2007 (5) TMI 640

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....ed counsel for the parties we admit this appeal and frame the following substantial question of law:- "Whether on the facts and in the circumstances of the case, the Income Tax Appellate Tribunal erred in law in holding that the amount received by way of interest from banks on temporary deposit of the funds is not exempted from tax on the ?principle of mutuality?" 2. Since a short question of l....

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.... 5. Applying the doctrine of mutuality, the Tribunal held that income received by the Assessee for the use of facilities by guests of the members is exempt from taxation. This being the position, we are of the view that deposits made as a result of this income received and the interest received thereon from the banks cannot be said to be outside the doctrine of mutuality. 6. Learned counsel for t....