M/S. BANGALORE CLUB vs. COMMISSIONER OF INCOME TAX

6. Mr. A.S. Chandhiok, learned Additional Solicitor General of India, on the other hand, contended that the fundamental principle for applicability of the doctrine of mutuality is a complete identity between the contributors and the participators, which is missing in this case. It was submitted that in the present case, the surplus funds in the hands of the assessee were