Members' association receipts for specific facilities are taxable when separate charges fund identifiable benefits beyond ordinary mutual dealings.

Receipts of a members' association from entrance fees for authorised assistants, subscriptions for authorised assistants, and fees for placing companies on the quotations list were treated as taxable income because they were paid for identifiable, separate facilities. The provision applied where an association carried on business by rendering specific services to members for remuneration directly linked to those services. The additional payments were not part of ordinary mutual membership dealings; they secured tangible benefits beyond general association rights. The mutuality argument failed because the receipts were separately charged and corresponded to distinct advantages conferred on the paying members. Accordingly, the receipts fell within section 10(6) and were taxable.

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Issues: Whether the receipts from entrance fees for authorised assistants, subscriptions in respect of authorised assistants, and fees for enlisting companies on the quotations list were chargeable to tax under section 10(6) of the Indian Income-tax Act, 1922.

Analysis: The provision deems a trade, professional or similar association carrying on business in respect of services rendered to its members for remuneration definitely related to those services. The expression "performing specific services" was understood to mean conferring particular tangible benefits on members for a separate payment. The entrance fees and periodic subscriptions were paid only by members who chose to obtain the benefit of employing authorised assistants within the exchange, and the quotation-list fees were paid by members seeking the benefit of having companies included for dealings. Each receipt was separately charged and was directly linked to a distinct facility or advantage provided by the association. The argument based on mutuality failed because the additional payments were made for special benefits beyond the ordinary mutual dealings of membership.

Conclusion: The receipts fell within section 10(6) and were taxable income.

Ratio Decidendi: Where a members' association, for a separate charge, confers identifiable and tangible benefits on members through organised facilities or permissions, the receipts are remuneration definitely related to specific services and are taxable under section 10(6).

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