https://www.taxtmi.com/caselaws?id=288354 Surplus arising from pure mutual insurance transactions between an association and its members was not assessable to income tax under Section 31(1) of the Finance Act 1933. The House of Lords construed the provision as limited to surpluses from transactions of an incorporated company or society with its own members, and held that the statutory deeming language did not displace the mutuality principle. Because the contributors and participators in the common fund were identical, the surplus retained its character as the members' own money rather than taxable profit. Section 31(7) confirmed that "members" meant members of the incorporated body itself, not participants in a mutual scheme. en-us Fri, 29 Mar 1946 00:00:00 +0530 Tue, 02 Jun 2020 17:08:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=288354 Surplus arising from pure mutual insurance transactions between an association and its members was not assessable to income tax under Section 31(1) of the Finance Act 1933. The House of Lords construed the provision as limited to surpluses from transactions of an incorporated company or society with its own members, and held that the statutory deeming language did not displace the mutuality principle. Because the contributors and participators in the common fund were identical, the surplus retained its character as the members' own money rather than taxable profit. Section 31(7) confirmed that "members" meant members of the incorporated body itself, not participants in a mutual scheme. Case-Laws Income Tax Fri, 29 Mar 1946 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=288354