Incidental revenue generating activities do not end the principle of mutuality

Simply because some incidental activity of the assessee is revenue generating, does not provide any justification to hold that it is tainted with “commerciality” and reaches a point where relationship of mutuality ends and that of trading begins. RELEVANT PARAGRAPH 19. In the present case, as already noted above, the respondent is incorporated as a society and the main objective is to improve the purpose of public enterprises. The membership of the society is open to public sector enterprises of Central/State Governments. It is, thus, performed for the benefit of its members, which...