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of Exemption u/s 11 - applicability of the principle of mutuality - holding of exhibitions and organising of seminars - As per the assessee, the income from members is non-taxable not u/s 11 of the Act but the same is not taxable as per the principle of mutuality. An activity between persons associated together does not give rise to profit which is chargeable to tax, as the members cannot trade with themselves. No person or body of persons can earn profit out of himself or themselves jointly. - AO denied the exemption on the basis of wrong assumption - AT
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