013-14

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri G. Baskar & Shri I. DineshFor Respondent: Shri AR.V. Sreenivasan, Addl.CIT
Section 143(3)Section 194C

…ected from these non-voting right members. We noted that the Hon’ble Supreme Court in the Bankipur Club Ltd., supra held that “5. A similar issue came up for consideration before the Supreme Court in CIT vs. Bankipur Club Ltd. (1997) 140 CTR (SC) 102 : (1997) 226 ITR 97 (SC). The issue referred by the High Court therein was whether the profits arising from sales made to regular members of the club are entitled to exemption on the doctrine of mutuality. There also there were various kinds of members like permanent, temporary as also honorary members. The temporary and honorary members enjoyed all the privileges of…

M/S Madras Race Club, Chennai vs. DCIT Corpo Circle 4 (1), Chennai

In the result, the appeals filed by the assessee in ITA Nos

ITA 501/CHNY/2018[2012-13]Status: DisposedITAT Chennai13 Jul 2022AY 2012-13

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri G. Baskar & Shri I. DineshFor Respondent: Shri AR.V. Sreenivasan, Addl.CIT
Section 143(3)Section 194C

…ected from these non-voting right members. We noted that the Hon’ble Supreme Court in the Bankipur Club Ltd., supra held that “5. A similar issue came up for consideration before the Supreme Court in CIT vs. Bankipur Club Ltd. (1997) 140 CTR (SC) 102 : (1997) 226 ITR 97 (SC). The issue referred by the High Court therein was whether the profits arising from sales made to regular members of the club are entitled to exemption on the doctrine of mutuality. There also there were various kinds of members like permanent, temporary as also honorary members. The temporary and honorary members enjoyed all the privileges of…

M/S Federation of Freight Forwarders Associations in India, Mumbai vs. ITO 1(3), Mumbai

In the result, ground no.1 of the assessee is allowed and additions amounting to Rs

ITA 710/MUM/2020[2014-15]Status: DisposedITAT Mumbai07 Jul 2022AY 2014-15

Bench: Shri Pavan Kumar Gadale & Shri Gagan Goyalm/S Federation Of Freight Forwarders Associations, 311/313, Mahinder Chambers, W.T. Patil Marg, Opp. Dukes Factory, Chembur, Mumbai-400071 Pan: Aaatf0039J ...... Appellant Vs. Ito (Exemption)-1(3), Piramal Chambers 4Th Floor, Dr. S.S. Road, Parel, Mumbai-400012. ..... Respondent Appellant By : Sh. Nitesh Joshi Respondent By : Sh. Indira Adakil, Cit-Dr Date Of Hearing : 13/04/2022 Date Of Pronouncement : 07/07/2022 Order Per Gagan Goyal, A.M:

For Appellant: Sh. Nitesh JoshiFor Respondent: Sh. Indira Adakil, CIT-DR
Section 11Section 11(5)Section 12ASection 142(1)Section 2Section 2(15)

…g Exemption u/s. 11 & 12 of the Income Tax Act, 1961. In this case, it has been held by the Hon'ble 5 ITA No. 710/Mum/2020- M/s Federation of Freight Forwarders Associations Supreme Court that it is mutual organization (refer the case of Bankipur Club Ltd. 226 ITR 97 wherein the CCI Club was also a party). The object to promote, manage, or assist in the promotion or management for the development of trade and commerce for its members clearly show that the dominant object of the assessee is to provide amenities and facilities to the members of the assessee Trust only. It is, therefore, held that the assessee is…

Happy Home Co-Operative Housing Society Ltd., Mumbai vs. ITO 25 (2)(4), Mumbai

In the result, appeals of the assessee are allowed

ITA 5250/MUM/2018[2011-12]Status: DisposedITAT Mumbai07 Jul 2022AY 2011-12

Bench: Shri Pavan Kumar Gadale & Shri Gagan Goyal

For Appellant: Sh. Piyush ChaturvediFor Respondent: Sh. Indira Adakil, CIT-DR
Section 143(2)Section 143(3)Section 148

…rs and the participants in this sense. Any surplus in the common fund shall therefore not constitute income but will only be an increase in the common fund meant to meet sudden eventualities and liabilities. 18. In CIT, Bihar Vs. M/s Bankipur Club Ltd. (1997) 226 ITR 97 (SC), considering the surplus of receipts over expenditure generated from the facilities extended by a club to its members and its exemption from tax on principles of mutuality, it was observed : (A.Y. 2011-12, 2012-13 & 2014-15) "20........In all these cases, the appellate tribunal as also the High Court have found that the amounts received by th…

