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“doctrine of mutuality”

Judicial DoctrinesMutualityMutuality75 judgments

The decision most relied on for doctrine of mutuality is Bangalore Club v. CIT (350 ITR 509), cited in 247 judgments on BharatTax.

Leading authorities on doctrine of mutuality

Bangalore Club v. CIT
350 ITR 509 · 2013 · Supreme Court
247
citing judgments

The Supreme Court affirmed the doctrine of mutuality, holding that contributions received from and returned to members for a common purpose do not constitute taxable profits. However, income from transactions with non-members or interest earned from investments in external entities (like cooperative banks) may break the mutuality chain and be taxable under Section 56, falling outside the scope of Section 80P deductions.

CIT v. Bankipur Club Ltd.
226 ITR 97 · 1997 · Supreme Court
125
citing judgments

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.

Chelmsford Club v. CIT
243 ITR 89 · 2000 · Supreme Court
100
citing judgments

Income arising from mutual activities carried out by clubs or associations solely among their members is not assessable for income tax, as it does not constitute income from a trade or business due to the principle of mutuality.

CIT v. Ace Multi Axes Systems Ltd.
88 Taxmann.com 69 · 2017 · Supreme Court
61
citing judgments

Each assessment year constitutes a separate unit of assessment under the Income-tax Act, and findings or decisions for one assessment year do not operate as res judicata for subsequent assessment years.

CIT v. Royal Western India Turf Club Ltd.
24 ITR 551 · 1953 · Supreme Court
32
citing judgments

A mutual concern may be held to carry on a business or trade with its members, even if the surplus from such trade is not considered income or profit. The court adopted a stricter approach in applying the principle of mutuality, emphasizing the identity of contributors and recipients.

Sind Co-operative Housing Society v. ITO
317 ITR 47 · 2009 · High Court
32
citing judgments

The doctrine of mutuality applies to co-operative societies, preventing income derived from members from being taxed as income from other sources. The court affirmed that the principle of mutuality, as accepted by the jurisdictional High Court, should be followed.

CIT v. Common Effluent Treatment Plant (Thane Belapur) Association
328 ITR 362 · 2010 · High Court
25
citing judgments

Interest earned by an association from surplus funds deposited with non-members is taxable and does not fall under the principle of mutuality.

CIT v. Delhi Gymkhana Club Limited
339 ITR 525 · 2011 · Reported
21
citing judgments

The doctrine of mutuality is applicable to interest earned on fixed deposits, provided the interest is used for the maintenance and welfare of members. However, some later judgments have dissented from this view, holding that such interest is taxable.

Judgments citing doctrine of mutuality

The Masonic Fraternity of New Delhi, New Delhi vs. ITO Ward 52(1), New Delhi

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

ITA 3174/DEL/2023[2021-2022]Status: DisposedITAT Delhi27 Jun 2024AY 2021-2022

Bench: Ld. Cit(A) & Ld.Cit(A) Sustained The Addition With The Observation That The Registration Of Claim U/S 11 Of The Act Is Not Proper Within The Mandate Of Section 143(1) Of The Act.

Section 11Section 12ASection 143(1)Section 143(1)(a)

concept. Even though the assessee has submitted the details and relied on the several decisions in support of the claim in terms of doctrine of mutuality, however, he observed that the assessee has not provided any The Masonic Fraternity of New Delhi vs. ITO cogent material like mandatory forms 10B/10BB

Murude Sahakari Patsanstha Maryadit, Mumbai vs. Income Tax Officer, Ward-22(2)(1), Mumbai

In the result, the appeal of the assessee is allowed for In the result, the appeal of the assessee is allowed for In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1605/MUM/2024[2016-17]Status: DisposedITAT Mumbai21 Jun 2024AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2016-17

