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The ITAT Madras-C upheld the CIT(A)'s finding that the assessee is a mutual fund not liable to income tax for the assessment years 1980-81, 1981-82, and 1982-83. The principle of mutuality was satisfied as dividends were paid only to shareholders with transactions, not to outsiders. The departmental appeals were dismissed. (Case citation: 1989 (5) TMI 154 - ITAT MADRAS-C)
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