Tribunal rightly applied principle of mutuality in assessee...

Tribunal rightly applied principle of mutuality in assessee company's case, following Sports Club of Gujarat and Secunderabad Club judgments. Assessee formed to treat effluents as per court's directions, surplus not distributed to members, members contribute for services. On dissolution, members get only Rs. 100. Hence, assessee's income/surplus not taxable based on mutuality principle. Disallowance of depreciation and 80IA deduction not required if income not taxable due to mutuality. No substantial question of law arises from Tribunal's order in assessee's favor.

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