Principle of mutuality: member to member surplus and contributions are exempt from tax when confined to mutual activities. The principle of mutuality exempts surplus arising from activities confined to members where contributors are the sole participators; incorporation does not destroy mutual identity and member contributions remain exempt even if excess income is invested, provided income arises from mutual activities and member to member transactions.
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Provisions expressly mentioned in the judgment/order text.
Principle of mutuality: member to member surplus and contributions are exempt from tax when confined to mutual activities.
The principle of mutuality exempts surplus arising from activities confined to members where contributors are the sole participators; incorporation does not destroy mutual identity and member contributions remain exempt even if excess income is invested, provided income arises from mutual activities and member to member transactions.
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