https://www.taxtmi.com/caselaws?id=19398 For surtax computation under the Second Schedule to the Companies (Profits) Surtax Act, the true commercial character of an item determines whether it is a reserve or a provision, and that distinction governs inclusion in capital employed. Amounts described in the balance sheet as reserves must be assessed by substance, not label, while known liabilities such as unclaimed dividends are not converted into reserves by a mere book entry without a clear act of appropriation. The discussion also notes that deductions under Sections 80G and 80M of the Income-tax Act do not, by themselves, alter the surtax computation of capital employed in the manner argued by revenue. en-us Mon, 06 Dec 1993 00:00:00 +0530 Thu, 05 Nov 2009 18:25:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=19398 For surtax computation under the Second Schedule to the Companies (Profits) Surtax Act, the true commercial character of an item determines whether it is a reserve or a provision, and that distinction governs inclusion in capital employed. Amounts described in the balance sheet as reserves must be assessed by substance, not label, while known liabilities such as unclaimed dividends are not converted into reserves by a mere book entry without a clear act of appropriation. The discussion also notes that deductions under Sections 80G and 80M of the Income-tax Act do not, by themselves, alter the surtax computation of capital employed in the manner argued by revenue. Case-Laws Income Tax Mon, 06 Dec 1993 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=19398