https://www.taxtmi.com/caselaws?id=64907 Under rule 1(xi) of the First Schedule to the Companies (Profits) Surtax Act, statutory reserve transfers under clause (a) could not be duplicated under the general reserve deduction in clause (b); the two alternatives were mutually exclusive, so no deduction beyond the applicable higher amount was available. Contingency reserve, foreign exchange fluctuation reserve, and development reserve were treated as reserves, not provisions, because they were appropriations of profits for no existing liability, and they formed part of capital for surtax computation. Under rule 1(viii), dividend income was deductible on the gross dividend basis for the relevant year, as the later restrictive amendment was not retrospective. en-us Thu, 25 Jul 1985 00:00:00 +0530 Fri, 11 Feb 2011 11:06:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=64907 Under rule 1(xi) of the First Schedule to the Companies (Profits) Surtax Act, statutory reserve transfers under clause (a) could not be duplicated under the general reserve deduction in clause (b); the two alternatives were mutually exclusive, so no deduction beyond the applicable higher amount was available. Contingency reserve, foreign exchange fluctuation reserve, and development reserve were treated as reserves, not provisions, because they were appropriations of profits for no existing liability, and they formed part of capital for surtax computation. Under rule 1(viii), dividend income was deductible on the gross dividend basis for the relevant year, as the later restrictive amendment was not retrospective. Case-Laws Income Tax Thu, 25 Jul 1985 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=64907