Doctrine of Mutuality

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.... contributors and the participants who are also beneficiaries. There has to be a complete identity between the contributors and the participants. Therefore, it follows, that any surplus in the common fund shall not constitute income but will only be an increase in the common fund meant to meet sudden eventualities. The principle of mutuality in the context of income tax law. The Privy Counci....

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....ubject. The Supreme Court held, as extracted below, that an exemption founded on the doctrine of mutuality could not be granted: ".................in the instant case there is no mutual dealing between the members 'inter se' and no putting up of a common fund for discharging the common obligations to each other undertaken by the contributors for their mutual benefit. On the contrary, we have her....