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2017 (5) TMI 405 - AT - Income TaxDenial of exemption claimed u/s 11 - rejection of claim for exemption from tax on subscription and delegates fees collected from members, based on the principle of mutuality - interpretation to section 2(15) - Held that:- Admittedly receipt of the assessee classified by it as "other income", comprised in it seminars/delegates fees, advertisement and miscellaneous income which far exceeded limits laid down in the second proviso. Thus, in our opinion the assessee could neither be considered performing charitable activities within the meaning of section 2(15) of the Act during the relevant previous year nor it could be considered as exempt on the principle of mutuality. We therefore, find no reason to interfere with the orders of the lower authorities. - Decided in favour of revenue
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