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<h1>Court allows creation of development reserve before assessment, parties to bear own costs.</h1> <h3>Commissioner Of Income-Tax Versus Mutual Steel Industries</h3> Commissioner Of Income-Tax Versus Mutual Steel Industries - [1991] 187 ITR 292 The High Court of Bombay ruled in favor of the assessee regarding the creation of a development reserve before assessment, citing a previous decision in CIT v. Janardhan Zarapkar. The question referred by the Revenue was answered in the affirmative. Each party will bear their respective costs.