Transfer fee & TDR premium not exempt on the ground of mutuality for Co-op Hsg Societies

Issue – The principal issue involved is tax ability or otherwise of sums received by the assessee, a residential housing co-operative society, by way of transfer fee and TDR premium. While the assessee claims the same as tax-exempt on the ground of mutuality, relying on the decision by the Tribunal in its own case for other years, as well as by the Honorable jurisdictional High Court, the Revenue bases its case on the factual findings issued by its authorities, as well as, again, on the same decisions by the hon’ble jurisdictional high court. Full Text of the Judgment is as follows :- ...