https://www.taxtmi.com/caselaws?id=60345 Proposed dividend cannot remain part of the general reserve when computing capital base for surtax purposes, because it is an amount set apart for an identified allocation and must be excluded. The article also explains that a debenture stock redemption reserve is not automatically a provision; its character depends on substance and accountancy treatment. Where the sum is created out of surplus, shown as reserve, and not treated as a present charge against profits, it may retain the character of a reserve and be includible in capital base. The discussion applies these principles to distinguish reserve from provision under surtax computation. en-us Mon, 10 May 1982 00:00:00 +0530 Tue, 04 Jan 2011 17:31:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=60345 Proposed dividend cannot remain part of the general reserve when computing capital base for surtax purposes, because it is an amount set apart for an identified allocation and must be excluded. The article also explains that a debenture stock redemption reserve is not automatically a provision; its character depends on substance and accountancy treatment. Where the sum is created out of surplus, shown as reserve, and not treated as a present charge against profits, it may retain the character of a reserve and be includible in capital base. The discussion applies these principles to distinguish reserve from provision under surtax computation. Case-Laws Income Tax Mon, 10 May 1982 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=60345