Income of assessee chargeable to tax as principle of mutuality not applies

Yum! Restaurants Marketing Private Ltd. Vs ITO (ITAT Delhi)

The assessee’s first claim with respect to the income of the assessee not chargeable to tax because of principles of mutuality has already been decided by the Hon’ble Supreme Court in assessee’s own case reported in 424 ITR 630. The Hon’ble Supreme Court dismissed the appeal of the assessee. Thus, the income of the assessee is chargeable to tax and principle of mutuality does not apply. In view of this, ground Nos. 2–7 of the appeal, are dismissed.

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