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<h1>Court allows creation of development reserve before assessment, parties to bear own costs.</h1> The High Court of Bombay ruled in favor of the assessee, allowing the creation of a development reserve before assessment, following precedent from a ... Developement Rebate 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.