https://www.taxtmi.com/caselaws?id=20738 Amounts set apart by a banking company for bad and doubtful debts were treated as provisions, not reserves, because the true character of the allocation depends on the liability it is meant to meet, not the label used in the balance-sheet. Since anticipated bad debt risk is a foreseeable business liability in banking, the sums were not deductible as a reserve under the First Schedule and were also not includible as reserve capital under the Second Schedule. The earlier non-banking-company precedent was distinguished on its different factual and commercial setting, and the surtax computation was therefore to proceed on the basis that the amounts were provisions. en-us Mon, 27 Jul 1992 00:00:00 +0530 Mon, 16 Nov 2009 18:45:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=20738 Amounts set apart by a banking company for bad and doubtful debts were treated as provisions, not reserves, because the true character of the allocation depends on the liability it is meant to meet, not the label used in the balance-sheet. Since anticipated bad debt risk is a foreseeable business liability in banking, the sums were not deductible as a reserve under the First Schedule and were also not includible as reserve capital under the Second Schedule. The earlier non-banking-company precedent was distinguished on its different factual and commercial setting, and the surtax computation was therefore to proceed on the basis that the amounts were provisions. Case-Laws Income Tax Mon, 27 Jul 1992 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=20738