https://www.taxtmi.com/caselaws?id=35879 A union claiming tax exemption failed the mutuality test because complete identity between contributors and participants in the common fund was absent; outsiders contributed and members who had not contributed could still share in the surplus, so the income was not exempt on that basis. Exemption under section 11 of the Income-tax Act, 1961 also failed because the governing constitution permitted surplus funds, after liabilities, to be distributed among members on dissolution, showing an element of private gain and negating an obligation to hold the income wholly for charitable purposes. Both questions were answered against the assessee and the revenue's tax claim was sustained. en-us Mon, 02 Feb 1981 00:00:00 +0530 Wed, 17 Mar 2010 15:35:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=35879 A union claiming tax exemption failed the mutuality test because complete identity between contributors and participants in the common fund was absent; outsiders contributed and members who had not contributed could still share in the surplus, so the income was not exempt on that basis. Exemption under section 11 of the Income-tax Act, 1961 also failed because the governing constitution permitted surplus funds, after liabilities, to be distributed among members on dissolution, showing an element of private gain and negating an obligation to hold the income wholly for charitable purposes. Both questions were answered against the assessee and the revenue's tax claim was sustained. Case-Laws Income Tax Mon, 02 Feb 1981 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=35879