Development rebate allowed where prescribed reserve was credited before assessment was completed, even through revised return entries.

The prescribed reserve for development rebate can be created by the relevant accounting entries at any time before completion of the assessment, including through entries in a revised return. The timing and manner of the reserve entry do not defeat the claim where the reserve is credited before assessment is completed. On that basis, the assessee was entitled to the development rebate.

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Issues: Whether the assessee was entitled to development rebate where the prescribed reserve was credited before completion of assessment, including by entries made in a revised return.

Analysis: The governing rule applied was that the reserve for development rebate may be created by making the necessary accounting entries at any time before the assessment is completed. Since the assessee had credited the reserve before completion of the assessment, the timing and manner of the entry did not defeat the claim.

Conclusion: The assessee was entitled to development rebate.

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