For Appellant: Mr. Dharan GandhiFor Respondent: Ms. Usha Gaikwad, Sr. DR
Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

surplus amount itself, held that "unlike the surplus amount itself, which is exempt from tax under which is exempt from tax under the doctrine of mutuality, the amount of interest earned by the assessee the doctrine of mutuality, the amount of interest earned by the assessee the doctrine of mutuality

Madapura vs. Sbn, Kodaguvs.Income Tax Officer, Ward-1, Madikeri

In the result, appeal of the assessee is allowed for statistical purposes

ITA 705/BANG/2024[2017-18]Status: DisposedITAT Bangalore06 Jun 2024AY 2017-18

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

For Appellant: Shri Ravishankar S.V, AdvocateFor Respondent: Ms. Shamala D.D, Addl. CIT(DR)
Section 2(19)Section 234ASection 80PSection 80P(2)Section 80P(2)(a)Section 8o

facts and circumstances of the case. b. The authorities below have failed to appreciate that the appellant has not claimed exemption under the `doctrine of mutuality' and the deduction is claimed under section 8oP(2)(a)(i) which does not require it to satisfy the test of mutuality

Omkar 1998 Co Op Housing Society Ltd, College Road vs. Income Tax Officer, Ward 1(1), Nashik, Gadkari Chowk

The appeal of the assessee is ALLOWED and all the grounds stands adjudicated accordingly

ITA 284/PUN/2024[A.Y. 2018-19]Status: DisposedITAT Pune29 May 2024

Bench: Hon’Ble S. S. Godara & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No. 0284/Pun/2024 निर्धारण वषा / Assessment Year : 2018-19

For Appellant: None for the AssesseeFor Respondent: Mr Ramnath Murkunde [‘Ld. DR’]
Section 143(1)Section 250Section 80P(2)(d)

society is no-more res-integra. 8. The appellant is a housing co-operative society and admittedly is governed by the doctrine of mutuality. This doctrine of mutuality refers to the principle that one cannot engage into a business with self. If the identity ITAT-Pune Page ... received by the appellant from its member was admittedly towards contribution to common pool of the society and since is governed by the doctrine of mutuality hence is inexigible to tax. The incorrect reporting of such contribution while filing the return would per-se does not change the character & nature

Shivashree Souharda Credit Co-Operative Limited, Tumakuru vs. Income Tax Officer, Ward-3, Tumkur

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

ITA 300/BANG/2024[2017-18]Status: DisposedITAT Bangalore18 Apr 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Sri Ravishankar, A.RFor Respondent: Shri V. Parithivel, D.R
Section 234Section 250Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

facts and circumstances of the case. b. The authorities below have failed to appreciate that the appellant is not claiming exemption under the 'doctrine of mutuality' and the deduction is claimed under section 80P(2)(a)(i) which does not require it to satisfy the test of mutuality

Mehsana Taluka Madhyamik Teachers Credit & Consumers Sahakari Mandali Ltd, Mehsana vs. The ITO, Ward-2, Present Ward-1, Mehsana

In the result, appeal of the assessee is partly allowed

ITA 6/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad10 Apr 2024AY 2017-18

Bench: Shri Waseem Ahmed (Accountant Member), Ms. Madhumita Roy (Judicial Member)

For Appellant: Shri Hasmukh V. Doshi, A.RFor Respondent: Shri Sudhendu Das, CIT-D.R. &
Section 57Section 80Section 80P(2)(d)

business income’ alone but also extends to income derived from investments ordinarily falling under the head ‘income from other sources’ as well ; secondly doctrine of mutuality is not necessarily a pre-condition in appropriate circumstances, for instance 80P(2)(a(ii); and thirdly and quite significantly ; the investment

Junior Chamber International India, Andheri, Mumbai vs. Income Tax Officer (Exemptions) - 1(4), Mumbai, Mtnl Building, Pedder Road

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 2454/MUM/2023[2014-2015]Status: DisposedITAT Mumbai20 Mar 2024AY 2014-2015

