Assessment Reopening u/s 147: Development Charges and TDR Deposits Do Not Violate Mutuality Principles.

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....Reopening of assessment u/s 147 - addition of development charges and TDR deposits violating the principles of mutuality - The TDR premium is a payment made by a member to the Society of which he is a member, as a consideration for being permitted to make an additional utilization of FSI on the plot allotted by the Co-operative Housing Society. The Society which looks after the infrastructure, requires the payment of the premium in order to defray the additional burden that may be cast as a result of the utilization of the FSI. - It is essentially clear that the receipts of the assessee are not chargeable to tax applying the doctrine of mutuality. - AT....