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    <title>1976 (11) TMI 48 - MADRAS High Court</title>
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    <description>A reserve is includible in capital under the Super Profits Tax Act unless it contains amounts already allowed as deductions in computing business profits; on that basis, a replanting, building and machinery reserve was treated as part of capital because no credited depreciation had been taken into the reserve. Interest received from a foreign-incorporated bank was not excludible from chargeable profits on the footing that the bank was an &quot;Indian concern&quot;, because that expression requires a substantive Indian nexus in ownership, management and control, not merely a branch or business presence in India. The material distinguishes &quot;Indian concern&quot; from the wider phrase &quot;concern in India&quot;.</description>
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    <pubDate>Mon, 01 Nov 1976 00:00:00 +0530</pubDate>
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      <title>1976 (11) TMI 48 - MADRAS High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=38708</link>
      <description>A reserve is includible in capital under the Super Profits Tax Act unless it contains amounts already allowed as deductions in computing business profits; on that basis, a replanting, building and machinery reserve was treated as part of capital because no credited depreciation had been taken into the reserve. Interest received from a foreign-incorporated bank was not excludible from chargeable profits on the footing that the bank was an &quot;Indian concern&quot;, because that expression requires a substantive Indian nexus in ownership, management and control, not merely a branch or business presence in India. The material distinguishes &quot;Indian concern&quot; from the wider phrase &quot;concern in India&quot;.</description>
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      <pubDate>Mon, 01 Nov 1976 00:00:00 +0530</pubDate>
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