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Supreme Court of India 2019-10-03 allowed

State of West Bengal & Ors vs Calcutta Club Limited

Bench: 3 — R.F. Nariman

In Brief

This consolidated judgment addresses whether sales and service taxes apply to incorporated members' clubs. The Supreme Court held that the doctrine of mutuality—the principle that members of a club cannot be both buyers and sellers—continues to apply after the 46th Constitutional Amendment. The expression "body of persons" in Article 366(29-A) and the Finance Act does not include incorporated entities like companies or cooperative societies. Therefore, incorporated members' clubs remain exempt from both sales tax and service tax on supplies to their members. The landmark decision in Young Men's Indian Association (1970) remains binding law. Show-cause notices and tax demands against incorporated members' clubs were declared void.

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Constitutional Law Sales Tax Service Tax Clubs and Associations Doctrine of Mutuality Interpretation of Statutes Tax Exemptions

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