https://www.taxtmi.com/caselaws?id=168400 The Privy Council HC held that a co-operative society incorporated under the Industrial and Provident Societies Act 1893 was not exempt from Assam agricultural income-tax on profits from selling tea cultivated at its estate to members. The court rejected the mutuality principle defense, finding that the society's business structure was capable of generating taxable profits despite sales being exclusively to members. The society's rules contemplated profit-making and provided for net profit application similar to trading companies. The HC judgment was varied to confirm the society's tax liability, and the appeal was dismissed. en-us Tue, 27 Apr 1948 00:00:00 +0530 Wed, 09 Jul 2025 12:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=168400 The Privy Council HC held that a co-operative society incorporated under the Industrial and Provident Societies Act 1893 was not exempt from Assam agricultural income-tax on profits from selling tea cultivated at its estate to members. The court rejected the mutuality principle defense, finding that the society's business structure was capable of generating taxable profits despite sales being exclusively to members. The society's rules contemplated profit-making and provided for net profit application similar to trading companies. The HC judgment was varied to confirm the society's tax liability, and the appeal was dismissed. Case-Laws Income Tax Tue, 27 Apr 1948 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=168400