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    <title>2004 (9) TMI 318 - ITAT COCHIN</title>
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    <description>An association of bus operators supplying spare parts, tyres, technical guidance and allied facilities only to members was found to satisfy mutuality because the contributors and participators in the surplus were the same class. The Tribunal held that third-party suppliers in the procurement chain did not destroy mutuality, as the relevant relationship is between members contributing to and benefiting from the surplus. The arrangement was treated as non-trading in character and confined to mutual benefit, so the surplus from these member-only activities was not taxable as business income and the revenue authorities&#039; view was reversed.</description>
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