No exemption from tax liability in case principles of mutuality reiterated

Yum Restaurants (Marketing) Pvt. Ltd. Vs CIT (Supreme Court)

Conclusion: The doctrine of mutuality bestows a special status to qualify for exemption from tax liability. It is a settled proposition of law that exemptions are to be put to strict interpretation. Asssessee having failed to fulfil the stipulations and to prove the existence of mutuality, the question of extending exemption from tax liability to assesse, that too at the cost of public exchequer, did not arise. Once it was conclusively determined that the assessee company had not operated as a

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