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    <title>2022 (10) TMI 213 - ITAT MUMBAI</title>
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    <description>The Tribunal allowed the appeal of the assessee, holding that the amounts received from members towards the Surety Guarantee Fund were not chargeable to tax. The principle of mutuality and consistency in treating such receipts as capital receipts were pivotal in this decision. The validity of re-assessment was not addressed as the appeal was granted based on the merits related to the SGF addition.</description>
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      <description>The Tribunal allowed the appeal of the assessee, holding that the amounts received from members towards the Surety Guarantee Fund were not chargeable to tax. The principle of mutuality and consistency in treating such receipts as capital receipts were pivotal in this decision. The validity of re-assessment was not addressed as the appeal was granted based on the merits related to the SGF addition.</description>
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