https://www.taxtmi.com/caselaws?id=26883 Explanation 1 to Rule 2 of the Second Schedule to the Companies (Profits) Surtax Act, 1964 excludes reserves created by revaluation of book assets, but not a reserve reflecting a realised increase in asset value arising from devaluation-related gain. On the facts stated, the amount credited to reserve was not treated as a revaluation reserve and remained includible in the capital base. Rule 1(v) likewise applies broadly to moneys borrowed from any person in a country outside India; the term "person" was read with wide amplitude and was taken to include a foreign governmental department. The USAID loan was therefore includible in the capital base. en-us Tue, 06 Nov 1984 00:00:00 +0530 Tue, 09 Feb 2010 11:18:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=26883 Explanation 1 to Rule 2 of the Second Schedule to the Companies (Profits) Surtax Act, 1964 excludes reserves created by revaluation of book assets, but not a reserve reflecting a realised increase in asset value arising from devaluation-related gain. On the facts stated, the amount credited to reserve was not treated as a revaluation reserve and remained includible in the capital base. Rule 1(v) likewise applies broadly to moneys borrowed from any person in a country outside India; the term "person" was read with wide amplitude and was taken to include a foreign governmental department. The USAID loan was therefore includible in the capital base. Case-Laws Income Tax Tue, 06 Nov 1984 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=26883