https://www.taxtmi.com/caselaws?id=7000 Exemption on the ground of mutuality applies only where there is complete identity between the contributors to a common fund and the persons participating in its surplus. The assessee, a public limited company carrying on business on terms comparable to an ordinary banking concern, failed that test because the contributors were not the same as the shareholders receiving the distribution. The return to shareholders was therefore not a mutual return of their own money in law. The income was held to constitute taxable business income and was not exempt from tax. en-us Fri, 23 Jun 1967 00:00:00 +0530 Sat, 07 Feb 2009 18:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7000 Exemption on the ground of mutuality applies only where there is complete identity between the contributors to a common fund and the persons participating in its surplus. The assessee, a public limited company carrying on business on terms comparable to an ordinary banking concern, failed that test because the contributors were not the same as the shareholders receiving the distribution. The return to shareholders was therefore not a mutual return of their own money in law. The income was held to constitute taxable business income and was not exempt from tax. Case-Laws Income Tax Fri, 23 Jun 1967 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7000