M/S Savitri Phule Mahila Bahu Kuddeshiya Sahakari Samiti Ltd., Bharatpur vs. Assistant Commissioner of Income Tax, Circle, Bharatpur

In the result, the appeal filed by the assessee is allowed

ITA 347/JPR/2019[2012-13]Status: DisposedITAT Jaipur30 Jun 2022AY 2012-13
For Appellant: Shri B.P. Mundra, CAFor Respondent: Shri A.S. Nehra, Addl. CIT
Section 143(2)Section 143(3)Section 4

…ant contends that its business admittedly does not come under that clause, hence, any income earned by the appellant is not exigible to income-tax. The appellant relies on a decision of this Court in CIT vs. Bankipur Club Ltd. (1997) 140 CTR (SC) 102 : (1997) 226 ITR 97 (SC) : TC S38.3434 and Chelmsford Club Vs. CIT, 243 ITR P.89 (SC). It is further contended by the appellant that what is taxed under s. 22 of 5 M/S. SAVITRI PHULE MAHILE BAHU UDDESHIYA SAHKARI SAMITI LTD VS ACIT,CIRCLE-BHARATPUR the Act is in reality an income, though in a deemed form and, therefore, this income is also outside the scope of income…

The Fateh Maidan Club(AOP), Hyderabad vs. DCIT, Circle -5 (1), Hyderabad

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 99/HYD/2022[2014-15]Status: DisposedITAT Hyderabad30 Jun 2022AY 2014-15

Bench: Shri R. K. Panda

For Appellant: Sri S. Rama Rao, AdvocateFor Respondent: Sri Waseem Ur Rehman,DR
Section 142(1)Section 144Section 147Section 148

…ctivity and hence is not taxable on the principles of mutuality is concerned, he submitted that the Hon'ble Supreme Court in the case of Bangalore Club (Supra) after considering the facts and the ratio laid down in the case of CIT vs. Bankipur Club Ltd (1997) 5 SCC 394 (Para 20) and Natarajan Finance Corporation has decided the issue in favour of the Revenue. Therefore, the decision of the Tribunal no longer holds good in view of the decision of the Hon'ble Supreme Court. He also relied on various other decisions. 14. So far as the taxability of the income at maximum marginal rate is concerned, he submitted that…

DCIT, Circle -5 (1), Hyderabad vs. The Fateh Maidan Club, Hyderabad

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 98/HYD/2022[2012-13]Status: DisposedITAT Hyderabad30 Jun 2022AY 2012-13

Bench: Shri R. K. Panda

For Appellant: Sri S. Rama Rao, AdvocateFor Respondent: Sri Waseem Ur Rehman,DR
Section 142(1)Section 144Section 147Section 148

…ctivity and hence is not taxable on the principles of mutuality is concerned, he submitted that the Hon'ble Supreme Court in the case of Bangalore Club (Supra) after considering the facts and the ratio laid down in the case of CIT vs. Bankipur Club Ltd (1997) 5 SCC 394 (Para 20) and Natarajan Finance Corporation has decided the issue in favour of the Revenue. Therefore, the decision of the Tribunal no longer holds good in view of the decision of the Hon'ble Supreme Court. He also relied on various other decisions. 14. So far as the taxability of the income at maximum marginal rate is concerned, he submitted that…

The Fateh Maidan Club(AOP), Hyderabad vs. DCIT, Circle -5 (1), Hyderabad

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 101/HYD/2022[2016-17]Status: DisposedITAT Hyderabad30 Jun 2022AY 2016-17

Bench: Shri R. K. Panda

For Appellant: Sri S. Rama Rao, AdvocateFor Respondent: Sri Waseem Ur Rehman,DR
Section 142(1)Section 144Section 147Section 148

…ctivity and hence is not taxable on the principles of mutuality is concerned, he submitted that the Hon'ble Supreme Court in the case of Bangalore Club (Supra) after considering the facts and the ratio laid down in the case of CIT vs. Bankipur Club Ltd (1997) 5 SCC 394 (Para 20) and Natarajan Finance Corporation has decided the issue in favour of the Revenue. Therefore, the decision of the Tribunal no longer holds good in view of the decision of the Hon'ble Supreme Court. He also relied on various other decisions. 14. So far as the taxability of the income at maximum marginal rate is concerned, he submitted that…

