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Supreme Court of India 2018-03-12

Income Tax Officer, Mumbai vs Venkatesh Premises Co-operative Society Ltd

Bench: 2 — Navin Sinha

In Brief

This consolidated appeal concerns whether cooperative housing and premises societies must pay income tax on receipts from members—including non-occupancy charges, transfer fees, and common amenity fund charges. The Court held that such receipts are exempt from tax under the doctrine of mutuality where there is commonality between contributors and beneficiaries and funds are used for common benefit. Transfer fees paid before membership admission are not taxable; admission triggers mutuality automatically. Non-occupancy charges and amenity fund contributions, though at varying rates, are exempt as they maintain common properties benefiting all members. The notification governing charges applies only to housing societies, not non-residential premises societies. All appeals by Revenue were dismissed and the assessee society's appeal allowed.", "disposition": "allowed", "citations": []} </invoke>

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Income Tax Cooperative Societies Doctrine of Mutuality Tax Exemption Constitutional Law Statutory Interpretation

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