https://www.taxtmi.com/caselaws?id=276911 The principle of mutuality applies only where there is complete identity between the contributors to the common fund and the persons entitled to participate in the surplus. Here, the receipts came from a section of members who had obtained ration cards, while the intended benefit was for a different section of members who had not obtained such cards, so the contribution base and benefit group were not identical. The association's role as an intermediary and its obligation to apply the surplus in a specified manner did not alter the character of the receipts as income. The surplus was therefore taxable and not exempt under mutuality. en-us Wed, 23 Feb 1955 00:00:00 +0530 Tue, 20 Nov 2018 12:32:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276911 The principle of mutuality applies only where there is complete identity between the contributors to the common fund and the persons entitled to participate in the surplus. Here, the receipts came from a section of members who had obtained ration cards, while the intended benefit was for a different section of members who had not obtained such cards, so the contribution base and benefit group were not identical. The association's role as an intermediary and its obligation to apply the surplus in a specified manner did not alter the character of the receipts as income. The surplus was therefore taxable and not exempt under mutuality. Case-Laws Income Tax Wed, 23 Feb 1955 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276911