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Interest from Bank Fixed Deposits Not Exempt for Club, Taxable u/s 11 Due to Mutuality Principle Violation.

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....Exemption u/s 11 - principle of mutuality - the interest earned by the assessee club on certain fixed deposits kept with certain banks who are also corporate members of the assessee is not covered by the mutuality principles and would therefore, be chargeable to tax in the hands of the assessee.....