Bench: Shri Vikas Awasthy & Shri Amarjit Singhita Nos. 2448,2450,2451, 2452 & 2454/Mum/2023 (A.Ys. 2012-13 To 2016-17) Junior Chamber Vs. Income Tax Officer International India (Exemption)-1(4) 506, Windfall Sahar Plaza, 6Th Floor, Mtnl Tel. Ex. J.B. Nagar Near Chakala Building, Cumballa Hills, Metro Station, Andheri Pedder Road, Maharashtra – 400059 Maharashtra - 400026 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaati1215P Appellant .. Respondent Appellant By : Ms. Chaitee Londhe & Ms. Pallavi Limye Respondent By : Ankush Kapoor Date Of Hearing 18.03.2024 Date Of Pronouncement 20.03.2024 आदेश / O R D E R Per Bench: All These 5 Appeals For Ays 2012-13 To 2016-17 Are Directed The Different Orders Of Ld. Cit(A) Passed U/S 250 Of The Act. Since, All These Appeals Are Based On Similar Issue & Identical Facts, Therefore, For The Sake Of Convenience All These Appeals Are Adjudicated Together By Taking

For Appellant: Ms. Chaitee Londhe &For Respondent: Ankush Kapoor
Section 11Section 12ASection 143(2)Section 2(15)Section 250

assessing officer was of the view that the assessee was a mutual association and not a charitable one, therefore, he has applied the doctrine of mutuality and treated the assessee’s receipt from non- members and other sources such as interest income, sponsor ship and royalty etc, as income

Junior Chamber International India, Andheri, Mumbai vs. Income Tax Officer (Exemptions)- 1(4), Mumbai, Mtnl Building, Pedder Road

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 2452/MUM/2023[2015-2016]Status: DisposedITAT Mumbai20 Mar 2024AY 2015-2016

Bench: Shri Vikas Awasthy & Shri Amarjit Singhita Nos. 2448,2450,2451, 2452 & 2454/Mum/2023 (A.Ys. 2012-13 To 2016-17) Junior Chamber Vs. Income Tax Officer International India (Exemption)-1(4) 506, Windfall Sahar Plaza, 6Th Floor, Mtnl Tel. Ex. J.B. Nagar Near Chakala Building, Cumballa Hills, Metro Station, Andheri Pedder Road, Maharashtra – 400059 Maharashtra - 400026 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaati1215P Appellant .. Respondent Appellant By : Ms. Chaitee Londhe & Ms. Pallavi Limye Respondent By : Ankush Kapoor Date Of Hearing 18.03.2024 Date Of Pronouncement 20.03.2024 आदेश / O R D E R Per Bench: All These 5 Appeals For Ays 2012-13 To 2016-17 Are Directed The Different Orders Of Ld. Cit(A) Passed U/S 250 Of The Act. Since, All These Appeals Are Based On Similar Issue & Identical Facts, Therefore, For The Sake Of Convenience All These Appeals Are Adjudicated Together By Taking

For Appellant: Ms. Chaitee Londhe &For Respondent: Ankush Kapoor
Section 11Section 12ASection 143(2)Section 2(15)Section 250

assessing officer was of the view that the assessee was a mutual association and not a charitable one, therefore, he has applied the doctrine of mutuality and treated the assessee’s receipt from non- members and other sources such as interest income, sponsor ship and royalty etc, as income

Junior Chamber International India, Mumbai vs. Income Tax Officer(Exemptions)- 1(4) Mumbai, Mtnl Building, Pedder Road

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 2451/MUM/2023[2016-2017]Status: DisposedITAT Mumbai20 Mar 2024AY 2016-2017

