https://www.taxtmi.com/caselaws?id=185138 A depreciation fund was held not to be a reserve representing accumulations of past profits under the first proviso to section 23A(1) of the Indian Income-tax Act, 1922. The proviso applies only to reserves in the balance-sheet that are accumulated profits capable of being brought within section 23A. Depreciation is a charge made in computing commercial profits and reflects estimated asset wear and tear, not profits set apart after ascertainment. On the facts, the fund arose from yearly depreciation entries, the assets remained shown at cost, and there was no evidence of excess depreciation being appropriated out of profits. The answer was therefore in the negative, in favour of the assessee. en-us Tue, 11 Apr 1961 00:00:00 +0530 Mon, 01 Aug 2016 17:45:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=185138 A depreciation fund was held not to be a reserve representing accumulations of past profits under the first proviso to section 23A(1) of the Indian Income-tax Act, 1922. The proviso applies only to reserves in the balance-sheet that are accumulated profits capable of being brought within section 23A. Depreciation is a charge made in computing commercial profits and reflects estimated asset wear and tear, not profits set apart after ascertainment. On the facts, the fund arose from yearly depreciation entries, the assets remained shown at cost, and there was no evidence of excess depreciation being appropriated out of profits. The answer was therefore in the negative, in favour of the assessee. Case-Laws Income Tax Tue, 11 Apr 1961 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=185138