Investment of surplus in Bank – Interest/return on such investment not be covered by character of mutuality hence liable to tax.

When a mutual concern invests its surplus funds or makes deposit in bank, return or interest on such
investment/deposits will not be covered by character of mutuality and such an amount will be liable totax. (AY 1996‐97)
Dy.DIT v. Societe International De Telecommunication (2012) 139 ITD 328 (Mum)(Trib.)