As per case facts the Bangalore Club established many years ago faced tax demands for wealth tax The assessing officer determined that the club's members had rights beyond mere usage ... and that the club's assets belonged to them making it liable for wealth tax due to uncertain membership and dissolution dates This decision was upheld on appeal The question arose whether the Bangalore Club was liable to pay wealth tax Finally the Supreme Court noted the club's objects which were social and for the benefit of its members and considered the fixed list of members on the date of liquidation to determine that the members would be determinate implying that the Wealth Tax Act section might not apply