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    <title>1975 (2) TMI 32 - ITAT COCHIN</title>
    <link>https://www.taxtmi.com/caselaws?id=62083</link>
    <description>Amounts appropriated out of taxed profits and shown in the balance-sheet as reserves were treated as reserves for capital base purposes where they were not earmarked against any existing accrued liability. The fund described as reserve for repayment of the I.F.C.I. loan existed before the loan was negotiated, was not used to meet instalments, and was later applied for bonus shares; it was therefore a general reserve, not a provision. The gratuity reserve was also a reserve because no gratuity scheme was in force and no accrued liability arose in the relevant year. The amounts had to be included in the capital base for super profits tax and surtax.</description>
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    <pubDate>Thu, 13 Feb 1975 00:00:00 +0530</pubDate>
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      <title>1975 (2) TMI 32 - ITAT COCHIN</title>
      <link>https://www.taxtmi.com/caselaws?id=62083</link>
      <description>Amounts appropriated out of taxed profits and shown in the balance-sheet as reserves were treated as reserves for capital base purposes where they were not earmarked against any existing accrued liability. The fund described as reserve for repayment of the I.F.C.I. loan existed before the loan was negotiated, was not used to meet instalments, and was later applied for bonus shares; it was therefore a general reserve, not a provision. The gratuity reserve was also a reserve because no gratuity scheme was in force and no accrued liability arose in the relevant year. The amounts had to be included in the capital base for super profits tax and surtax.</description>
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