https://www.taxtmi.com/caselaws?id=5762 A sum set apart for redemption of preference shares was treated as a reserve, not expenditure in the commercial sense, so it could not be added back under rule 5(a) of the First Schedule to the Income-tax Act, 1961. The special accounting fiction in rule 2(2)(a) of the General Insurance Business (Nationalisation) Rules, 1973 allowed the item to be debited in accounts for that scheme alone, but it did not convert the reserve into taxable expenditure for computation under section 44. The nationalisation rules and the Income-tax Act operated in different fields, and the reserve remained outside the scope of add-back under the First Schedule. en-us Tue, 21 Sep 1999 00:00:00 +0530 Wed, 08 Oct 2025 20:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5762 A sum set apart for redemption of preference shares was treated as a reserve, not expenditure in the commercial sense, so it could not be added back under rule 5(a) of the First Schedule to the Income-tax Act, 1961. The special accounting fiction in rule 2(2)(a) of the General Insurance Business (Nationalisation) Rules, 1973 allowed the item to be debited in accounts for that scheme alone, but it did not convert the reserve into taxable expenditure for computation under section 44. The nationalisation rules and the Income-tax Act operated in different fields, and the reserve remained outside the scope of add-back under the First Schedule. Case-Laws Income Tax Tue, 21 Sep 1999 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5762