Development rebate eligibility requires conformity with judicial precedents; prior board guidance withdrawn and assessments to be revised. Allowance of the development rebate is limited to reserves that conform with the judicial tests set out in the cited Supreme Court and Gujarat High Court decisions; the Board's earlier circular of 14-10-1965 is withdrawn to the extent inconsistent. Income-tax officers are directed to complete pending assessments and review past assessments applying those judicial standards, and to take the same position in appeals to secure necessary disallowance, including by enhancement.
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Provisions expressly mentioned in the judgment/order text.
Development rebate eligibility requires conformity with judicial precedents; prior board guidance withdrawn and assessments to be revised.
Allowance of the development rebate is limited to reserves that conform with the judicial tests set out in the cited Supreme Court and Gujarat High Court decisions; the Board's earlier circular of 14-10-1965 is withdrawn to the extent inconsistent. Income-tax officers are directed to complete pending assessments and review past assessments applying those judicial standards, and to take the same position in appeals to secure necessary disallowance, including by enhancement.
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