https://www.taxtmi.com/caselaws?id=761659 Amounts set apart from accrued profits for a statutory reserve, where the assessee retains control and no diversion at source is shown, are treated as an appropriation of profits rather than a diversion of income by overriding title. The transfer was therefore not allowable as a deduction under the general computation provisions of the Income-tax Act, 1961. The same reserve was also includible in book profit under section 115JB because it was created out of profits and did not represent an ascertained liability, and no exclusion applied under the statutory computation scheme. en-us Mon, 04 Nov 2024 00:00:00 +0530 Tue, 10 Jun 2025 14:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761659 Amounts set apart from accrued profits for a statutory reserve, where the assessee retains control and no diversion at source is shown, are treated as an appropriation of profits rather than a diversion of income by overriding title. The transfer was therefore not allowable as a deduction under the general computation provisions of the Income-tax Act, 1961. The same reserve was also includible in book profit under section 115JB because it was created out of profits and did not represent an ascertained liability, and no exclusion applied under the statutory computation scheme. Case-Laws Income Tax Mon, 04 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761659