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    <description>Amounts transferred to a statutory reserve fund under the Gujarat State Cooperative Societies Act are described as an appropriation of profits, not a diversion of income at source by overriding title, because the fund remains available for use in the business of the society. The text also states that such a transfer is not deductible as business expenditure under the Income-tax Act since it is not an actual outgoing incurred for business purposes but only a reserve appropriation. On that basis, the substantial questions of law were answered against the assessee and the tax appeals failed.</description>
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