YUM!RESTAURANTS (MARKET.) PVT.LTD. vs C.I.T.,NEW DELHI

The Supreme Court addressed the applicability of the doctrine of mutuality in the context of income tax for Yum! Restaurants (Marketing) Private Limited, a wholly owned subsidiary of Yum! Restaurants (India) Pvt. Ltd. The Court upheld the High Court's decision confirming the taxability of Rs. 44,44,002 for the Assessment Year 2001-02, ruling that the assessee did not qualify as a mutual concern and thus was not exempt from tax. The judgment emphasizes that the principles of mutuality do not apply as the contributions received were not for the benefit of individual contributors but for collective advertising and promotional activities.