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    <title>1972 (8) TMI 29 - KERALA High Court</title>
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    <description>Retirement gratuity reserve was treated as a reserve, not a provision or current liability, for capital computation under the Companies (Profits) Surtax Act, 1964. The amount had not become an accrued liability or debt due in the accounting year; it was retained out of profits for future application. The balance-sheet explanation excluded current liabilities and provisions, but that exclusion did not apply because no present gratuity liability had arisen. The item had to be characterised by its substance rather than its accounting label, so it was includible in capital under rule 1 of the Second Schedule.</description>
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      <link>https://www.taxtmi.com/caselaws?id=8856</link>
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