https://www.taxtmi.com/caselaws?id=12800 For surtax computation under the Companies (Profits) Surtax Act, 1964, a bad and doubtful debts item could be included in capital only if the amount in excess of what was reasonably necessary for that liability had in substance become a true reserve. The accounting label was not conclusive, and the character of the amount had to be determined on its real nature. An earlier assessment year did not operate as res judicata for the year under reference. On the facts, there was no material to show any identifiable excess or cessation of necessity, so the item could not be treated as part of the company's capital base. en-us Wed, 20 Feb 2002 00:00:00 +0530 Fri, 22 May 2009 11:04:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=12800 For surtax computation under the Companies (Profits) Surtax Act, 1964, a bad and doubtful debts item could be included in capital only if the amount in excess of what was reasonably necessary for that liability had in substance become a true reserve. The accounting label was not conclusive, and the character of the amount had to be determined on its real nature. An earlier assessment year did not operate as res judicata for the year under reference. On the facts, there was no material to show any identifiable excess or cessation of necessity, so the item could not be treated as part of the company's capital base. Case-Laws Income Tax Wed, 20 Feb 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=12800