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2016 (11) TMI 1312 - AT - Income TaxBenefit of principle of mutuality - receipts from the members and taxes the surplus income from non-members - Held that:- If the objects of the assessee are looked into cumulatively, then it would spell out that in order to appraise members about the latest technology in construction activities, market trend, it would not be futile to organize property show. As far as cricket match is concerned, it was not organized on commercial basis, rather participators are mainly from among the members. It is recreational activities. The assessee has pointed out that total receipts from these matches have not crossed one and half -lakhs of rupees. Therefore, this is minor contribution from non-members which has been offered for taxation, would not destroy the principle of mutuality. We find that the ld.CIT(A) has made reference to the various case laws, but not examined analytically the facts of the assessee’s case. She simply concurred with the proposition laid down in those cases laws, but has not spell out how these propositions are applicable on the facts of the present case. It is pertinent to observe that facts of all other years are identical. Therefore, we allow all the appeals of the assessee for statistical purpose.
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