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    <title>2023 (7) TMI 1141 - ITAT KOLKATA</title>
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    <description>Book-profit computation requires adjustments only within the items expressly permitted under section 115JB. Amounts transferred to a statutory special reserve remained taxable income and were includible in book profit because restricted use did not constitute diversion of income by overriding title. A contingent provision for standard assets was treated as an unascertained liability and included in book profit. Leave encashment and education cess deductions were disallowed. Receipts from transfers of voting and subscription rights were not taxable as capital gains where acquisition cost was indeterminable, while no taxable transfer of share-purchase rights arose in the relevant year. Disallowances relating to exempt-income investments and business investments were restricted or deleted where sufficient own funds existed, and a revised deduction claim was admitted in appellate proceedings.</description>
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      <link>https://www.taxtmi.com/caselaws?id=440868</link>
      <description>Book-profit computation requires adjustments only within the items expressly permitted under section 115JB. Amounts transferred to a statutory special reserve remained taxable income and were includible in book profit because restricted use did not constitute diversion of income by overriding title. A contingent provision for standard assets was treated as an unascertained liability and included in book profit. Leave encashment and education cess deductions were disallowed. Receipts from transfers of voting and subscription rights were not taxable as capital gains where acquisition cost was indeterminable, while no taxable transfer of share-purchase rights arose in the relevant year. Disallowances relating to exempt-income investments and business investments were restricted or deleted where sufficient own funds existed, and a revised deduction claim was admitted in appellate proceedings.</description>
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