Bench: Shri Vikas Awasthy & Shri Amarjit Singhita Nos. 2448,2450,2451, 2452 & 2454/Mum/2023 (A.Ys. 2012-13 To 2016-17) Junior Chamber Vs. Income Tax Officer International India (Exemption)-1(4) 506, Windfall Sahar Plaza, 6Th Floor, Mtnl Tel. Ex. J.B. Nagar Near Chakala Building, Cumballa Hills, Metro Station, Andheri Pedder Road, Maharashtra – 400059 Maharashtra - 400026 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaati1215P Appellant .. Respondent Appellant By : Ms. Chaitee Londhe & Ms. Pallavi Limye Respondent By : Ankush Kapoor Date Of Hearing 18.03.2024 Date Of Pronouncement 20.03.2024 आदेश / O R D E R Per Bench: All These 5 Appeals For Ays 2012-13 To 2016-17 Are Directed The Different Orders Of Ld. Cit(A) Passed U/S 250 Of The Act. Since, All These Appeals Are Based On Similar Issue & Identical Facts, Therefore, For The Sake Of Convenience All These Appeals Are Adjudicated Together By Taking

For Appellant: Ms. Chaitee Londhe &For Respondent: Ankush Kapoor
Section 11Section 12ASection 143(2)Section 2(15)Section 250

assessing officer was of the view that the assessee was a mutual association and not a charitable one, therefore, he has applied the doctrine of mutuality and treated the assessee’s receipt from non- members and other sources such as interest income, sponsor ship and royalty etc, as income

Junior Chamber International India, Andheri, Mumbai vs. Income Tax Officer(Exemptions)- 1(4), Mumbai, Mtnl Building, Pedder Road

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 2450/MUM/2023[2012-2013]Status: DisposedITAT Mumbai20 Mar 2024AY 2012-2013

Bench: Shri Vikas Awasthy & Shri Amarjit Singhita Nos. 2448,2450,2451, 2452 & 2454/Mum/2023 (A.Ys. 2012-13 To 2016-17) Junior Chamber Vs. Income Tax Officer International India (Exemption)-1(4) 506, Windfall Sahar Plaza, 6Th Floor, Mtnl Tel. Ex. J.B. Nagar Near Chakala Building, Cumballa Hills, Metro Station, Andheri Pedder Road, Maharashtra – 400059 Maharashtra - 400026 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaati1215P Appellant .. Respondent Appellant By : Ms. Chaitee Londhe & Ms. Pallavi Limye Respondent By : Ankush Kapoor Date Of Hearing 18.03.2024 Date Of Pronouncement 20.03.2024 आदेश / O R D E R Per Bench: All These 5 Appeals For Ays 2012-13 To 2016-17 Are Directed The Different Orders Of Ld. Cit(A) Passed U/S 250 Of The Act. Since, All These Appeals Are Based On Similar Issue & Identical Facts, Therefore, For The Sake Of Convenience All These Appeals Are Adjudicated Together By Taking

For Appellant: Ms. Chaitee Londhe &For Respondent: Ankush Kapoor
Section 11Section 12ASection 143(2)Section 2(15)Section 250

assessing officer was of the view that the assessee was a mutual association and not a charitable one, therefore, he has applied the doctrine of mutuality and treated the assessee’s receipt from non- members and other sources such as interest income, sponsor ship and royalty etc, as income

Junior Chamber International India, Andheri, Mumbai vs. Income Tax Officer(Exemptions)- 1(4), Mumbai, Mtnl Building, Pedder Road

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 2448/MUM/2023[2013-14]Status: DisposedITAT Mumbai20 Mar 2024AY 2013-14

Bench: Shri Vikas Awasthy & Shri Amarjit Singhita Nos. 2448,2450,2451, 2452 & 2454/Mum/2023 (A.Ys. 2012-13 To 2016-17) Junior Chamber Vs. Income Tax Officer International India (Exemption)-1(4) 506, Windfall Sahar Plaza, 6Th Floor, Mtnl Tel. Ex. J.B. Nagar Near Chakala Building, Cumballa Hills, Metro Station, Andheri Pedder Road, Maharashtra – 400059 Maharashtra - 400026 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaati1215P Appellant .. Respondent Appellant By : Ms. Chaitee Londhe & Ms. Pallavi Limye Respondent By : Ankush Kapoor Date Of Hearing 18.03.2024 Date Of Pronouncement 20.03.2024 आदेश / O R D E R Per Bench: All These 5 Appeals For Ays 2012-13 To 2016-17 Are Directed The Different Orders Of Ld. Cit(A) Passed U/S 250 Of The Act. Since, All These Appeals Are Based On Similar Issue & Identical Facts, Therefore, For The Sake Of Convenience All These Appeals Are Adjudicated Together By Taking

