COMMISSIONER OF INCOME TAX Vs. WILLINGDON SPORTS CLUB

JUDGEMENT

(1.) The Revenue has preferred this appeal on the following substantial questions of law:

(2.) A few facts may be set out:

(3.) The relevant assessment year is 1992-93. The respondent is governed by its rules and bye laws. Its members are described as gymkhana member, corporate member, short-term member all of whom are entitled to the advantages or privileges or membership of the club except that of being present or of voting at the general meetings of the club or of serving on the general committee and of proposing or seconding candidates for elections as members of the club. Apart from these members, there are life/founder/ordinary/super number members. The Assessing Officer pursuant to the return filed by the assessee, assessed the total income at Rs. 15,75,900.