DELHI STOCK EXCHANGE ASSOCIATION LTD. vs COMMISSIONER OF INCOME TAX, DELHI

The Supreme Court upheld the Punjab High Court's decision that the admission fees received by a stock exchange company from its members and authorized assistants are taxable income under the Income Tax Act. The Court clarified that the nature of the receipt, rather than its treatment in the company's books, determines taxability. It distinguished the company from a mutual society, emphasizing that the income was distributable among shareholders, thus lacking mutuality, and referred to the precedent set in Commissioner of Income-tax v. Calcutta Stock Exchange Association Ltd. (1959) 36 I.T.R. 222.