For Appellant: Ms. Chaitee Londhe &For Respondent: Ankush Kapoor
Section 11Section 12ASection 143(2)Section 2(15)Section 250

assessing officer was of the view that the assessee was a mutual association and not a charitable one, therefore, he has applied the doctrine of mutuality and treated the assessee’s receipt from non- members and other sources such as interest income, sponsor ship and royalty etc, as income

Vishram Sahakari Awas Samiti Limited, G.Noida vs. ITO, Ward-2(5), Noida

In the result, appeal of the assessee stands allowed

ITA 1667/DEL/2021[2011-12]Status: DisposedITAT Delhi07 Feb 2024AY 2011-12

Bench: Shri Shamim Yahya & Shri Anubhav Sharma

For Appellant: Shri Ved Jain, AdvFor Respondent: Shri Amit Katoch, Sr. DR
Section 147Section 148Section 68

assessee that addition made by the AO cannot be taxed in the hands of the assessee (Association of Persons) in view of the doctrine of Mutuality. 13. The appellant craves leave to add, amend or alter any of the grounds of appeal.” 2. The assessee has raised several grounds

Conservator of Forest and Field Director Tiger Project Sariska, Sariska Alwar vs. Income Tax Officer Ward TDS, Moti Dungari Alwar

In the result, the appeal of the assessee in ITA no

ITA 475/JPR/2023[2015-16]Status: DisposedITAT Jaipur08 Nov 2023AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. Nos. 450, 466, 470 to 475/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2016-17, 2009-10, 2010-11 to 2015-16 M/s Conservator of Forest and Field Tiger Project Sariska, Alwar cuke Vs. The Income Tax Officer (TDS), Alwar LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAALC 1579 N vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. Saajan Saini (Adv.) jktLo dh vksj ls@ Revenue b

For Appellant: Sh. Saajan Saini (Adv.)For Respondent: Sh. Arvind Kumar (CIT) &
Section 201(1)

depleting, therefore even if there is some income or surplus arising out of their activities the same is exempt under the principles of "doctrine of mutuality In the case of CIT vs. Common Effluent Treatment Plant (Thane Belapur) Association (2010) 328 ITR 0362 (Born) where it has That "The principle ... this sense that the law postulates that there must be a complete identity between the contributors and the participators. The essence of the doctrine of mutuality lies in the principle that what is returned is what is contributed by a member. A person cannot trade with himself

Conservator of Forest and Field Director Tiger Project Sariska, Sariska Alwar vs. Income Tax Officer Ward TDS, Moti Dungari

In the result, the appeal of the assessee in ITA no

ITA 474/JPR/2023[2014-15]Status: DisposedITAT Jaipur08 Nov 2023AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. Nos. 450, 466, 470 to 475/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2016-17, 2009-10, 2010-11 to 2015-16 M/s Conservator of Forest and Field Tiger Project Sariska, Alwar cuke Vs. The Income Tax Officer (TDS), Alwar LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAALC 1579 N vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. Saajan Saini (Adv.) jktLo dh vksj ls@ Revenue b

For Appellant: Sh. Saajan Saini (Adv.)For Respondent: Sh. Arvind Kumar (CIT) &
Section 201(1)

depleting, therefore even if there is some income or surplus arising out of their activities the same is exempt under the principles of "doctrine of mutuality In the case of CIT vs. Common Effluent Treatment Plant (Thane Belapur) Association (2010) 328 ITR 0362 (Born) where it has That "The principle ... this sense that the law postulates that there must be a complete identity between the contributors and the participators. The essence of the doctrine of mutuality lies in the principle that what is returned is what is contributed by a member. A person cannot trade with himself

