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    <description>Deduction under section 80P(2)(a)(i) was found unavailable where a society operated with distinct classes of members and the test of mutuality failed. Loans were advanced to associate members who had no voting rights, no role in management and no entitlement to share in profits, while the surplus was distributed only to shareholding members. Because the contributors to the surplus and the participators in the surplus were not the same, the common character required for mutuality was absent. On that basis, the claim for deduction failed and the Revenue&#039;s position prevailed.</description>
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