https://www.taxtmi.com/caselaws?id=66458 For surtax computation, the true character of an appropriation must be determined from its substance, purpose and surrounding circumstances, not its accounting label. Quarry Land Amortisation Reserve was held to be a reserve because it was consistently shown as such, lacked any corresponding investment, had no uniform basis and was later written back; it was therefore included in the capital base and not treated as a sinking fund or provision. Development rebate reserve also continued to qualify as a reserve after expiry of the statutory eight-year period, because the basis for denying that treatment had ceased. en-us Mon, 30 Jul 1984 00:00:00 +0530 Thu, 24 Feb 2011 17:57:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=66458 For surtax computation, the true character of an appropriation must be determined from its substance, purpose and surrounding circumstances, not its accounting label. Quarry Land Amortisation Reserve was held to be a reserve because it was consistently shown as such, lacked any corresponding investment, had no uniform basis and was later written back; it was therefore included in the capital base and not treated as a sinking fund or provision. Development rebate reserve also continued to qualify as a reserve after expiry of the statutory eight-year period, because the basis for denying that treatment had ceased. Case-Laws Income Tax Mon, 30 Jul 1984 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=66458