Conservator of Forest and Field Director Tiger Project Sariska, Sariska Alwar vs. Income Tax Officer Ward TDS, Moti Dungari Alwar

In the result, the appeal of the assessee in ITA no

ITA 473/JPR/2023[2013-14]Status: DisposedITAT Jaipur08 Nov 2023AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. Nos. 450, 466, 470 to 475/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2016-17, 2009-10, 2010-11 to 2015-16 M/s Conservator of Forest and Field Tiger Project Sariska, Alwar cuke Vs. The Income Tax Officer (TDS), Alwar LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAALC 1579 N vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. Saajan Saini (Adv.) jktLo dh vksj ls@ Revenue b

For Appellant: Sh. Saajan Saini (Adv.)For Respondent: Sh. Arvind Kumar (CIT) &
Section 201(1)

depleting, therefore even if there is some income or surplus arising out of their activities the same is exempt under the principles of "doctrine of mutuality In the case of CIT vs. Common Effluent Treatment Plant (Thane Belapur) Association (2010) 328 ITR 0362 (Born) where it has That "The principle ... this sense that the law postulates that there must be a complete identity between the contributors and the participators. The essence of the doctrine of mutuality lies in the principle that what is returned is what is contributed by a member. A person cannot trade with himself

Conservator of Forest and Field Director Tiger Project Sariska, Sariska Alwar vs. Income Tax Officer Ward TDS, Moti Dungari

In the result, the appeal of the assessee in ITA no

ITA 472/JPR/2023[2012-13]Status: DisposedITAT Jaipur08 Nov 2023AY 2012-13

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. Nos. 450, 466, 470 to 475/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2016-17, 2009-10, 2010-11 to 2015-16 M/s Conservator of Forest and Field Tiger Project Sariska, Alwar cuke Vs. The Income Tax Officer (TDS), Alwar LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAALC 1579 N vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. Saajan Saini (Adv.) jktLo dh vksj ls@ Revenue b

For Appellant: Sh. Saajan Saini (Adv.)For Respondent: Sh. Arvind Kumar (CIT) &
Section 201(1)

depleting, therefore even if there is some income or surplus arising out of their activities the same is exempt under the principles of "doctrine of mutuality In the case of CIT vs. Common Effluent Treatment Plant (Thane Belapur) Association (2010) 328 ITR 0362 (Born) where it has That "The principle ... this sense that the law postulates that there must be a complete identity between the contributors and the participators. The essence of the doctrine of mutuality lies in the principle that what is returned is what is contributed by a member. A person cannot trade with himself

Conservator of Forest and Field Director Tiger Project Sariska, Sariska Alwar vs. Income Tax Officer Ward TDS, Moti Dungari Alwar

In the result, the appeal of the assessee in ITA no

ITA 471/JPR/2023[2011-12]Status: DisposedITAT Jaipur08 Nov 2023AY 2011-12

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. Nos. 450, 466, 470 to 475/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2016-17, 2009-10, 2010-11 to 2015-16 M/s Conservator of Forest and Field Tiger Project Sariska, Alwar cuke Vs. The Income Tax Officer (TDS), Alwar LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAALC 1579 N vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. Saajan Saini (Adv.) jktLo dh vksj ls@ Revenue b

For Appellant: Sh. Saajan Saini (Adv.)For Respondent: Sh. Arvind Kumar (CIT) &
Section 201(1)

depleting, therefore even if there is some income or surplus arising out of their activities the same is exempt under the principles of "doctrine of mutuality In the case of CIT vs. Common Effluent Treatment Plant (Thane Belapur) Association (2010) 328 ITR 0362 (Born) where it has That "The principle ... this sense that the law postulates that there must be a complete identity between the contributors and the participators. The essence of the doctrine of mutuality lies in the principle that what is returned is what is contributed by a member. A person cannot trade with himself

