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Issues: Whether the amount representing the contingency reserve formed part of the commercial profit or real income of the assessee and was includible in its total assessable income for the assessment years 1971-72 and 1972-73.
Analysis: The question had already been concluded by earlier Division Bench decisions involving the same assessee. Following those decisions, the amount credited to contingency reserve was treated as not constituting commercial profit or real income and therefore not chargeable to tax as part of the assessee's total income.
Conclusion: The issue was answered against the Revenue and in favour of the assessee. The Tribunal was held to be correct in excluding the contingency reserve from the assessee's assessable income.
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