https://www.taxtmi.com/caselaws?id=59276 Where a balance-sheet provision for taxation exceeds the assessee's final tax liability, the excess is to be treated as a reserve for capital computation under the surtax scheme, subject to factual determination of the overall excess, if any. The note states that the relevant test is whether a real provision existed on the relevant date and whether that provision overstated the liability. It also explains that a higher quantification of the same claim at appellate stage does not, by itself, make it a new ground; the controversy remains the same claim on excess provision over tax liability. en-us Fri, 20 Jul 1984 00:00:00 +0530 Wed, 25 Jan 2012 16:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59276 Where a balance-sheet provision for taxation exceeds the assessee's final tax liability, the excess is to be treated as a reserve for capital computation under the surtax scheme, subject to factual determination of the overall excess, if any. The note states that the relevant test is whether a real provision existed on the relevant date and whether that provision overstated the liability. It also explains that a higher quantification of the same claim at appellate stage does not, by itself, make it a new ground; the controversy remains the same claim on excess provision over tax liability. Case-Laws Income Tax Fri, 20 Jul 1984 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59276