Conservator of Forest and Field Director Tiger Project Sariska, Sariska Alwar vs. Income Tax Officer Ward TDS, Alwar

In the result, the appeal of the assessee in ITA no

ITA 470/JPR/2023[2010-11]Status: DisposedITAT Jaipur08 Nov 2023AY 2010-11

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. Nos. 450, 466, 470 to 475/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2016-17, 2009-10, 2010-11 to 2015-16 M/s Conservator of Forest and Field Tiger Project Sariska, Alwar cuke Vs. The Income Tax Officer (TDS), Alwar LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAALC 1579 N vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. Saajan Saini (Adv.) jktLo dh vksj ls@ Revenue b

For Appellant: Sh. Saajan Saini (Adv.)For Respondent: Sh. Arvind Kumar (CIT) &
Section 201(1)

depleting, therefore even if there is some income or surplus arising out of their activities the same is exempt under the principles of "doctrine of mutuality In the case of CIT vs. Common Effluent Treatment Plant (Thane Belapur) Association (2010) 328 ITR 0362 (Born) where it has That "The principle ... this sense that the law postulates that there must be a complete identity between the contributors and the participators. The essence of the doctrine of mutuality lies in the principle that what is returned is what is contributed by a member. A person cannot trade with himself

Conservator of Forest and Field Director Tiger Project Sariska, Sariska Alwar vs. Income Tax Officer Ward TDS, Alwar

In the result, the appeal of the assessee in ITA no

ITA 466/JPR/2023[2009-10]Status: DisposedITAT Jaipur08 Nov 2023AY 2009-10

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. Nos. 450, 466, 470 to 475/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2016-17, 2009-10, 2010-11 to 2015-16 M/s Conservator of Forest and Field Tiger Project Sariska, Alwar cuke Vs. The Income Tax Officer (TDS), Alwar LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAALC 1579 N vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. Saajan Saini (Adv.) jktLo dh vksj ls@ Revenue b

For Appellant: Sh. Saajan Saini (Adv.)For Respondent: Sh. Arvind Kumar (CIT) &
Section 201(1)

depleting, therefore even if there is some income or surplus arising out of their activities the same is exempt under the principles of "doctrine of mutuality In the case of CIT vs. Common Effluent Treatment Plant (Thane Belapur) Association (2010) 328 ITR 0362 (Born) where it has That "The principle ... this sense that the law postulates that there must be a complete identity between the contributors and the participators. The essence of the doctrine of mutuality lies in the principle that what is returned is what is contributed by a member. A person cannot trade with himself

Conservator of Forest and Field Director, Tiger Project Sariska (Local Authority), Sariska, Alwar vs. Income Tax Officer ( TDS), Moti Dungari Alwar

In the result, the appeal of the assessee in ITA no

ITA 450/JPR/2023[2016-17]Status: DisposedITAT Jaipur08 Nov 2023AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. Nos. 450, 466, 470 to 475/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2016-17, 2009-10, 2010-11 to 2015-16 M/s Conservator of Forest and Field Tiger Project Sariska, Alwar cuke Vs. The Income Tax Officer (TDS), Alwar LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAALC 1579 N vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. Saajan Saini (Adv.) jktLo dh vksj ls@ Revenue b

For Appellant: Sh. Saajan Saini (Adv.)For Respondent: Sh. Arvind Kumar (CIT) &
Section 201(1)

depleting, therefore even if there is some income or surplus arising out of their activities the same is exempt under the principles of "doctrine of mutuality In the case of CIT vs. Common Effluent Treatment Plant (Thane Belapur) Association (2010) 328 ITR 0362 (Born) where it has That "The principle ... this sense that the law postulates that there must be a complete identity between the contributors and the participators. The essence of the doctrine of mutuality lies in the principle that what is returned is what is contributed by a member. A person cannot trade with himself