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Issues: Whether any part of the transfer fees received by the assessee societies from outgoing or incoming members was liable to tax.
Analysis: The issue was governed by the principle of mutuality. It was held that contributions received both from outgoing and incoming members fell within that principle. The effect of the Government circulars dated 27.11.1989 and 20.12.1989 was also considered and did not alter that conclusion.
Conclusion: The transfer fees were not liable to tax on the ground of mutuality, and the question was answered in favour of the assessee and against the Revenue.
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