https://www.taxtmi.com/caselaws?id=28934 For surtax capital computation under the Second Schedule to the Companies (Profits) Surtax Act, 1964, the character of an amount depends on its substance, purpose, and surrounding circumstances, not its label. An amount created against doubtful debts is a provision if it reflects an anticipated non-recovery and is set aside to meet a known or expected liability; it is a reserve only if it is an appropriation of surplus profits as a free reserve. On the balance-sheet materials, the account was built up from transfers linked to doubtful debts and was not a free reserve. It was therefore a provision and excluded from the capital base for surtax. en-us Wed, 25 Nov 1981 00:00:00 +0530 Mon, 08 Mar 2010 17:11:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=28934 For surtax capital computation under the Second Schedule to the Companies (Profits) Surtax Act, 1964, the character of an amount depends on its substance, purpose, and surrounding circumstances, not its label. An amount created against doubtful debts is a provision if it reflects an anticipated non-recovery and is set aside to meet a known or expected liability; it is a reserve only if it is an appropriation of surplus profits as a free reserve. On the balance-sheet materials, the account was built up from transfers linked to doubtful debts and was not a free reserve. It was therefore a provision and excluded from the capital base for surtax. Case-Laws Income Tax Wed, 25 Nov 1981 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=28934