The Fateh Maidan Club(AOP), Hyderabad vs. DCIT, Circle -5 (1), Hyderabad

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 100/HYD/2022[2015-16]Status: DisposedITAT Hyderabad30 Jun 2022AY 2015-16

Bench: Shri R. K. Panda

For Appellant: Sri S. Rama Rao, AdvocateFor Respondent: Sri Waseem Ur Rehman,DR
Section 142(1)Section 144Section 147Section 148

…ctivity and hence is not taxable on the principles of mutuality is concerned, he submitted that the Hon'ble Supreme Court in the case of Bangalore Club (Supra) after considering the facts and the ratio laid down in the case of CIT vs. Bankipur Club Ltd (1997) 5 SCC 394 (Para 20) and Natarajan Finance Corporation has decided the issue in favour of the Revenue. Therefore, the decision of the Tribunal no longer holds good in view of the decision of the Hon'ble Supreme Court. He also relied on various other decisions. 14. So far as the taxability of the income at maximum marginal rate is concerned, he submitted that…

DCIT, New Delhi vs. M/S. Deloitte Touche Tohmastu, Gurgaon

ITA 530/DEL/2016[2011-12]Status: DisposedITAT Delhi11 Apr 2022AY 2011-12

Bench: Sh. R. K. Panda & Sh. Anubhav Sharmaita No.6703/Del/2015, A.Y. 2008-09 Ita No.5760/Del/2015, A.Y. 2009-10 Ita No.5759/Del/2015, A.Y. 2010-11 Ita No.530/Del/2016, A.Y. 2011-12

…or the assessee relied on following judgments to bring before the Bench the concept and principles upon which rule of mutuality has to be ascertained. i. International Zinc Association [2018] 94 taxmann.com 27 (AAR- New Delhi) ii. CIT v. Bankipur Club Limited 226 ITR 97 (SC) iii. Chelmsford Club v. C.I.T. 243 ITR 89 (SC) 8 ITA No. 5759 & Ors. iv. Canara Bank Golden Jubilee Staff Welfare Fund v. DCIT 308 ITR 202 (Kar) v. Bangalore Club 350 ITR 509 (SC) vi. A P Moller Maersk AS vs. DIT (IT) [2017] 392 ITR 186 vii. CIT vs. Kotak Securities Ltd. [2016] 67 taxmann.com 356 (SC)] viii. KPMG 8] taxmann.com 118 [2017]…

DCIT (International Taxation), New Delhi vs. M/S Deloitte Touche Tohmastu, Gurgaon

ITA 6703/DEL/2015[2008-09]Status: DisposedITAT Delhi11 Apr 2022AY 2008-09

Bench: Sh. R. K. Panda & Sh. Anubhav Sharmaita No.6703/Del/2015, A.Y. 2008-09 Ita No.5760/Del/2015, A.Y. 2009-10 Ita No.5759/Del/2015, A.Y. 2010-11 Ita No.530/Del/2016, A.Y. 2011-12

…or the assessee relied on following judgments to bring before the Bench the concept and principles upon which rule of mutuality has to be ascertained. i. International Zinc Association [2018] 94 taxmann.com 27 (AAR- New Delhi) ii. CIT v. Bankipur Club Limited 226 ITR 97 (SC) iii. Chelmsford Club v. C.I.T. 243 ITR 89 (SC) 8 ITA No. 5759 & Ors. iv. Canara Bank Golden Jubilee Staff Welfare Fund v. DCIT 308 ITR 202 (Kar) v. Bangalore Club 350 ITR 509 (SC) vi. A P Moller Maersk AS vs. DIT (IT) [2017] 392 ITR 186 vii. CIT vs. Kotak Securities Ltd. [2016] 67 taxmann.com 356 (SC)] viii. KPMG 8] taxmann.com 118 [2017]…

DCIT, Intl. Taxation, New Delhi vs. Deloitte Touche Tohmastu, Gurgaon

ITA 5760/DEL/2015[2009-10]Status: DisposedITAT Delhi11 Apr 2022AY 2009-10

Bench: Sh. R. K. Panda & Sh. Anubhav Sharmaita No.6703/Del/2015, A.Y. 2008-09 Ita No.5760/Del/2015, A.Y. 2009-10 Ita No.5759/Del/2015, A.Y. 2010-11 Ita No.530/Del/2016, A.Y. 2011-12

