Mutuality upheld, but bank interest taxed: ITAT sends club case back

President Siddgrtha Sports Club Vs ITO (ITAT Bangalore) The ITAT Bangalore held that the principle of mutuality applies to a members’ club, and income received from members cannot be taxed, subject to verification of complete identity between contributors and beneficiaries. In this case, the assessee club was treated as a non-filer and assessed under section 147, with substantial additions including unexplained cash deposits under section 69A and denial of mutuality. The AO also relied on discrepancies such as incorrect PAN status (shown as partnership firm) and lack of details. The Tribunal...