Appellant Denied Tax Exemption Due to Lack of Mutuality; Strict Interpretation of Exemptions Essential for Public Exchequer.

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....Doctrine of mutuality - Exemption from taxability - The doctrine of mutuality bestows a special status to qualify for exemption from tax liability. It is a settled proposition of law that exemptions are to be put to strict interpretation. The appellant having failed to fulfil the stipulations and to prove the existence of mutuality, the question of extending exemption from tax liability to the appellant, that too at the cost of public exchequer, does not arise - SC....