…or the assessee relied on following judgments to bring before the Bench the concept and principles upon which rule of mutuality has to be ascertained. i. International Zinc Association [2018] 94 taxmann.com 27 (AAR- New Delhi) ii. CIT v. Bankipur Club Limited 226 ITR 97 (SC) iii. Chelmsford Club v. C.I.T. 243 ITR 89 (SC) 8 ITA No. 5759 & Ors. iv. Canara Bank Golden Jubilee Staff Welfare Fund v. DCIT 308 ITR 202 (Kar) v. Bangalore Club 350 ITR 509 (SC) vi. A P Moller Maersk AS vs. DIT (IT) [2017] 392 ITR 186 vii. CIT vs. Kotak Securities Ltd. [2016] 67 taxmann.com 356 (SC)] viii. KPMG 8] taxmann.com 118 [2017]…

DCIT, Intl. Taxation, New Delhi vs. Deloitte Touche Tohmastu, Gurgaon

ITA 5759/DEL/2015[2010-11]Status: DisposedITAT Delhi11 Apr 2022AY 2010-11

Bench: Sh. R. K. Panda & Sh. Anubhav Sharmaita No.6703/Del/2015, A.Y. 2008-09 Ita No.5760/Del/2015, A.Y. 2009-10 Ita No.5759/Del/2015, A.Y. 2010-11 Ita No.530/Del/2016, A.Y. 2011-12

…or the assessee relied on following judgments to bring before the Bench the concept and principles upon which rule of mutuality has to be ascertained. i. International Zinc Association [2018] 94 taxmann.com 27 (AAR- New Delhi) ii. CIT v. Bankipur Club Limited 226 ITR 97 (SC) iii. Chelmsford Club v. C.I.T. 243 ITR 89 (SC) 8 ITA No. 5759 & Ors. iv. Canara Bank Golden Jubilee Staff Welfare Fund v. DCIT 308 ITR 202 (Kar) v. Bangalore Club 350 ITR 509 (SC) vi. A P Moller Maersk AS vs. DIT (IT) [2017] 392 ITR 186 vii. CIT vs. Kotak Securities Ltd. [2016] 67 taxmann.com 356 (SC)] viii. KPMG 8] taxmann.com 118 [2017]…

All India Liquid Bulk Impoerters & Exporters Asssociation, Mumbai vs. ADIT(E)-II(2), Mumbai

In the result, the appeal filed by the assessee is allowed

ITA 1604/MUM/2020[2011-12]Status: DisposedITAT Mumbai03 Feb 2022AY 2011-12

Bench: Shri Om Prakash Kant & Shri Pavan Kumar Gadaleall India Liquid Bulk Vs. Adit(E)-Ii(2) Importers & Exporters Piramal Chambers, Association Lalbaug, Parel, 501- Mulratna, Mumbai – 400012. 334- Katha Bazar, Masjid, Mumbai – 400009. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aagca5018F Appellant .. Respondent Appellant By : Mr.Paresh Shaparia.C.A. Ar Respondent By : Mr.Kailash Mangal.Sr.Dr Date Of Hearing 08.02.2022 Date Of Pronouncement 14.02.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Of The Cit(A)-3, Mumbai Passed U/S 143(3) & 250 Of The Income Tax Act, 1961.The Assessee Has Raised The Fallowing Grounds Of Appeal: I. Confirmation Of Treatment Of The Non-Profit Organisation As A Mutual Concern & Denying Exemption U/S 11: 1. The Learned C1.T(A) Erred In Confirming Treatment Of The All Inida Liquid Bulk Importers & Exporters Association, Mumbai. Appellant As A Mutual Association Created Exclusively For The Benefit Of Its Members. 2. The Learned Cit(A) Failed To Appreciate The Fact That The Basic Conditions Of The Concept Of Mutuality Are Not Satisfied, Hence The Same Is Not Applicable To The Appellant.

For Appellant: Mr.Paresh Shaparia.C.A. ARFor Respondent: Mr.Kailash Mangal.Sr.DR
Section 11Section 12ASection 143(2)Section 143(3)Section 25

…panies A and was earlier assessed to tax in this Range only and it w as a] claiming Exemption u/ s. 11 & 12 of the Income Tax Act, 1961. in case, it has been held by the Honb1e Supreme Court that it is mutual organization (refer the case of Bankipur Club Ltd. 226 ITR 97 wherein the CCI Club was also a party). The object to promote or manage or assist in the promotion or management for the development of trade and commerce for its members clearly show that the dominant object of the assessee is to provide amenities and facilities to the members of the assessee Company only. It is, therefore, held that the assessee…

