Section 10(6) requires specific member services and linked remuneration; association receipts were taxable under another provision.

Section 10(6) applied only where an association rendered specific services to its members and received remuneration directly linked to those services. On the stated facts, there was no finding that the association itself rendered such services or that any remuneration was paid for them, so taxation under section 10(6) could not be sustained. The proper enquiry was whether the receipts were taxable under some other provision disclosed by the facts, and the document notes that the same facts had earlier supported taxation under section 12. The receipts were therefore treated as properly taxed on the material available.

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Issues: Whether the receipts of the assessee association were properly taxed, and whether they could be brought to tax under section 10(6) or under another provision of the Act.

Analysis: Section 10(6) applies only where the assessee renders specific services to its members, the members pay remuneration for those services, and there is a connection between the remuneration and the services rendered. On the facts stated, there was no finding that the association itself rendered such specific services or that any remuneration was paid to it for those services. The Tribunal's conclusion that services were rendered was unsupported by the stated facts. The receipts could therefore not be sustained under section 10(6). The facts, however, were the same as in the earlier reference, where the income had been held taxable under section 12, and the proper enquiry was whether the receipts were taxable under any provision disclosed by the facts.

Conclusion: The receipts were properly taxed, and the answer was in the affirmative.

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