https://www.taxtmi.com/caselaws?id=168400 The doctrine of mutuality applies only where contributors to a common fund and participators in that fund are identical, and the association merely returns members' own contributions. A co-operative society that owned tea land, grew and manufactured tea, sold it at market rates to members, and treated the surplus as trading profit did not satisfy that test. Member purchases did not eliminate the presence of real trading receipts, and member advances were treated as loans rather than mutual contributions. The claimed exemption therefore failed, and the society remained liable to Assam agricultural income-tax on profits from the tea sales. 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 doctrine of mutuality applies only where contributors to a common fund and participators in that fund are identical, and the association merely returns members' own contributions. A co-operative society that owned tea land, grew and manufactured tea, sold it at market rates to members, and treated the surplus as trading profit did not satisfy that test. Member purchases did not eliminate the presence of real trading receipts, and member advances were treated as loans rather than mutual contributions. The claimed exemption therefore failed, and the society remained liable to Assam agricultural income-tax on profits from the tea sales. Case-Laws Income Tax Tue, 27 Apr 1948 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=168400