After referring to various passages from the speeches of the different Law Lords in Styles ' case, Lord Normand, who delivered the judg ment of the Board, summarised the grounds of the decision in Styles ' case as follows: (1) ; 75 I.A. 196; 301 "From these quotations it appears that the exemption was based on (1) the identity of the contributors to the fund and the recipients from the fund, (2) the treatment of the company, though incorporated as a mere entity for the con venience of the members and policy holders, in other words, as an instrument obedient to their mandate and (3) the im possibility that contributors should derive profits from contributions made by themselves to a fund which could only be expended or returned to themselves." The Judicial Committee held that none of these grounds was available on the special facts of the case before them and, therefore, the principles laid down in Styles ' case (supra) were wholly inapplicable to that case.