https://www.taxtmi.com/caselaws?id=35908 For capital computation under rule 1 of the Second Schedule to the Companies (Profits) Surtax Act, 1964, an amount earmarked through a composite dividend arrangement could not be treated as a reserve merely because it was entered in a dividend reserve account. The court held that the character of the amount had to be tested on the relevant valuation date, and the surrounding corporate acts showed that the transfer, recommendation and declaration of dividend formed one integrated transaction intended for dividend distribution. On that basis, the amount was unavailable as reserve for capital computation, and the issue was decided against the assessee and in favour of the Revenue. en-us Fri, 23 Aug 1974 00:00:00 +0530 Wed, 17 Mar 2010 17:52:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=35908 For capital computation under rule 1 of the Second Schedule to the Companies (Profits) Surtax Act, 1964, an amount earmarked through a composite dividend arrangement could not be treated as a reserve merely because it was entered in a dividend reserve account. The court held that the character of the amount had to be tested on the relevant valuation date, and the surrounding corporate acts showed that the transfer, recommendation and declaration of dividend formed one integrated transaction intended for dividend distribution. On that basis, the amount was unavailable as reserve for capital computation, and the issue was decided against the assessee and in favour of the Revenue. Case-Laws Income Tax Fri, 23 Aug 1974 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=35908