ITO (Exemption), Ward, Surat vs. Gujarat Hira Bourse, Surat

In the result, appeals filed by the Revenue (in ITA No

ITA 190/SRT/2020[2017-18]Status: DisposedITAT Surat31 Dec 2021AY 2017-18

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 11Section 11(1)(a)Section 13Section 13(8)Section 2(15)Section 254(1)

…s not carrying out any activity in the nature trade, commerce or business. It is well settled law that no one can trade with himself or derive profit from him. For that we rely on the judgment of Hon'ble Supreme Court, in the case of CIT vs. Bankipur Club Ltd 226 ITR 97 (SC), wherein the Hon'ble Apex Court held as under: "Under the IT Act, what is taxed is, the income, profits or gains earned or "arising", "accruing" to a "person". Where a number of persons combine together and contribute to a common fund for the financing of some venture or object and in this respect have no dealings or relations with any outsi…

ITO (Exemption) Ward, Surat vs. Gujarat Hira Bourse, Surat

In the result, appeals filed by the Revenue (in ITA No

ITA 189/SRT/2020[2014-15]Status: DisposedITAT Surat31 Dec 2021AY 2014-15

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 11Section 11(1)(a)Section 13Section 13(8)Section 2(15)Section 254(1)

…s not carrying out any activity in the nature trade, commerce or business. It is well settled law that no one can trade with himself or derive profit from him. For that we rely on the judgment of Hon'ble Supreme Court, in the case of CIT vs. Bankipur Club Ltd 226 ITR 97 (SC), wherein the Hon'ble Apex Court held as under: "Under the IT Act, what is taxed is, the income, profits or gains earned or "arising", "accruing" to a "person". Where a number of persons combine together and contribute to a common fund for the financing of some venture or object and in this respect have no dealings or relations with any outsi…

M/S Vip Group Housing Society, Jaipur vs. Income Tax Officer, Ward-4-2, Jaipur

ITA 923/JPR/2019[2009-10]Status: DisposedITAT Jaipur28 Jun 2021AY 2009-10
For Appellant: Ms. Pallavi Joshi (Adv.)For Respondent: Smt. Runi Pal (Addl.CIT)
Section 139Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 44ASection 68

…Housing Society Ltd. (2015) 377 ITR 13 (Guj) 4. CIT vs. Adarsh Co-operative Housing Society Ltd (1995) 213 ITR 677 (Guj) 5. Chelmsford Club vs. CIT (2000) 159 CTR (SC) 235 : (2000) 243 ITR 89 (SC) 6. CIT vs. Bankipur Club Ltd. (1997) 140 CTR (SC) 102 : (1997) 226 ITR 97 (SC) 7. CIT vs. Royal Western India Turf Club Ltd. (1953) 24 ITR 551 (SC) 8. Delhi Stock Exchange Association Ltd. vs. CIT (1961) 41 ITR 495 (SC) 9. CIT vs Talangang Co-operative Housing Society Ltd. (2010) 44 DTR (Del) 58 in which it was held that: the bye-laws clearly exposit that it is for the ITA Nos. 923, 677, 678 & 679/JP/2019 9 M/s VIP Grou…

M/S Anil Kumar Singhal, Jaipur vs. Income Tax Officer, Ward-4-2, Jaipur

ITA 679/JPR/2019[2009-10]Status: DisposedITAT Jaipur28 Jun 2021AY 2009-10
For Appellant: Ms. Pallavi Joshi (Adv.)For Respondent: Smt. Runi Pal (Addl.CIT)
Section 139Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 44ASection 68

…Housing Society Ltd. (2015) 377 ITR 13 (Guj) 4. CIT vs. Adarsh Co-operative Housing Society Ltd (1995) 213 ITR 677 (Guj) 5. Chelmsford Club vs. CIT (2000) 159 CTR (SC) 235 : (2000) 243 ITR 89 (SC) 6. CIT vs. Bankipur Club Ltd. (1997) 140 CTR (SC) 102 : (1997) 226 ITR 97 (SC) 7. CIT vs. Royal Western India Turf Club Ltd. (1953) 24 ITR 551 (SC) 8. Delhi Stock Exchange Association Ltd. vs. CIT (1961) 41 ITR 495 (SC) 9. CIT vs Talangang Co-operative Housing Society Ltd. (2010) 44 DTR (Del) 58 in which it was held that: the bye-laws clearly exposit that it is for the ITA Nos. 923, 677, 678 & 679/JP/2019 9 M/s VIP Grou…