https://www.taxtmi.com/caselaws?id=24456 Concurrent findings showed that the club's facilities were used exclusively by members and that no non-member was permitted to use or occupy any room during the relevant accounting period. On that factual basis, charges collected from members for amenities did not involve any trading element, because mutual dealings do not generate assessable profit where a person cannot trade with himself. The club's income was therefore treated as exempt under the doctrine of mutuality. As the controversy depended entirely on findings of fact, no referable question of law survived under section 256(2) of the Income-tax Act, 1961, and the request for a direction to refer was declined. en-us Tue, 14 Jul 1987 00:00:00 +0530 Wed, 20 Jan 2010 12:06:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=24456 Concurrent findings showed that the club's facilities were used exclusively by members and that no non-member was permitted to use or occupy any room during the relevant accounting period. On that factual basis, charges collected from members for amenities did not involve any trading element, because mutual dealings do not generate assessable profit where a person cannot trade with himself. The club's income was therefore treated as exempt under the doctrine of mutuality. As the controversy depended entirely on findings of fact, no referable question of law survived under section 256(2) of the Income-tax Act, 1961, and the request for a direction to refer was declined. Case-Laws Income Tax Tue, 14 Jul 1987 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=24456