Development rebate--Allowance where reserve created is in excess of the statutory percentage.

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....-2-68 relating to computation of the capital of a company for the purposes of super profits tax, it was stated that a development rebate reserve which is either less than the statutory percentage [specified in section 10(2)(vib) of the Income-tax Act, 1922, and section 34(3) of the Income-tax Act, 1961] or, in excess of the prescribed percentage could not be said to have been created in compliance....