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Revenue has raised the ground that on the basis of facts and circumstances of thecaseand in law, the Ld. CIT (A) has erred in holding that the activities of the assessee are charitable in nature and that assessee is eligible for exemption u/s. 11 of the I.T. Act, 1961 by ignoring the fact that principle of mutuality is not applicable incaseof the assessee as the contributions by members over & above Rs. 50,000/- become beneficiaries as per Section 13(3)(b) of the Act, 1961.

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Sec. 11 of Income Tax Act, 1961— Exemption — CIT(A) rightly observed that there is no sufficient reason to deviate from the appellate orders of the CIT(A) of the earlier years allowing the exemption u/s. 11(1) and accordingly, the AO was directed to allow the exemption u/s. 11(1) with all consequential benefits, which does not need any interference, hence, we uphold the action of the CIT(A) on the issue in dispute and reject the grounds raised by the Revenue - ASSTT. CIT V/s PHD CHAMBER OF COMMERCE AND INDUSTRY - [2020] 28 ITCD Online 079 (ITAT-DELHI)