24 . In view of the aforesaid discussion, we think that we cannot accept the argument advanced by learned senior counsel, Sri Datar, for the following reasons : firstly, the order in Cawnpore Club is not on the basis of any reasoning or a deduction made as to whether on the interest earned on fixed deposits made by a club in a bank, Income-tax would be attracted or not. In the absence of any deduction or reasoning or analysis, the said order cannot carry precedential value so as to be binding on this court in a subsequent case. This is because there is no discernible ratio decidendi in the said order. Of course, the said order would bind the parties to the case. While carefully reading the order passed by this court in Cawnpore Club, it can be discerned that the High Court had clearly spelt out that in the case of income earned from letting out of rooms/property to its members, the same would not be subjected to tax. On the aforesaid aspect, the Revenue had not filed any appeal before this court, and therefore, on that aspect the matter should conclude in favour of the assessee therein, i. e., Cawnpore Club. Secondly, without going into the other aspects of the case, this court simply noted that the assessee therein (Cawnpore Club) could not be taxed on the principle of mutuality, therefore, it would not serve any purpose to proceed with the appeals on the other questions. What those other questions were has not been spelt out in the order nor have reasons been
