( 1 ) REVENUE is before us challenging the order of the Income Tax Appellate tribunal dtd 7-1-1999. The order of the Commissioner of Income Tax dtd 30-8-1991 on the following facts.

( 2 ) THE assessee is a club registered under the Societies Registration Act. It has several members. Four of its members are Vijaya Bank, Canara Bank, State Bank of Mysore, and State Bank of india. The club is running on commercial lines for the assessment year 1989-90. The assessee declared a total income of Rs. 2,26,991/ -. The assessee deposited a surplus amount of Rs. 76,16,054/- in Fixed Deposit with the above stated four banks. The Fixed Deposit earned an interest of Rs. 7,887,648/ -. This interest was claimed as deduction by the assessee on the principle of mutuality. It was stated that the four banks being members of a club constitute a common entity and that therefore tax could not be levied as it would amount to levying tax on oneself. The assessing authority did not accept the same and he disallowed the claim. An appeal was filed and the appellate commissioner set aside the order of assessment. A second appeal was filed and it stood rejected. It is in these circumstances, appellant is befor

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