https://www.taxtmi.com/caselaws?id=12037 Mutuality applies only where there is complete identity between contributors to the common fund and participators in the surplus; membership alone is insufficient if interest income arises from lending to only some members while surplus is shared more broadly. On that basis, the interest income failed the mutuality test for the earlier years. A later amendment to the surplus-distribution rule could not be applied retrospectively to alter the tax character of completed transactions and operated only prospectively. Interest paid on members' deposits was allowable as business expenditure, and mutuality was recognised for the assessment year 1991-92 where complete identity was established. en-us Wed, 11 Sep 2002 00:00:00 +0530 Tue, 16 Feb 2010 12:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=12037 Mutuality applies only where there is complete identity between contributors to the common fund and participators in the surplus; membership alone is insufficient if interest income arises from lending to only some members while surplus is shared more broadly. On that basis, the interest income failed the mutuality test for the earlier years. A later amendment to the surplus-distribution rule could not be applied retrospectively to alter the tax character of completed transactions and operated only prospectively. Interest paid on members' deposits was allowable as business expenditure, and mutuality was recognised for the assessment year 1991-92 where complete identity was established. Case-Laws Income Tax Wed, 11 Sep 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=12037