https://www.taxtmi.com/caselaws?id=220237 The SC held that the appellant, an unincorporated AOP, could not claim exemption from income tax on interest earned from fixed deposits with certain banks under the doctrine of mutuality. The court found no complete identity between contributors and participators, as the funds were placed in fixed deposits and used by banks for commercial lending to third parties, breaking the closed circuit required for mutuality. The surplus funds were not applied towards the club's objects, nor was there a prohibition on profit derived from contributions, since banks profited by lending the deposits at higher rates to outsiders. Consequently, the interest earned did not satisfy the conditions of mutuality and was taxable. The HC's decision allowing the revenue's appeal was upheld. en-us Mon, 14 Jan 2013 00:00:00 +0530 Tue, 05 Aug 2025 16:55:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=220237 The SC held that the appellant, an unincorporated AOP, could not claim exemption from income tax on interest earned from fixed deposits with certain banks under the doctrine of mutuality. The court found no complete identity between contributors and participators, as the funds were placed in fixed deposits and used by banks for commercial lending to third parties, breaking the closed circuit required for mutuality. The surplus funds were not applied towards the club's objects, nor was there a prohibition on profit derived from contributions, since banks profited by lending the deposits at higher rates to outsiders. Consequently, the interest earned did not satisfy the conditions of mutuality and was taxable. The HC's decision allowing the revenue's appeal was upheld. Case-Laws Income Tax Mon, 14 Jan 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=220237