https://www.taxtmi.com/caselaws?id=38951 For surtax capital computation, a balance retained in a dividend equalisation reserve is treated as a true reserve where it represents appropriation of profits kept available for future years, and may be included in capital. By contrast, an amount earmarked for payment of dividend is a provision or current liability and is excluded from reserves under the statutory Explanation. The analysis turns on the commercial distinction between reserve and provision, and on the character of the amount as retained surplus or proposed dividend rather than its label. en-us Wed, 28 Jul 1976 00:00:00 +0530 Sat, 10 Apr 2010 14:36:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38951 For surtax capital computation, a balance retained in a dividend equalisation reserve is treated as a true reserve where it represents appropriation of profits kept available for future years, and may be included in capital. By contrast, an amount earmarked for payment of dividend is a provision or current liability and is excluded from reserves under the statutory Explanation. The analysis turns on the commercial distinction between reserve and provision, and on the character of the amount as retained surplus or proposed dividend rather than its label. Case-Laws Income Tax Wed, 28 Jul 1976 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38951