(F.M. IBRAHIM KALIFULLA, J.):

These appeals arise out of orders passed by the Income Tax Appellate Tribunal, Chennai in various Income Tax appeals preferred by M/s.Madras Gymkhana Club, M/s. Madras Club and M/s. The Coonoor Club.

2. The common question of law involved in these appeals are as to "whether the Tribunal was right in holding that the interest income of the assessee clubs received from its corporate members, on the investment of surplus funds as Fixed Deposits with them, is not exempted from tax on the concept of Mutuality". In some appeals, a further question of law as to "whether the Tribunal is right in holding that the re-opening of the assessment under Section 147 of the Income Tax Act was valid in respect of the assessee clubs".

3. As far as the first question is concerned, the activities of the clubs viz., Madras Gymkhana Club, Madras Club and The Coonoor Club is for the benefit of its members, in as much as, the club members are provided with various facilities such as Restaurant, Gymnasium, Library, Bar, Coffee Shop, Swimming Pool and other facilities for indoor and outdoor games such as Table Tennis, playing of Cards, Tennis Court etc., In so far a