Development rebate allowance: excess reserve creation does not by itself bar deduction where statutory reserve requirement is met. Development rebate deduction remains allowable where the credited development rebate reserve exceeds the statutory percentage because excess provisioning does not, by itself, violate the requirement to create a reserve equal to the prescribed percentage; the Board's earlier comment related only to treating such amounts as a 'reserve' for capital computation under rule 1 of the Second Schedule to the Super Profits Tax Act and not to denial of the rebate.
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Provisions expressly mentioned in the judgment/order text.
Development rebate allowance: excess reserve creation does not by itself bar deduction where statutory reserve requirement is met.
Development rebate deduction remains allowable where the credited development rebate reserve exceeds the statutory percentage because excess provisioning does not, by itself, violate the requirement to create a reserve equal to the prescribed percentage; the Board's earlier comment related only to treating such amounts as a "reserve" for capital computation under rule 1 of the Second Schedule to the Super Profits Tax Act and not to denial of the rebate.
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