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The SC in CIT (Exemptions) v. IHC (2020) 424ITR325 following Delhi Gymkhana case ( 339ITR525) held that a registered society having members as contributories/beneficiaries and also holding registration u/s 12A is entitled to claim reliefs u/ss. 11, 12 and 13 in completeness without any requirement to display application of the mutuality principles. The SC distinguished their Bangalore club ( 350ITR509)  decision for the fact that the decision therein pertained to an unincorporated AOP not holding any 12A registration.

This ratio therefore affirms the understanding that even amounts earned by a society from non members like interest earned from banks etc. would not escape exemption provided it holds S. 12A charitable registration.

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