https://www.taxtmi.com/caselaws?id=27659 For surtax capital computation, the substance of an appropriation determines whether it is a reserve or a provision. Amounts set apart for a reasonably anticipated future contingency, and not earmarked for any known liability, may be treated as reserves and included in capital. On the facts, the development and contingency reserve was held to have the character of a general reserve. Excess depreciation separately reflected in the accounts was also treated as a reserve, not a secret reserve or revaluation item, because no asset revaluation was shown and the entry was not tied to a known liability. en-us Mon, 12 Mar 1984 00:00:00 +0530 Mon, 15 Feb 2010 12:24:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=27659 For surtax capital computation, the substance of an appropriation determines whether it is a reserve or a provision. Amounts set apart for a reasonably anticipated future contingency, and not earmarked for any known liability, may be treated as reserves and included in capital. On the facts, the development and contingency reserve was held to have the character of a general reserve. Excess depreciation separately reflected in the accounts was also treated as a reserve, not a secret reserve or revaluation item, because no asset revaluation was shown and the entry was not tied to a known liability. Case-Laws Income Tax Mon, 12 Mar 1984 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=27659