https://www.taxtmi.com/caselaws?id=71477 A bad and doubtful debt fund maintained through periodic ad hoc transfers, without earmarking against specific debts, was treated as a reserve rather than a provision for surtax computation, and was therefore includible in capital under the Companies (Profits) Surtax Act, 1964. The fund's character as a banking reserve, supported by the practice of writing off actual bad debts directly to profit and loss account, defeated the revenue's contrary classification. Rectification under section 13 was also invalid because the reserve-versus-provision issue was not a patent mistake apparent from the record; once the fund was held to be a reserve on its legal and factual character, there was no basis for rectification. en-us Tue, 09 Feb 1993 00:00:00 +0530 Mon, 25 Apr 2011 10:53:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=71477 A bad and doubtful debt fund maintained through periodic ad hoc transfers, without earmarking against specific debts, was treated as a reserve rather than a provision for surtax computation, and was therefore includible in capital under the Companies (Profits) Surtax Act, 1964. The fund's character as a banking reserve, supported by the practice of writing off actual bad debts directly to profit and loss account, defeated the revenue's contrary classification. Rectification under section 13 was also invalid because the reserve-versus-provision issue was not a patent mistake apparent from the record; once the fund was held to be a reserve on its legal and factual character, there was no basis for rectification. Case-Laws Income Tax Tue, 09 Feb 1993 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=71477