https://www.taxtmi.com/caselaws?id=38752 For surtax computation, capital is determined with reference to the first day of the previous year, and only amounts retaining the character of reserve on that date are includible. A proposed dividend does not create a liability until shareholder approval, so the accumulated balance in the dividend equalisation reserve remained a reserve and was includible in capital on 1 November 1964. By contrast, amounts appropriated from current profits for proposed dividend payment were set apart for a liability and were not available as reserve for capital computation on that date. en-us Thu, 29 Jul 1976 00:00:00 +0530 Thu, 08 Apr 2010 17:32:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38752 For surtax computation, capital is determined with reference to the first day of the previous year, and only amounts retaining the character of reserve on that date are includible. A proposed dividend does not create a liability until shareholder approval, so the accumulated balance in the dividend equalisation reserve remained a reserve and was includible in capital on 1 November 1964. By contrast, amounts appropriated from current profits for proposed dividend payment were set apart for a liability and were not available as reserve for capital computation on that date. Case-Laws Income Tax Thu, 29 Jul 1976 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38752