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    <description>Transfer fees received by cooperative housing societies from members were treated as mutual contributions, not taxable income, where they were collected under the bye-laws and statutory framework for common society purposes and did not arise from a commercial venture. Mutuality was held to depend on an identifiable class of contributors and participators with control over the surplus, not on each member contributing or receiving the same amount. Any sum collected beyond what the bye-laws or applicable government directions permit was characterised as refundable excess and, if retained, could be taxable to that extent.</description>
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      <link>https://www.taxtmi.com/caselaws?id=34176</link>
      <description>Transfer fees received by cooperative housing societies from members were treated as mutual contributions, not taxable income, where they were collected under the bye-laws and statutory framework for common society purposes and did not arise from a commercial venture. Mutuality was held to depend on an identifiable class of contributors and participators with control over the surplus, not on each member contributing or receiving the same amount. Any sum collected beyond what the bye-laws or applicable government directions permit was characterised as refundable excess and, if retained, could be taxable to that extent.</description>
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